NC0020389_Permit Modification_20040212

Mr. Keith Langdon
Town of Benson
P.O. Box 69
Benson, North Carolina 27504
Michael F. Easley, Governor
State of North Carolina
William G. Ross, Jr., Secretary
Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
February 12, 2004
Subject: Minor Modification of NPDES Permit
Permit No. NC0020389
Town of Benson WWTP
Johnston County
Dear Mr. Langdon:
The Division of Water Quality's NPDES Unit has reviewed the Town of Benson's request to remove
Special Condition A.(5), Additional Upstream Monitoring Requirements, from its NPDES permit for the
Benson WWTP. In his letter of February 5, Mr. Marty Morris, WWTP Superintendent, indicated that
this function is now being performed as part of the Lower Neuse Basin Association's approved
monitoring schedule. Therefore, we are approving the Town's request and are enclosing the modified
pages of its NPDES permit. Please insert the revised pages into your permit and discard the old versions
being replaced.
All other terms and conditions contained in the original permit, issued September 24, 2003, are
unchanged and remain in full effect. This permit modification is issued pursuant to the requirements of
North Carolina General Statutes 143-215.1 and the Memorandum of Agreement between North
Carolina and the U.S. Environmental Protection Agency.
If any parts, measurement frequencies or sampling requirements contained in this permit modification
are unacceptable to you, you have the right to an adjudicatory hearing upon written request within thirty
(30) days following receipt of this letter. This request must be a written petition conforming to Chapter
150B of the North Carolina General Statutes, filed with the Office of Administrative Hearings, Post
Office Drawer 27447, Raleigh, North Carolina 27611-7447. Unless such demand is made, this decision
shall be final and binding.
If you have any questions concerning the final permit or the requirements for your facility, please contact
Mike Templeton at [phone], extension 541, or at [e-mail].
Sincerely,
Alan W. Klimek, P.E.
Y Director
Enclosures: Permit NC0020389
cc (w/ encl.): EPA Region IV, Permits Section
Raleigh Regional Office / Water Quality
Point Source Compliance Enforcement Unit
Technical Assistance and Certification Unit
NPDES Unit Files
Central Files
cc (w/oencl.): Lauren Elmore, Coalition Coordinator, ESB
North Carolina Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
[phone]
FAX [phone]
On the Internet at http://h2o.enr,state.nc.us/

Permit NC0020389
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized
to discharge 1.5 MGD of municipal wastewater from outfall 001. Such discharges shall be limited and monitored by
the Permittee as specified below:
EFI=LUENT
CHARACTERISTICS.
••
LIMITS'
MONITORING REQUIREMENTS
,:Monthly
Average e g �
Weekly .
Average_ �
Daily
Maximum '
Measurement,
� Frequency ,
Sample .
, • Type, , .
Sample
; Lactation
Flow
1.5 MGD
Continuous
Recording
Influent or Effluent
Total Monthly Flow (MG)
Monitor
and Report
Monthly
Recorded or
Calculated
Effluent
BOD, 5 day (209C)2 [April 1—October 31]
5.0 mg/I
7.5 mg/I
Daily
Composite
Influent & Effluent
BOD, 5 day (20°C)2 [November 1—March 31]
10.0 mg/I
15.0 mg/I
Daily
Composite
Influent & Effluent
Total Suspended Solids2
30.0 mg/1
45.0 mg/I
Daily
Composite
Influent & Effluent
NH3 as N [April 1— October 31 ]
2.0 mg/I
6.0 mg/I
Daily
Composite
Effluent
NH3 as N [November 1— March 31]
4.0 mg/I
12.0 mg/I
Daily
Composite
Effluent
Dissolved Oxygen3
Daily
Grab
Effluent
Dissolved Oxygen
Variable'
Grab
U& D
Fecal Coliforrn (geometric mean)
200/100 ml
400/100 ml
Daily
Grab
Effluent
Fecal Coliform (geometric mean)
Variable'
Grab
U& D
Total Residual Chlorine
17 µg/L4
Daily
Grab
Effluent
TKN (mg/L)5
Monitor and Report
Weekly
Composite
Effluent
NO2 + NO3 (mg/L)5
Monitor and Report
Weekly
Composite
Effluent
Total Nitrogen (mg/L)5
Monitor and Report
Weekly
Composite
Effluent
6
Total Nitrogen Load
Monitor and Report (pounds/month)
Monthly
Calculated
Effluent
33,790 pounds/year
Annually
Calculated
Effluent
Total Phosphorus'
2.0 mg/L (Quarterly Average)
Weekly
Composite
Effluent
Temperature (9C)
Daily
Grab
Effluent
Temperature (°C)
.
Variable'
Grab
U& D
Conductivity
Daily
Grab
Effluent
Conductivity
Variable'
Grab
U& D
Chronic Toxicity5
Quarterly
Composite
Effluent
Total Chromium
50 µg/I
1,022 µg/I
Weekly
Composite
Effluent
Total Nickel
88 µg/I
261 µg/I
Weekly
Composite
• Effluent
Total Mercury
0.012 µg/I
Weekly
Composite
Effluent
Total Copper
2/Month
Composite
Effluent
Total Zinc
2/Month
Composite
Effluent
pH9
6-9 standard units
Daily
Grab
Effluent
Footnotes:
1.
U: Upstream at the culvert on NCSR 1158. D: Downstream at (1) NCSR 1227 and (2) I-95 culvert. Stream samples shall be
grab samples collected 3/Week from June to September and 1/Week during the remaining months of the year. Instream
monitoring is provisionally waived in light of the Permittee's participation in the Lower Neuse Basin Association.
Instream monitoring shall be conducted as stated in this permit should the Permittee end its participation in the
Association.
2. The monthly average effluent BOD5 and Total Suspended Residue concentrations shall not exceed 15% of the respective
influent value (85% removal).
3. The daily average dissolved oxygen effluent concentration shall not be less than 6.0 mg/l.
4. Total Residual Chlorine lirnit takes effect May 1, 2005. See condition A. (6).
5. For a given wastewater sample, Total Nitrogen = TKN + NO3-N + NO2-N where TKN is Total Kjeldahl Nitrogen, and NO3-
N and NO2-N are Nitrate and Nitrite Nitrogen, respectively.
6. Total Nitrogen Load is the mass quantity of Total Nitrogen discharged in a given period of time. See A. (3). The annual TN
Load limit shall become effective with the calendar year beginning on January 1, 2003. Compliance with this limit shall be
determined in accordance with condition A. (4), Annual Limits for Total Nitrogen.
Modified 3/ 1 /2004

Permit NC0020389'
ii. Association roster(s) and members' TN allocations will be updated annually
and in accordance with state and federal program requirements.
iii. If the Permittee intends to join or leave a compliance association, the Division
must be notified of the proposed action in accordance with the procedures
defined in the association's NPDES permit.
(1) Upon receipt of timely and proper notification, the Division will modify the
permit as appropriate and in accordance with state and federal program
requirements.
(2) Membership changes in a compliance association become effective on
January 1 of the year following modification of the association's permit.
The TN monitoring and reporting requirements in this Permit remain in effect until expiration
of this Permit and are not affected by the Permittee's membership in a compliance association.
A. (5) ADDITIONAL UPSTREAM MONITORING REQUIREMENTS
[Deleted]
A. (6) TOTAL RESIDUAL CHLORINE COMPLIANCE SCHEDULE
The limit for total residual chlorine shall become effective upon completion of the installation
of a disinfection system but no later than May 1, 2005. If a method different than
chlorination/dechlorination is used, the total residual chlorine limit will not be applicable.
A. (7) LAGOON FREEBOARD HEIGHT REQUIREMENT
A minimum of 2 feet of freeboard height must be maintained in the lagoons (currently used
for equalization/sludge holding). A staff gauge must be placed in each lagoon and the height
recorded daily.
Modified 3/ 1 /2004

Re: benson request
Subject: Re: benson request
From: Lauren Elmore <[e-mail]>
Date: Thu, 12 Feb 2004 11:07:43 -0500
To: Mike Templeton <[e-mail]>
Mike,
I'll update the marker files in the Coalition Program folder on the shared WQ drive today and add the new LNBA MOA. I'll
attach a copy of the new LNBA MOA to this email. Benson is continuing their participation in the Lower Neuse Basin
Association. At DWQ's request the LNBA added a monitoring station upstream of the Benson discharge to their new MOA.
Benson related sampling in the current MOA (effective February 1, 2004):
• The upstream monitoring location is at SR 1158 (Aliens Crossroads Dr.)
• The downstream monitoring location is just downstream of 1-95 at SR 1227 (Ivey Rd.) not SR1171 which is ups of
195. 1 conducted a site visit in December .
• Parameters monitored monthly at both these stations include: DO, pH, temp, conductivity, NH3, TKN, NO2/NO3, TP,
Turbidity, TSS, and Fecal Coliform. The field parameters (DO, pH, Temperature, and conductivity) are measured
twice monthly in May, June, July, August, and September.
Let me know if you have any remaining questions.
Thanks!
Lauren
Mike Templeton wrote:
Hi, Lauren - Marty Morris, the Benson WWTP supt., has requested that we delete that upstream monitoring we added to
their permit. They indicate that they will begin monitoring Hannah Creek this month and are still participating in the LNBA. I
just need you to verify that this monitoring is being picked up by the LNBA (through the MOA?) and that you are satisfied
with the arrangement. Here are the details from his letter:
• location: upstream of their discharge at SR 1158 - Allen's Crossroads and downstream at SR 1227 (or is it SR
1171?) - Ivey Rd.
• parameters: DO, temperature, pH, conductivity
• frequency: 2/month, May -Sep
Thanks.
- Mike T
Lauren Elmore
Coalition Coordinator
North Carolina Division of Water Quality
Environmental Sciences Branch
Phone: [phone]
Fax: [phone]
Mailing Address:
1621 Mail Service Center
Raleigh, NC 27699-1621
Location:
4407 Reedy Creek Road
Raleigh, NC 27607
1 of 1 2/12/2004 11:49 AM

MAYOR
DON H. JOHNSON
COMMISSIONER
FREDRICK D. NELSON, JR.
J.W. PARRISH, JR.
JACK R. LITTLETON
CASANDRA P. STACK
LINDELL NORDAN
RAY G. SMITH
FEBURARY 5 2004
TOWN OF BENSON
Mr. Mike Templeton
NCDENR-DWQ-NPDES Unit
1617 Mail Services Center
Raleigh, N.0 27699-1617
Subject: Permit Modification
Permit NC0020389
Town of Benson WWTP
Johnston County
Dear Mr. Templeton,
P.O. BOX 69
303 EAST CHURCH STREET
NORTH CAROLINA
27504
[phone]
FAX [phone]
TOWN MANAGER
KEITH R. LANGDON
TOWN CLERK
CONNIE M. SORRELL
FINANCE OFFICER
DONNA M. HONEYCUTT
TAX COLLECTOR
ROSALIE G. WEST
TOWN ATTORNEY
DONALD A. PARKER
The Town of Benson is filing a request that Special Condition A(5.), Additional Upstream
Monitoring Requirements, be modified from, "the Permitee is required to perform year- round
upstream monitoring", and allow the upstream monitoring to be waived in light of the Permitee's
participation in the Lower Neuse Basin Association (LNBA).
The LNBA will start monitoring the following Hannah Creek stations starting in February 2004:
SR 1158 Allen's Crossroads (upstream)
SR 1227 Ivey Rd (Downstream)
The following parameters will be collected monthly at these stations: Dissolved Oxygen (DO)
Temperature, pH, and Conductivity, these 4 parameters will be collected twice a month in May, June,
July, August, and September. Also the Downstream SR is incorrect it is SR 1171.
If you should have any comments and/or questions please contact me at [phone].
SINCE
Marty Morris
WWTP Superintendent
C:\My Documents \Old_does \TOWN FILES \wwtp\Mike Templeton-npdes-2-6-2004.doc

Benson
Subject: Benson
From: Susan Wilson <[e-mail]>
Date: Wed, 03 Dec 2003 14:01:45 -0500
To: Jay Sauber <[e-mail]>, Lauren Elmore <[e-mail]>
CC: Dave Goodrich <[e-mail]>, Mike Templeton
<Mike.Templeton@ncmail. net>
OK - I've had some serious computer snafu's the last couple of days, so I had trouble even
looking up the permit number for Benson! But, I have pulled it now and looked over the
permit language and the cover letter for Benson. I'm not sure what you were getting at Jay,
but the penult specifically states (fortunately or unfortunately) that the upstream
monitoring is not waived under the LNBA participation (and this is more specifically stated
in Condition A.(5.) of the permit). I'm sure you guys know why this was done (we had no
way to evaluate the impact of the discharge because there was no upstream site; we've
discussed this before re. the lapse we have for localized impacts.) However, we appreciate
the reliability of the coalition data and don't want to thwart that effort. Likely, Natalie was
trying to get the permit issued as soon as possible, so she put in that particular language
(and maybe that was a situation where she didn't realize it was an issue until she was
working on the permit, which sometimes happens). Since we are pressured to move
permits out of here, she probably didn't have time to wait for a change with the MOA (I'm
speculating - but I imagine this was the case) . If you guys can work that into the MOA -
that would be great and we'd be fine with it; Benson would just need to request a minor
permit modification and we'd incorporate it into the permit.
Perhaps if we run into this again (and hopefully we touch base with Lauren before doing
something like that) - we could give them a 6 month compliance schedule on the instream
monitoring, to give them a chance to try and get the monitoring coalition to cover it. The
permittee also needs to take some responsibility for this during the draft stage. Benson
could have requested some relief of that requirement to see if they could get the coalition to
cover it - however, it looks like their only objection was with the original location of the
upstream site (my point being that the Town didn't really express much objection to having
an upstream monitoring site for the simple parameters of DO and temperature).
I don't know if this answers your question or helps resolve the issue - but I'm sure you'll let
me know if not.
1 of 1 12/3/2003 2:09 PM

[Fwd: pONSON AND THOSE TO COME...INSTREAM MONITORING]
Subject: [Fwd: BENSON AND THOSE TO COME...INSTREAM MONITORING]
Date: Mon, 24 Nov 2003 14:28:26 -0500
From: Dave Goodrich <[e-mail]>
To: Susan A Wilson <[e-mail]>
Susan -
Can you take a look at this and give me'your opinion about what the
problems are, and how to respond?
Thanks,
Dave
Subject: BENSON AND THOSE TO COME...INSTREAM MONITORING
Date: Fri, 21 Nov 2003 10:07:27 -0500
From: Jimmie Overton <[e-mail]>
To: Dave Goodrich <[e-mail]>
DG
i would like your attention on a couple of issues with instream
monitoring requirements for coalition facilities participating with
memorandums'6f agreement. . I feel it is imperative that we live up to
our part of these agreements. The case brought to my attention was an
upstream station sampling requirement for the town of Benson (a
coalition member) in a recently issued permit, and i hope we can rectify
that... but more importantly that we are able to prevent this happening
in the future...and that we can have our folks get together and work out
consistent language in coalition member permits... Lauren has and will
make all efforts to accomodate identified needs of your folks and the
modelers in station selection and parametric coverage as we modify
MOA's but just as we hold the coaltions to our agreement we should be
held to it ourselves.
We as an agency gain tremendously on having quality assurred data
collected by a qualified entity and provided in a consistent electonic
format All that we can do to help each other enjoy this benefit with
minimum pain is worth doing.
Please don't take this as a slam on your people...they are good folks,
and you actually have some good experienced folks with Mike, Mark, Susan
and others...or a focus on one that might have slipped through the
cracks (that happens to us all)....in looking through a few of the
permits it just looked like templates for coaliton monitors could easily
be created...and a FLAG procedure for your new folks to quickly identify
the difference in coaliton members might help...much like it did when we
got into the USFWS T&E species maps...
thanks in advance for your attention
jimmie o . .
gJ 50,3,
'i/Z' UO3 PatArr — f DD0) Gt.P5Tizc,9ot Au) nt (11i/2-
4. 4.(5) Does 140 i Wilve lkesr Aloof v 5
1 of 1 11/25/03 8:21 AM