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NC0020389_Permit Issuance_20001009
State of North Carolina Department of Environment and Natural Resources Division of Water Quality James B. Hunt, Jr., Governor Bill Holman, Secretary Kerr T. Stevens, Director Mr. Keith Langdon Benson Town Administrator P.O. Box 69 Benson, North Carolina 27504 Dear Mr. Langdon: 4 • NCDENR NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES October 9, 2000 Subject: Issuance of NPDES Permit NCO020389 Benson WWTP Johnston County In accordance with the Town of Benson's application for renewal of its municipal discharge permit, the Division of Water Quality is forwarding herewith the Town's NPDES permit renewal. This permit is issued pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between North Carolina and the U.S. Environmental Protection Agency dated May 9, 1994 (or as subsequently amended). The Benson WWTP discharges in the Neuse River Basin (NRB). All streams in the NRB have been designated as nutrient sensitive waters (NSW) as a result of algal bloom problems in the estuary. The North Carolina Environmental Management Commission recently adopted rules establishing the Neuse River Basin Nutrient Sensitive Waters Management Strategy for the reduction of phosphorus and nitrogen inputs. The point source rule (15A NCAC 2B.0234) is intended to reduce total nitrogen (TN) discharges by 30% by 2003. All facilities with permitted flow greater than or equal to 0.5 MGD are receiving a TN limit in this permit cycle. A public hearing was held May 1, 2000 in Raleigh due to public interest generated as a result of the renewal of this (and other) NPDES permits. This final permit incorporates some of the comments and concerns raised during that hearing. The following changes were made: • Due to the Division's concerns regarding operation and maintenance at the plant, the Division has required Benson to complete a Wastewater Management Plan within 180 days of the effective date of the permit. The details of the plan should include estimation of future flows, a facilities assessment, optimization plan, and biosolids management plan. Please refer to the Wastewater Management Plan special condition in the permit. • Benson must provide continuous effluent flow monitoring at the plant. Effluent flow monitoring is critical to calculating total nitrogen loading to Hannah Creek and the Neuse River. • A minimum of 2 feet of freeboard must be maintained in each of the lagoons (currently used as equalization/sludge holding). A staff gauge must also be provided in each lagoon. • The Town is in the process of reconfiguration/modification of the WWTP to incorporate biological nutrient removal. Due to the complexities in operation of this process, the wastewater treatment plant classification will be increased to Class IV (from the current rating of Class III). In order to allow the Town to budget for the increased monitoring, the Division will phase in the Class IV monitoring requirement within one year of the effective date of this permit. • The Division encourages the Town, if they have not already done so, to contact the Division's Technical Assistance and Certification Unit at (919) 733-0026. This Unit may be able to assist the Town with treatment operation and maintenance questions or problems. 1617 MAIL SERVICE CENTER, RALEIGH, NORTH CAROLINA 27699-1617 - TELEPHONE 919-733-5083/FAX 919-733-0719 AN EQUAL OPPORTUNITY AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/ 10% POST -CONSUMER PAPER VISIT US ON THE WEB AT http://h2o.enr.state.nc.us/NPDES Mr. Keith Langdon Town of Benson Page 2 of 2 • The Town should make every effort to allocate appropriate resources to fund any future or current wastewater treatment plant maintenance requirements, expansions, and/ or nutrient offset payments. If any parts, measurement frequencies, or sampling requirements contained in this permit 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 in the form of a written petition, conforming to Chapter 150B of the North Carolina General Statutes, and filed with the Office of Administrative Hearings (6714 Mail Service Center, Raleigh, North Carolina 27699-6714). Unless such a demand is made, this permit shall be final and binding. This permit is not transferable except after notice to the Division. The Division may require modification or revocation and reissuance of the permit. This permit does not affect the legal requirements to obtain other permits that may be required by the Division of Water Quality, the Division of Land Resources, the Coastal Area Management Act, or any other federal or local government. If you have any questions concerning this permit, please contact Susan Wilson at telephone number (919) 733-5083, ext. 510. Sincerely, Kerr T. Stevens cc: Mr. Roosevelt Childress, EPA Raleigh Regional Office, Water Quality Construction Grants & Loans Section Point Source Compliance & Enforcement Unit Aquatic Toxicology Unit Technical Assistance and Certification Unit Central Files Iftaft" Town of Benson Commissioners (letter only, same address as above) Keith Dupree Frederick Nelson Charles L. Nordan Ray G. Smith Jack R. Littleton M. Scott Barnes Permit NCO020389 STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY PERMIT TO DISCHARGE WASTEWATER UNDER THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM In compliance with the provisions of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Water Quality Commission, and the Federal Water Pollution Control Act, as amended, the Town of Benson is hereby authorized to discharge wastewater from a facility located at the Benson WWTP 770 Hannah Creek Road (south of I-95) Four Oaks Johnston County to receiving waters designated as Hannah Creek in the Neuse River Basin in accordance with the discharge limitations, monitoring requirements, and other conditions set forth in Parts I, II, III and IV hereof. This permit shall become effective November 1, 2000. This permit and the authorization to discharge shall expire at midnight on April 30, 2003. Signed this day October 9, 2000. Kerr T. Stevens, Director Division of Water Quality By the Authority of the Environmental Management Commission Permit NCO020389 ' SUPPLEMENT TO PERMIT COVER SHEET The Town of Benson is hereby authorized to: 1. Continue to operate an existing 1.5 MGD wastewater treatment facility with the following components: ➢ Bar screen ➢ Grit removal ➢ Parshall flume with flow measurement ➢ Influent screw pumps ➢ Three extended aeration/oxidation basins ➢ Four secondary clarifiers ➢ Tertiary filters ➢ Chlorine contact basin ➢ Dechlorination equipment ➢ Post aeration ➢ Alum and lime storage/handling units ➢ Aerated sludge lagoon ➢ Two stabilization lagoons (also act as influent flow storage) ➢ Lagoon effluent return pump station This facility is located at the Benson WWTP (770 Hannah Creek Road) near Four Oaks in Johnston County. 2. Discharge wastewater from said treatment works at the location specified on the attached map into Hannah Creek, classified C - NSW waters in Neuse River Basin. Latitude: 35°23'22" R1 C 0 0 2 0 3 8 9 Facility" .' Longitude: 78 30'03" Location & r ; WO Quad #: F24NE Receiving Stream: Hannah Creek Town of Benson Stream Class: C-NSW WViTp Subbasin:30404 North IF SCALE 1:24000 A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - FINAL During the period beginning on the effective date of the permit and lasting until one year after the effective date, 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: Effluent Characteristics Lunits Monitoring Requirements Monthly Average Weekly Average Daily Maximum Measurement ' Frequency 'Sample Type Sample Location 1 ; Flow 1.5 MGD Continuous Recording Influent or Effluent BOD, 5. day (20°C)2 [April 1 - October 31] BOD, 5 day (209C)2 [November 1 - March 31] Total Suspended Residue? 5.0 mg/I 10.0 mg/I 30.0 mg/I 7.5 mg/I 15.0 mg/I 45.0 mg/I 3/Week 3/Week 3/Week Composite Composite Composite Influent f luent & Influent & Effluent "I Influent & Effluent NH3 as N [April 1- October 311 NH3 as N [November 1- March 31] Dissolved Oxygen3 2.0 mg/I 4.0 mg/I Week 3/Week 3Meek Composite Composite Grab Effluent Effluent Effluent Dissolved Oxygen 3Meek Grab Upstream & Downstream Fecal Coliform (geometric mean) 200/100,ml 400/100 ml 3/Week Grab Effluent Fecal Coliform (geometric mean) 3/Week Grab Upstream & Downstream Total Residual Chlorine 3Meek Grab Effluent Total Nitrogen (NO2-N + NO3-N + TKN) 4 No, Effluent Limit (mg/1) 'Weekly Composite Effluent No Effluent Limit (lb/month) Monthly Calculated Effluent 33,790 lb/year (Annual Mass Loading) 5 Annually Calculated, Effluent Total Phosphorus 6 2.0 mg/L (Quarterly Ave rage) Weekly Composite Effluent. Temperature 2C Daily Grab Effluent Temperature (°C) 3Meek Grab Upstream & Downstream 3/Week Grab Effluent -Conductivity Conductivity 3Meek Grab Upstream & Downstream Chronic Toxicity7 Quarterly Composite Effluent Copper 2/Month Composite Effluent Zinc 2/Month Com osite Effluent 'Silver Quarter) Composite Effluent Hg 6-9 Daily Grab Effluent (Footnotes on next page) Town of Benson Permit No. NCO020389 a A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - FINAL (Continued) Footnotes: 1. Sample locations: E - Effluent, I - Influent, U - Upstream at NCSR 1211, D - Downstream at (1) NCSR 1711 and (2) 1-95 culvert. Stream samples shall be grab samples and shall be collected 3/Week during June - 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. See Special Condition A.(3.), Total Nitrogen Monitoring. 5. The annual mass loading limit for total nitrogen shall become effective with the calendar year beginning on January 1, 2003 unless it is provisionally waived per Special Condition A.(4.), Annual Limits for Total Nitrogen. 6. The quarterly average for total phosphorus shall be the average of composite samples collected weekly during the calendar quarter (January -March, April -June, July -September, October - December). 7. Chronic Toxicity (Ceriodaphnia dubia) P/F at 90%: January, April, July, and October [see Special Condition A.(5)]. Toxicity monitoring shall coincide with metals and cyanide monitoring. 8. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored daily at the effluent by grab sample. There shall be, no discharge of floating solids or visible foam in other than trace amounts. Town of Benson Permit No. NCO020389 A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - FINAL During the period beginning one year after 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: Effluent Characteristics Limits Monitorviq Requirements Monthly Average Weekly Average Daily Maximum Measurement Frequency Sample Type Sample Locationl Flow 1.5 MGD Continuous Recording Influent or Effluent BOD, 5 day (202C)2 [April 1- October 311 5.0 mg/I 7.5 mg/I Daily Composite Influent & Effluent BOD, 5 day (202C)2 [November 1 - March 311 10.0 mg/I 15.0 mg/I Daily Composite Influent & Effluent Total Suspended Residue2 30.0 mg/l 45.0 mg/l Daily Composite Influent & Effluent NH3 as N [April 1 - October 311 2.0 m /I Daily Composite Effluent NH3 as N [November 1- March 311 4.0 m /I Daily Composite Effluent Dissolved Oxygen3 Daily Grab Effluent Dissolved Oxygen 3/Week Grab Upstream & Downstream Fecal Coliform (geometric mean) 200/100 ml 400/100 ml Daily Grab Effluent Fecal Coliform (geometric mean) 3/Week Grab Upstream & Downstream Total Residual Chlorine Daily Grab Effluent Total Nitrogen (NO2-N + NO3-N + TKN) 4 No Effluent Limit (mg/1) Weekly Composite Effluent No Effluent Limit Ib/month ( ) Monthly Calculated Effluent 33,790 lb/year (Annual Mass Loading) 5 Annually Calculated Effluent Total Phosphorus 6 2.0 mg/L (Quarterly Average) Weekly Composite Effluent Temperature (2C) Daily Grab Effluent Temperature (2C) 3/Week Grab Upstream & Downstream Daily Grab Effluent -Conductivity Conductivity 3/Week Grab Upstream & Downstream Chronic Toxicity7 Quarterly Composite Effluent 2/Month Composite Effluent -Copper Zinc 2/Month Composite Effluent Silver Quarterly Composite Effluent H8 6-9 Daily Grab Effluent (Footnotes on next page) Town of Benson PCI"rnit No. NCOO2O389 A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - FINAL (Continued) Footnotes: Sample locations: E - Effluent, I - Influent, U - Upstream at NCSR 1211, D - Downstream at (1) NCSR 1711 and (2) I-95 culvert. Stream samples shall be grab samples and shall be collected 3/Week during June - 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. See Special Condition A.(3.), Total Nitrogen Monitoring. 5. The annual mass loading limit for total nitrogen shall become effective with the calendar year beginning on January 1, 2003 unless it is provisionally waived per Special Condition A.(4_), Annual Limits for Total Nitrogen. 6. The quarterly average for total phosphorus shall be the average of composite samples collected weekly during the calendar quarter (January -March, April -June, July -September, October - December) . 7. Chronic Toxicity (Ceriodaphnia dubia) P/F at 90%: January, April, July, and October [see Special Condition A.(5)]. Toxicity monitoring shall coincide with metals and cyanide monitoring. 8. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored daily at the effluent by grab sample. There shall be no discharge of floating solids or visible foam in other than trace amounts. Town of Benson Permit No. NCO020389 A. (3.) TOTAL NITROGEN MONITORING The Permittee shall calculate the annual mass loadinis of total nitrogen as the sum of monthly loadings, according to the following equations: (1) Monthly Mass Loading (lb/mo) = TN x Q x 8.34 where: TN = the average total nitrogen concentration (mg/L) of the composite samples collected during the month Q = the total wastewater flow discharged during the month (MG/month) 8.34 = conversion factor, from (mg/L x MG) to pounds (2) Annual Mass Loading (ib/yr) = E (Monthly Mass Loadings) for the calendar year The Permittee shall report the total nitrogen concentration for each sample and the monthly mass loading in the appropriate self -monitoring report and the annual mass loading of total nitrogen in the December self -monitoring report for the year. A. (4.) ANNUAL LIMITS FOR TOTAL NITROGEN (a) The Neuse Nutrient Management Strategy rule for point sources (1) provides that annual mass limits for total nitrogen shall be included in the permits for all dischargers with permitted flows (as defined in the Strategy) greater than or equal to 0.5 MGD and that those nitrogen limits, including the limits in this permit, shall become effective with the calendar year beginning on January 1, 2003. (b) The Neuse rule also provides that members of a group compliance association shall not be subject to individual annual mass limits for total nitrogen. At the time of permit issuance, the Permittee had expressed interest in joining such an association. Accordingly, (1) the total nitrogen limit in Condition A(1) of this permit is deemed waived provided that the following conditions are met: (i) a formal agreement between the association and Environmental Management Commission, as outlined in 15A NCAC 2B. 0234, is established and is in effect; and (ii) the Permittee is a party to said agreement; and (iii) the association and the Permittee substantially conform with the agreement. (2) So long as the total nitrogen limit in Condition A. (1.) is waived, the group nitrogen allocation established pursuant to the agreement referenced above and any subsequent amendments is hereby incorporated as an enforceable part of this permit. (c) If the Division determines, at any time during the term of this permit, that these conditions are not being met, it shall notify the Permittee in writing of this determination and of its basis. The consequence of such a determination shall be that the Permittee's annual mass limit for total nitrogen and its effective date shall be reinstated immediately. The Division shall accept and consider written responses received from the Permittee and/or the association within thirty (30) days of the original notice before making a final decision and will provide that decision in writing. Tovzi of Benson Permit No. NCO020389 A. (4.) ANNUAL LIMITS FOR TOTAL NITROGEN (cont'd.) (d) The Permittee shall notify the Division in writing within five (5) working days if, at any time during the term of this permit, the Permittee elects not to join the association, or if it withdraws or otherwise loses its membership in the association. Notification shall be sent to: NC DENR / Division of Water Quality / NPDES Unit 1617 Mail Service Center Raleigh, NC 27699-1617 Footnote: Neuse River Basin - Nutrient Sensitive Waters Management Strategy: Wastewater Discharge Requirements (15A NCAC 2B. 0234). A. (5.) CHRONIC TOXICITY PERMIT LIMIT (QRTRLY) The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to Ceriodaphnia dubia at an effluent concentration of 90%. The permit holder shall perform at a minimum, quarterlu monitoring using test procedures outlined in the "North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised February 1998, or subsequent versions or "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions. The tests will be performed during the months of January, April, July, and October. Effluent sampling for this testing shall be performed at the NPDES permitted final effluent discharge below all treatment processes. If the test procedure performed as the first test of any single quarter results in a failure or ChV below the permit limit, then multiple -concentration testing shall be performed at a minimum, in each of the two following months as described in "North Carolina Phase H Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions. The chronic value for multiple concentration tests will be determined using the geometric mean of the highest concentration having no detectable impairment of reproduction or survival and the lowest concentration that does have a detectable impairment of reproduction or survival. The definition of "detectable impairment," collection methods, exposure regimes, and further statistical methods are specified in the "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions. All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge Monitoring Form (MR-1) for the months in which tests were performed, using the parameter code TGP3B for the pass/fail results and THP3B for the Chronic Value. Additionally, DWQ Form AT-3 (original) is to be sent to the following address: Attention: North Carolina Division of Water Quality Environmental Sciences Branch 1621 Mail Service Center Raleigh, North Carolina 27699-1621 Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no later than 30 days after the end of the reporting period for which the report is made. Test data shall be complete, accurate, include all supporting chemical/physical measurements and all concentration/response data, and be certified by laboratory supervisor and ORC or approved designate signature. Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for disinfection of the waste stream. To1Az1 of Benson Perinit No. NCO020389 A. (5.) CHRONIC TOXICITY PERMIT LIMIT (QRTRLY) (cont'd.) Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required, the permittee will complete the information located at the top of the aquatic toxicity (An test form indicating the facility name, permit number, pipe number, county, and the month/year of the report with the notation of "No Flow" in the comment area of the form. The report shall be submitted to the Environmental Sciences Branch at the address cited above. Should the permittee fail to monitor during a month in which toxicity monitoring is required, monitoring will be required during the following month. Should any test data from this monitoring requirement or tests performed by the North Carolina Division of Water Quality indicate potential impacts to the receiving stream, this permit may be re- opened and modified to include alternate monitoring requirements or limits. NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism survival, minimum control organism reproduction, and appropriate environmental controls, shall constitute an invalid test and will require immediate follow-up testing to be completed no later than the last day of the month following the month of the initial monitoring. A. (6.) WASTEWATER MANAGEMENT PLAN No later than 180 days after the effective date of this permit, the Permittee shall submit to the Division a wastewater management plan. The plan shall include, at a minimum, the following elements: Future flows. Provide estimates of wastewater flows and characteristics for the next 10-20 years and the basis for those estimates, including assumptions and calculations. Facilities assessment. Describe deficiencies and operational difficulties in the existing collection system or treatment facility which affect performance or permit compliance, and identify potential improvements to correct those. At a minimum, evaluate the following considerations: • inflow and infiltration, • headworks performance, • diversion of wasteloads during peak flows, • equipment repairs and preventative maintenance, • removal of accumulated solids, wastes, other debris Optimization plan. Develop a strategy for optimization, rehabilitation, expansion and/or replacement of the collection and/or treatment system to achieve optimum performance. Identify specific measures and key tasks, including those in the above facilities assessment, and provide an estimated schedule for completion of each. Biosolids management plan. Develop an operations protocol to be used or describe the protocol currently used for managing septage/ biomass in the treatment system, including associated solids wasting and disposal, to promote optimum treatment system performance. Identify operating parameters to be used and target values or ranges of values where appropriate. Town of Bem-ion Permit No. NCO020389 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. A. (8.) EFFLUENT FLOW MONITORING Continuous effluent flow monitoring must be provided at the plant. Town of Benson Permit No. NC0020389 Summary and Recommendations Facility Description Neuse River Basin Public Hearings May 1, 2000 Town of Benson Benson WWTP NCO020389 Benson operates a 1.5 MGD wastewater treatment facility consisting of a bar screen, grit removal, parshall flume with flow measurement, influent screw pumps, three extended aeration/oxidation basins, four secondary clarifiers, tertiary filters, chlorine contact basin, dechlorination, post aeration, alum and lime storage/handling units, aerated sludge lagoon and 2 stabilization lagoons (that also act as influent flow storage) with a lagoon effluent return pump station. Permit Summary The facility must meet limits of 5 mg/1 BOD5 (summer) and 2 mg/1 NH3-N (summer). The permit also has a 2 mg/1 total phosphorus limit. A 33,790 lb/yr annual nitrogen load has been required with this draft permit based on the revised nitrogen allocation. Benson is a member of the LNBA and has proposed to become a member of the Neuse Nutrient Trading Association. Copper, silver and zinc monitoring has been added to this draft permit. Benson is currently operating under a Special Order by Consent (SOC) and has a relaxed limit for total flow (i.e., the Town is required to make improvements to plant via inflow/infiltration (1/1) reduction and come into compliance with the flow limit by Sept. 2000). The Town discharges to a stream that is listed on NC's 303d list and is biologically impaired. Additionally, numerous instream DO values have been recorded below 5 mg/l. DWQ has concerns about Benson's future growth plans, although the Town has received speculative limits for a discharge into the adjacent Cape Fear River Basin. During the site visit by DWQ on April 27, it was noted that flow does not appear to be accurately monitored. This is because when elevated flow conditions arise, flow is diverted to the "equalization lagoons" prior to the flow monitoring area. Flow is pumped from the equalization lagoons to the screw pumps (bypassing the flow meter). Accurate flow measurements must be determined in order to properly assess exact nutrient load from the plant (*recommend that hearing officer specify that effluent monitoring must be conducted. Influent monitoring should at minimum be estimated). Comments • Heather Beard (NRF) — concern over discharge into impaired creek, concern over numerous operation and maintenance problems, concern over deficiencies in pretreatment data and "falsification" of pretreatment data which lead to an assessment, concern that Town needs to be more aggressive in planning further expansion and upgrades. • NRF recommends more oversight of Town's pretreatment program • NRF recommends Town become more serious re. planning and make immediate effort to proceed with planning for growth demands. • Keith Langdon, Benson — Have made progress on addressing inflow/infiltration issues, are about to complete construction to assist with nitrogen removal, state $$s spent on projects, have to balance competing issues for limited resources, accept responsibility that infrastructure improvements will be ongoing process, proud of the performance record of plant and acknowledge that paper work has sometimes been deficient, have contracted with The Wooten Company to complete the Town's 201 Facility Plan for future expansion, disagrees with DWQs requirement to monitoring silver, copper, and zinc with this permit renewal — feels resources would be better used elsewhere. Response and Discussion DWQ acknowledges that this discharge is into a creek with DO levels documented at less than 5 mg/1; this creek is classified as "swamp", so the depressed DO's may be due to natural conditions. Hannah Creek was not listed on the state's 303d list. However, should the facility expand, DWQ may not consider Hannah. Creek as a discharge site. Additionally, any expansion would require that the facility meet tertiary treatment levels. The recent inspection noted O&M problems and a Notice of Violation is being submitted to the facility; should corrections not be made to the plant, DWQ may pursue enforcement. A pretreatment audit is conducted 1/year; [RRO and Pretreatment Unit has expressed concerns with regard to record keeping and are in the process of further investigation] ***Should problems recur with pretreatment, then enforcement may be pursued via the pretreatment requirements. A recommendation regarding documentation of financial commitment to, and planning for, future wastewater needs has been discussed with the hearing officer. Another special condition regarding some specific maintenance requirements has been recommended to be placed in the permit (flow measurement, lagoon freeboard height, headworks maintenance, etc.). DWQ is encouraged that Benson is working on the 201 Facility Plan for expansion. The NPDES Unit does not recommend that any of the requirements from the draft be eliminated. Also, the question has arisen as to the classification of the facility after the modifications for nutrient removal have been put in place. Currently, Benson is a Class III facility — with nutrient removal current rules specify that the classification will go to Class IV (although flow is under 2.5 MGD). The NPDES Unit recommends that this either be phased in after a year or be phased in with any permit request for expansion. • The Raleigh Regional Office recommended via memo dated 6/14/00 that a minimum of 2 ft. of freeboard be maintained in the facility's lagoons and a staff gauge (or similar instrument to measure freeboard height) be permanently placed at each lagoon. Recommended Actions) NPDES Unit recommendations listed in responses and summarized below: Phase in monitoring requirements for Class IV within 1 year. Require minimum of 2 feet of freeboard height and staff gauges within each lagoon. Require continuous effluent flow monitoring. Require financial commitment for expansion. 0 Issue permit with attached Special Condition. A. (_.) WASTEWATER MANAGEMENT PLAN No later than 180 days after the effective date of this permit, the Permittee shall submit to the Division a wastewater management plan. The plan shall include, at a minimum, the following elements: • Future flows. Provide estimates of wastewater flows and characteristics for the next 10-20 years and the basis for those estimates, including assumptions and calculations. Facilities assessment. Describe deficiencies and operational difficulties in the existing collection system or treatment facility which affect performance or permit compliance, and identify potential improvements to correct those. At a minimum, evaluate the following considerations: • inflow and infiltration, • beadworks performance, • diversion of wasteloads during peak flows, • equipment repairs and preventative maintenance, • removal of accumulated solids, wastes, other debris • Optimization plan. Develop a strategy for optimization, rehabilitation, expansion and/or replacement of the collection and/or treatment system to achieve optimum•performance. Identify specific measures and key tasks, including those in the above facilities assessment, and provide an estimated schedule for completion of each. • Biosolids management plan. Develop an operations protocol to be used or describe the protocol currently used for managing septage/ biomass in the treatment system, including associated solids wasting and disposal, to promote optimum treatment system performance. Identify operating parameters to be used and target values or ranges of values where appropriate. June 14, 2000 MEMORANDUM TO: Dave Goodrich FROM: Ted Cashion `A L,,r�,t-1' , �J J THROUGH: Ken Schuster SUBJECT: Administrative Letter for an Addition to the Benson WWTP NPDES Permit NCO020389 The Town of Benson has 2 lagoons at the WWTP. One is for equalization/sludge storage, one is for sludge storage. The NPDES permit does not require 2 feet of freeboard in these lagoons. Previous site visits have shown levels <2 feet of freeboard. We are requesting an administrative letter requiring a minimum two foot freeboard be added to this permit for each lagoon. Also, we would like the permit to state that some sort of measuring device be put in place to read the freeboard. We feel that the administrative letter would help prevent potential problems. If questions call me at 571-4700 ext. 250. cc: Ken Schuster Kevin Barnett benson2.mem J J N 2 2 2000 Re: freeboard Subject: Re: freeboard Date: Wed, 07 Jun 2000 08:38:20 -0400 From: Sue Homewood <sue.homewood@ncmail.net> Organization: DWQ To: Susan Wilson <susan.a.wilson@ncmail.net> its 19 inches for typical anaerobic lagoons on swine farms, can be 26 inches if its a newer lagoon. for other non -discharge lagoons (all types) we usually require 2 feet. sue Susan Wilson wrote: > is the standard free board height recommended as 19 inches? is this for > all lagoon types? Sue Homewood Environmental Engineer NCDENR - Division of Water Quality Non -Discharge Permitting Unit 1617 Mail Service Center Raleigh, NC 27699-1617 919-733-5083 extension 502 fax: 919-733-0719 Mailto:Sue.Homewood@ncmail.net 1 of 1 6/7/00 9:00 AM May 16, 2000 Mr. Keith Langton, Town Manager Town of Benson 303 East Church Street Benson, NC 27504 DRAFT D d a MAY 2 5 = f DEAR - WATER QUALITY --MiNT SOURCE BRANCH SUBJECT: NOTICE OF VIOLATION/ Compliance Evaluation Inspection Town of Benson WWTP NPDES Permit No. NCO020389 Johnston County Dear Mr. Langton: Enclosed is a copy of the Compliance Evaluation Inspection conducted Apra 26,- 2000. The subject inspection was performed by several staff members representing various regional offices of the Division of Water Quality. Conducting the inspection were Belinda Henson and Dale Lopez of the Fayetteville Regional Office and Ted Cashion, Jenne Sowell, Robin Simpson and Mitchell Hayes of the Raleigh Regional Office. The cooperation of Mr. John Alt the "ORC" of the facility was greatly appreciated. A violation was noted for the following NPDES permit condition, Part II Section C.2.Pt_oper Operation and MaintP.,a,,,.o - "The permittee shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the permittee to achieve compliance with the condition of this permit." The following summary of the inspection is noted: The facility has one industry, Chicapi, with an average flow of 0.6 GPD. This industry is responsible for 40-50% of the influent flow. The industry produces woven material for hospital usage. It has an air flotation pretreatment system. Chlorination is not used. Does the Town have a pretreatment program?????? 2. The plant is equipped with a influent Equalization Basin. When influent flow exceeds 1.8 MGD the gates will automatically open and the flow is diverted into the basin. -continued- 3. The flow travels through a manual bar screen and then through an automatic bar screen. All screenings are disposed of through the Johnston county landfill. There were paper products (screenings) located on the ground beside the bar screen. Removal of these screenings from this area and proper disposal is needed. Drainage from stock piled screenings should be routed back into the facility. Such "on the ground" storage is not viewed as proper screenings management. 4. Septage haulers are allowed to dispose of wastewater.into the facility. The average amount is 20,000 gallons/month. It is recommended that the septage hauler waste is analyzed to eliminate adverse affects to the facility. It is recommended that septage be discharged at the headworks of the plant to allow complete treatment. 5. The Town has eight (8) lift stations. A portable generator is utilized when necessary. 'The plant generator is believed to be under powered for the facility with a output capacity only a 150 KVA. The ORC indicated that plans are to replace this generator with a 450 KVA in the next fiscal year. It is recommended that enough portable generators should be on hand to supply power to all lift stations in case of an emergency. 6. The grit removal system was not operational and had not been for approximately two (2) weeks as per Mr. Alt. The facility had not notified the Raleigh Regional office concerning this. As stated in the NPDES permit Part H. 9. Noncompliance Notification "The permittee shall report by telephone to either the central office or the appropriate regional office of the Division as soon as possible, but in no case more than 24 hours or on the next working day following the occurrence or first of the occurrence of any of the following: b. Any process unit failure, due to known or unknown reasons, that render the facility incapable of adequate wastewater treatment such as mechanical or electrical failures of pumps, aerators, compressors, etc." 7. The alarm system at the facility was not inclusive of all components and pumps at the facility. It is strongly recommended that telemetry installed at the facility as well as the lift stations for all key components to alert municipal staff of equipment failure and high water flow indications. 8. The influent flow meter which was an ISCO 3210 Ultrasonic did not appear to have a recent calibration. Flow meter calibration records were not available. As stated in the Administrative Code Section: 15A NCAC 2B .0505(b)(1)"Devices selected shall be capable of measuring flows with a maximum deviation of less that 10 percent from true discharge volumes. Flow measurement devices shall be accurately calibrated at a minimum of once per year and maintained to ensure that the accuracy of the measurements is consistent Edith the accepted capability of that type of device." It is advisable that the flow meter calibration document contain the % error before and after calibration by the technician. Failure to -continued - provide proper and timely calibration is considered a violation. 9. The stilling well used to read the flow appeared to have some sludge in it which will block the signal necessary for accurate flow measurement. Cleaning the stilling well should be completed immediately. Please be aware that lack of maintenance in this area could lead to false flow violations resulting in fines. 10. Three (3) screw pumps are used to pump the wastewater into the oxidation ditches. All pumps appeared to be operational. One (1) pump is used under ordinary conditions. Screw pump 91 appeared to have an unusual sound when it was turned on. Possible repairs maybe needed on this pump. Further evaluation should be performed to access the possible problems and prevent undue repairs and expenses. 11. The wastewater from the equalization basin is pumped in at the area after the influent has been pumped by the screw pumps. The flow is not properly metered since the flow from the equalization basin is not metered. All flow coming into the plant should be properly metered for a total flow. This must be corrected within 60 days of receipt of this report. 12. The influent flows into three oxidation ditches. Oxidation ditch #1 was under repairs at the time of the inspection for maintenance and some mechanical changes. During the inspection it was noted that grit and other material was amassed in piles in this ditch. Before this ditch is put back into service this material should be removed to increase the capacity of space for wastewater as well as improved treatment. Plans are to use oxidation ditch #2 as an anoxic zone for nitrogen removal which means the flow will travel to #2 ditch and then to #1 and #3 in parallel to complete aeration. All aerators appeared to be operational. A recommendation to place fencing around the oxidation ditches to assist with safety was made during the inspection. Painting the power boxes and other needed components in this area is suggested. The Mixed Liquor Suspended Solids (MLSS) content ranges from 2000 mg/1 to 2500 mg/l. The analyses for MLSS is performed twice a week. 13. Lime is added into the oxidation ditches when needed for ammonia reduction. The lime tank on site appeared to need painting and proper maintenance now could eliminate major repairs and cost in the future. It has not been necessary to use the lime in 6-8 months. 14. The facility had four (4) clarifiers. There was not a operable sludge judge on site to monitor sludge blankets. At least two (2) sludge judges should be purchased to assist in operation of the clarifiers. Sludge depths should be monitored daily to assist with overall wastewater treatment. There appeared to be some floatable paper products in the clarifier which blocked the flow over the weirs in a few area. The floatable items should be removed on a daily basis to eliminate this.. In clarifier #2 the motor had an unusual sound which could be a symptom of necessary repairs. The motor should be checked for possible problems. The catwalks and railings appeared to have paint worn from the surface. Maintenance in these areas should be addressed as soon as possible to eliminate major repairs and cost in the future. -continued- 15. An alum tank on site is utilized for solids settling in the clarifiers if necessary. Alum is not used at this time. A containment wall is located around the tank to prevent spillage onto the ground. The drain located inside the wall will drain to the scum well. This drain should be closed to prevent, spillage from slugging the plant. Rainwater should be released as needed. 16. The effluent filters are made of multimedia sand, gravel and anthracite. There appeared to be some floatable solids (not excessive) located on the surface of the water. Increased backwash time may be necessary to eliminate this. The electrical boxes for the filters were open which appeared to be unsafe. As per conversation with Mr. Alt, the electrical boxes were open due to monitoring the system because of various problems with one being not able to automatically control the operations of the filters. They can only be manually operated. The operation of the filters should be evaluated by the town's engineers and plans developed to correct any operational problems. 17. Chlorine is added for disinfection of the effluent. The system will automatically switch cylinders when one is empty. A ton cylinder will last approximately five (5) months. A flow paced chlorine system is suggested to assist in adequate disinfection without over dosage: 18. The chlorine contact tank is cleaned annually. jPlease note that solids should never be allowed to accumulate over 12 inches in depth, ever that accumulation may cause effluent violations. 19. Two (2) effluent pumps are used with one (1) leaking profusely. Repairs should be made as soon as possible to eliminate this leakage. The pumps also appeared to have paint worn from the surfaces. Painting of these surfaces could eliminate major repairs in the future. 20. The post aeration tank is the last phase of the wastewater treatment. Dried solid material appeared on the side of the tank and on a step ladder leading the inspectors to believe that solids had spilled over in this tank previously. We highly recommend that the chlorine contact tank and the post aeration tank are cleaned to ensure the best quality effluent is discharged as well meeting NPDES permit requirements. Both grab and composite sampling is completed at the end of the post aeration tank with the exception of the .chlorine residual sample which is collected at the end of the chlorine contact chamber. All sampling should be done at one point. Soda ash is added for pH adjustment in this tank. 21. The effluent appeared to be a little cloudy. 22. The effluent outfall was easily accessible. As a reminder all grass and weeds should be maintained adequately to continue accessibility to the effluent outfall. 23. An aerated sludge lagoon has been utilized since the year "1995" with no sludge disposal. The aerated lagoon had three (3) 15 horsepower floating surface aerators. This facility should find a way to popery dispose of sludge before problems are created for the treatment of the wastewater. A plan for sludge disposal should be implemented immediately. There -continued - appeared to be some duckweed not excessive floating on the surface of the wastewater. It is requested that the Town provide the total sludge volume ahead. 24. The equalization lagoon and the #3 sludge holding lagoon are recommended to be dredged and all paper products located on the grounds outside the lagoons should be properly disposed of. Removing trash and debris from the ground is a basic maintenance requirement. 25. The influent composite sampler temperature was over 5 Degrees Celsius. The effluent composite sampler temperature appeared to be adequate at 4 Degrees Celsius. Composite sampler temperatures should be maintained at 0-4 Degrees Celsius. The composite sampler containers were enclosed in a refrigerated unit. There was no protection from the elements for the refrigerated unit. Without the added protection of some type of enclosure adequate holding temperatures may be difficult to maintain during hot_ and humid weather. During the inspection it was noted that during composite sampling one (1) sample was collected every 38 minutes. Based on Administrative Code Section: 15A NCAC 2B. 0503- "Composite sample (d) Constant time/constant volume - a series of grab samples of equal volume collected over a 24 hour period at a constant time interval. This method may be used in situations where effluent flow rates vary less than 15 percent. The grab samples shall be taken at intervals of no greater than 20 minutes apart during any 24 hour period and must be of equal size and of no less that 100 milliliters. Use of this method requires prior approval by the Director". The influent composite sample can be collected based on this type of sampling but the effluent must choose one of the other types of composites which area proportiona . Please contact the Raleigh Regional Office for further information. 26. The facility is presently under a Special Order by Consent (SOC) with modified limits for flow which expire June 1, 2000. A copy of the SOC was not on site. The NPDES permit was effective April 1, 1994 and expired -January 31, 1999 and was on site for review. 27. Laboratory records were reviewed for the months October through December 1999 and compared to Discharge Monitoring Reports (DMRs): The records appeared to be adequate. 28. A compliance evaluation analysis report for the period March 1999 through February 2000 did not reveal any violations. I 29. The on site laboratory performs all required NPDES permit parameters except Toxicity and Total Nitrogen. The Toxicity parameter is analyzed by the commercial laboratory "Water Technology and Controls" and Total Nitrogen is analyzed by "Southern Testing". 30. The laboratory on site was inspected during this time and the following items were noted: a. The BOD incubator temperature was 19.6 Degrees Celsius which is adequate. The temperature range for the incubator should be 20 +/- 1 Degrees Celsius. f -continued- b. The drying oven for the Total Suspended Solids analyses was adequate at 103.6 Degrees Celsius. The temperature range for the oven is 103-105 Degrees Celsius: C. Calibration records for the pH parameter were adequate. 'pH buffers were checked and the pH buffer 7.0 had expired January 26, 2000. The buffer should be discarded and an unexpired pH buffer 7.0 should be purchased -immediately. d. Calibration logs for weights were adequate with the following weights used: 100 milligram, 1 gram, 5 grams, 10 grams. Please respond in writing -to the following items: 6, 8-12, 149 169 20, 23, 25 explaining the actions to resolve these problems. Please respond on or before June 30, 2000. Violations of the NPIDES permit are enforceable by our Division. Violations can be accessed up to $25,000/day/violation. As a reminder the Division's Technical Assistance and Certification Unit is available upon request to provide assistance to the Town with technical problems at no cost. You can contact Dwight Lancaster, Supervisor, at 919-733-0026. If you or your staff have any questions please contact Mr. Cashion or other`water quality staff at 919-571-4700. cc: Laboratory Certification Brief Facility Description: "M I Iwo I =1648 - MINI1104•• •• a.. ',. •�MeN.�1 FACILITY SITE REVIEW (!eD No N/A 1. Treatment'units properly operated and maintained. es No N/A 2. Standby power or other equivalent provision provided. Yes. �Z� N/A 3. Adequate alarm system for power or equipment failure available. 4. Sludge disposal procedures appropriate: Yes No N/A a. Disposal of sludge according to regulations Yes No N/A b. State approval for sludge disposal received. Yes (S� N/A 5. All treatment units other than backup units in service. Yes No � 6. Sufficient sludge disposed of to maintain treatment process equilibrium. Yes No N/A 7. Adequate number of qualified operators on staff. Yes No N/A 8. Established procedures available for training new employees. No N/A 9. Adequate spare parts and supplies inventory maintained. Yes N/A 10. a. Hydraulic overflows and/or organic overloads experienced Yes (N N/A b. Untreated bypass discharge occurs during power failure. Yes N/A c. Untreated overflows occurred since last inspection. Yes o N/A 11. Plant has general safety structures such as rails around or covers over tanks, pits, or wells. Yes (Ro N/A 12. Plant is generally clean, free from open trash areas. Page 2 I Screening: No N/A a. Manual es No N/A b. Mechanical (UP No N/A c. Buildup of debris DNo N/A d. Screenings properly disposed of. 14. Grit Removal: nr-A e p e rct� ; e nl I Yes No N/A a. Excessive organic content in the grit chamber Yes No N/A b. Excessive odors Yes No N/A c. Grit properly disposed of. 15. Primary clarifier: Yes No 1 / a. Excessive gas bubbles Yes No N/A b. Black and odorous wastewater Yes No N/A c. Poor suspended solids removed Yes No N/A d. Excessive buildup of solids in center well of circular clarifier Yes No N/A e. Weirs level Yes No N/A f. Weir blockage Yes No N/A g. Evidence of short circuiting Yes No N/A h. Lack of adequate scum removal Yes No N/A i. Excessive floating sludge Yes No N/A j. Broken sludge scraper. 16. Trickling Filter: . Yes No (95� a. Trickling filter ponding(indicating clogged media) Yes No N/A b. Leak at center column of trickling filter's distribution arms Yes No N/A c. Uneven distribution of flow on tricklina filter surface Yes No N/A d. Uneven or discolored growth Yes No N/A e. Excessive sloughing of growth Yes No N/ A f. Odor Yes No N/A g. Clogging of trickling filter's distribution arm orifices ; Yes No N/A h. Filter flies, worms, or snails. 17. Rotating Biological Contactors (RBC): / Yes No i a. Development of white biomass on rotating biological contactor media Yes No N/A b. Excessive sloughing of growth Yes No N/A' c. Excessive breakage of rotating disks or shafts in RB C units_. Yes No N/A d. Excessive breakage of paddles on brush aerators Yes No N/A e. Shaft, bearing. drive gear, or motor failure on disk or brush aerators. Page 3 18. Activated Sludge Basins/Oxidation Ditches: v Yes (g3) N/A a. Dead spots Yes C b N/A b. Failure of surface aerators Yes cis N/A c. Air rising in clumps Yes 62 N/A d. Dark foam or bad color Yes 0 N/A e. Thick billows of white, sudsy foam Yes No �T/A� f. Air rising unevenly Yes No 1/� g. Excessive air leaks in compressed air piping. 19. Stabilization Ponds/Lagoons: Yes No N/A a. Excessive weeds including duckweed in stabilization ponds Yes Q N/A b. Dead fish or aquatic organisms Yes No N/A c. Buildup of solids around influent pipe Yes (&) N/A d. Excessive scum on surface. 20. Secondary Clarifier: Yes o N/A a. Excessive gas bubbles on surface Yes dO N/A b. Unlevel overflow weirs TJ6 No N/A c. Weir blockage Sc. M C No N/A d. Evidence of short circuiting Yes No N/� e. Excessive buildup of solids in center well of circular clarifier Yes No N/A f. Pin floc in overflow Yes No %t g. Ineffective scum rake Yes (Tes N/A h. Floating sludge on surface Yes No N/A i. Excessive high sludge blanket n e Yes No N/A j. Clogged sludge withdrawal ports on secondary clarifier. - 21. Filtration: Yes < sD N/A a. Filter surface clogging y Yes No N/A b. Short filter run . Yes 1i' N/A c. Gravel displacement of filter media Yes KO N/A d. Loss of filter media during backwashing Yes N/A e. Recycled filter backwash water in excess of 5 percent Yes C 0— N/A f. Formation of mudballs in filter media. 22. Chlorination Unit: Yes N/A a. Sludge buildup in contact chamber Yes ' T N/A b. Gas bubbles Yes NO' N/A c. Floating scum and/or solids Yes �' N/A d. Inadequate ventilation of chlorine feeding room and storage area Des No N/A e. NIOSH-approved 30 minute air pack Yes Q�) N/A f. All standing chlorine cylinders chained in place to in H, 0 1Z s1No N/A Q. All personnel trained in the use of chlorine es )No N/A h. Improper chlorine feed, storage, and reserve supply. Page 4 Yes No <S7L�) 23. Ultraviolet radiation disinfection present and in use. _ 24. Dechlorination: Yes No C/P�% a. Improper storage of sulfur dioxide cylinders Yes No N/A b. Inadequate ventilation of sulfur dioxide feeding room Yes No N/A c. Automatic sulfur dioxide feed or feedback control not operating properly. 25. Aerobic Digester: L—(z J•o o n Yes * N/A a. Excessive foaming in tank Yes Zg6) N/A b. Noxious odor . Yes Q N/A c. Mechanical aeration failure Yes No //A� d. Clogging of diffusers. 26. Anaerobic Digester: Yes No N/ a. Floating cover tilting Yes No N/A b. Gas burner inoperative Yes No N/A c. Supernatant has a sour odor. 27. Sludge Drying and/or disposal: Yes No �/� a. Poor sludge distribution on drying beds Yes No N/A b. Vegetation in drying beds Yes No N/A c. Dry sludge remaining in drying beds Yes No N/A d. Dry sludge stored on site Yes No N/A e. Filtrate from sludge drying beds returned to front of plant Yes No N/A f. Approved disposal site for the sludge Yes No N/A g. Sludge land applied. 28. Filter Press: Yes No a. High level of solids in filtrate from filter presses or vacuum filters Yes No N/A b. Thin filter cake caused by poor dewatering Yes No N/A c. Sludge buildup on belts and/or rollers of filter press Yes No N/A d. Excessive moisture in belt filter press sludge cake. 29. Polishing Ponds or Tanks: Yes No i D a. Objectionable odor, excessive foam, floating solids, or oil sheens on water surface Yes No N/A b. Solids or scum accumulations in tank or at side of pond Yes No N/A c. Evidence of bypassed polishing ponds or tanks because of low capacity. Page 5 30. Plant Effluent: Yes L q N/A a. Excessive suspended solids, turbidity, foam, grease, scum, color, and other macroscopic particulate matter present Yes (0 N/A b. Potential toxicity (dead fish, dead plant at discharge) 's) No N/A c. Outfall discharge line easily accessible. 31. Flow Measurement: Yes No N/A a. Improper placement of flow measurement device Yes W N/A b. Flow totalizer not calibrated Yes No N/A c. Buildup of solids in flume or weir Yes No N/A d. Broken or cracked flume or weir Yes No N/A e. Improperly functioning magnetic flowmeter No N/A f. Clogged or broken stilling wells Yes (RD N/A g. Weir plate edge corroded or damaged Yes No N/A h. System not capable of measuring maximum flow Yes No N/A i. Flow measurement error greater than +/- 10%. 32. Sampling: No N/A a. Sampling and analysis completed on parameters specified by permit es No N/A i b. Samples refrigerated during compositing Yes No N/A c. Composite sample temperatures maintained at less than or equal to 4 degrees Celsius during sampling 5e C, 4 Yes No N/A d. Contract laboratory used for sample analysis. RECORDKEEPING AND REPORTING Yes No N/A 1. Records and reports maintained as required by permit. es No N/A 2. All required information available, complete, and current. es No N/A 3. Records maintained for') years and all sludge records maintained for 5 years. Yes No N/A 4. Analytical results consistent with data reported on DMRs. _ 5. Sampling and analyses data adequate and include: es ` No N,1A a. Dates, times, and location of sampling Yeses, No N/A b. Name of individual performing sampling es-7No N/A c. Results of analyses and calibration No N/A d. Dates of analyses es No N/A e. Name of person performing analyses. FILTER BACKWASH HASTE CHLORINE DECHLORINATION SYSTEM CONTACT BASIN POST AERATION TANK FILTERS 2 EFFLUENT PUMPING STATION BACKWASH WATER STORAGE FILTER BACKWASH II �� �\-.,_SLUDGE CLEAR WATER ISLUDGE WASTE III RECIRCULATION 11jIt AL\; \ \\ AERATION 1 TANK f3 —� \� IIIAL \ \ 1_ 1�.l C A. \° �— I I� 1�I I I I ALUM 'k I I +�— 1 f2AR. UNITLING 6 I AERATION TANK 02 0 1 / 1 5 I I 1 ISPLITT D) } ( ' LIME �❑0 1 IBOX —i 0 1 UNITLING Ro CLAR. 03. 8 AERATION C #Ai TANK f i -� SCREW PUMPS 9 IGRIT INFLUENT 1 CHAMBER-, BYHPASSTSCREEN �- ol 7 PARSHALL SLUDGE HOLDING LAGOON 03 EXHIBIT V-9 SAMPLING LOCATIONS LAGOON EFFLUENT RETURN AERATED b� LAGOON fi SLUDGE HOLDING LAGOON f2 -1 9 Re: benson Subject: Re: benson Date: Mon, 27 Mar 2000 10:31:19 -0500 From: Marcia Lieber <marcia.lieber@ncmail.net> Organization: NCDENR-DWQ To: Susan Wilson <susan.a.wilson@ncmail.net> hi, the Town is compliant with their& mile stones so far, the next mile stone date is March 30, 2000, when construction to the collection system is completed. Iglet you know when/"If they can meet that date. Susan Wilson wrote: > Mrcia, > could you verify if benson has been compliant with their SOC schedule? > some dates are filled in (it looks like to me) but others aren't. if > they go to hearing - we'll need this info. I of 1 3/27/00 10:33 AM AFFIDAVIT O _ UBLICATION NORTH CAROLINA. Wake County. ) Ss. TO BE HELD BY NORTH GkROLINA ENVIRONMENTAL MANAGEMENT COMMISSION ing has been scheduled concerning the proposed renewal and, issuance of the following nits: iber NCO023841 to the City of Durham for the Durham North Water'Reclamation tted in Durham (Durham County) for the discharge of treated municipal wastewater Creek. Iber N000Z0389 To the Town of Benson for the Benson Wastewater Treatment Plant Jenson (Johnston County) for the discharge of treated municipal wastewater into Iek. tber NC0 M.M to Uniprop, Inc. for the Mill Run Mobile Home Park Wastewater Plant located in Garner (Wake County) for the discharge of. treated domestic into an unnamed tributary to swift Creek. nber N00049662 to Heater Utilities for the Hawthorne Subdivision Wastewater Plant located in Raleigh (Wake County) for the discharge of treated domestic into Upper Barton Creek. Iber NC0038to Riverview Mobile Home, Park for the Riverview Mobile Home Park Treatment P784lant located in Raleigh (Woke County) for the discharge of treated astewater into the Neuse River. nber NCO064408 to Whitewood Properties, Inc. for the Neuse Crossing Wastewater Plant located in Raleigh (Wake County) for the discharge of treated domestic into the Neuse River. nber NCO063746 to Ira D. Lee for the Deerchose Subdivision Wastewater Treatment :din Wake Forest ( Wake County) for the discharge of treated domestic wastewater into k. fiber NC0060526to Pope Industrial Park I[, Ltd. forthe Pope Industrial Park Wastewater Plant located in Raleigh (Wake County) for the discharge of treated domestic into an unnamed tributary to Swift Creek. e facilities has applied for renewal of their NPDES permit far the discharge of treated municipal wastewater into waters of the Neuse River basin. On the basis of prel immary and application of Article 21 of Chapter 143, General Statutes of North Carolina, and standards and regulations, the North Carolina Environmental Management Commis s to issue a NPDES permit for each facility sub)ect to specific pollutant ltations and litions. The Director of the Division of Water Quality Pursuant to NCG5143 215.1(c) (3) .an 15 CA r Section 0700 has determined that it is m The public interest that a held to rece-rye aii pertinent public -comment on whether to issue, modify, or deny the 2E: I will be corMucted in the following manner: oration of North. Carolina Environmental Management Commission's Permitting vill be Presented by the Division of Water Quality. motion of the action for which each permit is required may be made by The applicant. mment- Comments, statements, dato and other information may be submitted in writing urine the meeting or may he presented orally at the meeting. Persons desiring to sceak Th is intent at thetime of registration ai the meeting. So that al I persons desi ring to speak lengthy statements may be IIm)ted at the discretion of the meeting officer. Oral ns that exceed three minutes should be accompanied by Three written copies, which will th Division staff at the time of registration. �minafion Of persons Presenting testimony will not be allowed. however, the hearing ask questions far clarification. •ing record maybe closed at the conclusion of the meeting. lay 1, 2000 at 7:00 P•m. Archdale Building -Ground Floor Hearing Room 512 North Salisbury Street Raleigh, North Carolina rloN: the draft NPDES permit(s) and a map showing the location of the discharge(i) are ,y writing or calling: e Jackson n of Water Ouolity/NPDES Unit iervice Center orth Carolina 27699-1617 number: 619) 733-5083, extension 538 - y ations and other'information are on file at the Division of Water quality, 512 North treet, Raom 925 of the Archdale Building in Raleigh, North Carolina and of the Division's gional Office (3800 Barrett Drive in Raleigh). They may be inspected during normal s. Copies of the information on file are available upon request and.payment of the costs of on. All such comments and requests regarding this matter should make reference to the nber(s) listed above. rh 99. 211011 -. Pus Before the undersigned, a Notary Public of Johnston County North Carolina, duly commissioned and authorized to administer oaths, affirmations, etc., personally appeared Debra Peebles who, being duly sworn or affirmed, according to law, doth depose and say that she is Billing Manager -Legal Advertising of THE NEWS AND OBSERVER PUBLISHING COMPANY a corporation organized and doing business under the Laws of the State of North Carolina, and publishing a newspaper known as THE NEWS AND OBSERVER, in the City of Raleigh, County and State aforesaid, the said newspaper in which such notice, paper, document, or legal advertisement was published was, at the time of each and every such publication, a newspaper meeting all of the requirements and qualifications of Section 1-597 of the General Statutes of North Carolina and was a qualified newspaper within .the meaning of Section 1-597 of the General Statutes of North Carolina, and that as such she makes this affidavit; that she is familiar with the books, files and business of said corporation and by reference to the files of said publication the attached advertisement for NC DEPT OF DEHNR was inserted in the aforesaid newspaper on dates as follows: 03/29/00 Account Number:' 73370152 books and files of the aforesaid Corporation and publication. 114 . . . . .................... ...... . . 41 Billing Manager -Legal Advertising Sworn or affirmed to, and subscribed before me, this 30 day of MARCH , 2000 AD In Testimony Whereof, I have hereunto set my hand and affixed my official seal, the day and year aforesaid. Notary Public My commission expires 2nd day of July 2000. - LONG TERM MONITORING PLAN REQUEST FORM FACILITY: I`ow vi v� �ehSOv� - NPDES NO.: IVC 0,02v38 - - EXPIRATION DATE: 0/13111` q- REGION: P&E REQUESTOR: PRETREATMENT CONTACT: DATE OF REQUEST: INDICATE THE STATUS OF PRETREATMENT PROGRAM: 1) THE FACILITY HAS NO SIU'S AND SHOULD NOT HAVE PRETREATMENT LANGUAGE. ' 2) THE FACILITY HAS A PREATREATMENT PROGRAM, 3) ADDITIONAL CONDITIONS REGARDING THE PRETREATMENT PROGRAM ATTACHED. PERMITTED FLOW: INDUSTRIAL 4S- SD DOMESTIC Pretreatment Unit Staff (Region) !vD V�jetc��5. 5�-efJl��i'- J A/O ...ClV 5Q DJ TS 5 /V1�3 d) —r. f'4-1 ' OS Gtvre�S /ec�( C'©�� fcf�,.. — J� S�a���o�esper 1 � D le in 1A W W W W W W W in H 1A NOO rr aaa e "4,341, 4 i'�v y" , s o is' 'S 7-1v1F !� czIrIC4I .d Ck? IL ei/e1 j, 7ec e %ash�waf�s ��s �D�D3 l99�i �h� 4c c%a-c,. za"'Apies 4jare eol(ec�ed CY u C c, p / ' T � l s cYo no Y` v/'�` y ak ah� C AI. 7�ie ,r Qr�v�ef2rs are 30D� 7SS) 4111j cis/V � T��� rhalphohuS) Fecal cc Orw, 3 Saw��eS'>¢rWeeKo 0 7of' ( I ,t+r-oSe✓t ''lon4 , A i (15-008). vt e T N(}� 5'a �,► ; �. Se f r"t u s t� Y^u ve 8/2oc& awd Blow! . 2. v + LAB SAMPLE NO.(s): 7820E1-2 Sample (s).,-of WASTEWATER NAM.: JOHN ALT, SR. ORG :- TOWN OF BENSON ,.ADD* "'170 HANNAHCREEK ROAD CSZ FOUR OAKS, NC 27524 of: 3 Marked- - A: 822--03 -INF COMP/3-11-96 C: Date Received: 3-14-96 Date Reported: 5-8'0-:-96 Telephone 919-894-2373 FAX :--919-8941283--- -PO/Job No. PROJECT ID :HEADWORKS"ANALYSI&' B: 822-03 EFF.,COMP/3--13-,9,6--� D: Lab Sample No.=> A: 7820E1 B: 7820E2.C: D.: CAT. NO. ANALYSES UNITS -- ---------------- ---------- EW-020 : ----------------------------------------------- CYANIDE: TOTAL (mg/L) : <0.005 : <0.005 EP-001 : DIGESTION : Yes :.Yes EM- 03 3. 1:, ARSENIC-(GFAAS) (mg/L) : <0.005 : <0.005',.: EM-048 CADMIUM (ICP) (mg/L) <0.005 , : <0.005 :'EM-024 CHROMIUM (ICP) -,(mg/L) .<0.002 : <0.002 .. ..... : EM-029 COPPER (ICP) (mg/L) 0.0.34 0.031 : EM-082.1: LEAD (GFAAS) (mg/L) 0 . P11 : <0.010 : EM-080.1: MERCURY (CVAAS) (mg/L) <0.0002 : <0.0002 : EM-042 : MOLYBDENUM (ICP) (mg/L) 0.0,13 : <0.010 EM-028 : NICKEL (ICP) (mg/L) -<O. 010 : <0.010 EM-034.1: SELENIUM (GFAAS) (mg/L) <0.002 : <0.002 EM-047 : SILVER (ICP) (mg/L)" 0.017 : .0.006 EM-030 : ZINC (ICP) (mg/L) 0.092 0.066 Q.01 Comments: ALL RESULT . S ARE REPORTED ON AN "AS RECEIVED"- BAS Laboratory Contact For Above Report Name : Debbie Collins Title: Head, Water Quality- Section RLuEovirfm JUk- 3 1996 -FACILITIES ASSESSMENT UNIT ve d7 p ii' Va &e X, Manager, EnFviro ental Dept. ----------------- ------ -- ---------------- ---------- SUBMISSION INFO- Analyst(s): No. Containers: Sample Submission: C-O-C: Samp Admin: Pickup: Time: Miles: RUSH ------------------------------------------------- ------------------------- Chemical and Microbiological Analyses: Environmental - Industrial Hygiene Agrichemical Foods - Pharmaceuticals Q 9 FA1R T Southern Vesting & Research Laboratm-ies, Inc. 3809 Airport Drive (919) 237-4175 Fax: (919) 237-9341 Wilson, NC 27896 REPORT OF ANALYSIS LAB SAMPLE NO.(s): 7999E1-2 of: 3 Date Received: 3-21-96 Sample(s) of WASTEWATER Date Reported: 5-30-96 NAM : JOHN; ALT , SR. ORG : TOWN OF BENSON --.. Telephone : 919--894-2373 - ADD ' - : 7 7 0 ' HANNAH CREEK -,'ROAD--'_ ` - ' FAX : 919 - 8 9 4 -12 8 3 CSZ FOUR OAKS., -NC 27524 PO/Job No. PROJECT< ID : HEADWORKS ANALYSIS Marked A: 822-03_7INF-COMP/3-18-96 B: 822-03-EFF COMP/3-20-96 _. C: <, D: Lab Sample_ No.=> A: 7999E1 B: 7999E2 C: D: - CAT : NO. ANALYSES UNITS -------------------------------------------------------------------------------- : EW-020 : CYANIDE: TOTAL (mg/L) <0.005 : <0.00;5 : EP-001 : DIGESTION Yes : Yes . :-EM-033.1: ARSENIC (GFAAS) (mg/L) <0.002 : <0.002 : EM-048 : CADMIUM (ICP) (mg/L) <0.002. : <0.002 : EM-024 :`CHROMIUM-(ICP) (mg/L) : <0.005 : <0.005 : EM-029 COPPER (ICP) (mg/L)-: 0.019 0.017 : EM-082.1: LEAD (GFAAS) (mg/L) : <0.010 : <0.010 - : EM-080.1: MERCURY (CVAAS) (mg/L) : <0.0002 : <0.0002 . : EM-042 : MOLYBDENUM (ICP) (mg/L) : <0.01 : <0.01 . : EM-028 : NICKEL (ICP) (mg/L) : <0.01 : <0.01 : EM-034.1: SELENIUM (GFAAS) (mg/L) <0.002 : <_0.002 : EM-047 : SILVER (ICP) (mg/L) 0.018 : <0.005 . : EM-030 : ZINC (ICP) (mg/L) 0.128 0.051 Comments: ALL RESULTS ARE REPORTED ON -AN "AS RECEIVED" BASIS'. Laboratory Contact For Above Report Revi Name : Debbie Collins - Title: -_Head, Water Quality Section 1 and Environmental Dept. ----- - --------------SUBMISSION INFO(--:�4-----------------------=-==--_ Analyst(s): No. Containers: mple Submission: C-O-C: Samp Admin: Pickup: Time:. Miles: RUSH : ------------------------------------------------------------------------ Chemical and Microbiological Analyses: Environmental Industrial Hygiene Agrichemical Foods • Pharmaceuticals tfJ If S 9` P � . a Southem Testing & Research Laboratofies, Inc. '� � 3809 Airport Drive (919) 237-4175 - Fax: (919) 237-9341 Wilson, NC 27896 9 FA1R '? SAMPLE No.: E8167-002 R E P O R T of A N A L Y S I S Date Reported: 04/24/96 John Alt Sr. Town of Benson 770-Hannah Creek Rd. Phone:(919)894-2373 X Four Oaks NC 27524 Fax: (919)894-1283 P. 0.: _ Client Sample -ID: HEADWORKS ANALYSIS Marks: 822-03-Eff Comp Collected: 03/27/96 09:00 Matrix: WASTEWATER Received: 03/28/96 15:30 Classification: ENV CAT No. ANALYSES MDL RESULT UNITS EW-020 Cyanide: Total 0.005 ND mg/L EW.-.040 .2 -::.Solids c -_Total 2 .329 mg/L EP-020 Distillation: Cyanide Yes EP-001. -.Digestion (I.CP/FAAS) Yes Arsenic (ICP) . N DEM-033 mg/L EM-048 Cadmium (ICP) 0.002 ND mg/L EM-024 Chromium (ICP) 0.005 ND mg/L EM-029 Copper (ICP) 0.005 0.039 mg/L EM-082 Lead (ICP) 0.025 ND mg/L EM-080.1 Mercury (CVAAS) 0.0002 ND mg/L EM-042 Molybdenum (ICP) 0.010 ND mg/L.-. EM-028 Nickel (ICP) 0.010 ND mg/L EM-0.34 Selenium (I.CP). 0.1 ND mg/L EM-047 Silver (ICP) 0.005 0.006 mg/L 01 EM-030 Zinc (ICP) 0.010 0.064, mg/L COMMENTS: ND = Not Detected Laboratory 'Contact (s): Rev' wed and Approved by:- Debbie Collins James B. Cox, III, S. Section Head, Water Quality Manager, Environmental Dept. Page 2 of 2 E8167R.914 (EHl:V2R07.2) 04/24/96 14:12 Chemical and Microbiological Analyses: Environmental - Industrial Hygiene - Agrichemical • Foods • Pharmaceuticals 5r, LAB SAMPLE NO.(s).: 8348E1-2 of: 2 Date Received: 4-4-96 - Sample(s) of WASTEWATER Date Reported: 5-30-96 NAM JOHN ALT, SR. -ORG._:--TOWN•OF_ BENSON . ,-- . - Telephone 919-894--2373___ ADD.: 770 HANNAH CREEK ROAD FAX 919-894-1283 -- CSZ -: FOUR_ -OAKS;- NC. 27524 i PO/Job - No . - : - -- _ ..PROJECT ID--:HEADWORKS .::ANALYSIS. - =Marked As-�822-03-INF-_COMP/4-1-96 B: 822-03-EFF COMP/4-3=96 C: D: Lab --Sample No.=> A: 8348E1-13: 8348E2 C: D:- CAT . NO. ANALYSES UNITS ---------------- -------------------------------------------------- EW-020 CYANIDE: TOTAL (mg/L) : <0.005 -------------- : <0.005 • EP-001 : DIGESTION - ,-_ Yes Yes ... .. ._ .._...,-....._:. __.._ _ EM-033.1: ARSENIC (GFAAS) (mg/L) : <0.-002 : <0.002 . :.EM-048 CADMIUM (ICP) (mg/L) : <0.005 : <0.005 : EM-024 CHROMIUM (ICP) (mg/L) 0.006 : <0.0.05 :'EM-029 COPPER-(ICP) (mg/L) 0.042 0.022 : EM-082.1: LEAD (GFAAS) (mg/L) <0.010 : <0.010 : EM-080.1: MERCURY (CVAAS) (mg/L) 0.0003 <0.0002 . : EM-042 MOLYBDENUM (ICP) (mg/L) 0.006 0.007 : EM-028 NICKEL (ICP) (mg/1) <0.01 <0.01 : EM-034.1: SELENIUM (GFAAS) (mg/L)°...<0.002 <0.002 . : EM-047 : SILVER (ICP) (mg/L) 0.018 <0.005 : EM-03.0 : ZINC (ICP) (mg/L) :. 0.0.80 0.064 Comments: ALL RESULTS ARE REPORTED ON AN "AS RECEIVED" BASIS. Laboratory Contact For Above Report Rev wed and App v Name : Debbie Collins J es B. Cox, II L Title: Head," Water Quality Section :,M ager; Environmental Dept. ---------------------------SUBMISSION I 0-- ------------------------------- Analyst(s): No. Containers: ample Submission: C-O-C: Samp Admin: Pickup: Time: -- Miles: RUSH ------------------------------------------------------------------- Chemical and Microbiological Analyses: Environmental • Industrial Hygiene • Agrichemical • Foods • Pharmaceuticals 0 Hannah Creek r. T (LNBA Data) Agency Station Parameter Date Depth Result Rmk LNBA J5400000 10 8/5/99 11:40 0.32808 25 LNBA J5400000 10 8/19/9911:10 0.32808 26 LNBA J5400000 630 8/5/99 11:40 0.32808 0.01 K LNBA J5400000 300 8/5/99 11:40 0.32808 0.5 K i LNBA J5400000 300 8/19/99 11:10 0.32808 0.5 K c LNBA J5400000 625 7/8/99 11:20 0.32808 2.6 LNBA J5400000 10 7/8/99 11:20 0.32808 26 LNBA J5400000 10 7/22/9911:20 0.32808 26 LNBA J5400000 630 7/8/99 11:20 0.32808 0.02 K LNBA J5400000 300 7/8/99 11:20 0.32808 0.5 K LNBA J5400000 300 7/22/99 11:20 0.32808 0.5 K LNBA J5400000 610 8/5/99 11:40 0.32808 0.02 LNBA J5400000 665 8/5/99 11:40 0.32808 0.71 LNBA J5400000 625 8/5/99 11:40 0.32808 1.7 LNBA J5400000 625 6/2/9911:40 0.32808 1 LNBA J5400000 10 6/23/9911:00 0.32808 20 LNBA J5400000 10 6/2/9911:40 0.32808 23 LNBA J5400000 610 6/2/9911:40 0.32808 0.01 K LNBA J5400000 610 7/8/99 11:20 0.32808 0.17 LNBA J5400000 665 7/8/99 11:20 0.32808 0.87 LNBA J5400000 625 5/4/9913:20 0.32808 1 LNBA J5400000 300 5/18/9911:35 0.32808 2.4 LNBA J5400000 300 5/4/9913:20 0.32808 3.4 LNBA J5400000 10 5/4/9913:20 0.32808 17 LNBA J5400000 10 5/18/9911:35 0.32808 19 LNBA J5400000 630 6/2/9911:40 0.32808 0.15 LNBA J5400000 665 6/2/9911:40 0.32808 0.2 LNBA J5400000 300 6/23/9911:00 0.32808 0.6 LNBA J5400000 300 6/2/9911:40 0.32808 0.7 LNBA J5400000 10 1/10/9511:35 0.49199 5 LNBA J5400000 300 1/10/9511:35 0.49199 2.6 LNBA J5400000 610 1/10/95 11:35 0.49199 0.3 K LNBA J5400000 625 1/10/9511:35 0.49199 0.55 LNBA J5400000 630 1 /10/95 11:35 0.49199 0.52 LNBA J5400000 665 1/10/9511:35 0.49199 0.07 LNBA J5400000 10 2/2/9512:50 0.49199 5 LNBA J5400000 300 2/2/9512:50 0.49199 10.2 LNBA J5400000 610 2/2/95 12:50 0.49199 0.3 K LNBA J5400000 625 2/2/9512:50 0.49199 0.37 LNBA J5400000 630 2/2/9512:50 0.49199 1.19 LNBA J5400000 665 2/2/9512:50 0.49199 0.07 LNBA J5400000 10 3/10/9512:05 0.49199 6.5 LNBA J5400000 300 3/10/9512:05 0.49199 9.8' LNBA J5400000 610 3/10/95 12:05 0.49199 0.3 K LNBA J5400000 625 3/10/9512:05 0.49199 0.3 LNBA J5400000 630 3/10/9512:05 0.49199 1.13 LNBA J5400000 665 3/10/9512:05 0.49199 0.1 LNBA J5400000 10 4/8/9514:05 0.49199 10 LNBA J5400000 300 4/8/9514:05 0.49199 7 LNBA J5400000 610 4/8/95 14:05 0.49199 0.3 K LNBA J5400000 625 4/8/9514:05 0.49199 0.46 i% a/9 5 - 8/91 - r �►� �04 G/Z % dw LC-S 40 -74 54--10 Hannah Creek (LNBA Data) Agency Station Parameter Date Depth Result Rmk LNBA J5400000 630 4/8/9514:05 0.49199 0.77 LNBA J5400000 665 4/8/9514:05 0.49199 0.1 LNBA J5400000 10 5/8/95 10:45 0.49199 16 LNBA J5400000 300 5/8/95 10:45 0.49199 6--m8j LNBA J5400000 625 3/2/9911:15 0.32808 1.9 LNBA J5400000 630 3/2/9911:15 0.32808 0.62 LNBA J5400000 665 3/2/9911:15 0.32808 0.06 LNBA J5400000 610 5/8/95 10:45 0.49199 0.3 K LNBA J5400000 625 5/8/95 10:45 0.49199 0.2 K LNBA J5400000 630 5/8/95 10:45 0.49199 0.42 LNBA J5400000 665 5/8/95 10:45 0.49199 0.14 LNBA J5400000 10 5/22/9515:25 0.49199 19 LNBA J5400000 300 5/22/95 15:25 0.49199 7.9 LNBA J5400000 10 6/7/95 11:55 0.49199 19 LNBA J5400000 300 6/7/95 11:55 0.49199 LNBA J5400000 610 6/7/95 11:55 0.49199 0.3 K LNBA J5400000 625 6/7/95 11:55 0.49199 0.5 K LNBA J5400000 630 6/7/95 11:55 0.49199 0.35 LNBA J5400000 665 6/7/95 11:55 0.49199 0.24 LNBA J5400000 10 6/20/9516:00 0.49199 20 LNBA J5400000 300 6/20/9516:00 0.49199 7.5' LNBA J5400000 10 7/12/95 12:20 0.49199 22 LNBA J5400000 300 7/12/95 12:20 0.49199 2 LNBA J5400000 610 7/12/95 12:20 0.49199 0.3 K LNBA J5400000 625 7/12/95 12:20 0.49199 0.5 K LNBA J5400000 630 7/12/95 12:20 0.49199 0.05 K LNBA J5400000 665 7/12/95 12:20 0.49199 0.34 LNBA J5400000 10 7/21/95 2:10 0.49199 25.5 LNBA J5400000 300 7/21/95 2:10 0.49199 1.2 LNBA J5400000 10 8/2/9512:25 0.49199 s 25 LNBA J5400000 300 8/2/9512:25 0.49199 1.8, o LNBA J5400000 610 8/2/9512:25 0.49199 0.51 LNBA J5400000 625 8/2/9512:25 0.49199 1.39 LNBA J5400000 630 8/2/95 12:25 0.49199 0.05 K LNBA J5400000 665 8/2/9512:25 0.49199 0.41 LNBA J5400000 10 8/16/951:35 0.49199 27 LNBA J5400000 300 8/16/95 1:35 0.49199 3-8- LNBA J5400000 10 9/13/9513:15 0.49199 21 LNBA J5400000 300 9/13/9513:15 0.49199 � LNBA J5400000 610 9/13/95 13:15 0.49199 0.3 K LNBA J5400000 625 9/13/9513:15 0.49199 1.46 LNBA J5400000 630 9/13/9513:15 0.49199 0.06 LNBA J5400000 665 9/13/9513:15 0.49199 0.8 LNBA J5400000 10 9/21/95 2:30 0.49199 20 LNBA J5400000 300 9/21/95 2:30 0.49199 3 LNBA J5400000 10 10/4/9512:45 0.49199 18 LNBA J5400000 300 10/4/9512:45 0.49199 LNBA J5400000 610 10/4/95 12:45 0.49199 0.3 K LNBA J5400000 625 10/4/9512:45 0.49199 2.41 LNBA J5400000 630 10/4/9512:45 0.49199 0.08 LNBA J5400000 665 10/4/9512:45 0.49199 0.16 2 Hannah Creek (LNBA Data) Agency Station Parameter Date Depth Result Rmk LNBA J5400000 10 11/10/95 11:25 0.49199 6 LNBA J5400000 300 11/10/95 11:25 0.49199 7.8 , LNBA J5400000 610 11/10/95 11:25 0.49199 0.3 K LNBA J5400000 625 11/10/95 11:25 0.49199 0.6 LNBA J5400000 630 11/10/95 11:25 0.49199 0.82 LNBA J5400000 665 11/10/95 11:25 0.49199 0.06 LNBA J5400000 10 12/6/9511:30 0.49199 8 LNBA J5400000 300 12/6/9511:30 0.49199 LNBA J5400000 610 12/6/95 11:30 0.49199 0.3 K LNBA J5400000 625 12/6/9511:30 0.49199 0.73 LNBA J5400000 630 12/6/9511:30 0.49199 1.06 LNBA J5400000 665 12/6/9511:30 0.49199 0.14 LNBA J5400000 10 1 /5/96 12:20 0.49199 _2 LNBA J5400000 300 1/5/9612:20 0.49199 9.6_. LNBA J5400000 610 1/5/96 12:20 0.49199 0.3 K LNBA J5400000 625 1/5/9612:20 0.49199 0.6 LNBA J5400000 630 1/5/9612:20 0.49199 1.09 LNBA J5400000 665 1/5/9612:20 0.49199 0.12 LNBA J5400000 10 2/8/96 12:20 0.49199 3 LNBA J5400000 300 2/8/96 12:20 0.49199 11.8 LNBA J5400000 610 2/8/96 12:20 0.49199 0.3 K LNBA J5400000 625 2/8/96 12:20 0.49199 0.5 K LNBA J5400000 630 2/8/96 12:20 0.49199 1.17 LNBA J5400000 665 2/8/96 12:20 0.49199 0.05 LNBA J5400000 10 3/6/9613:05 0.49199 11 LNBA J5400000 300 3/6/9613:05 0.49199 8 LNBA J5400000 610 3/6/96 13:05 0.49199 0.3 K LNBA J5400000 625 3/6/9613:05 0.49199 0.56 LNBA J5400000 630 3/6/9613:05 0.49199 1.27 LNBA J5400000 665 3/6/9613:05 0.49199 0.15 LNBA J5400000 10 4/3/96 13:35 0.49199 13 LNBA J5400000 300 4/3/96 13:35 0.49199 11.2 LNBA J5400000 10 4/15/9911:50 0.32808 17 LNBA J5400000 610 4/3/96 13:35 0.49199 0.3 K LNBA J5400000 625 4/3/96 13:35 0.49199 0.5 K LNBA J5400000 630 4/3/96 13:35 0.49199 3.45 LNBA J5400000 665 4/3/96 13:35 0.49199 0.1 LNBA J5400000 10 5/8/9613:55 0.49199 17.5 LNBA J5400000 300 5/8/9613:55 0.49199 7.8 LNBA J5400000 610 5/8/96 13:55 0.49199 0.3 K LNBA J5400000 625 5/8/9613:55 0.49199 0.59 LNBA J5400000 630 5/8/9613:55 0.49199 0.33 LNBA J5400000 665 5/8/9613:55 0.49199 0.12 LNBA J5400000 10 5/18/9611:40 0.49199 19 LNBA J5400000 300 5/18/9611:40 0.49199 7 LNBA J5400000 10 6/5/9610:00 0.49199 19 LNBA J5400000 300 6/5/9610:00 0.49199 3.8 0 LNBA J5400000 610 6/5/96 10:00 0.49199 0.3 K LNBA J5400000 625 6/5/9610:00 0.49199 0.68 LNBA J5400000 630 6/5/9610:00 0.49199 0.15 LNBA J5400000 665 6/5/9610:00 0.49199 0.16 3 Hannah Creek (LNBA Data) Agency Station Parameter Date Depth Result Rmk LNBA J5400000 10 6/15/9615:20 0.49199 26 LNBA J5400000 300 6/15/9615:20 0.49199 6.6 LNBA J5400000 10 7/3/9611:10 0.49199 23.5 LNBA J5400000 300 7/3/9611:10 0.49199 3.2 W LNBA J5400000 610 7/3/96 11:10 0.49199 0.3 K LNBA J5400000 625 7/3/9611:10 0.49199 1.14 LNBA J5400000 630 7/3/9611:10 0.49199 0.27 LNBA J5400000 665 7/3/9611:10 0.49199 0.23 LNBA J5400000 10 7/14/9613:50 0.49199 23 LNBA J5400000 300 7/14/9613:50 0.49199 6.4 LNBA J5400000 10 8/7/96 12:05 0.49199 21 LNBA J5400000 300 8/7/96 12:05 0.49199 5.3 LNBA J5400000 610 8/7/96 12:05 0.49199 0.3 K LNBA J5400000 625 8/7/96 12:05 0.49199 0.77 LNBA J5400000 630 8/7/96 12:05 0.49199 0.05 K LNBA J5400000 665 8/7/96 12:05 0.49199 0.29 LNBA J5400000 10 8/19/96 21:30 0.49199 23 LNBA J5400000 300 8/19/96 21:30 0.49199 5.6 LNBA J5400000 10 10/10/9616:45 0.49199 20 LNBA J5400000 300 10/10/9616:45 0.49199 5.6 LNBA J5400000 610 10/10/9616:45 0.49199 0.24 LNBA J5400000 625 10/10/9616:45 0.49199 0.76 LNBA J5400000 630 10/10/9616:45 0.49199 0.5 LNBA J5400000 665 10/10/9616:45 0.49199 0.09 LNBA J5400000 10 11/15/9614:15 0.49199 7.5 LNBA J5400000 300 11/15/9614:15 0.49199 7.8 LNBA J5400000 610 11/15/9614:15 0.49199 0.06 LNBA J5400000 625 11/15/96 14:15 0.49199 0.5 K LNBA J5400000 630 11 /15/96 14:15 0.49199 0.16 LNBA J5400000 665 11 /15/96 14:15 0.49199 0.05 K LNBA J5400000 10 12/12/96 13:30 0.49199 13 LNBA J5400000 300 12/12/96 13:30 0.49199 7.2 LNBA J5400000 610 12/12/96 13-30 0.49199 0.3 K LNBA J5400000 625 12/12/96 13:30 0.49199 0.5 K LNBA J5400000 630 12/12/96 13:30 0.49199 0.43 LNBA J5400000 665 12/12/96 13:30 0.49199 0.05 K LNBA J5400000 10 2/5/9713:30 0.49199 11.9 LNBA J5400000 300 2/5/9713:30 0.49199 7.2 LNBA J5400000 610 2/5/97 13:30 0.49199 0.05 K LNBA J5400000 625 2/5/9713:30 0.49199 0.65 LNBA J5400000 630 2/5/9713:30 0.49199 0.76 LNBA J5400000 665 2/5/9713:30 0.49199 0.06 LNBA J5400000 10 3/5/9714:00 0.49199 15.5 LNBA J5400000 300 3/5/9714:00 0.49199 8.5 LNBA J5400000 610 3/5/97 14:00 0.49199 0.05 K LNBA J5400000 625 3/5/9714:00 0.49199 0.64 LNBA J5400000 630 3/5/9714:00 0.49199 0.2 LNBA J5400000 665 3/5/9714:00 0.49199 0.04 LNBA J5400000 10 4/2/9711:00 0.49199 12 LNBA J5400000 300 4/2/9711:00 0.49199 6.2 LNBA J5400000 610 4/2/97 11:00 0.49199 0.05 K 4 Hannah Creek (LNBA Data) Agency Station Parameter Date Depth Result Rmk LNBA J5400000 625 4/2/97 11:00 0.49199 0.5 K LNBA J5400000 630 4/2/9711:00 0.49199 0.57 LNBA J5400000 665 4/2/9711:00 0.49199 0.04 LNBA J5400000 10 5/7/9710:40 0.49199 16.6 LNBA J5400000 300 5/7/9710:40 0.49199 6 LNBA J5400000 610 5/7/9710:40 0.49199 0.03 LNBA J5400000 625 5/7/9710:40 0.49199 0.38 LNBA J5400000 630 5/7/9710:40 0.49199 0.11 LNBA J5400000 665 5/7/9710:40 0.49199 0.07 LNBA J5400000 300 4/15/9911:50 0.32808 4.2 LNBA J5400000 10 5/19/97 9:50 0.49199 19.4 LNBA J5400000 300 5/19/97 9:50 0.49199 2.4 ►' LNBA J5400000 10 6/4/9710:30 0.49199 18.7 LNBA J5400000 300 6/4/9710:30 0.49199 2.2 LNBA J5400000 610 6/4/9710:30 0.49199 0.03 LNBA J5400000 625 6/4/9710:30 0.49199 0.53 LNBA J5400000 630 6/4/9710:30 0.49199 0.08 LNBA J5400000 665 6/4/9710:30 0.49199 0.16 LNBA J5400000 10 6/12/9711:25 0.49199 20.4 LNBA J5400000 300 6/12/9711:25 0.49199 4 a LNBA J5400000 10 7/2/9713:00 0.49199 23.3 LNBA J5400000 300 7/2/9713:00 0.49199 3.5 LNBA J5400000 610 7/2/9713:00 0.49199 0.35 LNBA J5400000 625 7/2/9713:00 0.49199 2.03 LNBA J5400000 630 7/2/9713:00 0.49199 0.01 K LNBA J5400000 665 7/2/9713:00 0.49199 0.55 LNBA J5400000 10 7/11/9711:05 0.49199 24.1 LNBA J5400000 300 7/11/97 11:05 0.49199 0.5 K t LNBA J5400000 10 8/5/9711:25 0.49199 24.3 LNBA J5400000 300 8/5/9711:25 0.49199 1.5 LNBA J5400000 610 8/5/9711:25 0.49199 0.2 LNBA J5400000 625 8/5/9711:25 0.49199 0.9 LNBA J5400000 630 8/5/9711:25 0.49199 0.09 LNBA J5400000 665 8/5/9711:25 0.49199 0.37 LNBA J5400000 10 8/14/9711:10 0.49199 25.9 LNBA J5400000 300 8/14/9711:10 0.49199 0.6 c LNBA J5400000 10 9/4/9711:45 0.49199 22.4 LNBA J5400000 300 9/4/9711:45 0.49199 0.8 r LNBA J5400000 610 9/4/9711:45 0.49199 0.3 LNBA J5400000 625 9/4/9711:45 0.49199 1.55 LNBA J5400000 630 9/4/9711:45 0.49199 0.1 LNBA J5400000 665 9/4/9711:45 0.49199 0.25 LNBA J5400000 10 9/17/9712:30 0.49199 22.9 LNBA J5400000 300 9/17/9712:30 0.49199 1.4 LNBA J5400000 10 10/8/9710:10 0.49199 18.8 LNBA J5400000 300 10/8/9710:10 0.49199 1.8 LNBA J5400000 625 4/15/9911:50 0.32808 0.7 LNBA J5400000 630 4/15/9911:50 0.32808 0.38 LNBA J5400000 665 4/15/9911:50 0.32808 0.17 LNBA J5400000 610 10/8/9710:10 0.49199 0.07 LNBA J5400000 625 10/8/9710:10 0.49199 0.36 5 Hannah Creek (LNBA Data) Agency Station Parameter Date Depth Result Rmk LNBA J5400000 630 10/8/9710:10 0.49199 0.08 LNBA J5400000 665 10/8/9710:10 0.49199 0.12 LNBA J5400000 10 11/5/9711:45 0.49199 13 LNBA J5400000 300 11/5/9711:45 0.49199 3.8 LNBA J5400000 610 11/5/9711:45 0.49199 0.02 LNBA J5400000 625 11/5/9711:45 0.49199 0.49 LNBA J5400000 630 11/5/9711:45 0.49199 0.15 LNBA J5400000 665 11 /5/97 11:45 0.49199 0.07 LNBA J5400000 10 12/4/9712:35 0.32808 14.9 LNBA J5400000 300 12/4/9712:35 0.32808 8.9 LNBA J5400000 610 12/4/9712:35 0.32808 0.01 K LNBA J5400000 625 12/4/9712:35 0.32808 0.4 LNBA J5400000 630 12/4/9712:35 0.32808 0.09 LNBA J5400000 665 12/4/9712:35 0.32808 0.04 LNBA J5400000 10 1/6/9814:00 0.32808 13 LNBA J5400000 300 1/6/9814:00 0.32808 12.2 LNBA J5400000 610 1/6/9814:00 0.32808 0.15 LNBA J5400000 625 1/6/9814:00 0.32808 0.1 K LNBA J5400000 630 1/6/9814:00 0.32808 0.28 LNBA J5400000 665 1/6/9814:00 0.32808 0.02 LNBA J5400000 10 2/9/9811:10 0.32808 7 LNBA J5400000 300 2/9/9811:10 0.32808 10.5 LNBA J5400000 610 2/9/9811:10 0.32808 0.02 LNBA J5400000 625 2/9/9811:10 0.32808 0.3 LNBA J5400000 630 2/9/9811:10 0.32808 0.57 LNBA J5400000 665 2/9/9811:10 0.32808 0.09 LNBA J5400000 10 3/5/9811:55 0.32808 9.8 LNBA J5400000 300 3/5/9811:55 0.32808 11.4 LNBA J5400000 610 3/5/9811:55 0.32808 0.02 LNBA J5400000 625 3/5/9811:55 0.32808 0.6 LNBA J5400000 630 3/5/9811:55 0.32808 0.43 LNBA J5400000 665 3/5/9811:55 0.32808 0.01 LNBA J5400000 10 4/3/9811:20 0.32808 19 LNBA J5400000 300 4/3/9811:20 0.32808 6.2 LNBA J5400000 610 4/3/9811:20 0.32808 0.03 LNBA J5400000 625 4/3/9811:20 0.32808 1.4 LNBA J5400000 630 4/3/9811:20 0.32808 0.33 LNBA J5400000 665 4/3/9811:20 0.32808 0.07 LNBA J5400000 10 5/5/9811:35 0.32808 19 LNBA J5400000 300 5/5/9811:35 0.32808 5.8 LNBA J5400000 610 4/15/9911:50 0.32808 0.05 LNBA J5400000 610 5/4/9913:20 0.32808 0.03 LNBA J5400000 630 5/4/9913:20 0.32808 0.03 LNBA J5400000 610 5/5/9811:35 0.32808 0.08 LNBA J5400000 625 5/5/9811:35 0.32808 0.23 LNBA J5400000 630 5/5/9811:35 0.32808 0.16 LNBA J5400000 665 5/5/9811:35 0.32808 0.09 LNBA J5400000 10 5/19/9811:20 0.32808 22 LNBA J5400000 300 5/19/9811:20 0.32808 6 LNBA J5400000 10 6/2/9812:35 0.32808 25 LNBA J5400000 300 6/2/9812:35 0.32808 7.7 M. Hannah Creek (LNBA Data) Agency Station Parameter Date Depth Result Rmk LNBA J5400000 610 6/2/9812:35 0.32808 0.11 LNBA J5400000 625 6/2/9812:35 0.32808 0.8 LNBA J5400000 630 6/2/9812:35 0.32808 0.1 LNBA J5400000 665 6/2/9812:35 0.32808 0.18 LNBA J5400000 10 6/16/9811:50 0.32808 26 LNBA J5400000 300 6/16/9811:50 0.32808 4.4 r LNBA J5400000 10 7/7/9812:10 0.32808 25 LNBA J5400000 300 7/7/9812:10 0.32808 1.3 r LNBA J5400000 610 7/7/9812:10 0.32808 0.2 LNBA J5400000 625 7/7/9812:10 0.32808 3.15 LNBA J5400000 630 7/7/9812:10 0.32808 0.04 LNBA J5400000 665 7/7/9812:10 0.32808 0.21 LNBA J5400000 10 7/21/9811:00 0.32808 28 LNBA J5400000 300 7/21/9811:00 0.32808 4 LNBA J5400000 10 8/4/9811:50 0.32808 23 LNBA J5400000 300 8/4/9811:50 0.32808 0.5 6 LNBA J5400000 610 8/4/9811:50 0.32808 0.05 LNBA J5400000 625 8/4/9811:50 0.32808 0.6 LNBA J5400000 630 8/4/9811:50 0.32808 0.01 K LNBA J5400000 665 8/4/9811:50 0.32808 0.42 LNBA J5400000 10 8/18/9811:35 0.32808 25 LNBA J5400000 300 8/18/98 11:35 0.32808 0.5 K r LNBA J5400000 10 10/13/9812:00 0.32808 24 LNBA J5400000 300 10/13/9812:00 0.32808 1.2 Q LNBA J5400000 610 10/13/9812:00 0.32808 0.3 LNBA J5400000 625 10/13/9812:00 0.32808 1.28 LNBA J5400000 630 10/13/9812:00 0.32808 0.11 LNBA J5400000 665 10/13/9812:00 0.32808 0.88 LNBA J5400000 10 11/3/9811:00 0.32808 14.5 LNBA J5400000 300 11/3/9811:00 0.32808 1.7 LNBA J5400000 610 11/3/9811:00 0.32808 0.05 LNBA J5400000 665 5/4/9913:20 0.32808 0.09 LNBA J5400000 625 11/3/9811:00 0.32808 0.5 LNBA J5400000 630 11/3/9811:00 0.32808 0.15 LNBA J5400000 665 11/3/9811:00 0.32808 0.08 LNBA J5400000 10 12/8/9811:40 0.32808 16.5 LNBA J5400000 300 12/8/9811:40 0.32808 1.5 a LNBA J5400000 610 12/8/9811:40 0.32808 0.02 LNBA J5400000 625 12/8/9811:40 0.32808 0.9 LNBA J5400000 630 12/8/9811:40 0.32808 0.18 LNBA J5400000 665 12/8/9811:40 0.32808 0.14 LNBA J5400000 610 2/4/9911:50 0.32808 0.01 K LNBA J5400000 610 1/6/9911:35 0.32808 0.04 LNBA J5400000 665 1/6/9911:35 0.32808 0.24 LNBA J5400000 630 1/6/9911:35 0.32808 0.67 LNBA J5400000 10 1/6/9911:35 0.32808 1.5 LNBA J5400000 625 1/6/9911:35 0.32808 4 LNBA J5400000 300 1/6/9911:35 0.32808 8.9 LNBA J5400000 610 3/2/9911:15 0.32808 0.01 K LNBA J5400000 10 3/2/9911:15 0.32808 9 LNBA J5400000 300 3/2/9911:15 0.32808 6.2 �► 7 Hannah Creek (LNBA Data) Agency Station LNBA J5400000 LNBA J5400000 LNBA J5400000 LNBA J5400000 LNBA J5400000 Parameter Date 665 2/4/9911:50 630 2/4/9911:50 625 2/4/9911:50 300 2/4/9911:50 10 2/4/9911:50 Depth Result Rmk 0.32808 0.05 0.32808 0.36 0.32808 0.6 0.32808 4.6 0.32808 11 L.i July 21, 1998 The Mr. Charles H. Weaver, Jr. Wooten NPDES Permits Group Company NCDENR-DWQ P.O. Box 29535 Raleigh, North Carolina 27626-0535 Engineering Re: Town of Benson NPDES Permit Renewal Application Additions Planning NPDES No. NCO020389 Architecture TWC No. 2293 Dear Mr. Weaver: Pursuant to our conversation of this morning, in reference to additions/corrections for the recently submitted NPDES renewal application for the Town of Benson, we offer the following (corresponding to numbers as listed in the NPDES application): 1) Page I-2, item 5 (Facility Location): The street address for the wastewater treatment plant needs to be modified. The updated street address is as 120 N. Boylan Avenue follows: Raleigh, NC Benson Wastewater Treatment Plant 27603 770 Hannah Creek Road Four Oaks, NC 27524 2) Page II-3, item 11 a (Discharge Treatment Description): Several process units need to be added to the description. The final description shall read as 919-828-0531 follows: Fax:919-834-3589 Treatment consists of flow equalization, a bar screen, flow meter, grit removal, influent pumping station, three (3) aeration and oxidation ditches, four (4) clarifiers, chemical (alum) addition for phosphorous removal, tertiary filters, gas chlorination, dechlorination, and post aeration. Sludge is discharged into a concrete aerated sludge holding basin for stabilization and storage, prior to land application. 3) Page H-4, item 11 b (Discharge Treatment Codes): Codes for the additional treatment units have been added. The final description codes shall read as follows: J, S, M, G, SC, APO, N, FSR, PG, Post -air, DA, XD Please make a note of these items in the application packages and should you have any questions concerning this matter, please feel free to call. Sincerely, THE WOOTEN COMPANY Since 1936 E. Eric Mills, P.E. cc: Mr. Keith Langdon, Town of Benson Mr. Jack Alt, Town of Benson OF at, MAYOR v >k DON H. JOHNSON COMMISSIONERS NATHAN B. BLACKMON 'PTH CAROB\ RAY G. SMITH JACK R. LITTLETON UPRE KENNITH M.. DUPREE TOWN OF BENSON LINDELL NORDAN P.O. R J.W. PARRISH, JR. H 303 EAST CHURCH STREET NORTH CAROLINA 27504 (919) 894-3553 FAX (919) 894-1283 March 9, 1998 North Carolina DENR Kenneth Schuster, P.E. Dear Mr. Schuster; TOWN ADMINISTRATOR KEITH R. LANGDON TowN CLERK CAROLYN A. NORDAN, CMC TAX COLLECTOR ROSALIE G. WEST TOWN ATTORNEY DONALD A. PARKER This Letter is in response to your letter in February 20, requesting an explanation of the events of January 23. I will address each point in the following paragraphs. Your first point was that you could not meet Mr. Alt's request because this would " constitute an illegal discharge". Our permit under section C allows and permits such an action when there is a danger to property or life. If the walls had failed, two homes and a bridge would have been imperiled by the on rush of water from the deluge. . When the overflow of water occurred at the grit chamber, there was a supervisor on top of the filters who was watching the chamber and he reacted quickly to minimize the overflow. The policy that allows septic haulers to dump into our system has been modified to eliminate any extra flows into the plant during times of extreme weather. We do no have any written or oral recommendations concerning the freeboard depth our lagoons. We have relied upon the operators' judgement as to what was suitable working depth. In this situation, we had rains that were equivalent to those during hurricane fran and coupled with high flows into the plant there was no way to pump from the lagoons into plant and lower the levels in the lagoons to protect the integrity of the walls. Mr. Alt has sealed the valves and they have not been opened since Hurricane Fran as per your departments' instruction. There is a section of the lagoon wall that had some water overflow. This was inspected and tested and no problems were found. The section of the wall that this occurs at is lower than any other section. Years ago this part of the wall was used by a construction company to store dirt from excavations at the plant. When they remove the dirt from the area for back filling they removed a few inches too much and this section the wall be brought back to its original height. We are in the process of adding suitable dirt to this low area to prevent any overflows in future. This area should be corrected__ hv_, th_e week ending March 13, 1998. The town is currently pursuing an I and I elimination strategy that is estimated to cost $950,000.00 and will impact about 20% of our system. It is evident that we have problems with this system and I will require a lot time and money to repair. The town has pursued a conservative strategy of having the plant rerated in order to no over -burden our citizens with debt. We started this process some 18 months and have been repeatedly held up by your department. This re -rating would be sufficient to handle the needs of capacity for our plant for 3-5 years. This would allow the town time to retire its present bond debt and be in a position to finance a full expansion without a severe impact upon its ratepayers. We are ready to begin the planning process but; again, your department has held up our engineers due to an inability to provide us with data concerning \nitrogen removal requirements for our plant. I would say that HB 515 mandates a 301/6 reduction of nitrogen from 1995 levels and our plant has already achieved more than that and is working with the LNRB to make even more reductions. _ T ---------------- I ope at t 's letter explains our situation and if you need further information please contact Town Manager Keith R. Langdon or me at (919) 894-3553. Sincerely, j Abn�hnson Mayor ' DHJ/cros schuster-ncdenr To: Permits and Engineering Unit Water Quality Section Attention: NPDES STAFF REPORT AND RECOMMENDATION County Johnston Permit No. NC�10020389 /,�.j,346e�e4! PART I - GENERAL INFORMATION N N MAY 1999 W 1. Facility and Address : Town of Benson WWTP N RECEIVED, Post Office Box 69 N Watet WRY cn Benson, NC 27504 t9c, Ptatteatment cp" G ✓� a, i' Q' 2. Date of :January 29, 1999 �tZLZO'L6 3. Report Prepared by: S. Mitchell 4. Persons Contacted and Telephone Number:Mr. John Alt 919-894-2373 S. Directions to Site:Highway 50 So thru Benson, left on SR 1143, left on SR 1141, left on entrance road before I 95 6. Discharge Point(s), List for all discharge points: Latitude: S° 3' Longitude: 7803 0 ' 3 0" U.S. Quad No.F 24 NE Quad Name:Benson 7. Site size and expansion area consistent with application ? _XX_ Yes No If No, explain: 8. Topography (relationship to flood plain included):Flat 9. Location of nearest dwelling:greater than 100 meteres 10. Receiving stream or affected surface waters: Hannah Creek a. Classification:C NSW b. River Basin and Subbasin No.: 03-04-04 NEU C. Describe receiving stream features and pertinent downstream uses:Swamp PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS C ' 1. a. Volume of Wastewater.to be permitted:-A--5—MGD b. What is the current permitted capacity of the Waste Water Treatment facility?1.5 MGD C. Actual treatment capacity of the current facility (current design capacity)?1.5 MGD d. Please provide a description of existing or substantially constructed wastewater treatment facilities: Mechanical bar scree and grit removal, manual bar screen with Parschall flume, splitter box, 3 oxidation ditches, 4 clarifiers, tertiary filters, chlorine disinfection and con/tact chamber, aerated sludge lagoon, and 2 stabilization lagoons. e. Please provide a description of proposed wastewater treatment facilities:Proposed system to include enhanced nitrogen removal. (See SOC) f. Possible toxic impacts to surface waters:Chlorine. 2. Residuals handling and utilization/disposal scheme:As necessary and in approved manner under Permit WQ0012514. 3. Treatment plant classification:Class 3 4. SIC Code(s):4952 Wastewater Codes Primary _01_ 78 Main Treatment Unit Code: 101 3 PART III - OTHER PERTINENT INFORMATION 1. Is this facility being constructed with Construction Grant Funds or are any public monies involved. (municipals only)?No 2. Special monitoring or limitations (including toxicity) requests:None 3. Alternative Analysis Evaluation: Has the facility evaluated all of the non -discharge options available. Please provide regional perspective for each option evaluated. Spray Irrigation:No land available Connection to Regional Sewer System:N/A Subsurface:N/A Other disposal options:No alternatives available. 5. Other Special Items: PART IV - EVALUATION AND RECOMMENDATIONS The most recent inspection of this facility indicated complinace with the terms �d regulations contained in the discharge permit. The plant appeared to be well maintained and in good operational condition. Therefore the Raleigh Regional Office recommends the reissuance of the discharge permit. TDate Signature of report preparer TIC61 I��_ Date Water Quality Regional Supervisor III ` / >/ ,• � 1 _ •. @ 'ca J 263 •rye` _ ^' / `'•./ 9 :!' : I --' �0 ��� Pe; 222 3922 .� 25' ✓`�/ :Cem38 i 5 rc 9 i _Per^ '—�'__-7� — � \ ICY —. • " � � - ` ' Hannah i'rcf•k Ch•' / i J L• ; ` _ r - _ _ _ _ ' ✓�\ ! i i/ ✓/ South Johnston? 3921 S High ch. _ •',1 Sc •I�'/� Cemel 179 \ 65 if CO Co / r — 2,98 Sewage Loney ibis osal P ds it//• �O r •� ��2°°/ p • / /: 234 hh _ •� � � _ _,;_=�I Cem •,• '� 222 r96 .-.. \\ Cem.. 724 725 726000m.E... • •32'30" 'moo ROAD CLASSIFICATION L Light -duty road• hard or ° v MILE Primary highway, s� .s hard surface. improved surface s4 s Secondary highway, — Unimproved road s�o hard surface — --- ' Interstate Route U. S. Route State Route a- Fd�R M2 The October 24, 1997 ` Wooten Mr. Don Safrit br Company Assistant Chief POINT SOURCE BRANCH Technical Support Branch Engineering NCDEHNR-DWQP.O. Box 29535 Planning Raleigh, N.C. 27626-0535 Architecture Re: Speculative Limits Request Benson Wastewater Treatment Plant NPDES Permit No. NCO020389 TWC No. 2293 Dear Mr. Safrit: We are writing on behalf of the Town of Benson to request speculative limits for 2 sites of discharge for the existing Benson Wastewater Treatment Plant. A map showing the existing and proposed discharge location is enclosed. This plant, 120 N. Boylan Avenue which operates under NPDES Permit No. NC0026051, is permitted at an average Raleigh, NC daily flow of 1.5 million gallons per day GD and discharges to Hannah Creek 27603 y g p y� ) g in the Neuse River Basin (labeled "Existing Discharge Point"). The other proposed location for discharge is in Mingo Swamp, which is in the Cape Fear River Basin (labeled "Proposed Discharge Point"). Speculative limits are requested for a flow of 2.0 MGD at both locations. On 919 828 0531 Mingo Swamp, if the Division has any recommendations as to alternative discharge points in the vicinity, we would entertain and investigate these alternative locations. We asked Mr. Curtis Weaver of the USGS to provide background flow information at the Mingo Swamp location. Mr. Weaver informed us that his office had flow data for a point on Mingo Swamp, southeast of Dunn. Giving us the drainage area of our proposed discharge location and the Dunn -Mingo Swamp location, he suggested that we proportion the given flow information to back out flow estimates for our desired point. We have done that on the following page. If you have any questions or require any additional information, please contact us at 828-0531. Sincerely, THE WOOTEN COMPANY E. Eric Mills Enclosures Since 1936 cc: Mr. Keith Langdon, Town of Benson (w/enclosures) STREAMFLOW ESTIMATES FOR PROPOSED MINGO SWAMP. DISCHARGE Town of Benson, N.C. In order to estimate streamflow data for our proposed discharge location on Mingo'Swamp, data was acquired from an USGS stream gaging station just southeast of Dunn, NC. By using the proportion of the drainage area of the known data and the drainage area of our proposed discharge location, the streamflow data for the proposed location was approximated. This method of approximation was suggested to us by Mr. Curtis Weaver of the USGS. Given data from the Dunn -Mingo Swamp location and approximated data from our proposed discharge location are as follows: Given Data from USGS Gaging Station Name: Gaging Station Number: Gaging Station Location: Drainage Area at Location: # Measurements Made: Average Flow: Annual or summer 7Q10 Flow: Winter 7Q10 Flow: Annual 30Q2 Flow: Annual 7Q2 Flow: Mingo Swamp near Dunn 02106760 Intersection of Mingo Swamp and Highway 421, southeast of Dunn 50.4 square miles 50 (1955-1985) 50.4 cfs (runoff is 1.0 cfs per mil) 0.0 cfs 1.6 cfs (Nov. - March) 3.3 cfs 0.2 cfs Flow Data for Proposed Discharge Location Proposed Location Name: Mingo Swamp near Benson Proposed Location: Intersection of Mingo Swamp and SR 1102 (Johnson County side) and SR 1812 (Harnett County side) Drainage Area at Location: 14.3 square miles • Using the two (2) drainage areas given, a proportioning factor was derived: 14.3 mil _ 50.4 mil = 0.2837 • This factor was multiplied by the given flow data to approximate the flow data at the proposed location as follows: Average Flow: 14.3 cfs Annual or summer 7Q10 Flow: 0.0 cfs Winter 7Q10 Flow: 0.454 cfs (Nov. - March) Annual 30Q2 Flow: 0.936 cfs Annual 7Q2 Flow: 0.057 cfs \ I) J �) �• :` \ � - , ..'' 11�•5 <� � /.._•� I/ `;'-- -i Lone lI S v4age ( -- �, t\ 50 13i)6 `30' j f I, ;1♦ _ Ir. j r; l D�d aI l �5 Drive-in z3l I 1 a6 _ 1 / l I' P I U � h l Thea .II'.BM•I' '•J•�6'_ -.1 � '� �^ �--,)•. ,•r/! \ \ �\ •�}.\,�; ,,O �, i � ``,l :\1173 '•�`,') - , f `�. �! - 1 �, �� - 'I 1��1 \\1'� °III 259 -__•i �, • \\ I 1 •y •• \` .I c.,\ ��"� l~• _l_ i' - /r, �-`� 1` ^I � �, if EXISTING If 11/I \ if DISCHARGE -c' .�..;�: 2� POINT (1 r �OIL .�w� (� • —_ S i . I ( ) l ' II ,, �;..•� Lj °ll :✓�•.,�.. •."�'�\.� �i,. f<• Ile=ell_"_= Ce_m /f // •1.l�r�a��l� ��_'uf II' :/� I 0 3.;• ��. >' QI' `•r/'�.�/ c-7—�__f' If .� �. •,�. ,O4j •� ✓(,%�\. III' .- 222 . , 2? ; ; II' p, — -elr -��• l'(_.,\ ;/; If if `I `l�' (►.c \ /'\/(� •\. . \ . QC219 ` Zoo t] ` 1 \ r t 1I I/ `\ �, �� �7� •f� � (IIn!\'1\ •� _, -!. I _ II.•� `� •',1��/ � �21II '�•''��`-`%,`'I 'lp� � ;� `Avg- Cq';1 . - , _ �' ,,,,,,iii �• -<. 223 •11 II / Water �'O •• '1• I 7L5 . IN iERIGR-GEUI.OGICAL SURVEY, RESION, VIRGIIJIA-19)S- ,1 Tank',' 1 ; I '..\\ •: 726000m.E. 242 • 'll 301j •�; ��•� I' I �� '; ( '�� �� r•95 Benson so ROAD CLASSIFICATION I Primary, hi hwa 2441 I" / I /�;' ^ \ ---- _______ Y g Y• Light -duty road, hard or hard surface..,... improved,surface .. I t Secondary highway 1 I� l• , r• ; • �, ,.:, �11)ge l� hard surface .................. —_, Unimproved road.........______ �_3 C� State Rout, Interstate Route U. S. Route 223 I it ` / i r ti ,•� 1 Water. 09 1 , Tank e ` 20o t ll Glove it L• \ i .-; . � � �� LOCATION MAP Joh, Benson Wastewater Treatment Plant -'1'sT° ` ��� I, Benson, NC NPDES No. NC0020389 i ��' co° (/I �r.'• �l USGS Map: Benson & Dunn, NC Scale: 1"-2000' TernJ102 (1709) 21 %Cem ✓'„ o 240 ^ PROPOSED l 11 , DISCHARGE V1.. POINT 'i_' ..." State of North Carolina Department of Environment, Health and Natural Resources Division of Water Quality James B. Hunt, Jr., Governor SEP Wayne McDevitt, Secretary A. Preston Howard, Jr., P.E., Director POINT SOURC CERTIFIED MAIL RETURN RECEIPT REQUESTED The Honorable Don H. Johnson Town of Benson P.O.. Box 69 303 East Church Street Benson, NC 28694 Subject: Dear Mayor Johnson: J4 J: =HNR AAA lo4e_, ez � ce,&-e f em �✓-/ ,0, Lifting of Sewer Line Moratorium Town of Benson NPDES Permit No. NCO020389 Johnston County On June 12, 1997 a moratorium on the issuance of sewer line permits was placed on the Town of Benson per the authority of 15A NCAC 2H .0223, which specifies that prior to exceeding 80% of their hydraulic treatment capacity, facilities must submit an approvable engineering evaluation of their future wastewater needs before permits for sewer line extensions may be issued. Monitoring data submitted by the Town showed the subject wastewater treatment plant operated at 89.53% of its treatment capacity during 1996. I have reviewed the Town of Benson's letter of July 24, 1997, requesting to have the sewer moratorium lifted along with the "Future Wastewater Treatment Plan Including Wastewater Disposal Alternative Analysis," prepared by the Wooten Company. The report presented the Town's "two prong" strategy in addressing future wastewater treatment needs and compliance with 15A NCAC 2H .0223, namely the reduction of inflow and infiltration to the collection system and the re -rating of the existing wastewater treatment plant to a higher design capacity. While a final determination on the latter portion of this strategy is still under review by Division staff, I have determined that by submitting this report, the Town has complied with the terms of 15A NCAC 2H .0223(l). In light of these findings, I hereby remove the moratorium on the issuance of sewer line permits placed on the Town of Benson. The Town is reminded that prior to the facility exceeding 90% of its permitted hydraulic capacity, approvable plans and specifications, including a construction schedule, must be submitted to the Division in order to remain in compliance with the terms of 15A NCAC 2H .0223. Compliance will be judged based upon the facility's average flow of calendar year 1997 and subsequent calendar years. Should the average flow for any calendar year exceed 90% of permitted hydraulic capacity without the Town having first submitted the required plans and specifications, the sewer line moratorium will again be imposed. P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone 919-733-5083 FAX 919-733-9919 An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper If you have any questions about this letter, please do not hesitate to contact Judy Garrett, Water Quality Regional Supervisor for our Raleigh Regional Office at (919) 571-4700, extension 252 or Bob Sledge of our Central Office staff, at (919) 733-5083, extension 233. Sincerely, A. Preston Howar Tr. P.E. cc: Steve Tedder Ken Schuster Don Safrit Kim Colson Bob Sledge State of North Carolina Department of Environment, .Health and Natural Resources Division of Water Quality James B. Hunt, Jr., Governor Wayne McDevitt, Secretary A. Preston Howard, Jr., P.E., Director September 16, 1.997 Mayor Don H. Johnson Town of Benson Post Office Box 69 Benson, North Carolina 27504 Subject: Permit Application Return Return Number 889 Permit No. NCO020389 Town of Benson WWTP Johnston County Dear Mayor Johnson: POINT SOURCE BRANCH A review of the NPDES Permit Application (Standard Form A) and the report titled "Future Wastewater Treatment Plan Including Wastewater Disposal Alternative Analysis" indicated that the report does not include all of the information required for the Division to accurately review the re - rating request and.the alternatives analysis provided is insufficient. Therefore, the application package is being returned as incomplete. This letter is divided into two separate comment sections. The first section covers the deficiencies identified during the Engineering Alternatives Analysis review. The second section identifies the deficiencies in the re -rating request and potential obstacles for approving this request. Engineering Alternatives Analysis Review In addition to requesting a flow expansion, a comprehensive Engineering Alternatives Analysis must be prepared to study all possible discharge options. Based on the findings of the Division staff, the Division requires that more information be provided regarding possible alternatives to discharge. It is the Division's mandate to permit the most environmentally sound wastewater treatment system of the reasonably cost effective alternatives. Subsurface or irrigation disposal systems are typically considered to be more environmentally sound alternatives than discharges to surface waters. The following issues must be addressed prior to resubmitting the Engineering Alternatives Analysis for Division review: • The report titled "Wastewater Treatment Plan Including Wastewater Disposal Alternative Analysis" discusses the fact that the Town of Benson is experiencing, and wishes to continue experiencing, a moderate growth rate. The report does not provide documentation that a study was performed in reference to projected growth for the area. The Engineering Alternatives Analysis must provide justification for the requested flow P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone 919-733-7015 FAX 919-733-0719 An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper �f 0 Permit Application Return Return Number 889 Permit No. NCO020389 Town of Benson WWTP Page 2 of 3 increase. A detailed study should be performed to project growth (i.e., perform a 20- year projection on population and commercial/industrial growth). • An Engineering Alternatives Analysis also requires the comparison of present worth costs for each technically feasible alternative. ' Resubmittal of this application must include a present worth cost analysis to. support the claim that the direct discharge is the only viable option. • The Engineering Alternatives Analysis stated that surface water discharge can be continued without any additional capital costs. The Division disagrees with this statement for two reasons. First, House Bill 515 was recently approved which requires facilities that discharge to Nutrient Sensitive Waters (NSW) in the Neuse River Basin to meet a total nitrogen limit of 5.5 mg/l. In addition, the Neuse River NSW Management Strategy is currently being reevaluated. The modified strategy has not been finalized, but may include more restrictive limits than House Bi11515 for any expanding discharge. It is the Division's understanding that the current facility does not have nitrogen removal capabilities. In response to these additional requirements, information should be provided in reference to the capital and the operation and maintenance costs required to upgrade the facility for nitrogen removal. In addition, the Engineering Alternatives Analysis report stated that if nutrient removal capabilities can not be achieved with minimal capital costs, then the treated effluent can be discharged to Mingo Swamp in the Cape Fear River Basin. A more detailed discussion of this alternative is required. As outlined in the Division's Guidance for Evaluation of Wastewater Disposal Alternatives (copy attached), the analysis of subsurface and irrigation disposal systems may require a report based on a site investigation from a soil scientist. However, a screening method may be used to gather and interpret preliminary data without performing a site investigation. First use county soil maps to identify on -site soils. Using this soils characterization, determine best case loading rates. Then perform a present value of cost analysis. If the present value for -a non -discharge alternative is less than a discharge system, then a more detailed report from a soils scientist must be performed based on a site investigation. This document should include the following: - A copy of field notes and boring log information. - A soils site map overlain on a topographic map. - Description of soils characteristics to include texture, structure, soil wetness and mineralogy. - Characterization of the depth of soil to 48" or to a restrictive horizon, and Soil loading rate recommendations and land area requirements. If the present value for a non -discharge alternative is greater than 15% higher than a discharge system, no further information is necessary. • In reference to water reuse, please provide more information in reference to the large water using industry referenced in the alternatives analysis report. It was stated that this facility produces pharmaceutical grade materials, and any water of lesser quality than potable water is likely to prove objectionable for use. Please provide Permit Application Return Return Number 889 Permit No. NC0020389 Town of Benson WWTP Page 3 of 3 documentation that this facility would reject the use of recycled water, even for non - process water use such as lawn irrigation or cooling water use. Re -rating Request The re -rating request is considered a major modification based on the fact that the additional flow will be considered "new flow." Please be aware that any increase in flow to the Neuse River Basin will most likely initiate significant public interest. The public may request that a hearing be scheduled in reference to the proposed expansion. In addition, the request may take in excess of six months to issue. For example, two municipalities in the Neuse River Basin recently requested expansions. One facility requested an expansion in June of 1996 and the other facility submitted its request in August of 1996. Public hearings were held for both facilities in early July 1997. The first step the Town of Benson should take is to submit a request for speculative limits based on the expanded flow. This is a free service offered by the Division for municipalities. Upon receipt of this request, the Division will prepare a wasteload allocation to study the effects of the proposed discharge on the receiving stream. New effluent limitations will be developed based on the assimilative capacity of the receiving stream. Speculative limits, based on the expanded flow, must be developed and incorporated into a modified NPDES permit prior to requesting an Authorization to Construct. In other words, the existing permit must be modified to include limits for the "new flow" prior to requesting a re -rating of the facility. The Division would like to suggest that a meeting be scheduled to discuss the issues that were addressed in this letter. Should you have any questions or if you would like to schedule a meeting, please do not hesitate to contact Jeff Myhra at (919) 733-5083, extension 597. Sincerely, A. Preston Howard, Jr., P.E. cc: -C� Raleigh Regional Office, Water Quality Section NPDES Unit, Jeff Myhra Buck Kennedy, The Wooten Company July 24, 1997 The Wooten Mr. David A. Goodrich NPDES Group Supervisor Company NPDES Permits Group NCDEHNR-DWQ P.O. Box 29535 Engineering Raleigh, NC 27626-0535 Planning Re: NPDES Permit Modification Architecture Demonstration of Future Wastewater Treatment Capacities _ NPDES No. NCO020389 Town of Benson Johnston County TWC # 2293 Dear Mr. Goodrich: Per your request letter dated April 25, 1997 and the request letter from Mr. Steve 120 N. Boylan Avenue W. Tedder dated June 12, 1997, we are hereby forwarding the requested items in Raleigh, NC regards to the modification of NPDES Permit No. NC0020389. This modification 27603 is requested to increase the plant's flow rating from 1.5 MGD to 1.732 MGD, which will allow time for the Town's inflow and infiltration rehabilitation program to take effect. The following items are enclosed: 1) Three (3) copies of the executed NPDES Permit Application (Standard 919-828-0531 Form A). 2) A check in the amount of $400, made out to NCDEHNR, to cover the permit modification fee. 3) Three (3) copies of the Future Wastewater Treatment Plan Including Wastewater Disposal Alternative Analysis. This plan is written as requested in your letter and Mr. Tedder's letter. We trust that this submittal covers all requirements set forth by your department. However, if you have any questions or require any additional information, please contact us. Sincerely, THE WOOTEN COMPANY E. Eric Mills Enclosures Since 1936 cc: Mr. Keith Langdon, Town of Benson (w/enclosures) NCDEHNR-DWQ Facility Assessment Unit (w/enclosures) Cl TOWN OF BENSON NORTH CAROLINA FUTURE WASTEWATER TREATMENT PLAN WASTEWATER DISPOSAL ALTERNATIVE JuLY 1997 ���etueerrrrh `'6���0.` of E5•� �����''�, s Q l i i vE4f i a 1'2: 9792CwA �= rrreu11014%t EVERETTE L. CHAMBLISS, P.E. THE WOOTEN COMPANY Engineering - Architecture - Planning 120 North Boylan Avenue Raleigh, North Carolina 27603 INCLUDING ANALYSIS ---- TOWN OF BENSON NORTH CAROLINA FUTURE WASTEWATER TREATMENT PLAN INCLUDING WASTEWATER DISPOSAL ALTERNATIVE ANALYSIS Jui,Y 1997 te,,�e�erearrgrr SEAL i = 9792 ' ¢= F ( CH EVERETTE L. CHAMBLISS, P.E. THE WOOTEN COMPANY Engineering - Architecture - Planning 120 North Boylan Avenue Raleigh, North Carolina 27603 Table of Content General Information ..... .::......... ......... - ... 1.1 Facility and Analysis Information ................................ 1 1.2 Project Description and Flow Projections ........................... 1 1.3 Existing Units ............................................. 2 1.4 Project Phase ............................................. 6 2.0 Evaluation of Disposal Alternatives .................................... 7 2.1 Connection to a Sewer Collection System ........................... 7 2.2 Land Based Disposal ........................................ 7 2.3 Wastewater Reuse .......................................... 8 2.4 Surface Water Discharge .......... . ........................... 9 2.5 Conclusions ............................................... 9 3.0 Summary.....................................................10 I U 1.0 GENERAL INFORMATION 1.1 Facility and Analysis Information Facility Name: County: Facility Address: Facility Telephone Number: Report Preparer's Name: Benson Wastewater Treatment Facility Johnston County Off of SR 1171, South of I-95 (919)894-3553 Everette L. Chambliss, P.E. Report Preparer's Address: The Wooten Company 120 North Boylan Avenue Raleigh, NC 27603 Report Preparer's Telephone Number: (919)828-0531 1.2 Project Description and Flow Projections The Town of Benson's existing wastewater treatment plant (WWTP) has a currently permitted capacity of 1.5 million gallons per day (MGD). The average flow calculated for calendar year 1996 was 1.343 MGD, which represents 89.53% of the existing permitted capacity. While the average flow is distorted due to an exceptionally wet year, more ordinary flow conditions saw average flows approaching and at tunes exceeding 80% of the design capacity. The Town of Benson is experiencing, and wishes to continue experiencing, a moderate growth rate. In order to accommodate this growth rate without wastewater treatment capacity constraints, the Town has adopted a two prong strategy. This strategy has been developed in consideration of two factors s unique to the Benson situation. These are: (1) the fact that a low strength industrial discharge is a major component of the Town's wastewater stream, resulting in the Town having ample organic load reserve capacity, and; (2) the fact that infiltration and inflow account for much of the peak 30 day loading experienced by the Town's treatment plant. The first prong of the Town's strategy is to aggressively pursue infiltration and inflow correction, with the goal of eliminating infiltration and inflow sources at a rate at least equal to the rate at which growth increases domestic, commercial, and light and/or dry industrial wastewater flows. This prong of the strategy is expected to result in no net increase in wastewater flow rates over the next 5 to 10 years, and possibly even a decrease in flow rates. The second prong of the strategy is to provide some additional permitted treatment capacity to provide the Town some cushion for accommodating growth while its infiltration and inflow rehabilitation efforts are getting underway. A report entitled "Wastewater Treatment Plant Capacity Evaluation" was performed in December 1996 to determine how much of a reserve capacity is available at the existing plant. That 1 study concluded that even the most limiting treatment unit, the final clarifiers, could perform -- - ---adequately at an -average daily -flow-of-1:732--MGD. Therefore, it was concluded that-the--plant-can- - - - operate as a 1.732 MGD tertiary treatment facility and a request has been made for a NPDES permit flow limit increase to that level. This will provide the Town with 0.232 MGD of additional treatment capacity while it works on recovering more capacity through an inflow and infiltration abatement program. 1.3 Existing Units Existing units, which would remain- in use with an increase in permitted flow, are described as follows: Design Population 3,924 Design Waste Loadings, mg/L BODS (Bio-Chemical Oxygen Demand, 5 day 20' C) 2500 lbs/day TSS (Total Suspended Solids) 2500 lbs/day NH3-N (Ammonia Nitrogen) 2501bs/day Phosphorous 100 lbs/day Bar Screens Mechanical: Number of units 1 Design flows, ADF, mgd 1.50 PDF, mgd 3.75 Channel width, ft 2 Channel depth, ft 5 Motor horsepower, hp 0.5 Unit power control Time Clock Maximum raki lift capacity, lb 462.0 Manual: Number .of units 1 Channel width, ft _ 1.5. Channel depth, ft 2 Unit capacity, mgd 1.65 Grit Chamber Number of units 1 Length, ft 17 Width, ft 1.25 Average water depth, ft 1.50 Detention time at peak flow, min 0.30 Velocity at peak flow, ft/sec 1.36 Surface overflow rate at peak flow, mgd/sq ft 0.077 Method of grit removal Mechanical Comminutor Number of units 1 Unit size, in - 15 Unit capacity, mgd 2.4 Size of drive unit, hp 0.75 2 Parshall Flume (for -flow measuring) _ _ Number of units, 9-inch size 1 Aeration Tanks (Oxidation Ditches) Number of units 3 Liquid depth, ft 5 Unit Volume, mil gal 0.618 Total Volume, mil gal 1.854 Detention time, average hr 30 BOD5 to aeration tanks, lb/day, average 2,500 Organic loadings to tanks, lb BOD5/1000 ft3, average 10 MLVSS concentration, mg/L 2,200 F/M ratio, lb BOD5/lb MLVSS 0.09 MCRT or SRT, days (@ 10° C, Yn=0.65, BODR=98%) 27 Sludge recycle ratio 1:1 Aeration Facilities for Aeration Tanks Type of aeration Mechanical, brush type Number of aerators, 27 1 in x 10 ft long brush rotor with 7.5 hp drive unit, each/tank 4 Total number of brush aerators 12 Total horsepower provided, hp 90 Aerator capacity at 6-in immersion, lb 02/hr/ft of rotor 1.74 Total aeration capacity, lb 02/hr 208.80 Total oxygenation capacity, lb 02/lb BODr, average 2.00 Secondary Clarifiers Number of units, 35 ft diam x 12 ft SWD 2 Unit Volume, gal 86,359 Number of units, 35 ft diam x 10 ft SWD 2 Unit Volume, gal; 71,966 Total Volume, gah 316,650 Detention time at average flow, his 5.07 Unit surface area, sq ft 962 Total surface area, sq ft 3,848 Surface overflow rate, gpd/sq ft 390. Unit weir length, ft 110 Total weir length, ft 440 Weir overflow rate, gpd/lf 3,410 Type of sludge removal Pump Filters Number of filters, 10 ft x 12 ft 5 Total surface area, sq ft 600 Filtration rate at average daily flow, gpm/sq ft 1.74 Filtration rate at peak daily flow, gpm/sq ft 4.34 Maximum wash rate at 20' C, gpm/sq ft 15.0 Filter Media Anthracite Medium: 2 ft 3 inch depth of the media. Particle sizes ranging from 1.2 mm to 1.6 mm, with a maximum uniformity coefficient of 1.4 and not more than 10% by weight being no more than 1.2 m- Anthracite has aspecific-gravity of 1:57. Silica Medium: 12-inch depth of the media. Particle sizes ranging from 0.50 mm, with a maximum uniformity coefficient of 1.6 and not more than 10% by weight being smaller than 0.50 mm. the specific gravity of sand is 2.50. Gravel Medium: 13-inch depth of the media consisting of.. 4-inch 1/8" x No. 16 mesh 3-inch 1/8" x 3/8" 3-inch 3/8" x 1" 3-inch 5/8" x 1" Underdrain system Wheeler bottom type Caustic Feed System (for alkalinity and pH Control) Total lime storage capacity, cu ft 1,800 Number of feed pumps 2 Feed rate, gal/hr 0 - 0.5 Alum Feed System (for phosphorus removal) Number of storage tanks, 12'-0" ID x 18'-6" 2 Unit capacity, gal 15,000 Total capacity,. gal 30,000 Number of feed pumps 2 Feed rate, gal/hr at 150 psig back pressure 50 Motor horsepower, hp 1 Chlorination System Chlorine Contact Tanks Number of tanks 23'-6" x 8' - 8" x 6' - 6" SWD 2 Unit volume, gal 8,593.5 Total volume, "gal 17,187 Detention time at average daily flow, min. 16.5 Chlorine Feed System Number of chlorinators 2 Chlorine feed rate, lb/day 20 - 200 Number of one ton cylinders 4 Filter Backwash Clear Water Storage Number of tanks - 18'-8" x 18'-0" x 6'-6"/11'-3" x 9'-10" x 5'-0" 1 Total volume, gal 20,475 Post Aeration Number of units 18'-6" x 18'-0" x 6'-6" 1 Total volume, gal 16,190 Detention time at average daily flow, min. 15.5 Type of aeration Submerged self -aspirating type Number of aerators, 7.5 hp 1 Aerator capacity, CWTR at 41 cfm air flow and STP in lb 02/hr 26 Dechlorination System Solution type 4 Sodium sulfite Number of metering pumps 2 Capacity, gph —---------- -- -- - - 0 to 1.5 -- — - -- T -^^ Solution tank size, gal 250 Aerated Sludge Holding Lagoon (for sludge stabilization, disposal) Number of lagoons 1 Size of lagoon: Area at water surface, sq ft 191 ft x 299 ft = 57,110 Area at bottom surface, sq ft 166 ft x 274 ft = 45,310 Side slopes 1.5:1 Liquid depth, ft 8.5 Total volume, gal 3,080,220 Stabilization Lagoons (for equalization of influent flow & filter backwash waste) Number of lagoons 2 Size of lagoon Lar es rLai!oon Smaller lagoon Area at water surface 315' x 575' = 181,125 sq ft. 1/2 (385+265)x795=258,375 sq ft Area at bottom 300' x 560' = 168,000 sq ft 1/2 (370+250)x780=241,800 sq ft Slide Slopes 2.5:1- Liquid depth 3.0 ft Volume of each lagoon, gal 3,844,800 5,611,960 Total volume, gal 9,456,760 Pumps:. Pump Type No. hp/each unit TDH Design Capacity* Screw Pumps 1 5 7 ft 1,750 gpm Screw Pumps 2 3 7 ft 1,370 gpm Filter Lift Pumps- 3 15 34 ft 1,300 gpm Sludge .Recirculation Pumps 2 10 17 ft 1,050 gpm Sludge Waste Pumps a 1 1.5 10 ft 100 gpm Scum Pumps 2 1.5 10 ft 100 gpm Filter Backwash Pumps 2 40 40 ft 2,700 gpm Surface Wash Pumps 2 10 198 ft - 120 gpm Wash Water Pumps 2 5 150 ft 75 gpm - Sludge Lagoon Pumps 2 5.4 25 ft 200 gpm *For each pump 61 The following is a schematic representation of the Benson wastewater plant: — ----Filter Backwash' — ----- Dechlorination _ Chlorine System -ost Aeration Contact Basing I / Tank WClar. I Effluent Sludge Pump Waste —Filter Backwash ge Pump rculation Aeration Tank #3 �-- Mechanical Bar Screen Mrs. CIar, ular. _ ■ —r ■ —Tank #1 #1 Splitte �_ Comminutor By -Pass Box Screen Screw Pumps rit hamber Parshall _ ume Equalization Aerated Basins Sludge Holding 1.4 Project Phase The requested flow limit increase is for the existing plant and is not part of any phased project_ The Benson plant discharge is within the nutrient sensitive Neuse River Basin. The plant is already equipped for phosphorus removal, and it appears likely that some form of nitrogen removal will be required as well. Depending on the final form that the nitrogen removal requirements take (plant specific limitations or limitations applied to aggregate discharge of voluntary associations), some upgrading of the plant to achieve nitrogen removal may also be required. Detailed plans for this upgrading will be developed once specific nitrogen removal requirements are known. The existing plant configuration, with its use of multiple long, shallow, oxidation ditches, is readily amendable to modification for use of a number of different biological nitrogen removal processes. M 2.0 EVALUATION OF DISPOSAL ALTERNATIVES 2.1 Connection to a Sewer Collection System The Town of Benson operates its own wastewater collection and treatment system. There is no other existing sewer system within a five (5) mile radius of the existing Town system. There is no planned area wide sewerage system expected within the next five (5) years that would be within a five (5) mile radius of the existing Benson system. Therefore, connection to another sewer system is not regarded as being a viable alternative. 2.2 Land Based Disposal Land application is an effective wastewater treatment method that takes advantage of the physical, chemical, and biological processes that occur when water, -soil, plants, microorganisms, and the atmosphere interact. Use of a land treatment system eliminates point source discharges while providing a high degree of treatment and nutrient removal. Land treatment systems are sometimes found to be the most cost-effective solution to treatment problems. However, land treatment systems are normally only cost effective when the systems are used as the tertiary treatment system and when reasonably suitable land area is available: The Town of Benson has already constructed tertiary treatment facilities capable of treating the design flow of 1.732 MGD. Therefore, in its case, land application costs would be additive to conventional tertiary system costs, rather than a true alternative to those costs. Site selection criteria remain unchanged even if tertiary. treatment is provided as the preliminary treatment system. When selecting potential land application sites, many factor's must be taken into account, including: • Site should be selected that has soil groups most suited for the land application processes under consideration. • Site should not conflict with the present and anticipated land use and should reinforce the adopted land use plans. • Site should be within a reasonable transport distance from the source of wastewater. • Site should not endanger sensitive environmental areas such as historic sites or rare or endangered plants or animal species. • Site should minimize adverse socio-economic impacts. • Site should not have geological or groundwater conditions that would adversely effect the land application treatment process being considered. • Elevation difference between the site and the source of wastewater should be minimum to reduce pumping costs. • The number and size of the available land parcels should also be considered. 7 In order to make a rough approximation of the costs of installing a 1.732 MGD spray irrigation -system -to -serve --the -T-own-of Benson, -Soil Survey- Maps - of -Johnston -County--were- reviewed. The soil surveys showed that large acreages of Wagram and Norfolk soils, usually intermixed with lessor quality soils such as Goldsboro and Bibb soils, are available at a number of areas within the general vicinity of Benson. Considering these soil types, it was assumed that a site could be located that could sustain an annual average loading of 1.2 inches per week and that would require a wastewater storage lagoon (for holding treated wastewater during inclimate weather) of only 60 days storage size. Based on these assumptions, a 373 acre sprayfield and a 104 MG storage lagoon would be required for land application of the Benson wastewater. The cost of such a system is approximated as follows: Item Quantity Unit Price- Extended Total Transfer Pump Station (from WWTP to Storage Lagoon) 1 LS $200,000 Effluent Storage Facility: Excavation & Fill $3,400,000 Slope Protection $2,400,000 Spray Irrigation Pump Station 1 LS $350,000 Sprayfield Piping 373 acres $5,500/acre $2,052,000 Fencing 22,000 LF $2.10/LF $46,000 Sitework & Piping $1,143,000 Access Roads 5 miles $16/LF $422,000 Electrical $55,000 Administrative Bldg. & Equipment Sheds $120,000 Sub -Total $10,188,000 Land: Sprayfield '� 373 acres $5,000/acre $1,865,000 Land: Buffers & Uneconomic Remnants 250 acres $5,000/acre $1,250,000 Land: Storage Lagoon 55 acres $5,000/acre $275,000 Equipment $80,000 Contingencies $1,019,000 Engineering $1,019,000 Total Project Cost $15,696,000 These approximate costs are for comparison purposes only. Other costs, such as those for the conveyance force main, have not been included since it is not known exactly where such a facility would be located. The cost projection above is therefore something less than the actual minimum cost of a land application system. 2.3 Wastewater Reuse There are no golf courses or similar facilities near the Benson wastewater treatment plant that would have irrigation needs that would justify a water reuse system. There is one large water using industry within the Benson system, but the products it makes included pharmaceutical grade materials, and any process water of lesser quality than potable water is likely to prove --- ---objectionable. Therefore, reuse is- not regarded as a viable alternative -to an --increase in the permitted--- - -- discharge flow. 2.4 Surface Water Discharge As shown in the December 1996 report, a surface water discharge of 1.732 MGD meeting tertiary treatment standards can be achieved with the existing wastewater treatment system, at no additional capital cost. The imposition of nutrient removal requirements may require some capital expenditures with or without a plant expansion. Should the nutrient removal requirements imposed be greater than that which could be achieved with only moderate capital expenditures, then pumping treated effluent to a discharge point in Mingo Swamp, within the Cape Fear River Basin, would be a viable alternative. 2.5 Conclusions The wastewater disposal analysis shows that discharge to another sewage treatment system is not practical. Elimination of the discharge by construction of a land application system would cost in excess of $15,696,000 and would bring the Town, in effect, only 0.232 MGD of additional capacity. This is obviously not a viable solution. Wastewater reuse could in theory allow the Town to treat up to 1.732 MGD but to keep its discharge at or under 1.500 MGD. However, for this theory to be a reality, there must be a reuse market, which at present does not exist. Increasing the discharge permit capacity from 1.500 MGD to 1.732 MGD would allow the Town to maximize the investment it has already made in wastewater treatment capacity. The discharge can be increased to 1.732 MGD without any capital improvements if the present effluent limits remain unchanged. Some requirements for nitrogen removal appears likely with or without the plant expansion. Under these circumstances, some capital outlay may be required to add nitrogen removal capability. The present treatment system is readily adaptable to biological nutrient removal, and assuming any nutrient removal requirements that might be imposed are reasonable, this should be achievable at a cost of only a small fraction of that of land application. In the event that nutrient removal requirements are unreasonable, consideration would have to be given to pumping treated effluent to Mingo Swamp in the Cape Fear River Basin, where no nutrient removal requirements are expected. 9 3.0 SUMMARY The Town of Benson's wastewater treatment plant, due in large part to the presence of infiltration and inflow, has flows that at times reach, and even exceed, 80% of its design flow. A two prong approach has been developed for the Town to assure that its wastewater flows do not exceed its actual treatment capacity. One prong of this approach is an on -going program for locating and eliminating infiltration and inflow problems. The Town's goal for this program is to eliminate extraneous flows from its system at least as fast as normal growth adds flows to its system. It is expected that this program will allow the Town to hold the average daily flows over the next 5 to 10 years at or near their present levels, if not to actually reduce its flows. The second prong of the Town's strategy is to provide an additional 232,000 gallons per day of permitted reserve wastewater treatment capacity while the Town gets its sewer collection system rehabilitation program underway. This is to be done by re -rating its plant for a higher discharge capacity. An engineering analysis completed in December of 1996 concluded that the existing plant can operate as a 1.732 tertiary treatment facility. Accordingly, the Town of Benson has requested that its NPDES discharge permit be increased from 1.500 MGD to 1.732 MGD. The North Carolina Division of Water Quality required the Town to evaluate alternatives to an increase in permitted surface discharge capacity. That evaluation is contained in this, report. Alternatives considered were discharge to another system, land treatment by spray irrigation, and water reuse. Discharge to another system was found to be impractical because there is no other - system within a reasonable distance. Spray irrigation was found .to be too costly (at a cost of at least $15,696,000 for what would amount to only a 232,000 gallon per day increase in capacity). Conditions around Benson are such that reuse is also not a practical alternative. Continuing with the point source discharge, and expanding the permitted capacity by even the modest amount proposed, could result in the imposition of future total nitrogen limits. If and when such limits are imposed, the plant may need to be upgraded. The treatment plant utilizes three long, shallow oxidation ditches, a configuration amenable to modification for biological nitrogen removal by a number of different processes. Should a degree of nitrogen removal be imposed that can not be achieved using relatively modest modifications to the existing treatment system, then pumping of the treated effluent to Mingo Swamp, a tributary of the Cape Fear River, can be considered. 10 . , • State of North Carolina Department of Environment, Health and Natural Resources Division of Water Quality James B. Hunt, Jr., Governor Jonathan B. Howes, Secretary A. Preston Howard, Jr., P.E., Director April 25, 1997 Mayor Don H. Johnson Town of Benson P.O. Box 69 Benson, North Carolina 27504 Subject: Permit Application Return NPDES No. NCO020389 Town of Benson WWTP Vmr,Eounty Dear Mayor Johnson: I received your request for modification of your NPDES permit to discharge. Specifically, you requested that consideration be given to allow this discharge to be increased from 1.5 million gallons per day (MGD) to 1.732 MGD. After discussions with Mr. Keith Langdon (Town Administrator) and Eric Mills (The Wooten Company), the Division is hereby returning this request with the following comments. First, as you may know, the water quality in the Neuse River basin has prompted the Division to reevaluate the existing Nutrient Sensitive Waters Management Strategy. The modified strategy has not been finalized, but will likely include limits for total nitrogen for any expanding discharge. The town should consider this when making future plans to expand above 1.5 MGD. Furthermore, the town should perform an alternatives analysis as described in the attached document for any expansion. Please note that there is a provision for the requirements regarding soils analyses for expanding discharges greater than 1.0 MGD. Finally, the Town of Benson will need to submit a completed NPDES application form (Standard Form A) with any resubmittal. If you have any questions or comments, please do not hesitate to contact me at (919)-733-5083, extension 517. Sincerely, T' David A. Goodrich NPDES Group Supervisor cc: Central Files Raleigh Regional Office/Water Quality Section P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone 919-733-5083 FAX 919-733-0719 An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper ` MAYOR DON H. JOHNSON COMd5510hERS NATHAN B. BLACKMON RAY G. SMITH JACK R. LITTLETON KENNITH M. DUPREE LINDELL NORDAN J.W. PARRISH, JR. January 13. 1997 Mr. Dave Goodrich, Supervisor NPDES Group Oda OF BE�� O Cy, OATH CARO�� TOWN OF EENSON P.O. BOX 69 303 EAST CHURCH STREET NORTH MOLINA 27504 (919) 894-3553 FAX (919) 894-1283 North Carolina Department of Environment Health and Natural Resources Post Office Box 29535 Raleigh, North Carolina 27626-0535 Re. NPDES Permit NC 0020389 Benson, North Carolina Dear Mr. Goodrich: TOWN ADM ASTRATOR KEITH R. LANGDON TowN CLERK CAROLYN A. NORDAN, CIVIC TAx COLLECTOR ROSALIE G. WEST TOWN ATTORNEY DONALD A. PARKER The Town of Benson hereby requests that the above referenced permit, issued to the Town, be modified to allow an average monthly discharge of 1.732 million gallons per day. This is the maximum monthly average discharge rate that an engineering study shows our treatment plant can handle without any physical modifications. Infiltration and inflow have caused plant flows to reach, and, at times, exceed our currently permitted capacity of 1.500 million gallons per day. Increasing the permitted capacity of the plant will allow the Town to continue to grow and to operate its treatment plant without permit violations while it continues to work to eliminate infiltration and inflow sources. A $400.00 check for the permit modification fee, and three (3) copies of the aforementioned engineering study, are enclosed in support of this request. If any additional information is required, please let us know. Sincerely Cam'Nat�-�� Don H. Johnson Mayor DHJ/cros attachments C:\MAY0R\G00DR1CH.DHJ TOWN OF BENSON WASTEWATER TREATMENT PLANT CAPACITY EVALUATION DECEMBER 1996 r SEAL 9792 w • � EVERET"I'E L. CHAALISS, JR., P.E. THE WOOTEN COMPANY Engineering • Architecture • Plzuj! ng t-; 120 North Boylan Avenue " Raleigh, North Carolina 27603 U TOWN OF BENSON WASTEWATER TREATMENT PLANT CAPACITY EVALUATION DECEMBER 1996 • SEAL 9792 oE eaaaaas a 1,1.,,E EVERETTE L. CHkM LISS, JR., P.E. THE WOOTEN COMPANY Engineering • Architecture • Planning 120 North Boylan Avenue Raleigh, North Carolina 27603 Table of Contents Page 1.0 Purpose and Methodology ........................................ 1 2.0 Description of Existing Units and Limiting Parameter for Each Unit ............. 1 3.0 Analysis of Limiting Factors - Flow Related Units ........................ 7 4.0 Evaluation of Non -Flow Limited Units ................................ 9 5.0 Conclusions ................................................. 13 Tablel.......................................................... 2 Table2......................................................... 10 Figure.......................................................... 6 1.0 PURPOSE AND METHODOLOGY This study has been undertaken to determine the actual safe wastewater treatment plant capacity available to the Town of Benson. The Town is currently permitted to discharge 1.5 mil gals per day of wastewater. During a recent thirteen month period (September 1995 through September 1996) flows averaged 1.312 mil gals per day, which is 87.8% of the permitted capacity. Although the flow average is somewhat distorted by the effects of two hurricanes and a tropical storm, even under more ordinary flow conditions average flows approach and often exceed 80% of the design capacity. The Town of Benson has developed a two prong approach to assuring that its wastewater flows do not exceed its permitted capacity. One prong involves an ongoing sewer rehabilitation effort aimed at reducing extraneous infiltration and inflow. The second prong of the Town approach is the subject of this study, and involves rerating the capacity of the existing treatment plant. Rerating of the treatment plant to a higher capacity should be possible at Benson due to several factors, the most important of which are: - A substantial portion of the current flows consist of process wastewater from an industry which is substantially lower in pollutant concentrations (BOD5, TSS, and ammonia) than the design concentrations for the plant. - The plant has extra -ordinarily large flow equalization capabilities which can be used to minimize peak loading on hydraulically limited treatment plant components. - The conservatism inherent in the original plant design. The above three factors combine to allow the plant to successfully treat more than its 1.5 mil gal per day rated capacity. The purpose of this study is to quantify just how much more than the permitted capacity the Town can reasonably expect its facility to be able to treat. The methodology used in making this quantification consists of reviewing all major treatment plant processes to determine which wastewater characteristic most limits its performance, determining the maximum wastewater flow that each component can handle, and finally comparing limiting components to determine which component will govern overall plant performance. 2.0 DESCRIPTION OF EXISTING UNITS AND LIMITING PARAMETER FOR EACH UNIT Table 1 contains a detailed description of the existing wastewater treatment plant. Figure 1 is a schematic flow diagram of the treatment plant. Reviewing those components it can be sent that the following principal components are flow limited. Mechanical & Manual Screens & Comminutor Grit Chamber Parshall Flume Influent Screw Pumps -1- TABLE I DESIGN DATA OF BENSON WASTE TREATMENT PLANT Design Population 3,924 Design Flows, mgd Average daily flow 1.5 Peak hydraulic flow 3.75 Design Waste Loadings, lb/day BOD5 (Bio-Chemical Oxygen Demand, 5 day 20° C) 2,500 (200 mg/L) TSS (Total Suspended Solids) 2,500 (200 mg/L) NH3-N (Ammonia Nitrogen) 250 (20 mg/L) Phosphorous 100 (8 mg/L) Bar Screens Mechanical Number of units 1 Design flows, ADF, mgd 1.50 PDF, mgd 3.75 Channel width, ft 2 Channel depth, ft 5 Motor horsepower, hp 0.5 Unit power control Time Clock Maximum rake lift capacity, lb 462.0 Manual Number of units 1 Channel width, ft 1.5 Channel depth, ft 2 Unit capacity, mgd 1.65 Grit Chamber Number of units 1 Length, ft 17 Width, ft 1.25 Average water depth, ft 1.50 Detention time at peak flow, min 0.30 Velocity at peak flow, ft/sec 1.36 Surface overflow rate at peak flow, mgd/sq ft 0.077 Method of grit removal Mechanical Comminutor Number of units 1 Unit size, in 15 Unit capacity, mgd 2.4 Size of drive unit, hp 0.75 -2- Table 1 cont'd. Parshall Flume (or flow measuring) Number of units, 9-inch size Aeration Tanks (Oxidation Ditches) Number of units 3 Liquid depth, ft 5 Unit Volume, mil gal 0.618 Total Volume, mil gal 1.854 Detention time, average hr 30 BOD5 to aeration tanks, lb/day, average 2,500 Organic loadings to tanks, lb BOD5/1000 ft3, average 10 MLVSS concentration, mg/L 2,200 F/M ratio, lb BOD5/lb MLVSS 0.09 MCRT or SRT, days (@ 10° C, Yn=0.65, BODR=98%) 27 Sludge recycle ratio 1:1 Aeration Facilities for Aeration Tanks Type of aeration Mechanical, brush type Number of aerators, 27 z — in x 10 ft long brush rotor with 7.5 hp drive unit, each/tank 4 Total number of brush aerators 12 Total horsepower provided, hp 90 Aerator capacity at 6-in immersion, lb 02/hr/ft of rotor 1.74 Total aeration capacity, lb 02/hr 208.80 Total oxygenation capacity, lb O2/lb BODr, average 2.00 Secondary Clarifiers Number of units, 35 ft diam x 12 ft SWD 2 Unit Volume, gal 86,359 Number of units, 35 ft diam x 10 ft SWD 2 Unit Volume, gal 71,966 Total Volume, gal 316,650 Detention time at average flow, hrs 5.07 Unit surface area, sq ft 962 Total surface area, sq ft 3,848 Surface overflow rate, gpd/sq ft 390 Unit weir length, ft 110 Total weir length, ft 440 Weir overflow rate, gpd/lf 3,410 Type of sludge removal Pump Filters Number of filters, 10 ft x 12 ft 5 Total surface area, sq ft 600 Filtration rate at average daily flow, gpm/sq ft 1.74 Filtration rate at peak daily flow, gpm/sq ft 4.34 Maximum wash rate at 20° C, gpm/sq ft 15.0 -3- Table 1 cont'd. Filter Media Anthracite Medium - 2 ft 3 inch depth of the media. Particle sizes ranging from 1.2 mm to 1.6 mm, with a maximum uniformity coefficient of 1.4 and not more than 10% by weight being no more than 1.2 mm. Anthracite has a specific gravity of 1.57. Silica Medium - 12-inch depth of the media. Particle sizes ranging from 0.50 mm, with a maximum uniformity coefficient of 1.6 and not more than 10% by weight being smaller than 0.50 mm. the specific gravity of sand is 2.50. Gravel - 13-inch depth of the media consisting of- 4-inch 1 /8" x No. 16 mesh 3-inch 1/8" x 3/8" 3-inch 3/8" x 1" 3-inch 5/8" x 1" Underdrain system Wheeler bottom type Caustic Feed System (for alkalinity and pH Control) Total lime storage capacity, cu. ft 1,800 Number of feed pumps 2 Feed rate, gal/hr 0 - 0.5 Alum Feed System (for phosphorus removal) Number of storage tanks, 12'-0" ID x 18'-6" 2 Unit capacity, gal 15,000 Total capacity, gal 30,000 Number of feed pumps 2 Feed rate, gal/hr at 150 psig back pressure 50 Motor horsepower, hp 1 Chlorination System Chlorine Contact Tanks Number of tanks 23'-6" x 8' - 8" x 6' - 6" SWD 2 Unit volume, gal 8,593.5 Total volume, gal 17,187 Detention time at average daily flow, min. 16.5 Chlorine Feed System Number of chlorinators 2 Chlorine feed rate, lb/day 20 - 200 Number of one ton cylinders 4 Filter Backwash Clear Water Storage Number of tanks - 18'-8" x 18'-0" x 6'-6' /11'-3" x 9'-10" x 5'-0" 1 Total volume, gal 20,475 Post Aeration Number of units 18'-6" x 18'-0" x 6'-6" 1 Total volume, gal 16,190 Detention time at average daily flow, min. 15.5 -4- Table 1 cont'd Type of aeration Submerged self -aspirating type Number of aerators, 7.5 hp 1 Aerator capacity, CWTR at 41 cfm air flow and STP in lb 02/hr 26 Dechlorination System Solution type Number of metering pumps Capacity, gph Solution tank size, gal Aerated Sludge Holding Lagoon (for sludge stabilization, disposal) Number of lagoons Size of lagoon Area at water surface, sq ft Area at bottom surface, sq ft Side slopes Liquid depth, ft Total volume, gal Sodium sulfite 2 0 to 1.5 250 1 191 ft x 299 ft = 57,110 166 ft x 274 ft = 45,310 1.5:1 8.5 3,080,220 Stabilization Lagoons (for equalization of influent flow & filter backwash waste) Number of lagoons Size of lagoon Area at water surface Area at bottom Slide Slopes Liquid depth Volume of each lagoon, gal Total volume, gal Pumps Lar eg_r Lagoon Smaller lagoon 315' x 575' = 181,125 sq ft. 1/2 (385+265)x795=258,375 sq ft 300' x 560' = 168,000 sq ft 1/2 (370+250)x780=241,800 sq ft 2.5:1 3.0 ft Screw Pumps Screw Pumps Filter Lift Pumps Sludge Recirculation Pumps Sludge Waste Pumps Scum Pumps Filter Backwash Pumps Surface Wash Pumps Wash Water Pumps Sludge Lagoon Pumps 5,611,960 9,456,760 2 No. hp/each unit TDH Design Capacity* 1 5 7 ft 1,750 gpm 2 3 7 ft 1,370 gpm 3 15 34 ft 1,300 gpm 2 10 17 ft 1,050 gpm 1 1.5 loft 100 gpm 2 1.5 10 ft 100 gpm 2 40 40 ft 2,700 gpm 2 10 198 ft 120 gpm 2 5 150 ft 75 gpm 2 5.4 25 ft 200 gpm * For Each Pump -5- Waste Bar Screen Filter Backwash Filters Clar. uHandlin #4 Unit Lime _® Claz. Claz. # #1 Comminutor By -Pass Screen _ Equalization Basins Dechlormation Chlorine System —post Aeration Contact Basin I / Tank I Effluent Filter Backwash Sludge Pump Recirculation Screw Pumps Aerated Sludge Holding Aeration Tank #3 —Aeration Tank #2 Aeration Tank #1 Figure 1 Schematic of Benson Wastewater Treatment Facility Final Clarifier* Filter Lift Pump Station Tertiary Filters Chlorination System Dechlorination System Sludge Recirculation Pumps Sludge Wasting Pumps *Solids loading & phosphorus loading could also potentially limit capacity The following components are expected to be limited by BOD5 loading: Aeration Basins (Oxidation Ditches)* Aerated Sludge Holding Lagoon ** * Hydraulic loading and ammonia loading could also potentially impact minimum allowable loading ** Influent TSS and phosphorus could also impact potential maximum allowable loading The following components are expected to be limited by influent phosphorus loading: Alum Feed System Caustic Feed System * Ammonia loading could also potentially impact minimum allowable loading 'lds Certain components are clearly going to be impacted only by one wastewater characteristic, (i.e. pumps will be effected by flow only) while others could be limited by more than one parameter, depending on loading. In cases where more than one waste characteristic could potentially be the governing factor in determining a unit process's overall perfonnance, the unit has been listed under the waste characteristics most likely to be the limiting factor with domestic wastewater. As an example, clarifiers are listed as being flow limited. However, solids loading can also limit clarifier performance. Solids loading in turn could be determined by BOD5 loading (which will govern the mixed liquor of suspended solids concentration maintained in the aeration basins which feed the clarifiers) or by phosphorus loading (which determines the alum feed rate to the clarifiers which in turn determines the mass of chemical precipitate which the clarifiers must handle). 3.0 ANALYSIS OF LIMITING FACTORS - F+LOw RELATED UNITS Perhaps the simplest units to evaluate are the flow related units. The simplest of these units to evaluate are the pumps. The last part of Table 1 contains a sumimary listing of the major pumping systems employed at the plant. Three (3) influent screw pumps are used at the plant, one with a capacity of 1,750 gpm, and two with capacities of 1,370 gpm each. Therefore, with the largest pump out of service, the influent pumps can still handle a flow of 3.946 mil gals per day (2 pumps x 1,370 gpm x 1,440 rains./day = 3,946 mil gals per day). Ordinarily, a lessor average daily flow than the pump capacity would have to be considered to account for peak flows. However, since the Benson plant has 9.457 mil gals of equalization capacity, it would, at least in theory, be possible to equalize all peak flows and operate the plant at only one flow rate, the average daily flow. Therefore, the limiting plant capacity of the influent pumps will be considered 3.946 mil gals per day. Three (3) filter lift pumps, each having a capacity of 1,300 gpm are provided. Assuming one pump is out of service, these pumps would have a capacity of 3.74 mil gals per day (2 pumps x 1,300 gpm x 1,440 mins/day = 3.74 mil gals per day). The filter backwash and surface wash pumps are matched to the needs of the filters, and therefore will not directly effect plant capacity. The wash water pumps are sized based on projected incidental plant needs for clean-up, and therefore will have no impact on plant capacity. The sludge lagoon pumps, scum pumps and sludge waste pumps are sized based on the need to maintain minimum velocities through established minimum size sludge wasting and scum piping lines. Each of these pumps is needed to run only a tiny fraction of the day, and therefore these pumps will have no impact on plant capacity. Sludge recirculation pumps do, however, have some potential impact on overall plant capacity. There are two (2) such pumps, each rated at 1,050 gpm. Sludge recirculation rates employed vary with a number of factors, but assuming a recirculation rate of 80% of the average -7- daily flow is not unreasonable (some plants have been successfully operated with recirculation rates as low as 50% of average daily flow, but it would be imprudent to assume that such a low recirculation rate could be reliably used). Therefore, the limiting capacity due to the recirculation pumps is estimated as being 1.890 mil gals per day, assuming one of the two pumps is out of service (1,050 gprn x 1/80% x 1,440 rains/day = 1.890 roil gals per day). This limiting capacity could be increased by some relatively minor structural changes. Additional piping and valves could be added, allowing the sludge wasting pumps to also be used for sludge recirculation. This would add an additional 0.288 mil gal per day of capacity, assuming the sludge wasting pumps were available for recirculation 80% of the time, with the remaining 20% used for actual sludge wasting. (2 pumps x 100 gpm/pump x 80% available x 1,440 min.x 1/80% = 0.288 mil gal per day). Alternatively, an entirely new sludge recirculation pump and motor could be purchased and made available for service. This would add an additional 1.890 mil gals per day of reliable capacity to the system. Of all the pumps, sludge recirculation capacity is the limiting factor, limiting flows to 1.890 mil gals per day. However, with relatively minor changes to piping and valves, this figure could be increased to 2.178 mil gals per day. The purchase of a standby sludge recirculation pump and motor could result in a capacity of 3.78 mil gals per day, essentially matching the 3.74 mil gals per day capacity of the filter lift pumps. Other unit processes besides pumps are hydraulically limited. These other processes include the screens and comminutor, flow metering, clarifiers, tertiary filters, and chlorination and dechlorination systems. Because of the enormous equalization capacity at the plant, peak flows can be considered tantamount to average daily flows when evaluating the capacity of these units. The mechanical screen has a capacity of 3.75 mil gals per day. When it is out of service, screening can be accomplished with a manual screen and a comminutor having a combined capacity of 3.9 mil gals per day. Therefore, the limiting capacity of the plant screening is 3.75 mil gals per day. The grit chamber is designed for that same 3.75 mil gals per day flow rate. Benson uses a 9-inch Parshall Flume. Such a flume can accurately measure flows up to 5.73 mil gals per day. Therefore, none of the headworks will limit plant capacity to a greater extent than the limitations imposed by the plant pumping systems. Clarifiers and tertiary filters are unit processes whose performance is greatly impacted by flow rates, and for which no simple, relatively inexpensive means exists to increase capacities. There are four clarifiers having a total combined surface area of 3,848 square feet. A 450 gpd per square foot loading rate is generally considered to be a reasonably conservative clarifier loading. Based on that loading rate, the Town of Benson should be able to treat 1.732 mil gals per day of wastewater (3,848 sq ft x 450 gpd/sq ft = 1.732 mil gals per day). Even should one clarifier be out of service, -8- with a flow of 1.732 mil gals per day an overflow rate of 600 gpd/sq ft could still be achieved. 600 gpd/sq ft is considered to be a reasonable design overflow rate for activated sludge system secondary clarifiers by many authorities. Typical design wastewater filtration rates range from 2 to as high as 10 gpm per square foot. Using a conservative design value of 3 gpm per square foot, and considering that one 120 square feet filter is being backwashed, the Benson plant would still have 480 square feet of filter area which could accommodate an average daily flow of 2.074 mil gals per day. The most limiting flow factor of all major units is therefore that of the clarifiers, with a safe capacity of 1.732 mil gals per day. At this rate, the chlorination/ dechlorination system still needs to be checked for adequacy. The existing chlorine contact chambers have a volume of 17,187 gallons. The adjoining filter backwash clearwell storage provides an additional 20,475 gallons of tank volume for chlorine contact. Therefore, the total effective chlorine contact volume is 37,662 gallons. At an average daily flow of 1.732 million gallons, this volume will provide a detention time of 31 minutes. Assuming a chlorine dose of 7 mg/L is required for effective disinfection, 101 pounds per day of chlorine will be needed (1.732 mil gals per day x 8.34 x 7 mg/L = 101 lbs/day). Referring to Table 1, the existing chlorine feed system can deliver up to 2001bs. per day. The dechlorination system is matched in capacity to the chlorination system, and therefore will also be able to accommodate a 1.732 million gallon per day flow. 4.0 EVALUATION OF NON -FLOW LIMITED UNITS While the preceding analysis has shown that the treatment plant can accept an average daily flow of up to 1.732 mgd, before the Town accepts the flow, or the State agrees to permit the flow, there needs to be some reasonable level of assurance that BOD, TSS, ammonia, and phosphorus loads associated with this flow will not overload those plant components whose performance is related to loading of these pollutants. In order to make this determination, some projections regarding future wastewater characteristics must be made. During the 13 month period from September 1995 to September 1996, influent BOD5 concentrations averaged 77 mg/L, influent TSS concentrations averaged 76 mg/L, and influent ammonia concentrations averaged 10 mg/L (see Table 2). Influent phosphorus is not measured, but since effluent phosphorus averaged 1.5 mg/L, without the Town using the phosphorus removal treatment processes at the plant, it is conservatively assumed that influent phosphorus levels were not more than 4 mg/L. The low concentrations for all pollutant parameters are due largely to the presence of a high volume, low strength industrial waste, although infiltration and inflow also contribute to the low influent pollutant concentrations. Influent concentrations of all pollutants are expected to increase in the future. Two factors will contribute to the increase in treatment plant influent pollutant concentrations. The first of these is the ongoing -9- sewer rehabilitation program the Town is undertaking. This program will eliminate flows which essentially have no pollutant load so that each gallon eliminated will result in the remaining flow into the treatment plant having higher pollutant concentrations. The second factor is that growth in the Town service area is expected to bring additional flows with greater pollutant concentrations than the existing wastewater. In order to project the future plant pollutant influent concentrations at an average daily flow of 1.732 mil gal per day, the following assumptions have been made: (1) The Town will eliminate approximately 10% of its existing average daily wastewater flow through its ongoing sewer rehabilitation program, (i.e., will eliminate 131,000 gallons per day of infiltration/inflow on a full year, average daily flow basis) (2) The 131,000 gallons per day of flow eliminated from 19 reduction will not eliminate any BOD5, ammonia, TSS, or phosphorous loading on the plant. (3) The 131,000 gallons per day of eliminated infiltration and inflow will be replaced, through growth, with municipal type wastewater, and an additional 415,000 gallons per day of municipal type wastewater will be added to the system, so that the treatment plant will eventually run at an average daily flow of 1.732 mil gal per day, (i.e. the plant will eventually receive 546,000 more gallons per day of wastewater and 131,000 less gallons per day of rain water and groundwater). (4) All future wastewater flows will have a BOD5 concentration of 350 mg/L, a TSS concentration of 300 mg/L, an ammonia concentration of 30 mg/L and a phosphorous concentration of 6 mg/L. Table 2 Benson Wastewater Treatment Flow Monitoring Data Influent Effluent Date Flow BOD5 NH3-N TSS BOD5 NH3-N TSS TN TP (mgd) Sep-95 0.996 74 12.35 93.7 2.6 0.17 6.62 16.03 2.05 Oct-95 1.747 71 9.39 80 2 0.23 10.03 11.47 1.55 Nov-95 1.447 59 9.9 69 2.9 0.47 7.74 10.44 1.17 Dec-95 1.113 93 12.57 81.2 3.5 1 11.62 10.61 1.51 Jan-96 1.186 77 8.93 81.8 5.5 1 14.24 8.01 1.83 Feb-96 1.318 68 7.92 56 4.8 1.14 8.97 12.08 1.05 Mar-96 1.193 65 9.95 72 2.37 0.34 7.61 10.76 1.52 Apr-96 1.208 67 10.54 89 2 0.3 6.82 10.29 1.49 May-96 1.310 91 10.81 93 2.8 0.31 7.66 11.01 1.73 Jun-96 1.311 69 10.2 80 1.3 0.31 7.68 11.06 1.61 Jul-96 1.186 69 10.23 77 1.9 0.33 10.18 10.5 1.53 Aug-96 1.380 113 10.05 58 1.4 0.4 2.69 7.85 1.32 -10- Influent Effluent Date Flow BOD5 NH3-N TSS BOD5 NH3-N TSS TN TP (ingd) Jul-96 1.186 69 10.23 77 1.9 0.33 10.18 10.5 1.53 Aug-96 1.380 113 10.05 58 1.4 0.4 2.69 7.85 1.32 Sep-96 1.721 89 7.06 59 1.5 0.2 4.25 8.65 1.54 Ave. 1.317 77 10 76 2.6 0.5 8 11 1.5 Using the previously listed assumptions, it is possible to calculate the plant pollutant loadings at a flow of 1.732 mil gal per day. This is done as follows: Existing Baseline Loads (average loads from 9/95 through 9/96): BOD5: 1.371 mgd x 8.34 x 77 rng/l = 846 lbs/day TSS: 1.371 mgd x 8.34 x 76 mg/l = 835 lbs/day NH3-N: 1.371 mgd x 8.34 x 10 mg/1 = 110 lbs/day P: 1.371 mgd x 8.34 x 3.8 mg/l = 44 lbs/day Projected Future Load Increases: BOD5: 0.546 mgd x 8.34 x 350 ing/1= 1594 lbs/day TSS: 0.546 mgd x 8.34 x 300 mg/l= 1366 lbs/day NH3-N: 0.546 mgd x 8.34 x 30 mg/1 = 137 lbs/day P: 0.546 mgd x 8.34 x 6 mg/1 = 27 lbs/day Total Projected Future Pollutant Loads BOD5: 846 lbs/day+15941bs/day'"- 72440 lbs/day TSS: 8351bs/day+1366lbs/day = 2201 lbs/day NH3-N: 1101bs/day+1371bs/day = 247 lbs/day P: 44lbs/day+271bs/day = 71 lbs/day Comparing the projected loads to the design loads for the treatment system given in Table 1 shows that in all cases the actual future plant loadings will be less than the loadings for which the plant is designed. This means that all aeration, chemical feed, and sludge handling facilities are adequately sized. However, the detention tune within the aeration basins will be shortened, and the mass loading on the final clarifiers potentially increased by the greater design flow. Therefore, the adequacy of the existing aeration basins and clarifiers at 1.732 mil gal per day flow must be determined The aeration basins (oxidation ditches) have a combined volume of 1.854 mil gals At a design flow of 1.732 mil gals per day, a detention time of approximately 26 hours will be provided. The system should, therefore, be able to continue to operate as an extended aeration -11- sludge system will need an SRT (solids retention time) of 25 days, (Figure 14-11, ASCE MOP 36, 1977). The mixed liquor of suspended solids required to achieve this SRT is calculated as follows (equation source: page 235, ASCE MOP 36, 1977): SRT —a(M)—b where: F = food (BOD5 load in pounds) M = mass of microorganisms (mixed liquor of volatile suspended solids, in pounds) a = cell yield coefficient, typically 0.7 for extended aeration systems b = endogenous decay coefficient, typically 0.04 for extended aeration systems. Rearranging to solve for M, the equation becomes: M= aF 1 (SRT )+ b Substituting values for variables, M is calculated as: M= 0.7 (2440 lbs) (Y+.04 5) M= 21, 3501bs The corresponding mass of total mixed liquor, assuming a 70% volatile solids content, is 30,500 lbs (21,350 lbs/70% = 30,500 lbs), and the required mixed liquor of suspended solids (MLSS) concentration is determined as follows: MLSS = 30,5001bs 8.34 x 1.854 mil. gal. aeration basins =1972 mg / L Maintaining a 1972 mg/1- MLSS is not an unreasonable expectation, and therefore the aeration basins are adequately sized to allow a 1.732 mil. gal. per day design flow. The mass loading on the final clarifiers at a 1.732 roil. gal. per day flow is calculated as follows: - 12- 1.732 mgd x 8.34 x 1972 mg / L Mass Loading = 3848 sq ft of clarifier surface area = 7.4 lbs per sq ft per day 7.4 lbs per sq ft is substantially below the 30 to 35 lbs per square foot per day loading generally considered as acceptable maximum solids loadings for clarifiers used within activated sludge systems. The adequacy of the clarifiers from a hydraulic stand point has been previously demonstrated. Therefore, the clarifiers can safely be assumed as adequate to accept a 1.732 mil gal per day design flow. 5.0 CONCLUSIONS The Town of Benson wastewater treatment plant can accept and successfully treat considerably more than its currently permitted capacity of 1.5 mil gals per day. This ability can be attributed to a number of factors, the most significant of which are the relatively low pollutant concentrations found within the wastewater, the presence of an extraordinarily large equalization facility, and the conservatism of the original plant design. A unit process by unit process evaluation of the plant has been conducted and based on that evaluation it has been concluded that the lirniting factor in plant performance will be the size of the final clarifiers. The final clarifiers could perform adequately at an average daily flow of 1.732 rnil. gals per day. Accordingly,it is concluded that the plant can operate as a 1.732 mil. gal per day tertiary treatment facility. The Town of Benson should therefore submit a request to the North Carolina Division of Water Quality that its plant be rerated as a 1.732 mil gal per day plant, and that its NPDES Permit be correspondingly modified. -13-