NC0020389_Pretreatment Compliance Audit_20170815

i.,
iy
Water Resources
E` ARONH[NTAL ©UAMTY
August 15, 2017
Mr. Matt Zapp
Town Manager
Town of Benson
PO Box 69
Benson, NC 27504
Subject- Pretreatment Compliance Audit
Town of Benson WWTP
NPDES Permit No. NCO020389
Johnston County
Dear Mr. Zapp
ROY COOPER
Got tyror
MICHAEL S. REGAN
St Croo"y
S. JAY ZIMMERMAN
Defector
RECEIVED/NCDENWR
AUG 18 2017
Water Quainy
Permitting Section
On July 21, 2017, Monti Hassan of the Pretreatment, Emergency Response, and Collection Systems
(PERCS) Unit and 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. Paul Allen,
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 and Slug/Spill Control Plan could not be located. Industrial permit
files need to be better organized.
The POTW and SIU completed monitoring as required by the IUPs during the first semi-annual
period of 2017. The SIU had two BOD limit violations in January 2017. At the time of the
audit, no enforcement actions were taken against these violations. The POTW must take
enforcement actions as specified by the Enforcement Response Plan. It was noted that
compliance judgement was not conducted appropriately, violations identified from POTW
sampling must be included when judging compliance.
4. A review of the files containing the pretreatment program elements was conducted These files
were available for review All elements were up to date Please be reminded that an update of the
Industrial Waste Survey is due by June 1, 2018
5. As a modified program, the POTW is not required to sample for Short Tenn Monitoring Plan
(STMP) monitoring currently. Monitoring will resume one year before the next update of
Headworks Analysis is due (April 1, 2020).
Division of Water Re,,olllces, Raleigh Regional Office, water Quality Operations Section bttp //deq ne gov/aboutfdrvr5ions/t,,<rter-resources
1628 Mail Service Center, Raleigh, NC 27699-1628 Phone [phone]
Location 3800 Barrett Drive, Raleigh, NC 27609 Fax [phone]

6. The scheduled SIU inspection hac to be canceled due to power outrage at the industry.
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: cheng zhang@ncdenr gov)
,Sincerl,
Danny Smtf h
Water Quality Regional Supervisor
Raleigh Regional Office
Enclosure 2017 Benson PT Audit Form
CC Monti Hassan, DWQ - PERCS Unit
Central Files
Cheng Zhang, RRO
Paul Allen, 770 Hannah Creek Rd, Four Oaks NC 27524

M L; NORTH CAROLINA DIVISION OF WATER RESOURCES
,PRETREATMENT AUDIT REPORT
Background Information [Complete prior to audit, re-�ievv Program Into Database Sheet(s)]
1 Control Authority (P01 W) Name Town of Benson NNNNTP
2 Control Authority Representative(,) Paul Allen
3 Title(s) Wasteyvater Superintendent
4 Addre„ of POT'%V
Mailing 770 Hannah Creek Road
Cray Four Oaks Zip Code 27524
Phone Number 9198942373 Fax Number 9198945808 E -Mail pallen r tovvnofbenson com
Audit Date 7 21 2017
6 Last Inspection Date 7 26 2016 Inspection Type ❑ PC I ❑ Audit
7 Has Program Completed All Requirement,, from the Pre%loU, Inspection and Pr <__>ram Into Shcet(,) " ❑ Yes ❑ No
If No Explain
8 In the la,t year ha, the POTW experienced any NPDES or Shidge Permit compliance problems ❑ Yep ❑ No
If Yes Explain One BOD «eekly a--erage Ntolat►on of NPDES Permit
9 I, POTW under an Order That Includes Pretieatment Conditions', ❑ Ye, ❑ No
Ordei Type and Number Aje. Milestone Date, Beira, Met'' ❑ Yes ❑ No ❑ NA
Parameters Covered Under Order
ICIS Coding
Jlam Program Permit Numbci
N 1C1010 12 10 13 18 19
\1%1 DD YY
7 121 117
10 Current Number of Significant Industrial Users (SIU,,)"
t 1 Number of SIUs ��ith No IUP, or a ith an Expned IUP'
12 Numbei of SIU, Not Inspected by POTW in La,t Calcndai Yeai z
13 Number of SIU, Not Sampled by POTW in Last Calendar Year's
14 Number of SIU, in SNC for Limits Violation, During Eithei of Last 2 Semi -Annual Periods)
15 Numbei of SIUs to SNC for Reporting During Either of La,t 2 Semi -Annual Peiiod>"
16 Numbei of SIUs it SNC �N ith Pietreatment Schedulc'a
17 Numbei of SIUs on Schedule,')
18 Current Number of Categoiteal Industiial Useis (CIU„)”
19 Numbei of CIU, in SNG"
I
0
0
0
0
0
0
0
0
0

�U. 1 1%L` l XXXIt111V1L` L\ 1 L 1XV"X%-'llVX L` LL' 1V1L` 1\ 10 r JP. V 11.' VV - 1,U V1G W TU 1 VV L11GJ, VGllly F%-) 1 VV 11d6 GUyy U1 UdUll FIUgldlll 1:1G111GI1L
in their File. comnlete with all sunnortme documents and PFRCS Annroval Tetter_ 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)
5/18/2015
® Yes ❑ No
9/24/2015
® Yes ❑ No
4/1/2020
Industrial Waste Survey (IWS)
6/4/2013
® Yes ❑ No
7/29/2013
® Yes ❑ No
6/1/2018
Sewer Use Ordinance (SUO)
4/5/2013
® Yes ❑ No
4/11/2013
® Yes ❑ No
Equipment
Enforcement Response Plan (ERP)
4/16/2009
® Yes ❑ No
6/2/2009
® Yes ❑ No
Additional Sampling and/or Analysis
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
22 If yes to #21, Do you have current Interjurisdictional Agreements (IJAs) or other Contracts9 ® Yes ❑ No ❑ NA
A copy, if not already submitted, should be sent to Division
23 If yes to #21, Have you had any trouble working with these towns or districts ❑ Yes ® No ❑ NA
If yes, Explain
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 SU09 ❑ 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 FollowinE S=Satisfactory M=Mammal U=Unsatisfactory
Rating
Explanation, if Unsatisfactory
Personnel Available for Maintaining
Two fulltime personnel
POTW's Pretreatment Program
®S ❑M ❑U
Access to POTW Vehicles for
4 vehicles (one dedicated to pretreatment)
Sampling, Inspections, and
®S ❑M ❑U
Emergencies
Access to Operable Sampling
One sampler, split samples with contract lab
Equipment
®S ❑M ❑U
Availability of Funds if Needed for
Additional Sampling and/or Analysis
®S ❑M ❑U
Reference Materials
Books, manuals
®S ❑M ❑U
Staff Training (i e Annual and
Plan to attend 2018 PAR and HWA workshop
Regional Workshops, Etc )
®S ❑M ❑U
Computer Equipment (Hardware and
Three PCs, internet
Software)
®S ❑1'I ❑U

30 Does the POTW have an adequate data management system to run the pretreatment program9 ®Yes ❑ No
Explain Yes or No Microsoft Excel spreadsheets
31 How does the POTW recover the cost of the Pretreatment Program from their mdustries9 Explain
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)9
❑ Yes ® No If yes, Explam
33 Has anyone from the public ever requested to review pretreatment program files9 ❑ Yes ® No
If yes, Explain procedure If no, how would the request be addressed9
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?
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 Limits9 ❑Yes ® No
37 Were all industries in SNC published in the last notice9 ❑ 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
SIU9) Based on flow, pollutant discharge, categorical status, vIAHL criteria, process flow
40 Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate9
❑Yes ®No If Yes, How many are there9
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
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 done
43 How does the POTW allocate its loading to mdustries9 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 allocations9 (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 perrmts? Monitor for9 (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
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 mdustnes9 What was (will be) the outcome of the adjudication
51 Demonstrate how the POTW fudges 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 PERCS compliance judgement sheet
52 Does the POTW use the Division's model mspect-on 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 POTW could not locate the updated SPCP.
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 deteiTmne 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 SIU should be located
At the end of the pipe before discharging to put -lie 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 Environmental 1
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
-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 All LTMP/STMP effluent data on Discharge M=onitoring Report (DMR)? ® NA Division Inspector, verify yourself'
60e If NO to any above, list violations
60f Should any Pollutants of Concern be Eliminate from or Added to LTMP/STMP9 ❑ YES ® NO
If yes, which ones? Eliminated Added
61 Do you complete your own headworks analysis (H Vv A) 9 ❑ 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
❑More LTMP data available
Explain
❑Resolve over allocation
05 year expiration
❑NPDES limits change
❑Other
63 In general, what is the most limiting criteria of your HWA9 ❑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
i
65 Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment9

66 User Name
1 Chicopee, Inc
2
3
67 IUP Number
0001
68 Does File Contain Current Perrrut?
® Yes ❑ No 11
❑Yes ❑ N—o-11
❑Yes ❑ No
69 Permit Expiration Date
J 12/31/2021
70 Categorical Standard Applied (I E 40 CFR, Etc,' Or N/A
I N/A
71 Does File Contain Permit Application Completec 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 ❑
No1
❑ Yes ❑ No
❑ Yes ❑ No
73 a Does File Contain Slug/Spill Control Plan?
a ❑Yes ®No
a ❑Yes ❑No
a FO Yes ❑No
b If No, is One Needed9 (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❑NoNN/A
❑Yes❑No❑N/A
Orgamc Management Plan (TOMP)?
F❑Yes❑No❑N/A
75 a Does File Contain Original Permit Review Letter from Divisions
❑Yes ®No
a ❑Yes No
a ED] es ❑No
b All Issues Resolved
Fb ❑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
® Yes ❑ NoF
❑ Yes ❑ No
❑ No
Sampling as Required by IUP, including Flow?
1[7Ws
77 Does File Contain POTW Sampling Cham -Of -Custody Forms9
®Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
78 During Most Recent Semi -Annual Period, Did SIU Complete its
®Yes❑No❑N/A❑Yes❑No❑N/A
❑Yes❑No❑N/A
Sampling as Required by IUP, including Flow
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 include process/dilution flows as Required by IUP?
80b For categorical IUs with Production based limits, does file include
❑Yes❑No®N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
production rates and/or flows as Required by IUPC
1
1
81 During Most Recent Semi -Annual Period, Did POTW Identify All
® Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
Limits Non -Compliance from Both POTW and SIU Sampling?
82 Dunn- Most Recent Semi -Annual Period, Did POTW Identify All
❑Yes❑No®N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
Reporting 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 PO—_W within 30 Days9
b ❑Yes❑No®N/A
b ❑Yes❑No❑N/A
b ❑Yes❑No❑N/A
c If applicable, did POTW resample and obtain res-ilts within 30 days of
becoming aware of SIU limit violations in the POTW's sampling of SIU9
c ❑Yes❑No®N/A
c ❑Yes❑No❑N/A
c ❑Yes❑No❑N/A
84 During Most Recent Semi -Annual Period, Was SIU in SNCL
❑ Yes ® No
I ❑ Yes ❑ No
1 ❑ 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 )9
86 Does File Contain Penalty Assessment Notices
❑Yes❑No®N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
87 Does File Contain Proof Of Penalty Collection9
❑Yes❑No®N/A
❑Yes❑No❑N/A
❑Yes❑No❑N/A
88 a Does File Contain Any Current Enforcement Orders9
a ❑Yes❑NouN/A
❑Yes❑No❑N/A
a ❑Yes❑No❑N/A
b Is SIU in Compliance with Order?
b ❑Yes❑No®N/A
Fb ❑Yes❑No❑N/A
b ❑Yes❑No❑N/A
89 Did POTW Representative Have Difficulty in Obtaining Any Requested
® Yes ❑ No
❑Yes ❑ No
❑ Yes ❑ No
Information For You9
FILE REVIEW COMMENTS:
73 — Slug/Spill Control Plan could not be located
75 — IUP review letter could not be located
81 — The SIU had two BOD violations in January 2017
85 — The POTW did not take enforcement against the BOD violations as required by the ERP

111 11\Vl 1JV 11V1\ 11..1V I.VLll\V•
Main Program Permit Number MM/DD/YY
INICIO IO 1 I I I I 1 I 1
1 Industry Inspected
2 Industry Address
3 Type of Industry/Product
4 Industry Contact Title Phone Fax
5 Does the POTW Use the Division Model Inspection Form or Equivalent9 ❑ Yes ❑ No
6 Did the POTW Contact Conduct the Following Parts of the Industrial Inspection Thoroughly9
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:
Industrial inspection had to be canceled due to power outrage at the industry
Audit SUMMARY AND COMMENTS:
Audit Comments The program experienced setbacks due to the sudden death of the previous coordinator and needs improvement
in file organization, taking enforcement actions within the timeframe specified in the ERP. and compliance judgement.
Requirements Issue NOV for the BOD violations in January 2017. Request industry to submit updated Slug/Spill Control Plan.
Violations from POTW sampling must be included when judging compliance.
Recommendations The coordinator is encouraged to attend pretreatment workshops (PAR, IUP, HWA etc.) provided by the
Division.
NOD: ❑ Yes
NOV: ❑ Yes
QNCR: ❑ Yes
POTW Rating:
Satisfactory ❑ Marginal ® Unsatisfactory ❑
Audit COMPLETED BY: Monti Hassan PERCS. and Cheng Zhang, Raleigh Regional Office DATE: 7/21/2017