NC0020389_Pretreatment Compliance Inspection_20190723

ROY COOPER
';nvernr r
MICHAEL S. REGAN
.S.,rre.'ar j
LINDA CULPEPPEP
OirrUV
Mr. Tim Robbins
Director of Public Utilities
Town of Benson
PO Box 69
Benson, NC 27504
P,'_- TH GaPO1,l-
Envlr7nmental Quality
July 23, 2019
Subject: Pretreatment Compliance Inspection
Town of Benson WWTP
NPDCS Permit No. NCO020389
Johnston County
Dear Mr. Robbins:
On July 19, 2019, Cheng Zhang of the Raleigh Regional Office (RRO) conducted a
Pretreatment Compliance Inspection of Town of Benson's pretreatment program. The
assistance given by Mr. Brian Leavitt, Chief Operator of the WWTP, and Mr. Brian Gay,
consultant for the Town, was greatly appreciated. The inspection report is attached.
Findings during the inspection were as follows:
1. Chicopee, Inc. is the only Significant Industrial User (SIU) discharging to the Town of
Benson WWTP, which is not a Categorical Industrial User (CIU). It was noted that
the SIU was not in Significant Non -Compliance (SNC) for the two most recent semi-
annual periods.
2. A review of the files containing the pretreatment program elements was conducted.
All elements were up to date. Update of Headworks Analysis (HWA) is due April 1,
2020. The due date was extended to October 1, 2020 by the Division upon the
Town's request. Per the Town's Short Term Monitoring Plan, quarterly
sampling shall start in July 2019 in order to collect data for the HWA update.
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The pretreatment inspection file review included Chicopee, Inc. (Permit No. 0001).
The files needed for review were available, contained all the required elements and
were in good condition. Both the town and SIU have completed monitoring as
required by the Industrial User Pretreatment. The SIU was compliant during the
first six-month period of 2019.
Thank you for your continued support of the Pretreatment Program. If you have questions
regarding to the attached report or any of the findings, please contact Cheng Zhang at 919-
791-4200 (or email: [e-mail]).
Sincerely,
l
Rick Bolich, L.G.
Assistant Supervisor
Division of Water Resources
Raleigh Regional Office
Enclosure: Town of Benson PCI form
CC: Monti Hassan, DWR - FPERCS Unit
Cheng Zhang - RRO
Central Files
Brian Leavitt - Town of Benson (electronic copy only)

T
NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
BACKGROUND INFORMATION [Complete Prior To PCI• Review Program Info Database Sheets
1. Control Authority (POTW) Name: Town of Benson
2. Control Authority Representative(s): Brian Leavitt
3. Title(s): Chief O erator
4. Last Inspection Date:.luly� 21, 2017 Inspection Type (Check One): ❑ PCI ® Audit
5. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s)? ❑ YES 0 NO
6. Is POTW under an Order That Includes Pretreatment Conditions'? ❑ YES ® NO
Order Type, Number, Parameters: Are Milestone Dates Being Met? ❑ YES ❑ NO
ICIS CODING
Main Program Permit Number MCI DD YY
I-_N I C 10 1 0 1 21 0 1 3 1 81 9 1 107 1 191 19 1
7. Current Number Of Significant Industrial Users (SIUs)'?
I
8. Number of SIUs With No IUP, or With an Expired [UP?
0
9. Number of SIUs Not Inspected By POTW in the Last Calendar Year'
0
10. Number of SIUs Not Sampled BY-POTW in the Last Calendar Year?
0
11. Number of SIUs In SNC For Limits Violations During Either of the Last 2 Semi -Annual Periods?
0
12. Number of SIUs in SNC For Reporting During Either of the Last 2 Scmi-Annual Periods?
0
13. Number of SIUs in SNC with Pretreatment Schedule'?
0
14. Number of SIUs on Schedules`!
0
15. Current Number Of Categorical Industrial Users (C[Us)?
1
16. Number of CIUs in SNC?
0
POTN1' INTERVIEW
17. Since the Last PCI, has the POTW had any NPDES Limits Violations'? ® YES ❑ NO
If Yes, What are the Parameters and I -low are these Problems Being Addressed? BOD,ammonia,TRC,TSS,sludge
overflow
18. Since the Last PCI, has the Pam had any Problems Related to an Industrial ❑ YES 0 NO
Discharge (Interference, Pass -Through, Blockage, Citizens* Complaints, Increased
Sludge Production, Etc.)?
If Yes, f low are these Problems Being Addressed?
19. Which Industries have been in SNC for Limits or Reporting during ShC fir Limits: None
either of the Last 2 Semi -Annual Periods`? Not Been Published I'or SNC for Reporting: None
Public Notice?(May refer to PAR if Excessive SIUs in SNC) Not Published: None
20. Which Industries are on Compliance Schedules or Orders'? For all SIUs on an
Order, Has a Signed Copy of the Order been sent to the Division? None
21. Are Any Permits or Civil Penalties Currently Under Adjudication? If Yes, Which ❑ YES ®NO
Ones`?F-
LTMP/ST,iNIP FILE REVIEW:
22. Is LTNIP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies'? ❑ YES ❑ NO ® N.-'A
23. Are Correct Detection Levels being used for all LTNIP. STNIP Monitoring? ❑ YES ❑ NO ® N/A
24. Is LTNIP/STMP Data Maintained in a Table or Equivalent? ® NIA Is Table Adequate'? ❑ YES ❑ NO ®N/A
25. All LTMP/STMI' effluent data reported on Discharge Monitoring Report? ❑ N/A Division Inspector, please verify yourself,
26. If NO to 23 - 26, list violations
27. Should any Pollutants of Concern be Eliminated from or Added to LTNIP. STMP? ❑ YES ®NO
If yes, which ones'? Eliminated: Added:
NC DWR Pretreatment Compliance Inspection (PCI) Fonn Undated December 2016 Pare I

28. PRETREATit1ENT PROGIUMNl ELEMENTS REVIENV- Please review PO I'W fifes, verify POTW has copy of Program Clement in
their tiles, complete with supporting documents and copy of PERCS Approval Letter, and dates consistent with Program Info:
Program Element
Last Submittal
Date in tile?
Last Approval
Date In rile
Date Next Due,
If Applicable
Ileadworks Analysis(111VA)
5/812015
El Yes El No
9124/2015
Yes El No
10/1/2020
Industrial NN'aste Surve • (IWS)
6/7/2018
Yes 0 No
1213/2018
N Yes LJ No
6/1/2023
Server Use Ordinance SUO)
4/5/2013
Yes No
4111/2013
Z Yes No
Enforcement Response Plan (ERP)
4/16/2009
Yes No
612/2009
Yes No
Short Term iilonitoring Plan (STNIP)
10/31/2013
Yes No
117/2014
YesNo
INDUSTRIAL USER PERIMIT (IUP) FILE REVIEW (3 IUP I-ILE REVIEWS OR I FILE REVIEW AND I IU INSPECTION)
39. User Name
l .Chicopee, Inc.
�. 3.
30, IUP Number
0001
31. Does File Contain Current Permit?
® Yes No
32. Permit Expiration Date
12131121121
33. Categorical Standard Applied (I.E. 40 CFR, Etc,) Or N A
NIA
34. Does File Contain Permit Application Completed Within One Year Prior
ED Yes ElNo
F IF
to Permit Issue Date'?
35. Does File Contain an Inspection Completed Within I.ast Calendar Year?
Yes No
36. a. Does the File Contain a Slug;Spill Control Plan?
a. ®Yes ❑No
F
b. If No, is One Needed? (See Inspection Form from POT\V)
b, ❑Yes ❑No —
37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxi,
❑Yes❑NoO A
Organic Management Plan (TOMP)?
38. a. Does File Contain Original Permit Review Letter from the Di\ ision'
a_ ®Yes ON
b. All Issues Resolved'?
b ❑Yes❑No❑N
39. During the Most Recent Semi -Annual Period, Did the POl W Complete=
® Yes El
its Sampling as Required b IUP, includin = flow`?
40. Does File Contain POTW Sampling Chain -Or -Custody Fornis?
® Yes 0 No
41. During the Most Recent Semi -Annual Period, Did the SIU Complete its
®Yes❑No❑NIA
=
Sampling as Required b IUP, including flow?
41 b, During the Most Recent Semi -Annual Period, Did SIU submit all reports
OYesONo❑NiA
on time`?
42a. For categorical [Us with Combined Wastestream Formula (CWF), does
®Yeti❑No❑NIA
IF7
file include rocess dilution flows as Required by IUP?
42b. For categorical fUs with Production based limits, does file include
F®tiles❑Nu❑NSA
production rates andror flows as Re uired b lull?
43a. During the Most Recent Scmi-Annual Period, Did the POTW Identify
❑N'cs❑Nip®N/A
All Limits Non -Compliance from Both POTW and SIU Sampling?
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
❑Yes❑No®NIA
All Re ortin� Non -Compliance from SIU Sampling'?
44. a. Was the POTW Notified by SIU (Within 24 Hours) of -All Sell-
a.QYes❑No®N'A
Monitoring Violations'?
b. Did Industry Resample and submit results to POTW Within 30 Days'?
h.❑ti eti❑tio®`'A
c. If applicable, Did POTW resample within 30 days of becoming aware
c ❑Yes❑NuQN!A
of siu limit violations in the POTW's sampling of the SIU?
46. During the Most Recent Semi -Annual Period, Was the SIU in SNC?
El Yes No
47. During the Most Recent Semi -Annual Period, Was Enforcement "Laken
❑Yea❑NoE)
as Sp ecifted in the POI'W's ERP (NOVs, Penalties, timing, etc.)'?
48. Does the File Contain Penalty Assessment Notices?
❑Yes❑No®N�A
49. Does The File Contain Proof Of Penalty Collection'?
❑Yes❑1M)EI A
50. a. Does the File Contain Any Current Enforcement Orders'?
a.❑Ycs❑No®NIA
b. Is SIU in Compliance with Order?
b.❑Yeti❑NoGN1A
5 L Did the POTW Representative I -lave Difliculty in Obtaining Any of This
Yes ® No
Requested information For You?
NC DWR Pretreatment Compliance Inspection (PCI) Forin Updated December 2016 Page 2

FILE: REVIEW COMMENTS:
22-24 —Original due date for IINVA is April I, 2020. The due date is extended to October 1, 2021). ronv kill shirt quarterly- sampling
in .Jule 2019.
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number
1. Industry Inspected:
2. Industry Address:
3_ Type of Industry Product:
4. Industry Contact: Title:
MM DD W
Phone: Far:
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 Thorou011}"
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:
OV;RALL SUM-NiARY AND CO"I,MENTS:
Comments: The inspector noted the improvement in record kee ing and file or ■anizalion.
Requirements: Start STMP santplins in .Jul%- 2019.
Recommendations: None
NOD: ❑ YES ® NO
NOV: ❑ YES ® NO
QNCR: ❑ YES ®NO
POTW Ratinu:
® Satisfactury ❑ Marginal ❑ UnSatisfactor�
PCI COMPLETED BY: Cheng Zhang, Raleigh Regional Office DfkTE: ,Ittir 19, 2019
NC DWR Pretreatment Compliance Inspection (PCI) I-onn Undated December 2016 11aue 3