NC0082376_Permit Issuance_20080905

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Michael F. Easley, Governor
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State of North Carolina
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William G. Ross, Jr., Secretary
Department of Environment and Natural Resources
Coleen H. Sullins, Director
Division of Water Quality
September 5, 2008
Mr. J. Russell Allen
City Manager
City of Raleigh
P.O. Box 590
Raleigh, North Carolina 27602
Subject: Issuance of NPDES Permit
Permit No. NCO082376
E.M. Johnson WTP
Wake County
Dear Mr. Allen:
Division personnel have reviewed and approved your application for renewal of the subject permit.
Accordingly, we are forwarding the attached NPDES discharge permit. 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 October 15, 2007 (or as subsequently
amended).
There are tthree changes in this final permit from the draft permit sent to you:
➢ A footnote has been modified to clarify Total Residual Chlorine reporting requirements.
➢ . At the request of Public Water Supply, weekly fecal coliform monitoring has been added in the
event that you discharge in the future. No limit is imposed at this time.
➢ Special Condition (A.(7)) has been added. The Planning Unit has requested that if at all possible,
the facility should make any future discharges during- winter months, when additional nutrients
will have less effects on algal blooms. In the event that Public Water Supply requires a discharge
at a different time, the facility has to comply with PWS requirements.
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 demand is made, this decision shall be
final and binding.
Please note that 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
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required by the Division of Land Resources, the Coastal Area Management Act or any other Federal or Local
governmental permit that may be required
North Carolina Division of Water Quality [phone]
1617 Mail Service Center FAX [phone]
Raleigh, North Carolina 27699-1617 On the Internet at http://h2o.enr.state.nc.us/

If you have any questions concerning this permit, please contact Jim McKay at telephone number
[phone]. '
Sincerel ,
Col e6 n H. Sullins
cc: NPDES Files
Central Files
Raleigh Regional Office/Surface Water Protection
EPA Region 4
Marilyn Grolitzer ([e-mail]) PDF
Ron Gregory ([e-mail]) PDF
Nora Deamer ([e-mail]) PDF

Permit NCO082376
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 provision of North Carolina General Statute 143-215.1, other lawful standards
and regulations promulgated and adopted by the North Carolina Environmental Management
Commission, and the Federal Water Pollution Control Act, as amended, the
City of Raleigh
is hereby authorized to discharge wastewater from a facility located at the
E.M. Johnson Water Treatment Plant (WTP)
10301 Falls of Neuse Road
Raleigh
Wake County
to receiving waters designated as an unnamed tributary to the Neuse River (outfall 001) and
an unnamed tributary to Honeycutt Creek - arm of Falls Lake (Outfall 002 and Outfall 003) in
the Neuse River Basin
in accordance with effluent limitations, monitoring requirements, and other conditions set
forth in Parts I, II, III, and IV hereof.
The permit shall become effective October 1, 2008.
This permit and the authorization to discharge shall expire at midnight on February 28, 2013.
Signed this day September 5, 2008.
. L
6. Co een H. S s, Director -
Division of Water Quality
By Authority of the Environmental Management Commission

f`
Permit NCO082376
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby
revoked. As of this permit issuance, any previously issued permit bearing this number is no
longer effective. Therefore, the exclusive authority to operate and discharge from this facility
arises under the permit conditions, requirements, terms, and provisions included herein.
The City of Raleigh is hereby authorized to:
1. Continue to discharge treated filter backwash water and associated wastewater from
residuals processing, which includes the following components:
♦ Two backwash clarifiers
♦ Filtrate pump station
♦ Flow sputter box
♦ Three sludge thickeners
♦ Parshall flume
♦ Polymer and caustic feed systems
Thickened sludge pump station
(with diversion to blending tanks or sludge disposal facility)
♦ Four sludge blending tanks
(residuals pumped to sludge disposal facility or filter presses)
♦ Three belt filter presses (drainage to sanitary sewer pump station)
truck hauling and concrete pad for residuals
belt filter press washwater pumps
belt conveyors
♦ Twelve sand drying beds (drainage to sanitary sewer pump station)/ containment pad
♦ Refer to Permit No. WQ0008431 for components specific to the sludge disposal facility.
Decanted wastewater from the sludge disposal facility is directed to the sanitary sewer pump
station.
♦ Dechlorination and automatic pH control system
♦ Refer to Permit No. WQ0022036 for the bulk reclaimed water distribution program (and
associated approvals and components).
This facility is located at the E.M. Johnson Water Treatment Plant at 10301 Falls of Neuse Road
in Wake County.
2. Discharge from Outfall 001 at the location specified on the attached map into an unnamed
tributary of the Neuse River, classified as WS-IV-NSW waters in the Neuse River Basin. 001
- Discharge from overflow from the east raw water reservoir and possible discharge of
treated water/wastewater (located across Falls of the Neuse Road from the water treatment
plant).
3. Discharge from Outfalls 002 and 003 at the locations specified on the attached map into an
unnamed tributary to Honeycutt Creek (arm of Falls Lake), classified as WS-IV-NSW waters
in the Neuse River Basin. 002 - Dischar a of wastewater associated with the treatment of
water for drinking purposes (main wastewater discharge), and leakage om e p ant ­---­
t
clearwells. 003 - Discharge of stormwater and overflow from the west raw water reservoir
from the culvert directly upstream of Outfall 002

r_u
Ouifall 002
UT Honeycutt Creek, arm of Falls
Lake, WS-IV NSW
350 54' 56" N, 780 35" 59" W
ft
II 35054' 56" Creek, NSW
N, 780 35" 58" W
River Basin:
Neuse
Sub -Basin:
03-04-01
Quad #:
D24NE, Wake Forest
Permitted Flow:
8.8 MGD Outfalls 001, 002 and 003
J
Outfall 001 I
LIT Neuse River, WS-IV NSW
350 54' 38" N, 780 35" 25" W
u
Facility
Location AOW
Raleigh - E.M. Johnson WTP
D�r NC0082376

Permit NC0082376
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of the permit and lasting. until expiration, the
Permittee is authorized to discharge wastewater associated with the water treatment plant from
Outfall 001 (outfall located across Falls of the Neuse). Such discharges shall be limited and
monitored by the Permittee as specified below:
Effluent Characteristics
Limits
Monitoring Requirements
Monthly
Average
Weekly
Average
Daily
Maximum
Measurement
Fre uency
Sample Typel
Sample
Location
Flow
Weekly
Estimate
Effluent
Total Suspended Solids
30.0 mqjL
45.Om IL
Weekly
Grab
Effluent
Total Residual Chlorine
17 lL 2
Weekly
Grab
Effluent
NH3-N (mg/1)
Monitor & Report
Monthly
Grab
Effluent
TKN (mg/1)
Monitor & Report
Monthly
Grab
Effluent
NO2-N + NO3-N (mgll)
— Monitor & Report
Monthly
Grab
Effluent
TN (mgll) 3
Monitor & Report
Monthly
Grab
Effluent -
Total Monthly Flow (MG)
Monitor & Report
Monthly
Calculated
Effluent
TN Load 4
Monitor & Report
(Annual Mass Loading) 5
Monthly
Annually
Calculated
Calculated
Effluent
Effluent
Total Phosphorus
2.0 mglL (Quarterly Average) 6
Monthly
Grab
Effluent
Total Copper
I Weekly
Grab
Effluent
Total Iron
Weekly
Grab
Effluent
Total Manganese
200 u IL
Weekly
Grab
Effluent
Total Aluminum
Quartedy
Grab
Effluent
Total Barium
Quarterly
Grab
Effluent
Total Calcium
Quarterly
Grab
Effluent
Total Lead
Quarterly
Grab
Effluent
Total Magnesium
Quarterly
Grab
Effluent
Total Nickel
Quarterly
Grab
Effluent
Total Zinc
Quartedy
Grab
Effluent
Chronic Toxicity 7
Quarterly
Grab
Effluent
Fecal Coliform
Weekly
Grab
Effluent
PH 6
Weekly
Grab
Effluent

Permit NCO082376
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Continued)
NOTES:
1. Due to the remote location of Outfall 001 and the infrequency of discharge, the City may
conduct grab samples for all parameters at Outfall 001.
2. The Division shall Consider all effluent TRC values reported below 50 ug/l to be in
compliance with the permit. However, the Permittee shall continue -to record and submit all
values reported by a North Carolina certified laboratory (including field certified), even if
these values fall below 50 ug/l.
3. TN means Total Nitrogen. For a given wastewater sample, TN is the sum of Total Kjeldahl
Nitrogen and Nitrate -Nitrite Nitrogen: TN = TKN + NO2-N + NO3-N.
4. TN Load is the mass load of TN discharged by the Permittee in a period of time. See Special
Condition A.(4.), Calculation of TN Loads.
S. Annual TN load must be reported. Annual TN load is not limited for this permit cycle. See
Special Condition A.(4.), Calculation of TN Loads.
6. The quarterly average for total phosphorus shall be the average of composite samples
collected monthly during each calendar quarter (January - March, April - June, July -
September, October - December).
7. Chronic Toxicity (Ceriodaphnia dubia) Monitoring at 90%: February, May, August, and
November [see Special Condition A.(5). Quarterly metals monitor shall coincide with
quarterly toxicity monitoring.
8. The pH shall not be less than 6.0 nor greater than 9.0 standard units.
All samples collected should be representative of the discharge.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
There shall be no discharge of waste or chemicals that do not directly result from the
responsible treatment of raw water.

Permit NCO082376
A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of the permit and lasting until expiration, the
Permittee is authorized to discharge wastewater associated with the water treatment plant from
Outfalls 002 (main wastewater outfall). Such discharges shall be limited and monitored by the
Permittee as specified below:
Effluent Characteristics
Limits
Monitoring Requirements
Monthly
Average
Weekly
Average
Daily
Maximum
Measurement
Frequency
Sample Type
Sample
Location
Flow
8.8 MGD
Continuous
Recordin
Effluent
Total Suspended
Solids
30.0 m
45.0 m /L
Weekly
Composite
Effluent
Total Residual
Chlorine
1
17 [L 1
Weekly
Grab
Effluent
NH3-N (mgll)
Monitor & Report
Monthly
Composite
Effluent
TKN (mgll)
Monitor & Report
Monthly
Composite
Effluent
NO2-N + NO3-N (mgll)
Monitor & Report
Monthly
Composite
Effluent
TN (mgll) 2
Monitor & Report
Monthly
Composite
Effluent
Total Monthly Flow (MG)
Monitor & Report
Monthly
Calculated
Effluent
TN Load 3
Monitor & Report
(Annual Mass Loading) 4
Monthly
Annually
Calculated
Calculated
Effluent
Effluent
Total Phosphorus
2.0 mg/L (Quarterly Average) 5
Monthly
Composite
Effluent
Total Copper
Weekly
Composite
Effluent
Total Iron
Weekl
Composite
Effluent
Total Manganese
200 u /L
Weekly
Composite
Effluent
Total Aluminum
Quarterly
Composite
Effluent
Total Barium
Quarterly
Composite
Effluent
Total Calcium
Quarterly
Composite
Effluent
Total Lead
Quarterly
Compsite
Effluent
Total Magnesium
Quarterly
Composite
Effluent
Total Nickel
Quarterly
Composite
Effluent
Total Zinc
Quarterly
Composite
Effluent
ChronlcToxicitYS
Quarterly
Composite
Effluent
Fecal Coliform
Weekly
Grab
Effluent
PH 7
Weekly
Grab
Effluent

S
Permit NCO082376
A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Continued)
NOTES:
1. The Division shall consider all effluent TRC values reported below 50 ug/l to be in
compliance with the permit. However, the Permittee shall continue to record and submit all
values reported by a North Carolina certified laboratory (including field certified); even if
these values fall below 50 ug/l.
2. TN means Total Nitrogen. For a given wastewater sample, TN is the sum of Total Kjeldahl
Nitrogen and Nitrate -Nitrite Nitrogen: TN = TKN + NO2-N + NO3-N.
3. TN Load is the mass load of TN discharged by the Permittee in a period of time. See Special
Condition A.(4.), Calculation of TN Loads.
4. Annual TN load must be reported. Annual TN load is not limited for this permit cycle. See
Special Condition A.(4.), Calculation of TN Loads.
5. The quarterly average for total phosphorus shall be the average of composite samples
collected monthly during each calendar quarter (January - March, April - June, July -
September, October - December).
6. Chronic Toxicity (Ceriodaphnia dubia) Monitoring at 90%: February, May, August, and
November [see Special Condition A.(5). Quarterly metals monitor shall coincide with
quarterly toxicity monitoring.
7. The pH shall not be less than 6.0 nor greater than 9.0 standard units.
All samples collected should be representative of the discharge.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
There shall be no discharge of waste or chemicals that do not directly result from the
responsible treatment of raw water.

Permit NCO082376
A. (3.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of the permit and lasting until expiration, the
Permittee is authorized to discharge wastewater associated with overflow from the west raw
water terminal reservoir from Outfall 003 (drainage from the culvert above Outfall 002). Such
discharges shall be limited and monitored by the Permittee as specified below only for water
associated with overflow of the west raw water terminal reservoir. Stormwater discharged
through Outfall 003 will continue to be permitted and regulated by NPDES Stormwater
Discharge Permit NCS000245
Effluent Characteristics
Limits
Monitoring Requirements
Monthly
Average
Weekly
Avera a
Daily
Maximum
Measurement
Frequency
Sample Type
Sample
Location
Flow
WeeklyEstimate
Effluent
Total Suspended Solids
MonthlyGrab
Effluent
Total Residual Chlorine
Monthl
Grab
Effluent
NH3-N (mgll)
Monthly
Grab
Effluent
TN (mgll)
Monthly
Grab
Effluent
Total Phosphorus
2.0 mg/
L (Quarterly Average)
Monthly
Grab
Effluent
Total Copper
Monthly
Composite
Effluent
Total Iron
Total Manganese
200 u / L
Monthly
Monthly
Composite
Composite
Effluent
Effluent
Total Aluminum
Quarterly
Composite
Effluent
Total Barium
Quarterly
Composite
Effluent
Total Calcium
Quarterly
Composite
Effluent
Total Lead
Quarterly
Composite
Effluent
Total Magnesium
Quarterly
Composite
Effluent
Total Nickel
Quarterly
Composite
Effluent
Total Zinc
Quarterly
Composite
Effluent
PH 2
Monthly
Grab
Effluent
NOTES:
1. The quarterly average for total phosphorus shall be the average.of composite samples
collected monthly during each calendar quarter (January — March, April — June, July —
September, October — December).
2. The pH shall not be less than 6.0 nor greater than 9.0 standard units.
All samples collected should be representative of the discharge.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
There shall be no discharge of waste or chemicals that do not directly result from the
responsible treatment of raw water.

Permit NCO082376
A.(4.) CALCULATION OF TOTAL NITROGEN LOADS
a. The Permittee shall calculate monthly and annual TN Loads as follows:
L Monthly TN Load (lb/mo) = TN x TMF x 8.34
where:
TN = the average Total Nitrogen concentration (mg/ L) of the composite samples
collected during the month
TMF = the Total Monthly Flow of wastewater discharged during the month (MG/mo)
8.34 = conversion factor, from (mg/ L x MG) to pounds
ii. Annual TN Load (lb/yr) = Sum of the 12 Monthly TN Loads for the calendar year
b. The Permittee shall report monthly Total Nitrogen results (mg/ L and lb/ mo) in the
discharge monitoring report for that month and shall report each year's annual results
(lb/yr) in the December report for that year.
A.(5.) CHRONIC TOXICITY MONITORING (QUARTERLY]
The permittee shall conduct chronic toxicity tests using test procedures outlined in the "North
Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure", Revised February 1998 or
subsequent versions.
The effluent concentration defined as the Instream Waste Concentration (IWC) shall be 90%.
The chronic. value 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
described by the document referenced above.
The permit holder shall perform at a minimum, guarierIu monitoring using these procedures to
establish compliance with the permit condition. The tests will be performed during the months
of February, May, August, and November. Effluent sampling for this testing shall be
performed at the NPDES permitted final effluent discharge below all treatment processes.
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 THP3B. Additionally, DWQ Form AT-3 (original) is to be sent to the
following address:
Attention: Environmental Sciences Branch
North Carolina Division of Water Quality
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch
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Permit NCO082376
A.(5.) CHRONIC TOXICITY MONITORING (QUARTERLY) - Continued
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.
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 (AT) 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.) ADDITIONAL STIPULATIONS REGARDING DISCHARGE MONITORING
REPORT (DMR) FORMS
1. The City must submit a DMR form for Outfall 001 and. Outfall 002, whether a discharge
occurs or does not occur. If there is no discharge from Outfall 001 or from Outfall 002
during a month, the monthly report must be submitted with the notation "No Flow".
2. For Outfall 003, the City should state whether a discharge has occurred from the
overflow of the raw water reservoir (this may be submitted as a notation on the DMR or
as an appendix to the DMR).
A.(7.) ADDITIONAL STIPULATIONS REGARDING DISCHARGE TIMING
In order to minimize effects of future nutrient discharges on algal blooms, The City shall make
all reasonable efforts so that any future discharges occur during the months of December,
January, February, or March. If Public Water Supply requires discharge any other time of the
year, the facility must comply with the requirements of PWS.

DIVISION OF WATER QUALITY
July 16, 2008
To: Coleen H. Sullins, Director
Division of Water Quality
Through: Gil Vinzani, P.E.
Supervisor, Eas NPDES Program ZIAI
Paul is
Sec on C ' f, Surface Water Protection
From: Jim McKay.
Eastern NPD S Program
Subject: City of Raleigh E.M. Johnson WTP
Summary of Comments Received on NPDES Permit Renewal NCO082376
The abovementioned draft permit was sent to public notice on April 11, 2008. During the
notice period comments from four members of the public, and one DWQ staff member
were received, all via email. All requested a public hearing for the permit renewal.
There was a four -page email from one individual with many enumerated points and
issues; two others forwarded that same email with a note that they also share her
concerns. The concerns include stream bank erosion, how TMDLs are developed and
applied, how limits are developed and implemented, toxicity of manganese, and the use
of Whole Effluent Toxicity testing. The other commentor was concerned about toxicity
of manganese and wanted the facility to sample for manganese in the discharge, in -
stream, in ground water and areas in the vicinity.
Some background on the WTP outfalls:
There are three outfalls associated with this permit. The City currently recycles 100% of
the wastewater back to the raw water reservoirs, with no discharge. The amount of water
recycled is about 5% of the water treated for drinking water. When the City began
recycling WTP wastewater in 2005, Public Water Supply (PWS) rules required that
recycling be stopped for two weeks each quarter in order to flush out parasites, such as
cryptosporidium and giardia from the reservoirs and treatment plant. Ultraviolet (UV)
light treatment was added to disinfect the recycle water in order to control these parasites.
As drought conditions developed and worsened, the requirement to discharge was
reduced to two weeks per year, then eventually dropped altogether. If drinking water
quality declines, the City may again be required to discharge from Outfall 002.
Outfall 001— Potential discharge from overflow from the east raw water reservoir and
possible discharge of treated water/wastewater (located across Falls of the Neuse Road
from the water treatment plant). Discharge is to an unnamed tributary of the Neuse
River, classified as WS-IV-NSW. There has been no discharge from Outfall 001 for
the past two permit cycles (10 years).
Outfall 002 — Discharge of wastewater associated with the treatment of water for drinking
purposes (main wastewater discharge), and leakage from the plant clearwells.

NCco'"2376
DIVISION OF WATER QUALITY
July 16, 2008
To: Coleen H. Sullins, Director
Division of Water Quality
Through: Gil Vinzani, P.E.
Supervisor, Easlam NPDES Program A "%/
Paul is
Sec on C ' f, Surface Water Protection
From: Jim McKay A, /.,\ < /<„�
Eastern NPDES Program (/
'1('o
j v6s S
o� ,
"'t5;'oe2
C6�
Subject: City of Raleigh E.M. Johnson WTP
Summary of Comments Received on NPDES Permit Renewal NCO082376
The abovementioned draft permit was sent to public notice on April 11, 2008. During the
notice period comments from four members of the public, and one DWQ staff member
were received, all via email. All requested a public hearing for the permit renewal.
There was a four -page email from one individual with many enumerated points and
issues; two others forwarded that same email with a note that they also share her
concerns. The concerns include stream bank erosion, how TMDLs are developed and
applied, how limits are developed and implemented, toxicity of manganese, and the use
of Whole Effluent Toxicity testing. The other commentor was concerned about toxicity
of manganese and wanted the facility to sample for manganese in the discharge, in -
stream, in ground water and areas in the vicinity.
Some background on the WTP outfalls:
There are three outfalls associated with this permit. The City currently recycles 100% of
the wastewater back to the raw water reservoirs, with no discharge. The amount of water
recycled is about 5% of the water treated for drinking water. When the City began
recycling WTP wastewater in 2005, Public Water Supply (PWS) rules required that
recycling be stopped for two weeks each quarter in order to flush out parasites, such as
cryptosporidium and giardia from the reservoirs and treatment plant. Ultraviolet (UV)
light treatment was added to disinfect the recycle water in order to control these parasites.
As drought conditions developed and worsened, the requirement to discharge was
reduced to two weeks per year, then eventually dropped altogether. If drinking water
quality declines, the City may again be required to discharge from Outfall 002.
Outfall 001 — Potential discharge from overflow from the east raw water reservoir and
possible discharge of treated water/wastewater (located across Falls of the Neuse Road
from the water treatment plant). Discharge is to an unnamed tributary of the Neuse
River, classified as WS-IV-NSW. There has been no discharge from Outfall 001 for
the past two permit cycles (10 years).
Outfall 002 — Discharge of wastewater associated with the treatment of water for drinking
purposes (main wastewater discharge), and leakage from the plant clearwells.
Z�

Discharge is to an UT to Honeycutt Creek — arm of Falls Lake, classified as WS-IV-
NSW. There has been no discharge from Outfall 002 since August 2006.
Outfall 003 — Discharge of stormwater and overflow from the west raw water reservoir
from the culvert directly upstream of Outfall 002. Discharge is to an UT to Honeycutt
Creek — arm of Falls Lake, classified as WS-IV-NSW. There has been no discharge
from Outfall. 003 since January 2007 except for stormwater, which is regulated by
Stormwater Discharge Permit NCS000245.
Dis6ussion of specific comments:
Item 1. in Mrs. Grolitzer's email concerns erosion and sedimentation in the creek that the
WTP discharge occurs in. The Biological Assessment Unit did Benthic surveys of the
area in August, 2005 and again in January, 2006. In both reports, sedimentation and
erosion were noted, but only upstream of the discharge, not downstream. The report
speculated that this was caused by homeowners removal or alteration of the riparian
vegetation, allowing runoff problems. Judy Garret of the RRO is not aware of any
erosion problems downstream of the discharge point. The second issue in this item
concerns discharge flow. We did not put flow limits on conventional WTP discharges
in the past. Our new Permitting Strategy does require flow limits, which were set at the
facility's design flowrate of 8.8 mgd. Mrs. Grolitzer thought that this was a 100%
increase based on past discharge rates, but nothing has changed, the discharge should
be the same as before. The third issue in this item concerns removal of turbidity
monitoring upstream and downstream of the discharge. Instream turbidity monitoring
was removed from the permit based on DMR data review. A review of instream
turbidity from 2005 through the end of discharge in August 2006 shows low turbidity
upstream and downstream of the discharge point. Upstream turbidity ranged from a
minimum of 0.48 NTU to a maximum of 8.79 NTU. Downstream turbidity ranged
from a minimum of 0.96 NTU to a maximum of 7.07 NTU. On 50% of the data set, the
downstream turbidity was lower than upstream turbidity.
Item 2 requests nutrient limits be implemented in advance of the TMDL and Rulemaking
process. We cannot arbitrarily impose limits in this case. We need the TMDL and
associated rules in order to allocate nutrients to point source permittees.
Item 3 requests a reopener clause be inserted in the permit for when the TMDL is
completed. This is not necessary as it is already covered by permit standard
conditions..
Item 4 discusses manganese limits and requests daily monitoring instead of weekly.
Weekly monitoring is consistent with the WTP Permitting Strategy. The City is doing
more frequent manganese sampling to identify the sources of manganese, and may
reroute some streams to the POTW.
Item 5 requests a permit limit for iron. Iron is an action level parameter, and as long as
the facility passes any future WET tests, no iron limit is required.
Item 6 requests monitoring for calcium thiosulfate, used for dechlorination. WET testing
provides protection against toxicity from this or other materials.

Item 7 discusses polymers used as sludge conditioners and requests extensive testing to
determine how each component of the polymer and dispersant distribute throughout the
process. She cites a consultant's report as requesting such analysis. In the report the
consultant recommended adding an additional polymer to the treatment process. He
suggested toxicity testing if this was done. The City has not accepted the
recommendation to add additional polymer. We think that WET testing will monitor
for any possible toxicity and that this extensive study is not required
Item 8 requests limits for all metals being monitored. We impose limits based on
Reasonable Potential Analysis, not just because the Red Book lists a water quality
standard If data show that a parameter has Reasonable Potential to exceed a water
quality standard, then a limit is imposed. If not, no limit.
Item 9 requests seasonal benthic surveys in the discharge creek. We believe this is
unnecessary.
Item 10 concerns HPC (Heterotrophic Plate Count — an estimate of bacteria count) and
turbidity. It refers to a consultant's report that recommends when sedementation basins
are being cleaned that the water be directed to another part of the process and not
discharged before further treatment. The City is considering adding these changes in a
planned capital upgrade to utility facilities in fiscal year 2012 - 2013. The consultant's
report finds that turbidity of the recycle stream has little, if any, effect on finished
treated water quality. Regarding the concern over bacterial contamination, at the
request of DEHIPWS, we are adding monitoring for fecal coliform on a weekly basis.
Item 11 concerns trihalomethanes and haloacetic acid — byproducts of disinfection with
chlorine. The consultant's report notes that data is available for finished water, but not
for the recycle stream. He recommends gathering data during July and August. The City
supports this recommendation, and will incorporate the recommendation into a future
study.
Item 12 concerns a non-existant plant expansion due to the fact that the draft permit has a
flow limit of 8.8 mgd (the design capacity of the WTP waste water treatment system) as
opposed to the recent discharge of less than 4 mgd. There is no increase in discharge
planned at this time.
In addition, comments received from Associate Professor John Bang, M.D., Ph.D. of NC
Central University raises three issues, all related to manganese.
Issue 1 requests reinstatement of chronic WET testing. It was never discontinued.
Issue 2 requests daily monitoring of manganese when discharging instead of recycle.
The draft permit requires weekly monitoring. This is consistent with our Permitting
Strategy. The City has been conducting more frequent sampling in order to better
understand the manganese in the system.

Issue 3 requests monitoring manganese levels in the discharged water, instream in the
creek, ground water, and areas in the vicinity of the discharge to help protect public
health and understand the impacts of discharge on the physical environment as well as
human health. The Division does not consider manganese in water to be a toxicity
issue. Our current standard of 200 ug/L in WS waters is an aesthetic standard, based
on concern that too much manganese can stain laundry. EPA has a nonenforceable
secondary standard of SO ug/L manganese in drinking water based on concern that too
much manganese can make drinking water smell and taste bad, and cause staining.
We see no reason to require such extensive monitoring for manganese.
NPDES staff does not recommend that the Division grant a public hearing. This is a
permit renewal with only minor changes from past NPDES permits. The comments
received reflect misunderstandings regarding how permits are developed and
implemented, and concerns over toxicity of manganese, which staff does not agree with.

RE: EE&T. Recommendations
Subject: RE: EE&T Recommendations
From: "Waldroup, Kenneth" <[e-mail]>
Date: Tue, 8 Jul 2008 17:07:34 -0400
To: "Garland, John" <[e-mail]>, "Berndt, Robert A."
<[e-mail]>, "James Mckay" <[e-mail]>, "Crisp, Dale"
<[e-mail]>
CC: "Bishop, Mark M." <[e-mail]>, "Hopkins, Cory"
<[e-mail]>, "Jones, Russell E." <[e-mail]>, "Wang,
Michael" <[e-mail]>, "Hamilton, Bryan" <[e-mail]>,
"Best, Ken" <[e-mail]>
July 8th, 2008
Mr. Jim Mckay
Eastern NPDES Program
NC DENR DWQ
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Subject: City of Raleigh Draft NPDES Permit for E.M. Johnson Water Treatment Plant, Permit #
NC0082376.
Dear Mr. McKay,
In response to your inquires of 6-18-08 please accept the following information for your consideration.
As you have noted, our consultants at EE&T have made several recommendations as part of their
assessments of the recycle system and residuals treatment system at the E.M. Johnson Water Treatment
Plant. Below is a copy of the issues raised in the reports, the recommendation from EE&T and our
subsequent response to the recommendation.
Recommendations of the Recycle System Assessment
1. Issue: When the main WTP sedimentation basins are cleaned out (such as in Dec. 2006 through
Feb. 2007), the wash water is currently routed to the SFBW clarifiers. This arrangement results in
substantial fluctuations of recycle water turbidity levels during the times of basin cleanout, and levels
that are often higher than the raw lake water turbidity. There would be much less impact from this
wash water if it was instead directed to the splitter box leading into the three thickeners. That way
the wash water would be treated with polymer and clarification prior to that supernatant entering the
SFBW clarifiers.
Recommendation: Install appropriate piping and valves to route the wash water from the five main
WTP sedimentation basins to the splitter box entering the thickeners, and discontinue the current
practice of routing that wash water directly to the SFBW clarifiers. Draining of the clear water in the
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RE: EE&T Recommendations
basins should still be directed to the SFBW settling basins, and the wash water used for cleaning out the
solids could be directed to the thickeners. Currently finished water is used to wash the main WTP
sedimentation basins, and WTP staff are concerned that the relatively high alkalinity in the finished
water would affect the settling in the thickeners if it was directed to them. Accordingly, if the wash
water is directed to the thickeners, the effect of using finished water on thickener settling should be
evaluated, and if there is an adverse impact then settled water should be used for this washing (a means
of storing and pumping the settled water may be necessary). Further analysis of the potential
ramifications of this recommendation should be performed to assess all potential issues.
Response: The City of . Raleigh Public Utilities Department (CORPUD) has developed a long term
Capital Improvement Plan (CIP) for all utility infrastructure, including the E.M. Johnson water
treatment plant. As part of this plan, the recycle/residuals treatment system will be modified and
expanded. Funds for this work are programmed into the CIP in fiscal year 2012 2013 to design
residuals treatment system improvements. This recommendation will be evaluated as part of that
design project and the recommendation has the support of treatment facility staff as an important
minimum design criteria for the modification.
2. Issue: An improved mass balance analysis would be useful to better understand the fate of
manganese in the WTP. Also, manganese levels in the SFBW settling basin supernatant (recycle
water) were historically as high during periods when permanganate was not used as they were when
it was being applied, and it would be good to determine the source of that manganese: Until piping
improvements were made in May 2007, some of the underdrain water from the filter cake drying
beds (which is high in manganese) was inadvertently pumped to the SFBW settling basins.
Permanganate has been used continuously since that time, so it is as yet unknown if the piping
improvements will help reduce recycle water manganese levels.
Recommendation: Measure the manganese concentration of the thickener overflow and the SFBW
(during both periods of permanganate use and non-use), and perform a mass balance analysis. Also,
when permanganate use is next discontinued, increase the frequency of analysis of manganese in the
SFBW supernatant to daily to better assess any improvement in manganese levels (currently weekly
analyses are performed).
Response: Treatment facility staff support this recommendation and are planning to implement this
suggestion now. Data collection has been ongoing during the past year of permanganate use. The
data collection will continue through ozone operation, which is scheduled to begin in July, 2008. Use
of ozone is expected to reduce the manganese concentrations in the SFBW effluent. As we identify the
high manganese waste streams we are trying to collect and direct the flows to the sewer system. We
are also planning to investigate alternative treatment methods to reduce the manganese
concentrations.
3. Issue: No TTHM or HAA5 data are available for the recycle water; only finished water TTHM and
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RE: EE&T Recommendations
HAA5 data are available. The highest DBP results of the year were obtained during the warmest
month (83.4 ?g/L for TTHM and 66.7 ?g/L for HAA5 on August 7, 2006), about half way through a
two -week period of no recycle. Since these numbers are at least approaching the future LRAA MCL,
it would be good to determine if recycle is contributing to the levels. Recycle can add to both the
instantaneous DBP levels by recycling preformed DBPs and add to the formation potential by adding
precursors.
Recommendation: Obtain TTHM and HAA5 data for the recycle stream during the warmest months
(July and August, when DBP levels are expected to be highest) at the same time as the monthly DBP
sampling of the finished water. Analyze for both instantaneous DBPs and SDS levels by adding
additional chlorine, buffering the pH to the distribution system level, and holding for an appropriate time
(— 3 days).
Response: Treatment facility staff support this recommendation and will incorporate the suggestion
in a future study.
4. Issue: The City is currently required by the NCDENR to discharge the SFBW settling basin
supernatant (recycle water) to a nearby unnamed tributary of Honeycutt Creek for one 2-week period
each year. The above analysis showed that this requirement is unnecessary and unduly burdensome.
In fact, many parameters are lower in the recycle than the raw water and thus improve the plant
intake levels. The requirement puts a physical and water quality load on the receiving stream
(normally dry except for storm events) with no recognizable benefit to the WTP, and can lead to
unnecessary objections from local residents who are not familiar with the specific quality of the
discharged water nor the reasons for its discharge.
Recommendation: The City should negotiate with the State to rescind the requirement for occasional
discharge of SFBW settling basin supernatant to the nearby creek. The NPDES permit that allows that
discharge should be maintained, however, in the event of some unforeseen circumstance where
operational conditions mandate a release of SFBW settling basin supernatant to the creek.
Response: The City of Raleigh Public Utilities Department will discuss this issue with DEH this year.
This is a complicated issue given the conflicting nature of DEH and DWQ requirements for both the
NPDES parameters and DEH's requirement to "break the cycle" of recycling. It is important to point
out that we believe that we are currently breaking the cycle by sending belt filter press filtrate water to
the sewer. This water contains the greatest amount of iron, manganese, and organics. This is a daily
discharge to the sewer system that we believe fully implement the intent of DEH's policy.
5. Issue: The City has resisted using a polymer in the SFBW settling basins to improve coagulation
and clarification because of toxicity concerns from the polymer for occasions when the supernatant is
discharged to the nearby creek, as required for one 2-week period per year by the NCDENR. The
City previously determined in 2005 that the polymer used for the splitter (entering the three
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RE: EE&T Reconunendations
thickeners) and the filter presses was likely causing toxicity in the water discharged to the creek.
Subsequent modifications to the residuals system now direct the press filtrate to the sewer, and no
polymer -is recycled from the presses. Any polymer left over in the thickener supernatant passes
along to the SFBW settling basins.
Recommendation: Consider evaluating the use of a polymer to improve clarification in the SFBW
settling basins and the quality of the supernatant water recycled. Polymer addition might be particularly
helpful during the times when wash water from cleaning out the five main WTP sedimentation basins is
directed to the SFBW settling basins (note that Recommendation No. 1 above suggests directing that
wash water to the thickeners). Since the SFBW settling basin supernatant might on occasion need to be
discharged to the nearby creek (e.g., as was done when there was a problem with the pump station at the
UV disinfection facility in July 2007), the issue of potential toxicity of the supernatant water containing
polymer should be reevaluated. This evaluation should also include an assessment of any impacts from
recycling polymer to the raw water reservoirs.
Response: The staff of the E.M. Johnson water treatment are concerned about this recommendation
and do not support the addition any polymer feed at this time. City Of Raleigh Public Utilities
Administrative staff deferred to opinion and experiise of the treatment facility staff in this issue. If
this recommendation is deemed necessary by subsequent studies, the treatment facility staff suggest a
larger pilot study which would evaluate different polymers and their effects. Other methods to
improve clarification, including the use of Lamella separators following the SFBW settling basins,
will also be evaluated during the design of residuals system improvements scheduled for fiscal year
2012-2013.
6. Issue: Recycle water turbidity levels on occasion were measured higher than the raw water
turbidity. However, the recycle flow averages only 5.0 percent of the influent flow (maximum of
10.0 percent), and as such on those occasions contributes a minor increase in turbidity for the
influent water compared to that in the raw water. Overall through the one-year period studied, there
were 337 days when recycle was occurring, and of those 337 days there were 43 occasions (12.5
percent) where the recycle water turbidity level exceeded that measured for the raw water.
Furthermore, of the times when recycle turbidity was greater than for raw water, recycle turbidity
was > 4 NTU on only 13 occasions (3.6 percent of all sample days), and only 23 occasions where
recycle turbidity was > 3 NTU (6.8 percent of all sample days). Raw water turbidity averaged 5.5
NTU during the year. The NCDENR has stipulated a maximum turbidity for the recycle water of 30
NTU (NCDENR 2005).
Recommendation: One goal would be to establish a recycle water turbidity maximum value, such as 4.0
or 5.0 NTU. Alternatively, the maximum could be set at the influent turbidity, but this is a harder
operating goal to monitor and maintain and during times of low influent turbidity could be difficult to
achieve.
4 of 6 8/7/2008 3:50 PM

RE: EE&', Recommendations
Response: Treatment facility staff support the recommendation and are implementing the suggestion
now. Operational goals have been established and are being evaluated for effectiveness. Currently,
staff respond to any condition that is out of the operating norm of the waste facility. The Operations
Supervisor (ORC) responds to determine the cause and take corrective measures. These operational
goals will be documented Improvements to the terminal reservoirs to improve raw water quality will
also be considered based on the recommendations of the plant expansion study. Also see Response to
Item 5 above.
Recommendations of the Residual System Assessment
The recommendations proffered based on this assessment are summarized as follows:
1. Initiate a study to better determine discrepancies between calculated, plant measured, and hauler
reported solids quantities.
Response: This issue will be further evaluated as part of the design of residuals system modification
and expansion planned in fiscal year 2012 2013.
2. Consider installation of a fourth thickener to provide additional capacity, and to enable three
thickeners to be operating while one is being cleaned and/or serviced
Response: The City of Raleigh Public Utilities Department (CORPUD) has developed a long term
Capital Improvement Plan (CIP) for all utility infrastructure, including the E.M. Johnson water
treatment plant. As part of this plan, the recycle/residuals treatment system will be modified and
expanded Funds for this work are programmed into the CIP in fiscal year 2012 2013 to design
residuals treatment system improvements. This recommendation will be evaluated as part of that
design project and the recommendation has the support of treatment facility staff as an important
minimum design criteria for the modification.
3. Consider installation. of a fifth sludge holding tank prior to the filter belt presses to provide
additional capacity, including more storage time if the filter press operation is temporarily
unavailable
Response:. This recommendation will be evaluated as part of the design project described above in
response #2. The recommendation has the support of treatment facility staff as an important
minimum design criteria for the modification.
4. It would be appropriate to install sludge level gauges in each tank, as well as a means to
automatically transmit that data to the dewatering system building to aid in operator evaluation
Response: This recommendation will be evaluated as part of the design project described above in
response #2. The recommendation has the support of treatment facility staff as an important
minimum design criteria for the modification.
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RE: EE&T Recommendations
5. Consider the feasibility of using the existing processes or additional presses to process sludge from
the on -site lagoons as an alternative to hiring a contractor to dredge and dewater the material.
Response: Treatment facility staff support the recommendation and are implementing the suggestion
now via an internal evaluation.
6. The City should consider evaluating different options for keeping the filter press solids covered.
Possibilities include (a) constructing a roof over the current drying bed, and (b) devising a system
where several trailers are kept on site, loaded one at a time directly from the filter press conveyor
belt, and then covered with a tarp until a time when it is convenient for them to be hauled away.
This latter method would require changes to the filter press building structure to accommodate the 20
cubic yard trailers used by the hauler, but would also eliminate the need to handle the cake twice.
Either of these methods (`a' or `b') should save on shipping costs (due to a lower weight of the
solids). The City could also explore the possibility of getting the filter cake classified as "Class A",
and then perhaps the local wastewater plant would be able to take the WTP filter cake and mix it
with theirs.
Response: We are evaluating the use of covered trailers as a method to reduce handling of the
material. Modifications to eliminate the need to handle the filter cake twice were also addressed in the
design study proposed in response #2 above.
7. Consider installation of an on -site truck scale to weigh the amount of cake hauled away
Response: This recommendation will be evaluated as part of the design project described above in
response #2. The recommendation has the support of treatment facility staff as an important
minimum design criteria for the modification.
Jim, please let me know if you need any further information. Thanks!
-Kenny
Kenneth R. Waldroup, PE
Assistant Public Utilities Director
CORPUD
Post Office Box 590
Raleigh, North Carolina 27602
(919).857-4540
"E-mail correspondence to and from this address may be subject to the North Carolina Public Records
Law and may be disclosed to third parties by an authorized City or Law Enforcement official."
6 of 6 8n12008 3:50 PM

FW: EM Johnson WTP NPDES Permit NCO082376
Subject: FW: EM Johnson WTP NPDES Permit NCO082376
From: "Ron Gregory" <ron e o m>
g rY" �' g ryec.rr.co
Date: Mon, 12 May 2008 15:12:04 -0400
To: <j [e-mail]>
CC: <[e-mail]>
Mr McKay,
I am sending you this email as per the request of Upper Neuse Riverkeeper
Dean Naujoks. He is having email problems, but wished you to know that he
and the Neuse River Foundation support the document below prepared by Dr.
Marilyn Grolitzer.
Sincerely,
Dean Naujoks
Upper Neuse Riverkeeper
Neuse River Foundation
(RG)
-----Original Message -----
From: Marilyn Grolitzer [mailto:[e-mail])
Sent: Sunday, May 11, 2008 6:51 PM
To: James McKay
Subject: EM Johnson WTP NPDES Permit NCO082376
Mr. McKay,
These comments are in response to the proposed draft NPDES permit for the
City of Raleigh's E. M. Johnson water treatment plant (WTP) renewal, NPDES
Permit No. NC0082376.
Over the last few years the City of Raleigh has made significant financial
investments in their plant and has worked to lessen their environmental
impact on the surrounding community, the neighboring creek and Falls Lake,
by recapturing large volume losses of highly chlorinated finished water,
leaks from underdrains from presses and raw water reservoirs. In addition,
they are currently recycling process water which was previously discharged
into the creek on a daily basis. We are most hopeful that these practices
will continue.
As the WTP is retaining their NPDES permit, every measure must be taken to
ensure that any discharges conducted do not impact the environment. Falls
Lake is on the 2008 draft 303 (d) list for impairment. In addition, although
the creek is not officially listed due to it's size, it would fall under the
category of impaired due to the loss of aquatic life (DWQ macroinvertebrate
survey/EPT testing) .
Falls Lake and the creek are classified per NC Red Book as WS-IV C waters
and are recreational waters. Children frequently play in the creek behind
their homes just downstream of the discharge points. It is essential that
the state ensure that the recreational value of these waters is preserved as
well as protecting the aquatic life and vegetation.
1. Erosion
Wake County Environmental Services, Soil & Water Division, has conducted
monitoring of water quality, soil, sediment and erosion of the creek both
upstream and downstream of the WTP. It has been shown that there is bank
erosion occurring in the creek. The proposed permit lists a flow limit of
8.8 MGD. Discharge volumes into the creek were previously around 4 MGD. It
should be noted that the release time of this discharge is within a very
short time frame (<lhr). Water depth in this creek has been noted to
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FW: EM Johnson WTP NPDES Permit NCO082376
FN
increase over 18 inches during the release of 4 MG. The impact of an
increase of this discharge to 8.8 MGD would potentially be severe. As
sediment is the number one cause of pollution in our waters in NC, an
increase in discharge volume, would contribute to sediment pollution of
Falls Lake and would lead to a change in the physical characteristics of the
creek.
Upstream and downstream monitoring for turbidity has been removed from this
permit. This seems unqualified especially in light of the significant
increase in allowable discharge volumes.
2. Nutrient Loading
The permit requires monitoring of nutrients yet no limits are set. As
monitoring has been conducted for many years there is sufficient data to set
limits to not allow any increases in nutrient loading until a TMDL is
developed.
3. TMDL
Given that Falls Lake is on the 2008 303 (d) impaired list, this permit
should contain a reopening provision to re-evaluate the discharge limits as
the TMDL for Falls Lake is under development now.
4. Manganese limit and test frequency
The inclusion of a manganese limit into the permit is justified and strongly
supported. At this time, there are numerous studies being conducted at
several research institutions within NC on the effect of manganese levels in
potable water on human health. Research to date has shown manganese to
effect the human nervous system causing degeneration. Until more information
is know about the effect of the various species (covalent states) of
manganese, the Red Book Standard of 200 ug/l (0.2mg/1) should be firmly
adhered to. Data on the discharge over the last few years of discharge have
shown manganese levels to routinely exceed Red Book standards with levels as
high as 4-5 times NC Red Book standard being reported.
The proposed permit sets a monitoring frequency of weekly. This is not
consistent with the data as it will not give a representative sample and be
an indicator of environmental impact. For example, daily data in Sept 2006
of the Treated Waste Effluent Discharge as reported by the WTP to NCDENR, in
the recycle report, showed a range of 0.53-2.33 mg/l. A variation of this
range was not atypical. The most recent recycle data made available to us
for Feb 2008 of Treated Waste Effluent Discharge showed a variation of
0.25-0.48 mg/l. As stated in the permit "all samples collected should be
representative of the discharge". In order to meet this condition, if
discharges are conducted only 1 hour/day, then it should be captured and
reported during that discharge. If changes in discharge volume and timing
are made which result in a more extensive period, then continuous flow
monitoring should be required. Given the demonstrated variability in the
daily process, this testing should be conducted daily during discharge
periods.
5. Iron limit
The Red Book standard for Iron for Class C waters is 1 mg/l yet no limit is
being required on this permit. Actual discharge data from the WTP reported
to NCDENR has shown levels higher than Red Book standard. Recycle data on
material available for discharge (Treated Waste Effluent) reported in Sept
2006 show large daily variability 0.35mg/l to 1.13 mg/l. Ferric Sulfate is
one of the largest volume chemicals used in the WTP process, yet there are
no monitoring requirements for iron or sulfate.
6. Calcium thiosulfate monitoring
Calcium thiosulfate is used to dechlorinate the discharge water. This
chemical was shown to adversely -affect the creek back in January 2006. Judy
Garrett from DWQ formally recommended on Sept 28. 2006 in a letter to Matt
Matthews that the permit be reopened at that time to add both a manganese
limit and also a monitoring requirement for the dechlorination chemical
"since we investigated a growth of sulfur oxidizing bacteria in the stream
in January 2006. It was suggested that the bacteria were possibly growing on
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FW: EM Jphnson WTP NPDES Permit NCO082376
a
the excess dechlorination chemicals". We strongly support her request for
daily monitoring of this chemical during discharges.
7. Thickening polymer dispersion monitoring, toxicity testing
In both of the consultants (EE&T, Inc) reports, contracted by the City of
Raleigh on Assessment of Raleigh's Residual Treatment System, Dec 2007, and
Assessment of Raleigh's Recycle Stream, Oct 2007, it was recommended that
the potential toxicity of the supernatant water containing polymer be
re-evaluated as the "City of Raleigh previously determined in 2005 that the
polymer used in the splitter was causing toxicity in the water discharged to
the creek". Although changes have been implemented to direct press filtrate
to the sewers, "any polymer left over in the thickener supernatant passes
along to the SFBW settling basins", which is the liquid that is either
recycled or discharged to the creek. The polymer used as a flocculant is in
the form of an emulsion of the polymer and water dispersed in a petroleum
distillate. The petroleum distillate accounts 20 to 30% by weight of the
product used. This petroleum distillate has been shown to be toxic to
fathead minnows and bluegills. It is not clear where the petroleum
distillate ends up, since it is lighter than water and has very limited
solubility in water. The polymer itself is toxic to green algae, daphnia
and zebrafish. The product also contains 1 to 3% of a type of surfactant
that has been banned for most applications in the European Union due to
environmental concerns. There are other available versions of the same
flocculant that do not contain petroleum distillates or surfactants,
although they are not as easy to handle.
Under the current permit, Part IV, Section B 2 , it states that under no
circumstances shall the permittee allow introduction in the waste treatment
system; f- petroleum oil.
The WTP should be required to thoroughly investigate where each of the
components of this product is distributed in the process, determine the
concentrations of the various components and conduct extensive toxicity
testing.
It should be noted that this polymer is added into the splitter box for the
3 thickener units and is added once again prior to the presses. As the
system is set up to capture filtrate overflow from the presses and return it
to the thickener units which supply the supernatant into the settling basins
for recycle or discharge, it is important to determine the level of this
material and all the components including the petroleum solvent.
8. Limits on Metals
The Red Book lists limits for various metals, yet the proposed permit does
not set limits for the metals being monitored. At a minimum the limits
should be consistent with those specified for Class C or WS-IV waters.
It was demonstrated by DWQ back in 2002 and again most recently by Wake Soil
& Water, that there is significant deposition of sediment in the creek and
that soil has been contaminated with metals. The 2002 DWQ report states that
"high concentrations of total metals were found in the black precipitate, at
levels when present in a bioavailable form, adequate to potentially cause
ecological effects to freshwater benthic organisms in a sediment exposure
scenario". This finding supports the justification for concern requiring
action limits.
9. Toxicity testing
Given the concerns mentioned above and the repeated results of the benthic
macroinvertebrate surveys which have shown degradation and impairment on
aquatic life, additional biological and chemical monitoring should be
required in association with toxicity monitoring. Benthic macroinvertebrate
surveys should be conducted seasonally.
The water which is released to the creek from the Spent Filter Backwash
Water (SFBW) North & South Basins is the supernatant liquid collected from
three parts of the process; 1. Filter Back wash water 2. supernatant from
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FW: EM Johnson WTP NPDES Permit NCO082376
the 3 thickener units which receive sediment from the sedimentation basins,
3. overflow from the sludge filter presses via the thickener units. The
potential contaminants in this water may include a wide variety of oxidized
organic chemicals and metals, therefore it is important to monitor and
evaluate the effect on aquatic life, in addition to ensuring the safety of
these materials in recreational waters.
10 HPC/turbidity
It was mentioned in the consultants reports referred to above that the
process water currently being recycled, exhibits a lower turbidity level
than raw water around 85% of the time. It was noted that a significant
increase in turbidity occurs when the sedimentation basins are being cleaned
out. It was also noted that HPC is generally higher than the intake raw
water. The recommendation was to not recycle the clean -out water, but to
repipe it to the thickener units. We support this recommendation as to not
increase turbidity in the water being released. If the WTP continues to
treat it's recycle water with W and treats discharge water in a similar
manner, the concern regarding HPC level will be reduced.
It should be noted here, that during the period of time when the plant was
still discharging process water, several neighbors reported that their
children and their friends had become ill after playing in the creek.
11. Trihalomethanes/Haloacetic acids- TTHM/HAA5
As recommended to the City of Raleigh in the two referenced reports, since
no data is available for the recycle or discharge stream, this data should
be generated in the summer months. We support the recommendation made in
this report.
12. Plant expansion
The creek appears to be showing signs of life again now that all discharges,
releases and leaks have been discontinued. The contamination of sediment and
soil will continue to exist in the creek and lake. If any discharges or
releases resume, it is likely that aquatic life will again be negatively
impacted. Also, as there is significant bank erosion, high volume releases
of water may further degrade the creek and push more sediment into the lake.
If the volume of water releases is increased as the proposed permit allows,
it is likely that the contaminated soil and sediment deposits will be
distributed over a wide range of area and also flow into Falls Lake. If the
plant is allowed to increase the volume of discharge, then the creek should
be first dredged to properly capture and contain the contaminated soils,
stabilized and restored.
As stated in the two referenced reports referring to the discharge "it puts
a physical and water quality load on the receiving stream" therefore it is
the best interest of all for the WTP to continue to recycle and reuse it's
process water. Water is a precious resource and the WTP should be supported
in reusing 4-8M GPD of process water, particularly as we will continue to
experience increasing demands for water and increasing occurrences of
drought.
Given the community's concerns regarding this discharge and the demonstrated
detrimental effects of this discharge on benthic macroinvertebrates, the
renewal of this permit should be taken to public hearing.
Marilyn A. Grolitzer, Ph.D.
William A. Dupont, Ph.D.
4 of 4 5/12/2008 3:17 PM

FW: EM Jgbwon WTP NPDES Permit NCO082376
Subject: FW: EM Johnson WTP NPDES Permit NCO082376
From: "Ron Gregory" <[e-mail]>
Date: Mon, 12 May 2008 09:14:03 -0400
To: <j [e-mail]>
CC: "'Marilyn Grolitzer"' <[e-mail]>, <[e-mail]>
Dear Mr. McKay,
I am 100% in support of the opinions expressed by Dr. Grolitzer in the
attached letter below.
Clearly, Red Book limits for various chemicals were established based on
sound scientific understanding and should be respected and enforced by those
responsible for protecting our environment.
Sincerely,
Ron Gregory
9817 Koupela Drive
Raleigh, NC 27614
919-426-4404
Mr. McKay,
These comments are in response to the proposed draft NPDES permit for the
City of Raleigh's E. M. Johnson water treatment plant (WTP) renewal, NPDES
Permit No. NC0082376.
'Over the last few years the City of Raleigh has made significant financial
investments in their plant and has worked to lessen their environmental
impact on the surrounding community, the neighboring creek and Falls Lake,
by recapturing large volume losses of highly chlorinated finished water,
leaks from underdrains from presses and raw water reservoirs. In addition,
they are currently recycling process water which was previously discharged
into the creek on a daily basis. We are most hopeful that these practices
will continue.
As the WTP is retaining their NPDES permit, every measure must be taken to
ensure that any discharges conducted do not impact the environment. Falls
Lake is on the 2008 draft 303 (d) list for impairment. In addition, although
the creek is not officially listed due to it's size, it would fall under the
category of impaired due to the loss of aquatic life (DWQ macroinvertebrate
survey/EPT testing).
Falls Lake and the creek are classified per NC Red Book as WS-IV C waters
and are recreational waters. Children frequently play in the creek behind
their homes just downstream of the discharge points. It is essential that
the state ensure that the recreational value of these waters is preserved as
well as protecting the aquatic life and vegetation.
1. Erosion
Wake County Environmental Services, Soil & Water Division, has conducted
monitoring of water quality, soil, sediment and erosion of the creek both
upstream and downstream of the WTP. It has been shown that there is bank
erosion occurring in the creek. The proposed permit lists a flow limit of
8.8 MGD. Discharge volumes into the creek -were previously around 4 MGD. It
should be noted that the release time of this discharge is within a very
short time frame klhr). Water depth in this creek has been noted to
increase over 18 inches during the release of 4 MG. The impact of an
increase of this discharge to 8.8 MGD would potentially be severe. As
sediment is the number one cause of pollution in our waters in NC, an
increase in discharge volume, would contribute to sediment pollution of
Falls Lake and would lead to a change in the physical characteristics of the
1 of 4 5/12/2008 10:49 AM

FW: EM Johnson WTP NPDES Permit NCO082376 -
creek.
Upstream and downstream monitoring for turbidity has been removed from this
permit. This seems unqualified especially in light of the significant
increase in allowable discharge volumes.
2. Nutrient Loading
The permit requires monitoring of nutrients yet no limits are set. As
monitoring has been conducted for many years there is sufficient data to set
limits to not allow any increases in nutrient loading until a TMDL is
developed.
3. TMDL
Given that Falls Lake is on the 2008 303 (d) impaired list, this permit
should contain a reopening provision to re-evaluate the discharge limits as
the TMDL for Falls Lake is under development now.
4. Manganese limit and test frequency
The inclusion of a manganese limit into the permit is justified and strongly
supported. At this time, there are numerous studies being conducted at
several research institutions within NC on the effect of manganese levels in
potable water on human health. Research to date has shown manganese to
effect the human nervous system causing degeneration. Until more information
is know about the effect of the various species (covalent states) of
manganese, the Red Book Standard of 200 ug/l (0.2mg/1) should be firmly
adhered to. Data on the discharge over the last few years of discharge have
shown manganese levels to routinely exceed Red Book standards with levels as
high as 4-5 times NC Red Book standard being reported.
The proposed permit sets a monitoring frequency of weekly. This is not
consistent with the data as it will not give a representative sample and be
an indicator of environmental impact. For example, daily data in Sept 2006
of the Treated Waste Effluent Discharge as reported by the WTP to NCDENR, in
the recycle report, showed a range of 0.53-2.33 mg/l. A variation of this
range was not atypical. The most recent recycle data made available to us
for Feb 2008 of Treated Waste Effluent Discharge showed a variation of
0.25-0.48 mg/l. As stated in the permit "all samples collected should be
representative of the discharge". In order to meet this condition, if
discharges are conducted only 1 hour/day, then it should be captured and
reported during that discharge. If changes in discharge volume and timing
are made which result in a more extensive period, then continuous flow
monitoring should be required. Given the demonstrated variability in the
daily process, this testing should be conducted daily during discharge
periods.
S. Iron limit
The Red Book standard for Iron for Class C waters is 1 mg/l yet no limit is
being required on this permit. Actual discharge data from the WTP reported
to NCDENR has shown levels higher than Red Book standard. Recycle data on
material available for discharge (Treated Waste Effluent) reported in Sept
2006 show large daily variability 0.35mg/l to 1.13 mg/l. Ferric Sulfate is
one of the largest volume chemicals used in the WTP process, yet there are
no monitoring requirements for iron or sulfate.
6. Calcium thiosulfate monitoring
Calcium thiosulfate is used to dechlorinate the discharge water. This
chemical was shown to adversely affect the creek back in January 2006. Judy
Garrett from DWQ formally recommended on Sept 28. 2006 in a letter to Matt
Matthews that the permit be reopened at that time to add both a manganese
limit and also a monitoring requirement for the dechlorination chemical
"since we investigated a growth of sulfur oxidizing bacteria in the stream
in January 2006. It was suggested that the bacteria were possibly growing on
the excess dechlorination chemicals". We strongly support her request for
daily monitoring of this chemical during discharges.
7. Thickening polymer dispersion monitoring, toxicity testing
In both of the consultants (EE&T, Inc) reports, contracted by the City of
2 of 4 5/12/2008 10:49 AM

FW,: EM-Jghnson WTP NPDES Permit NC0082376
s
Raleigh on Assessment of Raleigh's Residual Treatment System, Dec 2007, and
Assessment of Raleigh's Recycle Stream, Oct 2007, it was recommended that
the potential toxicity of the supernatant water containing polymer be
re-evaluated as the "City of Raleigh previously determined in 2005 that the
polymer used in the splitter was causing toxicity in the water discharged to
the creek". Although changes have been implemented to direct press filtrate
to the sewers, "any polymer left over in the thickener supernatant passes
along to the SFBW settling basins", which is the liquid that is either
recycled or discharged to the creek. The polymer used as a flocculant is_in
the form of an emulsion of the polymer and water dispersed in a petroleum
distillate. The petroleum distillate accounts 20 to 30% by weight of the
product used. This petroleum distillate has been shown to be toxic to
fathead minnows and bluegills. It is not clear where the petroleum
distillate ends up, since it is lighter than water and has very limited
solubility in water. The polymer itself is toxic to green algae, daphnia
and zebrafish. The product also contains 1 to 3% of a type of surfactant
that has been banned for most applications in the European Union due to
environmental concerns. There are other available versions of the same
flocculant that do not contain petroleum distillates or surfactants,
although they are not as easy to handle.
Under the current permit, Part IV, Section B 2 , it states that under no
circumstances shall the permittee allow introduction in the waste treatment
system; f- petroleum oil.
The WTP should be required to thoroughly investigate where each of the
components of this product is distributed in the process, determine the
concentrations of the various components and conduct extensive toxicity
testing.
It should be noted that this polymer is added into the splitter box for the
3 thickener units and is added once again prior to the presses. As the
system is set up to capture filtrate overflow from the presses and return it
to the thickener units which supply the supernatant into the settling basins
for recycle or discharge, it is important to determine the level of this
material and all the components including the petroleum solvent.
8. Limits on Metals
The Red Book lists limits for various metals, yet the proposed permit does
not set limits for the metals being monitored. At a minimum the limits
should be consistent with those specified for Class C or WS-IV waters.
It was demonstrated by DWQ back in 2002 and again most recently by Wake Soil
& Water, that there is significant deposition of sediment in the creek and
that soil has been contaminated with metals. The 2002 DWQ report states that
"high concentrations of total metals were found in the black precipitate, at
levels when present in a bioavailable form, adequate to potentially cause
ecological effects to freshwater benthic organisms in a sediment exposure
scenario". This finding supports the justification for concern requiring
action limits.
9. Toxicity testing
Given the concerns mentioned above and the repeated results of the benthic
macroinvertebrate surveys which have shown degradation and impairment on
aquatic life, additional biological and chemical monitoring should be
required in association with toxicity monitoring. Benthic macroinvertebrate
surveys should be conducted seasonally.
The water which is released to the creek from the Spent Filter Backwash
Water (SFBW) North & South Basins is the supernatant liquid collected from
three parts of the process; 1. Filter Back wash water 2. supernatant from
the 3 thickener units which receive sediment from the sedimentation basins,
3. overflow from the sludge filter presses via the thickener units. The
potential contaminants in this water may include a wide variety of oxidized
organic chemicals and metals, therefore it is important -to monitor and
evaluate the effect on aquatic life, in addition to ensuring the safety of
3 of 4 5/12/2008 10:49 AM

FW: EM Johnson WTP NPDES Permit NCO082376
these materials in recreational waters.
10 HPC/turbidity
It was mentioned in the consultants reports referred to above that the
process water currently being recycled, exhibits a lower turbidity level
than raw water around 85% of the time. It was noted that a significant
increase in turbidity occurs when the sedimentation basins are being cleaned
out. It was also noted that HPC is generally higher than the intake raw
water. The recommendation was to not recycle the clean -out water, but to
repipe it to the thickener units. We support this recommendation as to not
increase turbidity in the water being released. If the WTP continues to
treat it's recycle water with UV and treats discharge water in a similar
manner, the concern regarding HPC level will be reduced.
It should be noted here, that during the period of time when the plant was
still discharging process water, several neighbors reported that their
children and their friends had become ill after playing in the creek.
11. Trihalomethanes/Haloacetic acids- TTHM/HAA5
As recommended to the City of Raleigh in the two referenced reports, since
no data is available for the recycle or discharge stream, this data should
be generated in the summer months. We support the recommendation made in
this report.
12. Plant expansion
The creek appears to be showing signs of life again now that all discharges,
releases and leaks have been discontinued. The contamination of sediment and
soil will continue to exist in the creek and lake. If any discharges or
releases resume, it is likely that aquatic life will again be negatively
impacted. Also, as there is significant bank erosion, high volume releases
of water may further degrade the creek and push more sediment into the lake.
If the volume of water releases is increased as the proposed permit allows,
it is likely that the contaminated soil and sediment deposits will be
distributed over a wide range of area and also flow into Falls Lake. If the
plant is allowed to increase the volume of discharge, then the creek should
be first dredged to properly capture and contain the contaminated soils,
stabilized and restored.
As stated in the two referenced reports referring to the discharge "it puts
a physical and water quality load on the receiving stream" therefore it is
the best interest of all for the WTP to continue to recycle and reuse it's
process water. Water is a precious resource and the WTP should be supported
in reusing 4-8M GPD of process water, particularly as we will continue to
experience increasing demands for water and increasing occurrences of
drought.
Given the community's concerns regarding this discharge and the demonstrated
detrimental effects of this discharge on benthic macroinvertebrates, the
renewal of this permit should be taken to public hearing.
Marilyn A. Grolitzer, Ph.D.
William A. Dupont, Ph.D.
4 of 4 5/12/2008 10:49 AM

RE: Comments on NPDES Draft Permit (Permit #: NC0082376)_ Mo...
Subject: RE: Comments on NPDES Draft Permit (Permit #: NC0082376)_ Monitoring Manganese
From: 'Bang, John J" <[e-mail]>
Date: Sun, 11 May 2008 21:34:47 -0400
To: "j [e-mail]" <j [e-mail]>
CC: Marilyn Grolitzer <[e-mail]>, "[e-mail]" <[e-mail]>
Mr. McKay:
After reviewing the NPDES Draft Permit dated back on April 9, 2008 (permit number:
NC0082376) and other copies of some archived data related to manganese (Mn) levels in
the creeks nearby E.M. Johnson WTP and ground water in Raleigh, North Carolina, a few
recommendation has been sought. First of all, monitoring effort on the levelsof Mn
would make more sense when it is done in both environmental and health perspectives.
One challenge we face is that most of the studies conducted at molecular and macro
scale levels are not specific enough to apply their findings to individual cases like
EM Johnson WTP case in terms of setting a threshold monitoring level. This lack of
specificity or uncertainty, however, motivates us be more cautious in selecting
regulatory practice. For this reason, it would be a reasonable step for the WTP to
reinstate toxicity monitoring through chronic WET testing although modification in
the facility in recent years helped pass WET tests (unless it causes atremendous
financial constraint on the plant). Second, timing of the discharged water sampling
for Mn may need to be monitored well enough to reflect the level of Mn present in the
discharged water from the WTP. Considering the range of Mn level fluctuation, daily
monitoring of the Mn level during the time of water discharge seems to be more
logical. Accurate asessment of Mn levels in discharged water, creek, ground water,
and areas in the vicinity will be able to help protect publich health and understand
the real impacts of the current discharging practice observed on physical environment
as well as human health. For any question, please contact me without hesitation.
John Bang, M.D., Ph.D.
Associate Professor
Dept. Environmental, Earth, and Geospatial Sciences
College of Sciences and Technology
North Carolina Central University
1801 Fayetteville St.
#2105 Mary M. Townes Science Building
Durham, NC 27707
phone: [phone]
fax: [phone]
jjbang®nccu.edu
1 of 1 5/ 12/2008 8:03 AM

EM Johnson WTP NPDES Permit NCO082376
Subject: EM Johnson WTP NPDES Permit NCO082376
From: "Marilyn Grolitzer" <[e-mail]>
Date: Sun, 11 May 2008 18:51:17 -0400
To: "James McKay" <[e-mail]>
Mr. McKay,
These comments are in response to the proposed draft NPDES permit for the
City of Raleigh's E. M. Johnson water treatment plant (WTP) renewal, NPDES
Permit No. NC0082376.
Over the last few years the City of Raleigh has made significant financial
investments in their plant and has worked to lessen their environmental
impact on the surrounding community, the neighboring creek and Falls Lake,
by recapturing large volume losses of highly chlorinated finished water,
leaks from underdrains from presses and raw water reservoirs. In addition,
they are currently recycling process water which was previously discharged
into the creek on a daily basis. We are most hopeful that these practices
will continue.
As the WTP is retaining their NPDES permit, every measure must be taken to
ensure that any discharges conducted do not impact the environment. Falls
Lake is on the 2008 draft 303 (d) list for impairment. In addition, although
the creek is not officially listed due to it's size, it would fall under the
category of impaired due to the loss of aquatic life (DWQ macroinvertebrate
survey/EPT testing).
Falls Lake and the creek are classified per NC Red Book as WS-IV C waters
and are recreational waters. Children frequently play in the creek behind
their homes just downstream of the discharge points. It is essential that
the state ensure that the recreational value of these waters is preserved as
well as protecting the aquatic life and vegetation.
1. Erosion
Wake County Environmental Services, Soil & Water Division, has conducted
monitoring of water quality, soil, sediment and erosion of the creek both
upstream and downstream of the WTP. It has been shown that there is bank
erosion occurring in the creek. The proposed permit lists a flow limit of
8.8 MGD. Discharge volumes into the creek were previously around 4 MGD. It
should be noted that the release time of this discharge is within a very
short time frame (<1hr). Water depth in this creek has been noted to
increase over 18 inches during the release of 4 MG. The impact of an
increase of this discharge to 8.8 MGD would potentially be severe. As
sediment is the number one cause of pollution in our waters in NC, an
increase in discharge volume, would contribute to sediment pollution of
Falls Lake and would lead to a change in the physical characteristics of the
creek.
Upstream and downstream monitoring for turbidity has been removed from this
permit. This seems unqualified especially in light of the significant
increase in allowable discharge volumes.
2. Nutrient Loading
The permit requires monitoring of nutrients yet no limits are set. As
monitoring has been conducted for many years there is sufficient data to set
limits to not allow any increases in nutrient loading until a TMDL is
developed.
3. TMDL
Given that Falls Lake is on the 2008 303 (d) impaired list, this permit
should contain a reopening provision to re-evaluate the discharge limits as
the TMDL for Falls Lake is under development now.
4. Manganese limit and test frequency
1 of 4 5/12/2008 8:04 AM

EM Johnson WTP NPDES Permit NCO082376
The inclusion of a manganese limit into the permit is justified and strongly
supported. At this time, there are numerous studies being conducted at
several research institutions within NC on the effect of manganese levels in
potable water on human health. Research to date has shown manganese to
effect the human nervous system causing degeneration. Until more information
is know about the effect of the various species (covalent states) of
manganese, the Red Book Standard of 200 ug/l (0.2mg/1) should be firmly
adhered to. Data on the discharge over the last few years of discharge have
shown manganese levels to routinely exceed Red Book standards with levels as
high as 4-5 times NC Red Book standard being reported.
The proposed permit sets a monitoring frequency of weekly. This is•not
consistent with the data as it will not give a representative sample and be
an indicator of environmental impact. For example, daily data in Sept 2006
of the Treated Waste Effluent Discharge as reported by the WTP to NCDENR, in
the recycle report, showed a range of 0.53-2.33 mg/l. A variation of this
range was not atypical. The most recent recycle data made available to us
for Feb 2008 of Treated Waste Effluent Discharge showed a variation of
0.25-0.48 mg/l. As stated in the permit "all samples collected should be
representative of the discharge". In order to meet this condition, if
discharges are conducted only 1 hour/day, then it should be captured and
reported during that discharge. If changes in discharge volume and timing
are made which result in a more extensive period, then continuous flow
monitoring should be required. Given the demonstrated variability in the
daily process, this testing should be conducted daily during discharge
periods.
5. Iron limit
The Red Book standard for Iron for Class C waters is 1 mg/l yet no limit is
being required on this permit. Actual discharge data from the WTP reported
to NCDENR has shown levels higher than Red Book standard. Recycle data on
material available for discharge (Treated Waste Effluent) reported in Sept
2006 show large daily variability 0.35mg/l to 1.13 mg/l. Ferric Sulfate is
one of the largest volume chemicals used in the WTP process, yet there are
no monitoring requirements for iron or sulfate.
6. Calcium thiosulfate monitoring
Calcium thiosulfate is used to dechlorinate the discharge water. This
chemical was shown to adversely affect the creek back in January 2006. Judy
Garrett from DWQ formally recommended on Sept 28. 2006 in a letter to Matt
Matthews that the permit be reopened at that time to add both a manganese
limit and also a monitoring requirement for the dechlorination chemical
"since we investigated a growth of sulfur oxidizing bacteria in the stream
in January 2006. It was suggested that the bacteria were possibly growing on
the excess dechlorination chemicals". We strongly support her request for
daily monitoring of this chemical during discharges.
7. Thickening polymer dispersion monitoring, toxicity testing
In both of the consultants (EE&T, Inc) reports, contracted by the City of
Raleigh on Assessment of Raleigh's Residual Treatment System, Dec 2007, and
Assessment of Raleigh's Recycle Stream, Oct 2007, it was recommended that
the potential toxicity of the supernatant water containing polymer be
re-evaluated as the "City of Raleigh previously determined in 2005 that the
polymer used in the splitter was causing toxicity in the water discharged to
the creek". Although changes have been implemented to direct press filtrate
to the sewers, "any polymer left over in the thickener supernatant passes
along to the SFBW settling basins", which is the liquid that is either
recycled or discharged to the creek. The polymer used as a flocculant is in
the form of an emulsion of the polymer and water dispersed in a petroleum
distillate. The petroleum distillate accounts 20 to 30% by weight of the
product used. This petroleum distillate has been shown to be toxic to
fathead minnows and bluegills. It is not clear where the petroleum
distillate ends up, since it is lighter than water and has very limited
solubility in water. •The polymer itself is toxic to green algae, daphnia
and zebrafish. The product also contains 1 to 3% of a type of surfactant
that has been banned for most applications in the European Union due to
environmental concerns. There are other available versions of the same
2 of 4 5/12/2008 8:04 AM

EM Johnsgn WTP NPDES Permit NCO082376
flocculant that do not contain petroleum distillates or surfactants,
although they are not as easy to handle.
Under the current permit, Part IV, Section B 2 , it states that under no
circumstances shall the permittee allow introduction in the waste treatment
system; f- petroleum oil.
The WTP should be required to thoroughly investigate where each of the
components of this product is distributed in the process, determine the
concentrations of the various components and conduct extensive toxicity
testing.
It should be noted that this polymer is added into the splitter box for the
3 thickener units and is added once again prior to the presses. As the
system is set up to capture filtrate overflow from the presses and return it
to the thickener units which supply the supernatant into the settling basins
for recycle or discharge, it is important to determine the level of this
material and all the components including the petroleum solvent.
8. Limits on Metals
The Red Book lists limits for various metals, yet the proposed permit does
not set limits for the metals being monitored. At a minimum the limits
should be consistent with those specified for Class C or WS-IV waters.
It was demonstrated by DWQ back in 2002 and again most recently by Wake Soil
& Water, that there is significant deposition of sediment in the creek and
that soil has been contaminated with metals. The 2002 DWQ report states that
"high concentrations of total metals were found in the black precipitate, at
levels when present in a bioavailable form, adequate to potentially cause
ecological effects to freshwater benthic organisms in a sediment exposure
scenario". This finding supports the justification for concern requiring
action limits.
9. Toxicity testing
Given the concerns mentioned above and the repeated results of the benthic
macroinvertebrate surveys which have shown degradation and impairment on
aquatic life, additional biological and chemical monitoring should be
required in association with toxicity monitoring. Benthic macroinvertebrate
surveys should be conducted seasonally.
The water which is released to the creek from the Spent Filter Backwash
Water (SFBW) North & South Basins is the supernatant liquid collected from
three parts of the process; 1. Filter Back wash water 2. supernatant from
the 3 thickener units which receive sediment from the sedimentation basins,
3. overflow from the sludge filter presses via the thickener units. The
potential contaminants in this water may include a wide variety of oxidized
organic chemicals and metals, therefore it is important to monitor and
evaluate the effect on aquatic life, in addition to ensuring the safety of
these materials in recreational waters.
10 HPC/turbidity
It was mentioned in the consultants reports referred to above that the
process water currently being recycled, exhibits a lower turbidity level
than raw water around 85% of the time. It was noted that a significant
increase in turbidity occurs when the sedimentation basins are being cleaned
out. It was also noted that HPC is generally higher than the intake raw
water. The recommendation was to not recycle the clean -out water, but to
repipe it to the thickener units. We support this recommendation as to not
increase turbidity in the water being released. If the WTP continues to
treat it's recycle water with UV and treats discharge water in a similar
manner, the concern regarding HPC level will be reduced.
It should be noted here, that during the period of time when the plant was
still discharging process water, several neighbors reported that their
children and their friends had become ill after playing in the creek.
3 of 4 5/12/2008 8:04 AM

EM Johnson WTP NPDES Permit NCO082376
11. Trihalomethanes/Haloacetic acids- TTHM/HAA5
As recommended to the City of Raleigh in the two referenced reports, since
no data is available for the recycle or discharge stream, this data should
be generated in the summer months. We suppoYt the recommendation made in
this report.
12. Plant expansion
The creek appears to be showing signs of life again now that all discharges,
releases and leaks have been discontinued. The contamination of sediment and
soil will continue to exist in the creek and lake. If any discharges or
releases resume, it is likely that aquatic life will again be negatively
impacted. Also, as there is significant bank erosion, high volume releases
of water may further degrade the creek and push more sediment into the lake.
If the volume of water releases is increased as the proposed permit allows,
it is likely that the contaminated soil and sediment deposits will be
distributed over a wide range of area and also flow into Falls Lake. If the
plant is allowed to increase the volume of discharge, then the creek should
be first dredged to properly capture and contain the contaminated soils,
stabilized and restored.
As stated in the two referenced reports referring to the discharge "it puts
a physical and water quality load on the receiving stream" therefore it is
the best interest of all for the WTP to continue to recycle and reuse it's
process water. Water is a precious resource and the WTP should be supported
in reusing 4-8M GPD of process water, particularly as we will continue to
experience increasing demands for water and increasing occurrences of
drought.
Given the community's concerns regarding this discharge and the demonstrated
detrimental effects of this discharge on benthic macroinvertebrates, the
renewal of this permit should be taken to public hearing.
Marilyn A. Grolitzer, Ph.D.
William A. Dupont, Ph.D.
4 of 4 5/12/2008 8:04 AM

RE: Comments on NPDES Draft Permit (Permit #: NC0082376)_ Mo...
Subject: RE: Comments on NPDES Draft Permit (Permit #: NC0082376)_ Monitoring Manganese
From: "Bang, John J" <[e-mail]>
Date: Sun, 11 May 2008 21:34:47 -0400
To: "[e-mail]" <[e-mail]>
CC: Marilyn Grolitzer <[e-mail]>, "[e-mail]" <[e-mail]>
Mr. McKay:
After reviewing the NPDES Draft Permit dated back on April 9, 2008 (permit number:
NC0082376) and other copies of some archived data related to manganese (Mn) levels in
the creeks nearby E.M. Johnson WTP and ground water in Raleigh, North Carolina, a few
recommendation has been sought. First of all, monitoring effort on the levelsof Mn
would make more sense when it is done in both environmental and health perspectives.
One challenge we face is that most of the studies conducted at molecular and macro
scale levels are not specific enough to apply their findings to individual cases like
EM Johnson WTP case in terms of setting a threshold monitoring level. This lack of
specificity or uncertainty, however, motivates us be more cautious in selecting
regulatory practice. For this reason, it would be a reasonable step for the WTP to
reinstate toxicity monitoring through chronic WET testing although modification in
the facility in recent years helped pass WET tests (unless it causes a tremendous
financial constraint on the plant). Second, timing of the discharged water sampling
for Mn may need to be monitored well enough to reflect the level of Mn present in the
discharged water from the WTP. Considering the range of Mn level fluctuation, daily
monitoring of the Mn level during the time of water discharge seems to be more
logical. Accurate asessment of Mn levels in discharged water, creek, ground water,
and areas in the vicinity will be able to help protect publich health and understand
the real impacts of the current discharging practice observed on physical environment
as well as human health. For any question, please contact me without hesitation.
John Bang, M.D., Ph.D.
Associate Professor
Dept. Environmental, Earth, and Geospatial Sciences
College of Sciences and Technology
North Carolina Central University
1801 Fayetteville St.
#2105 Mary M. Townes Science Building
Durham, NC 27707
phone: [phone]
fax: [phone]
[e-mail]
1 of 1 7/10/2008 9:17 AM

EM Johnson WTP permit renewal
Subject: EM Johnson WTP permit renewal
From: Nora Deamer <[e-mail]>
Date: Fri, 09 May 2008 14:47:45 -0400
To: James McKay <[e-mail]>
CC: Dianne Reid <[e-mail]>
Hi Jim,
I'm the Neuse River Basin planner and I stopped up to talk with you about this permit
but you were not at your desk. I have spoken with several people that are highly
concerned about the renewal of this permit. Since I have not been involved in many
of these I really couldn't answer many of their questions. I think that it would be
beneficial to have a public hearing on this permit. I'm not sure how one goes about
making this request but I think the public would benefit from this process.
This plant is looking to double the discharge into a very small tributary to Falls
Lake. It appears that there is very little monitoring requirements and few limits
put on the discharge water. This has many people concerned. It is my understanding
that when they do discharge water it is at a very high rate and concentration over a
relatively short duration of time. This velocity of water discharged is causing
major habitat degradation in this unnamed tributary. It is my understanding that
they are actually discharging very little at this time. Why do they need to double
the potential discharge rate if this is not needed. Are they preparing for a plant
expansion? Why do they not have toxicity limits and Turbidity monitoring
requirements? These are just some of the questions I could not answer. Can you let
me know if you intend to take this out for a public hearing. I would be interested
in attending. I also think it would be helpful for the community.
Thanks
Nora
Nora Deamer
DENR-DWQ
Planning Section
Basinwide Planning Section.
1 of 1 5/9/2008 4:09 PM

about:blank
Thank you for your help Kathy. I think the City should be able to live with these restrictions. I do not
know now if the PWS folks will make the City resume two weeks a year discharge or not, now that the
drought has eased. For now they are on 100% recycle, pumping treated filter backwash back to the raw
water reservoirs.
Re. item 3, the City is working on plans to increase the capacity of the WTP, but traditionally we
(NPDES) do not consider water treatment plants as nutrient dischargers in the same league as
wastewater treatment plants.
Kathy Stecker wrote:
Jim,
Here are our recommendations for the permit we discussed today:
1. Nutrient concentrations and flow are relatively low. If for any reason TN or TP concentrations
increase, or are expected to increase, please advise so we can re-evaluate.
2. Discharges are infrequent and of short duration. The lake is most sensitive to nutrient inputs
during the warmer months; therefore, the City should be required to discharge only during
December, January, or March. If this is not possible, please advise.
3. Falls Lake is on the 303(d) list for chlorophyll a impairment. I understand it is DWQ's policy not
to allow any increases in nutrient loading until a TMDL is developed.
4. A TMDL for Falls Lake is under development now. When it is completed, this discharge may
have to be re-evaluated.
Please let us know if you need anything else.
-Kathy
1 of 1 5/9/2008 10:37 AM

`lY (9f Male v�
NORTH CAROLINA
Mr. Jim Mckay
Eastern NPDES Program
NC DENR—DWQ
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
May 8111 2008
RECEIVED
WAY - 8 M
Subject: City of Raleigh Draft NPDES Permit for E.M. Johnson OffiRmatVMUtL QUALITY
Permit #NCo082376. POINT SOURCE BRANCH
Dear Mr. McKay
Thank you for this opportunity to comment on the subject draft permit that DWQ has
prepared in response to the City's request for renewal. As you are aware, this permit is of
crucial interest to the City of Raleigh's water customers as well as necessary for the
protection of water quality within the Neuse River Basin. We believe that the City has an
excellent record of compliance with the current permit and is committed to maintaining
and improving this level of permit compliance performance in the renewed permit.
Our Public Utilities Department staff and our engineering consultants at Hazen & Sawyer
have reviewed the draft permit prepared by DWQ. We have some concerns and
objections to the changes that are being proposed by DWQ and we have summarized our
comments in the enclosed sheet and supporting tables. Once your NPDES permit writing
staff has had sufficient time to review the comments, we would welcome the opportunity
to discuss these concerns in a meeting with your staff.
We look forward to working with DWQ toward the goal of getting this permit finalized
and re -issued to the City. Please contact Mr. Dale Crisp at 857-4540 if you have any
questions or to let us know when we can meet with the DWQ staff.
ONE EXCHANGE PLAZA CITY OF RALEIGH
219 FAYETTEVILLE STREET MALL POST OFFICE BOX 590 • RALEIGH,
RALEIGH, NORTH CAROLINA 27601 NORTH CAROLINA 27602
S'nc ely;
;�.-�
J. Russell Allen
City Manager
MUNICIPAL BUILDING
222 WEST HARGETT STREET
RALEIGH, NORTH CAROLINA 27602
(MAILING ADDRESS)

Draft NPDES Permit for City of Raleigh
E.M. Johnson Water Treatment Plant
City of Raleigh Comments on Draft Permit
1. The City requests the deletion of the proposed manganese limit of 200 ug/L as evaluated
under a weekly average. The raw water source for the water treatment process is Falls Lake
and the receiving waters for the discharge of Outfalls 002 and 003 is Honeycutt Creek,
which is a tributary of Falls Lake. The raw water source contains ambient concentrations of
manganese that exceed the proposed discharge limit [see attached spreadsheet]. As such, it
is unreasonable to expect the manganese content of the wastewater from the water
treatment process that uses the same source to remain below ambient background level of
Falls Lake. Furthermore, the State water quality standard of 200 ug/L for manganese is
found only in the fresh surface water standards for water supply watersheds. This
manganese standard was promulgated at its current level to protect human health through
water consumption, not through consumption of fish tissue. The City of Raleigh is the only
entity allowed to remove water from Falls Lake for water supply. Total manganese is
treated by the City of Raleigh in its water treatment plant consistent with the requirements
of the Division of Environmental Health and so that the drinking water supplied to
customers of the City meets the Maximum Containment Level concentration for total
manganese considered safe for drinking, culinary and food -processing purposes as
specified in the national drinking water regulations and in the North Carolina Rules
Governing Water Supplies at 15A NCAC 18C .1500. The existing background level of
manganese in Falls Lake, from naturally occurring conditions, is higher than the proposed
discharge limit. There is no fish advisory to avoid or limit consumption of fish from Falls
Lake due to manganese contamination. Therefore, total manganese in the discharge from
the E.M. Johnson Water Treatment Plant, as source of potential water pollution for Falls
Lake as a drinking water source or from fish consumption, will not preclude any of the
protected uses for the waters of Falls Lake on either a short-term or a long-term basis. For
that reason, its continued discharge consistent with its past discharge is not a violation of a
water quality standard and the exclusion of the limit from the NPDES permit should
continue as it is consistent with the provisions of 15A NCAC 2B .0216(3).
2. If a manganese limit must be considered, the City requests that DWQ defer such decision
until the next permit renewal cycle because of the ongoing negotiation with DEH-PWSS to
eliminate the need to discharge from Outfall 002 to comply with Public Water Supply
Section's interpretation of 40 CFR 141.76 Filter Backwash Recycling Rule (FBRR) as
adopted by reference in 15A NCAC 18C .2003. The City contends that our current
treatment of the wastewater from the water treatment process, which is one of the most
advanced processes in the State, coupled with our recycle discharge into the terminal (raw
water) reservoirs in lieu of direct recycle to the plant raw water intake more that meets the
standards of the FBRR and the required discontinuation of this process is unnecessary. The
resolution of this issue in the City's favor would allow for discontinuing the use of Outfall
002.
3. If a manganese limit cannot be deferred, the City requests that DWQ base such limit on
the maximum ambient concentration of the source/receiving water within Falls Lake and to

Raw (Lake) Water Mn Results from 2/2006 thru 2/2008
Fei Mn
avg. 009
026
min 002
Jon2000 Mn
avg. 0.04
max 0A9
min. DOI
Om2006 Mn
avg ON
max. 0.33
min 004
Jan.2007 Mn
avg. ON
max 011
min 004
Mar1008 _MO
avg. 0.0!
max- ow
min 001
Jui.2006 _�
avg. 003
an. ON
min. 001
Nov2005 Mn
avg. 0 a6
012
min 003
Fe62002 Mn
avg. DOS
max 007
min 004
MaY2001 Mn
Jun.2007 Mn
J
avg.
0,05
an
ON a
max
0.11
mu
0.09 m
min.
002
min.
0.03 m
Sep! 2007 Mn
Otl 007 Ma
!1
avg.
0.1
avg.
043
max.
0.13
max.
0.39 m
min.
0.01
in.
0.03 m
Ja02008 Mn
FeO200S MO
avg.
007
avg.
007
max.
0.1
m ax.
OA
min.
0.05
Max
0.05
0 11002
avg. max
min.
EM. Avg.r
FEB'OB
0.09
0.26
002 0.26
MAR
ON
026
0,01
APR
0.05
0.08
003
pr.2006 Mn
1g. 005
008
in 003
ug.2005 Mn
g 0,05
a 0.14
in. 0.01
40.2006
Ig. 0.06
in. 03
0.
00
m. 0
ar.2007 Mn
19. ONax, 0.11
m. 0.03
u12M ;W,
9. 007
ax D12
In. ON
W.V i`®
a g. 0.25
111 0.62
In. 01
May.20OS &In
avg. 003
max. ON
min 001
Sapt2006 Mn
avg. Ow
me 0.23
min. 0.01
Apr10OT Ma
evg. 0,05
0.09
min 002
Aug 200T Mn
avgom
max 019
min. 0,02
Dii Mn
avg O ❑
max. 019
mm. 0 08
Raw (Lake) Water Mn 212006 - 212008
MAY
0.03
0.06
001
1.2
---
JUN
0.01
0.09
D.01
0.06
JUL
ow
0.08
0.01
AUG
0.05
0.14
0.01
1.03
SEP
0.00
0.23
0.01
OCT
ON
0,33
ON
0.8
--_ -� - -
NOV
ON
0.12
0.03
DEC
006
0.00
am
JAN'0]
0.08
0.11
0.04
li0.8
FEB
ON
0.07
004
E
MAR
ON
0.11
003
APR
0.05
009
0.02
0.4
--- - -- - ---- --
MAY
0.05
0.11
0.02
JUN
0.04
009
0.03
JUL
0.07
0.12
0A3
0.2 --
AUG
007
0.19
0.02
,�..
SEP
0.1
0.13
001
0 I
OCT
0.12
039
0.03
NOV
0.25
0.62
0.09
1 3 5 7 9 11 13 15 77 19 21 23 25
DEC On
0.12
Dig
D.OB
month
AN 90
0.07
0.1
0.05
FEB
007
0.1
OM
_
avg
0.0688
0.189
0.03
0.45
INo Bmikii, remomAsin2DOOvAbnavaW sain w No Eatalor200Tand2008
M

re NC0082375, Raleigh E. M. Johnson WTP
Subject: re NC0082375, Raleigh E. M. Johnson WTP
From: [e-mail]
Date: Thu, l May 2008 09:09:3-2 -0400
To: [e-mail]
EPA will not be reviewing this permit.
1 of 1 10/31/2008 10:33 AM

EM Johnson Permit issue
Subject: EM Johnson Permit issue
From: "[e-mail]" <[e-mail]>
Date: Fri, 25 Apr 2008 11:23:43 -0400 (EDT)
To: [e-mail]
CC: [e-mail]
Hi Jim,
I took a quick look at the EM Johnson WTP renewal permit language
(Permit # NC0082376). The permit states that the discharge is into
Neuse Subbasin 03-04-02 and that the Neuse River in this subbasin is
not on the 303(d) list. The UT to Honeycutt Creek and the others flow
into Falls Lake and is in Neuse subbasin 03-04-01. Falls Lake is now
on the draft 2008 303(d) list (chlorophyll a standard violations) and
there is a TMDL that is being completed with rule making to follow.
I'm not sure.how this affects the permit. Nutrient reductions from
those discharging to the lake will need to be reduced. I know that
they don't discharge very much any more so I don't know what additional
requirement will be needed. I would talk with Kathy Stecker in the
TMDL unit about this.
I just wanted to give you a heads up. Let me know if you have any
questions.
Have a good weekend.
Nora
1 of 1 4/25/2008 2:34 PM

odd W.,AT�cRpG
i y
Michael F. Easley, Governor
State of North Carolina
William G. Ross, Jr., Secretary
Department of Environment and Natural Resources
pY Coleen H. Sullins, Director
Division of Water Quality
April 9, 2008
MEMORANDUM
To: Michael Douglass
NC DENR / DEH / Regional Engineer
Raleigh Regional Office
From: Jim McKay
Eastern NPDES Program
Subject: Review of proposed NPDES Permit NCO082376
Raleigh's E.M. Johnson Water Treatment Plant Permit
PpR � 0 2006
APR 71 2008
Please indicate below your agency's position or viewpoint on the draft permit and return this form by May 9,
2008. If you have any questions on the draft permit, please contact me at telephone number [phone],
extension 595 or via e-mail at [e-mail].
RESPONSE: (Check one)
❑Concur with the issuance of this permit provided the facility is operated and maintained properly, the stated
effluent limits are met prior to discharge, and the discharge does not contravene the designated water quality
standards.
Concurs with iss ante of the above permit, provided the following con'tins are
� � �Nd r�,, ait P�/L l Q -C�44_J
❑ Opposes the issuance of the above permit, based on reasons stated below, or attached:
1617 MAIL SERVICE CENTER, RALEIGH, NORTH CAROLINA 27699-1617 -TELEPHONE [phone]/FAX-919-733-0719
VISIT US ON THE WEB AT http://h2o.enr.state.nC.U5/NPDES

DENR/DWQ
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES No. NCO082376, E.M. Johnson WTP (Raleigh)
Facility Information
Applicant/Facility Name:
City of Raleigh/ E.M. Johnson WTP
Applicant Address:
P.O. Box 590, Raleigh, NC 27602
Facility Address:
10301 Falls of the Neuse Road
Permitted Flow
8.8 MGD
Type of Waste:
100% Non -domestic from drinking water treatment plant
Facility/ Permit Status:
Renewal
Coun :
Wake
Miscellaneous
Receiving Stream: UT Honeycutt Regional Office: RRO
Creek - arm of Falls
Lake (002 & 003)
UT Neuse River
001
Stream Classification: WS-IV-NSW Quad D24NE
(002 & 003) Wake Forest
WS-IV-NSW 001
303(d) Listed?: Yes on 2008 draft, Permit Writer: Jim McKay
Chlorophyll a
Subbasin: 03-04-01 Date: Aril 9, 2008
Drainage Area mil : <0.01
Summer 7Q10 cfs 0
Winter 7Q10 (cfs): 0 AdAW
Avera e Flow cfs : 1.1
IWC %: 100%
Primaxy SIC Code:
SUMMARY
The City of Raleigh submitted a permit renewal application for the E.M. Johnson water
treatment plant (WTP) on August 22, 2007 (the previous permit was issued after adjudication
July 6, 2005 with an expiration date of February 28, 2008). The WTP treats surface water from
Falls Lake for distribution as drinking water to the City of Raleigh and several surrounding
towns. Wastewater from this process is generated from the backwashing of the filters at the
water treatment plant [frequent backwashing is required by the Division of Environmental
Health to ensure drinking water safety]. Residual solids from the water treatment process are
also separated and treated through the wastewater treatment system.
The City of Raleigh treats the backwash water and solids from the water treatment process
through a series of solid/liquid separators [ref. Supplement to Permit Cover Sheet as well as
flow chart with permit application for list of treatment units].
There are three outfalls associated with this permit. The City currently recycles 100% of the
wastewater back to the raw water reservoirs, with no discharge. When the City began
recycling WTP wastewater in 2005, Public Water Supply rules required that recycling be
stopped for two weeks each quarter in order to flush out the reservoirs and treatment plant due
to concerns over buildup of parasites that are not controlled by chlorination. Ultraviolet (UV)
light treatment was added to disinfect the recycle water. As drought conditions developed and
worsened, the requirement to discharge was reduced to two weeks per year, then eventually
dropped altogether. If drinking water quality declines, the City may again be required to
discharge from Outfall 002.
NCO082376
NPDES Renewal
Page I

Outfall 001 - Discharge from overflow from the east raw water reservoir and possible discharge
of treated water/wastewater (located across Falls of the Neuse Road from the water
treatment plant). Discharge is to an unnamed tributary of the Neuse River, classified as WS-
IV-NSW. There has been no discharge from Outfall 001 for the past two permit cycles (10
years) .
Outfall 002 - Discharge of wastewater associated with the treatment of water for drinking
purposes (main wastewater discharge), and leakage from the plant clearwells. Discharge is
to an UT to Honeycutt Creek - arm of Falls Lake, classified as WS-IV-NSW. There has been
no discharge from Outfall 002 since August 2006.
Outfall 003 - Discharge of stormwater and overflow from the west raw water reservoir from the
culvert directly upstream of Outfall 002. Discharge is to an UT to Honeycutt Creek - arm of
Falls Lake, classified as WS-IV-NSW. There has been no discharge from Outfall 003 since
January 2007 except for stormwater, which is permitted and regulated by Stormwater
Discharge Permit NCS000245.
All three outfalls discharge to subbasin 03-04-01 in the Neuse River Basin. In this subbasin,
the Neuse River is listed on the 2008 draft 303 (d) list of impaired waters due to chlorophyll a.
A TMDL and nutrient rules are being developed for Falls Lake. However, due to chlorophyll -a
standard violations in the estuary, nutrient impacts (total nitrogen) on the Neuse River Basin
are a concern. A TMDL for total nitrogen has been developed for the Neuse River Basin.
Nutrient monitoring has been required with this permit in accordance with nutrient
management strategy. Because nutrient discharges cause more algae growth during warm
months, the Planning Section has requested that the City try to make any future discharges
only in winter months.
A benthic study was conducted in January 2006 on the main unnamed tributary that Outfall
002 discharges to (at the behest of DWQ). Upstream and downstream sampling had been
conducted in August 2002 and August 2005. In addition to the discharge, this area is
subjected to urban development. The summary of the report stated:
Conditions downstream of Raleigh's Johnson WTP (on UT Falls Lake) have declined
considerably in the past five months, and are similar to those seen in 2002. The
remnant aquatic community found downstream of the Plant is less diverse, much less
dense and more pollution tolerant than both the August 2005 sampling below the Plant,
and to current conditions at an upstream control site.
Based on this information - chronic toxicity monitoring will continue to be required for Outfall
002 (and 001) with this permit.
TOXICITY TESTING:
Current Requirement: Chronic Whole Effluent Toxicity Testing with Ceriodaphnia dubia
Monitoring at 90%.
The facility failed several WET tests through mid -year 2005. Toxicity screening revealed that a
polymer added as a sludge conditioning agent in the belt filters was causing the toxicity. A new
sanitary sewer pump station was installed so that the belt filter filtrate, drainage from the sand
filter beds, and water decanted from the sludge storage area are all sent to the sanitary sewer.
The facility has passed WET tests since this change was made.
No toxicity monitoring is recommended for Outfall 003 at this time.
COMPLIANCE SUMMARY:
There have been no NOVs issued in the current permit cycle.
NCO082376
NPDES Renewal
Page 2

INSTREAM MONITORING:
The requirement for upstream and downstream monitoring for turbidity has been removed in
accordance with the Division's Permitting Strategy for Conventional Water Treatment Plants. A
review of instream turbidity from 2005 through the end of discharge in August 2006 shows low
turbidity upstream and downstream of the discharge point. Upstream turbidity ranged from a
minimum of 0.48 NTU to a maximum of 8.79 NTU. Downstream turbidity ranged from a
minimum of 0.96 NTU to a maximum of 7.07 NTU. On 50% of the data set, downstream
turbidity was lower than upstream turbidity.
RESONABLE POTENTIAL ANALYSIS:
A Reasonable Potential to Exceed Water Quality Standards Analysis was conducted in
accordance with EPA requirements. Iron and manganese both showed potential to exceed WQ
standards, and DMR data show both exceeding the WQ standards several times. Iron is an
Action Level standard. As the plant is passing WET testing, no iron limit will be added at this
time. Monitoring will remain at the same frequency (weekly) as the last permit cycle. A new
limit of 200 ug/ L has been added for manganese as a weekly average as discussed below. The
limit was set at the instream standard because there is no dilution factor. Sampling frequency
of weekly is retained.
PROPOSED CHANGES:
Many of the proposed changes have been discussed in the text above. Changes, by Outfall
number, are discussed below:
At the request of Public Water Supply (PWS), weekly monitoring for fecal coliform has been
added to all 3 outfalls. The concern is that the discharge is upstream of the intake, and is less
than five miles upstream. Monitoring will only be required when the facility is discharging.
At the request of the Planning unit, a special condition (A.(7)) has been added to the permit to
restrict future discharges to winter months unless PWS requires a discharge during another
time. PWS requirements have to be followed by the facility.
Based on discussions with Mike Templeton, a limit of 2.0 mg/ L Total Phosphorus has been
added to the permit.
Outfall 001- This outfall has not been used during the last two permit cycles. The City wishes
to retain this outfall for future use. This outfall and Outfall 002 have identical requirements,
except that Outfall 001 can use grab samples instead of composite. Outfa11002 - current
treated effluent discharge. Outfall 002 has not discharged since August of 2006. Changes are
outlined below.
OutfaUs 001 and 002
Parameter
Action
Basis
Flow
Monthly average limit of
In accordance with Permitting
8.8 MGD was added
Strategy for Conventional WTPs.
The renewal application lists 8.8
MGD as the design rate.
Settleable Solids
Limits and monitoring
In accordance with Permitting
removed
Strategy for Conventional WTPs
Upstream and
Monitoring requirement removed
In accordance with Permitting
Downstream monitoring
Strategy for Conventional WTPs
of turbity
Total Phosphorus
A limit of 2.0 mg/ L was added as a
In accordance with Neuse River
uarte ly average
Nutrient Strategy.
Total Manganese
Weekly average limit of 200 ug/ L
DMR data indicate that the
added
instream standard has been
exceeded
Fecal coliform
Weekly monitoring only
Requested by PWS
NCO082376
NPDES Renewal
Page 3

Outfall 003 - (the culvert prior to 002). It contains some stormwater, groundwater,
and potentially overflow from the west raw water reservoir. It used to receive
leakage from clearwell finish water; this is now captured and routed to Outfall 002.
Similar constituents as Outfalls 001 and 002 (except that toxicity testing is not
included). Sampling is required monthly (except Al, Cd, Cr, Pb are required
quarterly, as with 002). The same new limits as for Outfall 002 have been added -
2.0 mg/L TP as a quarterly average, and 200 ug/L manganese weekly average.
Weekly monitoring for fecal colifform was added at the request of PWS. Monitoring
and limits apply only for water discharged from overflow of the raw water reservoir.
Stormwater continues to be permitted and regulated by Stormwater Discharge
Permit NCS000245.
PROPOSED SCHEDULE FOR PERMIT ISSUANCE:
During the Public Notice period, comments were received from four people, all requesting a
Public Hearing. Based on recommendations from staff, the Director has decided that a Public
Hearing will not be held for this permit renewal.
Draft Permit to Public Notice: April 9, 2008
Permit Issue: September 5, 2008
Permit Effective Date: October 1, 2008
Permit Expiration Date: February 28, 2013.
STATE CONTACT:
If you have any questions on any of the above information or on the attached permit, please
contact Jim McKay at [phone].
Staff report received March 27, 2008. Major comments:
➢ Resolve the issue of manganese limits. Response: a limit of 200 ug/L has been
added as a weekly average to Outfalls 001, 002 and 003.
➢ Clearwell leakage into Outfall 003 has been removed and directed to Outfall 002.
Update the permit language to reflect this. Response: this has been done.
AA
Reeional Office Comments
NCO082376
NPDES Renewal
Page 4

AFFIDAVIT OF PUBLICATION
NORTH CAROLINA.\
Wake County. / Ss
PUBLIC NOTICE
STATE OF NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT
COMA SSIONNPDES UNIT
117 *MAL SERVICE CENTER
El GH, NO 416 1617
NOTIFICATION OF INTENT'.TO ISSUE
A NPDES WASTEWATER PERMIT
WriHen comments regarding the Proposed permit will be
accepted until 30 days after the Publish dote of this notice:
All comments received Prior to that d.te are considered in
the final determinations regarding the Proposed permit.
The Director of the NC Division of Water Duality may
decide to hold a Public meeting for the Proposed Permit
should the Division receive o significant degree of public
interest.
Copies of the draft Permit and other SUPPe"fing informa.
tion on file used to determine conditions Present in the
draft permit are available upon request and Povment of
the costs of reproduction. Mail comments and/or requests
for information to the NC Division of Water Duality at the
above address or call Dina Sprinkle [phone]i extern
Sion 363 at 1hePoint Source Branch. Please Include the
NPDES permit number (below) in any communication.
Interested persons may also visit the Division of Water
Duality a1513 N. So if dry Street Raleigh. NC D58d-lit@
between the hours of 6:00 a.m.aM.500 p.m. to review
information an file.
Town of Hookerton; NCa025712, has applied to renew its
NPDES Permit discharging toCantentnea Creek in the
Neuse River Basin.: Total Residual chlorine (TRC) and
fecal coliform are water -quality limited. This discharge
may affect future wasteload allocations to the receiving..
no
Before the undersigned, a Notary Public of Chatham
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 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 , Wake
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
DIVISION OF WATER QUALITY was inserted in the
aforesaid newspaper on dates as follows: 04/11/08
Account Number: 73350833
The above is correctly copied from the books and files of the aforesaid Corporation and publication.
rotary
� Pubtt° :2
......... �o�c
Debra Peebles, Billing Manager -Legal Advertising
Wake County, North Carolina
Sworn or affirmed to, and subscribed before me, this
14 day of APRIL 2008 AD ,by Debra Peebles.
In Testimony Whereof, I have hereunto set my hand
and affixed my official seal, the day and year aforesaid.
i
Janet Scroggs, Notary Public
My commission expires 10 of March 2009.

The Town of Smithfield has aPPl led for renewal of N PDES
Permit numbefNC00833a8 for Its WTP. This Permitted
facility discharges filter -backwash wastewater to Buffalo
Creek in the Neese River Basin. Currently total residual
chlorine is water quality limitetl. This discharge may
affect future allocations in this Portion of Buffalo Creek.
The City of Raleigh has applied for renewce*of the NPDES
discharge Permit (NCW29033) for Its Neuse River Waste
water Treatment Plant located on NCSR 2552 southeast of
Raleigh. This facility discharges to the Neuse River, a
class C-NSW water in the Neuse River Basin. Currently,
BOD, PH, dissolved oxygen, ammonia, total nitrogen, and
total phosphorus are water quality limited.
Aqua North Coralina, Inc. has applied for renewal and a
modification to NPDES Permit Number NO0O5905, Mal.
lard Crossing Subdivision WWTP on NCSR U77 north of
Knigthdale in Wake County. This facility discharges
treated wastewater IMP an unnamed tributary to Hedges
Mill Creek in the Neuse River Basin. Currently, ammonia.
fecal coliform, temperature, dissolved oxy9er, PH, total
residual Chlorine, and various radiological components
based on drinking water standards are water quality
limited. This discharge may affect future allocations in
this portion of the receiving stream.
Aqua North Carolina, Inc. has applied for renewal of
NPDES permit number 1,100023699. Oak Hollow. WTP
located off NC. 42 near Mount Pleasant in Wake County.
This Permitted facility discharges filter wastewater to an
unnamed tributary to Middle Creek in the Neuse River
Basin. Currently total re5idupl Chlorine and PH are water
quality limited. This discharge may affect future alloca-
tions in this Portion of Middle Creek.
The City of Raleigh (P.O. Be. 5g), Raleigh, NC 27602) has
applied for renewal of NPDES Permit number NC0002376
far the E.M. Johnson WTP in Wake County. This Permitted
facility discharges filler -backwash wastewater to the
Neuse River or to aUT to Honeycutt Creek arm of Falls
Lake in the Neuse River Basin. Currently Suspended
Solids, total residual chlorine, Phosphorus, and Manga-
nese are water quality limited. This discharge may affect
future allocations in this Portion of the Neuse River Basin.
Aqua North Carolina, Inc. has applied for renewal of
NPDES Permit NC0082996 for the Hollybrook WTP located
on Kildare Form -Road southeast of Cary in Woke County.
This Permitted facility discharges send filter wastewater
to an unnamed tributary to Middle Creek in the Neuse
River Basin. Currently total residual chlorine and PH are
water quality limited. This discharge may cited future
allocations in this portion of Middle Creek.
Aqua North Carolina, Inc. has applied for renewal of
NPDES Permit NC00OM90 for the Stonsted Well #2 WTP
located on Stansted Drive north of Fuquay-Varinq in Wake
County. This permitted facility discharges sand filter
wastewater to an unnamed tributary to Basal Creek in the
Neuse River Basin. Currently total residual chlorine and
PH are water quality limited. This discharge may affect
future allocations in this Portion of Basal Creek.
NSO: April 11, 2009

NPDES REGIONAL WATER QUALITY
STAFF REPORT AND RECOMMENDATIONS
(This form is best filled out on computer, rather than hard copy. Then unprotect to
highlight in light blue as needed to make your comments more visible in the final printing.)
[But DON'T protect document again, or Word wipes out all you have entered.]
Date: County: Wake
To: NPDES Discharge Permitting Unit Permitee: City of Raleigh EM Johnson WTP
Attn. NPDES Reviewer: Jim McKay Application/ Permit No.: NCO082376
Staff Report Prepared By: Judy Garrett
Project Name:
SOC Priority Project? (Y/l) _ If Yes, SOC No.
A. GENERAL INFORMATION
1. This application is (check all That apply): ❑ New M Renewal
❑ Modification
2. Was a site visit conducted in order to prepare this report? M Yes or ❑ No.
a. Date of site visit: 03/13/2008
b. Person contacted and telephone number: Bryan Hamilton, 919 870-2870
c. Site visit conducted by: Judy Garrett
d. Inspection Report Attached: ❑ Yes or M No.
3. Keeping BIMS Accurate: Is the following BRAS information (a. through e. below) correct?
❑ Yes or ❑ No. If No, please either indicate that it is correct on the current application or the
existing permit or provide the details. If none can be supplied, please explain:
Discharge Point: (Fill this section only if BIMS or Application Info is incorrect or missing)
(If there is more than one discharge pipe, put the others on the last page of this form.)
a. Location OK on Existing PermitEl, OR, if not, is
OK on Application M, or if neither is right, provide Location:
b. Driving Directions OK on Existing Pemvt M, OR, if not, is
OK on Application ❑, or provide Driving Directions (please be accurate):
c. USGS Quadrangle Map name and number OK on Existing Permit ❑, OR, if not, is
OK on Application M, or provide USGS Quadrangle Map name and number:
d. Latitude/Longitude OK on Existing Permit ❑, (check at hqp://www.tonozone.com These are
often inaccurate) or is OK on Application M, or provide Latitude: Longitude: 3
pipes
e. Receiving Stream OK on Existing Permit M, OR, if not, is
OK on Application ❑, or provide Receiving Stream or affected waters:
a. Stream Classification: Outfall 001 Unnamed tributary to Neuse River, WS-IV-NSW
b. Outfalls 002 and 003 Unnamed tributary to Honeycutt Creek Arm of Falls Lake, WS-IV-
NSW
c. River Basin and Sub basin No.: 03-04-02

NPDES REGIONAL WATER QUALITY
STAFF REPORT AND RECOMMENDATIONS
d. Describe receiving stream features and downstream uses: Outfall 001- No stream within 100
feet. Discharge to ground. Outfalls 002 and 003- small stream. WTP grounds and Falls of
Neuse Road are the headwaters.
For NEW FACILITIES Proceed to Section C. Evaluation and Recommendations
(For renewals or modifications continue to section B)
B. DESCRIPTION OF FACILITIES AND WASMS) (renewals and modifications only)
1. Describe the existing treatment facility: Outfall 001- this is a discharge from the east raw water
reservoir which includes untreated water from the intake on Falls Lake, the recycle water from treated
002 water and potassium permanganate. Outfall 003- this is a discharge from the west raw water
reservoir including untreated water from the intake on Falls Lake, the recycle water from treated 002
water and potassium permanganate. This outfall has changed. It no longer contains the leakage from
the finished water clearwells. It still contains stormwater permitted under a separate stormwater permit.
Outfall 002- this is a 100 MGD Water Treatment Plant with wastewater treatment consisting of
declorination of filter backwash water and thickener overflow using calcium thiosulfate, treatment
through 2 backwash clarifiers and caustic addition for pH adjustment prior to discharge. The solids
from the backwash clarifiers and the sedimentation basin solids are processed through 3 sludge
thickeners, 4 sludge blending tanks, 3 belt filer presses with polymer addition, and discharge of filtrate
to the City of Raleigh sewer system. Sludge is stored on a containment pad and there are 8 sand drying
beds, 3 of'which are being used to receive contractor flush water from cleaning and testing new water
lines. This water is pumped to the backwash clarifiers using a portable 6 inch pump. Each bed holds
70,000 gallons. Sludge is removed by Eastern Compost. There is a reuse water station where certified
individuals can haul 002 water. The facility has permission from PWS to recycle the treated water from
Outfall 002 and the clearwell leakage to the raw water reservoirs except for 2 weeks out of each year
and when PWS tells the facility they must discharge. The requirement to discharge 2 weeks during the
past year was waived due to the drought, so there has been no discharge from 002 during the past year.
2. Are there appropriately certified ORCs for the facilities? ® Yes or ❑ No.
Operator in Charge: Bryan Hamilton Certificate # 986461 (Available in BIMS or Certification
Website)
Back- Operator in Charge: Certificate #
3. Does the facility have operational or compliance problems? Please comment: The facility has reported
Mn in excess of the standard. There is currently no limit for manganese in the NPDES Permit. I
understand that DWQ is attempting to remove the standard since it is not based on health criteria but
FORM: NPDES-RRO 06/03, 9/03, 1 /07 2

NPDES REGIONAL WATER QUALITY
STAFF REPORT AND RECOMMENDATIONS
rather on aesthetics(staining of clothes in drinking water), and the WTP has the capability to adequately
remove the manganese.
Summarize your BIMS review of monitoring data (Notice(s) of violation within the last permit cycle;
Current enforcement action(s)): None
Are they currently under SOC, ❑ Currently under JOC, ❑ Currently under moratorium ❑? Have
all compliance dates/conditions in the existing permit, SOC, JOC, etc. been complied with? ❑ Yes
or ❑ No. If no, please explain:
4. Residuals Treatment: PSRP ❑ (Process to Significantly Reduce Pathogens, Class B) or
PFRP ❑ (Process to Further Reduce Pathogens, Class A)?
Are they liquid or dewatered to a cake? Eastern Compost removes the sludge which does not contain
significant pathogens and does not have to be treated.
Land Applied? Yes ❑ No ❑ If so, list Non -Discharge Permit No.
Contractor Used:
Landfilled? Yes ❑ No❑ If yes, where?
Other?
Adequate Digester Capacity? Yes ❑ No ❑ Sludge Storage Capacity? Yes ® No ❑
Please comment on current operational practices: dewaters sludge is stored on a storage pad and
removed by Eastern Compost.
5. Are there any issues related to compliance/enforcement that should be resolved before issuing this
permit? ❑ Yes or ❑ No. If yes, please explain: We must resolve Mn issue described in 3 above.
C. E VAL UA TION AND RECOMMENDATIONS
1. Alternative Analysis Evaluation: has the facility evaluated the non -discharge options available? Give
regional perspective for each option evaluated:
Spray Irrigation: not available
Connect to Regional Sewer System: There is not adequate capacity in the sewer line.
Subsurface: Not practical
Other Disposal Options: The City has significantly reduced the amount of water discharged through
recycling and through capture of the clearwell leakage.
2. Provide any additional narrative regarding your review of the application:
3. List any items that you would like NPDES Unit to obtain through an additional information
request. Make sure that you provide a reason for each item:
FORM: NPDES-RRO 06/03, 9/03, 1/07 3

NPDES REGIONAL WATER QUALITY
STAFF REPORT AND RECOMMENDATIONS
Recommended Additional Information Reason
4. List specific Permit requirements that you recommend to be removed from the permit when
issued. Make sure that you provide a reason for each condition:
Recommended Removal
Reason
The mention of the clearwell leakage discharge for
003 should be removed. Pipes 001 and 003 should
have monitoring requirements and limits the same
as 002 because 002 is being recycled through the
raw water reservoirs.
A pump station was constructed which
removes this water from the wastestream.
Treated 002 is recycled through the raw
water reservoirs.
5. List specific special requirements or compliance schedules that you recommend to be included in
the permit when issued. Make sure that you provide a reason for each special condition:
Recommended Addition Reason
6. Recommendation: ❑ Hold, pending receipt and review of additional information by regional office;
❑ Hold, pending review and approval of required additional information by NPDES permitting
office; ® Issue; ❑ Deny. If deny, please state reasons: after resolving the manganese standard
issue.
Reminder. attach inspection report if Yes was checked for 2 d.
7. Signature of report preparer:
Signature of WQS regional supervisor:
Date:
A ADDITIONAL REGIONAL STAFF REVIEW ITEMS
If next page is not used, PLEASE set printer for pages 1 through 3 to avoid wasting paper.
FORM: NPDES-RRO 06/03, 9/03, 1/07 4

NPDES review.9f EA document for Raleigh E.M. Johnson WTP expa...
Subject: NPDES review of EA document for Raleigh E.M. Johnson WTP expansion
From: James Mckay <[e-mail]>
Date: Fri, 15 Feb 2008 16:15:37 -0500
To: Hannah Stallings <[e-mail]>
CC: Gil Vinzani <[e-mail]>
Hannah:
I have reviewed the subject document. Because of the increased treatment capacity of
the expanded facility and the corresponding increase in discharge of filter backwash
wastewater, the expansion likely will require a full SEPA process with a FONSI. An
Engineering Alternatives Analysis will be required to explore alternates to direct
discharge of the increased wastewater flow prior to issuing a revised NPDES discharge
permit.
As an aside, the current NPDES discharge permit does not have a flow limit. In
keeping with the current Permitting Strategy for Water Treatment Plants, the renewed
permit will have a flow limit.
Please contact me if you have any questions or comments. A copy of this email will
be attached to the Tracking Sheet when it is returned to you.
Jim McKay
Eastern NPDES Program
[phone], ext. 595
1 of 1 2/15/2008 4:18 PM

0a ARCADIS
Infrastructure, environment facilities
Jean Manuals
Field Supervisor
U.S. Army Corps of Engineers
Raleigh District
3331 Heritage Trade Drive, Suite 105
Wake Forest, NC 27587
sulced:
Status of Terms and Conditions in Biological Opinion
Dempsey E. Benton Water Treatment Plant
City of Raleigh Public Utilities Department
Dear Ms. Manuals:
A Biological Opinion for the Dempsey E. Benton Water Treatment Plant (WTP) was
issued on February 23, 2006 by the U.S. Fish and Wildlife Service (USFWS) after
formal consultation regarding the federally endangered dwarf wedgemussel (DWM)
in Swift Creek. The USFWS concluded that the Demspey E. Benton WTP project is
not likely to jeopardize the continued existence of the DWM. The Biological Opinion
requires compliance with terms and conditions necessary for the reasonable and
prudent measures necessary for the continued protection of the DWM.
On behalf of the City of Raleigh, the purpose of this letter is to provide an update on
the status of the City's progress in implementing the terms and conditions of the
Biological Opinion to the U.S. Army Corps of Engineers (USACE). Where applicable,
a schedule for completion is provided. The City retained ARCADIS to coordinate the
follow-up work relating to the BO, as well as the construction administration of the
Dempsey E. Benton WTP.
The construction of the Dempsey E. Benton WTP is currently in progress and is
scheduled for completion in February 2010. Many of these terms and conditions are
not applicable until the WTP is in operation. However, the City's Alternative Water
Source Exchange has triggered several terms and conditions related to the base
withdrawal rate and the minimum flow release.
The following is a summary of the status of the progress made toward compliance
with the terms and conditions:
1. Reasonable and prudent measure #1: Instream flows will be provided that are
protective of the DWM, including a tiered minimum release flow schedule and
corresponding reductions in withdrawal. Monitoring and reporting of the minimum
release flow is required. A maximum threshold on the base withdrawal rate was
established in addition to the frequency of the maximum withdrawal rate.
Imagine the result
ARCADIS 08M of North Carolina,
Inc.
801 corporate Center Drive
Suite 300
Raleigh
North Carolina 27607
Tel [phone]
Fax [phone]
"marcadis•us.conn
WATER RESOURCES
Data:
February 11, 2008
Contact
Mary Sadler
Extension:
229
Email:
mary.sadler@ arcadis-
us.com
Our rel:
NC706025.0000

ARCADIS Ms. Manuals
U.S. Army Corps of Engineers
In November 2007, the City submitted an Alternative Water Source Exchange
proposal to the USACE in response to the exceptional and record setting
drought. The proposal included the use of the constructed, but not yet in-service,
Highway 50 Pump Station and force main. The City also agreed to adhere to the
terms and conditions of the Biological Opinion in regards to water withdrawn and
the minimum flow release from Lake Benson dam. The USFWS agreed to the
Alternative Water Source Exchange for a two month period starting November
21, 2007. In January 2008, the City submitted a request for an extension on the
Alternative Source Water Exchange.
During the Alternative Water Source Exchange, the City has not exceeded the
base flow withdrawal of 14 mgd. Additionally, with the exception of the start-up
day (November 21) and one other day in November, the City has maintained a
minimum flow release in excess of the Tier i minimum flow of 3 cfs. The
Alternative Source Water Exchange did not require a tier 3 flow (1.0 cfs) release,
therefore facsimile notification has not been necessary.
The City is not reporting the base withdrawal rate or the minimum flow release to
the USACE on a daily basis during the Alternative Source Water Exchange.
However, the City has reported this information in letter correspondence to the
USACE as part of a request to extend the time period for the water exchange.
It has not been necessary to reduce the water levels at Lake Benson for
construction.
2. Reasonable and prudent measure #2: The USACE/City must construct the
intake, outlet, and minimum flow release structures at the Lake Benson dam to
accurately control the release rate of instantaneous minimum flows. The City
must ensure that that water released is of suitable water quality for the DWM and
meets North Carolina water quality standards, e.g. North Carolina dissolved
oxygen standards (4 mg/1 instantaneous and 5 mg4 average). From April to
November, the temperature and dissolved oxygen must be monitored in Lake
Benson on a weekly basis. If necessary, adjustments shall be made to the intake
depth to optimize dissolved oxygen. Dissolved oxygen levels must be measured
continuously in the water released from Lake Benson dam and notify the
Service's Raleigh Field Office when levels fall below 5 mgA
The City has constructed a temporary minimum release flow structure (weir and
ultrasonic level control) for the Alternative Water Source Exchange effort due to
the on -going drought (refer to reasonable and prudent measures #1). The
permanent minimum release flow structure (venturi meter and flow control valve)
will be installed as appropriate to the construction schedule.
Dissolved oxygen levels will be monitored in Lake Benson and downstream of
the minimum release upon completion and start-up of the Demspey E. Benton
WTP.
Pill

ARCADIS Ms. Manuele
U.S. Army Corps of Engineers
3. Reasonable and prudent measure #3: Dwarf wedgemussel (DWM) surveys in
Swift Creek must be periodically performed downstream of Lake Benson dam.
The survey scientists must be pre -qualified by the Service. The level of effort for
each survey must not exceed 250 man -person hours. An initial baseline survey
must be conducted, a follow-up survey within 12 months of project operations,
and surveys performed once every 5 years thereafter for a total of 20 years.
Additional surveys may be conducted if the minimum releases from Lake Benson
dam are maintained at Tier 3 (1.0 cis) for more than seven consecutive days or
more than 14 days within any 30 consecutive days. These additional surveys
must not exceed 40 person man-hours and no more than one survey shall be
triggered in any year. The Service, Wildlife Resources Commission (WRC), and
Natural Heritage Program (NHP) shall be informed one week prior to any survey.
The survey data shall be submitted annually.
The protocols and reporting requirements for the surveys were developed four
months after the receipt of the Finding of No Significant Impact (FONSI) for the
Dempsey E. Benton WTP project in the fall of 2006. The initial baseline survey
was performed by the Catena Group in the summer of 2007. The Catena Group
was pre -qualified by the Service to perform the survey. A total of 250 person
man-hours were spent surveying, with survey time allocated in Swift Creek as
agreed to in the mussel survey plan. The survey data will be submitted with the
Dempsey E. Benton Sampling and Monitoring Program Report In early spring
2008.
4. Reasonable and prudent measure #4: A flow gauging station on Swift Creek
downstream of the Lake Benson Dam must be implemented prior to project
operations.
The City had suggested the Highway 42 Bridge Crossing as a potential USGS
gaging station site on Swift Creek. The Highway 42 site was rejected by the
USGS due to access issues. The USGS recommended the next available
downstream site at Barber Mill Road. The City is in the process of working with
USGS to install the gaging station in 2008.
5. Reasonable and prudent measure #5: The City must implement three stations in
the Swift Creek Watershed as part of the Sampling and Monitoring Program. One
station will be downstream of Lake Benson dam, and the other two locations will
be selected by DENR. Monthly water chemistry sampling and annual benthic
macroinvertebrate sampling will be performed at each site. Photodocumentation
surveys will be performed once every two years. A summary of the data will be
provided to the Service with the Sampling and Monitoring Program Report.
The three new sampling stations in Swift Creek were approved by DWQ for
benthic sampling in the spring of 2007. The new sampling station at Lake
Benson dam was moved one-half mile downstream by DWQ for habitat suitability
for benthic monitoring. Benthic sampling occurred in late spring 2007.
The new sampling stations were named by DWQ in the fall of 2007. These
stations will be reported to the Lower Neuse Basin Association (LNBA) to add to
M

ARCADIS Ms. Manuele
U.S. Army Corps of Engineers
the City's roster of water chemistry sampling sites. It is expected that water
chemistry sampling will commence in the spring of 2008.
The photodocumentation surveys took place in the summer and early fall 2007.
All available data will be reported in the Sampling and Monitoring Program
Report. A draft is expected in spring 2008.
6. Reasonable and Prudent measure #6: Upon approval of the Highway 50 Pump
Station and prior to initiation of Project operations (I.e., water withdrawals), the
City must secure all required permits and approvals for the decommissioning of
the two private WWTPs (Indian Creek Overlook and Mill Run Mobile Home
Park). Both WWTPs must be decommissioned and removed from service within
12 months of initiation of Project water withdrawals.
The Mill Run Mobile Home Park community has been shut down. The area is
slated for future development. Therefore, the Mill Run WWTP has been removed
from service permanently.
The process of removing the Indian Creek WWTP from service is in progress. A
Preliminary Engineering Report has been completed for the design of a new
pump station and force main to tie into an existing outfall. Final design is
expected to be complete by January 2009 with possible bid dates in February
2009. Construction is anticipated to be completed in 2010.
Reasonable and Prudent measure #7: Riparian corridor protection for the Steep
Hill Creek and Lake Wheeler to Lake Benson corridors must be pursued for
water quality protection within the Swift Creek watershed. The Lake Wheeler to
Lake Benson corridor includes an approximate 300-foot-buffer along 4.1 miles of
Swift Creek between Lake Wheeler and Lake Benson. The Steep Hill Creek
corridor includes an approximate 300-foot buffer along 7.2 miles of Steep Hill
Creek for water quality protection. Protection mechanisms may include land
acquisition, conservation easements, purchase by other third parties with
protective covenants, and other means that provide protection against
development and allow uses appropriate for buffers and green space. Protection
mechanisms must be in place for at least 50 percent of the land contained within
the corridors within 12 months of initiation of Project water withdrawals. Beyond
this time frame, the City, in conjunction with Wake County, must continue its
efforts in good faith and to the best of its ability to pursue riparian protection for
the remaining parcels. The lands will be incorporated into the City and County
Greenways Program as appropriate and allowable by ownership, protection
status, and conservation easement conditions.
The County has been successful in acquiring property or protective easements
along the Swift Creek and Steep Hill corridors since the Biological Opinion was
issued in February 2006. The County has acquired two properties along the Swift
Creek corridor totaling 2.89 acres. Along the Steep Hill Creek corridor, the
County closed on a nine -acre easement in September 2006.
4/6

ARCADIS Ms. Manuals
U.S. Army Corps of Engineers
The County is continuing the pursuit of land acquisitions per the Open Space
Plan as approved by the Wake County Commissioners.
8. Reasonable and orudent measure #8: A Public Service Announcement (PSA), in
the form of television, radio, or newspaper advertisements, must be implemented
to encourage water conservation, especially during periods of low rainfall. Two of
the three PSAs must be released whenever the minimum flow is maintained at
Tier 2 (2.0 cis) for more than fourteen (14) consecutive days or more than
fourteen (14) days within any thirty (30) day period. All three PSAs must be
released whenever the minimum flow is maintained at Tier 3 (1.0 cfs) for more
than fourteen (14) consecutive days or more than fourteen (14) days within any
thirty (30) day period. All radio and television PSAs must be broadcast between
the hours of 5:00 AM and 11:00 PM.
The City has not implemented PSAs at this time. The Dempsey E. Benton WTP
is scheduled for completion in February 2010. Additionally, the minimum release
during the Alternative Water Source Exchange has remained in Tier 1.
9. Reasonable and prudent measure #9: Additional measures to conserve water
usage within the City's service area must be adopted. The existing water
conservation measures must be modified or additional measures designed to
reduce or minimize the need to operate the Project at the Tier 2 and Tier 3 levels
must be adopted. Any municipality obtaining finished water from the City's water
treatment plants (e.g. Rolesville, Garner, Zebulon, etc.) must adopt water
conservation measures at least as stringent at those used by the City.
The City simplified water restrictions in 2007 as a result of the water conservation
task force committee recommendations. Stage 3 water restrictions were replaced
with modifications to Stage 1 and 2 restrictions. In response to the drought,
Stage 1 restrictions went into effect August 26, 2007. The City Council then
passed an amended Stage 1 restriction on October 16, 2007. The amended
Stage 1 restrictions eliminated all outdoor water use not needed for a living wage
(e.g. pressure washing). The amended Stage 1 allows for hand watering of
plants. The City Council is currently considering entering fully into Stage 2
restrictions. The City is also discussing the possibility of implementing a tiered
rate structure for water use.
Per the water and sewer merger agreements, any water conservation measure
that the City implements must also be implemented by Garner, Rolesville, Wake
Forest, Wendell, Knightdale, and Zebulon.
The Sampling and Monitoring Program Report will be provided to the USACE and
the USFWS as soon as it is completed and has been reviewed by the City.
5/6

ARCADIS Ms. Manuele
U.S. Army Corps of Engineers
Please do not hesitate to call if you have any questions.
Sincerely,
ARCADIS G&M of North rpIn I c.
Mary E. S dler, PE J
Associate Project Manager
Copies:
J. Russell Allen, Raleigh City Manager
Dale Crisp, City of Raleigh Public Utilities Director
Robert Massengill, City of Raleigh Assistant Public Utilities Director
Perry Allen, City of Raleigh Construction Project Manager
T.J. Lynch, City of Raleigh Wastewater Treatment Plants Superintendent
John Garland, City of Raleigh Water Treatment Plants Superintendent
Colonel John Pulliam, Wilmington District, USACE
Terry Brown, Wilmington District, USACE
James Sham, Raleigh District, USACE
Dale Suiter, U.S. Fish and Wildlife Service
Pete Benjamin, U.S. Fish and Wildlife Service
Coleen Sullins, Division of Water Quality, DENR
Matt Mathews, Division of Water Quality, DENR
Hannah Stallings, Division of Water Quality, DENR
Tom Fransen, Division of Water Resources, DENR
John Morris, Director, Division of Water Resources, DENR
Dan McLawhom, City of Raleigh Associate Attorney
Mary Sadler, ARCADIS
Whit Wheeler, ARCADIS
Linda Diebolt, ARCADIS
MI

DWQ Environmental Review Tracking Sheet
DENRA 08-0244
DWQ# 13949
iced S23�G
Date: 2/11/2008 TYPE: EA
Environmental Sciences Section
_Trish MacPherson - Biological Assessment Unit
_Jay Sauber - Ecosystems Unit
_Cindy Moore - Aquatic Toxicology Unit
_Intensive Survey Unit
Wetlands and Stormwater Branch
_Bradley Bennett - Stormwater Unit
_John Hennessy - DOT
_Cyndi Karoly - 401 Unit
_Julie Ventaloro - Water Supply
Point Source Branch
_Matt Matthews - NPDES Unit
_Gil Vinzani (EAST)
_Susan Wilson (WEST)
_Jeff Poupart - PERCS Unit
Aquifer Protection Section
_Todd Bennett - Animal Feeding Operations Unit
_Kim Colson - Land Application Unit
_Groundwater Planning Unit
_Debra Watts - Groundwater Protection Unit
_Groundwater Investigation Unit
Planning Section
.KBasinwide Planning Unit
I'�he2t
_Jeff Manning - Classification and Standards Unit
_Rich Gannon - Non -Point Source Planning Unit
Kathy Stecker - Modeling and TMDL Unit
!L
jy'er�y Y
Others
A copy of the environmental document for the project described below is attached. Subject to the requirements of
SEPA, you are being asked to review the document for potential significant impacts to the environment that are
pertinent to your jurisdiction, level of expertise, or permitting authority. Please return this completed form along with
any written comments by the date indicated. Thanks for your help.
If an extension is needed, contact Hannah Stallings prior to the response deadline.
Project Description:
Response Deadline
City of Raleigh's E.M. Johnson Water Treatment Pant expansion located on Falls of the
Neuse Road in Wake County
= No comment
/Lys., a f . iI' ` 115V_
Elcomments attached and emailed
Signature � - 15 - 2 ege" tr Date
Return To:
Hannah Stallings: voice: [phone], ext. 555; fax: [phone]; [e-mail]
DWQ Planning Section, 1617 MSC, Raleigh, NC 27699-1617
Office 625i Archdale Building
Notes:

Environmental Assessment for the
City of Raleigh's E.M. Johnson Water
Treatment Plant Expansion
Scoping Document
Introduction
The City of Raleigh owns and operates the E.M. Johnson Water Treatment Plant (WTP)
located at 10301 Falls of the Neuse Road (Figure 1). This plant is currently the City's primary
water treatment facility. Starting in 2000 and ending in 2006, the City completed a series of
water and wastewater utility merger agreements with the eastern Wake County towns of
Gamer, Knightdale, Rolesville, Wake Forest, Wendell, and Zebulon. The driver for these
merger agreements was the Wake County Water/Sewer Master Plan, completed in 1998, that
concluded the most efficient and environmentally sound alternative was to provide the
County municipalities with a regional utility service provider. As a result of the merger
agreements, Raleigh provides water and wastewater utility services for its own service area
as well as the service areas of the merger communities (Figure 2). Through the merger
agreements the City is contractually obligated to provide safe, reliable water and wastewater
service to each of these communities at their current populations and for yearly growth rates
outlined within each community's merger agreement. Raleigh also has water sales contracts
with Holly Springs and Fuquay-Varina.
Current Situation and Project Need
The currently approved peak day finished water treatment capacity of the E.M. Johnson
WTP is 86 million gallons per day (mgd). However, due to hydraulic limitations at the
plant, the actual peak day safe operating capacity of the plant is approximately 72 to 77 mgd.
The annual average demands in 2006 and 2007 were 48.4 mgd and 50.8 mgd, respectively.
Growth within Raleigh's service area and the need for reliable, redundant treatment capacity
are driving the need for the peak day capacity increase at the E.M. Johnson WTP. The City is
constructing the new D.E. Benton WTP near Lake Benson, with the lake as its water supply;
the peak day capacity of this plant will be 18 mgd. In addition, Raleigh is planning a new
water supply project, the Little River Reservoir in eastern Wake County. Both of these
projects are important components of the City's long range plan to meet water demands
beyond 2025.
The purpose of the proposed project is to expand the peak day treatment capacity of the E.M.
Johnson WTP to 120 mgd. This project does not increase the raw water supply for the City of
Raleigh. It does increase the WTP s treatment capacity so that it is consistent with the City's
contracted 45,000 acre-feet of raw water supply storage in Falls Lake. This volume of storage
was contracted to the City by the US Army Corp of Engineers (USACE) in 1965 authorized
by Public Law 89-298. According to a frequency analysis conducted by the USACE and

E.M. JOHNSON WATER TREATMENT PLANT EXPANSION - SCOPING DOCUMENT
documented to the City in 1992, this 45,000 acre-feet translates to a 20-year safe yield of 82
mgd. This safe yield is an average annual yield.
In order for the WTP to treat the available 82 mgd safe yield from Falls Lake, the peak day
treatment capacity of the plant must be increased to 120 mgd, based on the City's current
maximum day to average day peaking factor of 1.47. Expansion of the peak day capacity to
120 mgd will enable the City to meet peak day demands and provide redundancy of
treatment capacity. It will also give the City needed operating flexibility during planned
maintenance activities at the E.M. Johnson WTP or the D.E. Benton WTP, as well as during
emergency situations.
The expansion project will require a new intake structure located in Falls Lake, a pumping
station, a raw water transmission main from the lake to the WTP, and treatment plant
infrastructure. The intake and pumping station will provide redundancy of the raw water
supply infrastructure to equip the City with back-up facilities in case either intake or
pumping station experiences an emergency shut down.
Study Area
The Environmental Assessment (EA) will address only the direct impacts resulting from this
project. The study area for this EA is therefore limited to areas that will be disturbed for
construction of the intake and pumping station, the corridor of the raw water transmission
main from Falls Lake to the WTP, and construction of the plant expansion. The raw water
main will be constructed parallel to the existing raw water main. The plant expansion will
be located adjacent to the existing WTP facilities on property already owned by the City of
Raleigh.
Secondary and Cumulative Impacts
The City of Raleigh is currently working with CH2M HILL to develop a Secondary and
Cumulative Impacts (SCI) Management Plan for its entire service area, including the merger
communities. This plan will address the SCI that could occur as a result of this project and
will be available prior to or concurrently with the EA for this WTP expansion.
Proposed Project Alternatives
The following proposed project alternatives will be evaluated:
1. No action. This alternative would preclude the City from fully utilizing its purchased
water supply storage in Falls Lake. This alternative is deficient because it limits the ability of
the City to meet future peak day demands, and provides no operating redundancy or
flexibility to the City
2. Expansion of the existing E.M. Johnson Water Treatment Plant with Falls Lake as the
water source. This alternative would provide the needed infrastructure to allow the City to
utilize the entire Falls Lake water supply storage pool purchased by the City. The additional
water would be treated by expanded infrastructure at the existing WTP; the existing raw
water transmission corridor would be utilized for a second raw water transmission main.

E.M. JOHNSON WATER TREATMENT PLANT EXPANSION - SCOPING DOCUMENT
3. Construction of a new water treatment plant with Falls Lake as the water source. The new
plant alternative would also provide the needed infrastructure to allow the City to utilize the
entire purchased Falls Lake water supply storage pool. This alternative would require the
purchase of a new plant site and the construction of new raw water and treatment
infrastructure.
Environmental Assessment Tasks
The followingtasks will be performed in order to evaluate the referred alternative:
P P c6-
1. Identify fish and wildlife resources within the study area, with an mphasis on sensitive
species found in the City of Raleigh water service area. Identify possible impacts directly
related to the proposed projecFederally-listed wildlife species will also be a focus, and
these can be found in Table 1.
2. Identify sensitive flora species found within the project area and possible impacts
directly related to the proposed project.. Federally listed flora species will be the focus,
and these can be found in Table 1.
3. Conduct a GIS analysis using existing GIS data layers to provide a visual characterization
of the existing land cover, land use, and rare or significant natural areas/habitats within
the study area. The GIS information will be used as an aid in determining the extent of
possible impacts directly related to the proposed project on wetlands, forests, significant
natural areas, and public lands.
4. Conduct a GIS and literature search to identify the presence and significance of historical,
cultural and archaeological resources known to exist within the study area and provide `4
an overview of possible impacts directly related to the the proposed project on these
resources.
5. Perform literature searches to evaluate the existingconditions and possible
P �
environmental impacts directly related to the proposed project..
6. Summarize construction mitigative measures and local ordinances as well as other local or
regional efforts that will facilitate mitigation of possible direct impacts of the proposed
project.
7. Prepare a Biological Assessment/Biological Evaluation, to include with the EA, for
federally -listed species. This evaluation will be performed through a literature review of
species habitat needs and other available information, including pertinent mussel
sampling results.

TREATMENT PLANT EXPANSION - SCOPING DOCUMENT
TABLE t
Federally Listed Species within the Study Area
Federal
Common Name
Scientific Name
State Status
Status
County Status
Animals
Ambloplites cavifrons
Roanoke Bass
SR
FSC
Current
Myotis austroriparius
Southeastern Myotis
SC
FSC
Destroyed
Noturus furiosus
Carolina Madtom
SC (PT)
FSC
Historic
Picoides borealis
Red -cockaded Woodpecker
E
E
Destroyed
Invertebrates
Alasmidontaheterodon
Dwarfwedgemussel
E
E
Current
Fusconaia masoni
Atlantic pigtoe
E
FSC
Current
Elliptio lanceolata
Yellow lance
E
FSC
Current
Plants
Lindera subcoriacea
Bog spicebush
T FSC Current
Trillium pusillum var.
Virginia least trillium
E FSC Current
virgianium
Rhus michauxii
Michawes Sumac
E-SC E Current
Source: NHP, 2007
State Status
Federal Status
T = Threatened
E = Endangered
E = Endangered
FSC = Federal Species of Concern
SC = Species of Concern
SR = State Rare
(PT) = Potentially Threatened
Proposed
Environmental Assessment Outline
1. Project
Description
2. Project
Purpose and Need
3. Project
Alternatives
4. Existing Environmental Characteristics of Project Area
4.1
Topography
4.2
Soils
4.3
Land Use
4.4
Wetlands
4.5
Prime or Unique Agricultural Lands
4.6
Public Lands and Scenic, Recreational, and State Natural Areas
4.7
Areas of Archaeological or Historic Value
4.8
Air Quality
4.9
Noise Level
4.10
Water Resources (Surface Water and Groundwater)
4

E.M. JOHNSON WATER TREATMENT PLANT EXPANSION - SCOPING DOCUMENT
4.11
Forest Resources
4.12
Shellfish or Fish and Their Habitats
4.13
Wildlife and Natural Vegetation
5. Predicted Environmental Effects of Project
5.1
Topography
5.2
Soils
5.3
Land Use
5.4
Wetlands
5.5
Prime or Unique Agricultural Lands
5.6
Public Lands and Scenic, Recreational, and State Natural Areas
5.7
Areas of Archaeological or Historic Value
5.8
Air Quality
5.9
Noise Level
5.10
Water Resources (Surface Water and Groundwater)
5.11
Forest Resources
5.12
Shellfish or Fish and Their Habitats
5.13
Wildlife and Natural Vegetation
5.14
Introduction of Toxic Substances
6. Programs to Minimize Environmental Impacts (*)
7. List of Preparers
8. References
Appendices
• Scoping Document
• Agency Involvement
• Biological Assessment/ Biological Evaluation
• Secondary and Cumulative Impacts Management Plan
(*) The Secondary and Cumulative Impacts Management Plan that is currently being
prepared for the City of Raleigh will be cited in Section 6 and provided in the Appendix of
the EA. Section 6 will focus only on the direct impacts of the proposed project.
5

DURHAM
FRANKLIN COUNTY
I
Raleigh
W EECOUNTY_,___f
Knightdale
I
Municipal Boundary
ETJ Limit
Raleigh
Raleigh
Garner
Garner
Knightdale
Knigthdale
_ Rolesville
Rolesville
_ Wake Forest
Wake Forest
_ Wendell
Wendell
_ Zebulon
Zebulon
0 5 10 Miles
Urban Service Area
Raleigh
Q Watershed
Garner
Waterbodies
Knightdale
O Study Area
Rolesville
County Boundary
Wake Forest
Wendell
Zebulon
Figure 2
City of Raleigh Public Utilily Department Service Area
EM. Johnson WTP Expansion Scoping Document

Oty Of Raleigh
.worth eamltna
August 22, 2007
Mrs. Frances Candelaria
N.C. Department of Environment and Natural Resources
Division of Water Quality
Point Source Branch
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Re: City of Raleigh
E.M. Johnson WTP
NPDES Permit Renewal
Permit No. N0082376
Dear Mrs. Candelaria:
Enclosed is the permit renewal package for the NPDES Permit for the E.M. Johnson Water
Treatment Plant (WTP) for the City of Raleigh, North Carolina. The package includes the
following information:
This cover letter.
Completed NPDES Permit Application — Short Form C - WTP
Sludge Management Plan for the E.M. Johnson WTP Facilities
The renewal application does not include a Priority Pollutant Analysis (PPA) because
communication with DWQ staff indicated that a PPA was not required since the E.M.
Johnson WTP is not a primary industry or a wastewater treatment plant.
Changes made to the facilities since the last permit was issued consist of changes to the
discharge conditions for Outfalls 002 and 003, construction of a new recycle pump station
and ultraviolet (UV) disinfection facilities, and construction of a sanitary sewer pump station.
Outfall 002 has been changed from a continuous to an intermittent discharge. Discharge to
Outfall 002 is expected to occur for only a two -week period each year to meet Division of
Environmental Health, Public Water Supply Section requirements (see permit application).
The rest of the time the discharge is recycled to the raw water terminal reservoirs. For
Outfall 003, the plant clearwell leakage is no longer discharged through this outfall since it
Cover Letter EMJWTP 082207 NPDES rene val

Mrs. Frances Candelaria
August 22, 2007
Page 2
has been rerouted to Outfall 002. Therefore, Outfall 003 only includes stormwater and
overflow from the west raw water terminal reservoir. Overflow from the west raw water
terminal reservoir is an infrequent occurrence, in the same manner as for Outfall 001.
Therefore, the City requests that discharge monitoring for Outfalls 002 and 003 be the same
as for Outfall 001, namely that a monthly DMR will be submitted whether a discharge occurs
or does not occur [Condition A.(7.)]. In addition, the notation "No Flow" will be made if there
is no discharge from these outfalls for that month. For Outfall 003, the only discharge
monitored will be overflow from the west raw water terminal reservoir. Stormwater
discharged through Outfall 003 will continue to be permitted and regulated by the NPDES
Stormwater Discharge Permit No. NCS000245.
The new recycle pump station and UV disinfection system are used for the recycle of the
discharge from Outfall 002 to the raw water terminal reservoirs. The sanitary sewer pump
station is used to convey residuals from the wastewater treatment facilities to the City of
Raleigh wastewater collection system. Currently, the belt filter press filtrate, the sand drying
bed drainage, and the decant from the sludge disposal facility are directed to the sanitary
sewer pump station.
Please let me or Robert Massengill, Asst Public Utilities Director (919)-857-4540 know if you
have any questions or comments on this renewal package.
Z
y,C 'sp, .E.
Raleigh Pub tilities Director
HDC/rab
Enclosure
Cc: City Manager
Asst. Public Utilities Director — Massengill
Water Plants Superintendent
Hazen & Sawyer — Bob Berndt

Additional Information
Item 7. Treatment Processes for Raw Water
Water treatment processes include rapid mixing, flocculation, sedimentation, ozonation, filtration
and disinfection with chlorine (sodium hypochlorite) and ammonia. Raw water from Falls Lake
is conveyed to two terminal reservoirs, and from the terminal reservoirs to two pre -ozone
contact tanks. Ozone is introduced to the main flow in the pre -ozone facility at the upstream
end of the contact tanks.
Ozonated raw water flows to two rapid mix basins, where chemicals are introduced in two
locations: into the pipeline immediately upstream from the rapid mix basins and directly into
submersible mixers located inside the rapid mix basins. From the rapid mix basins, the water is
discharged into a common flocculation distribution channel that distributes the flow to five
flocculation/sedimentation trains.
Flocculation is provided by walking beam flocculators in a two -stage flocculation process. Flow
from each flocculation basin is directed to its associated sedimentation basin. Settled solids are
collected in the influent end of each sedimentation basin by a traveling bridge solids collector.
All solids removed from the basins are directed to the solids handling facilities.
Settled water from the sedimentation basin collection channel flows to the intermediate ozone
facility, where four intermediate ozone contactors introduce ozone to the settled water. Settled
ozonated water flows to the filter influent channel, from which it is distributed to 11 two -cell, dual
media (sand and anthracite) filters. Filter backwash water from the filters is also directed to the
solids handling facilities.
Filtered water is collected in the filtered water flume and is distributed to two clearwells, which
provide contact time for free chlorine disinfection and storage of finished water upstream from
the finished water pumping facilities.
Ferric sulfate is currently used as the primary coagulant in the plant. Powdered activated
carbon (PAC) has been used intermittently to control taste and odor events. Chlorine is used as
the primary disinfectant. A chloramine residual is formed by adding ammonia to the chlorinated
water in order to produce chloramines after free chlorine disinfection in the clearwells.
Item 8. Wastewater and Treatment Processes for Wastewater Generated by the Facility
Residuals from the water treatment plant process include solids settled in the sedimentation
basins, filter backwash water, and decant water from a sludge disposal facility.
The solids from the sedimentation basins are discharged to a splitter box, which distributes the
solids to three sludge thickeners. A fourth sludge thickener is planned to be added to
supplement the existing three thickeners. The thickened sludge is pumped to four sludge
blending tanks, from which the sludge is pumped to three belt filter presses for dewatering.
Polymer is added to the thickened sludge to the belt presses for solids conditioning before
dewatering. The dewatered cake is hauled by truck to a containment pad. The dewatered cake
is hauled from the containment pad and recycled to a contractor. Backwash clarifier solids are
returned to the splitter box for treatment with the solids from the sedimentation basins. Belt filter
press filtrate and decant water from the sludge disposal facility are pumped to the City of
Raleigh wastewater collection system for treatment at the Neuse River WWTP (City of Raleigh
Permit No. EMJ1).
0:130681130681-0021Eng1EMJ\Perrrut NCO082376 071107.doc 1

The filter backwash water is discharged to two backwash clarifiers, which also receive decant
water from the sludge thickeners. A Parshall flume with an ultrasonic flow meter is used for
measuring the decant water flow rate from the sludge thickeners. Caustic is added to the flow
from the thickeners to the backwash clarifiers for pH control of the filter backwash water. The
backwash clarifier effluent is dechlorinated before discharge, and is the only discharge to the
receiving stream from the treatment facilities. The discharge to the receiving stream is
intermittent (see Additional Information, Item 10). The backwash clarifier effluent is normally
recycled to the raw water terminal reservoirs. A portion of the backwash clarifier effluent is also
reused for irrigation (DWQ Permit No. WQ0022036).
The sludge disposal facility is used for storage of thickened sludge from the sludge blending
tanks when one or more of the belt presses are out of service for maintenance or repairs (DWQ
Permit No. WQ0008431). The sludge disposal facility is periodically decanted using a portable
pump, and returned to the sanitary sewer pump station for return to the City wastewater
collection system.
Item 10. Frequency of Discharge
Discharge to Outfall 001 is intermittent and has not changed from the current permit conditions.
Discharge to Outfall 003 is also intermittent and has changed from the current permit conditions.
It currently includes only stormwater and overflow from the west raw water terminal reservoir.
This discharge no longer includes miscellaneous wastewater (leakage from the plant
clearwells), which is currently being recycled to the raw water terminal reservoirs.
Discharge to Outfall 002 has also been changed to intermittent since the discharge flow is
normally being recycled to the terminal reservoirs. The Division of Environmental Health (DEH),
Public Water Supply (PWS) Section currently requires the recycle to the terminal reservoirs to
be discontinued for two weeks each year, during which period there will be a discharge to
Outfall 002 (see attached letter from PWS, November 21, 2006). PWS can also require the City
to return to disc harai nif rIaAmPr� n _ .essary by PWS
Item 12. Name of Receiving Stream(s)
See Figure 1 for map showing outfall locations.
Item 13. Water Treatment Additives That Have the Potential to be Discharged
CHEMICALS ADDED:
Water Treatment Processes
Potassium permanganate (oxidant)
Ferric sulfate (coagulant)
Polymer (coagulant aid)
Hydrated lime (pH control)
Caustic (pH control)
Powdered activated carbon (odor control)
Polymer (filter aid)
Sodium silicate (corrosion inhibitor)
Hydrofluosilicic acid (fluoride)
Chlorine (disinfectant)
Ammonia (disinfectant)
Wastewater Treatment Processes
Polymer (coagulant aid)
Caustic (pH control)
Calcium thiosulfate (dechlorinating agent)
0:130681130681-0021Eng1EMAPemiit NCO082376 071107.doc 2

Item 15. Schematic of Flow Through the Facility and Solids Handling Plan
A schematic of the wastewater treatment processes at the E.M. Johnson WTP is included in
Figure 2.
The following page presents the sludge management plan for the facility.
0:130681130681-0021Eng1EMJi Permit NC0082376 071107.doc 3

E.M. Johnson WTP
Sludge Management Plan
Residuals from the E.M. Johnston Water Treatment Plant (WTP) include solids from the
sedimentation basins and filter backwash water. The residuals are treated in a residuals
treatment system that includes the following:
• One Flow Splitter Box (for Flow to Sludge Thickeners)
• Three Sludge Thickeners
• Four Sludge Blending Tanks
• Three Belt Filter Presses (BFPs)
• One Containment Pad
• Seventeen Sand Drying Beds
• One Sludge Disposal Facility
• Two Backwash Clarifiers
• Recycle Pumps (for Flow to Terminal Reservoirs)
• Ultraviolet Disinfection Facilities (for Flow to Terminal Reservoirs)
• Thickened Sludge Pumps
• BFP Feed Pumps
• Polymer Feed System (for BFPs)
• Filtrate Pumps
• Sanitary Sewer Pumps
• Caustic Feed System (for Filter Backwash Water)
• Parshall Flume (for Sludge Thickener Decant/Overflow)
Filter backwash water is treated in the backwash clarifiers. Effluent from the backwash clarifiers
is currently recycled to the terminal reservoirs for most of the year. During a two -week period
each year, it is discharged to receiving waters through Outfall 002.
Solids from the sedimentation basins, along with backwash clarifier solids, are distributed to the
sludge thickeners for thickening by gravity. The thickened sludge is pumped to the sludge
blending tanks for storage, and from there is pumped to the belt filter presses for dewatering.
The dewatered sludge is discharged from the belt filter presses to trucks for hauling to the
containment pad for storage. From the containment pad, the dewatered sludge is hauled by
truck for recycling to a contractor.
0A30681\30681-0021Eng1EMMerrrit NCO082376 071107.doc 4

FLOW
SPUTTER
BOX
SL
SLUDGE
THICKENERS
(3)
0.24 MGD ITS
THICKENED
SLUDGE
PUMP
STATION
I
I
I
I
I
I
I
I
I
THICKENED SLUDGE
TO SLUDGE DISPOSAL
FACILITY
(ALTERNATE)
RAW WATER
FROM PRETREATMENT
RESERVOIRS WATER TREATMENT
FACILITIES
1.87 MGD
POLYMER - -,
I
SL
2.23 MGD MANHOLE
N0. 2
0.36 MGD I BCS
TS
0.24 MGD
HAZEN AND SAWYER
Environmeniel Engineers & Scientists
BCS
0.36 MGD
TO WASTEWATER
COLLECTION SYSTEM
TO
1.99 MGD
CHEMICALS (SEE ADDITIONAL
INFORMATION ITEM 13)
FINISHED WATER
6.94 MGD
FILTER BACKWASH
SLUDGE CALCIUM
FROM THIOSULFATE -----
SEDIMENTATION
TANKS CALCIUM
THIOSULFATE - - - - -
--- POLYMER i
I
I} CAUSTIC E 8.93 MGD!
�9 TO
PARSHALL
FLUME
MANHOLE
MANHOLE
CALCIUM
THIOSULFATE
BACKWASH
CLARIFIERS
(2)
r - - - - - - - - - - - - - —
DISCHARGE TO
I
OUTFALL 001
I
I
(FUTURE)
I I r------------ -
CALCIUM
I I
THIOSULFATE
I
UV
P
RECYCLE TO
DISINFECTION
TERMINAL RESERVOIRS
RECYCLE TO WEST
-
- - - - - - - - - ►
TERMINAL RESERVOIR
8.43 MGD -
I
CAUSTIC
I
I
CALCIUM THIOSULFATE
II
----1-
••
DISCHARGE TO
OUTFALL 002
METERING
0.15 MGD FLUME
BCS P- - - - - - - - - -
TO IRRIGATION
0.36 MGD SYSTEM
POLYMER WASHWATER
0.29 MGD 0.14 MGD POTABLE
WATER
SLUDGE I BELT
BLENDING ` TS TS FILTER Ds TRUCK CONTAINMENT
TANKS P 0.24 MGD PRESSES 0.02 MGD HAULING PAD
(4) I (3) pRp E
I N �
I
LJI----BTO-- L------- - - - - - - - - - - - - - - - -
I
P I
I
F 0.51 MGD
I
I
I
FILTRATE I,
PUMP - r
STATION I
r
THICKENED SLUDGE I
TO SLUDGE DISPOSAL I
FACILITY I I
I
F SANTARY
SEWER PUMP
0.51 MGD STATION
UNDERDi
DECANT FROM
SLUDGE DISPOSAL
FACILITY
FIGURE 2
LEGEND
BCS
BACKWASH CLARIFIER SLUDGE
BTO
BLENDING TANK OVERFLOW
DS
DEWATERED SLUDGE
F
FILTRATE
SL
SLUDGE
TO
THICKENER OVERFLOW
TS
THICKENED SLUDGE
©
PUMPS
TYPICAL OPERATION
---
ALTERNATE OPERATION
TRUCK RECYCLE
HAULING 1 0.02 MGD TO A CONTRACTOR
NCO082376
E.M. JOHNSON WTP
� CITY OF RALEIGH
RESIDUALS TREATMENT SYSTEM
PROCESS FLOW SCHEMATIC