NC0025453_correspondence_20061220

F VWATF
�0 �Q Michael F.Easley,Governor
' 0 William G.Ross 7r..Secretary
t-^ North Carolina Department of Environment and Natural Resources
t� ^C Alan W.Klimek,P.E.Director
Division of Water Quality
December 20, 2006
Mr. R. Steven Biggs, Town Manager
Town of Clayton
Post Office Box 879
Clayton, North Carolina 27520
SUBJECT: Town of Clayton
Engineering Report for Wastewater Treatment
System Capacity Study and Improvements
Project No. CS370431-05 and
Engineering Report for Clayton Wastewater
Discharge to City of Raleigh
Project No. CS370431-06
Dear Mr. Biggs:
On August 8, 2005, the Construction Grants and Loans Section confirmed the status of
our review of the Engineering Report(431-05)received on May 13, 2005 in a letter to the town
(copy attached). That letter includes the Division's rationale for not beginning its review of the
proposed project, and requested that an approvable Nutrient Management Plan be submitted to
address how the town will meet its nitrogen allocation at a design capacity of 8.0 mgd. To date
we have not received any additional information. Accordingly, the Division has not begun its
technical or environmental review of the proposed expansion to 8.0 mgd.
We also received an Engineering Report(431-06) in March 2006 proposing the discharge
of 1.0 mgd of Clayton's wastewater to the City of Raleigh's treatment system. The report was
subsequently revised and resubmitted in October 2006. Appendix 1 of the report contains a
copy of a ten-year agreement between Clayton and the city of Raleigh, with conditional renewal
terms. Typically, a 20-year agreement is required in order to provide loan or grant funds for a
proposed project. Thus, to ensure that the town can continue to meet its nitrogen allocation if the
agreement is executed in its current form and not renewed at the end of the first ten-year term, an
approvable Nutrient Management Plan must also be submitted for this project prior to our
approval of the Engineering Report. The Division currently considers 3.0 mg/l TN as the best
available technology (BAT). Thus, the supplemental allocation of 7,336 lbs/yr of TN being held
in reserve in the town's NPDES permit is insufficient to cover 1.0 mgd of wastewater proposed
for discharge to Raleigh.
Construction Grants and Loans Section
1633 Mail Service Center Raleigh NC 27699-1633 One
Phone:[phone]/FAX:[phone]/Internet:www.nccgi.net NofthCarolina
An Equal Opportunity/Affirmative Action Employer—50%Recycled/10%Post Consumer Paper Aahmally

Mr. R. Steven Biggs, Town Manager
December 20, 2006
Page 2
Upon receipt of an acceptable response to our letter of May 13, 2005, and an updated
intermunicipal agreement between the town of Clayton and the city of Raleigh, a FNSI for the
Clayton/Raleigh interconnect project can be prepared, and review of the 8.0 mgd Clayton project
can be initiated. Therefore, please provide us with a schedule for receipt of the requested
information.
If you have any questions regarding this matter,please contact me at [phone] or
Mr. Daniel M. Blaisdell, P.E. at [phone].
Sincerely, l
hn R. Blowe, P.E., Chief
Construction Grants and Loans Section
DMB/dr
cc: Neuse River Compliance Association -Cindy Finan,Executive Director
Neuse River Compliance Associate - Haywood Phthisic, President
City of Raleigh- Dale Crisp, P.E.
Division of Water Quality-Alan Klimek, P.E., Director
Division of Water Quality - Colleen Sullins, Deputy Director
Matt Matthews, SWP-NPDES
Mike Templeton, P.E.
DWQ Raleigh Regional Office
The Wooten Company- Shankar Mistry, P.E.
Daniel Blaisdell,P.E.
DMU/FEU/SRF