NC0020389_Pretreatment Audit_20231114

DocuSign Envelope ID: 5409A49B-FDC4-4B8B-86D5-3AC846886CA1
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Ms. Kimberly Pickett
Town Manager
Town of Benson
PO Box 69
Benson, NC 27504
NORTH CAROLINA
Environmental Quality
November 14, 2023
Subject: Pretreatment Compliance Audit
Town of Benson WWTP
NPDES Permit No. NCO020389
Johnston County
Dear Ms. Pickett:
On August 18, 2023, Cheng Zhang of the Raleigh Regional Office (RRO) conducted a Pretreatment
Compliance Audit of Town of Benson's pretreatment program. The assistance given by Mr. Brian
Leavitt, the wastewater superintendent and pretreatment coordinator, was greatly appreciated. The audit
report is attached. Findings during the inspection were as follows:
1. Town of Benson has one Significant Industrial User (SIU), which is not a Categorical Industrial
User (CIU). It was noted that the SIU was not in significant non-compliance (SNC) during the
two most recent semi-annual periods.
2. The pretreatment inspection file review included Chicopee Inc. (Permit No. 0001). It was noted
that the permit review letter was not available. Mr. Leavitt submitted the IUP to the Division for
review and approval during the audit.
3. The POTW and SIU completed monitoring as required by the IUPs during the first semi-annual
period of 2023. The SIU was compliant.
4. A review of the files containing the pretreatment program elements was conducted. These files
were available for review. It was noted that the Town failed to submit update of Industrial
Waste Survey to the Division before the due date (June 1, 2023).
5. As a modified program, the POTW is not required to sample for Short Term Monitoring Plan
(STMP) monitoring currently. Monitoring will resume one year before the next update of
Headworks Analysis is due.
6. As part of the audit, Mr. Leavitt conducted a thorough and detailed SIU inspection at Chicopee
Inc..
Please respond in writing to RRO within 30 days of receipt of this letter regarding Item 4.
North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Office I 3800 BarrettDrive I Raleigh, North Carolina 27609
NORTH CAROLINA ^ 919.791.4200
n�,Mo E,Amnm W1 Q­IR,

DocuSign Envelope ID: 5409A49B-FDC4-4B8B-86D5-3AC846886CA1
Thank you for your continued support of the Pretreatment Program. If you have any questions or
comments, please call Cheng Zhang at [phone] (or email: [e-mail]).
Sincerely,
DocuSigned by:
Vaun t,SSa -e. Btil atn tit
62916E6AB32144F...
Vanessa E. Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
Attachment(s): Town of Benson PT Audit Form
Cc: Laserfiche
Brian Leavitt, Town of Benson (Electronic copy only)
D � ��� North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611
NORTH CAROLINA ��` 919.707.9000

DocuSign Envelope ID: 5409A49B-FDC4-4B8B-86D5-3AC846886CA1
NORTH CAROLINA DIVISION OF WATER RESOURCES
1%" PRETREATMENT AUDIT REPORT
Water Resources
ENVIRONMENTAL QUALITY
Background Information [Complete prior to audit; review Program Info Database Sheet(s)]
1. Control Authority (POTW) Name: Town of Benson WWTP
2. Control Authority Representative(s): Brian Leavitt
3. Title(s): Wastewater Superintendent
4. Address of POTW:
Mailing 770 Hannah Creek Road
City Four Oaks Zip Code 27524
Phone Number 9198942373 Fax Number 9198945808 E-Mail pallen(dtownofbenson.com
5. Audit Date 8/18/2023
6. Last Inspection Date: 7/29/2021 Inspection Type: ® PCI ❑ Audit
7. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s) ? ❑ Yes ❑ No
If No, Explain.
8. In the last year has the POTW experienced any NPDES or Sludge Permit compliance problems? ® Yes ❑ No
If Yes, Explain. Multiple BOD, ammonia, TP violations, not related to industrial discharge
9. Is POTW under an Order That Includes Pretreatment Conditions? ❑ Yes ® No
Order Type and Number: Are Milestone Dates Being Met? ❑ Yes ❑ No ® NA
Parameters Covered Under Order
ICIS Coding
Main Program Permit Number
INIC10101210 13 18 19 1
MM/DD/YY
08 118 � 23
10.
.................................................................
Current Number of Significant Industrial Users(SIUs)?...............................................................................................
1
11.
....................................................................................................................................................................................................................................................................................................
Number of SIUs with No IUP, or with an Expired IUP?
0
12.
....................................................................................................................................................................................................................................................................................................
Number of SIUs Not Inspected by POTW in Last Calendar Year?
0
13.
....................................................................................................................................................................................................................................................................................................
Number of SIUs Not Sampled by POTW in Last Calendar Year?
0
14.
....................................................................................................................................................................................................................................................................................................
Number of SIUs in SNC for Limits Violations During Either of Last 2 Semi -Annual Periods?
0
15.
....................................................................................................................................................................................................................................................................................................
Number of SIUs in SNC for Reporting During Either of Last 2 Semi -Annual Periods?
0
16.
....................................................................................................................................................................................................................................................................................................
Number of SIUs in SNC with Pretreatment Schedule?
0
17.
....................................................................................................................................................................................................................................................................................................
Number of SIUs on Schedules?
0
18.
Current Number of Categorical Industrial Users..(CIUs)?............................................................................................
0
19.
Number of CIUs in SNC?
0
NC DWR Pretreatment Audit Form Revised: December 2016 Page 1

DocuSign Envelope ID: 5409A49B-FDC4-4B8B-86D5-3AC846886CA1
20. PRETREATMENT PROGRAM ELEMENTS REVIEW- Review POTW files, verify POTW has copy of each Program Element
in their File, complete with all supporting documents and PERCS Approval Letter, and dates consistent with Program Info:
Program Element
Last Submittal
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
9/25/2020
® Yes ❑ No
9/24/2015
® Yes ❑ No
4/1/2020
Industrial Waste Survey (IWS)
6/7/2018
® Yes ❑ No
12/3/2018
® Yes ❑ No
6/1/2023
Sewer Use Ordinance (SUO)
4/5/2013
® Yes ❑ No
4/11/2013
® Yes ❑ No
Enforcement Response Plan (ERP)
2/25/2020
® Yes ❑ No
3/17/2020
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
10/31/2013
® Yes ❑ No
1/7/2014
® Yes ❑ No
Legal Authority (Sewer Use Ordinance-SUO)
21. Do you have any towns and/or areas from which you receive wastewater which are not in your annexed jurisdiction?
® Yes ❑ No If yes, Please list these towns and/or areas. Town of Four Oaks and Johnston County
22. If yes to #21, Do you have current Interjurisdictional Agreements (IJAs) or other Contracts? ® Yes ❑ No ❑ NA
A copy, if not already submitted, should be sent to Division. IJA between the Town and the County is under negotiation
23. If yes to #21, Have you had any trouble working with these towns or districts? ® Yes ❑ No ❑ NA
If yes, Explain. The Town and County have not agreed in the duration of the IJA.
24. Date of Last SUO Adoption by Local Council 5/14/2013
25. Have you had any problems interpreting or enforcing any part of the SUO? ❑ Yes ® No
If yes, Explain.
Enforcement (Enforcement Response Plan-ERP)
26. Did you send a copy of the ERP to your industries? ❑ Yes ❑ No
If no, POTW must send copy within 30 days.
27. Have you had any problems interpreting or enforcing any part of the ERP (i.e. any adjudication, improper enforcement, etc?
❑ Yes ® No If yes, Explain.
28. List Industries under a Schedule or Order and Type of Schedule or Order
Resources
29. Please Rate the Followinc: S=Satisfactory M=Mareinal U=Unsatisfactory
Rating
Explanation, if Unsatisfactory
Personnel Available for Maintaining
POTW's Pretreatment Program
®S ❑M ❑U
Access to POTW Vehicles for
Sampling, Inspections, and
®S ❑M ❑U
Emergencies
Access to Operable Sampling
Equipment
®S ❑M ❑U
Availability of Funds if Needed for
Additional Sampling and/or Analysis
®S ❑M ❑U
Reference Materials
®S ❑M ❑U
Staff Training (i.e. Annual and
Regional Workshops, Etc.)
®S ❑M ❑U
Computer Equipment (Hardware and
Software)
®S ❑M ❑U
NC DWR Pretreatment Audit Form Revised: December 2016 Page 2

DocuSign Envelope ID: 5409A49B-FDC4-4B8B-86D5-3AC846886CA1
30. Does the POTW have an adequate data management system to run the pretreatment program? ® Yes ❑ No
Explain Yes or No. Microsoft Excel spreadsheets
31. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
No. Cost of Pretreatment Program comes from wastewater budget
Public Perception/ Participation
32. Are there any local issues affecting the pretreatment program (e.g.. odor, plant closing, new or proposed plants)?
❑ Yes ® No If yes, Explain.
33. Has any one from the public ever requested to review pretreatment program files? ❑ Yes ® No
If yes, Explain procedure. If no, how would the request be addressed? Pretreatment files except confidential information will be
available for public review
34. Has any industry ever requested that certain information remain confidential from the public? ❑ Yes ® No If yes, Explain
procedure for determining whether information qualified for confidential status, as well as procedure for keeping files confidential
from public. If no how would the request be addressed? Confidential information will be kept in a locked cabinet.
35. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatment? ® Yes ❑ No
36. Is the public notified about changes in the SUO or Local Limits? ® Yes ❑ No
37. Were all industries in SNC published in the last notice? ❑ Yes ❑ No ® NA
Permitting (Industrial Waste Survey-IWS)
38. How does the POTW become aware of new or changed Users? Utility accounts, town planning department
39. Once the POTW becomes aware of new or changed Users, how does the POTW determine which industries have the
reasonable potential to adversely impact the WWTP and therefore require a new permit or a permit revision? (Who is an
SLU?) Based on flow, pollutant discharge, categorical status, MAHL criteria, process flow
40. Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate?
❑Yes ®No If Yes, How many are there?
Please list each site and how it is permitted, if applicable.
41. Does the POTW accept waste by (mark if applicable) ® Truck ❑Dedicated Pipe ❑ NA
Will receive septage next year via septic receiving station
42. If the POTW accepts trucked waste, what controls are placed on this waste? (example. designated point, samples drawn,
manifests required) At designated point, random sampling
43. How does the POTW allocate its loading to industries? Mark all that apply
❑ Uniform Limits ® Historical Industry Need ❑ By Surcharge ❑ Categorical Limits ❑ Other
Explain Other:
44. Review POTW's copies of current allocation tables for each WWTP. Are there any over allocations? ❑ Yes ® No
If yes, what parameters are over allocated?
45. If yes to #44, What is being done to address the over allocations? (short-term IUPs, HWA to be revised, pollutant study, etc.)
N/A
46. Does the POTW keep pollutant loading in reserve for future growth / safety? ® Yes ❑ No
If yes, what percentage of each parameter 10%
47. Has the POTW experienced any difficulty in allocation? (for example: adjudication by an industry) ❑ Yes ® No
If yes, Explain.
48. How does the POTW decide on which pollutants to limit in the permits? Monitor for? (for example: were only those pollutants
listed on the application limited; categorical parameters; NPDES Pollutants of Concern)
Based on POCs, NPDES permit limits, categorical status
NC DWR Pretreatment Audit Form Revised: December 2016 Page 3

DocuSign Envelope ID: 5409A49B-FDC4-4B8B-86D5-3AC846886CA1
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
SIU monitoring: monthly; POTW monitoring: once/six months
Permit Compliance
50. Does the POTW currently have or during the past year had any permits under adjudication? ❑ Yes ® No
If yes, which industries? What was (will be) the outcome of the adjudication?
51. Demonstrate how the POTW judges compliance. This should include compliance judgment on all violations of limits, reporting
requirements, and permit conditions, as well as for SNC. Compare monthly monitoring data to IUP limits; stamp receipt dates
of SIU monitoring reports, use DWR compliance judgement sheet
52. Does the POTW use the Division's model inspection form or equivalent? ® Yes ❑ No
If no, does the POTW form include all Division data? ❑ Yes ❑ No
53. Were all SIUs evaluated for the need of a slug/spill control plan during their most recent inspections? ® Yes ❑ No
If no, Explain.
54. What criteria are used to determine if a slug/spill control plan is needed?
Based on industries' potential impact
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
Ensure contact information is up to date and accurate.
56. How does the POTW decide where the sample point for an SILT should be located?
At the end of the pipe before discharging to public sewer
57. Has the POTW established a procedure to ensure that representative samples will be taken by the POTW or SIU each time?
(example: correct location; proper programming of sampler; clean equipment; swirling the sample bucket uniformly)
POTW: ® Yes ❑ No SIU: ® Yes ❑ No If yes, Explain.
58. Who performs sample analysis for the POTW for Metals Waypoint Analvtical
Conventional Parameters POTW lab
Organics Environmental 1
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
Fill out COC, date and time of samples collected, signed by the collector. Need to use COC for in house parameters for
POTW samping
Long/Short Term Monitoring Plan (L/STMP) and Headworks Analysis (HWA)
60a. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ❑ YES ❑ NO ® NA
60b. Are Correct Detection Levels being used for all LTMP/STMP Monitoring? ❑ YES ❑ NO ® NA
60c. Is LTMP/STMP Data Maintained in Table or Equivalent? ❑ YES ❑ NO ® NA Is Table Adequate? ® NA
60d.
60e.
60f.
All LTMP/STMP effluent data on Discharge Monitoring Report (DMR)? ® NA Division Inspector, verify yourself!
If NO to any above, list violations
Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES ® NO
If yes, which ones? Eliminated: Added:
61. Do you complete your own headworks analysis (HWA) ? ❑ Yes ® No
If no, who completes your HWA? The Wooten Company Phone [phone]
62. Do you have plans to revise your HWA in the near future? ❑ Yes ® No
If yes, what is the reason for the revision? (mark all that apply) ❑Increased average flow ❑NPDES limits change
❑More LTMP data available ❑Resolve over allocation ❑5 year expiration ❑Other
Explain.
63. In general, what is the most limiting criteria of your HWA? ❑Inhibition ® Pass Through ❑Sludge Quality
64. Do you see any way to increase your loading in the future (Example: obtaining more land for sludge disposal)? ® Yes ❑ No
Explain. Plant upgrade and expansion (from 1.9 to 3.75 MGD)
NC DWR Pretreatment Audit Form Revised: December 2016 Page 4

DocuSign Envelope ID: 5409A49B-FDC4-4B8B-86D5-3AC846886CA1
Summary
65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment?
No
NC DWR Pretreatment Audit Form Revised: December 2016 Page 5

DocuSign Envelope ID: 5409A49B-FDC4-4B8B-86D5-3AC846886CA1
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS AND 1 IU INSPECTION)
66. User Name IF
1. Berry Global
2.
3.
67. IUP Number
0001
68. Does File Contain Current Permit?
® Yes ❑ No
❑ Yes ❑ No
[—]Yes ❑ No
69. Permit Expiration Date
12/31/2027
70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
N/A
71. Does File Contain Permit Application Completed Within One Year Prior
® Yes ❑ No
❑Yes ❑ No
❑ Yes ❑ No
to Permit Issue Date?
72. Does File Contain Inspection Completed Within Last Calendar Year?
® Yes ❑ No
❑ Yes ❑
I ❑ Yes ❑
No
73. a. Does File Contain Slug/Spill Control Plan?
a. ®Yes []No
a. []Yes ❑No
a. ❑Yes []No
b. If No, is One Needed? See Inspection Form from POTW)
b. ❑Yes ❑No
b. []Yes ❑No
b. ❑Yes ❑No
74. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
❑Yes❑NoON/A
F
❑Yes❑No❑N/A
❑Yes❑No❑N/A
Organic Management Plan (TOMP)?
75. a. Does File Contain Original Permit Review Letter from Division?
a. [-]Yes ®No
I
a. ❑Yes ❑No
a. ❑Yes []No
b. All Issues Resolved?
b.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
76. During Most Recent Semi -Annual Period, Did POTW Complete its
[A Yes ❑ No
FM77[:] No
❑ Yes ❑ No
Sampling as Required by IUP, including Flow?
77. Does File Contain POTW Sampling Chain -Of -Custody Forms?
® Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
78. During Most Recent Semi -Annual Period, Did SIU Complete its
®Yes❑No❑N/A
F
❑Yes❑No❑N/A
❑Yes❑No❑N/A
Sampling as Required b IUP, includingFlow?
1
79. During Most Recent Semi -Annual Period, Did SIU submit all reports on
®Yes❑No❑N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
time?
80a. For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes❑No®N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
file includeprocess/dilution flows as Required by IUP?
80b. For categorical IUs with Production based limits, does file include
❑Yes❑No[D
❑Yes❑No❑N/A
❑Yes❑No❑N/A
production rates and/or flows as Required by IUP?
81. During Most Recent Semi -Annual Period, Did POTW Identify All
❑Yes❑No®N/A
❑ Yes ❑ No
❑ Yes ❑ No
Limits Non -Compliance from Both POTW and SIU Sampling?
82. During Most Recent Semi -Annual Period, Did POTW Identify All
❑Yes❑No®N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
Re ortin Non -Compliance from SIU Sampling?
83. a. Was POTW Notified by SIU (Within 24 Hours) of All Self-
a.❑Yes❑No®N/A
a.❑Yes❑No❑N/A
a.❑Yes❑No❑N/A
Monitoring Violations?
b. Did Industry Resample and submit results to POTW within 30 Days?
b.❑Yes❑No®N/A
b.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
c. If applicable, did POTW resample and obtain results within 30 days of
❑ c.Yes❑No®N/A
becomingaware of SIU limit violations in the POTW's sampling of SIU?
c.❑Yes❑No❑N/A
c.❑Yes❑No❑N/A
84. During Most Recent Semi -Annual Period, Was SIU in SNC?
❑
Yes
®
No
❑
Yes
❑
No
❑
Yes
❑
No
85. During Most Recent Semi -Annual Period, Was Enforcement Taken as
❑Yes❑No®N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
Specified in POTW's ERP (NOVs, Penalties, timing, etc.)?
86. Does File Contain Penalty Assessment Notices?
0Yes0No[9
❑Yes❑No❑N/A
❑Yes❑No❑N/A
87. Does File Contain Proof Of Penalty Collection?
❑Yes❑No[D
❑Yes❑No❑N/A
❑Yes❑No❑N/A
88. a. Does File Contain Any Current Enforcement Orders?
a.❑Yes❑No®N/A
a.❑Yes❑No❑N/A
a.❑Yes❑No❑N/A
b. Is SIU in Compliance with Order?
b.❑Yes❑No®N/A
b.❑Yes❑No❑N/A
b.❑Yes❑No❑N/A
89. Did POTW Representative Have Difficulty in Obtaining Any Requested
❑ Yes ® No
❑ Yes ❑ No
❑ No
Information For You?
L!::
FILE REVIEW COMMENTS:
75 — The POTW submitted the IUP to the Division for review and approval on the day of audit.
NC DWR Pretreatment Audit Form Revised: December 2016 Page 6

DocuSign Envelope ID: 5409A49B-FDC4-4B8B-86D5-3AC846886CA1
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
I N I C 1 0 IO I2 IO 13 18 I9 I I08 I18 I23 I
1. Industry Inspected: Chicopee, Inc
2. Industry Address: 1203 Chicopee Rd, Benson, NC 27504
3. Type of Industry/Product: Textile/Non-woven wipes, filters
4. Industry Contact: Matt Rice
Title: ESH Manager Phone: Fax:
5. Does the POTW Use the Division Model Inspection Form or Equivalent? ® Yes ❑ No
6. Did the POTW Contact Conduct the Following Parts of the Industrial Inspection Thoroughly?
Comments:
A. Initial Interview
® Yes ❑ No
B. Plant Tour
® Yes ❑ No
C. Pretreatment Tour
® Yes ❑ No
D. Sampling Review
® Yes ❑ No
E. Exit Interview
® Yes ❑ No
Industrial Inspection Comments:
The inspection was thorough and covered all required areas.
Audit SUMMARY AND COMMENTS:
Audit Comments: The POTW has significantly improved its pretreatment program.
Requirements: Submit update of IWS for review and approval; use COC for in house parameters in POTW sampling
Recommendations: None.
NOD: ❑ Yes ® No
NOV: ❑ Yes ® No
QNCR: ❑ Yes ® No
POTW Rating:
Satisfactory ❑ Marginal ® Unsatisfactory ❑
Audit COMPLETED BY: Cheng Zhang, Raleigh Regional Office DATE: 8/18/2023
NC DWR Pretreatment Audit Form Revised: December 2016 Page 7