NC0020389_Moratorium Response_20210322

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JERRY M. MEDLIN TOWN MANAGER
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MAYOR PRO-TEM 7 Tat CASANDRA P.STACK `$� ASSISTANT TOWN MANAGER
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COMMISSIONER
MAXINE HOLLEY TOWN OF BENSON TOWN CLERK
JAMES D.JOHNSON ANGELA THORNTON
DEAN MCLAMB P.O. BOX 69
WILLIAM NEIGHBORS 303 EAST CHURCH STREET TOWN ATTORNEY
DR. R. MAX RAYNOR BENSON, NC 27504 R. ISAAC PARKER
[phone]
FAX[phone]
www.fownofbenson.corn
March 15, 2021
RECEIVED
Ms.Sydney Carpenter MAR 2 2 2021
NC Division of Water Resources
NPDES Wastewater Permitting
1617 Mail Service Center NCDEC IDWRINPDES
Raleigh, NC 27699-1617
RE: Notification of 80%Threshold Exceedance of Permitted Treatment Capacity
Town,of Benson, North Carolina—NPDES No. 0020389
Dear Ms. Carpenter:
We are notifying you that the Town of Benson recognizes that the 12-month average daily flows at the Town's
Wastewater Treatment Plant (WWTP) have now exceeded beyond 80%of the permitted 1.9 MGD capacity.
The average flow between January 2020 and December 2020 was recorded as 1.57 MGD, or 82%of the
permitted capacity, notably jumping almost 17%in 2020 over 2019.This increase is likely due to a ramp up in
production from Berry Global in response to the Covid-19 Pandemic and above average rainfall totals.
Therefore, per the North Carolina Code 15A NCAC 02T.0118, "Demonstration of Future Wastewater
Treatment Capacities",the Town of Benson has begun the process of developing an Engineering Alternatives
Analysis(EAA).The Town has contacted an engineering consultant to complete a scope of work and timeline
for the completion of the EAA. We expect that this process will begin in earnest within the next month.The
EAA will evaluate disposal alternatives in accordance with guidance documents posted on the NPDES
Wastewater Permitting group website.
In addition to the development of the EAA,the Town is currently involved in several projects that will evaluate
and address unwarranted flows to the WWTP. In February,the Town received notification that it was awarded
a Merger and Regionalization Feasibility(MRF) grant to evaluate the potential for a regional system with the
City of Dunn.Among the goals of this study, it will look at disposal options for the Town's wastewater, and thus
may provide an option for capacity to be increased at the WWTP.This will essentially compliment the overall
EAA.Additionally,the Town was awarded a CWSRF loan to correct some areas of deficiency within the
collection system.These areas have been identified in the Town's 2018 Wastewater Assessment Management
Plan as critical and are considered top priority improvement projects.The criticality of these areas is due to
crucial deficiencies in the aged piping and manholes which has led to significant I/I influence into the system.
The purpose of the funding is to rehabilitate and replace these critical gravity sewer segments,which is
anticipated to reduce considerable I/I flow to the WWTP. Lastly,the Town has applied for CDBG grant funding

as well.The decision about this funding application will be made in April. If awarded,these grant funds would
make additional improvements to the collection system (i.e., reduce rainwater intrusion and help reduce the
plant flows).
Additionally,the Town is currently studying the feasibility of redirecting a large volume of flow from the
Chicopee Rd. Lift Station sewer sub-basin.This station pumps collected wastewater into a shared forcemain
with the Town's only SIU, Berry Global. Due to growth in the area, and production increases from Berry Global,
the pumping capacity of the Chicopee Rd.station is greatly diminished when both the station and Berry Global
are pumping at the same time.To alleviate this,the Town is evaluating the construction of new gravity sewer
to eliminate the lift station,thus allowing Berry Global to be the sole user of the existing forcemain.The new
gravity sewer will be routed to a new pump station and force main.This initiative further displays Benson's
commitment to correcting system deficiencies and investment in the long-term benefits of the community.
Based on the current activities of the Town and the previously listed projects in progress,we respectfully
request the Director.(per 15A NCAC 02T.0118 (3)) allow for the continued issuance of permits to the Benson
WWTP and that the Town be allowed to continue to accept flow from new developments while the EAA is
being produced. Specifically,the Town was notified that a 12-lot subdivision would not be permitted due to
the flows tripping the 80/90 rule threshold. It is approximated that this subdivision would only add 4,500 gpd,
which the plant still has available treatment capacity to handle. Our concern is that, if we are unable to allow
for this small development to be permitted,then it could lead to other developers to consider other locations
for their planned investments.The economic surge that is currently being experienced in North Carolina has
led the Town of Benson to be an ideal locale for both the private and public sector,which has become evident
due to Town officials having been recently approached by these entities seeking investment in the area.
Therefore,we are requesting that this 12-lot subdivision be permitted to move forward, as well as
consideration for similar future developments.
We expect the EAA should be completed in a timely manner due to a study which was completed in 2007 that
evaluated multiple alternatives for treatment of flows beyond the capacity of the plant.This study,which does
require an update,will serve as a guide during the EAA. Furthermore,the Benson WWTP has also been in
compliance with all permit limitations and requirements, and adequate progress is being made to reduce
extraneous flows in the system. It should also be noted that the Town has employed key staff members which
have made significant strides over the past few years to optimize the operations of the facility,which the State
recently recognized by granting reduced monitoring. It is not anticipated that flows due to any new growth or
developments will result in the exceedance of the plant's permitted hydraulic capacity while the EAA is being
completed. Once our consultants have provided us with a scope and timeline for the development of this
document, we will inform your office of our expectation for submittal and review.
We trust this information is sufficient for your consideration; however, if you should need any additional
information or have any questions, please do not hesitate to contact us.
Sincerely,
I—
Tim Robbins
Director of Public Works and Utilities
Jerry Medlin Fred Nelson
Mayor Town Manager