NC0025453_Modification_Request_20200908

MAYOR MAYOR PRO TEM
Jody L. McLeod Jason Thompson
•
INTERIM TOWN MANAGER GAR0�� COUNCIL MEMBERS
JD Solomon F 2 Michael Grannis
n'Or`. Art Holder
TOWN ATTORNEY Z j``��ON Bobby Bunn
Parker Poe Cif= Avery Everett
Attention: Mike Montebello
Municipal Permitting Unit Supervisor
North Carolina Department of Environmental Quality, Division of Water Resources
512 N. Salisbury St RECEIVED
Raleigh, NC 27604
SEP 1 1 2020
NCDEQIDWRINPDES
September 8, 2020
Subject: Town of Clayton Water Reclamation Facility Permit Major Modification - Permit No.
NC0025453
Dear Mr. Montebello,
The Town of Clayton is submitting this application for major modification to NPDES permit
NC0025453 as part of the Town's Water Reclamation Facility (WRF) Expansion project. The Town is
seeking to replace its current wastewater treatment capacity and expand to meet growing capacity
demands with construction of a 6-million gallon per day (MGD) WRF. The Town will expand its
current outfall 001 to the Neuse River as part of this project. The proposed facility will be located on
the same parcel as the current outfall 001, at 1422 North O'Neil Street, Clayton, NC.
The Town has purchased an additional 13,000 lb/year in supplemental estuary nitrogen allocation
credits from International Paper Company and requests that this be added to the NPDES permit as
part of this major modification process, resulting in a total of 29,013 lb/year in estuary nitrogen
allocation credits.
Please find enclosed a check in the amount of$1,030 for the permit major modification processing
fee and one electronic copy and one hard copy of each of the following documents for the Clayton
Water Reclamation Facility permit major modification application:
• EPA Application Form 2A— New and Existing Publicly Owned Treatment Works
• Topographic Map
• Process Flow Diagram
• WET Testing Laboratory Results
• International Paper Company Nitrogen Allocation Purchase Agreement
• NPDES Permit NC0025453, Little Creek WRF in Johnston County (current draft)
• Engineering Report meeting your Engineering Alternatives Analysis guidance
This application and supporting documentation include information per the permit application
meeting held on June 15, 2020 as part of the broader project initial Engineering Report-
Environmental Impact Document submittals.
Think
CLkrt-C1•1
PO Box 879 • Clayton,NC 27528 • 919-553-5002 Fax [phone] • TownofClaytonNC.org

Thank you for your assistance with the permit major modification process. Please direct any
questions to James Warren, Operator, at [e-mail] and to Jaime Robinson,
our consultant at [e-mail].
Yours re ,
Solomon
Interim Town Manager
Copies to: Rich Cappola, PE/Town of Clayton
James Warren/Town of Clayton
Jacobs
think
YT
YPO Box 879 • Clayton,NC 27528 • 919-553-5002 Fax [phone] •TownofClaytonNC.org

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19
NC0025453 Neuse River Water Reclamation OMB No.2040-0004
Form U.S.Environmental Protection Agency
2A : EPA Application for NPDES Permit to Discharge Wastewater
NPDES NEW AND EXISTING PUBLICLY OWNED TREATMENT WORKS
SECTION 1.BASIC APPLICATION INFORMATION FOR ALL APPLICANTS(40 CFR 122.21(j)(1)and(9))
1.1 Facility name
Neuse River Water Reclamation Facility(Future Facility)
Mailing address(street or P.O.box)
P.O.Box 879
City or town State ZIP code
o Clayton North Carolina 27528
47.
Contact name(first and last) Title Phone number Email address
wc James Warren Superintendent [phone] jowarren@townofclaytonnc.o
Location address(street,route number,or other specific identifier) ❑ Same as mailing address
R 1422 N.O'Neil St.
LL
City or town State ZIP code
Clayton NC 27520
1.2 Is this application for a facility that has yet to commence discharge?
❑ Yes 4 See instructions on data submission ❑✓ No
requirements for new dischargers.
1.3 Is applicant different from entity listed under Item 1.1 above?
❑✓ Yes ❑ No 4 SKIP to Item 1.4.
Applicant name
J D Solomon,Town Manager
Applicant address(street or P.O. box)
w 111 East Second Street
€ City or town State ZIP code
c Clayton North Carolina 27528
Contact name(first and last) Title Phone number Email address
n. J D Solomon Town Manager [phone] jdsolomon@townofclaytonnc.
n
1.4 Is the applicant the facility's owner,operator,or both?(Check only one response.)
❑ Owner ❑ Operator ✓❑ Both
1.5 To which entity should the NPDES permitting authority send correspondence?(Check only one response.)
0 Facility El Applicant
❑ Facility and applicant
(they are one and the same)
1.6 Indicate below any existing environmental permits. (Check all that apply and print or type the corresponding permit
`o number for each.)
Existing Environmental Permits
a
❑ NPDES(discharges to surface ❑ RCRA(hazardous waste) ❑ UIC(underground injection
water) control)
E NC0025453,NCC000001
o ❑ PSD(air emissions) ❑ Nonattainment program(CM) ❑ NESHAPs(CM)
fr) ❑ Ocean dumping(MPRSA) ❑ Dredge or fill(CWA Section ❑ Other(specify)
404)
WQ0022224
EPA Form 3510-2A(Revised 3-19) Page 1

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19
NC0025453 Neuse River Water Reclamation OMB No.2040-0004
1.7 Provide the collection system information requested below for the treatment works.
Municipality Population Collection System Type
Served Served (indicate percentage) Ownership Status
100 %separate sanitary sewer D Own 0 Maintain
-a Town of Clayton 25,234 %
d combined storm and sanitary sewer 0 Own ❑ Maintain
d 0 Unknown 0 Own 0 Maintain
= 100 %separate sanitary sewer 0 Own 0 Maintain
East Clayton Industrials %combined storm and sanitary sewer 0 Own 0 Maintain
`° Industrial Area
❑ Unknown 0 Own 0 Maintain
a %separate sanitary sewer 0 Own 0 Maintain
13 %combined storm and sanitary sewer 0 Own 0 Maintain
co 0 Unknown 0 Own 0 Maintain
E %separate sanitary sewer 0 Own 0 Maintain
N %combined storm and sanitary sewer 0 Own 0 Maintain
_ 0 Unknown 0 Own 0 Maintain
w Total
m Population 25,234
o Served
Separate Sanitary Sewer System Combined Storm and
Sanitary Sewer
Total percentage of each type of
sewer line(in miles) 100 % 0
1.8 Is the treatment works located in Indian Country?
oo 0 Yes Q No
c.,
R 1.9 Does the facility discharge to a receiving water that flows through Indian Country?
c 0 Yes ❑� No
1.10 Provide design and actual flow rates in the designated spaces. Design Flow Rate
6.0&10.0 mgd
Ti Annual Average Flow Rates(Actual)
ain
- Two Years Ago(2017) Last Year(2018) This Year(2019)
-o
= c 1.67 mgd 1.69 mgd 1.72 mgd
" Maximum Daily Flow Rates(Actual)
o Two Years Ago(2017) Last Year(2018) This Year(2019)
5.45 mgd 4.78 mgd 3.93 mgd
y 1.11 Provide the total number of effluent discharge points to waters of the United States by type.
.o Total Number of Effluent Discharge Points by Type
mtu
, Combined Sewer Constructed
Treated Effluent Untreated Effluent Overflows
s Bypasses Emergency
Overflows
N_
0 1(Neuse River)
EPA Form 3510-2A(Revised 3-19) Page 2

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19
NC0025453 Neuse River Water Reclamation OMB No.2040-0004
Outfalls Other Than to Waters of the United States
1.12 Does the POTW discharge wastewater to basins,ponds,or other surface impoundments that do not have outlets for
discharge to waters of the United States?
❑ Yes ❑✓ No• SKIP to Item 1.14.
1.13 Provide the location of each surface impoundment and associated discharge information in the table below.
Surface Impoundment Location and Discharge Data
Average Daily Volume Continuous or Intermittent
Location Discharged to Surface (check one)
Impoundment
❑ Continuous
gpd ❑ Intermittent
❑ Continuous
gpd ❑ Intermittent
O Continuous
gpd 0 Intermittent
2 1.14 Is wastewater applied to land?
✓❑ Yes ❑ No 4 SKIP to Item 1.16.
c 1.15 Provide the land application site and discharge data requested below.
Land Application Site and Discharge Data
Continuous or
Location Size Average Daily Volume Intermittent
Applied (check one)
txs
Conw Pine Hollows Golf Course 97.4 acres 27,759 gpd ❑ Intermittent
t acres d ❑ Continuous
9p 0 Intermittent
acres gpd ❑ Continuous
co ❑ Intermittent
R 1.16 Is effluent transported to another facility for treatment prior to discharge?
❑✓ Yes
❑ No 4 SKIP to Item 1.21.
1.17 Describe the means by which the effluent is transported(e.g.,tank truck,pipe).
The Town of Clayton's wastewater system has pipeline connections with the Johnston County Wastewater Treatment
Facility and the City of Raleigh Neuse River Resource Recovery Facility.(page 4 of this application has been duplicated to
allow for lictina a cPrnnd farilitvl
1.18 Is the effluent transported by a party other than the applicant?
❑ Yes ❑✓ No 4 SKIP to Item 1.20.
1.19 Provide information on the transporter below.
Transporter Data
Entity name Mailing address(street or P.O.box)
City or town State ZIP code
Contact name(first and last) Title
Phone number Email address
EPA Form 3510-2A(Revised 3-19) Page 3

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19
NC0025453 Neuse River Water Reclamation OMB No.2040-0004
1.20 In the table below,indicate the name,address.contact information. NPDES number,and average daily flow rate of the
receiving facility.
Receiving Facility Data
Facility name Mailing address(street or P.O. box)
43
Johnston County Wastewater Treatment Facility P.O.Box 2263
.2 City or town State ZIP code
o Smithfield NC 27577
0
U, Contact name(first and last) Title
o Chandra Farmer,P.E. Public Works Utilities Director
d Phone number Email address
2 [phone] [e-mail]
cNPDES number of receiving facility(if any) ❑ None Average daily flow rate 0.734 mgd
CI NC0030716
0 1.21 Is the wastewater disposed of in a manner other than those already mentioned in Items 1.14 through 1.21 that do not
d have outlets to waters of the United States(e.g.,underground percolation, underground injection)?
0 ElYes 0 No-3 SKIP to Item 1.23.
0 1.22 Provide information in the table below on these other disposal methods.
d Information on Other Disposal Methods
oDisposal Location of Size of Annual Average Continuous or Intermittent
-0 Method Daily Discharge
R Description Disposal Site Disposal Site Volume (check one)
o 0 Continuous
o acres gpd 0 Intermittent I
0 Continuous
acres gpd 0 Intermittent
acresgpd ❑ Continuous
0 Intermittent
1.23 Do you intend to request or renew one or more of the variances authorized at 40 CFR 122.21(n)?(Check all that apply.
43 y Consult with your NPDES permitting authority to determine what information needs to be submitted and when.)
c . ❑ Discharges into marine waters(CWA ❑ Water quality related effluent limitation(CWA Section
Section 301(h)) 302(b)(2))
0 Not applicable
1.24 Are any operational or maintenance aspects(related to wastewater treatment and effluent quality)of the treatment works
the responsibility of a contractor?
❑ Yes 0 No+SKIP to Section 2.
1.25 Provide location and contact information for each contractor in addition to a description of the contractor's operational
and maintenance responsibilities.
Contractor Information
Contractor 1 Contractor 2 Contractor 3
c Contractor name
0
.r (company name)
gMailing address
"E (street or P.O.box)
c City,state, and ZIP
t' code
12
cContact name(first and
c.) last)
Phone number
Email address
Operational and
maintenance
responsibilities of
contractor
EPA Form 3510-2A(Revised 3-19) Page 4

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19
NC0025453 Neuse River Water Reclamation OMB No.2040-0004
1.20 In the table below.indicate the name,address,contact information, NPDES number, and average daily flow rate of the
receiving facility.
Receiving Facility Data
-o Facility name Mailing address(street or P.O. box)
City of Raleigh Neuse River Resource Recovery Facility 8500 Battle Bridge Rd
City or town State ZIP code
o Raleigh NC 27610
Contact name(first and last) Title
o Ti Lynch Director Wastewater
d Phone number Email address
[phone] [e-mail]
c NPDES number of receiving facility(if any) ❑ None Average daily flow rate 0.228 mgd
NC0029033
1.21 Is the wastewater disposed of in a manner other than those already mentioned in Items 1.14 through 1.21 that do not
have outlets to waters of the United States(e.g.,underground percolation, underground injection)?
L ❑ Yes ❑✓ No 4 SKIP to Item 1.23.
0 1.22 Provide information in the table below on these other disposal methods.
Information on Other Disposal Methods
o Disposal Location of Size of Annual Average Continuous or Intermittent
Method Disposal Site Disposal Site Daily Discharge (check one)
Description Volume
acres gpd 0 Continuous
❑ Intermittent
0 Continuous
acres gpd ❑ Intermittent
acresgpd ❑ Continuous
❑ Intermittent
1.23 Do you intend to request or renew one or more of the variances authorized at 40 CFR 122.21(n)?(Check all that apply.
0 0 Consult with your NPDES permitting authority to determine what information needs to be submitted and when.)
G, Discharges into marine waters(CWA Water quality related effluent limitation(CWA Section
❑ Section 301(h)) ❑ 302(b)(2))
❑✓ Not applicable
1.24 Are any operational or maintenance aspects(related to wastewater treatment and effluent quality)of the treatment works
the responsibility of a contractor?
❑ Yes ❑✓ No+SKIP to Section 2.
1.25 Provide location and contact information for each contractor in addition to a description of the contractor's operational
and maintenance responsibilities.
Contractor Information
Contractor 1 Contractor 2 Contractor 3
0
Contractor name
(company name)
0
Mailing address
(street or P.O.box)
o City,state,and ZIP
code
Contact name(first and
0
last)
Phone number
Email address
Operational and
maintenance
responsibilities of
contractor
EPA Form 3510-2A(Revised 3-19) Page 4

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19
NC0025453 Neuse River Water Reclamation OMB No.2040-0004
SECTION 2.ADDITIONAL INFORMATION(40 CFR 122.21(j)(1)and(2))
o Outfalls to Waters of the United States
2.1 Does the treatment works have a design flow greater than or equal to 0.1 mgd?
a>
o ❑✓ Yes ElNo 4 SKIP to Section 3.
c 2.2 Provide the treatment works'current average daily volume of inflow Average Daily Volume of Inflow and Infiltration
"1 and infiltration.
220,000 gpd
c Indicate the steps the facility is taking to minimize inflow and infiltration.
The Town of Clayton has an ongoing sewer system evaluation and rehabilitation program.The Town is planning a study,
which will investigate RDII and address it and will use pump station runtime data to identify basins with high wet
weather peaking factors to focus their efforts.
2.3 Have you attached a topographic map to this application that contains all the required information?(See instructions for
m specific requirements.)
0"/
0
O.
❑✓ Yes ❑ No
E 2.4 Have you attached a process flow diagram or schematic to this application that contains all the required information?
3 Es_ (See instructions for specific requirements.)
o En
" o ❑✓ Yes ❑ No
2.5 Are improvements to the facility scheduled?
✓❑ Yes ❑ No 4 SKIP to Section 3.
Briefly list and describe the scheduled improvements.
0
1. See Attachment C for list of processes&equipment
a>
E
m
n 2.
E
0
N 3.
C)
d
4.
cn
2.6 Provide scheduled or actual dates of completion for improvements.
c Scheduled or Actual Dates of Completion for Improvements
Affected Attainment of
Scheduled Begin End Begin
o Outfalls Operational
Improvement Construction Construction Discharge
(from above) (list outfall (MM/DD/YYYY) (MM/DD/YYYY) (MM/DD/YYYY) Level
number) (MM/DD/YYYY)
1. 001 03/01/2021 08/01/2022 09/01/2022 10/01/2022
CD
m
in 2.
3.
4.
2.7 Have appropriate permits/clearances concerning other federal/state requirements been obtained?Briefly explain your
response.
❑ Yes ❑✓ No ❑ None required or applicable
Explanation:
Environmental permitting underway.
EPA Form 3510-2A(Revised 3-19) Page 5

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19
NC0025453 Neuse River Water Reclamation OMB No.2040-0004
SECTION 3.INFORMATION ON EFFLUENT DISCHARGES(40 CFR 122.21(j)(3)to(5))
3.1 Provide the following information for each outfall. (Attach additional sheets if you have more than three outfalls.)
Outfall Number ool Outfall Number Outfall Number
State North Carolina
o County Johnston County
0 City or town Town of Clayton
w
o
Distance from shore so ft. ft. ft.
0.
Depth below surface 3 ft. ft. ft.
Average daily flow rate 1.62 mgd mgd mgd
Latitude 35° 39' 50" N °
Longitude 78° 25' 26" W
3.2 Do any of the outfalls described under Item 3.1 have seasonal or periodic discharges?
❑ Yes ✓❑ No 4 SKIP to Item 3.4.
d
3.3 If so,provide the following information for each applicable outfall.
y Outfall Number Outfall Number Outfall Number
0
Number of times per year
0 discharge occurs
n Average duration of each
discharge(specify units)
Average flow of each
discharge mgd mgd mgd
eo
(0Months in which discharge
occurs
3.4 Are any of the outfalls listed under Item 3.1 equipped with a diffuser?
❑ Yes ❑✓ No 4 SKIP to Item 3.6.
3.5 Briefly describe the diffuser type at each applicable outfall.
a
Outfall Number Outfall Number Outfall Number
0
c vi 3.6 Does the treatment works discharge or plan to discharge wastewater to waters of the United States from one or more
discharge points?
❑✓ Yes ❑ No 4SKIP to Section 6.
EPA Form 3510-2A(Revised 3-19) Page 6

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19
NC0025453 Neuse River Water Reclamation OMB No.2040-0004
3.7 Provide the receiving water and related information(if known)for each outfall.
Outfall Number 001 Outfall Number Outfall Number
Receiving water name Neuse River
Name of watershed,river,
c or stream system Neuse Sub Basin 03-04-02
fl- U.S. Soil Conservation
d Service 14-digit watershed 03020201100030
o code
Name of state
management/river basin Neuse River Basin
cn
U.S. Geological Survey
8-digit hydrologic 03020201
cataloging unit code
Critical low flow(acute) 181 cfs cfs cfs
Critical low flow(chronic) cfs cfs cfs
Total hardness at critical mg/L of mg/L of mg/L of
low flow 34.6 CaCO3 CaCO3 CaCO3
3.8 Provide the following information describing the treatment provided for discharges from each outfall.
Outfall Number 001 Outfall Number Outfall Number
Highest Level of 0 Primary ❑ Primary ❑ Primary
Treatment(check all that ❑ Equivalent to ❑ Equivalent to ❑ Equivalent to
apply per outfall) secondary secondary secondary
O Secondary ❑ Secondary ❑ Secondary
O Advanced ❑ Advanced ❑ Advanced
❑ Other(specify) ❑ Other(specify) ❑ Other(specify)
0
'Q Design Removal Rates by
Outfall
BOD5 or CBOD5 98
ok
m TSS 97 %
❑ Not applicable ❑ Not applicable ❑Not applicable
Phosphorus 78
❑Not applicable ❑ Not applicable ❑Not applicable
Nitrogen 95 %
Other(specify) ❑Not applicable ❑ Not applicable ❑ Not applicable
cyo
EPA Form 3510-2A(Revised 3-19) Page 7

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19
NC0025453 Neuse River Water Reclamation OMB No.2040-0004
3.9 Describe the type of disinfection used for the effluent from each outfall in the table below. If disinfection varies by
season,describe below.
Open channel low-pressure,high-output(LPHO)UV
0
U
c Outfall Number 001 Outfall Number Outfall Number
Disinfection type
Ultraviolet(UV)Disinfection
0)
Seasons used
all
Dechlorination used? 0 Not applicable 0 Not applicable 0 Not applicable
❑ Yes 0 Yes 0 Yes
0 No 0 No 0 No
3.10 Have you completed monitoring for all Table A parameters and attached the results to the application package?
O Yes 0 No
3.11 Have you conducted any WET tests during the 4.5 years prior to the date of the application on any of the facility's
discharges or on any receiving water near the discharge points?
O Yes 0 No+SKIP to Item 3.13.
3.12 Indicate the number of acute and chronic WET tests conducted since the last permit reissuance of the facility's
discharges by outfall number or of the receiving water near the discharge points.
(See attachment D for Outfall Number 001 Outfall Number Outfall Number
laboratory reports) Acute Chronic Acute Chronic Acute Chronic
Number of tests of discharge 2
water
Number of tests of receiving
water
3.13 Does the treatment works have a design flow greater than or equal to 0.1 mgd?
,� ❑✓ Yes 0 No 4 SKIP to Item 3.16.
c 3.14 Does the POTW use chlorine for disinfection,use chlorine elsewhere in the treatment process,or otherwise have
reasonable potential to discharge chlorine in its effluent?
❑ Yes 4 Complete Table B,including chlorine. 0 No Complete Table B,omitting chlorine.
c 3.15 Have you completed monitoring for all applicable Table B pollutants and attached the results to this application
package?
0 Yes 0 No
3.16 Does one or more of the following conditions apply?
• The facility has a design flow greater than or equal to 1 mgd.
• The POTW has an approved pretreatment program or is required to develop such a program.
• The NPDES permitting authority has informed the POTW that it must sample for the parameters in Table C,must
sample other additional parameters(Table D),or submit the results of WET tests for acute or chronic toxicity for
each of its discharge outfalls(Table E).
Yes 4 Complete Tables C,D,and E as
❑ applicable. ElNo-4 SKIP to Section 4.
3.17 Have you completed monitoring for all applicable Table C pollutants and attached the results to this application
package?
O Yes ❑ No
3.18 Have you completed monitoring for all applicable Table D pollutants required by your NPDES permitting authority and
attached the results to this application package?
❑ Yes 0 No additional sampling required by NPDES
permitting authority.
EPA Form 3510-2A(Revised 3-19) Page 8

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19
NC0025453 Neuse River Water Reclamation OMB No.2040-0004
3.19 Has the POTW conducted either(1)minimum of four quarterly WET tests for one year preceding this permit application
or(2)at least four annual WET tests in the past 4.5 years?
No 4 Complete tests and Table E and SKIP to
❑✓ Yes ❑ Item 3.26.
3.20 Have you previously submitted the results of the above tests to your NPDES permitting authority?
No 4 Provide results in Table E and SKIP to
❑✓ Yes ❑ Item 3.26.
3.21 Indicate the dates the data were submitted to your NPDES permitting authority and provide a summary of the results.
Date(s)Submitted Summary of Results
(MM/DD/YYYY)
The Town of Clayton submits quarterly chronic toxicity results to NCDEQ
06/25/2020 DWR in accordance with their NPDES Permit.In the past 4.5 years no
"cslaboratory tests have resulted in toxicity.
c
0
CO
3.22 Regardless of how you provided your WET testing data to the NPDES permitting authority,did any of the tests result in
toxicity?
❑ Yes ❑✓ No 4 SKIP to Item 3.26.
3.23 Describe the cause(s)of the toxicity:
w
3.24 Has the treatment works conducted a toxicity reduction evaluation?
❑ Yes ❑✓ No 4 SKIP to Item 3.26.
3.25 Provide details of any toxicity reduction evaluations conducted.
3.26 Have you completed Table E for all applicable outfalls and attached the results to the application package?
El Yes ❑✓ Not applicable because previously submitted
information to the NPDES sermittin• authorit .
SECTION 4.INDUSTRIAL DISCHARGES AND HAZARDOUS WASTES(40 CFR 122.21(j)(6)and(7))
4.1 Does the POTW receive discharges from SIUs or NSCIUs?
❑ Yes ❑ No 4 SKIP to Item 4.7.
rd 4.2 Indicate the number of SIUs and NSCIUs that discharge to the POTW.
Number of SIUs Number of NSCIUs
3
0
2 4.3 Does the POTW have an approved pretreatment program?
CO
❑✓ Yes ❑ No
F, 4.4 Have you submitted either of the following to the NPDES permitting authority that contains information substantially
d identical to that required in Table F:(1)a pretreatment program annual report submitted within one year of the
R application or(2)a pretreatment program?
❑✓ Yes ❑ No SKIP to Item 4.6.
.173
4.5 Identify the title and date of the annual report or pretreatment program referenced in Item 4.4.SKIP to Item 4.7.
3 Pretreatment Annual Report(PAR)Town of Clayton,2018 02/25/2019
v
4.6 Have you completed and attached Table F to this application package?
❑✓ Yes ❑ No
EPA Form 3510-2A(Revised 3-19) Page 9

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19
NC0025453 Neuse River Water Reclamation OMB No.2040-0004
4.7 Does the POTW receive,or has it been notified that it will receive.by truck, rail,or dedicated pipe,any wastes that are
regulated as RCRA hazardous wastes pursuant to 40 CFR 261?
❑ Yes ❑✓ No 4 SKIP to Item 4.9.
4.8 If yes,provide the following information.
Annual
Hazardous Waste Waste Transport Method Amount of Units
Number (check all that apply) Waste
Received
❑ Truck ❑ Rail
❑ Dedicated pipe ❑ Other(specify)
0
❑ Truck ❑ Rail
to
❑ Dedicated pipe ❑ Other(specify)
O
N ❑ Truck ❑ Rail
_ ❑ Dedicated pipe ❑ Other(specify)
A 4.9 Does the POTW receive,or has it been notified that it will receive,wastewaters that originate from remedial activities,
including those undertaken pursuant to CERCLA and Sections 3004(7)or 3008(h)of RCRA?
❑ Yes ❑✓ No 4 SKIP to Section 5.
in 4.10 Does the POTW receive(or expect to receive)less than 15 kilograms per month of non-acute hazardous wastes as
specified in 40 CFR 261.30(d)and 261.33(e)?
❑✓ Yes 4 SKIP to Section 5. 0 No
4.11 Have you reported the following information in an attachment to this application:identification and description of the
site(s)or facility(ies)at which the wastewater originates;the identities of the wastewater's hazardous constituents;and
the extent of treatment,if any,the wastewater receives or will receive before entering the POTW?
O Yes ❑ No
SECTION 5.COMBINED SEWER OVERFLOWS(40 CFR 122.21(j)(8))
5.1 Does the treatment works have a combined sewer system?
rn ❑ Yes ❑✓ No 4SKIP to Section 6.
5.2 Have you attached a CSO system map to this application?(See instructions for map requirements.)
a ❑ Yes ElNo
5.3 Have you attached a CSO system diagram to this application?(See instructions for diagram requirements.)
cn
❑ Yes ❑ No
EPA Form 3510-2A(Revised 3-19) Page 10

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19
NC0025453 Neuse River Water Reclamation OMB No.2040-0004
5.4 For each CSO outfall,provide the following information. (Attach additional sheets as necessary.)
CSO Outfall Number CSO Outfall Number CSO Outfall Number
City or town
0 —
State and ZIP code
o County
Latitude
0 °
o °
cn Longitude ° °
o
Distance from shore ft. ft. ft.
Depth below surface ft. ft. ft.
5.5 Did the POTW monitor any of the following items in the past year for its CSO outfalls?
CSO Outfall Number CSO Outfall Number CSO Outfall Number
Rainfall 0 Yes 0 No 0 Yes 0 No 0 Yes 0 No
0)
c
o CSO flow volume 0 Yes 0 No 0 Yes 0 No 0 Yes 0 No
CSO pollutant 0 Yes 0 No 0 Yes 0 No 0 Yes 0 No
o concentrations
co
0 Receiving water quality 0 Yes 0 No 0 Yes ❑ No ❑ Yes ❑ No
CSO frequency 0 Yes 0 No ❑ Yes 0 No ❑ Yes 0 No
Number of storm events 0 Yes ❑ No ❑ Yes 0 No 0 Yes 0 No
5.6 Provide the following information for each of your CSO outfalls.
CSO Outfall Number CSO Outfall Number CSO Outfall Number
Number of CSO events in events events events
�, the past year
R .
a
c Average duration per hours hours hours
co event ❑Actual or 0 Estimated ❑Actual or❑Estimated ❑Actual or 0 Estimated
W million gallons million gallons million gallons
0 Average volume per event
0 0 Actual or 0 Estimated 0 Actual or 0 Estimated 0 Actual or 0 Estimated
Minimum rainfall causing inches of rainfall inches of rainfall inches of rainfall
a CSO event in last year ❑Actual or 0 Estimated ❑Actual or❑ Estimated ❑Actual or❑ Estimated
EPA Form 3510-2A(Revised 3-19) Page 11

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19
NC0025453 Neuse River Water Reclamation OMB No.2040-0004
5.7 Provide the information in the table below for each of your CSO outfalls.
CSO Outfall Number_ CSO Outfall Number CSO Outfall Number
Receiving water name
Name of watershed/
stream system
U.S.Soil Conservation 0 Unknown 0 Unknown 0 Unknown
1-4
Service 14-digit
c watershed code
> (if known)
Name of state
management/river basin
NU.S.Geological Survey 0 Unknown 0 Unknown 0 Unknown
8-Digit Hydrologic Unit
Code(if known)
Description of known
water quality impacts on
receiving stream by CSO
(see instructions for
exam des
SECTION 6.CHECKLIST AND CERTIFICATION STATEMENT(40 CFR 122.22(a)and(d))
6.1 In Column 1 below,mark the sections of Form 2A that you have completed and are submitting with your application. For
each section,specify in Column 2 any attachments that you are enclosing to alert the permitting authority.Note that not
all applicants are required to provide attachments.
Column 1 Column 2
❑ Section 1:Basic Application ❑ w/variance request(s) ❑ w/additional attachments
Information for All Applicants
Section 2:Additional w/topographic map ✓❑ w/process flow diagram
Information ❑✓ w/additional attachments
❑✓ w/Table A ❑ w/Table D
❑ Section 3:Information on ❑ w/Table B ❑ w/Table E
Effluent Discharges
Q w/Table C ❑✓ w/additional attachments
Section 4: Industrial ❑ w/SIU and NSCIU attachments ❑✓ w/Table F
❑✓ Discharges and Hazardous
Wastes ❑ w/additional attachments
Section 5:Combined Sewer ❑ w/CSO map ❑ w/additional attachments
Overflows ❑ w/CSO system diagram
❑ Section 6:Checklist and ❑ w/attachments
Certification Statement
Y 6.2 Certification Statement
cp
, /certify under penalty of law that this document and all attachments were prepared under my direction or supervision in
c. accordance with a system designed to assure that qualified personnel properly gather and evaluate the information
submitted. Based on my inquiry of the person or persons who manage the system,or those persons directly responsible
for gathering the information,the information submitted is, to the best of my knowledge and belief,true,accurate,and
complete.I am aware that there are significant penalties for submitting false information,including the possibility of fine
and imprisonment for knowing violations.
Name(print or type first and last name) Official title
Richard . Carr)a-34( PuNic 0
Signature Date signed
9/q
`EPA Form 3510-2A(Revised 3-19) Page 12

EPA Identification Number NPDES Permit Number Facility Name Outfall Number Form Approved 03/05/19
NC0025453 Neuse River Water Reclamation 001 OMB No.2040-0004
TABLE A. EFFLUENT PARAMETERS FOR ALL POTWS
Maximum Daily Discharge Average Daily Discharge Analytical ML or MDL
Pollutant Number of Methods (include
Value Units Value Units Samples units)
Biochemical oxygen demand
o ML
o BODs or 0 CBOD5 19.5 mg/L 2.6 mg/L 470 5M5210 B-2001 2 mg/L ❑MDL
(report one)
o ML
Fecal coliform 1600 #100mL 12 #100mL 465 SM9222-D 1#100mL ❑MDL
Design flow rate 5.820 mgd 1.608 mgd 1613
pH(minimum) 8.8 s.u.
pH(maximum) 6.6 s.u.
Temperature(winter) 23 degrees C 17 degrees C 465
Temperature(summer) 30 degrees C 24 degrees C 642
0 ML
Total suspended solids(TSS) 48.6 mg/L 3.1 mg/L 460 SM2540 D 2.5 mg/L ❑MDL
1 Sampling shall be conducted according to sufficiently sensitive test procedures(i.e.,methods)approved under 40 CFR 136 for the analysis of pollutants or pollutant parameters or
required under 40 CFR chapter I,subchapter N or 0.See instructions and 40 CFR 122.21(e)(3).
EPA Form 3510-2A(Revised 3-19) Page 13

EPA Identification Number NPDES Permit Number Facility Name Outfall Number Form Approved 03/05119
NC0025453 Neuse River Water Reclamation 001 OMB No.2040-0004
TABLE B. EFFLUENT PARAMETERS FOR ALL POTWS WITH A FLOW EQUAL TO OR GREATER THAN 0.1 MGD
Maximum Daily Discharge Average Daily Discharge Analytical ML or MDL
Pollutant Number of Method' include units
Value Units Value Units Samples Method' (
)
ip ML
Ammonia(as N) 6.44 mg/L 0.34 mg/L 486 sm44500NH3-D 0.1 mg/L ❑MDL
Chlorine n/a n/a n/a n/a n/a n/a n/a ❑ML
(total residual,TRC)2o ML
El MDL
Dissolved oxygen 9.82 mg/L 7.71 mg/L 1105 Hach10360-2011 LD( 0.2 mg/L 0 MDL
0 ML
Nitrate/nitrite 11.24 mg/L 2.68 mg/L 258 sm4500NO3-E 0.05 mg/L ❑MDL
0 ML
Kjeldahl nitrogen 11.50 mg/L 1.33 mg/L 219 SM4500Norg-B 0.2 mg/L 0 MDL
0 ML
Oil and grease 5 mg/L 5 mg/L 3 sm1664B 5 mg/L 0 MDL
0 ML
Phosphorus 6.53 mg/L 1.16 mg/L 273 sm4500P-B/E 0.05 mg/L 0 MDL
0 ML
Total dissolved solids 417 mg/L 350 mg/L 3 5m2540c-11 10 mg/L 0 MDL
1 Sampling shall be conducted according to sufficiently sensitive test procedures(i.e.,methods)approved under 40 CFR 136 for the analysis of pollutants or pollutant parameters or
required under 40 CFR chapter I,subchapter N or O. See instructions and 40 CFR 122.21(e)(3).
2 Facilities that do not use chlorine for disinfection,do not use chlorine elsewhere in the treatment process,and have no reasonable potential to discharge chlorine in their effluent are not
required to report data for chlorine.
EPA Form 3510-2A(Revised 3-19) Page 15

EPA Identification Number NPDES Permit Number Facility Name Outfall Number Form Approved 03/05/19
NC0025453 Neuse River Water Reclamation 001 OMB No.2040-0004
TABLE C. EFFLUENT PARAMETERS FOR SELECTED POTWS
Maximum Daily Discharge Average Daily Discharge Analytical ML or MDL
Pollutant Number of Methods (include units)
Value Units Value Units Samples
Metals,Cyanide,and Total Phenols
0 ML
Hardness(as CaCO3) 91 mg/L 76.3 mg/L 3 sm2340C-11 1 mg/1- 0 MDL
0 ML
Antimony,total recoverable 3 µg/L 3 µg/L 3 EPA200 3 µg/L 0 MDL
Arsenic,total recoverable 5 µg/L 4.3 µg/L 3 EPA200 3 µg/L ❑ML
m MDL
0 ML
Beryllium,total recoverable 1 µg/L 1 µg/L 3 EPA200 1 µg/L m MDL
ML
Cadmium,total recoverable 1 µg/L 0.8 µg/L 3 EPA200 0.5 µg/L m MDL
0 ML
Chromium,total recoverable 5 µg/L 4 µg/L 3 EPA200 2 µg/L m MDL
ML
Copper,total recoverable 10 µg/L 7.7 µg/L 3 EPA200 3 µg/L 0 MDL
0 ML
Lead,total recoverable 5 µg/L 4 µg/L 3 EPA200 2 µg/L ©MDL
0 ML
Mercury,total recoverable 10 µg/L 3.3 µg/L 4 EPA1631E 1 µg/L p MDL
ML
Nickel,total recoverable 10 µg/L 8.3 µg/L 3 EPA200 5 µg/L m MDL
ML
Selenium,total recoverable 10 µg/L 10 µg/L 3 EPA200 10 µg/L p MDL
0 ML
Silver,total recoverable 5 µg/L 3.7 µg/L 3 EPA200 1 µg/L m MDL
0 ML
Thallium,total recoverable 1 µg/L 1 µg/L 3 EPA200 1 µg/L m MDL
ML
Zinc,total recoverable 122 µg/L 102 µg/L 3 EPA200 10 µg/L ©MDL
Cyanide 0.005 mg/L 0.005 mg/L 3 sm4500CNE-11 0.005 m DO
ML
Y g ❑MDL
0 ML
Total phenolic compounds 5 µg/L 5 µg/L 3 EPA420.1-78 5 µg/L p MDL
Volatile Organic Compounds
Acrolein 100 µg/L ML
100 µg/L 3 EPA624.1 100 µg/L 0 MDL
0 ML
Acrylonitrile 50 µg/L 50 µg/L 3 EPA624.1 50 µg/L 0 MDL
0 ML
Benzene 5 µg/L 5 µg/L 3 EPA624.1 5 µg/L ❑MDL
0 ML
Bromoform 5 µg/L 5 µg/L 3 EPA624.1 5 µg/L ❑MDL
EPA Form 3510-2A(Revised 3-19) Page 17

EPA Identification Number NPDES Permit Number Facility Name Outfall Number Form Approved 03/05/19
NC0025453 Neuse River Water Reclamation 001 OMB No.2040-0004
TABLE C. EFFLUENT PARAMETERS FOR SELECTED POTWS
Maximum Daily Discharge Average Daily Discharge Analytical ML or MDL
Pollutant Number of Method1 (include units)
Value Units Value Units Samples
ML
Carbon tetrachloride 5 µg/L 5 µg/L 3 EPA624.1 5 µg/L p MDL
ML
Chlorobenzene 5 µg/L 5 HA3 EPA624.1 5 µg/L ©MDL
Chlorodibromomethane 5 µg/L 5 µg/L 3 EPA624.1 5 µg/L 0 ML
©MDL
Chloroethane 10 µg/L 10 µg/L 3 EPA624.1 10 µg/L ❑ML
©MDL
0 ML
2-chloroethylvinyl ether 5 µg/L 5 µg/L 3 EPA624.1 5 µg/L 0 MDL
0 ML
Chloroform 8.2 µg/L 6.1 µg/L 3 EPA624.1 5 µg/L ❑O MDL
0 ML
Dichlorobromomethane 5 µg/L 5 µg/L 3 EPA624.1 5 µg/L 0 MDL
0 ML
1,1-dichloroethane 5 µg/L 5 µg/L 3 EPA624.1 5 µg/L 0 MDL
ML
1,2-dichloroethane 5 µg/L 5 µg/L 3 EPA624.1 5 µg/L ©MDL
0 ML
trans-1,2-dichloroethylene 5 µg/L 5 µg/L 3 EPA624.1 5 µg/L 0 MDL
0 ML
1,1-dichloroethylene 5 µg/L 5 µg/L 3 EPA624.1 5 µg/L O MDL
0 ML
1.2-dichloropropane 5 µg/L 5 µg/L 3 EPA624.1 5 µg/L ❑O MDL
ML
1,3-dichloropropylene 5 µg/L 5 µg/L 3 EPA624.1 5 µg/L 0 MDL
ML
Ethylbenzene 5 µg/L 5 µg/L 3 EPA624.1 5 µg/L ©MDL
0 ML
Methyl bromide 10 µg/L 10 µg/L 3 EPA624.1 10 µg/L 0 MDL
0 ML
Methyl chloride 10 µg/L 10 µg/L 3 EPA624.1 10 µg/L 0 MDL
0 ML
Methylene chloride 10 µg/L 10 µg/L 3 EPA624.1 10 µg/L 0 MDL
0 ML
1,1,2,2-tetrachloroethane 5 µg/L 5 µg/L 3 EPA624.1 5 µg/L 0 MDL
0 ML
Tetrachloroethylene 5 µg/L 5 µg/L 3 EPA624.1 5 µg/L 0 MDL
0 ML
Toluene 5 µg/L 5 µg/L 3 EPA624.1 5 µg/L 0 MDL
0 ML
1,1,1-trichloroethane 5 µg/L 5 µg/L 3 EPA624.1 5 µg/L 0 MDL
0 ML
1,1,2-trichloroethane 5 µg/L 5 µg/L 3 EPA624.1 5 µg/L ❑MDL
EPA Form 3510-2A(Revised 3-19) Page 18
I i

EPA Identification Number NPDES Permit Number Facility Name Outfall Number Form Approved 03/05/19
NC0025453 Neuse River Water Reclamation 001 OMB No.2040-0004
TABLE C.EFFLUENT PARAMETERS FOR SELECTED POTWS
Maximum Daily Discharge Average Daily Discharge Analytical ML or MDL
Pollutant Value Units Value Units Number of Method' (include units)
Samples
ML
Trichloroethylene 5 µg/L 5 µg/L 3 EPA624.1 5 µg/L 0 MDL
ID ML
Vinyl chloride 10 µg/L 10 µg/L 3 EPA624.1 10 µg/L m MDL
Acid-Extractable Compounds
o ML
p-chloro-m-cresol 20 µg/L 20 µg/L 3 EPA625.1 20 µg/L ©MDL
ML
2-chlorophenol 10 µg/L 10 µg/L 3 EPA625.1 10 µg/L 0 MDL
O ML
2,4-dichlorophenol 10 µg/L 10 µg/L 3 EPA625.1 10 µg/L ❑O MDL
OML
2,4-dimethylphenol 10 µg/L 10 µg/L 3 EPA625.1 10 µg/L m MDL
0 ML
4,6-dinitro-o-cresol 50 µg/L 50 µg/L 3 EPA625.1 50 gel- m MDL
2,4-dinitrophenol 50 µg/L 50 µg/L 3 EPA625.1 50 µg/L 0 MDL
0 ML
2-nitrophenol 10 µg/L 10 µg/L 3 EPA625.1 10 µg/L O MDL
O ML
4-nitrophenol 50 µg/L 50 µg/L 3 EPA625.1 50 µg/L MDL
0 ML
Pentachlorophenol 50 µg/L 50 µg/L 3 EPA625.1 50 µg/L O MDL
O ML
Phenol 10 µg/L 10 µg/L 3 EPA625.1 10 µg/L m MDL
0 ML
2,4,6-trichlorophenol 10 µg/L 10 µg/L 3 EPA625.1 10 µg/L m MDL
Base-Neutral Compounds
o ML
Acenaphthene 10 µg/L 10 µg/L 3 EPA625.1 10 µg/L m MDL
O ML
Acenaphthylene 10 µg/L 10 µg/L 3 EPA625.1 10 µg/L ❑O MDL
0 ML
Anthracene 10 µg/L 10 µg/L 3 EPA625.1 10 µg/L m MDL
0 ML
Benzidine 100 µg/L 100 µg/L 3 EPA625.1 100 µg/L m MDL
ML
Benzo(a)anthracene 10 µg/L 10 µg/L 3 EPA625.1 10 µg/L 0 MDL
0 ML
Benzo(a)pyrene 10 µg/L 10 µg/L 3 EPA625.1 10 µg/L O MDL
ML
3,4-benzofluoranthene 10 µg/L 10 µg/L 3 EPA625.1 10 µg/L 0 MDL
EPA Form 3510-2A(Revised 3-19) Page 19

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EPA Identification Number NPDES Permit Number Facility Name Outfall Number Form Approved 03/05/19
NC0025453 Neuse River Water Reclamation 001 OMB No.2040-0004
TABLE C. EFFLUENT PARAMETERS FOR SELECTED POTWS
Maximum Daily Discharge Average Daily Discharge Analytical ML or MDL
Pollutant Value Units Value Units Number of Method, (include units)
Samples
0 ML
1,2-diphenylhydrazine 10 µg/L 10 µg/L 3 EPA625.1 10 µg/L ❑MDL
ML
Fluoranthene 10 µg/L 10 µg/L 3 EPA625.1 10 µg/L 0 MDL
ML
Fluorene 10 µg/L 10 µg/L 3 EPA625.1 10 µg/L 0 MDL
ML
Hexachlorobenzene 10 µg/L 10 µg/L 3 EPA625.1 10 µg/L El MDL
ML
Hexachlorobutadiene 10 µg/L 10 µg/L 3 EPA625.1 10 µg/L 0 MDL
ML I
Hexachlorocyclo-pentadiene 10 µg/L 10 µg/L 3 EPA625.1 10 µg/L 0 MDL
I ML
Hexachloroethane 10 µg/L 10 µg/L 3 EPA625.1 10 µg/L 0 MDL
0 ML
Indeno(1,2,3-cd)pyrene 10 µg/L 10 µg/L 3 EPA625.1 10 µg/L 0 MDL
0 ML
Isophorone 10 µg/L 10 µg/L 3 EPA625.1 10 µg/L m MDL
ML
Naphthalene 10 µg/L 10 µg/L 3 EPA625.1 10 µg/L 0 MDL
ML
Nitrobenzene 10 µg/L 10 µg/L 3 EPA625.1 10 µg/L El MDL
ML
N-nitrosodi-n-propylamine 10 µg/L 10 µg/L 3 EPA625.1 10 µg/L m MDL
0 ML
N-nitrosodimethylamine 10 µg/L 10 µg/L 3 EPA625.1 10 µg/L m MDL
ML
N-nitrosodiphenylamine 10 µg/L 10 µg/L 3 EPA625.1 10 µg/L 0 MDL
0 ML
Phenanthrene 10 µg/L 10 µg/L 3 EPA625.1 10 µg/L 0 MDL
ML
Pyrene 10 µg/L 10 µg/L 3 EPA625.1 10 µg/L 0 MDL
ML
1,2,4-trichlorobenzene 10 µg/L 10 µg/L 3 EPA625.1 10 µg/L 0 MDL
1 Sampling shall be conducted according to sufficiently sensitive test procedures(i.e.,methods)approved under 40 CFR 136 for the analysis of pollutants or pollutant parameters or
required under 40 CFR Chapter I,Subchapter N or 0.See instructions and 40 CFR 122.21(e)(3).
EPA Form 3510-2A(Revised 3-19) Page 21

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19
NC0025453 Neuse River Water Reclamation OMB No.2040-0004
TABLE F.INDUSTRIAL DISCHARGE INFORMATION
Response space is provided for three Sills.Copy the table to report information for additional SIUs.
SIU 003 SIU 004 SIU 001
Name of SIU
Novo Nordisk Pharmaceuticals,Inc.(DFP) Novo Nordisk Pharmaceuticals,Inc.(DAPI) Grifols Therapeutics,Inc.
Mailing address(street or P.O.box) 1612 Powhatan Road 1613 Powhatan Road 8368 US Highway 70 Business West
City,state,and ZIP code Clayton,NC 27527 Clayton,NC 27527 Clayton,NC 27520
Description of all industrial processes that affect
or contribute to the discharge. Packaging of sterile insulin products for Fermentation of yeast to produce protein Biological healthcare therapeutics
human diabetic therapy.Ultra pure water based insulin related products. produced from the pooling,coagulation,
treatment and sterile cleaning. Facility is expected to be in full production fractionation,dissolving and filtering of
by June 2021.Currently in partial blood plasma.
operation.
List the principal products and raw materials that
affect or contribute to the SIU's discharge. Crystallized Insulin,Water purification and Yeast,solvents,bases,acids and nitrogen Blood plasma,solvents,bases,acids,
sterile cleaning chemicals. compounds.Water purification and sterile nutrients.Water purification and sterile
cleaning chemicals. cleaning chemicals.
Indicate the average daily volume of wastewater
discharged by the SIU. 112,020 gpd est.500,000 gpd est.925,000 gpd
How much of the average daily volume is
attributable to process flow? 67,700 gpd est.250,000 gpd est.612,000 gpd
How much of the average daily volume is
attributable to non-process flow? 44,320 gpd est.250,000 gpd est.313,000 gpd
Is the SIU subject to local limits?
❑✓ Yes ❑ No ❑✓ Yes 0 No ✓❑ Yes ❑ No
Is the SIU subject to categorical standards?
❑✓ Yes 0 No ElYes 0 No ❑✓ Yes 0 No
EPA Form 3510-2A(Revised 3-19) Page 29

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19
NC0025453 Neuse River Water Reclamation OMB No.2040-0004
TABLE F. INDUSTRIAL DISCHARGE INFORMATION
Response space is provided for three SIUs.Copy the table to report information for additional Skis.
SIU 003 SIU 004 SIU 001
Under what categories and subcategories is the
SIU Subject? Pharmaceutical Manufacturing(439.46) Pharmaceutical Manufacturing(439.17) Pharmaceutical Manufacturing(439.27)
Has the POTW experienced problems(e.g.,
upsets,pass-through interferences)in the past 4.5 ❑ Yes ❑✓ No ❑ Yes El No ❑ Yes ❑✓ No
years that are attributable to the SIU?
If yes,describe.
EPA Form 3510-2A(Revised 3-19) Page 30

Attachments
Attachment A: Topographic Map
Attachment B: Process Flow Diagram
Attachment C: Treatment Facility Processes and Equipment
Attachment D: WET Testing Laboratory Results
Attachment E: International Paper Company Nitrogen Allocations Purchase Agreement
Attachment F: NPDES Permit NC0025453, Little Creek WRF in Johnston County (current draft)
Attachment G: Engineering Report

This page intentionally left blank.

Attachment A
Topographic Map

This page intentionally left blank.

78°27'0"W 78°26'0"W 78°25'0"W
•
`9- Fii
•14 13 � Filters
O O � 12 PoDisste rats
15 13 Post-Aeration&Pan[Water Pump Station
/ 14 RAS/WAS
‘‘ 4/ 15 Gravity Belt Thickner Building&Electrical
16 11 12 / 16 Centrifuge Building Dig 17 Aerobic esters
10 18 7 ,
18 Outfall Splitter Box
Neuse 2/Clayton to Raleigh
Pump Stations
15`40'0"N— -._ - -- — --_._._ -- -__ - —35°40'0"N
�............_ \ WRF Outfall
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. .. /Jr __ ._. --- 35°39'0"N
Service Layer Credits:USGS The National Map:National�iundaries Dataset,3DEP Elevati n Program,Geographic Names Information System,National
Hydrography Dataset,National Lanc Cover Database,National Strt�tures Dataset,and National Tra sportation Dataset;USGS Global Ecosystems;U.S.Census
Bureau TIGERILine data;USFS Road Data;Natural Earth f ta;U.S.Department of State H manitarian Information Unit,and NOAA National Centers for
♦ Environmental Information,U.S Coastal Relief Model Data refreshed May,2020
i I 1 1
78°27'0"W 78°26'0"W 78°25'0"W
Legend Topographic Map
--- New Force Main ----- Existing Force Main N 0 1,500 3,000 Water Reclamation Facility Expansion
--- New Gravity Main Existing Gravity MainA I I I Town of Clayton, NC
Plant Footprint E 1 Parcel Boundary Feet

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Attachment B
Process Flow Diagram

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1 2 I 3 I 4 5 I 6
GENERAL SHEET NOTES
1. SAMPLE POINT REFER TO BOTH INFLUENT AND rc
EFFLUENT SAMPLES THAT WILL BE PROVIDED IN w
FLOW BALANCE TABLE:
ACCORDANCE WITH NC DEQ REQUIREMENTS. w
a,
re
Phase 1,ADF Phase 1,MMADF Phase 1,Peak Day Phase 1,PHF
LEGEND (MGD) (MGD) , (MGD) (MGD) oi
RS 5.25 6.00 _ 9.70 11.20 R
ALP AIR LOW PRESSURE 5R5 5.25 6.00 _ 9.70 11.20 m
0
A BWW BACKWASH WASTE EQ 5.25 6.00 9.70 9.70 0 Lu a
BYP BYPASS MI. 9.79 11.65 - 17.54 17.54 Q Z 9
DEC DECANT
SE 5.34 6.08 9.78 9.78 Q
DR
DC DEWIATERED CAKE FE 5.25 5.99 9.69 9.69 CO 82
DG DEWATERED GRIT UVE/PLE 5.25 5.99 - 9.69 9.69
EQ EQUALIZATION TO ODOR NRCY 22.36 23.28 - 40.08 40.08
FE FILTER EFFLUENT CONTROL
GS GRIT SLURRY RAS 4.20 4.99 7.53 7.53 p
M FLOW METER WAS 0.26 0.57 _ 0.57 0.57 a o
ML MIXED LIQUOR Filtrate 0.02 0.03 _ 0.03 0.03 <
NRCY NITRIFIED RECYCLE Q BWW 0.09 0.09 0.09 0.09 y
OA ODOROUS AIR O p a o
PLE PLANT EFFLUENT / - Y w
RAS RETURN ACTIVATED SLUDGE \ / O,o
RS RAW SEWAGE w m
SCR SCREENINGS - 0 4,--
SE SECONDARY EFFLUENT
SRS SCREENED RAW SEWAGE �'EQUALIZATION IQ z
O le ho
SSM SECONDARY SCUM 2 _
TWAS THICKENED WASTE ACTIVATED SLUDGE O is
WAS WASTE ACTIVATED SLUDGE s ` ' SQTATION PUMP oG PE y.
W3 REUSE WATER
UVE UV EFFLUENT I o
SRS 111, EQ
BWW Ig of
PROCESS TO DR
TO ODOR TO ODOR BIOREACTORS A TO <'LI i
CONTROL CONTROL PLANT SAMPLE 'a;
a a
USE POINT
0O ZU
< <
B SAMPLE ; OPTIONAL OPTIONAL m 1 a3
DR < POINT < FERRIC FERRIC rc
is
TO ODOR O : O SECONDARY ZI
CONTROL CLARIFICATION e o
ANAEROBIC ANOXIC AEROBIC POST-ANOXIC REAERATION F oo
RS RS MECHANICAL GRIT SRS BYP ZONE ZONE ZONE ZONE ZONE SE FE o
< DISC UV UVE POST PLE PLE ,/ TO NEUSE o$
O M SCREENS REMOVAL �� FILTERS ���DISINFECTION m I� AERATION K. RIVER z
iN g
O zz
FROM m
PLANT�� I2 U 08 N m g
INFLUENT y O w �q o0
0
INFLUENTV NRCY LL
in o o az
PUMP STATION \
/ \
/ . 1n Z w to Sw
OPTIONAL OPTIONAL Z o�i co W Z z S
w CARBON CARBON Z Z
TO DISPOSAL TO DISPOSAL g <o,IX 7 0 E rOr D a"
O;LL2 o. T Y
m <o
o�xc¢�¢� g z g
N LL?i U _m O jo
_ 9-Z O O O cnm,al <
p oi2Z U Et4$
<mU6
Zwzz
C ZZO7, 2
ti)I oaQ� I
FILTRATE FILTRATE C.) O o
F U
RAS/WAS TO DR TO DR F x m
PUMP STATION y oO it a
I- 1n F Z z
_f
WRF BACKUP POWER FLOW DIAGRAM
w� WAS ROTARY
DRUM � AERATED BIOSOLIDS
DEWA SCREW
DC , TO LANDFILL • a Q_
THICKENERS SLUDGE PRESSES COMPOSTING o
-
HOLDING
J TANK
1. or O
z -1O 1. • o i
0 LL
FROM AUTOMATIC TO WRF POWER <a.
En
En
UTILITY � TRANSFER � DISTRIBUTION T t
w W
POWER SWITCH SYSTEM TO ODOR TO ODOR TO ODOR 0 0
CONTROL CONTROL CONTROL 0 YQ
ce
FROM BACKUP a Q
DIESEL r CL
D GENERATOR(S)
11
ce
a
VERIFY SCALE J_
BAR IS ONE INCH ON 0
ORIGINAL DRAWING. m
0-1'
DATE JULY 2020 Z
PROJ 03301502 0
DWG 001-G-1010 w
SHEET of a
• $PWURL $PWPATH FILENAME 001-G-1010_D3301502.dgn PLOT DATE:2020\08110 PLOT TIME: 12:03:22 PM

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1
„ ,
Attachment C
Treatment Facility Processes
and Equipment

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Treatment Facility Primary Equipment, by Process
Component Quantity/Description
Influent Pumping
Pumps 2 duty/1 standby, submersible
Backup Pumps 2, dry-prime diesel
Headworks
Septage Receiving quick-connect nozzles
Screens 1 duty/1 standby, inclined cylindrical with
integral washer/compactors
Bypass Channel 1, with manual bar screen
Grit Removal 2, stacked tray
Flow Equalization
Tanks 2, 90 foot diameter
Pumps 4 duty/1 standby, submersible
Secondary Treatment
Bioreactor 5-Stage Bardenpho
Basins 3, 2.45 MG each
Secondary Clarifiers 3, circular
RAS Pumps 3 duty/1 standby, horizontal centrifugal
non-clog with VFD
WAS Pumps 3 duty/1 standby, horizontal centrifugal
non-clog with VFD
Aeration Blowers 2 duty/1 standby, high-speed turbo
Tertiary Filtration
Filters 2 duty/1 standby, cloth disc
Disinfection
2, open channel low-pressure, high-output
Trains
(LPHO) UV(ultraviolet)
Post-Aeration
Trains 2, cascade aeration
Solids Treatment
Thickening Units 2 duty/1 standby, rotary drum

SECTION ERROR!NO TEXT OF SPECIFIED STYLE IN DOCUMENT.-ERRORI NO TEXT OF SPECIFIED STYLE IN DOCUMENT.
Sludge Holding Tank 625,000 gallon capacity, with ceramic
coarse bubble diffusers
Dewatering Units 1 duty/1 standby, screw press
Chemical Systems
Metal Salt Tanks 2, fiber-reinforced plastic
Metal Salt Pumps 3 duty/1 standby, peristaltic
Supplemental Carbon Tanks 2,fiber-reinforced plastic
Supplemental Carbon Pumps 3 duty/1 standby, peristaltic
Odor Control
Type biotrickling filter or bioscrubber
Effluent Outfall
Receiving waters Upper Neuse River

Attachment D
WET Test Laboratory Reports

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TOWN OF CLAYTON
OPERATIONS CENTER .E .%;IRONMENT..
i .1� !_ 11=„ YCRI [C WORKS
1/42* r)ly,i57-l :fi
EFth'. is. i 1 Y�C?/ \\.ATER RECLAMATION
March 24, 2020
Water Science Branch
Aquatic Toxicity Branch
DWR
1621 Mail Service Center
Raleigh, NC 27699-1623
Re: Toxicity Results: NPDES#NC0025453
To Whom It May Concern:
Enclosed please find the Ceriodaphnia Pass' Fail results for the Little Creek Water
Reclamation Facility.
Please call me directly at 919-553-1536 if you have any questions.
Sincerely,
James Warren, ORC
Town of Clayton, NC
653 Hiehwely 3_Wes!t•P.O.Box 879•Clayton.tio.th Carolina 27520•[phone]•l-ax 919j 5,53-1341

Effluent Toxicity Report Form - Chronic Pass/Fail and Acute LC50 Date: 03/12/20
Facility: CLAYTON WWTP NPDES#: NC0025453 Pipe#: 001 County: JOHNSTON
Laboratory Performing ,Test: MERITECH LABS, INC.
Comments:
X 4,,,f Lam/ 1.214..)e A-th,-)
S ture of �
Operator in Responsible Charge
Signature of Labora ory Supervisor * PASSED: -5.51% Reduction *
Work Order: Environmental Sciences Branch
MAIL ORIGINAL TO: Div. of Water Quality
N.C. DENR
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
North Carolina Ceriodaphnia
Chronic Pass/Fail Reproduction Toxicity Test Chronic Test Results
Calculated t = -1.711
Tabular t = 2.508
CONTROL ORGANISMS 1 2 3 4 5 6 7 8 9 10 11 12 % Reduction = -5.51
Mortality Avg.Reprod.
# Young Produced 20 20 18 20 19 18 21 20122 21 19 18
0.00 19.67
Control Control
Adult (L) ive (D)ead L L L L L L L L L L L L
i i ' 0.00 20.75
Treatment 2 Treatment 2
Effluent %: 2.0%
TREATMENT 2 ORGANISMS 1 2 3 4 5 6 7 8 9 10 11 12 Control CV
6.624% i PASS FAIL
r�
# Young Produced 20121 18 19 21 20 23 22 18j22 23 22 % control orgs
rX
j producing 3rd
1 1 brood Check One
Adult (L)ive (D)ead L !L L L L L L L L IL IL L 100%
1st sample 1st sample 2nd sample Complete This For Either Test
pH Test Start Date: 03/04/20
Control 8.15 7.74 7.6717.75 Collection (Start) Date
Sample 1: 03/02/20 Sample 2: 03/04/20
Treatment 2 7.81 � 7.86 ,7.81 7.6917.86 Sample Type/Duration 2nd
1st P/F
s s s Grab Comp. 1Duration D
t e t e t e I S S
a n a n a n Sample 1 X 24.0 hrs L A A
✓ d r d r d U M M
t t t Sample 2 X 23 .8 hrs T P P
1st sample 1st sample 2nd sample
D.O. Hardness(mg/1) 42
Control 7.87 7.80' 7.68 7.98 7.17
®
Spec. Cond. (pmhos) 134 485 520
Treatment 2 7.87 7.34 7.7617.74 8.04 7.21 .
Chlorine(mg/1) <0.1 <0.1
LC50/Acute Toxicity Test Sample temp. at receipt(°C) , 2.6 3.4
(Mortality expressed as %, combining replicates) I
% o %�, % % % % Note:e Please
% % Concentration Complete This
Section Also
% % % % % % t t % % Mortality
start/end start/end
LC50 = % Method of Determination Control I
95% Confidence Limits Moving Average Probit
% -- % Spearman Karber = Other — High
- ' Conc.
pH D.O.
Organism Tested: Ceriodaphnia dubia Duration(hrs) :
Copied from DWQ form AT-1 (3/87) rev. 11/95 (DUBIA ver. 4.41)

Meritech, Inc. (Lab # 027)
// Mini Chronic Pass/Fail Test: Ceriodaphnia dubia Incubator#:
Client: ILb f-' r Pipe#: col County: , )(vv. .f 2-)j j Date Start: )�.Li - , ' Date End: ?. 1/-;?.6
NPDES#: NCk 2_SyCj j Date/Time of Culture Transfer:7 .21 /L1 7t.)4f' Time Start: / it)/p- Time End: Cr �, 11�
Dilution Water: Lake Brandt Date/Time Neonates born: 4 /i) > .,-`" - n / '5� „�L��M 1st Renewal Date: 3 s c , Time: (rot// �,., ��
Test Organism Source: Tray# t, Age of onates at Test Start.;)-0,, ' -1" hours 2nd Renewal Date: a' A` Time: `)"q .� ,�,,
Stirred /Aerated for D.O.: Y / NJ Randomized: Ye/ N Culture Tray Temp: '},'-(• °C Analyst(s): MR,CD,LV,KS Reviewed by: Y`�
Control Organism Reproduction Collection (Start) Dates:
Day#2 1 2 3 4 5 6 7 8 9 10 11 12 -}
#Young Produced 0 0 0 0 0 0 0 0 _ 0 0 0 0 Sample 1: ,�; Sample 2: �' �{��)
Adults Live/Dead L_- L L. L L - L_ L-- L. L- L. L. L Sample Information
Day#5 1 2 3 4 5 6 7 8 9 10 11 12 100% pH G /C? Duration
#Young Produced jj1' - /-? I//9. 11/-i L1/7 /:! ?/7 11//_ (1):,7 ;'[? 1//.7 ./ 4 Sample 1 7; 7'I C... L-,/,r- ) hours
Adults Live/Dead / ,_1:. / L- 4. - I-- ,;_ Z. L- ;,,� Sample 2 7 '/ .: '� N� hours
Day#7 1 2 3 4 5 6 7 8 9 10 11 22 Transferred by: Fed
#Young Produced 2 / Si `-- b ? H H ?� _j C i c ;, ' ,� Batch# '_l��/ /7/�� Sample 1 Sample 2 Day 0 O t
Adults Live/Dead L t- L- L L L. L L k 1--- i' Transfer Day 0( 2 y//5 Day 1 (_
—
Hardness 1 7 Day 2 /11Z L
(mg/L) `�,I .9
�Total Produced , C ,`�C) ( st; , +I 'S 1 ) :2 2 \ I`1 I ,7 Da 3 �y
Spec.Cond. y —
% 1'(umhos/cm) ,� / <185- •_(?: Day 4
Percent of Control producing third brood: Chlorine y/r( [ ,1 Day 5 �� L
(mg/L)Test Sample Organism Reproduction Day 6 L
Receipt Sample /7 / "')
Temp.1°C) ..�•(r,; ,T,, Terminated by: /. L
Effluent%: 9,() i
pH 1st Sample 2nd Sample 2nd Sample
Day#2 1 2 3 4 5 6 7 8 9 10 11 12#Young Produced 0 0 0 0 0 0 0 0 0 0 0 0 Control /'t( G.7
74( 7 c 1 77c / (7 7 7S-
Adults Live/ Dead L___ L— L- L L- L_ L_ L L._ L- L_ L ' "7 / ' 4
Day#5 1 2 3 4 5 6 7 8 9 10 11 12 Sample !,(1 I (t/ (� 7 :,—( 7,$�
initial final initial final initial final
#Young Produced (J/;1 ��1 �� U1 ��� (��� IU�?
.4(� .2/I"' t/ �J lr" f
D.O. 1st Sample 2nd Sample 2nd Sample
I, , .0
Adults Live/Dead L t , � L '- `�-
f - �- ,I__ 1— Control 7` i 7 73.7 7„90 " ( iic 717
Day#7, 1 2 3 4 5 6 7 8 9 10 11 12
#Young Produced ( `�j ' � n
x i 1 1 I ) (G I o i /0 Sample O ,' t' l { 4��
L �- k-. L l_. l_
initial final initial final initial final
Adults Live/Dead 1. �- 1. L l.- L-
Temp. _ 1st Sample 2nd Sample 2nd Sample
Total Produced ,X-C) 1 ' 0 .).i �L+ ). j -2� (`b ) 1 17 j 'rl Control '%9 ,� x ,
,,, � : Vic) I i y. S ?,:�
)ments: p )n`it7 �
Sample may.7 ,(,� , 0 I,:)u.' 2+0.

MERITECH, INC. (Lab #027) ,
Meritech Sample ID#: � )
Bioassay Sample Chain of Custody
642 Tamco Rd, Reidsville NC 27320
Phone: [phone] Fax: [phone]
Toxicity Supervisor email: [e-mail] Web Site: www.meritechlabs.com
CLIENT) INFORMATION
Client: % 2 f l)/ /I2 O/ f J/G� �^✓ PO#:
/
Contact Person: (4), �/ G Si/1/ /)SE7-J NPDES#: NC ,,Z }y,s'3
Address: pL7 A'px. g7 Phone: q/5'- ,jJj"" /.5.r
City: (_/0.4 r9^> >/ Pipe#: UCi/
County:�,>/-1,JS IZ,,J State: ,4 V Zip: ,2 752
SAMPLE INFORMATION
Sample Site: [, fr/e, Gr-Le_lc- Li /5"
Sample Type: ❑Grab -�Composite #of containers: �-
Sampling Time: Start Date: 3 "2 J Z Start Time: / Q/,� 4110 PM
End Date: - 3 Z(� End Time: 0 1 PM
—Triple rinse sample container with sample before filling completely with NO AIR SPACE. Pack the sample cooler completely with ice. The
sample must be<0.6°C upone receipt at Meritech***
Collector's Name: Print: L)1 //1 C)r? s;/c16/9^✓ Signature: -11
TOXICITY TEST INFORMATION
Test Required: lAchronic(7 days) Test Organism: Zi,Ceriodaphnia dubia (water flea)
❑ Acute(24-48 hours) ❑ Pimephales promelas (fathead minnow)
❑ Mysidopsis bahia (mysid shrimp)
IWC: i 0 o "*Friday Samples for Chronic Fathead test must be collected after 9:00 a.m. on Friday"*
Comments:
SHIPPING INFORMATION
Relinquished Date: j % Time: 11.3c" r A PM
C
Received by: &�, / Date: 3 - 3 i3O Time: AM, PM
Relinquished by:L � Date: 1 3 ,.2) Time: f O 3 AM glIP
Received by: Date: Time: AM PM
Relinquished by: Date: Time: AM PM
Received by: Date: Time: AM PM
Relinquished by: Date: Time: AM PM
Received by: Date: Time: AM PM
Sample Temperature(°C):
Method of Shipment:❑ UPS ❑ Fed EX Meritech Pick-up ❑Delivered ❑ Other
..Samples shipped on Friday must be FedEx and must be clearly labeled for Saturday delivery, NO SIGNATURE REQUIRED '-
SAMPLE RECEIVING(Laboratory Use Only)
Relinquished by: -Cc, -
Received by: I ;uti, ,'•";,;ti Date: Time: ' AM PM
•
Sample Temperatures(°C): • / - / / Sample Condition:

•
MERITECH, INC. (Lab #027) Mentech Sample ID I: C -`r-' ,3 C l i
ABioassay Sample Chain of Custody
642 Tamco Rd,Reidsville NC 27320
Phone: [phone] Fax:[phone]
Toxicity Supervisor email: [e-mail] Web Site: www.meritechlabs.com_
CLIENT INFORMATION
Client: L.Ji /3 CEC l./72�� PO#:
Contact Person: f r 1� -6 i,-7/S f2� / NPDES#: NC&e`Z r4'5
Address: /30 S 7)e- Ct''7 Phone: J/J�' -5..2 �J 5fr
City: r e--L,vJ Ir),L2 �7Pipe#: (..)(,)/County: .5 2J ,tl C 7`1), J State: /� Zip: /S?�d
SAMPLE INFORMATION
C./, / �, r
Sample Site: Li tile.- .-f�,'./G
Sample Type: ❑Grab �eomposite #of containers:
Sampling Time: Start Date: 2 el 1-0 Start Time: //0-...- Q PM
End Date:3/5/2,0 End Time: ,/ S---- 40 PM
"'Triple rinse sample container with sample before filling completely with NO AIR SPACE.Pack the sample cooler completely with ice. The
sample must be<0.6°C upone receipt at Meritech"'
�,I /I ` ''
Collector's Name: Print: ! /et ���F�� Signature: '. �/-�`j�!/, ,-----
TOXICITY TEST INFORMATION
Test Required: Chronic(7 days) Test Organism: Ceriodaphnia dubia (water flea)
❑ Acute(24-48 hours) ❑ Pimephales promelas (fathead minnow)
E Mysidopsis bahia (mysid shrimp)
IWC: ',Q % "°Friday Samples for Chronic Fathead test must be collected after 9:00 a.m. on Friday"'
Comments:
SHIPPING INFORMATION
Relinquished by: _ .,-- Date: 3/ /7(2 Time: /2 O AM 40
Received by: Date: 3/S ,,2..e9 Time: /2-0 Z AM PM
Relinquished by: Dater IC Time: /`_:,( AM
Received by: Date: f Time: AM PM
Relinquished by: Date: Time: AM PM
Received by: Date: Time: AM PM
Relinquished by: Date: Time: AM PM
Received by: Date: Time: AM PM
Sample Temperature(°C):
Method of Shipment:❑ UPS E Fed EX ,Mentech Pick-up ❑Delivered ❑ Other
-Samples shipped on Friday must be FedEx and must be c.early labeled for Saturday delivery, NO SIGNATURE REQUIRED "
SAMPLE RECEIVING(Laboratory Use Only)
Relinquished by: f '
_ r,,�,
Received by: n., .,^.!} , Date: Time: AM PM
Sample Temperatures(°C): �'.` / / / Sample Condition:
%AILJITC — I -.1......4...... ........ N./CI I ntu— (s1:_..a ___..

Effluent Toxicity Statistical Results - Chronic Pass/Fail Date: 03/12/20
Facility: CLAYTON WWTP NPDES#: NC0025453 Pipe#: 001 County:JOHNSTON
Laboratory Performing Test: MERITECH LABS, INC.
Reduction: -5.51% CONTROL 2.0% Effluent
# Replicates 12 12
Female Live 12 12
Adult Male 0 0
Adult Dead 0 0
Adult Mortality 0.00% 0.00%
# Neonates 236 249
Mean # Neonates 19.667 20.750
Standard Deviation 1.303 1.765
Coefficient of Variation 6.624%
Fisher's Exact Test
A = 12 B = 12 a = 12 b = 12
a/A = 1.00 b/B = 1.00
Success is: survival
Critical b value = 8
12 > 8
The test concludes that the proportion of survival is not
significantly different for the control and the effluent groups.
Test Passes!
SHAPIRO-WILK'S TEST FOR NORMAL DISTRIBUTION OF DATA
ORDERED OBSERVATIONS
i Group Neonates Centered i Group Neonates Centered
1 E 18 -2.7500 13 C 20 0.3333
2 E 18 -2.7500 14 C 20 0.3333
3 E 19 -1.7500 15 C 20 0.3333
4 C 18 -1.6667 16 C 20 0.3333
5 C 18 -1.6667 17 E 22 1.2500
6 C 18 -1.6667 18 E 22 1.2500
7 E 20 -0.7500 19 E 22 1.2500
8 E 20 -0.7500 20 C 21 1.3333
9 C 19 -0.6667 21 C 21 1.3333
10 C 19 -0.6667 22 E 23 2.2500
11 E 21 0.2500 23 E 23 2.2500
12 E 21 0.2500 24 C 22 2.3333

SHAPIRO-WILK'S TEST FOR NORMAL DISTRIBUTION OF DATA (cont.)
COEFFICIENTS AND DIFFERENCES
i x(n-i-1) x(i) a(i) x(n-i-1) - x(i)
1 2.3333 -2.7500 0.4493 5.0833
2 2.2500 -2.7500 0.3098 5.0000
3 2.2500 -1.7500 0.2554 4.0000
4 1.3333 -1.6667 0.2145 3 .0000
5 1.3333 -1.6667 0.1807 3.0000
6 1.2500 -1.6667 0.1512 2.9167
7 1.2500 -0.7500 0.1245 2.0000
8 1.2500 -0.7500 0.0997 2.0000
9 0.3333 -0.6667 0.0764 1.0000
10 0.3333 -0.6667 0.0539 1.0000
11 0.3333 0.2500 0.0321 0.0833
12 0.3333 0.2500 0.0107 0.0833
1
W = X 49.8916
52.9167
Calculated W = 0.943 Critical W = 0.884
0.943 > 0.884
The reproduction data is normally distributed
evaluated at a 99% confidence interval.
Test Passes!
F test for Homogeneity of Variance
Effluent variance 3.1136
F = _ = 1.83
Control variance 1.6970
Numerator degrees of freedom: 11 Denominator degrees of freedom: 11
Critical F = 5.32
1.83 s 5.32 =► The Test PASSES, the variances of the two groups
are significantly the same, homogeneous.

EQUAL VARIANCE t TEST
19.7 - 20.8
t = _ -1.711
0.633
Degrees of freedom = 22
Critical t = 2.508
-1.711 < 2.508
Test passed. There is not a significant difference in reproduction
between the Control and the effluent evaluated at a 99% confidence interval.
Chronic Test PASSES

TOWN OF CLAYTON
"SERVICE" OPERATIONS CENTER -ENVIRONMENT-
ELECTRIC SERVICE .CAR° PLBLIC WORKS
(919;553-1530 �t t'`� [phone]
VEHICLE MAINTEN z,. iTO
� WATER RECLAMATION
i919)553-153i" [phone]
ii
June 25, 2020
Water Science Branch
Aquatic Toxicity
DWR
1621 Mail Service Center
Raleigh, NC 27699-1623
Re: Toxicity Results: NPDES#NC0025453
To Whom It May Concern:
Enclosed please find the Ceriodaphnia Pass/Fail results for the Little Creek Water
Reclamation Facility.
Please call me directly at 919-553-1536 if you have any questions.
Sincerely,
mes Warren, ORC
Town of Clayton, NC
653 Highway 42 West•P.O.Box 879•Clayton.North Carolina 27520•[phone]•Fax[phone]

Effluent Toxicity Report Form - Chronic Pass/Fail and Acute LC50 Date: 06/10/20
Facility: CLAYTON WWTP NPDES#: NC0025453 Pipe#: 001 County: JOHNSTON
Labora Perf ing st: MERITECH LABS, INC.
Comments:
X
S'gna dre o Oper for in Responsible Charge
X .� 'e
DO1Signature of Laratory Supervisor * PASSED: -5.88% Reduction *
Work Order: Environmental Sciences Branch
MAIL ORIGINAL TO: Div. of Water Quality
N.C. DENR
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
North Carolina Ceriodaphnia
Chronic Pass/Fail Reproduction Toxicity Test Chronic Test Results
Calculated t = -1.257
Tabular t = 2.508
CONTROL ORGANISMS 1 2 3 4 5 6 7 8 9 10 11 12 % Reduction = -5.88
% Mortality Avg.Reprod.
# Young Produced 18 23 18 22 19 24 16 17 20 21 19 21
8.33 19.83
Control Control
Adult (L) ive (D)ead L L L L L L L D L L L L
0.00 21.00
Treatment 2 Treatment 2
Effluent %: 2%
TREATMENT 2 ORGANISMS 1 2 3 4 5 6 7 8 9 10 11 12 Control CV
12.319% PASS FAIL
# Young Produced 19 22 19 22 24 20 21 22 20 22 17 24 % control orgs X
producing 3rd
brood Check One
Adult (L) ive (D)ead L L L L L L L L L L L L 100%
1st sample 1st sample 2nd sample Complete This For Either Test
pH 1 Test Start Date: 06/03/20
Control 7.91 7.89 7.94 8.04 7.88 8.01 Collection (Start) Date
Sample 1: 06/01/20 Sample 2: 06/03/20
Treatment 2 7.96 7.93 7.97 7.91 8.06 7.87 Sample Type/Duration 2nd
1st P/F
s s s Grab Comp. Duration D
t e t e t e I S S
a n a n a n Sample 1 X 23 .6 hrs L A A
r d r d r d U M M
t t t Sample 2 X 23 .2 hrs T P P
1st sample 1st sample 2nd sample
D.O. Hardness(mg/1) 42
Control 7.92 7.71 8.09 7.70 8.08 7.56
Spec. Cond. (pmhos) 146 476 490
Treatment 2 7.91 7.76 8.12 7.47 8.04 7.51
Chlorine(mg/1) <0.1 <0.1
LC50/Acute Toxicity Test P t Sample te
mp.e receipt(°C)recei t( C) 1.3 1.4
(Mortality expressed as %, combining replicates)
Note: Please
% % % % % % % % % % Concentration Complete This
Section Also
Is % % % % % % % % % Mortality
start/end start/end
LC50 = st Method of Determination Control
95% Confidence Limits Moving Average Probit
% -- % Spearman Karber - Other High
Conc.
pH D.O.
Organism Tested: Ceriodaphnia dubia Duration(hrs) :
Copied from DWQ form AT-1 (3/87) rev. 11/95 (DUBIA ver. 4.41)

Meritech, Inc. (Lab # 027) --)
Mini Chronic Pass/Fail Test: Ceriodaphnia dubia Incubator#: .)
Client: C. (C y-L.',A. Pipe#: 0t- I County: 7, 1,,, , 1,•,,.I Date Start: /, - -' '� , -
NPDES#: NC (.'i:��C) 'l y 3 G � � :�� Date End: �• �� r� )
Date/Time of Culture Transfer.- '�-, �� 9' Time Start: - .,
��.' r 1/r. i/ O� ,,t:'n Time End: / ,.fir\
Dilution Water: Lake Brandt Date/Time Neonates born: I , 'OLj .)l-`1 / i`,.- 1st Renewal Date:
�, — � -�I'; Time: //; (; 7`f,.-`"�
Test Organism Source: Tray# Age of eonates at Test Start:)) ' 'P1 hours 2nd Renewal Date: (- 1
. i Time: Al t' f (.• j0�
Stirred/Aerated for D.O.: Y /(N) Randomized: Y)/ N Culture Tray Temp:.)1. 5 °C Analyst(s): MR,CD,LV,KS Reviewed by:
,uV.
-
Control Organism Reproduction Collection (Start) Dates:
Day#2 1 2 3 4 5 6 7 8 9 10 11 12 /
#Young Produced 0 0 0 0 0 0 0 0 0 0 0 0 Sample 1: 6c.6 - /-,16 Sample 2: 0- ) /:/t
Adults Live/Dead L_ � L L L L L L L L L. L Sample Information C
Da #5 1 2 3 4 5 . 7 $ 9 10 1 1 100% pH G/C? Duration
#Young Produced L. �, NTEMNIM SIKETAiniallifi Sample 1 7f 51 C. '2 3,6 hours
Adults Live/ Dead (, L-., ` 1_, I-- L L L- L- Sample 2 7,83 r 3
;,1_�. hours
Day#7 1 2 3 4 5 6 7 8 9 10 11 12
Transferred by: Fed by
#Young Produced 7 icy `� 1/ r,/- 1') 0 -7 ,r, O Batch # L 1 ) ii 1 Sample 1 Sample 2
/ I Day 0 Ai& Cl/
Adults Live/Dead L Z_ /— ( . !- L. n / /_ ,' L Transfer Day 0 2 5 t'r` Day 1 itM
Hardness [� LJl�/
Total Produced -' z) J ,' „ f, I (mg/L) 1 ! / 'rT Day 2 ���� �i
1�� J , f , ( I 1
1r-1! (' ,"\.-1 ,e" i7 > Spec.Cond. _ Day 3
% (umhos/cm) / IW /y y7, yy6) Day 4 ,cr1 Percent of Control producing third brood: , y�) w
Chlorine ; LQ Da 5 ^A'
Test Sample Organism Reproduction (mg/L) " ■l L� •, Y �,
Day6 /"l Receipt Sample /` (�\
Effluent%: , �� Temp (°C) } Terminated by: ,�'`L
pH 1st Sample 2nd Sample 2nd Sample
Day#2 1 2 3 4 5 6 7 8 9 10 11 12
#Young Produced 0 0 0 0 0 0 0 0 0 0 0 0 Control 7'1( 7,11`I 7 S Y ( (;y 7,s •' ,i
Adults Live/Dead L L L L L L ( 1_ L 1_ L �,, ' .
Day#5 4 5 7 9 10 11 12 Sample • i / v 7 7i�i �.( � �;
Initial final initial final initial ` final
#YoungProduced 3A. L � �� `� t1 /' t. >,� � X,fr. Y Ir. 4 1 1 .� N 4 (/ • y/c: D.O. 1st Sample n/ p 2 d Sample 2nd Sample
Adults L I p Live/Dead L- t_ L. L tr L L_ L L L (. L
Day#7 1 2 3 4 5 6 7 8 9 10 11 12 Control .71 tl 2. 7I n,67 7, .�� �.(' 7.z),
#Young Produced /(.) 7 /(i' 1 /C.; f ( l j (,_., _i ' (l' Sample 711 1 7 7(-, (1(Z 7Y7 (r) ('= 7‘)/
Adults Live/Dead initial final initial final initial final L L_ L. L /_ L- L- L_ / � L_
f Temp. 1st Sample 2nd Sample 2nd Sample
Total Produced /i ,-r)-.-Z /C :VI 94') .\ 9r)) -,.-.2:-.), 1 —7 ��',/ Control R11Ll 2',I <,� 3 �'1f .? Li. 1)1, y
Comments. t ` Sample 41 (_- i.� 91.;,� l -74;
Initial final filial final�` I Ij

MERITECH, L RITECH, INC. (Lab #027) Meritech Sample ID#: V L. 1-'L7 3
Bioassay Sample Chain of Custody
r� 642 Tamco Rd, Reidsville NC 27320
Phone: [phone] Fax: [phone]
Toxicity Supervisor email: mike.reedAmeritechlabs.com Web Site: www.meritechlabs.com
CLIENT INFORMATION
Client: �%JLJ.✓ /, t/1/c,y t� •J PO#: �{j'
Contact Person: fJ4,yi S l l,. '-' -� NPDES#: NC 00,2S ',,3
Address: /'0 7.30A. se 72 Phone: y'/5 5 -� 1 5'7 4•
City:1/C ni).J
y Pipe#: (x,/
County J p, Js ,..4.-L.,,, State: ,,fc,.. Zip:
SAMPLE INFORMATION
Sample Site: L, f"tIL. C, „me.L L)g) /
Sample Type: ❑Grab omposite #of containers: ,2
Sampling Time: Start Date: Lab /ZI: Start Time:1 j/,5 AM PM
End Date: 4 /,.2. L2o End Time: /5. © AM PM
"'Triple rinse sample container with sample before filling completely with NO AIR SPACE.Pack the sample cooler completely with ice. The
sample must be<0.6°C upone receipt at Meritech *
Collector's Name: Print: 1,j, fi, C.,0,1 P c. Mom,„J Signature: ��-...TOXICITY TEST INFORMATION
Test Required: hronic(7 days) Test Organism: -R.Ceriodaphnia dubia (water flea)
❑ Acute(24-48 hours) ❑ Pimephales promelas (fathead minnow)
❑ Mysidopsis bahia (mysid shrimp)
IWC: jt Cr % "'Friday Samples for Chronic Fathead test must be collected after 9:00 a.m. on Friday"'
Comments:
SHIPPING INFORMATION
Relinquished by. \ Date: .z (j Time: //) M PM
Received b ' Date: '
}�,, >�J Time: / b A P
Relinquished by: Date: - - ) Time: 3 -0_I AM PM
Received by: Date: Time: AM PM
Relinquished by: Date: Time: AM PM
Received by: Date: Time: AM PM
Relinquished by: Date: Time: AM PM
Received by: Date: Time: AM PM
Sample Temperature(°C):
Method of Shipment:❑ UPS ❑ Fed EX ❑ Meritech Pick-up C Delivered E Other
"Samples shipped on Friday must be FedEx and must be clearly labeled for Saturday delivery, NO SIGNATURE REQUIRED"
SAMPLE RECEIVING (Laboratory Use Only)
r` r
Relinquished by: t_ rn I c }c41R rr j
J
it ^^�� '11�
Received by: - nl(,tk, Date: .kJ—1--2J Time: 1 3 AM (PM
Sample Temperatures CC): i` 3 / / / I Sample Condition: ?C.'°;
INHITF = I atinr>tnno i-nn., vC. I r1Ui- r`rt.,.,a

MERITECH, INC. (Lab #027) Meritech Sample ID ' U C A C :9
Ak Bioassay Sample Chain of Custody
642 Tamco Rd, Reidsville NC 27320
Phone: [phone] Fax: [phone]
Toxicity Supervisor email: [e-mail] Web Site: www.meritechlabs.com
CLIENT INFORMATION
i
Client: ,fit J,_J O/ -/ yt 2,2 PO#:
Contact Person: j n,rt e_S (.,klN.- '4" NPDES#: NC ( 2,$y5-3
Address: ?a.) r7 9 Phone: 9/Y yyf-6:7G
City: (11Ct.,f Ar7--, Pipe#: e:k2/
County: .,]0/1_425 ,' State: ,,�C._ Zip: 21 Z Y;
/cuSAMPLE INFORMATION
L. 1l
Sample Site: , li LC,K. ✓
C,, Llt.-G/ _?( I rtvfc " '--' Ar G.7 !i
Sample Type: ❑Grab Composite #of containers:
Sampling Time: Start Date: la-,3- Start Time: //(J) At & PM
End Date:l4--i(-ieO End Time:j[)/ AM PM
"'Triple rinse sample container with sample before filling completely with NO AIR SPACE.Pack the sample cooler completely with ice. The
sample must be<0.6°C upone receipt at Meritech*"
Collector's Name: Print: t,✓1`/1,a 01. 5 7-t/j/ f('a--) Signature:
TOXICITY TEST INFORMATION
Test Required: Chronic(7 days) Test Organism: 21.Ceriodaphnia dubia (water flea) l
❑ Acute(24-48 hours) ❑ Pimephales promelas (fathead minnow)
❑ Mysidopsis bahia (mysid shrimp)
IWC: I,0 % "'Friday Samples for Chronic Fathead test must be collected after 9:00 a.m.on Friday"'
Comments:
SHIPPING INFORMATION
Relinquished by: % Date: ✓/7 l7✓ Time: !t'ai_ M PM
Received by: l✓ti— Date. �,�— - 1 Time: /b D PM
Relinquished by: Date: [p ot () Time: 7 t ( Sl AM eM )
Received by: Date: Time: AM PM
Relinquished by: Date: Time: AM PM
Received by: Date: Time: AM PM
Relinquished by: Date: Time: AM PM
Received by: Date: Time: AM PM
Sample Temperature(°C):
Method of Shipment:❑ UPS ❑ Fed EX El Meritech Pick-up ❑Delivered ❑ Other
Samples shipped on Friday must be FedEx and must be clearly labeled for Saturday delivery. NO SIGNATURE REQUIRED "
�� SC SAMPLE RECEIVING(Laboratory Use Only)
Relinquished by: C n i , SC((✓-r1
Received by: *(.) SIn( jL Date: a-fr—1� Time: 'f1 I I AM PM
Sample Temperatures(°C): il N I Of I 1 Sample Condition: L c°d
WHITE = Laboratory cony YFI I C)W= r'.liant rnrni

Effluent Toxicity Statistical Results - Chronic Pass/Fail Date: 06/10/20
Facility: CLAYTON WWTP NPDES#: NC0025453 Pipe#: 001 County:JOHNSTON
Laboratory Performing Test: MERITECH LABS, INC.
1
Reduction: -5.88% CONTROL 2% Effluent
# Replicates 12 12
Female Live 11 12
Adult Male 0 0
Adult Dead 1 0
Adult Mortality 8.33% 0.00%
# Neonates 238 252
Mean # Neonates 19.833 21.000
Standard Deviation 2.443 2.089
Coefficient of Variation 12 .319%
Fisher's Exact Test
A = 12 B = 12 a = 11 b = 12
a/A = 0.92 b/B = 1.00
Success is: survival
Critical b value = 6
12 > 6
The test concludes that the proportion of survival is not
significantly different for the control and the effluent groups.
Test Passes!
SHAPIRO-WILK'S TEST FOR NORMAL DISTRIBUTION OF DATA
ORDERED OBSERVATIONS
i Group Neonates Centered i Group Neonates Centered
1 E 17 -4.0000 13 C 20 0.1667
2 C 16 -3 .8333 14 E 22 1.0000
3 C 17 -2.8333 15 E 22 1.0000
4 E 19 -2.0000 16 E 22 1.0000
5 E 19 -2.0000 17 E 22 1.0000
6 C 18 -1.8333 18 C 21 1.1667
7 C 18 -1.8333 19 C 21 1.1667
8 E 20 -1.0000 20 C 22 2.1667
9 E 20 -1.0000 21 E 24 3 .0000
10 C 19 -0.8333 22 E 24 3 .0000
11 C 19 -0.8333 23 C 23 3 .1667
12 E 21 0.0000 24 C 24 4 .1667

SHAPIRO-WILK'S TEST FOR NORMAL DISTRIBUTION OF DATA (cont. )
COEFFICIENTS AND DIFFERENCES
i x(n-i-1) x(i) a(i) x(n-i-1) - x(i)
1 4 .1667 -4.0000 0.4493 8. 1667
2 3 .1667 -3 .8333 0.3098 7.0000
3 3 .0000 -2.8333 0.2554 5.8333
4 3 .0000 -2.0000 0.2145 5.0000
5 2.1667 -2.0000 0.1807 4.1667
6 1.1667 -1.8333 0.1512 3.0000
7 1 .1667 -1.8333 0.1245 3 .0000
8 1.0000 -1.0000 0.0997 2.0000
9 1.0000 -1.0000 0.0764 2.0000
10 1.0000 -0.8333 0.0539 1.8333
11 1.0000 -0.8333 0.0321 1.8333
12 0.1667 0.0000 0.0107 0.1667
1
W = X 110.0798
113 .6667
Calculated W = 0.968 Critical W = 0.884
0.968 a 0.884
The reproduction data is normally distributed
evaluated at a 99W confidence interval.
Test Passes!
F test for Homogeneity of Variance
Control variance 5.9697
F = _ = 1.37
Effluent variance 4.3636
Numerator degrees of freedom: 11 Denominator degrees of freedom: 11
Critical F = 5.32
1.37 s 5.32 =► The Test PASSES, the variances of the two groups
are significantly the same, homogeneous.

EQUAL VARIANCE t TEST
19.8 - 21.0
t = _ -1.257
0.928
Degrees of freedom = 22
Critical t = 2.508
-1.257 < 2.508
Test passed. There is not a significant difference in reproduction
between the Control and the effluent evaluated at a 99% confidence interval.
Chronic Test PASSES

Attachment E
International Paper Company
Nitrogen Allocations Purchase Agreement

This page intentionally left blank.

ESTUARY NITROGEN ALLOCATION
PURCHASE AND SALE AGREEMENT
("Agreement")
Buyer: Town of Clayton Address:
PO Box 879Clayton,NC 27528-0879
Buyer Contact: Richard D.Cappola,Jr. Contact Info:
Public Services Director Email: [e-mail]
Tel.#: [phone]
Seller: International Paper Company Address: 6400 Poplar Avenue
Memphis,TN 38197
Seller Contact: Patrick Wilson Contact Info:
International Paper Energy Sourcing Leader E-mail: [e-mail]
Phone#: [phone]
Effective Date: April 1,2020
Product, North Carolina Estuary Nitrogen Allocation Credits(hereinafter the"Credits")as specifically identified in the table
Quantity,and below:
Price: Emission Quantity Credit Price
Type Facility Identifier Sold per Pound
Estuary New Bern Mill NPDES 13,000 $500
Nitrogen NC0003191 pounds
Allocation
Purchase and Seller shall sell to Buyer, and Buyer shall purchase from Seller, the Credits identified above in the Quantity Sold
Sale: and at the Credit Price per Pound set forth above for a total purchase price of Six Million Five Hundred Thousand
dollars($6,500,000) (the"Total Purchase Price").
Buyer shall be responsible for taxes,filing fees, registration fees,and/or transfer fees applicable to the transfer of
the Credits,if any.
Upon the receipt by Seller of the full Total Purchase Price, ownership, title and any other rights and interests in
the Credits shall transfer from Seller to Buyer.
Transfer and Within three (3) business days after execution of this Agreement, Seller shall submit to Buyer an original of the
Payment Terms: required North Carolina Credit transfer forms.
Buyer shall pay the Total Purchase Price to Seller within seven (7)business days of final approval from the North
Carolina Department of Environmental Quality for the transfer of the Credits. All funds to be paid shall be
rendered in the form of immediately available funds (U.S. Dollars) by wire transfer or in such other form as
otherwise agreed to by the parties, in writing.
Seller's Banking Instructions are:
Bank:JP Morgan Chase Bank
ABA Routing No.:021000021
Account Name: International Paper Company
Account No.:0361046469
If Buyer fails to remit any amount payable by it when due,then interest on such unpaid portion shall accrue at a
rate equal to the prime interest rate in effect at the time as published in The Wall Street Journal plus two percent
(2%) from the date payment is due to the date of payment.
Buyer and Seller shall fully, timely and reasonably cooperate to obtain any and all required documentation,
approvals, and/or certificates which may be required to effectuate the transfer of the Credits to Buyer and to
comply with any and all other regulatory obligations relating to the recording and tracking of the transfer of the
Credits.
PPAB 5519821v2

Should the North Carolina Department of Environmental Quality not approve the transfer of the Credits from
Seller to Buyer, and thereafter the parties are unable to accomplish the transfer within the later of one hundred
twenty (120) business days of the first submitted request for transfer or July 31, 2020, due to the decision,
actions, or inactions of the North Carolina Department of Environmental Quality, then this Agreement will
become null and void. In such case, Seller shall return any monies paid and ownership of the Credits shall return
to the Seller and neither party shall have any further obligation or liability to the other party.
Additional Terms Mutual Representations and Warranties. Each party represents and warrants to the other party as of the date of
and Conditions: this Agreement, and as of the date of delivery of the Credits to be sold hereunder that (i) it has, and at all times
during the term of this Agreement will have, all necessary power and authority to execute, deliver, and perform
its obligations under this Agreement; (ii) the execution, delivery, and performance of this Agreement has been
duly authorized by all necessary action and does not violate any of the terms or conditions of its governing
documents, or any contract to which it is a party,or any law or other legal or regulatory determination applicable
to it; and (iii) there is no pending or (to its knowledge) threatened litigation, arbitration, or administrative
proceeding that materially adversely affects its ability to perform its obligations under this Agreement.
Representations and Warranties of Seller. Seller represents and warrants to Buyer that, with respect to the
Credits delivered to Buyer hereunder: (i) each Credits sold hereunder meets the specifications set forth in this
Agreement;(ii)Seller has good and legal ownership to the.Credits;and(iii)all right,title and interest in and to the
Credits are free and clear of any liens, taxes, claims,security interests, or other encumbrances, and upon receipt
of the Credits by Buyer, Buyer shall have all right, title, and interest in and to such Credits. SELLER EXPRESSLY
NEGATES ANY OTHER REPRESENTATION OR WARRANTY, WRITTEN OR ORAL, EXPRESS OR IMPLIED, INCLUDING,
BUT NOT LIMITED TO, ANY REPRESENTATION OR WARRANTY WITH RESPECT TO MERCHANTABILITY OR FITNESS
FOR ANY PARTICULAR PURPOSE AS RELATED TO THE CREDITS.
Event of Default. For purposes of this Agreement, a party shall be in default(each of the following, an "Event of
Default"): (i) if that party fails to make, when due, any payment required pursuant to this Agreement if such
failure is not remedied within five (5) business days of written notice from the other party; (ii) if that party
materially breaches any or all of its obligations under this Agreement and such breach is not cured within ten (10)
business days of written notice of such breach from the other party; (iii) if any representation or warranty made
by a party pursuant to this Agreement proves to have been misleading or false in any material respect when
made; or, before the conclusion of all actions required for the sale, delivery, and performance of obligations
under this Agreement, (iv) if a party makes an assignment or any general arrangement for the benefit of its
creditors; files a petition or otherwise commences, authorizes or acquiesces in the commencement of a
proceeding or cause under any bankruptcy or similar law for the protection of creditors; has a petition filed
against it; or otherwise becomes bankrupt or insolvent(however evidenced);(v) if a liquidator, receiver, trustee,
conservator or similar official is appointed with respect to a party or any substantial proportion of its property or
assets; (vi)if that party is generally unable, or admits in writing of its general inability,to pay its debts as they fall
due;or(vii)if that party repudiates any obligation under this Agreement.
Remedies upon Default. If an Event of Default occurs on the part of either party and is continuing, the non-
defaulting party may,at its sole option, upon five (5)business days'written notice and opportunity to cure to the
defaulting party,terminate this Agreement.
Failure to Deliver/Receive. Notwithstanding anything in this Agreement to the contrary,the remedies set forth in
this section are the exclusive monetary remedies of the performing party for the other party's failure to (i) take
delivery of all or any portion of the Credits specified hereunder, or (ii) deliver all or any portion of the Credits
specified herein,as applicable.
If Buyer fails to take delivery of all or any portion of the Quantity of Credits specified herein and such failure is
not excused under the terms of this Agreement (including, without limitation, due to a Change in Law (defined
below]), Buyer shall pay Seller,within five(5) business days of invoice receipt,an amount equal to the sum of the
Unit Price multiplied by the quantity for any Credits delivered to Buyer for which Seller has not been paid;plus(i)
reasonable actual, documented legal fees and costs incurred by Seller in enforcement and protection of its rights
under this Agreement;plus(ii)interest as described herein.
If Seller fails to deliver all or any portion of the Quantity of Credits to Buyer specified herein and such failure is
not excused under the terms of this Agreement, then Seller shall pay Buyer, within five (5) business days of
invoice receipt, an amount equal to $1000, plus reasonable actual, documented legal fees and costs incurred by
Buyer in enforcement and protection of its rights under this Agreement. In addition to monetary damages as
allowed by this Section, Buyer may sue for specific performance of this Agreement. The parties agree that an
PPAB 5519821v2

order of the court enforcing the consummation of the sale and delivery of the Credits is an appropriate remedy in
the event of a Seller Default.
Change of Law. Should any change in law governing the Credits occur prior to Buyer's receipt of transfer
documents evidencing that the Credits have been transferred to Buyer, and such change of law restricts or limits
the transferability of the Credits (i.e. not simply a clarification or modification of existing law which has little or
no effect on the ability of the parties hereto to effectuate this sale transaction or upon the nature and quality of
the Credits) (a "Change of Law"), then Buyer's sole recourse and remedy shall be to terminate this Agreement
upon written notice to Seller, and upon Buyer's exercising of said termination, Seller shall return any amounts
received from Buyer (if applicable) and Buyer shall cooperate to effect the return of the Credits to Seller (if
applicable), and thereafter no party shall have any further liability or obligation to any other party hereto. If a
Change of Law occurs after Buyer's receipt of documentation evidencing that the Credits have been transferred
to Buyer or Buyer's designee,then Buyer shall have no recourse or remedy against Seller.
Limitations of Liability. THE EXPRESS REMEDIES AND MEASURES OF DAMAGES PROVIDED HEREIN SATISFY THE
ESSENTIAL PURPOSES HEREOF. FOR BREACH OR DEFAULT ARISING FROM ANY PROVISION FOR WHICH AN
EXPRESS REMEDY IS PROVIDED HEREIN, SUCH REMEDY OR MEASURE OF DAMAGES SHALL BE THE SOLE AND
EXCLUSIVE REMEDY AND ALL OTHER REMEDIES OR DAMAGES AT LAW OR IN EQUITY ARE WAIVED, INCLUDING
ANY INDEMNIFICATION OBLIGATIONS RELATING THERETO. IF NO REMEDY OR MEASURE OF DAMAGES IS
EXPRESSLY PROVIDED HEREIN, LIABILITY SHALL BE LIMITED TO DIRECT, ACTUAL DAMAGES ONLY. SUCH DIRECT,
ACTUAL DAMAGES SHALL BE THE SOLE AND EXCLUSIVE REMEDY, AND ALL OTHER REMEDIES OR DAMAGES AT
LAW OR IN EQUITY ARE WAIVED. EXCEPT AS MAY BE INCLUDED IN AN EXPRESS REMEDY PROVIDED FOR HEREIN,
NEITHER PARTY SHALL BE LIABLE TO THE OTHER PARTY FOR ANY INDIRECT, SPECIAL, CONSEQUENTIAL, PUNITIVE
OR EXEMPLARY DAMAGES ARISING OUT OF OR RELATED TO THIS AGREEMENT, INCLUDING LOST PROFITS
(EXCEPT TO THE EXTENT THAT THE PAYMENTS REQUIRED TO BE MADE PURSUANT TO THIS AGREEMENT ARE
DEEMED TO BE SUCH DAMAGES) OR BUSINESS INTERRUPTION DAMAGES, WHETHER BASED ON STATUTE,
CONTRACT, TORT, UNDER ANY INDEMNITY OR OTHERWISE, WITHOUT REGARD TO CAUSE OR THE NEGLIGENCE
OF ANY PARTY, WHETHER SOLE, JOINT, ACTIVE OR PASSIVE, AND EACH PARTY HEREBY RELEASES THE OTHER
PARTY FROM ANY SUCH LIABILITY, EVEN IF DURING THE TERM HEREOF IT ADVISES THE OTHER OF THE
POSSIBILITY OF SUCH DAMAGES. TO THE EXTENT ANY DAMAGES REQUIRED TO BE PAID HEREUNDER ARE
LIQUIDATED, THE PARTIES ACKNOWLEDGE THAT THE DAMAGES ARE DIFFICULT OR IMPOSSIBLE TO DETERMINE,
OR OTHERWISE OBTAINING AN ADEQUATE REMEDY IS INCONVENIENT AND THE DAMAGES CALCULATED
HEREUNDER CONSTITUTE A REASONABLE APPROXIMATION OF THE HARM OR LOSS AND ARE NOT A PENALTY.
Confidentiality. To the extent allowable by law, the parties agree to keep confidential the contents of this
Agreement and any information made available by one party to the other party with respect to this Agreement
(the"Confidential Information")except: (i)in respect of information that is or becomes generally available to the
public other than as a result of a disclosure by either party in violation of this Agreement; (ii) in respect of
information that was already known by either party on a non-confidential basis prior to the execution of this
Agreement; (iii)in respect of information that becomes available to either party on a non-confidential basis from
a source other than the other party where such source is not known by the receiving party to be subject to a
confidentiality obligation with respect to such information; (iv) to the extent required by any administrator or
regulatory agency in order to effectuate the transaction contemplated by this Agreement or to comply with
applicable law; (v) in respect of information that is independently derived and is not directly attributable to the
party with respect to which it relates;and(vi)to the professional advisors of each party, provided that each party
ensures that the matters disclosed are kept confidential. The parties acknowledge and agree that in the event of
a breach of this confidentiality provision monetary damages may be insufficient to make the non-disclosing party
whole; as such, the non-disclosing party shall be entitled to seek equitable relief, including injunctive relief and
specific performance, in addition to all other remedies available at law or in equity.Seller agrees that publication
of this Agreement, in its totality, as part of Town Council meeting agendas or in response to a public records
request pursuant to N.C.G.S. §132 is not a breach of this Agreement.
Notices. All notices,demands,and other communications hereunder shall be effective only if given in writing and
shall be deemed given (i) when delivered in person; (ii) when delivered by a reputable overnight carrier (with
confirmation of delivery); (iii)when transmitted by facsimile or e-mail (with confirmation of transmission); or(iv)
five (5) business days after being deposited in the United States mail, first-class, registered or certified, return
receipt requested,with postage paid. For purposes hereof, all notices,demands and other communications shall
be sent to the contacts and addresses above (or to such other address furnished in writing by one party to the
other party).
Assignment. This Agreement shall be binding upon and inure to the benefit of the parties and their respective
PPAB 5519821 v2

successors and permitted assigns. Neither party may transfer or assign this Agreement, in whole or in part,
without the other party's prior written consent, which consent shall not be unreasonably withheld. Upon any
transfer or assignment permitted by this Agreement, the assignor shall be released from its obligations
hereunder to the extent such obligations are assumed by the assignee.
Amendment. This Agreement may be amended at any time, but only by a written agreement signed by both
parties.
No Waiver. No delay or omission by a party in the exercise of any right under this Agreement shall be taken,
construed, or considered as a waiver or relinquishment thereof. If any of the terms and conditions herein are
breached and thereafter waived in writing by a party, such waiver is limited to the particular breach so waived
and is not deemed to waive any other breach hereunder.
Severability. If any provision or portion of this Agreement is found to be unenforceable, the remainder shall be
enforced as fully as possible and the unenforceable provision shall be deemed modified to the limited extent
required to permit its enforcement in a manner most closely representing the intention of the Parties as
expressed herein.
Complete Agreement. This Agreement represents the parties' final and mutual understanding concerning its
subject matter. It replaces and supersedes any prior agreements or understandings,whether written or oral.
Governing Law. This Agreement shall be construed in accordance with and governed by the laws of the State of
North Carolina, excluding any choice of law or conflicts of law rules or principles that would result in application
of the laws of a different jurisdiction.
Dispute Resolution. Any dispute between the parties arising under or pertaining to this Agreement shall be
referred to representatives of the parties for informal dispute resolution discussions as soon as practicable. In
the event that the designated representatives do not reach a mutually acceptable resolution of the dispute
within thirty (30) days of such referral, the parties may agree to submit such dispute to mediation or other
dispute resolution process as may be agreed upon by the parties. If the dispute is not resolved within ninety(90)
days from the date of such submission for mediation or other dispute resolution process, either party may bring
an appropriate action at law or in equity in the courts of the State of North Carolina or the U.S. District Court
located in the State of North Carolina. Each party waives any objection which it may have at any time to the
laying of venue of any such proceedings brought in any such court, waives any claim that such proceedings have
been brought in an inconvenient forum and further waives the right to object, with respect to such proceedings,
that such court does not have any jurisdiction over such party. Nothing in this Agreement to the contrary shall,
or is intended to, prevent either party from bringing an action in equity to seek injunctive relief, if necessary, to
avoid irreparable harm. EACH PARTY WAIVES ITS RESPECTIVE RIGHT TO ANY JURY TRIAL WITH RESPECT TO ANY
LITIGATION ARISING UNDER OR IN CONNECTION WITH THIS AGREEMENT.
Counterparts. This Agreement may be executed in counterparts, each of which shall be deemed an original, and
all of which together shall be deemed to be one and the same instrument. Scanned and e-mailed copies of the
signed Agreement or other electronic transmission of any signed original document, will be the same as delivery
of any original document.
Further Assurances. Each party shall provide the other party any reasonably requested information or
documentation required to effect a transfer of Credits pursuant to the terms of this Agreement,will cooperate to
cause a transfer to occur, and will otherwise comply with any and all applicable procedures and requirements of
applicable law relating to the transfer.
PPAB 551982I v2

By signing below and in witness whereof,the parties agree to be bound by the terms and conditions contained in this
Agreement.
Buyer: TOWN OF CLAYTON Seller: INTERNATIONAL PAPER COMPANY
Signature: . Title: Town Manager Signature: Title:
• low C.athet/?re/Jlafe� SVP G C F & I P Asia
Printed ame: da Lindsay 'ei
Date: Printed Name: Date:
Catherine I Slater 04/01/2020
This instrument has beenbe preaudited in the manner required by the Local Government Budget and Fiscal Control Act.
i!r�/��i'/ ,t'!0.
Robert McKie,Finance Director
PPAB 5519821v2

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Attachment F
NPDES Permit NC0025453,
Little Creek WRF in Johnston County
( current draft)

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ROY COOPER
Governor M
MICHAEL S.REGAN
Secretary
S.DANIEL SMITH NORTH CAROLINA
Director Environmental Quality
July 20, 2020
James Warren, WWTP Operations Supt.
Town of Clayton
P.O. Box 879
Clayton, North Carolina 27520
Subject: Draft NPDES Permit Modification
Permit NC0025453
Little Creek WRF
Johnston County
Grade IV Biological WPCS
SIC Code 4952
Dear Mr. Warren:
The Division of Water Resources staff has reviewed your June 16, 2020,request for modification
of the Town of Clayton's NPDES permit to reflect the Town's pending purchase of nitrogen
offset credits. The Division has made a tentative determination to modify the permit as
requested and is forwarding herewith,for your review and comment, the draft permit with
revisions to Special Condition A.(6.),Total Nitrogen Allocations.
At this time, we are submitting a notice for publication in the newspapers of general circulation
in Johnston County,inviting public comment on the draft permit modification.The notice is
scheduled to be published on or about July 24, 2020. Following a 30-day comment period,the
Division will review all pertinent comments received and take appropriate action on the permit
modification.
Please provide any comments you have regarding the draft permit to this office,in writing,
no later than Monday,August 24,2020.Comments should be sent to my attention at either
NCDEQ/ DWR, WQ Permitting Section, 1617 Mail Service Center, Raleigh, NC,27699-1617;or
at i ike.templeton@ncdenr. s,.
The proposed modification affects only Condition A.(6.) of the permit and includes the
following changes:
• The offset credits purchased by the Town have been added to the table of allocations.
The offset credits will be held in reserve until they become available upon future
expansion of the facility;
• A new footnote to the table documents the total amount of offset credits to be purchased
and the amount available to the Town for its NPDES discharge;
• References to"allocation" have been revised to include offset credits as well;and
• The reference to the Neuse River wastewater discharge rule for nutrients has been
updated from 02B .0234 to 02B .0713 in light of its recent recodification.
North Carolina Department of Environmental Quality i Division of Water Resources
512 North Salisbury Street 11617 Mail Service Center Raleigh,North Carolina 27699-1617
„CatT 919.707.9000

Draft NPDES Permit Modification
July 20,2020
NOTE:The Director will not take final action on this permit modification until(1)issues arising
from the public review have been resolved to his satisfaction and (2) the Town has provided a
bill of sale or similar document verifying its purchase of offset credits and the amount of credits
purchased.
If you have any questions concerning the draft permit,please contact me at(919) 707-3603 or at
[e-mail].
Sincerely,
MALel E. em eton, . .
Water Quality Permitting Section
Enclosure: Draft Permit and Fact Sheet,NC0025453
Copies(with encl.): NPDES Files
eCopies(with end.): NPDES Permitting Section,EPA Region IV
Scott Vinson,DWR Raleigh Regional Office,Surface Water Protection
Allen Hardy,DWR Raleigh Regional Office,Public Water Supply
DWR Basin Planning Branch
Maureen McKinney,DWR Wastewater Operator Certification Group
Mark Vander Borgh,DWR Water Sciences Section
Hannah Headrick,DWR Water Sciences Section
25453 coy Itr-draft permit 20200710.docx
7/16/2020 5:44 PM

DRAFT Permit NC0025453
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WATER RESOURCES
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions 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
Town of Clayton
is hereby authorized to discharge wastewater from a facility located at the
Little Creek Water Reclamation Facility
1000 Durham Street Extension
Clayton
Johnston County
to receiving waters designated as the Neuse River in the Neuse River Basin
in accordance with the effluent limitations,monitoring requirements,and other applicable conditions
set forth in Parts I, II, III,and IV hereof.
This permit shall become effective ,2020.
This permit and the authorization to discharge shall expire at midnight on March 31,2024.
Signed this day , 2020.
DRAFT
S. Daniel Smith, Director
Division of Water Resources
By Authority of the Environmental Management Commission
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DRAFT Permit NC0025453
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 Town of Clayton
is hereby authorized to:
1. Continue to operate and maintain an existing 2.5 MGD wastewater treatment facility consisting of
the following components:
• mechanical screening and grit removal system,
• influent pump station
• 214,500 gallon anaerobic basin,
• 300,000 gallon anoxic tank,
• oxidation basin No. 2,
• 200,000 gallon anoxic tank
• oxidation basin No. 1,
• three(3) secondary clarifiers,
• two tertiary filters,
• ultraviolet disinfection with back-up chlorination/dechlorination,
• 90,000 gallon aerated digester/sludge stabilization tank,
• 360,000 gallon sludge holding tank,
• sludge loading station,
• sludge thickening building with rotary drum thickener
• non-potable water system using reclaimed treated wastewater
• reclaimed water pump station
This facility is located at the Little Creek Water Reclamation Facility,Durham Street Extension,
Clayton,Johnson County,and
2. Discharge from said treatment works at the location specified on the attached map via Outfall 001
into the Neuse River,classified WS-IV,NSW,CA waters in the Neuse River Basin.
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DRAFT Permit NC0025453
PART I
A.(1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS [2.5 MGD]
[15A NCAC 02B .0400 et seq., 15A NCACO2B .0500 et seq.] Grade IV
Biological Water Pollution Control System [15A NCAC 08G .0302]
a. During the period beginning on the effective date of the permit and lasting until expiration, the
permittee is authorized to discharge treated municipal and industrial wastewater from Outfall
001. Such discharges shall be limited and monitored) by the permittee as specified below:
EFFLUENT LIMITS MONITORING REQUIREMENTS
PARAMETER
Parameter Code Monthly Weekly Daily Measurement Sample Sample
Average Average Maximum Frequency Type Location2
Flow 50050 2.5 MGD Continuous Recording I or E
TN Load 9-10 QM600 Monitor and Report(lb/month) Monthly
QY600 22,832 lb/yr Annually Calculated E
BOD, 5 day, 20°C3 C0310 5.0 mg/L 7.5 mg/L 2/weeks Composite I and E
(April 1-October 31)
BOD, 5 day, 20°C3 C0310 10.0 mg/L 15.0 mg/L 2/week8 Composite I and E
(November 1- March 31)
Total Suspended Solids3 C0530 30.0 mg/L 45.0 mg/L 2/week8 Composite I and E
NH3 as N C0610 1.0 mg/L 3.0 mg/L 2/weeks Composite E
(Apr 1-Oct 31)
NH3 as N C0610 2.0 mg/L 6.0 mg/L 2/weeks Composite E
(Nov 1- Mar 31)
Dissolved Oxygen 00300 Daily Average >_ 6.0 mg/L Daily Grab E
pH 00400 Between 6.0 and 9.0 Standard Units Daily Grab E
Temperature°C 00010 Monitor and Report Daily Grab E
Fecal Coliform 31616 200/ 100 400/100
mL mL 2/weeks Grab E
(geometric mean) _ _
Total Residual Chlorine4 50060 28.ig/L Daily Grab E
TKN (mg/L) 00625 Monitor and Report Weekly Composite E
NO3-N + NO2-N (mg/L) 00630 Monitor and Report _ Weekly Composite E
Total Nitrogen5 (mg/L) C0600 Monitor and Report Weekly Calculated E
Total Monthly Flow(MG) 82220 Monitor and Report Monthly Calculated E
Total Phosphorus(mg/L) C0665 2.0 mg/L(Quarterly Average) Weekly Composite E
Conductivity(pmhos/cm) 00094 Monitor and Report Daily Grab E
Bis(2-ethylhexyl) phthalate(pg/L) 39100 Monitor and Report Quarterly Composite E
Chronic Toxicity6 TGP3B Monitor and Report Quarterly Composite E
Pollutant Scan' NC01 Monitor and Report Footnote 7 Footnote 7 E
Hardness "-Total as CaCO3(mg/L) 00900 Monitor and Report Quarterly Composite E
Hardness "-Total as CaCO3(mg/L) 00900 Monitor and Report Quarterly Grab U
Dissolved Oxygen (mg/L) 00300 Monitor and Report Variable2 Grab U and D
Temperature°C 00010 Monitor and Report Variable2 Grab U and D
Conductivity(umhos/cm) 00094 Monitor and Report Variable2 Grab _ U and D
Fecal Coliform (#/100mL) 31616 Monitor and Report Variable2 Grab U and D
(geometric mean)
Footnotes begin on next page.
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DRAFT Permit NC0025453
Footnotes,A.(1.)Effluent Limitations and Monitoring Requirements:
1. The permittee shall submit Discharge Monitoring Reports electronically using NC DWR's eDMR application
system. See Special Condition A.(7.).
2. Sample locations I-Influent,E-Effluent,U-Upstream=at NCSR 1700,D-Downstream=(1)NC HWY 42 and
(2)NCSR 1908. Upstream and downstream samples shall be grab samples collected 3/week during June,
July,August,and September and 1/week during the remainder of the year.Instream sampling requirements
are provisionally waived in light of the permittee's participation in the Lower Neuse River Basin Association.
Should participation in the association cease,all instream sampling requirements are immediately reinstated.
3. The monthly average effluent BOD5 and Total Suspended Solids concentrations shall not exceed 15% of the
respective influent value(85% removal).
4. The Division shall consider all effluent total residual chlorine values reported below 50 µg/1 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 µg/l.
5. For a given wastewater sample,TN=TKN+NO3-N+NO2-N,where TN is Total Nitrogen,TKN is Total
Kjeldahl Nitrogen,and NO3-N and NO2-N are Nitrate and Nitrite Nitrogen,respectively.
6. Chronic Toxicity(Ceriodaphnia dubia)P/F at 2% with testing in March,June,September,and December.See
Special Condition A. (2.).
7. The permittee shall perform three effluent pollution scans during the term of this permit.See Special
Condition A.(3.).
8. Twice per week sampling must occur on any two non-consecutive days during the calendar week.
9. TN Load is the mass load of TN discharged by the permittee in a period of time.See Special Condition A. (4.).
10. Compliance with these limits shall be determined in accordance with Special Condition A.(5.),Annual Limits
for Total Nitrogen.
11. The permittee shall sample instream hardness upstream of the facility's discharge.The sample shall be
representative of the hardness in the stream.If the permittee is a member of the Monitoring Coalition
Program,sampling for instream hardness may be waived as long as the Monitoring Coalition agrees to
sample hardness at the nearest upstream location,at a minimum frequency of quarterly,and the permittee
has obtained approval from DWR-NPDES Permitting Unit that the upstream station being monitored by the
coalition is representative of the receiving stream for this discharge.The permittee is responsible for
submitting instream hardness test results with its DMRs as results are received from the coalition.If coalition
membership is cancelled or the Monitoring Coalition terminates instream hardness sampling at the approved
station,the permittee will immediately notify the Division and resume sampling for instream hardness,
upstream of its discharge,as required in Section A.(1.). Effluent hardness shall be performed in conjunction
with testing for hardness dependent metals(cadmium,copper,lead,nickel,silver,and zinc).
b. There shall be no discharge of floating solids or visible foam in other than trace amounts.
A.(2.) CHRONIC TOXICITY PERMIT LIMIT(QUARTERLY) [15A NCAC 02B.0200[
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant
mortality to Ceriodaphnia dubia at an effluent concentration of 2%.
The permit holder shall perform at a minimum,quarterly monitoring using test procedures outlined in
the"North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised December 2010,or
subsequent versions or"North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure"
(Revised-December 2010) or subsequent versions.The tests will be performed during the months of
March,June,September,and December. These months signify the first month of each three-month
toxicity testing quarter assigned to the facility. Effluent sampling for this testing must be obtained
during representative effluent discharge and shall be performed at the NPDES permitted final effluent
discharge below all treatment processes.
4 of 12

DRAFT Permit NC0025453
If the test procedure performed as the first test of any single quarter results in a failure or ChV
below the permit limit, then multiple-concentration testing shall be performed at a minimum,in
each of the two following months as described in "North Carolina Phase II Chronic Whole Effluent
Toxicity Test Procedure" (Revised-December 2010) or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered electronically using
the Division's eDMR system for the month in which tests were performed,using the parameter code
TGP3B for the pass/fail results and THP3B for the Chronic Value. Additionally, DWR Form AT-3
(original) is to be sent to the following address:
Attention: North Carolina Division of Water Resources
Water Sciences Section/Aquatic Toxicology Branch
1621 Mail Service Center
Raleigh, NC 27699-1621
Or,results can be sent to the email, [e-mail].
Completed Aquatic Toxicity Test Forms shall be filed with the Water Sciences Section no later than 30
days after the end of the reporting period for which the report is made.
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 Water Sciences Section 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. Assessment of toxicity compliance is based on
the toxicity testing quarter, which is the three month time interval that begins on the first day of the
month in which toxicity testing is required by this permit and continues until the final day of the third
month.
Should any test data from this monitoring requirement or tests performed by the North Carolina
Division of Water Resources 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.(3.) EFFLUENT POLLUTANT SCAN (Municipal POTWs) [G.S. 143-215.1(b)]
The permittee shall perform a total of three (3) Effluent Pollutant Scans for all parameters listed below.
One scan must be performed in each of the following years: 2021,2022, and 2023. Analytical methods
shall be in accordance with 40 CFR Part 136 and shall be sufficiently sensitive to determine whether
parameters are present in concentrations greater than applicable standards and criteria.Samples
should be collected with one quarterly toxicity test each year,and must represent seasonal variation
5 of 12

DRAFT Permit NC0025453
[i.e., do not sample in the same quarter every year]. Unless otherwise indicated, metals shall be
analyzed as "total recoverable."
Ammonia(as N) Trans-1,2-dichloroethylene Bis(2-chioroethyl)ether
Chlorine(total residual,TRC) 1,1-dichloroethylene Bis(2-chloroisopropyl)ether
Dissolved oxygen 1,2-dichloropropane Bis(2-ethylhexyl)phthalate
Nitrate/Nitrite 1,3-dichloropropylene 4-bromophenyl phenyl ether
Kjeldahl nitrogen Ethylbenzene Butyl benzyl phthalate
Oil and grease Methyl bromide 2-chloronaphthalene
Phosphorus Methyl chloride 4-chlorophenyl phenyl ether
Total dissolved solids Methylene chloride Chrysene
Hardness 1,1,2,2-tetrachloroethane Di-n-butyl phthalate
Antimony Tetrachloroethylene Di-n-octyl phthalate
Arsenic Toluene Dibenzo(a,h)anthracene
Beryllium 1,1,1-trichloroethane 1,2-dichlorobenzene
Cadmium 1,1,2-trichloroethane 1,3-dichlorobenzene
Chromium Trichloroethylene 1,4-dichlorobenzene
Copper Vinyl chloride 3,3-dichlorobenzidine
Lead Acid-extractable compounds: Diethyl phthalate
Mercury(EPA Method 1631E) P-chloro-m-cresol Dimethyl phthalate
Nickel 2-chiorophenol 2,4-dinitrotoluene
Selenium 2,4-dichiorophenol 2,6-dinitrotoluene
Silver 2,4-dimethylphenol 1,2-diphenylhydrazine
Thallium 4,6-dinitro-o-cresol Fluoranthene
Zinc 2,4-dinitrophenol Fluorene
Cyanide 2-nitrophenol Hexachlorobenzene
Total phenolic compounds 4-nitrophenol Hexachlorobutadiene
Volatile organic compounds: Pentachlorophenol Hexachlorocyclo-pentadiene
Acrolein Phenol Hexachloroethane
Acrylonitrile 2,4,6-trichlorophenol Indeno(1,2,3-cd)pyrene
Benzene Base-neutral compounds: Isophorone
Bromoform Acenaphthene Naphthalene
Carbon tetrachloride Acenaphthylene Nitrobenzene
Chlorobenzene Anthracene N-nitrosodi-n-propylamine
Chlorodibromomethane Benzidine N-nitrosodimethylamine
Chloroethane Benzo(a)anthracene N-nitrosodiphenylamine
2-chioroethylvinyl ether Benzo(a)pyrene Phenanthrene
Chloroform 3,4 benzofluoranthene Pyrene
Dichlorobromomethane Benzo(ghi)perylene 1,2,4-trichlorobenzene
1,1-dichloroethane Benzo(k)fluoranthene
1,2-dichloroethane Bis(2-chloroethoxy) methane
Reporting. Test results shall be reported electronically via eDMR or on DWR Form- DMR-PPA-1 (or
on a form approved by the Director) by December 31st of each designated sampling year. The report
shall be submitted to the following address:
NC DEQ/DWR/Central Files, 1617 Mail Service Center, Raleigh, North Carolina 27699-1617.
Additional Toxicity Testing Requirements for Municipal Permit Renewal. Please note that
Municipal facilities that are subjectto the Effluent Pollutant Scan requirements above q
s listed abo a are also
subject to additional toxicity testing requirements specified in Federal Regulation 40 CFR 122.21(j)(5).
6 of 12

DRAFT Permit NC0025453
The US EPA requires four (4) toxicity tests for a test organism other than the test species currently
required in this permit. The multiple species tests should be conducted either quarterly for a 12-month
period prior to submittal of the permit renewal application,or four tests performed at least annually in
the four and one half year period prior to the application. These tests shall be performed for acute or
chronic toxicity,whichever is specified in this permit. The multiple species toxicity test results shall be
filed with the Aquatic Toxicology Branch at the following address:
North Carolina Division of Water Resources
Water Sciences Section/Aquatic Toxicology Branch
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Contact the Division's Aquatic Toxicology Branch at 919-743-8401 for guidance on conducting the
additional toxicity tests and reporting requirements. Results should also be summarized in Part E
(Toxicity Testing Data) of EPA Municipal Application Form 2A,when submitting the permit renewal
application to the NPDES Permitting Unit.
A.(4.) CALCULATION OF TOTAL NITROGEN LOADS [G.S. 143-215.1(b)]
a. The permittee shall calculate monthly and annual TN Loads as follows:
i. 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
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.) ANNUAL LIMITS FOR TOTAL NITROGEN [G.S. 143-215.1(b)]
a. Total Nitrogen (TN) allocations and TN Load limits for NPDES dischargers in the Neuse River
basin apply on a calendar year basis.
b. For any given calendar year, the permittee shall be in compliance with the annual TN Load limit
in this Permit if:
i. the permittee's annual TN discharge is less than or equal to its TN Load limit,or
ii. the permittee is a co-permittee member of a compliance association.
c. If the permittee is not a co-permittee member of a compliance association and the permittee's
cumulative annual TN discharge exceeds the effective TN Load limit in this permit at any point
during the calendar year, the permittee is in violation of its TN Load limit,and each day of a
continuing violation shall constitute a separate violation.
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DRAFT Permit NC0025453
d. The TN Load limit in this Permit(if any) may be modified as the result of allowable changes in
the permittee's TN allocation.
i. Allowable changes include those resulting from purchase of TN allocation from the
Wetlands Restoration Fund;purchase,sale,trade,or lease of allocation between the
permittee and other dischargers; regionalization;and other transactions approved by the
Division.
ii. The permittee may request a modification of the TN Load limit in this Permit to reflect
allowable changes in its TN allocation. Upon receipt of timely and proper application,the
Division will modify the permit as appropriate and in accordance with state and federal
program requirements.
iii. Changes in TN limits become effective on January 1 of the year following permit
modification.The Division must receive application no later than August 31 for changes
proposed for the following calendar year.
iv. Application shall be sent to:
NCDWR/ NPDES Programs
Attn: Neuse River Basin Coordinator
1617 Mail Service Center
Raleigh, NC 27699-1617
e. If the permittee is a member and co-permittee of an approved compliance association,its TN
discharge duringthatyear isgoverned bythat association's groupNPDES permit and the TN
g
limits therein.
i. The permittee shall be considered a Co-permittee Member for any given calendar year in
which it is identified as such in Appendix A of the association's group NPDES permit.
ii. Association roster(s) and members' TN allocations will be updated annually and in
accordance with state and federal program requirements.
iii. If the permittee intends to join or leave a compliance association, the Division must be
notified of the proposed action in accordance with the procedures defined in the
association's NPDES permit.
(A) Upon receipt of timely and proper notification,the Division will modify the permit as
appropriate and in accordance with state and federal program requirements.
(B) Membership changes in a compliance association become effective on January 1 of the
year following modification of the association's permit.
f. The TN monitoring and reporting requirements in this Permit remain in effect until expiration of
this Permit and are not affected by the permittee's membership in a compliance association.
A.(6.) TOTAL NITROGEN ALLOCATIONS AND OFFSET CREDITS [G.S. 143-215.1(b)]
a. The following table lists the Total Nitrogen(TN) allocations and offset credits assigned to,
acquired by,or transferred to or from the permittee in accordance with the Neuse River nutrient
strategy (15A NCAC 02B.0700)and the status of each as of permit issuance.These allocations and
credits are not enforceable limits nor do they supersede any TN limit(s)established elsewhere in
this permit or in the NPDES permit of a compliance association of which the permittee is a Co-
permittee Member.
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DRAFT Permit NC0025453
ALLOCATION/CREDITS
ALLOCATION/ AMOUNT1
SOURCE DATE STATUS
CREDITS TYPE Estuary Discharge
(Ib/yr) (Ib/yr)
Base Allocation Assigned by Rule 2 12/7/97;4/1/03 10,700 21,400 Active
Supplemental Purchased from South Granville 7/5/06 3,668 7,336 Reserve
Allocation WSA(NC0026824)
1,645 3,290 Mixed
Supplemental Purchased from UNIFI-Kinston 8/30/2007 716 1,432 Active
Allocation (NC0003760) 929 1,858 Reserve
Offset Credits Purchased from X/X/2020 15,908 31,816 Reserve
Restoration Systems
TOTAL 31,921 63,842 Mixed
11,416 22,832 Active
20,505 41,010 Reserve
Footnote:
1. Transport Factor=50%.Values are displayed to the nearest pound per year.
2. 15A NCAC 02B .0713(formerly 02B.0234)
3. The Permittee purchased offset credits in the amount of 715,858.18 lb/yr TN,or 23,861.94 Ib/yr,expressed
as estuary load.To satisfy the 1.5:1 uncertainty ratio(Rule .0713),15,907.96 lb/yr of credits are available to
the Permittee.The remaining 7,953.98 lb/yr are set aside for the benefit of the estuary and are not available
to offset any activity,whether point source or nonpoint source in nature.
b. Any addition, deletion, or modification of the listed allocations and credits (other than
typographical errors) or any change to Active status of any of the listed allocations and credits
shall be considered a major modification of this permit and shall be subject to the public review
process afforded such modifications under state and federal rules.
A.(7.) ELECTRONIC REPORTING OF MONITORING REPORTS [G.S. 143-215.1(b)]
Federal regulations require electronic submittal of all discharge monitoring reports (DMRs) and
program reports.The final NPDES Electronic Reporting Rule was adopted and became effective on
December 21, 2015.
NOTE: This special condition supplements or supersedes the following sections within Part II of this
permit (Standard Conditions for NPDES Permits):
• Section B. (11.) Signatory Requirements
• Section D. (2.) Reporting
• Section D. (6.) Records Retention
• Section E. (5.) Monitoring Reports
1. Reporting Requirements [Supersedes Section D. (2.) and Section E. (5.) (a)!
The permittee shall report discharge monitoring data electronically using the NC DWR's Electronic
Discharge Monitoring Report (eDMR) intemet application.
Monitoring results obtained during the previous month(s) shall be summarized for each month and
submitted electronically using eDMR. The eDMR system allows permitted facilities to enter
monitoring data and submit DMRs electronically using the internet. Until such time that the state's
eDMR application is compliant with EPA's Cross-Media Electronic Reporting Regulation
9 of 12

DRAFT Permit NC0025453
(CROMERR),permittees will be required to submit all discharge monitoring data to the state
electronically using eDMR and will be required to complete the eDMR submission by printing,
signing,and submitting one signed original and a copy of the computer printed eDMR to the
following address:
NC DEQ/ Division of Water Resources/ Water Quality Permitting Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh,North Carolina 27699-1617
If a permittee is unable to use the eDMR system due to a demonstrated hardship or due to the
facility being physically located in an area where less than 10 percent of the households have
broadband access, then a temporary waiver from the NPDES electronic reporting requirements
may be granted and discharge monitoring data may be submitted on paper DMR forms (MR 1,1.1,
2,3) or alternative forms approved by the Director. Duplicate signed copies shall be submitted to
the mailing address above. See"How to Request a Waiver from Electronic Reporting" section
below.
Regardless of the submission method,the first DMR is due on the last day of the month following
the issuance of the permit or in the case of a new facility,on the last day of the month following the
commencement of discharge.
Starting on December 21,2020, the permittee must electronically report the following compliance
monitoring data and reports,when applicable:
• Sewer Overflow/Bypass Event
Reports;
• Pretreatment Program Annual Reports;and
• Clean Water Act(CWA)Section 316(b) Annual Reports.
The permittee may seek an electronic reporting waiver from the Division (see"How to Request a
Waiver from Electronic Reporting" section below).
2. Electronic Submissions
In accordance with 40 CFR 122.41(1)(9), the permittee must identify the initial recipient at the time
of each electronic submission. The permittee should use the EPA's website resources to identify the
initial recipient for the electronic submission.
Initial recipient of electronic NPDES information from NPDES-regulated facilities means the entity
(EPA or the state authorized by EPA to implement the NPDES program) that is the designated
entity for receiving electronic NPDES data [see 40 CFR 127.2(b)].
EPA plans to establish a website that will also link to the appropriate electronic reporting tool for
each type of electronic submission and for each state. Instructions on how to access and use the
appropriate electronic reporting tool will be available as well. Information on EPA's NPDES
Electronic Reporting Rule is found at:
https://www.federalregister.gov/documents/2015/10/22/2015-24954/national-pollutant-
discharge-elimination-system-npdes-electronic-reporting-rule
Electronic submissions must start by the dates listed in the"Reporting Requirements" section
above.
3. How to Request a Waiver from Electronic Reporting
The permittee may seek a temporary electronic reporting waiver from the Division. To obtain an
electronic reporting waiver,a permittee must first submit an electronic reporting waiver request to
10 of 12

DRAFT Permit NC0025453
the Division. Requests for temporary electronic reporting waivers must be submitted in writing to
the Division for written approval at least sixty (60) days prior to the date the facility would be
required under this permit to begin submitting monitoring data and reports. The duration of a
temporary waiver shall not exceed 5 years and shall thereupon expire. At such time, monitoring
data and reports shall be submitted electronically to the Division unless the permittee re-applies for
and is granted a new temporary electronic reporting waiver by the Division. Approved electronic
reporting waivers are not transferrable. Only permittees with an approved reporting waiver
request may submit monitoring data and reports on paper to the Division for the period that the
approved reporting waiver request is effective.
Information on eDMR and the application for a temporary electronic reporting waiver are found on
the following web page:
http://deq.nc.gov/about/divisions/water-resources/edmr
4. Signatory Requirements[Supplements Section B. (11.) (b) and Supersedes Section B. (11.) (d)1
All eDMRs submitted to the permit issuing authority shall be signed by a person described in Part
II,Section B. (11.)(a) or by a duly authorized representative of that person as described in Part II,
Section B. (11.)(b). A person,and not a position,must be delegated signatory authority for eDMR
reporting purposes.
For eDMR submissions, the person signing and submitting the DMR must obtain an eDMR user
account and login credentials to access the eDMR system. For more information on North
Carolina's eDMR system, registering for eDMR and obtaining an eDMR user account,please visit
the following web page:
http://deq.nc.gov/about/divisions/water-resources]edmr
Certification. Any person submitting an electronic DMR using the state's eDMR system shall make
the following certification [40 CFR 122.221. NO OTHER STATEMENTS OF CERTIFICATION WILL
BE ACCEPTED:
"1 certify, under penalty of law, that this document and all attachments were prepared under my direction or
supervision in accordance with a system designed to assure that qualified personnel properly gather and
evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or
those persons directly responsible for gathering the infornuition, the information submitted is, to the best of my
knowledge and belief true,accurate,and complete.I am aware that there are significant penalties for submitting
false information, including the possibility of fines and imprisonment for knowing violations."
5. Records Retention[Supplements Section D. (6.)1
The permittee shall retain records of all Discharge Monitoring Reports,including eDMR
submissions. These records or copies shall be maintained for a period of at least 3 years from the
date of the report. This period may be extended by request of the Director at any time [40 CFR
122.411.
11 of 12

Permit No. NC0025453
-
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Little Creek WRF—NC0025453 Facility Location (not to scale)
Town of Clayton -
Receiving Stream: Meuse River Stream Class: WS-IV,
Drainage Basin: Neuse River Basin NSW CA 1 T
Permitted Flow: 2.5 Mal Sub-Basin: 03-04-02 Iv
State Grid/USGS Quad: E2SNW,Clayton HUC: 0320201
Latitude 35'39'50' Longitude 73'25'26"

AttachmentG
Engineering Report

This page intentionally left blank.

CH2M HILL North Carolina,Inc.
111 Corning Road,Suite 200
elk Cary,North Carolina 27518
2411/10
M United States
T+1.919.859.5000
www.jacobs.com
September 9, 2020
Subject:Town of Clayton NPDES Permit Modification Application Engineering Alternatives Analysis
The following attachment has been included to satisfy the Engineering Alternative Analysis(EAA)
portion of the NPDES permit modification application.It is comprised of sections taken from the ER-
EID submitted to NCDEQ for the Town of Clayton's WRF Expansion Project.To supplement the Flow
Projections requirement the Town's most recent projection update has also been included (Town of
Clayton Wastewater Forecast Update, 2020).
Contained in the selected ER-EID sections you will find:
Project Description—Sections 1.1 & 1.2
Population 20-year Projections—Section 3.1
Flow 20-year Projections—Section 3.2
Technological Feasibility of Alternatives
Alternative A—Section 5.1.4
Alternative B—Section 5.1.5
Alternative C—Section 5.1.6
Alternative D—Section 5.1.2.1
Alternative E—Section 5.1.9
Economic Feasibility of Alternatives
Alternative B—Section 5.2.2.4
Alternative D—Section 5.2.2.1
Summary Table—Section 5.2.3
The Town has also received Speculative Limits for this facility using the Town's current outfall.The
Town is preparing an updated model file to support the addition of seasonal limits to the future
permit.
Applicant Information:
JD Solomon,Town Manager
111 East Second Street
Clayton, NC 27528
[phone]
[e-mail]
Facility Information:
Neuse River Water Reclamation Facility(New Facility)
1422 North O'Neil Street
Clayton,Johnston County, NC 27520
Contact:James Warren, Superintendent
[phone]
jowarren antownofclaytonnc.orq

REVISED SUBMITTAL
Town of Clayton Water Reclamation
Facility Capacity Expansion
CS370431-07
ENGINEERING REPORT AND
ENVIRONMENTAL IMPACT DOCUMENT
Prepared for
Town of Clayton o��f ° y9
cif;
$33
1 c3 T'
September 9, 2020 / "�
A f3ME :.
A. G0
Prepared by
Ch2A41/.
M
CH2M HILL North Carolina, Inc.
111 Corning Road
Cary, NC 27518

SECTION 1
Executive Summary
1. 1 Project Description
Clayton is located in Johnston County, North Carolina. The Town of Clayton (Town) has initiated the
process to expand the Town's wastewater treatment capacity, which is currently 4.9 million gallons per
day (MGD) via its Little Creek Water Reclamation Facility (LCWRF) and wholesale contracts with
Johnston County (County) (for 1.4 MGD with the Johnston County Regional Wastewater Treatment Plant
[JCRWWTP]) (County and Town, 2005, 2006) and the City of Raleigh (City) (for 1.0 MGD with the Neuse
River Wastewater Treatment Plant [NRWWTP]) (City and Town, 2007).
The Town is planning a phased approach to meet current and projected demands, beginning with
construction of a new 6-MGD treatment facility.
The proposed project includes the following major components:
• New 6-MGD water reclamation facility (WRF) constructed on a Town-owned site adjacent to the
Neuse River and including the Town's existing outfall as a first phase, with anticipated incremental
expansion to 10 MGD to meet future needs
• Abandonment of the Town's existing LCWRF
• Construction of a pump station at the LCWRF site and associated Little Creek (LC) Transmission Main
infrastructure to convey flow to the new WRF (WithersRavenel, 2020a)
A Project Vicinity Map is included as Figure 1-1, and a Project Location Map is included as Figure 1-2.
These maps also show a separate project also being planned by the Town, expansion of the Town's
existing East Clayton Industrial Area (ECIA) pump station and construction of the ECIA Transmission
Main to convey flow to the new WRF (Town, 2020f).This separate project is separately funded and
permitted as part of the Town's overall master planning to meet future needs.
1.2 Reasons for the Project
The Town is seeking to replace existing capacity and prepare for known increasing near-term demands
with construction of a 6-MGD WRF. This plan is needed because of the LCWRF's aging infrastructure,
expiration of its contract with the County, and known near-term demands. The Town is also planning to
meet future rising demands through 2040. A recent capacity study indicated that the Town will require
approximately 10 MGD in total wastewater treatment capacity over the next 20 years to meet future
needs, including major increases in industrial flow from industrial and commercial customers (Wooten,
2018). The Town is planning a phased approach to meet this expected demand, with an initial step to
reach 6 MGD.

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Figure 1-1
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Miles I Water Reclamation Facility Expansion
Town of Clayton, NC

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Figure 1-2
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I I I
Water Reclamation Facility Expansion
Feet Town of Clayton, NC

SECTION 3
Future Situation
The Town's MM ADF is approaching 80 percent of its available total permitted capacity. With residential
growth occurring and industries notifying the Town of upcoming expansions,the Town is planning to
implement next steps to increase treatment capacity, as described in this section.
3. 1 Population Projections
Expected population growth in the Town's service area (the project study area) is typical of the growth
being experienced in the greater Raleigh metropolitan area.The Census released a population estimate
of 22,850 for Clayton in 2018 and 24,887 in 2019 (Census, 2019). The estimated 2040 Clayton service
area population is 70,870(Table 3-1). These service area population numbers are higher than the
current population served, as not all residents have public water and wastewater services.The Town is
expanding its service into the ETJ as development occurs.
Table 3-1. Projected Annual Town of Clayton and Extra-Territorial Jurisdiction Population Totals
Year Town Population a ETJ Population b Total Residential Population
2010 16,116` 10,930 27,046
2018 22,850` 14,170 37,020
2019 24,887` 15,180 40,067
2020 25,630 15,580 41,210
2021 26,400 15,960 42,360
2022 27,190 16,350 43,540
2023 28,010 16,760 44,770
2024 28,850 17,170 46,020
2025 29,710 17,590 47,300
2026 30,600 18,020 48,620
2027 31,520 18,470 49,990
2028 32,470 18,920 51,390
2029 33,440 19,390 52,830
2030 34,440 19,870 54,310
2031 35,480 20,300 55,780
2032 36,540 20,740 57,280
2033 37,640 21,190 58,830
2034 38,770 21,650 60,420
2035 39,930 22,120 62,050
2036 41,130 22,640 63,770
2037 42,360 23,170 65,530
2038 43,630 23,720 67,350
3-1

SECTION 3—FUTURE SITUATION
Table 3-1. Projected Annual Town of Clayton and Extra-Territorial Jurisdiction Population Totals
Year Town Population a ETJ Population b Total Residential Population
2039 44,940 24,280 69,220
2040 46,290 24,580 70,870
a Escalated from 2019 Census data using an estimated annual growth rate of 3%.
b Estimated using relationship between Clayton and Planning Area population(LandDesign,2015);Town
annexations have expanded Clayton limits into the ETJ over time.
Clayton population(Census,2019)
This population growth is evident in the Town Planning Department's requests for approvals for
additional housing units. In recent years, the Town has approved approximately 40-50 units per month,
or just under 500 units per year.Table 3-2 shows the housing units approved by the Town but not yet
built. These units are expected to be occupied by 2025 (Town, 2020c).
Table 3-2. Housing Unit Growth in the Town of Clayton
Units Total
Housing Units Built from 2015—2020 a 4,499
Housing Units Entitled from 2015—2020 9,406
Housing Units Entitled but Not Yet Built and Expected to be Served by 2025 4,907
Source:Town,2020c
a Data through April 2020
3.2 Flow Projections
While it is typical to base flow projections on population growth, there are unique aspects of the Town's
customer base that led to an alternative flow projection approach being employed. In the standard
approach presented in the ER and EID guidance and workbook (NCDEQ 2015), industrial flow is
estimated at 10 percent of the combined residential and commercial flow. For Clayton, industrial
development, which is concentrated in the ECIA, is significantly more that 10 percent of the total, and
major industries have shared their future flow expectations. Use of the ER and EID flow projection
method would result in underestimating current and future industrial treatment demands within the
Town's system;therefore, a different approach to developing a flow projection was required.
The current flow projection approach was originally developed as part of a conveyance optimization
project(CH2M, 2013) by first dividing the Town's service area into different zones, and then assessing the
current and projected flows for each zone. This allowed for higher growth projections for faster growing
zones where new development predominated, and slower growth in more established areas where infill
development was more likely. Pump station capacities and runtimes were analyzed to develop initial flows
for each zone, and the individual zone growth rates were then applied. When specific industrial flow
expectations were known, they were included directly in the flow estimate.This was applied in the ECIA,
where specific Grifols and Novo Nordisk flow projections were included (CH2M, 2020).
The flow projections included a probabilistic aspect, whereby several inputs were allowed to vary to
create an envelope of potential future flows, to allow the Town deeper insight into the important
factors behind future growth. For the residential component of flows, the Town understands the near-
term potential for growth because of housing units approved but not yet built. Uncertainty around the
potential growth increases into the future was incorporated into the forecast.The probabilistic model
provides flow projection for the 5`h-95`h percentile estimate, representing the range from low to high
3-2

SECTION 3—FUTURE SITUATION
growth scenarios. Details of this approach are presented in the conveyance optimization project
summary report, which is included as Appendix F.
The current flow projection reflects known and anticipated changes to existing flows and future
industrial demands, and incorporates uncertainty associated with growth forecasts in the ETJ and the
Town's Municipal Service Boundary, including potential for wholesale customers. Uncertainty in
industrial growth is also captured in the projection. Industrial and commercial flows were projected with
input from the Town's long-term industrial customers and expected growth in the commercial sector
that typically follows residential growth patterns. These facilities continue to invest and expand their
production capabilities, increasing industrial demands.
Figure 3-1 depicts the projected residential, industrial, and commercial wastewater forecast through
2040 against the available capacity.Table 3-3 summarizes the projected flows. Permitted capacity of the
Town's existing LCWRF is 2.5 MGD and is presented in light green. The Town's total treatment capacity,
including regional contracts, is depicted with a 1.0-MGD drop in the Town's total capacity in 2027 due to
the expected expiration of the agreement with the City.The Town recognizes that expected total
wastewater flows will exceed the Town's capacity before 2025.
The Town's residential growth is steadily increasing. In addition, industrial facilities in the ECIA are
investing in expansions.These facilities are in close coordination with the Town regarding those
expansions. An increase in flow from approved ECIA facility expansions is expected in 2023, pushing the
Town's wastewater treatment demands close to the currently available treatment capacity of 4.9 MGD
before 2025. So while the Town is not yet at 80 percent of its current capacity, the need to increase
treatment capacity requires the Town to plan its next steps now.
10.0
9.0
8.0
7.0
—6.0
0
2 5.0
`L 4.0
3.0
2.0
1.0
2015 2020 2025 2030 2035 2040
Year
---Total Historical Demand(2015-2019) —Total Forecast Demand
—Clayton Total Capacity LC WRF Permitted Capacity
Figure 3-1.Town of Clayton Wastewater Maximum Month Flow Forecast
3-3

SECTION 3-FUTURE SITUATION
Table 3-3. Projected Wastewater Maximum Month Flow Forecast
Residential and Commercial Flow Industrial Flow Total Flow
1 Year (MGD) (MGD) (MGD)
2020 2.49 1.27 3.76
2021 2.50 1.27 3.77
2022 2.51 1.27 3.79
2023 2.72 1.84 4.56
2024 2.76 1.94 4.70
2025 2.80 2.94 5.74
2026 2.84 2.94 5.78
2027 2.88 2.94 5.82
2028 2.93 3.30 6.22
2029 2.97 3.30 6.27
2030 3.16 3.80 6.96
2031 3.23 4.05 7.27
2032 3.30 4.05 7.35
2033 3.37 4.05 7.42
2034 3.70 4.51 8.21
2035 4.15 4.76 8.91
2036 4.31 4.76 9.07
2037 4.36 4.76 9.12
2038 4.42 4.76 9.18
2039 4.49 4.76 9.25
2040 4.56 4.76 9.32
Source:CH2M,2020
3-4

SECTION 5-ALTERNATIVES ANALYSIS
5.1.4 Alternative 4: Continued Use of Little Creek Water Reclamation Facility,
Maximizing Regional Connections to Existing Wastewater Treatment
Under this alternative, the Town would reach agreement with the County and the City to expand
contracts for the existing infrastructure connections while maintaining operation of the LCWRF to meet
future projected demands.These utilities are currently unwilling to reach these types of long-term
agreements with terms that are cost-effective for the Town.This alternative was included because it
could be technically feasible if cost-effective agreements were reached.
Additional conveyance capacity is likely necessary; details would be determined depending on which
regional contract would be increased.An expansion of the existing outfall into the Neuse River would
not be necessary.
Components of this alternative include:
• Maximized expansion of regional contracts and existing conveyance capacity with the City and
County to 4 MGD total
• Continued use of the LCWRF and investment in aging treatment system components
• Addition of denitrifiying filters to LCWRF to improve the level of TN removal and increase
operational capacity to the permitted 2.5 MGD
• Continued use of the LCWRF discharge into the Neuse River
Other components include permitting and building conveyance infrastructure from ECIA to the
1CRWWTP, permitting and building additional conveyance infrastructure to the NRWWTP, or some
combination of these.
Under this alternative, increased regional contracts for treatment capacity in the amount of
approximately 4 MGD would be necessary. Both the County and City are raising rates, and both are
experiencing their own increasing demands.The County has stated that it will only accept domestic-
strength waste (lower TDS) beginning in 2022.
This alternative is not considered feasible because, to date, the Town has been unable to reach
cost-effective agreements with these utilities. It is also highly unlikely that this alternative would be able
to meet the Town's long-term planning for 10 MGD of treatment capacity.
5.1.4.1 Design Criteria
This alternative includes limited improvements to the LCWRF to increase the facility treatment capacity
to 2.5 MGD (current permitted capacity). Process improvements include rehabilitation of existing
treatment systems and the construction of denitrification filters to comply with NPDES discharge limits
to the Neuse River.
The existing treatment system structures (that is, the oxidation ditch and clarifiers)are approximately
30 years into their expected minimum 50-year useful life and in good condition; therefore, near-term
rehabilitation of existing LCWRF treatment system components include the following systems and
processes:
• Grit removal
• Influent pumping
• Oxidation ditch aerators and VFDs
• RAS and WAS pumping
• Effluent pumping
• Reclaimed water pumping
• Plant water pumping
5-21

SECTION 5-ALTERNATIVES ANALYSIS
• Sludge thickener and associated pumping
• Sludge holding blowers
• Electrical system, including generators and transformers
Table 5-8 provides the design criteria for the denitrification filtration system.
Table 5-8.Denitrification Filtration System Design Criteria
Component Value
Type Deep bed granular media filter
No.of Units(duty and standby) 5 and 1
Depth,ft 6
Capacity,MGD(each) 0.54(average)and 1.5(peak)
Average Hydraulic Loading Rate,gpm/ft2 1.5
Peak Hydraulic Loading Rate,gpm/ft2 3.0
Carbon Feed System
Carbon Feed Dose Rate,mg/L 18
No.of Tanks 1
No.of Pumps 2
5.1.4.2 Environmental Considerations
Temporary and some permanent impacts would occur with construction of linear infrastructure.The
LCWRF resiliency from flood impacts and reliability with aging infrastructure is a risk for the Town that
would need to be remedied. Environmental impacts under this alternative are greater than the
Preferred Alternative,given the impacts of the additional infrastructure that would be required to
convey flow to either JCRWWTP or NRWWTP.
5.1.4.3 Cost Estimate
As this alternative is not considered to be feasible, the estimated capital cost and total present worth of
this option have not been calculated.
5.1.4.4 Acceptance or Rejection
The County and the City are the only neighboring utilities that would be options for contracting capacity.
This alternative is not considered feasible because,to date, the Town has been unable to reach
long-term agreements with these utilities.
The County has made the decision to not accept any wastewater with characteristics exceeding
domestic-strength limits. This eliminates the use of the County contract for increasing flows from the
ECIA Pretreatment Facility.The City intends to increase the fees associated with the current contract
capacity as high as 40 percent in 2020 and has proposed new fees and charges for any additional
capacity beyond the currently contracted 1.0 MGD. It is also highly unlikely that this alternative would
be able to cost-effectively meet the Town's long-term planning for 10 MGD of treatment capacity.This
alternative was eliminated from the evaluation. Present worth cost for Alternative 4 was not calculated.
5-22

SECTION 5-ALTERNATIVES ANALYSIS
5.1.5 Alternative 5: Construction of a New Water Reclamation Facility, and Use
of Land Application
Under this alternative, the Town would build a new 6-MGD WRF, with plans for future incremental
expansion to 10 MGD, as described in Section 5.1.2.1.The effluent discharge location at the Neuse River
would be abandoned, and the WRF treated effluent disposal would be diverted to suitable locations for
spray irrigation. Land application nutrient removal requirements are less stringent than for surface
water discharge, and the purchase of nitrogen credits in the Neuse River basin would be reduced or not
necessary.The Town currently provides a small amount of reuse water to the Pine Hollow Golf Course;
however, demand is seasonal, and other land application sites would be necessary. For this evaluation,
the Neuse 2 Pump Station site was used as the new WRF site.The amount of land necessary for land
application was estimated using area soil conditions.
Once a new WRF is online, the land application of effluent would include the construction of
transmission infrastructure, storage ponds, and land application facilities at the dedicated land
application site. Other components of this discharge alternative would include:
• Identification of other land application sites for additional effluent disposed using spray irrigation
• Retention of regional contracts as capacity backup after 2023, but minimization of flow to the City
and the County
• Plan for future expansion of the facility to 10 MGD as flows increase
Due to the less-stringent effluent treatment requirements associated with land application (NCAC 15A
NCAC 02T.0505), certain elements of the WRF as described in Section 5.1.2.1 can be eliminated from the
design, including tertiary treatment (effluent filtration) and supplemental carbon feed.
Preliminary estimates for the application rate, application area, and onsite storage capacity were
calculated.The preliminary loading rate for soils in the area is 1.5 inch per week per acre. Based on the
potential for extended wet periods in the spring and summer months in the county, 30 days of storage
was assumed.The total acreage required to land apply 6 MGD has been calculated as 1,300 acres.
Based on a preliminary review of open land near the Town, finding a suitable land application site with
adequate capacity for the total plant flow of 6 MGD within a reasonable distance of the new WRF will
prove difficult. For the basis of cost estimating and assessment of potential impacts, it has been assumed
that multiple (three) land application sites would be required and would be within 10 miles of the WRF site.
Considerations for this alternative include:
• Available land with suitable soils
• Pump stations at the WRF to send flows to the land application sites
• Conveyance from the pump station to the land application sites
• Lined storage point and irrigation pump at each site
• Solid-set sprinkler application system
• Site development costs, including:
— Clearing
— Crop establishment
— Access roads
— Fencing
— Monitoring wells
• Land purchase costs
5-23

SECTION 5—ALTERNATIVES ANALYSIS
5.1.5.1 Design Criteria
The new WRF under this alternative is subject to the same influent flow and load conditions detailed in
Section 5.1.2.1. Due to the less-stringent effluent treatment requirements associated with land
application, the following elements of the WRF as described in Section 5.1.2.1 can be eliminated from
the design:
• Tertiary treatment(effluent filtration)
• Supplemental metal salt feed
• Supplemental carbon feed
• Reduction in bioreactor volume
This design induces the flowing components for land application of the new WRF effluent:
• Reclaimed water storage reservoir
• Reclaimed water transfer pump station and transmission pipe
• Land application site distribution pump stations
• Irrigation piping and sprinkler application system
Table 5-9 provides the design criteria for the land application discharge system.
Table 5-9.Land Application System Design Criteria
Component Value
Reclaimed Water Storage and Transfer System
Reservoir
Type Earthen,lined
Volume,MG 20
Pump Station
Type Centrifugal
No.of Pumps(duty and standby) 2 and 1
Transmission Pipe
No.of Pipes 1
Diameter,inches 24
Length,LF 132,000
Material Concrete-lined DI pipe
Land Application Sites
No.of Sites 3
Storage Reservoir
Type Earthen,lined
No.of Reservoirs 3
Volume,MG(each) 68.3
Irrigation Distribution Pump Stations
No.of Pump Stations 3
5-24

SECTION 5-ALTERNATIVES ANALYSIS
Table 5-9. Land Application System Design Criteria
Component Value
Type Vertical turbine
No.of Pumps(each station,duty and standby) 2 and 1
Irrigation Mains
Diameter,inches 16
Length,LF(total) 15,000
Material DR 18 PVC
Notes:
DI=ductile iron
DR=dimension ratio
PVC=polyvinyl chloride
5.1.5.2 Energy Conservation
This alternative will incorporate moderate water and energy conservation measures by using treated
effluent for process washdown water and VFDs for rotating equipment. Given the long distance that
effluent would be conveyed the overall energy consumption of this alternative would be much higher
than the Preferred Alternative.
5.1.5.3 Environmental Considerations
Temporary and some permanent impacts would occur with construction of linear infrastructure,
including lines to convey effluent to the land application sites. Operations would be carefully monitored
to avoid impacts to soils and land uses, such as accumulation of salts in the soils over time. Operations
would also monitor runoff rates so that adjacent surface waters are not impacted by nutrient loading.
Environmental impacts under this alternative are less than the Preferred Alternative, as this alternative
would eliminate a surface water discharge.
5.1.5.4 Cost Estimate
The estimated total capital cost of Alterative 5 is$186,800,000.This cost includes 10 percent
contingency applied to the construction costs and all estimated administrative costs for the project.This
cost includes 6-MGD treatment capacity, as described in Section 5.1.2.1.The cost was estimated by
eliminating the cost of the tertiary treatment system, the supplemental carbon system, and outfall
upgrades from the cost presented in Section 5.1.2.1.
The estimated total present worth cost of the new WRF with the land application is$225,201,816.
5.1.5.5 Acceptance or Rejection
Alternative 5 received a score of 3.28, the lowest nonfinancial score of the six feasible alternatives. Refer
to Appendix G for details on the scoring of each alternative in the nonfinancial evaluation.This
alternative received a high score under the Increase the Town's control over the cost of treatment and
Resiliency from climate impacts nonfinancial criteria but received the low scores in the following criteria:
• Environmental impacts
• Land use compatibility or improvement
• Maximum use of existing assets
• Adaptability and phasing
5-25

SECTION 5—ALTERNATIVES ANALYSIS
Alternative 5, construction of a new 6-MGD WRF with land application provides the least long-term
benefit to the Town.
This alternative will also incorporate moderate water and energy conservation measures by using
treated effluent for process washdown water and VFDs for rotating equipment. However,this
alternative requires significantly more pumping to convey treated effluent to the land application sites;
therefore, energy and water conservation are less than the Preferred Alternative.
While there are sites with suitable soils available to the Town for this alternative to be feasible, costs
were estimated using the required acreage and an estimated conveyance distance of 10 miles.Although
the cost of treatment under this alternative reduces the cost of a new WRF and eliminates the need to
expand the outfall into the Neuse River,the costs associated with conveyance of the effluent,the land
application site, and O&M significantly increase the overall cost of the project compared to other
alternatives.This alternative also likely has less feasibility to meet the Town's long-term needs of
10 MGD of treatment capacity when compared to the Preferred Alternative. Given the costs of land
application and the limited availability of land, this alternative was dismissed from further consideration.
5.1.6 Alternative 6: Construction of a New Water Reclamation Facility, and
Implementation of Larger-scale Wastewater Reuse
Under this alternative, the Town would build a new 6-MGD WRF, with the potential to incrementally
expand to 10 MGD, as described in Section 5.1.2.1.Additionally, the Town would build a customer base
to support wastewater reuse of effluent.The Town has a limited reuse program and currently provides a
small amount of reuse water to a single golf course; however, demand is seasonal. Based on analysis of
LCWRF flow records,the average flow provided to the golf course over the period 2015—2018 was
11.4 MG per year, spread over a 7-or 8-month period each year.This is a functional equivalent of
0.05 MGD while operating.To evaluate this alternative,the Neuse 2 WRF site alternative was used
because the Town owns the land.
For large-scale reuse to be feasible and practical to the Town, available land for irrigation (such as golf
courses) or large industrial users would need to be available within a reasonable distance of the WRF
and have year-round demands. Based on an initial review of potential effluent reuse sites, two
additional golf courses were identified within a reasonable distance from the WRF. Using the
assumption that those golf courses would require a similar amount of irrigation water as the existing
reuse customer,the total expected to be used for irrigation would be 0.15 MGD of seasonal demand.
The largest industrial users in Clayton's ETJ are in the ECIA.The Town reached out to the two largest
pharmaceutical manufacturers to assess their potential as reuse customers. Each facility has
environmental sustainability programs in place to conserve water and energy, as listed in Table 5-10.
Under these programs, each facility's water cycle conserves and reuses water where possible.As a
result, the amount of water purchased is minimized and leaves little opportunity for additional outside
purchase of reuse water.
Table 5-10.Water Conservation Programs of East Clayton Industrial Area Facilities
Novo Nordisk Practicesa• Grifols Practicesb
Capture of RO reject water and HVAC condensate for reuse Replacement of RO units with units that generate much less
in cooling towers reject
Installation of efficient fixtures,including ultra-low-flow Capture of RO reject water,blowdown water,final rinse
toilets(1.0 gallon per flush)and waterless urinals water from clean-in-place systems,and air conditioning
condensate for reuse in cooling towers
Use of closed-loop cooling systems to reduce water Upgrade of a vacuum pump with reservoir vessel to eliminate
demands continuous run,saving—1.6 MGD per year
5-26

SECTION 5—ALTERNATIVES ANALYSIS
Use of steam systems with 100%condensate on dirty Use of water meters and inspections to detect leaks or
stream return malfunctions and repair quickly
Use of heat exchangers on high-temperature processes to Increase of time between water use for injection system
limit cooling demands and reduce evaporate losses sanitization cycles,and decrease of cycle time to save water
Use of water meters and inspections to detect leaks or Use of native vegetation to reduce irrigation demands
malfunctions and repair quickly
Use of native vegetation to reduce irrigation demands -
a Kuntz,pers.comm.,2020
b Grifols,pers.comm.,2020
Notes:
=approximately
HVAC=heating,ventilation,and air conditioning
RO=reverse osmosis
5.1.6.1 Design Criteria
The new WRF under this alternative is subject to the same flow and load characteristics detailed in
Section 5.1.2.1.Treatment system design criteria detailed in Tables 5-3 and 5-4 remain unchanged in
this alternative.
5.1.6.2 Environmental Considerations
An increase in discharge to the Neuse River would be avoided. Other, mostly temporary impacts would
occur with construction of linear infrastructure, including to the reuse locations.This alternative, if
feasible, could also lower potable water demand or groundwater usage by the reuse customers, and this
would be beneficial to the environment. Environmental impacts of this alternative are less than the
Preferred Alternative, as this alternative would eliminate a surface water discharge.
5.1.6.3 Cost Estimate
As this alternative is not considered to be feasible, the estimated capital cost and total present worth of
this option have not been calculated.
5.1.6.4 Acceptance or Rejection
With the sustainability programs already in place, limited potential exists for the large-scale reuse of
wastewater by industrial users in the ECIA. Other irrigation customers only generate seasonal demands
and likely total approximately 0.15 MGD. Given the limited nature of potential industrial and golf course
irrigation demand, development of a reuse system that could eliminate the need for a treated surface
water discharge from the WRF is not feasible. Large-scale wastewater reuse is, therefore, not a viable
alternative to expanding wastewater capacity.This alternative was dismissed from further
consideration.
5-27

SECTION 5-ALTERNATIVES ANALYSIS
5.1.2 Alternative 2: Construction of a New Water Reclamation Facility, and
Continued Use of Surface Water Discharge
Under this alternative, the Town would build a new 6-MGD WRF with potential for future incremental
expansion to 10 MGD. Two sites have been considered under this alternative: the Neuse 2 Pump Station
site (Alternative 2a) and the site of the ECIA Pretreatment Facility (Alternative 2b).
The following project components are common among the two sites considered:
• Continued use of the LCWRF, understanding limited treatment capacity of 2 MGD until the new
facility is online
• Decommissioning of LCWRF and conversion of the site use to a new pump station to convey 3-MGD
ADF
• Continued reliance on regional contracts with the City and County through 2023
• Retention of regional contracts as backup after 2023; minimization flow to the City and County
• Expansion of the LCWRF surface water discharge to the Neuse River at the Neuse 2 Pump Station
site
• Planning for future incremental expansion of the facility to 10 MGD as flows increase
Under this alternative, the contract with Pine Hollow Golf Course for reuse water will be terminated
after the construction of the new WRF due to the distance between the golf course and the new WRF.
5.1.2.1 Alternative 2a: Construction of a New Water Reclamation Facility at the Neuse 2 Pump
Station Site
Under this alternative, the Town would build a new 6-MGD WRF at the Neuse 2 Pump Station site, with
potential for future incremental expansion to 10 MGD.The Town-owned parcel with the Neuse 2 and
Clayton to Raleigh Pump Station and LCWRF Neuse River discharge into the Neuse River is of sufficient
size for the construction of a new 6-MGD WRF and could maintain stream and property buffers and
avoid the floodplain along the Neuse River. Public greenway infrastructure along Sam's Branch and the
Neuse River could remain available to the community. Connecting infrastructure would be necessary,
including conversion of the LCWRF to a pump station.
This site is more centrally located to the Town's operation and to most expected development within
the Town's ETJ. Other site improvements necessary for the WRF include a construction access road and
water service line. Easements through adjacent properties may be necessary for this infrastructure.
Construction of a new WRF would include the following elements:
• IPS
• Odor control
• Headworks (screening and grit removal)
• Flow equalization, which will reduce peak hour to peak day flow for follow-on treatment systems
• Five-stage biological treatment for nitrogen and phosphorus removal
• Supplemental carbon for enhanced nitrogen removal
• Supplemental metal salts for backup and polishing of phosphorous removal
• Cloth media (disc) tertiary filtration
• UV disinfection
• Cascade re-aeration
• Solids treatment, including:
— Thickening with RDTs
— 30-day aerated sludge holding
1

SECTION 5-ALTERNATIVES ANALYSIS
— Dewatering with screw press
• Effluent outfall to Neuse River
Figure 5-1 shows the proposed new WRF layout at the Neuse 2 Pump Station site.
Design Criteria
This section describes the WRF unit process design criteria.
The new 6-MGD WRF is expected to serve the Town's initial wastewater treatment capacity needs from
both residential, industrial, and commercial customers and allow the Town to expand incrementally to
10 MGD to meet future demands as needed.The new WRF will be designed to an MM flow of 6 MGD;
Table 5-1 lists the design flows.
Table 5-1. Design Flows
Combined Plant Influent
Metric (MGD)
ADF 5.25
MM ADF 6.0
Peak Day 9.7
PHF 11.2 a.
a Flow equalization will reduce the incoming PHF(11.2MGD)to peak day(9.7 MGD)for the secondary and
tertiary treatment systems.
Notes:
PHF=peak hour flow
Peaking factors used to develop the flows presented in Table 5-1 were determined individually for the
residential and commercial flows and the major industrial flows from the ECIA.The industrial flows are
subject to much less variability than residential and commercial flows, and that difference in variability is
reflected in the flows presented.
5-5

F: s. M het* "'.x., k' d 'v' * J� <
a
0
29
'A•
21
may\ /, \20 19
22 ,619
Fig No. Display Name ,„--/"; \ , 8 7 L s 31
1 Administration/Maintenance Building A a. - •_ 5
2 Electrical and Backup Power "�` `5 4 • �'
3 Influent Pump Station 9 3 r
24 .�
4 Headworks O.. 25 1 '. �'T', ,: `'t
5 EQTanks - `17 6 o• ��_ "
6 Secondary Pump Station ,•� q O 2� 12 '•* ,, 30 ..- ,`` , a 4
I 7 BNRs �:�ti:77 23 27� 13 �i
8 Blowers .•\, `J 14• �11 • 'J -�': dt *
9 Secondary Clarifiers • 4�,s / i'23 ' •I v -..s. ���� �"
10 Chemical Feed&Stora a �� - ‘1
• •
11 Filters g �� 28 10.•�` 18 Legend
12 UV Disinfection •�_ s•0' .uu Water Line to be installed
13 Post-Aeration ��, �� d • -■■■Proposed Force Mains s�
14 RAS/WAS Pump Station i ,- �� „,. -e. ,,�. -
-A "'.4 ♦ " - -- ,�1 Proposed Gravity Mains
15 Thickening Building 4 r s:+ •�0 a , .
16 DewateringBuilding ,, Y- 5� i*dui Gr .4 Existing Gravity Mains
17 Aerated Sludge Holding Tanks ", Af .;,°a t`.�.,,-,4" ��(a' "`*.,_ • Existing Force Mains
18 Influent Junction Box ♦ r • * _' "e', ..
g c
19 Future EQTanks '� +CJa� n W ► Hydrology
20 Future Primatry Clarifier Split/Junction Box . �•• 'Y ,n f"ect
w -��` + 6 MGD Proposed WRF
21 Future Primary Clarifiers f s, '
22 Future BNRs 10 MGD Future WRF Expansion
= 23 Future Aerated Sludge Holding Tanks h y /' r' • +Y ` ,,,A,-:',:,,..",y.+ � Pavement
ram, .�Jk.q
24 Future SecondaryClarifiers �� 'a '• a �"''k ��
'.i � i � ,. �..,. � x � i'=i'� w�,v°,r �Parcel Limits
25 Odor Control Facility 1 ,,, ', 1 v 4"'"- • ,. A .• '`- �` s t
',xx { s 04 , t 4x. €. 50'Buffer
26 Odor Control Facility 2 t � � �. 1 s 4:� .�
27 Plant Water Pump Station "' ' /i _ '
� � 'at ,y �,, Jf �r�.1 ®Area not evaluated
28 Drain Pump Station - i .yx• t1 • 44• --•* i s, s .` ^ }1 Wetlands
i
29 Future Odor Control Facility 3 ' • - i r? •� .• 1 t -, �,100 Year Floodplain
30 Effluent Junction Box y`1 y i S. - • t
31 Expanded Outfall •r„ th` •� 1+ b
p ilia ,fik t 'r-'�i, t'`e • .40 \
{ � '<, ' fit,. �•_'
Source:NC`Orthoimagery Program (2017)
Figure 5-1
0 490 980 N Proposed WRF at Neuse 2 Site
2 ! I I IA Water Reclamation Facility Expansion
Feet
Town of Clayton, NC
IThe treatment systems depicted on this conceptual layout represent conservative footprints,and may be revised as the design develops.

SECTION 5—ALTERNATIVES ANALYSIS
Influent loading conditions for the new WRF were developed based on the wastewater characteristics of
the Town's three major waste streams: LCWRF influent, Grifols pretreated effluent, and Novo Nordisk—
DAPI pretreated effluent.The Grifols and Novo Nordisk waste streams represent the Town's major
industrial customers; all other commercial and minor industrial customer waste streams currently
discharge to the LCWRF and are included in the domestic source characteristics presented in Table 5-2,
which summarizes wastewater characteristics for the Town's major waste streams.
Table 5-2.Town Waste Stream Characteristics(Maximum Month Concentrations)
Source Domestic and Commerciala Grifols Novo Nordisk—DAPIb•
Flow(MM ADF,MGD) 3.2` 2.0 0.8
BOD(mg/L) 308 409 250
TSS(mg/L) 347 725 250
TN(mg/L) 66 73 20
TP(mg/L) 9 9 8
COD:BOD ratio 2.0 2.9 2.0
a Based on current LCWRF influent characteristics.
b Based on existing Town industrial pretreatment permit limits.
Includes 0.5 MGD future nonresidential flow,assumed to be domestic-strength wastewater.
Notes:
COD=chemical oxygen demand
The new 6-MGD WRF will provide for BNR to comply with NPDES discharge limits for the Neuse River.
The new WRF will treat the existing permit limits of the LCWRF.Table 5-3 summarizes the WRF's
aggregate design loading.
Table 5-3.Design Loads and Effluent Limits
Influent Loading Effluent Limit
Source (MM ADF,lb/d) (Monthly Average,mg/L)
BOD 16,450 10.0
COD 39,730 -
TSS 22,370 30.0
TN 3,100 a 3.0
TP 450 2.0
a Assumes recalcitrant nitrogen from industries in influent is at typical domestic strength.
Notes:
Ib/d=pound(s)per day
Table 5-4 summarizes the design criteria for each treatment system in the primary liquids process.
5-7

SECTION 5-ALTERNATIVES ANALYSIS
Table 5-4.General Liquids Treatment System Design Criteria
Component Value
Influent Pumping
Pumps
Type Dry-pit submersible
No.Pumps(duty and standby) 2 and 1
Design Point 6.6 MGD at 105 ft TDH
Firm Capacity(2.5 x ADF) 13.2 MGD
Influent Flow Meter
Type Magnetic flow meter
Flow Range(MGD) 5.25-13.2
Influent Force Main
No.of Force Mains 2
Diameter,inches 24
Influent Screening
Type Inclined cylindrical with integral washer and compactors
No.of Screens(duty and standby) 1 and 1
Screen Opening 6-mm perforated plate
Design PHF per Screen,MGD 13.2
Grit Removal
Type Stacked tray(HeadCell)
No.of Units 2
Capacity per Unit,MGD 6.6
Flow Equalization
Total Volume,MG 1.60
No.of Tanks 2
No.of Equalization Pumps(duty and standby) 4 and 1
Bioreactors
Process Five-stage Bardenpho
No.of Basins 3
Basin Volume,MG(each) 2.45
Diffuser Type Membrane discs
Nitrified Recycle Pumps
Type Propeller pumps with VFD
No.of Pumps(duty and standby) 3 and 1
Surface Wasting Pumps(biofoam removal pumps)
Type Horizontal centrifugal nonclog with VFD
No.of Pumps(duty and standby) 3 and 1
5-8

SECTION 5-ALTERNATIVES ANALYSIS
Table 5-4.General Liquids Treatment System Design Criteria
Component Value
Secondary Clarification(Final Clarifiers)
No.of Clarifiers 3
Geometry Circular
Diameter,ft(each) 75
Sidewater Depth,ft 18
RAS
Type Horizontal centrifugal nonclog with VFD
No.of Pumps(duty and standby) 3 and 1
WAS
Type Horizontal centrifugal nonclog with VFD
No.of Pumps(duty and standby) 3 and 1
Aeration Blowers
Type High-speed turbo
No.of Blowers(duty and standby) 2 and 1
Average Air Total Flow,scfm 4,500
Tertiary Treatment
Type Cloth(disc)filtration
No.of Units(duty and standby) 2 and 1
Capacity,MGD(each) 2.7(average)and 4.9(peak)
Disinfection
Type Open channel LPHO UV
No.of Units 2
Capacity,MGD(each) 5
Postaeration
Type Cascade aeration
Minimum DO,mgO2/L 6.0
Effluent Flow Meter
Type Magnetic flow meter
Flow range(MGD) 5.25-10
Notes:
ft=foot(feet)
LPHO=low-pressure,high-output
mgOZ/L=milligram(s)per oxygen per liter
mm=millimeter(s)
TDH=total dynamic head
5-9

SECTION 5-ALTERNATIVES ANALYSIS
The solids treatment process will produce unclassified solids per the 503 Regulations (EPA, 2018)to be
composted or disposed of at a landfill.Table 5-5 provides the design criteria for each treatment system
in the solids process.
Table 5-5.Solids Treatment System Design Criteria
Component Value
Thickening
Type Rotary drum
No.of Units(duty and standby) 1 and 1
Target Thickened Solids Concentration,%TSS 5
Aerated Sludge Holding
Average Retention Time,days 30
No.of Tanks 1
Volume,gallons 625,000
Mixing and Aeration Method Coarse bubble diffuser
Dewatering
Type Screw press
No.of Units(duty and standby) 1 and 1
Target dewatered cake concentration,%TSS 18
Energy Conservation
VFDs will be provided for pumps and blowers,which results in more efficient operation and reduced
energy consumption.Treated effluent will be used for process washdown water, reducing consumption
of potable water at the plant.
Environmental Considerations
The proposed parcel is large enough that the facility plan can avoid impacts to floodplains,wetlands,
streams, and stream buffers (WithersRavenel, 2020a). Parcel development will also comply with water
supply watershed development rules. Other than temporary closure for construction of linear infrastructure,
greenways would not be impacted. Odor control technologies would be used to offset potential odor
impacts. Potential impacts to the Neuse River from increased discharge will be offset by purchase of
additional nitrogen credits and to comply with the facility's NPDES permit. Other, mostly temporary impacts
would occur with construction of linear infrastructure, an access road, and the expanded outfall.
Cost Estimate
The estimated total capital cost of Alternative 2a is $120,198,000.This cost includes 10 percent
contingency applied to the construction costs and all estimated administrative costs for the project.The
following project components are included in this estimate:
• Conversion of LCWRF to a pump station
• New transmission pipes and upgrades to existing transmission pipes to convey flow to the Neuse 2
Pump Station site
• Nitrogen credit purchase
540

SECTION 5-ALTERNATIVES ANALYSIS
The estimated total present worth of the new 6-MGD WRF at the Neuse 2 Pump Station site is$154,487,401.
Acceptance or Rejection
Alternative 2a received a score of 4.14, the highest nonfinancial score of the six feasible alternatives,
with higher scores being better aligned to the goals. Of these six alternatives, three compared different
potential sites for a 6-MGD facility, while the other three compared treatment options. When compared
to the other potential sites (ECIA and existing LCWRF), Alternative 2a had the highest weighted score.
This alternative received high scores under the following nonfinancial criteria:
• Resiliency from climate impacts
• Increase the Town's control over the cost of treatment
• Adaptability and phasing
Alternative 2a, construction of a new 6-MGD WRF at the Neuse 2 Pump Station site, provides significant
long-term benefits to the Town that align with the project purpose and need.
This alternative incorporates moderate water and energy conservation measures by using treated
effluent for process washdown water and employing VFDs.
This alternative is feasible, and the investment would provide long-term resiliency to the Town and its
customers.The construction of a new WRF at the Neuse 2 Pump Station site and continued use of a
surface water discharge is considered the Preferred Alternative.
s-ii

SECTION 5-ALTERNATIVES ANALYSIS
5.1.9 Alternative 9: Combination of Alternatives
Combinations of alternatives to meet the timing of wastewater capacity needs while also meeting the
project purpose have also been considered. One such alternative is to continue operation of the LCWRF
at its current capacity and construct a smaller plant at a new site.This alternative would require the
construction of a 4-MGD WRF at a second site. While this would have a lower capital cost than a new
6-MGD facility, rehabilitation of aging equipment at the LCWRF would still require investment to
maintain operational functionality of 2 MGD. Operational cost efficiencies would also be lost if two
facilities remained in operation.This combination does not yield significant cost-savings for the Town
and was not considered further.
A further combination of alternatives could be to land apply effluent during the dry season and revert to
NPDES discharge via the LCWRF outfall during the wet season.As noted in Section 5.1.5, a large area
would be required for land application, and the cost of that land and the associated infrastructure is
very high. In addition, because the WRF would be required to treat to a high enough level for a surface
water discharge,there would be no cost-savings related to the reduced effluent quality associated with
land application.As such, this combination of alternatives provides no benefit over the other options
and was not considered further.
Similarly, a combination of land application and large-scale reuse would be no more feasible than the
two options independently.These combinations of alternatives were eliminated.
5-32

SECTION 5—ALTERNATIVES ANALYSIS
5.2.2.4 Alternative 5: Construction of a New Water Reclamation Facility, and Use of Land
Application
The estimated total present worth cost of the new WRF using land application is$225,201,816.This cost
includes 6-MGD treatment capacity, as described for Alternative 2a.The cost was estimated by
eliminating cost of the tertiary treatment system,the supplemental carbon system, and outfall upgrades
presented for Alternative 2a.Table 5-23 provides a summary of the construction costs for this
alternative. Costs are expressed in 2020 dollars.A 10 percent factor is applied to estimated construction
costs for contingencies.
Table 5-23. Estimated Construction Cost—Land Application
Component Unit Cost($) Unit Quantity Total Cost($)a
IPS 2,361,000 LS 1 2,361,000
Headworks(Screening and Grit Removal) 5,753,000 LS 1 5,753,000
Flow Equalization(Tank and Pump Station) 4,268,000 LS 1 4,268,000
Five-stage BNR 7,661,000 LS 1 7,661,000
Secondary Clarifiers 3,744,000 LS 1 3,744,000
RAS and WAS Pump Station 3,165,000 LS 1 3,165,000
Blowers 4,589,000 LS 1 4,589,000
Disinfection(UV) 3,170,000 LS 1 3,170,000
Solids Treatment(RDT,Aerated Holding Tank,Screw Press) 8,370,000 LS 1 8,370,000
Chemical Feed and Storage Facilities 588,000 LS 1 588,000
Site Work 17,053,000 LS 1 17,053,000
Electrical 5,109,000 LS 1 5,109,000
Access Road 370 LF 3,950 1,462,000
LC Pump Station 4,338,000 LS 1 4,338,000
LC Force Main to Neuse 2 Pump Station Site(24-inch-
diameter PVC) 238 LF 4,310 1,026,000
LC Gravity Main to Neuse 2 Pump Station Site(36-inch-
diameter DI pipe) 443 LF 4,420 1,959,000
LC Gravity Main to Neuse 2 Pump Station Site(42-inch-
diameter DI pipe) 433 LF 5,030 2,179,000
LC Gravity Main to Neuse 2 Pump Station Site(48-inch-
diameter DI pipe) 513 LF 2,380 1,221,000
Reclaimed Water Storage and Pump Station 4,522,000 LS 1 4,522,000
Transmission Pipe to three Application Sites(24-inch-
diameter concrete-lined DI) 218 LF 132,000 28,737,000
Land Application Site Storage Reservoir and Distribution
Pump Station(total for three sites) 15,244,000 LS 1 15,244,000
Irrigation Pipes(16-inch-diameter PVC)(total for three sites) 113 LF 15,000 1,694,000
Irrigation Sprinklers(total for three sites) 8,855,000 LS 1 8,855,000
5-47

SECTION 5—ALTERNATIVES ANALYSIS
Table 5-23. Estimated Construction Cost—Land Application
Component Unit Cost($) Unit Quantity Total Cost($)a
Administrative and Maintenance Facility 2,373,000 LS 1 2,373,000
Total Construction Cost: 139,441,000
Construction Contingency Cost: 13,945,000
Project Administration Cost b: 33,414,000
Total Capital Cost: 186,800,000
a 15%markup applied to component cost to address cost estimate uncertainty at Conceptual Design Phase.This markup is in
addition to the construction cost markups.
b Project administration includes permitting,engineering,services during construction,commissioning,and startup.
Table 5-24 provides a summary of the total present worth cost.
Table 5-24. Present Worth Cost Summary—Land Application
Cost Item Total Cost($)
Capital Costs 186,800,000
Replacement Cost Present Worth a,b 7,866,222
O&M Costs Present Worth—Annual` 29,103,735
O&M Costs Present Worth—Intermittent d 1,431,859
O&M Costs Present Worth—Total 30,535,594
Total Present Worth 225,201,816
a Replacement costs are based on the capital cost of major equipment components for each treatment system presented in
Table 5-23 rather than the total capital cost for a treatment system.
b First year of operation of new plant is 2023.
Annual O&M cost is over a 17-year period from 2023—2040.
d Intermittent O&M cost is over a 17-year period from 2023—2040.
5-48

SECTION 5-ALTERNATIVES ANALYSIS
5.2.2.1 Alternative 2a: Construction of a New Water Reclamation Facility at the Neuse 2 Pump
Station Site
The estimated total present worth of the new 6-MGD WRF is$154,487,401.The following project
components are included in this estimate:
• Conversion of LCWRF to a pump station
• New and upgraded transmission mains to convey flow to the Neuse 2 Pump Station site
• Nitrogen credit purchase
Table 5-17 is a summary of the construction costs for this alternative. Costs are expressed in 2020
dollars.A 10 percent factor is applied to estimated construction costs for contingencies.
Table 5-17. Estimated Construction Cost—New Water Reclamation Facility at the Neuse 2 Pump Station Site
Unit Cost Total Costa
Component ($) Unit Quantity ($)
IPS 2,361,000 LS 1 2,361,000
Headworks(Screening and Grit Removal) 5,753,000 LS 1 5,753,000
Flow Equalization(Tank and Pump Station) 4,268,000 LS 1 4,268,000
Five-Stage BNR 12,768,000 LS 1 12,768,000
Secondary Clarifiers 3,744,000 LS 1 3,744,000
RAS and WAS Pump Station 3,165,000 LS 1 3,165,000
Blowers 4,589,000 LS 1 4,589,000
Cloth Filters 3,974,000 LS 1 3,974,000
Disinfection(UV) 3,170,000 LS 1 3,170,000
Solids Treatment(RDT,Aerated Holding Tank,Screw
Press) 8,370,000 LS 1 8,370,000
Chemical Feed and Storage Facilities 588,000 LS 1 588,000
Cascade Re-aeration 367,000 LS 1 367,000
Site Work 12,451,000 LS 1 12,451,000
Electrical 5,109,000 LS 1 5,109,000
Access Road 370 LF 3,950 1,462,000
LC Pump Station 4,338,000 LS 1 4,338,000
LC Force Main to Neuse 2 Pump Station Site
(24-inch-diameter PVC) 238 LF 4,310 1,026,000
LC Gravity Main to Neuse 2 Pump Station Site
(36-inch-diameter DI pipe) 443 LF 4,420 1,959,000
LC Gravity Main to Neuse 2 Pump Station Site
(42-inch-diameter DI pipe) 433 LF 5,030 2,179,000
LC Gravity Main to Neuse 2 Pump Station Site
(48-inch-diameter DI pipe) 513 LF 2,380 1,221,000
Administrative and Maintenance Facility 2,373,000 LS 1 2,373,000
Total Construction Cost: 85,235,000
5-42

SECTION 5—ALTERNATIVES ANALYSIS
Table 5-17. Estimated Construction Cost—New Water Reclamation Facility at the Neuse 2 Pump Station Site
Unit Cost Total Cost a
Component ($) Unit Quantity ($)
Construction Contingency Cost: 8,524,000
Project Administration Cost b,c: 26,439,000
Total Capital Cost: 120,198,000
a 15%markup is applied to component cost to address cost estimate uncertainty at Conceptual Design Phase.This markup is
in addition to the construction cost markups.
b Project administration includes permitting,engineering,services during construction,commissioning,and startup.
Includes$8,938,678 for nitrogen credit purchase.
Notes:
L5=lump sum
Table 5-18 provides a summary of the total present worth cost.
Table 5-18. Present Worth Cost Summary—New Water Reclamation Facility at the Neuse 2 Pump Station Site
Cost Item Total Cost($)
Capital Costs 120,198,000
Replacement Cost Present Worth a•b 7,524,499
0&M Costs Present Worth—Annual` 25,538,423
0&M Costs Present Worth—Intermittent d 1,226,479
0&M Costs Present Worth—Total 26,764,902
Total Present Worth 154,487,401
a Replacement costs are based on the capital cost of major equipment components for each treatment system presented in
Table 5-17 rather than the total capital cost for a treatment system.
b First year of operation of new plant is 2023.
`Annual O&M cost is over a 17-year period from 2023—2040.
d Intermittent O&M cost is over a 17-year period from 2023—2040.
5.2.3 Total Present Worth Summary
Present worth cost was developed for the 20-year planning period and assumes the project will be in
service by 2023. Annual O&M costs for the new or expanded plant do not occur until year 2023. Costs
related to maintaining and rehabilitating the existing LCWRF treatment systems from 2020—2023 were
included in Alternative 3. For the feasible alternatives evaluated,Table 5-29 provides the total present
worth summary in 2020 dollars.
5-43

Table 5-29.Total Present Worth for Feasible Alternatives
Replacement O&M Costs Present Worth
Alternative Capital Cost Costs Present Total Present
Number Alternative ($) Worth($) Annual($) Intermittent($) Total($) Worth($)
Construction of New WRF,and Continued Use
2a of a Surface Water Discharge(at Neuse 2 Pump
Station site) 120,198,000 7,524,499 25,538,423 1,226,479 26,764,902 154,487,401
2b Construction of New WRF,and Continued Use
of a Surface Water Discharge(at ECIA Site) 133,089,000 8,757,577 30,244,316 1,226,479 31,470,795 173,317,373
3 Expansion of LCWRF,and Continued Use of a
Surface Water Discharge 96,493,000 5,223,577 30,448,241 1,914,743 32,362,984 134,079,561
5 Construction of New WRF,and Use of Land
Application 186,800,000 7,866,222 29,103,735 1,431,859 30,535,594 225,201,816
7 Construction of New WRF—Alternative
Secondary Treatment Process 116,538,000 7,472,701 26,942,638 1,285,135 28,227,773 152,238,474
8 Construction of New WRF—Alternative
Biosolids Treatment Strategy 123,400,000 7,524,499 23,725,294 1,219,956 24,945,250 155,869,749

Memorandum
111 Corning Street,Suite 116
Cary. North Carolina 27604
United States
f+1.919.859.5000
F+1.919.859.5151
www.jacobs.com
Subject Town of Clayton Wastewater Forecast Update
Project Name Clayton WRF Expansion Project ��H....
:1 2 ..00.3814.yy
Prepared By William Bromby (CH2M); updated by Philip Ogden (CH2M) ''•.
Reviewed By Michelle Mayes(CH2M) p 97 412...j./*
Phil Ogden (CH2M) ••
Update by Jaime Robinson(CH2M) Ayj
�/P A.4GQ...
Date October 7, 2019; updated August 27, 2020
Revision R2
1. Introduction
The Town of Clayton (Town), estimated population of 22,800 within the town limits and 10,000 in the
extra-territorial jurisdiction (ETJ), currently owns and operates a water reclamation facility (WRF), Little
Creek WRF (LCWRF), with a permitted capacity of 2.5 million gallons per day (MGD). In addition, the
Town has purchased capacity via interlocal agreements from neighboring utilities, 1.4 MGD from
Johnston County (Johnston County Regional WWTP)and 1.0 MGD from the City of Raleigh (Neuse River
WWTP), for a total permitted treatment capacity of 4.9 MGD.
The recent Capacity and Improvement Study (Wooten, 2018) indicated that the Town will require
approximately 10 MGD in capacity over the next twenty years to meet current and future needs, including
major increases in industrial flow from existing and potential future bio-pharma customers. In order to
develop a cost effective and efficient method to meet the Town's capacity needs over the next twenty
years, CH2M evaluated recent capacity studies to a developed flow projection through a 25-year planning
horizon. The updated flow projection includes industrial flow demands reported by notable industries
within the Clayton ETJ, i.e. Novo Nordisk and Grifols Therapeutics (Grifols).
The objective of this Wastewater Forecast Update is to provide the Town with a revised analysis of the
wastewater flow forecast performed as part of the Town of Clayton Wastewater Conveyance Study
(CH2M, 2013). The primary objective of the 2013 study was to evaluate possible scenarios related to
intermediate- and long-term wastewater conveyance and treatment capacity balancing wastewater flows
sent to the Town's Little Creek WRF, City of Raleigh's Neuse River WWTP, and Johnston County
Regional WWTP. The first step of that study was to develop a meaningful wastewater flow forecast
through 2035 including the consideration of uncertainty related to future flows, both in magnitude and
timing.
This Wastewater Forecast Update incorporates more up-to-date neighborhood growth rates and
capacities and more recent industrial flow projections, as reported directly from industrial customers, to
produce an updated forecast which begins in 2019 and forecasts through 2045. The residential flows
forecasted are analyzed with respect to flow per housing unit to demonstrate expected future growth rates
in terms of housing unit development.

Jacobs
Ci11241 - Town of Clayton Wastewater Forecast Update
2. Wastewater Flow Forecast
2.1 Wastewater System Sub-Areas
A subdivision of the Town's future service area, represented by the Town's current extra-territorial
jurisdiction (ETJ), is important for allowing growth patterns to vary across the ETJ based on predictions.
For the 2013 forecast, CH2M worked with Town staff to identify wastewater system sub-areas within the
ETJ, and the result was the identification of nine sub-areas, seven of which are residential. These sub-
areas represented meaningful unit areas to use as the base for the wastewater flow forecast, with the
consideration that flow would be generated from within and adjacent to these sub-areas. The 2018
Wooten capacity study used this same sub-area approach. Figure 1 contains an updated map from the
2013 study presenting the wastewater system sub-areas.
FIGURE 1
Wastewater System Sub-Area Map
N
A
0 0 4 0.8 1 6 2.4 3.2
a
/ Legend
Z ■ Pump Station
\ -- -County Boundary
i
Railroad
A + !4 -Primary Roads
Roads
+��y , Nc.42 Sewer Lines
� �� ,`� -Force main
,' `,'i1� • '� lib. -Gravely line
��+��/ QETJ
!�� System Sub-Areas
j 1111111,
Center-No 1
rn Center-No.2
East Clayton
4 n Glen Laurel
"I a O North
n Pritch.Rd No 1&2
El soh
-77/
n Grifois/Novo
2.2 Wastewater Flow Forecasting Methodology
The methodology followed for this update is the same used for the 2013 CH2M forecast. The general
structure of the forecast tool, breakdown of wastewater system sub-areas, and calculation steps have not
been altered. Please reference the Town of Clayton Wastewater Conveyance Study (CH2M, 2013) for
details describing how the flow forecasting tool functions.
For this update, the primary changes made to the forecast inputs were:
�G,VI HILL NORTH CAROLINA, INC.

Town of Clayton Wastewater Forecast Update
• The time span was changed from 2013-2035 to 2019-2045.
• The assumed flows for the start year of 2019 were taken from the Wooten projections (Wooten,
2018).
• Growth rates for specific sub-areas were updated to reflect slowing development as build-out
capacities are reached (Table 2).
• Grifols and Novo Nordisk DAPI flows were updated based on data provided by each industry.
It should be noted that both Grifols and the recently constructed Novo Nordisk DAPI facility are located
within an area to the east of Clayton, known as the East Clayton Industrial Area (ECIA). A number of
other residential, commercial and industrial customers, including a separate Novo Nordisk facility (DFP)
are also located in the ECIA, and these are incorporated in the projection as the East Clayton node.
Potential exists for a future, large industry to locate in the ECIA, and while this has zero flow at present
this potential has been accounted for in the flow projection.
Table 1 presents, by wastewater system sub-area, the assumptions related to the existing flow conditions
including: the 2019 Average Day Flow(ADF) estimate, the Maximum Month Average Day Flow (MMADF)
peaking factor and estimate data source. The MMAD peaking factors are necessary to predict maximum
month flows for comparison to treatment capacities in the future.
Table 1
Wastewater System Sub-Area Existing Flow Assumptions
Wastewater System Sub Area 2019 Average Day Flow Maximum Month-Average Day
Estimate(MGD) Peaking Factor a
Center-North 1 0.05 1.2
Center-North 2 0.07 1.2
Glen Laurel 0.23 1.2
North 0.04 1.1
Pritchard Road 1 0.17 1.1
Pritchard Road 2 0.05 1.1
South 1.28 1.2
East Clayton 0.27 1.1
Grifols/Novo Nordisk° 1.07 varies b
a Developed based on the ratio of average day to maximum month-average day wastewater flow.
Peaking factor varies by industry
c This sub-area includes major industries in the ECIA.Current flows in this sub-area are from Grifols and Novo
Nordisk DAPI.
Table 2 presents the assumptions related to future growth for each system sub-area; these growth rates
are necessary for establishing the growth pattern for wastewater flow through 2045. The growth rates
r��bi n �L?w

Jacobs
0,424,14. Town of Clayton Wastewater Forecast Update
presented in Table 2 were applied starting in 2020 to the previous year's flow to calculate each
successive year's estimated future flow.
TABLE 2
Wastewater System Sub-Area Growth Rate Assumptions
Wastewater System Growth Rate Note
Sub-Area (%growth per year)
Center-North 1 2.0% Assumed linear growth pattern 2019 through 2045,rate
provided by Town staff.
Center North 2 2.0% Assumed linear growth pattern 2019 through 2045,rate
provided by Town staff.
Glen Laurel 2.0% Assumed linear growth to 0.75 MGD,the Town estimate of
build-out condition for sub-area.
Assumed linear growth pattern 2019 through 2045,rate
North 9.0% calculated based on the Town estimate of 40 percent build-
out(0.17 MGD)by approximately 2035
Pritchard Road 1 2.0% Assumed linear growth pattern 2019 through 2045,rate
provided by Town staff.
Assumed linear growth pattern to 0.44 MGD,the Town
Pritchard Road 2 14.5% estimate of build-out based on 2,935 lots(150 gpd per
home(based on pop.and flow data from Town LWSPs
(2006-2012))
South 0.5% Assumed linear growth pattern 2019 through 2045,rate
provided by Town staff.
East Clayton 2.0% Assumed linear growth pattern 2019 through 2045,rate
provided by Town staff.
Grifols/Novo Nordisk
b Per Industry Growth pattern characterized by increases in flow
projections c coincident with facility expansion.
'Growth in flow from one year to the next through 2045.
Novo Nordisk growth in the sub-area is from the DAPI facility
c Growth includes potential future major industries
LWSP=Local Water Supply Plan
2.3 Residential/Commercial Probabilistic Wastewater Flow Forecast
Tables 1 and 2 list the nine system sub-areas of which the seven residential/commercial sub-area
wastewater flow forecasts were simulated probabilistically. The East Clayton sub-area and the
Grifols/Novo Nordisk sub-area are primarily industrial and were not included in what is referred to here as
`residential' sub-areas. It should also be noted that these seven areas included a mix of residential and
commercial flows.
For sub-areas with build-out capacities provided by the Town (Glen Laurel, North, and Pritchard Road 2),
the year in which capacity was achieved and growth halted was estimated based on the deterministic
forecast. Both Glen Laurel and North sub-areas were observed not to reach capacity by 2045. Glen
Laurel achieved 52% build-out and North achieved 80% build-out. Pritchard Road 2 achieved its build-out
capacity of 0.44 MGD by 2036, so its growth rate was decreased to 0% for the years 2037-2045.
CH2M HILL NORTH CAROLINA, INC.

Town of Clayton Wastewater Forecast Update
Figures 2 and 3 show the ADF and MMADF wastewater forecasts, respectively, for the seven
residential/commercial sub-areas. The break in the curvature, at year 2036, is due to the Pritchard Road
2 sub-area reaching capacity.
The results are also presented in tabular form in Appendix A. Additionally, Appendix B contains tables
that include the annual residential forecast data for the 25th 50th 75th and 95th percentile forecasts by
sub-area.
FIGURE 2
Town of Clayton Residential Average Day Wastewater Flow Forecast, 2019-2045
5
4
95th Percentile
3
0
C7 75th Percentile
2
p50th Percentile
LL
R 2 25th Percentile
5th Percentile
d
Q
1
0 CCpp((pp
O N N N Ng N N N N N ON C') CN') CC') M C') C') [^+) c+) V' V V
O 0 0 O O O O O O 0 0 0 0 0 0 0 0 0 O O 0 0 0 O O O O
N N N N N N N N N N N N N N N N N N N N N N N N N N N
CH2M HILL NORTH CAROLINA, INC. 5

Jacobs
di 24 4- Town of Clayton Wastewater Forecast Update
FIGURE 3
Town of Clayton Residential Maximum Month Average Day Wastewater Flow Forecast, 2019-2045
5 _
4 - _
95th Percentile
0
2
3
it
O I
75th Percentile
c. 31I
co
� 50th Percentile
O
� 25th Percentile
R '
d
Q 5th Percentile
c 2
O j
2
I
1
6) O N C� LL7 CD r< a0 p) pp N M Cp n O) N '4- U')
N N N N N N N N N N N) C7 C7 M CO 0 0 C7 0 C 1 0 v v v v v
O O O O O O O O O O O O O O O O O O O O O O O O O 00
N N N N N N N N N N N N N N N N N N N N N N N N N N N
2.3.1 Projected Housing Unit Development Rate
Using the results from the residential flow forecast it is possible to calculate the expected number of
housing units developed by applying a 'flow per household' metric. During the 2013 flow forecasting effort
the average wastewater flow per household was determined to be 150 gallons per day (gpd) (CH2M,
2013).
Using this rate, the 50th, 75th and 95th percentile curves from the MMADF forecast were converted in
'average additional housing units per year' to demonstrate the rate of development associated with each
scenario.
• 50th percentile: 0.95 MGD increase from 2019-2045 equates to 240 household units per year
• 75th percentile: 1.30 MGD increase from 2019-2045 equates to 330 household units per year
• 95th percentile: 1.92 MGD increase from 2019-2045 equates to 490 household units per year
2.4 Industrial Wastewater Flow Forecast
The East Clayton and Grifols/Novo Nordisk sub-areas (each located in the ECIA) are included in the
industrial wastewater flow forecast. The two primary industrial customers Grifols Therapeutics and Novo
Nordisk will be served by Clayton's wastewater system with the implementation of the expansion project
.DH2M HILL NORTH CAROLINA, INC.

Town of Clayton Wastewater Forecast Update
and have reported their anticipated flows over the next 20 years. For the purposes of forecasting beyond
2037, these customers' flows were assumed to remain constant from 2037 through 2045. Historically,
Grifols flow has been sent to JCRWWTP for treatment. Since completion of a new pump station in the
ECIA in early 2020 flow from both Grifols and Novo Nordisk has been conveyed to JCRWWTP.
These industrial flows associated with Grifols and Novo Nordisk were not input into the probabilistic
model due to a higher degree of certainty related to the expected flow rates. The uncertainty instead lies
in the phasing of plant expansions in time and flows from any additional future industrial customers. The
known industrial flows reported herein are based on estimated phasing as reported by the industrial
users, although the phasing is subject to change. This analysis considers an industrial user(s) moving to
the region and requesting services from the Town of Clayton. The Wooten study and this update
considered additional unnamed industrial user(s) which could increase the demand by an additional 0.5 to
1.5 MGD within the 25-year planning horizon (Wooten, 2018), and these flows have been included in this
projection.
TABLE 3
Industrial Customers Maximum Month Average Daily Flow Projections
Year a Grifols(MGD) Novo Nordisk DAPI(MGD)b Un-Named Future
Non-Residential(MGD)
2019 1.0 0.35 0
2023 1.4 0.8 0
2025 2.0 0.8 0.5
2028 2.0 1.2 0.5
2030 2.0 1.2 1.0
2034 2.0 1.9 1.25
2040 2.0 1.9 1.5
2045 2.0 1.9 1.5
a Select years listed to correspond to anticipated increases in flow projection
Includes both domestic and industrial flow streams from the DAPI facility
3. Summary and Conclusion
The Town should use the combination of the residential/commercial and industrial forecasts for planning
purposes. Figure 4 depicts the residential and industrial wastewater flow forecast through from 2019
through 2045. The residential component represents the 50th percentile of the MMADF forecast for the
years through 2029. As the uncertainty around residential growth increases in the future, the projection
represents the 75th percentile of the MMADF for the years from 2030 through 2034, and the 95th
percentile from 2035. As shown in Figure 4, the industrial wastewater forecast component drives the flow
forecast between 2023, 2028, and 2034 and the timing of these increases should be considered when the
Town is determining timing of wastewater capacity increases.
CH2M HILL NORTH CAROLINA, INC.

Jacobs
cli244, Town of Clayton Wastewater Forecast Update
FIGURE 4
Town of Clayton Residential + Industrial Wastewater Maximum Month Average Day Flow Forecast, 2019-2045
10.0
9.0
8.0
7.0
—. 6.0
l7
- 5.0
0
Cr- 4.0
3.0
2.0
1.0
2015 2020 2025 2030 2035 2040
Year
---Total Historical Demand(2015-2019) -Total Forecast Demand
Appendix C contains a table of the forecast industrial flow, by customer, as well as a total forecast which
shows the summation of residential /commercial results from Appendix A and the industrial flows.
4. References
CH2M HILL North Carolina, Inc. (CH2M). 2013. Wastewater Conveyance Study. Prepared for the Town of
Clayton, NC.
The Wooten Company (Wooten). 2018. Presentation: Wastewater Capacity Study Additional Information.
Prepared for the Town of Clayton, NC and presented to the Town of Clayton Council. December 17.
CH2M HILL NORTH CAROLINA, INC.

Appendix A
Residential Wastewater Flow Forecast Tabular Data

This page intentionally left blank.

Table A-1
Residential-Only Average Day Flow Foresaw,2019 through 2045
Residential-Only Average Day Flow(MOD)
Percentile Forecast 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043 2044 2045
95th 1.67 1.80 1.82 1.85 1.88 1.92 1.96 2.00 2.05 2.11 2.17 2.23 2.31 2.40 2.48 2.59 2.70 2.84 2.88 2.93 2.98 3.03 3.10 3.16 3.24 3.31 3.40
75th 1.67 1.74 1.76 1.79 1.82 1.85 1.88 1.91 1.95 1.99 2.04 2.09 2.14 2.21 2.26 2.33 2.40 2.48 2.51 2.54 2.58 2.62 2.66 2.71 2.75 2.80 2.86
50th 1.67 1.69 1.71 1.74 1.76 1.79 1.82 1.85 1.88 1.92 1.95 1.99 2.04 2.08 2.13 2.17 2.23 2.28 2.30 2.33 2.36 2.39 2,42 2.45 2.49 2.52 2.56
25th 1.67 1.64 1.67 1.69 1.71 1.73 1.76 1.79 1.81 1.84 1.87 1.91 1.94 1.98 2.01 2.04 2.08 2.12 2.13 2.15 2.17 2.19 2.21 2.24 2.26 2.28 2.31
5th 1.67 1.59 1.61 1.62 1.64 1.66 1.68 1.70 1.72 1.74 1.76 1.79 1.81 1.83 1.85 1.87 1.89 1.91 1.91 1.92 1.94 1.95 1.96 1.97 1.98 1.99 2.00
Table A-2
Residential-Only Maximum Month Average Day Flow Forecast,2019 through 2045
Residential-Only Maximum Month Average Day Flow(MOD)
Percentile Forecast 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043 2044 2045
95th 1.98 2.16 2.19 2.22 2.26 2.30 2.34 2.39 2.44 2.49 2.56 2.63 2.71 2.80 2.89 3.00 3.13 3.28 3.32 3.38 3.43 3.50 3.56 3.64 3.72 3.81 3.90
75th 1.98 2.04 2.06 2.09 2.12 2.16 2.19 2.23 2.27 2.32 2.37 2.42 2.48 2.55 2.61 2.69 2.76 2.85 2.88 2.92 2.96 3.01 3.05 3.10 3.16 3.21 3.27
50th 1.98 1.99 1.99 2.00 2.03 2.06 2.09 2.13 2.16 2.20 2.24 2.29 2.34 2.39 2.44 2.49 2.55 2.62 2.64 2,67 2.70 2.73 2.77 2.80 2.84 2.88 2.92
25th 1.98 1.87 1.89 1.92 1.94 1.97 2.00 2.03 2.06 2.09 2.13 2.17 2.20 2.25 2.28 2.32 2.36 2.41 2.42 2.45 2.47 2.50 2.52 2.55 2.57 2.60 2.63
5th 1.98 1.76 1.78 1.80 1.83 1.85 1.87 1.90 1.92 1.95 1.97 2.00 2.03 2.06 2.08 2.10 2.13 2.15 2.15 2.17 2.19 2.20 2.22 2.23 2.24 2.25 2.26

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Appendix B
Residential Wastewater Flow Forecast by Sub-Area

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Table B-1
Residential/Commercial Average Day Flow Forecast by Sub-Area,2019 through 2045
Residential Average lay Flow IMGD)by Sub-Area
Sub-Area Percentile Forecast 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043 2044 2045
95th 0.05 0.05 0.06 0.06 0.06 0.06 0.06 0.06 0.07 0.07 0.07 0.07 0.07 0.08 0.08 0.08 0.08 0.09 0.09 0.09 0.09 0.10 0.10 0.10 0.11 0.11 0.11
Center-North 1 75th 0.05 0.05 0.05 0.05 0.06 0.06 0.06 0.06 0.06 0.06 0.06 0.07 0.07 0.07 0.07 0.07 0.07 0.07 0.08 0.08 0.08 0.08 0.08 0.08 0.09 0.09 0.09
50th 0.05 0.05 0.05 0.05 0.05 0.05 0.06 0.06 0.06 0.06 0.06 0.06 0.06 0,06 0.06 0.06 0.07 0,07 0.07 0.07 0.07 0.07 0.07 0.07 0.08 0.08 0.08
25th 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.06 0.06 0.06 0.06 0.06 0.06 0.06 0.06 0.06 0.06 0.06 0.06 0.06 0.06 0.06 0.07 0.07 0.07
95th 0.07 0.07 0.07 0.07 0.08 0.08 0.00 0.08 0.09 0.09 0.09 0.09 0.10 0.10 0.10 0.10 0.11 0.11 0.11 0.12 0.12 0.12 0.13 0.13 0.14 0.14 0.15
Center-North 2 75th 0.07 0.07 0.07 0.07 0.07 0.07 0.08 0.08 0.08 0.08 0.08 0.08 0.09 0.09 0.09 0.09 0.09 0.10 0.10 0.10 0.10 0.11 0.11 0.11 0.11 0.12 0.12
50th 0.07 0.07 0.07 0.07 0.07 0.07 0.07 0.07 0.08 0.08 0.08 0.08 0.08 0.08 0.08 0.08 0.09 0.09 0.09 0.09 0.09 0.09 0.09 0.10 0.10 0.10 0.10
25th 0.07 0.06 0.07 0.07 0.07 0.07 0.07 0.07 0.07 0.07 0.07 0.07 0.07 0.08 0.08 0.08 0.08 0.08 0.08 0.08 0.08 0.08 0.08 0.08 0.09 0.09 0.09
95th 0.23 0.25 0.26 0.27 0.27 0.28 0.29 0.30 0.31 0.31 0.32 0.33 0.34 0.36 0.37 0.38 0.39 0.40 0.41 0.42 0.43 0.45 0.46 0.48 0.49 0.51 0.53
Glen laurel 75th 0.23 0.24 0.25 0.25 0.26 0.27 0.27 0.28 0.28 0.29 0.30 0.30 0.31 0.32 0.32 0.33 0.34 0.34 0.35 0.36 0.37 0.38 0.39 0.40 0.40 0.41 0.42
50th 0.23 0.24 0.24 0.25 0.25 0.26 0.26 0.26 0.27 0.27 0.28 0.28 0.29 0.29 0.30 0.30 0.31 0.31 0.32 0.32 0.33 0.33 0.34 0.35 0.35 0.36 0.37
25th 0.23 0.23 0.23 0.24 0.24 0.25 0.25 0.25 0.26 0.26 0.26 0.27 0.27 0.27 0.27 0.28 0.28 0.28 0.28 0.29 0.29 0.30 0.30 0.30 0.31 0.31 0.31
95th 0.04 0.04 0.05 0.05 0.06 0.06 0,07 0.08 0.08 0.09 0.10 0.12 0.13 0.14 0.16 0.17 0.19 0.21 0.24 0.26 0.29 0.32 0.36 0.40 0.44 0.49 0.55
North 75th 0.04 0.04 0.04 0.05 0.05 0.06 0.06 0.07 0.07 0.08 0.09 0.09 0.10 0.11 0.12 0.13 0.14 0.16 0.17 0.19 0.20 0.22 0.24 0.26 0.29 0.31 0.34
50th 0.04 0.04 0.04 0.05 0.05 0.05 0.06 0.06 0.07 0.07 0.08 0.08 0.09 0.10 0.10 0.11 0.12 0.13 0.14 0,15 0.16 0.17 0.18 0.20 0.21 0.23 0.24
25th 0.04 0.04 0.04 0.04 0.05 0.05 0.05 0.06 0.06 0.06 0.07 0.07 0.08 0.08 0.09 0.09 0.10 0.10 0.11 0.11 0.12 0.13 0.14 0.15 0.15 0.16 0.17
95th 0.17 0.19 0.19 0.20 0.20 0.21 0.21 0.22 0.23 0.23 0.24 0.25 0.26 0.26 0.27 0.28 0.29 0.29 0.30 0.31 0.32 0.33 0.34 0,35 0.36 0.38 0.39
Pritchard Road 1 75th 0.17 0.18 0.18 0.19 0.19 0.20 0.20 0.21 0.21 0.21 0.22 0.23 0.23 0.24 0.24 0.25 025 0.26 0.26 0.27 0.27 0.28 0.29 0.29 0.30 0.31 0.31
50th 0.17 0.18 0.18 0.18 0.19 0.19 0.19 0.20 0.20 0.20 0.21 0.21 0.21 0.22 0.22 0.22 0.23 0.23 0.23 0.24 0.24 0.25 0.25 0.26 0.26 0.27 0.27
25th 0.17 0.17 0.17 0.18 0.18 0.18 0.18 0.19 0.19 0.19 0.19 0.20 0.20 0.20 0.20 0.21 0.21 0.21 0.21 0.21 0.22 0.22 0.22 0.22 0.23 0.23 0.23
95th 0.05 0.06 0.06 0.08 0.09 0.10 0.12 0.14 0.17 0.20 0.24 0.28 0.33 0.39 0.46 0.53 0.63 0.74 0.73 0.73 0.73 0.73 0.73 0.73 0.73 0,73 0.73
Pritchard Road 2 75th 0.05 0.05 0.06 0.07 0.08 0.09 0.10 0.12 0.14 0.16 0.18 0.21 0.24 0.27 0.31 0.35 0.40 0.46 0.46 0.46 0.46 0.46 0.46 0.46 0.45 0.45 0.45
50th 0.05 0.05 0.06 0.06 0.07 0.08 0.09 0.10 0.12 0.13 0.15 0.17 0.19 0.21 0.23 0.26 0.30 0.33 0.33 0.33 0.33 0.33 0.33 0.33 0.33 0.32 0.32
25th 0.05 0.05 0.05 0.06 0.07 0.07 0.08 0.09 0.10 0.11 0.12 0.13 0.15 0.16 0.18 0.20 0.21 0.24 0.23 0.23 0.23 0.23 0.23 023 0.23 0.23 0.23
95th 1.07 1.14 1.14 1.15 1.15 1.15 1.16 1.16 1.17 1.18 1.18 1.19 1.19 1.20 1.20 1.21 1.21 1.21 1.22 1.22 1.23 1.24 1.24 1.25 1.26 1.27 1.29
South 75th 1.07 1.10 1.10 1.11 1.11 1.12 1.12 1.12 1.13 1.13 1.14 1.14 1.14 1.15 1.15 1.15 1.15 1.15 1.15 1.16 1.16 1.17 1.17 1.18 1.18 1.19 1.20
50th 1.07 1.07 1.07 1.08 1.08 1.08 1.09 1.09 1.09 1.10 1.10 1.10 1.11 1.11 1.11 1.11 1.11 1.11 1.11 1.11 1.12 1.12 1.12 1.13 1.13 1.13 1.14
25th 1.07 1.04 1.04 1.05 1.05 1.05 1.06 1.06 1.06 1.06 1.07 1.07 1.07 1.07 1.07 1.07 1.07 1.07 1.07 1.07 1.07 1.07 1.08 1.08 1.08 1.08 1.08
95th 1.67 1.80 1.83 1.86 1.90 1.95 1.99 2.05 2,11 2.17 2.25 2.33 2.42 2.52 2.63 2.75 2.89 3.05 3.10 3.16 3.22 3.29 3.36 3.45 3.53 3.63 3.73
Total 75th 1.67 1.74 1.77 1.79 1.82 1.85 1.89 1.93 1.97 2.02 2.06 2.12 2.18 2.24 2.31 2.38 2.45 2.54 2.57 2.61 2.64 2.69 2.73 2.78 2.83 2.88 2.94
50th 1.67 1.69 1.71 1.74 1.76 1.79 1.82 1.85 1.88 1.91 1.95 1.99 2.03 2.07 2.12 2.16 2.21 2.26 2.28 2.31 2.33 2.36 2.39 2.42 2.45 2.49 2.52
25th 1.67 1.64 1.66 1.68 1.70 1.72 1.75 1.77 1.79 1.81 1.84 1.87 1.89 1.92 1.95 1.98 2.00 2.03 2.04 2.06 2.08 2.10 2.11 2.13 2.15 2.17 2.19
Page 1 of 1

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Appendix C
Industrial and Total Flow Forecast Tabular Data

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Table C-1
East Clayton Industrial Area Wastewater Forecast,2019 through 2045
Industrial Customers'Wastewater Flow Forecast(mad)
Town Service Area(ECM) 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043 2044 2045
East Clayton 0.30 0.31 0.32 0.33 0.33 0.34 0.34 0.35 0.36 0.36 0.37 0.38 0.38 0.39 0.40 0.41 0.41 0.42 0.43 0.43 0.44 0.45 0.46 0.47 0.48 0.49 0.50
Grifols 100 1.10 1.10 1.10 1.40 1.50 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 200 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00
Novo Nordisk DAPI Process W W 0.17 0.17 0.17 0.17 0.44 0.44 0.44 0.44 0.44 0.80 0.80 0.80 0.80 0.80 0.80 1.26 1.26 1.26 1.26 1.26 1.26 1.26 1.26 1.26 1.26 1.26 1.26
Novo Nordisk DAPI CUB - - - - 0.31 0.31 0.31 0.31 0.31 0.31 0.31 0.31 0.31 0.31 0.31 0.56 0.56 0.56 0.56 0.56 0.56 0.56 0.56 0.56 0.56 0.56 0.56
Novo Nordisk DAPI Sanitary W W 0.18 0.19 0.19 0.19 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0,05 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.05
Future Un-Named Non-Residential 0.00 0.00 0.00 0.00 0.00 0.00 0.50 0.50 0.50 0.50 0.50 1.00 1.25 1.25 1.25 1.25 1.50 1.50 1.50 1.50 1.50 1.50 1.50 1.50 1.50 1.50 1.50
Total: 1.65 1.77 1.78 1.79 2.53 2.64 3.64 3.65 3.66 4.02 4.02 4.53 4.79 4.80 4.80 5.52 5.78 5.79 5.80 5.80 5.81 5.82 5.83 5.84 5.85 5.86 5.87
Table C-2
Total Maximum Month Average Day Flow Forecast,2019 through 2045
Total Maximum Month Average Day Flow(mad)
Percentile Forecast 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043 2044 2045
9Sth 3.63 3.93 3.97 4.01 4.79 4.93 5.98 6.04 6.09 6.51 6.58 7.16 7.50 7.60 7.70 8.53 8.91 9.07 9.12 9.18 9.25 9.32 9.39 9.48 9.57 9.66 9.77
75th 3.63 3.81 3.84 3.88 4.66 4.80 5.84 5.88 5.93 6.34 6.39 6.96 7.27 7.35 7.42 8.21 8.55 8.64 8.68 8.73 8.77 8.83 8.88 8.94 9.00 9.07 9.14
50th 3.63 3.76 3.77 3.79 4.56 4.70 5.74 5.78 5.82 6.22 6.27 6.82 7.13 7.19 7.25 8.02 8.33 8.41 8.43 8.47 8.51 8.55 8.60 8.64 8.69 8.74 8.79
25th 3.63 3.64 3.67 3.70 4.47 4,61 5.64 5.68 5.72 6.11 6.15 6.70 6.99 7.04 7.09 7.65 8.15 8.20 8.22 8.25 8.28 8.32 8.35 8.38 8.42 8.46 8.49
5th 3.63 3.53 3.56 3.59 4.36 4.49 5.52 5.55 5.58 5.97 6.00 6.53 6.82 6.86 6.89 7.63 7.91 7.94 7.95 7.98 8.00 8.02 8.05 8.07 8.09 8.11 8.13

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