NC0025453_Permit Issuance_20030311

NPDE:i DOCUMENT SCANNING COVER :iNEET
NPDES Permit:
NC0025453
Clayton WWTP
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Plan of Action
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
March 11, 2003
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content on the resrerse side

y
State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
Alan W. Klimek, P.E., Director
Mr. Steve Biggs, Manager
Town of Clayton
P.O. Box 879
Clayton, North Carolina 27520
Dear Mr. Biggs:
NCDENR
NORTH CAROUNA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
March 11, 2003
Subject: NPDES Permit Issuance
Clayton - Little Creek WRF
Permit No. NCO025453
Johnston County
Attached to this letter is the final NPDES permit for the Town of Clayton's Little Creek Water
Reclamation Facility, NPDES Permit No. NC0025453. This permit is issued pursuant to the requirements
of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between North Carolina
and the U.S. Environmental Protection Agency dated May 9, 1994.
Minor changes to the total nitrogen language in the permit have been modified based on comments
from EPA Region IV, [ref. especially to Condition A.(4.)].
To reiterate what was stated with the draft permit, the following changes have been made
during this renewal cycle:
• The effluent limits pages for the expansion to 2.5 MGD have been included (along with the existing
design flow of 1.9 MGD).
• Based on a statistical analysis (reasonable potential analysis - RPA) of the existing data, the
Division has determined that no reasonable potential to exceed the water quality acute level for
lead exists, so lead monitoring will be eliminated from the permit. However, the Town will still be
required to perform quarterly monitoring via the pretreatment Long Term Monitoring Plan.
• Reasonable potential to exceed the acute values for copper, zinc, and silver still exist. Copper and
zinc monitoring will remain at a frequency of 1 /month. Because Clayton is consistently passing
the toxicity testing requirement, silver monitoring will be reduced to monthly during this permit
cycle.
Based on outstanding comments from EPA, the Division of Water Quality was required to
implement a policy to adopt weekly average NH3-N (ammonia) limits for municipalities, as required
by the Code of Federal Regulations. This implementation policy was adopted October 15, 2002.
The weekly average values are three times the monthly average values (this value was established
based on a review of treatment capability at various municipal plants). This permit includes both
monthly average and weekly average limits for NH3-N for the existing flow and the expanded flow.
1617 MAIL SERVICE CENTER, RALEIGH, NORTH CARouNA 27699-1617 - TELEPHONE [phone]/FAX [phone]
AN EQUAL OPPORTUNITY AFFIRMATIVE ACTION EMPLOYER - So% RECYCLED/ 1 0% POST -CONSUMER PAPER
VISIT US ON THE WEB AT http://h2o.enr.state.nc.us/NPDES

Mr. Biggs i +,
NCO025453
2 T
• In order to have complete information for the next permit renewal, the pollutant scan has been
added to the permit [ref. Condition A.(7.)].
If any parts, measurement frequencies, or sampling requirements contained in this permit are
unacceptable to you, you have the right to an adjudicatory hearing upon written request within thirty
(30) days following receipt of this letter. This request must be in the form of a written petition,
conforming to Chapter 150B of the North Carolina General Statutes, and filed with the office of
Administrative Hearings, Mail Service Center 6714, Raleigh, North Carolina 27699-6714. Unless such
a demand is made, this permit shall be final and binding.
Please take notice that this permit is not transferable except after notice to the Division of
Water Quality. The Division of Water Quality may require modification or revocation and reissuance of
the permit.
This permit does not affect the legal requirements to obtain other permits which may be required by
the Division of Water Quality, the Division of Land Resources, the Coastal Area Management Act, or any
other federal or local governmental permit.
If you have any questions regarding the final NPDES permit, please contact Susan Wilson at
(919) 733 - 5083, extension 510.
Sincerely,
W. Klimek, P.E.
cc: Raleigh Regional Office/Water Quality Section
NPDES Unit
EPA Region IV, Roosevelt Childress
Shankar Mistry, Ph.D., P.E. The Wooten Company
120 North Boylan Avenue
Raleigh, NC 27603

1f
4
Permit No. NCO025453
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELUMMATION 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 Water Quality Commission, and the
Federal Water Pollution Control Act, as amended,
Town of Clayton
Little Creek Water Reclamation Facility
is hereby authorized to discharge wastewater from a facility located at
Little Creek Water Reclamation Facility,
On Durham Street Extension
Clayton
Johnston County
to receiving waters designated as the Neuse River in the Neuse River Basin
in accordance with the discharge limitations, monitoring requirements, and other conditions set forth in
Parts I. II, III, and IV hereof.
This permit shall become effective April 1, 2003.
This permit and the authorization to discharge shall expire at midnight on March 31, 2008.
Signed this day March 11, 2003.
an W. Klimek, P.E., ector
Division of Water Quality
By the Authority of the Environmental Management Commission
Clayton kVX- %TP
NPDES No. NCO02545-P

`J]
.k
SUPPLEMENT TO PERMIT COVER SHEET
Town of Clayton
Little Creek Water Reclamation Facility
is hereby authorized to:
Permit No. NC0025453 Y
1. Continue to operate an existing 1.9 MGD wastewater treatment facility consisting of
a mechanical bar screen, grit removal, parshall flume with flow measurement,
primary clarifier/digester, trickling filter, dual oxidation ditches, dual secondary
clarifiers, tertiary filters, ultraviolet disinfection, chlorine contact chamber, sulfur
dioxide dechlorination, sludge thickener tank, aerobic sludge digester, and sludge
drying beds located at the Little Creek Water Reclamation Facility, Durham Street
Extension, Clayton, Johnston County, and
2. Discharge wastewater from said treatment works at the location specified on the
attached map into the Neuse River, which is classified WS-IV NSW CA waters, in Neuse
River Basin.
3. After receiving an Authorization to Operate from the Division of Water Quality, the
Town may operate the facility to a maximum design flow of 2.5 MGD, and discharge to
the point listed above.
Town of Clayton
NPDES No. NC0025453

Latitude: 35°39'50" Sub -Basin: 03-04-02
Facility ' K
Longitude: 78°25' 26" LOCatlOrl
r
Quad #: E25NW, Clayton
Stream Class: WS-IV, NSW CA
Receiving Stream: Neuse River, Neuse River Basin
Permitted Flow: 1.9 MGD, to 2.5 MGD Clayton Little Creek WRF
NC0025453
L , ,
North].

A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - FINAL
During the period beginning on the effective date of the permit and lasting until expansion or
expiration, the Permittee is authorized to discharge 1.9 MGD of municipal wastewater from outfall
001. Such discharges shall be limited and monitored by the Permittee as specified below:
Effluent Characteristics
Limits
Monitoring Reguirements
Monthly
Average
Weekly
Average
Daily
Maximum
Measurement
. Frequency
Sample Type
Sample
Locationl
Flow
1.9 MGD
Continuous
Recording
Influent or
Effluent
BOD, 5 day (20°C)2
[April 1- October 31J
5.0 mg/I
7.5 mg/l
Daily
Composite
Influent &
Effluent
BOD, 5 day (209C)2
[November 1- March 31 ]
10.0 mg/I
15.0 mg/I
Daily
Composite
Influent &
Effluent
Total Suspended Residue2
30.0 mg/I
45.0 mg/I
Daily
Composite
Influent &
Effluent
NH3 as N Aril 1- October 31
2.0 mg/I
6.0 m I
Dail
Composite
Effluent
NH3 aS N November 1- March 311
4.0 mgA
12.0 mg/I
Daily
Composite
Effluent
Dissolved Oxygen3
Daily
Grab
Effluent
Dissolved Oxygen
3/Week
Grab
Upstream &
Downstream
Fecal Coliform(geometric mean
200/100 ml
400/100 ml
Daily
Grab
Effluent
Fecal Coliform (geometric mean)
3Meek
Grab
Upstream &
Downstream
Total Residual Chlor1ne4
28 µg/I
Daily
Grab
Effluent
TKN (mg/1)
Monitor & Report
Weekly
Composite
Effluent
NO2-N + NO3-N (mg/1)
Monitor & Report
Weekly
Composite
Effluent
TN (mg/1)5
Monitor & Report
Weekly
Composite
Effluent
Total Monthly Flow (MG)
Monitor & Report
Monthly
Calculated
Effluent
TN Loads
Monitor & Report
21,400 Loadin Mass Annual lb/year 7
( 9)
Monthly
Annually
Calculated
Calculated
Effluent
Effluent
Total Phosphorus 8
2.0 mg/L (Quarterly Average)
Weekly
Composite
Effluent
Temperature 'C
Daily
Grab
Effluent
Temperature (°C)
3/Week
Grab
Upstream &
Downstream
Conductivity
Daily
Grab
Effluent
Conductivity
3/Week
Grab
`Upstream &
Downstream
Chronic Toxici 9
Quarterly
Composite
Effluent
Copper
Monthly
Composite
Effluent
Zinc
Monthly
Composite
Effluent
Silver
Monthly
Composite
Effluent
H10
6-9
Daily
Grab
Effluent
(Footnotes on nest page)
Town of Clayton
NPDES No. NCO025453

A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS — FINAL
(Continued)
Footnotes:
1. Sample locations: E - Effluent, I - Influent, U - Upstream at NCSR 1700, D - Downstream at
(1) NC Highway 42 and (2) NCSR 1908. Stream samples shall be grab samples and shall be
collected 3/Week during June - September and 1 /Week during the remaining months of the
year. Instream monitoring is provisionally waived in light of the permittee's
participation in the Lower Neuse Basin Association. Instream monitoring shall be
conducted as stated in this permit should the permittee end its participation in the
Associaiton.
Per 15A NCAC 2B .0505(c)(4), stream sampling (as well as influent/effluent sampling) may be
discontinued when flow conditions could result in injury or death of the person(s) collecting
the samples. In such cases, on each day that sampling is discontinued, written justification
shall be specified in the monitoring report for the month in which the event occurred.
2. The monthly average effluent BOD5 and Total Suspended Residue concentrations shall not
exceed 15% of the respective influent value (85% removal).
3. The daily average dissolved oxygen effluent concentration shall not be less than 6.0 mg/l.
4. Total residual chlorine is required only if chlorine is used as a disinfectant (or elsewhere in the
process).
5. TN means Total Nitrogen. For a given wastewater sample, TN is the sum of Total Kjeldahl
Nitrogen and Nitrate -Nitrite Nitrogen: TN = TKN + NO2-N + NO3-N.
6. TN Load is the mass load of TN discharged by the Permittee in a period of time. See Special
Condition A.D.), Calculation of TN Loads.
7. The annual TN Load limit shall become effective with the calendar year beginning on January
1, 2003. Compliance with this limits shall be determined in accordance with Special Condition
A.(4.), Annual Limits for Total Nitrogen.
8. The quarterly average for total phosphorus shall be the average of composite samples collected
weekly during the calendar quarter (January -March, April -June, July -September, October -
December).
9. Chronic Toxicity (Ceriodaphnia dubia) P/F at 1.60k: March, June, September, and December
[see Special Condition A.(5)]. Toxicity monitoring shall coincide with metals monitoring.
10. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall
be monitored daily at the effluent by grab sample.
There shalt be no discharge of floating solids or visible foam in other than trace amounts.
Town of Clayton
NPDES No. NCO025453

a
y
A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - FINAL
During the period beginning upon expansion above 1.9 MGD or expiration, the Permittee is
authorized to discharge up to 2.5 MGD of municipal wastewater from outfall 001. Such
discharges shall be limited and monitored by the Permittee .as specified below:
Effluent Characteristics
Limits
Monitoring Requirements
Monthly
Average
Weekly
Average
Daily
Maximum
Measurement
Frequency
Sample Type
Sample
Locationl
Flow
2.5 MGD
Continuous
Recording
Influent or
Effluent
BOD, 5 day (20°C)2
[April 1- October 31 ]
5.0 mg/I
7.5 mg/I
Daily
Composite
Influent &
Effluent
BOD, 5 day (20'C)2
[November 1- March 31 ]
10.0 mg/I
15.0 mg/l
Daily
Composite
Influent &
Effluent
Total Suspended Res1due2
30.0 mg/I
45.0 mg/l
Daily
Composite
Influent &
Effluent
NH3 as N dl 1- October 31
1.0 mg/I
3.0 mg/I
Daily
Composite
Effluent
NH3 as N November 1- March 31
2.0 Mg/1
6.0 mg1I
Daily
Composite
Effluent
Dissolved Oxygen3
Daily
Grab
Effluent
Dissolved Oxygen
3/Week
Grab
Upstream &
Downstream
Fecal Coliform(geometric mean
200/100 ml
400/100 ml
Daily
Grab
Effluent
Fecal Coliform (geometric mean)
3/Week
Grab
Upstream &
Downstream
Total Residual Chlorine4
28 µg/I
Daily
Grab
Effluent
TKN (mg/I)
Monitor & Report
Weekly
Composite
Effluent
NO2-N + NO3-N (mgll)
Monitor & Report
Weekly
Composite
Effluent
TN (mg/I)5
Monitor & Report
Weekly
Composite
Effluent
Total Monthly Flow (MG)
Monitor & Report
Monthly
Calculated
Effluent
TN Load6
Monitor & Report (lb/month)
21,400 lb/year Annual Mass Loadin 7
Monthly
Annually
Calculated
Calculated
Effluent
Effluent
Total Phosphorus 8
2.0 mg/L (Quarterly Average)
Weekly
Composite
Effluent
Temperature 4C
Daily
Grab
Effluent
Temperature (-C)
3/Week
Grab
Upstream &
Downstream
Conductivity
Daily
Grab
Effluent
Conductivity
3/Week
Grab
Upstream &
Downstream
Chronic Toxicity9
Quarterly
Composite
Effluent
Copper
Monthly
Composite
Effluent
Zinc
Monthly
Composite
Effluent
Silver
Monthly
Composite
Effluent
H10
6-9
Daily
Grab
Effluent
(Footnotes on next page)
Town of Clayton
NPDES No. NCO025453

A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - FINAL -
(Continued)
Footnotes:
1. Sample locations: E - Effluent, I - Influent, U - Upstream at NCSR 1700. D - Downstream at
(1) NC Highway 42 and (2) NCSR 1908. Stream samples shall be grab samples and shall be
collected 3/Week during June - September, and 1 /Week during the remaining months of the
year. Instream monitoring is provisionally waived in light of the permittee's
participation in the Lower Neuse Basin Association. Instream monitoring shall be
conducted as stated in this permit should the permittee end its participation in the
Associaiton.
Per 15A NCAC 2B .0505(c)(4), stream sampling (as well as influent/effluent sampling) may be
discontinued when flow conditions could result in injury or death of the person(s) collecting
the samples. In such cases, on each day that sampling is discontinued, written justification
shall be specified in the monitoring report for the month in which the event occurred.
2. The monthly average effluent BOD5 and Total Suspended Residue concentrations shall not.
exceed 15% of the respective influent value (85% removal).
3. The daily average dissolved oxygen effluent' concentration shall not be less than 6.0 mg/l.
4. Total residual chlorine is required only if chlorine is used as a disinfectant (or elsewhere in the
process) .
5. TN means Total Nitrogen. For a given wastewater sample, TN is the sum of Total Kjeldahl
Nitrogen and Nitrate -Nitrite Nitrogen: TN = TKN + NO2-N + NO3-N.
6. TN Load is the mass load of TN discharged by the Permittee in a period of time. See Special
Condition A.(3.), Calculation of TN Loads.
7. The annual TN Load limit shall become effective with the calendar year beginning on January
1, 2003. Compliance with this limits shall be determined in accordance with Special Condition
A.(4.), Annual Limits for Total Nitrogen. -
8. The quarterly average for total phosphorus shall be the average of composite samples collected
weekly during the calendar quarter (January -March, April -June, July -September, October -
December).
9. Chronic Toxicity (Ceriodaphnia dubia) P/F at 2.0 W March, June, September, and December
[see Special Condition A.(6)]. Toxicity monitoring shall coincide with metals monitoring.
10. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall
be monitored daily at the effluent by grab sample.
?'here shalt be no discharge of floating solids or visible foam in other than trace amounts.
Town of Clayton
NPDES No. NCO025453

A.(3.). CALCULATION OF TOTAL NITROGEN LOADS
a. * The Permittee shall calculate monthly and annual TN Loads as follows:
L Monthly TN Load (lb/mo) = TN x TMF x 8.34
where:
TN = the average Total Nitrogen concentration (mg/ L) of the
composite samples collected during the month
TMF = the Total Monthly Flow of wastewater discharged during the
month (MG/mo)
8.34 = conversion factor, from (mg/L x MG) to pounds
H. Annual TN Load (lb/yr) = Sum of the 12 Monthly TN Loads for the calendar year
b. The Permittee shall report monthly Total Nitrogen results (mg/L and lb/mo) in the discharge
monitoring report for that month and shall report each year's annual results (lb/yr) in the
December report for that year.
A.(4.) ANNUAL LIMITS FOR TOTAL NITROGEN
a. Total Nitrogen (TN) allocations and TN Load limits for NPDES dischargers in the Neuse River
basin are annual limits and are applied for the calendar year.
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 Load is less than or equal to said limit, or
ii. the Permittee is a Co-Permittee Member of a compliance association.
c. 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:
NCDWQ / NPDES Unit
Attn: Neuse River Basin Coordinator
Mail Service Center
Raleigh, NC 27699-1617
Town of Clayton
NPDES No. NCO025453

d. If the Permittee is a member and co-permittee of an approved compliance association, its TN
discharge during that year is governed by that association's group NPDES permit and the TN
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.
(1) Upon receipt of timely and proper notification, the Division will modify the permit
as appropriate and in accordance with state and federal program requirements.
(2) Membership changes in a compliance association become effective on January 1
of the year following modification of the association's permit.
e. 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. (5.) CHROMC TOXICITY PERMIT LIMIT (QRTRLY)
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant
mortality to Cerivdaphnia dubia at an effluent concentration of LS %.
The permit holder shall perform at a minimum, quarterlu monitoring using test procedures
outlined in the "North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised
February 1998, or subsequent versions or "North Carolina Phase II Chronic Whole Effluent
Toxicity Test Procedure" (Revised -February 1998) or subsequent versions. The tests will be
performed during the months of March, June, September, and December. Effluent sampling for
this testing shall be performed at the NPDES permitted final effluent discharge below all treatment
processes.
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 -February 1998) or subsequent versions.
The chronic value for multiple concentration tests will be determined using the geometric mean of
the highest concentration having no detectable impairment of reproduction or survival and the
lowest concentration that does have a detectable impairment of reproduction or survival. The
definition of "detectable impairment," collection methods, exposure regimes, and further statistical
methods are specified in the "North Carolina Phase II Chronic Whole Effluent Toxicity Test
Procedure" (Revised -February 1998) or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent
Discharge Monitoring Form (MR-1) for the months in which tests were performed, using the
parameter code TGP3B for the pass/fail results and THP3B for the Chronic Value. Additionally,
DWQ Form AT-3 (original) is to be sent to the following address:
Attention: North Carolina Division of Water Quality
Environmental Sciences Branch
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Town of Clayton
NPDES No. NC0025453

A. (5.) CHRONIC TOXICITY PERMIT LIMIT (QRTRLY) (cont'd.)
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch 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 Environmental Sciences Branch at the address cited above.
Should the permittee fail to monitor during a month in which toxicity monitoring Is required,
monitoring will be required during the following month.
Should any test data from this monitoring requirement or tests performed by the North Carolina
Division of Water Quality indicate potential impacts to the receiving stream, this permit may be re-
opened and modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum
control organism survival, minimum control organism reproduction, and appropriate
environmental controls, shall constitute an invalid test and will require immediate follow-up
testing to be completed no later than the last day of the month following the month of the initial
monitoring.
A. (6.) CHRONIC TOXICITY PERMIT LIMIT (QRTRLY)
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant
mortality to Ceriodaphnia dubia at an effluent concentration of 2.0 %.
The permit holder shall perform at a minimum, quarteriu monitoring using test procedures
outlined in the "North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised
February 1998, or subsequent versions or "North Carolina Phase II Chronic Whole Effluent
Toxicity Test Procedure" (Revised -February 1998) or subsequent versions. The tests will be
performed during the months of March, June, September, and December. Effluent sampling for
this testing shall be performed at the NPDES permitted final effluent discharge below all treatment
processes.
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 -February 1998) or subsequent versions.
Town of Clayton
NPDES No. NCO025453

A. (6.) CHRONIC TOXICITY PERMIT LIMIT (QRTRLY) (cont'd.)
The chronic value for multiple concentration tests will be determined using the geometric mean of
the highest concentration having no detectable impairment of reproduction or survival and the
lowest concentration that does have a detectable impairment of reproduction or survival. The
definition of "detectable impairment," collection methods, exposure regimes, and further statistical
methods are specified in the "North Carolina Phase II Chronic Whole Effluent Toxicity Test
Procedure" (Revised -February 1998) or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent
Discharge Monitoring Form (MR-1) for the months in which tests were performed, using the
parameter code TGP3B for the pass/fail results and THP3B for the Chronic Value. Additionally,
DWQ Form AT-3 (original) is to be sent to the following address:
Attention: North Carolina Division of Water Quality
Environmental Sciences Branch
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch 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 Environmental Sciences Branch at the address cited above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required,
monitoring will be required during the following month.
Should any test data from this monitoring requirement or tests performed by the North Carolina
Division of Water Quality indicate potential impacts to the receiving stream, this permit may be re-
opened and modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum
control organism survival, minimum control organism reproduction, and appropriate
environmental controls, shall constitute an invalid test and will require immediate follow-up
testing to be completed no later than the last day of the month following the month of the initial
monitoring.
Town of Clayton
NPDES No. NCO025453

A. (7.) EFFLUENT POLLUTANT SCAN
The permittee shall perform an annual pollutant scan of its treated effluent for the following
parameters:
Ammonia (as N)
Trans-1,2-dichloroethylene
Bis (2-chloroethyl) 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
Total Kjeldahl nitrogen
Ethylbenzene
Butyl benzyl phthalate
Oil and grease
Methyl bromide
2-chloronaphthalene
Total 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-dichlombenzene
Copper
Vinyl chloride
3,3-dichlorobenzidine
Lead
Acid -extractable compounds:
Diethyl phthalate
Mercury
P-chloro-m-creso
Dimethyl phthalate
Nickel
2-chlorophenol
2,4-dinitrotoluene
Selenium
2,4-dichlorophenol
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-chlomethylvinyl ether
Benzo(a)pyrene
Phenanthrene
Chloroform
3.4 benzoftuoranthene
Pyrene
Dichlorobromomethane
Benzo(ghi)perylene
1.2.4-trichlorobenzene
1. 1 -dichloroethane
Benzo(k)fluoranthene
1.2-dichloroethane
Bis (2-chloroethoxy) methane
1.
The total set of samples analyzed during the current term of the permit must be representative
of seasonal variations.
2.
Samples shall be collected and analyzed in accordance with analytical methods approved
under 40 CFR Part 136.
3.
Unless indicated otherwise, metals must be analyzed and reported as total recoverable.
4.
Test results shall be reported
to the Division in DWQ Form- DMR-PPAI or in a form approved
by the Director, within 90 days of sampling. Two copies of the
report shall be submitted along
with the DMRs to the following address: Division of Water Quality, Water Quality Section,
Central Files, 1617 Mail Service Center, Raleigh, North Carolina 27699-1617.
Town of Clayton
NPDES No. NCO025453
It

DENR/DWg
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES No. NC0025453, Clayton/ Little Creek WRF
Facility Information
Applicant/ FaciliName:
Town of Clayton/ Little Creek Water Reclamation Facility
Applicant Address:
P.O. Box 879, Clayton, NC 27520
Facility Address:
Durham Street Extension
Permitted Flow
1.9 MGD (expansion request to 2.5 MGD)
Type of Waste:
- 22% Ind., -78% Domestic (at permitted flow)
Facility/ Perrmt Status:
Renewal
County:
Johnston
Miscellaneous
Receiving Stream:
Neusc River
Regional Office:
RRO
Stream Classification:
\
WS-IV NSW CA
SI: 27-41.3
Quad
E25NW
Cla on
303(d) Listed?:
Yes
Permit Writer:
S. Wilson
Subbasin:
030402
Date:
January 003
Drainage Area (mi2):
1150
Summer 7 10 (cfs)
186 (regulated)
Winter 7Q10 (cfs):
Average Flow (cfs):
fWC (%):
1.6
Primary SIC Code:
4952
SUMMARY
Clayton operates a 1.9 MGD wastewater treatment facility that discharges into the Neuse River.
Average annual flow has been approximately 1.4 MGD (appx. 74% of permitted flow). Due to
the exponential growth in this area outside of Raleigh, Clayton proposes to expand from 1.9
MGD to 2.5 MGD. The Town will accomplish this through some construction additions and the
re -rating of the existing plant. An `Authorization to Operate' will have to be attained prior to
the expansion to 2.5 MGD - to ensure that all components can accommodate the increase in
flow. This expansion is not the 20 year projected flow, but will provide Clayton with some
capacity for growth. The Town is also in the process of adding biological nutrient removal,
which would ultimately decrease the nitrogen load to the Neuse River.
An alternative analysis was done to ensure that the discharge from this regional facility was the
most feasible alternative. [There are no nearby, cost effective areas for spray application of the
expanded flow. Due to the distance and cost, discharge to the City of Raleigh was not a feasible
option. Clayton continues to divert some wastewater to Johnston County. The Town has
received some grant funding for diverting re -use wastewater to a nearby golf course.].
The Clayton facility discharges to the mainstem of the Neuse River. According to the Basinwide
Water Quality Management Plan for the Neuse, the primary water quality considerations for
point sources in the basin are discharges of (1) oxygen -demanding substances and (2)
nutrients.
The Modeling Unit evaluated the impact of increased wastewater flows on dissolved oxygen
levels, using a QUAL2E model already developed for the Neuse River. The results show that,
with an increase in the Town's discharge to 2.5 MGD, the D.O. level in the river will remain
above the standard of 5.0 mg/L. Thus, the modeling results indicate the adverse impact of the
expanded discharge to be acceptable.
Point source rules regarding control of TN and TP have been passed by the EMC. To address
the nutrient reduction issue, the Town is a participant in the Neuse River Compliance
Association (this will allow the facility to comply with the nitrogen limit through the
Association). The Town also is currently in the process of seeking approval for biological
nutrient removal through the Construction Grants & Loans section.
NCO025453 Clayton
NPDES Renewal & Expansion to 2.5 MGD
Page I

Antidegradation
The Town of Clayton prepared an Environmental Assessment demonstrating that the
recommended alternative is the most environmentally sound of the reasonably cost-effective
options. The Division issued a Finding of No Significant Impact (FONSI) for the expansion on
February 24, 2002. The Division of Water Quality determined that the incremental impact of
the increased discharge will not result in contravention of applicable water quality standards or
loss of the river's designated uses. The Division concluded that expansion of the existing
treatment plant and continued discharge to the Neuse River is the most feasible alternative.
The expanded plant will serve as a regional treatment facility for the area. The Division has
determined that the proposed expansion is necessary to accommodate social and economic
growth in the area and that it will not result in contravention of surface water quality
standards or loss of designated uses in the receiving stream.
TOXICITY TESTING:
Current Requirement: Chronic P/F @ 1.6% (at 1.9 MGD)
Chronic P/F at 2.0 % (at 2.5 MGD)
Clayton has had 1 failure during the previous 5 years (that failure was followed -up with 2
passes).
COMPLIANCE SUMMARY: BASED ON THE PREVIOUS 2 YEARS
Clayton has had some limit excursions for ammonia and BOD5 (in the past 2 years), with
values below the threshold for automatic civil penalties. Additional treatment capacity may
help eliminate these minor excursions.
INSTREAM MONITORING:
Clayton is part of the Lower Neuse Basin Association (LNBA) and is not required to perform the
instream monitoring required in this permit. (The LNBA monitors several sites for various
facilities along the Neuse River).
PROPOSED CHANGES:
Clayton has been accepted as a member of the Neuse River Compliance Association. Special
language has been inserted into the permit regarding the compliance stipulation for total
nitrogen. The total phosphorus limit of 2 mg/1 was instituted in the previous permit (and since
Clayton is a member of the Compliance Association, the 2 mg/1 TP limit is applied again in this
permit).
Clayton monitors for copper, zinc, silver, and lead through the NPDES permit.
The Town of Clayton operates under an approved pretreatment program and must comply with
its Long Term Monitoring Plan (LTMP). As part of the pretreatment program, Clayton monitors
for arsenic, cadmium, chromium, mercury, molybdenum, nickel, selenium, and cyanide (and
these will continue through the pretreatment program) - copper, zinc, silver, and lead are also
required. Most values have been below detection level, and well below allowable levels, for all
except molybdenum. There is no water quality standard for molybdenum (and Mo will continue
to be monitored through the pretreatment program and the residuals permit), so no limit or
monitoring requirement will be imposed in the NPDES permit.
Other than conventional parameters, the parameters sampled in the application only had above
detection levels for copper, lead, silver, and zinc (which are currently monitored through the
permit). No changes are proposed based on information in the permit application.
Copper, silver and zinc will continue to be monitored due to the potential to exceed the action
level standard at the acute level. Copper and Zinc will be monitored at 1 /month due to
Clayton's "pass" on toxicity testing. Silver monitoring will be reduced to 1 /month. Lead
monitoring will remain at a quarterly frequency.
NC0025453 Clayton
NPDES Renewal & Expansion to 2.5 MGD
Page 2

Lead will be eliminated because the reasonable potential analysis showed that lead levels were
below the acute value. Lead will continue to be monitored quarterly via the facility's
pretreatment program LIMP.
Based on the NH3-N policy adopted October 15, 2003, weekly average NH3-N limits have been
inserted for the existing flow (1.9 MGD) and the expansion flow (2.5 MGD).
An annual priority pollutant scan has also been inserted in the permit to ensure that the
permittee complies with the requirement in the municipal permit applications.
PROPOSED SCHEDULE FOR PERMIT ISSUANCE:
Draft Permit to Public Notice: After Jan. 8, 2003
Permit Scheduled to Issue: Feb 28, 2003 (est.)
STATE CONTACT:
If you have any questions on any of the above information or on the attached permit, please
contact Susan Wilson, P.E. at [phone] ext. 510.
REGIONAL OFFICE COMMENT:
(Staff report received October 29, 2002).
NAME: � DATE:
NCO025453 Clayton
NPDES Renewal & Expansion to 2.5 MGD
Page 3

Whole Effluent Toxicity Testing Self -Monitoring Summary November 13, A
FACILITY REQUIREMENT YEAR IAN PER MAR APR MAY JUN JUL AUG SEP OCT NOV DEC
CRgo-Paw Crk Bulk Terminal Penn: 246r LC50 ac moon epic 0nd Utah)
I998 — —
—
-IN —
—
—
— —
—
— —
NC(M2196Y001 Bcgin:9/1200I Frt9mmry:A
NonComp:
1e99 — —
—
— —
-IN
—
— —
—
— —
Couny. Mccklenbutg Region: MRO Subbain: CTB34
2090 -IN —
—
— —
—
—
— —
—
— —
PF: NA SIvoil
2Wl — >1013
7QW: 0.0 IWC(u)IJOO (hoer:
2aM — —
—
-- —
—
—
— —
ClnremantNorrhYAVTP P. chr llm: 13%
1998 Pau —
—
Pau —
—
Paw
— —
Pa.>
— —
NC0032662/001 BeginAllaNI Fmgooney:Q Ian APr Jul Oct
+ NotuCon iSingle
INS, Pau —
—
Pass —
—
Pas.
— --
Pea.
— —
Coumy. Gtawba Region: MRO Subbain: M32
2N, Pau —
—
Pam —
—
Pas.
— —
Pau
— —
PF. 0.10 smal
2001 Pau —
_
Paw _
_
PW
— —
Pau
— —
7Q10:1.0 IWC(%):13 aov:
2N2 Pani.Paw —
—
Pau —
—
Pau
— —
Pau
Ch remora South 3V3vl'P Penn chr len 61%
1998 1 ——
NC0026549N01 ThWn,41112001 FragNw,:0 Jan Apr Jul Oct
+ NNCN,:Singlc
tell I ——
Caunry: Catawba Region: MRO Subbain: UR32
2000 1 —
—
I—
PF:0.10 SPmut
2NI 1 —-
7QIO:0Ao IWC(•.):60.78 aav:
2002 1 —
Claremont-MCLin Creek WWTP Petra chr lira: 9%
1998 Pau —
—
Pass —
—
Paw
— —
Pau
— —
NCO081370/001 Begin:6/1/2001 Frtquency:Q Jan Apr Jul Oct
+ NonComp:Single
1999 Pass —
—
Pew —
--
Pas
— —
Pas
— —
Coumy: C i awba Regian: MRO Subbain: CTR32
JON Paw —
—
Pass —
—
Pew
— —
Pass
-- --
PF: 0.3 Spaid
2001 Pau —
—
Pass —
--
Paas
-- -
Pa.s
-- -
7Q10:5.0 IWC(Sg5.0 Omv:
2002 Paw —
—
Pass —
—
Pas
— —
Pa95
Clads. Corp:Ml. Jlolly Plat, PERM CUR LIM: 1.8%
v 1998 — —
Pass
— —
Paw
—
— Paw
—
— Paw
NCOOU43751011I Bcgin:WI/IWI Fmquemy: Q P/F + Mar Jun Sep Dcc
NonCOmp:Svlgie
tell — —
Pow
— --
Pass
Pass
— NR
Pass
— NR`Paw
County: Mecklenburg Region: MRO Subbasirt UH34
JOIN — —
Pass
— —
Pass
—
— Paw
—
— Pat
PF: 3.9 Simm
2001 — _
Paw
— —
Pass
—
— Paw
—
— Pass
7Q10: 329 lWC(%):I.B omen:
20112 — —
Paw
— —
Paw
—
— Paw
ClarNon 3VWTP Pam rin It.: 90%
I999 Paw —
—
Fa Paw
—
Pass
Paw
NCIN21610M) BcgurlN1/1999 Frtganry:Q Jan Apr Jul Oct
+ Noncomp:Single
19911 Paw —
—
Paw —
—
Fail
Paw —
Paw
—
Count,, Bud. Region: FRO Subbain: LUM58
20N Fall 94.9
-IN
Paw —
—
Pass
— —
Fall
>100 >1N
PF: 024 Spwii
Joy a1IN —
—
-IN —
--
Pass
— —
Paaa
— —
7Q10 Op lwco1)100 qua:
JIM Paw —
—
Paw —
—
Paw
— —
"ICI.,I..WSYTP Penn chr lira: 1.6%
1998 —
— Pea — —
Paw
— — Paw —
— Pew
• NC0024453MOT Beglu:'0/2000 Fro cxcy:Q Mar Jun Sap Dec + No CoiV:SiVk,
1999 — —
Paw — —
Paw
— — Paw —
— Paw
Comny: Johnston Rcyion: no Subbain: NEU02
2000 — --
Paaa — —
Pau
>6 fie -661 Pau —
— Paw
IT 19 Slaaiat
2N1 — _
Paw _ —
Paw
— — Pass —
_ Paw
7QIU: 196 IWC(%):1.6 ado:
2002 — —
Pass >100.N00 —
Paw
Paw)tN
Cleveland ..3E11001 PERM CUR LIM:2.4%: IF EXP>.78MGD Q 3.4%
1198 —
— Lat. Pas —
paw — —
Paw --
- paw
\CO00,1120001 Bcgin:9/1/1993 Fre ion,: Q P/P + M.r Jun Sep Dee
NNC.cVSINGLE
1999 —
— Paw — —
Pass — —
Paw --
- Pat
Coumv: Cleveland Region: MRO SuNo im BRD04
JON —
— Pass — —
Pass — —
Pass --
- Pau
PF: 0.7E Spam
2001 —
— Paw — —
Paw — —
NRAI -
7Q10:41.40 IWC(%)IA (hdm
2002 —
— H — —
H — —
H
Cleveland W WTP Perm chr Iim: 3.0%
1998 Pass
— Pass — --
Pwa -- -
Paw —
— Pain
NC0049967/00I Begin:3/12000 Frequcncy:0 M. Jun Sep Dec
+ NouComp:Sindc
1999 —
— Fail Pan —
We Paw —
Pass —
— Paw
Caamry: Rmvan Region: MRO Subbain: YADO6
20N —
— NRIPass -- -
P9w.Pa.> — —
Paw
Peas
PF: 0.27 SMeiel
2Nt —
— Paw — —
Pau — —
Pass --
- We
7QIO: 140 IWC(0)3.0 au.+:
2002 Pew
— Pau — —
Paw — —
Pew
Clinton-LitrWa WPCF N. chr lira:%%
1998 —
— >IN — —
>N — —
NCN2011710I Begin:WI/1996 Frequrnry: Q P/F + Marlun Salr Dee
NonCorltp:Svtglc
two —
— Face — —
Paw — —
Paw —
— Fee
Cowy. Sampson Region: PRO Subbain: CPF19
2N0 Pm
>1IN alN Fos — —
Paw — —
Pass —
— Pan
PF: 5.0 Slain
pot —
— Pal — —
Paw — —
Paw —
— Fail
7Q10: 0.0 IWC(V.):100 adn.
2IN2 >1IN
>IN Pace — —
>N — —
>N
LEGEND:
PERM= Past rem Requient LET=AJ inishadvc Ldw-Target Frequency= Mountain, frequency: Q-Quarely; M-Monthly; BM-Bi thly;SA. Semimmwlly;A- Annually:OWD- Only when diuhetWng:D- Discontinued monitoring requirement
Bcoui—First laamhrrquirN 7Q10=Rttcidn6 smart low Bowciwri.(c4) — wancrly monitoring incrowas to manthly, upon Tallurt or be Montle that cating mat occur- ex. lan. Apr. Jul. Oct NonCottm— Cunene Compliance Riquiremcnt
PF=PC .,udnaw(MGD) IWCI-Imrreaavnexcancennation P/F=PawFail tut AC=Acute CHR=Chronic
Dam Noation:LFollhh JMinnow;•-Ccrioslapbrda sp.;my-MysiJ shrimp;ChV-Chronic veluq P-Morality of.tamd perccmegeahighest roncmlmdom et-Perfamtwl by DWQAgwtic Tox Unil;br Bod tat
Rcponing Notation: Win notin Bred: NR-Not repainted Facility Activity Statwa-Inactive. N- Newly luucd('T. cot +rum);H- Active but ra, discharging; t-More dent availableforor momh in question;•= ORC sipamrc needed
10

Facility Name = Clayton - Little Creek WRF
NPDES # = NC0025243
Qw (MGD) = 2.5
7QIOs (cfs)= 186
1WC 2.04
FINAL RESULTS
Copper
Max. Pred Cw 35.8
Allowable Cw 3430
\ kt. uE, 7.3
RESULTS
Std Dev. 3.5555
Mean 4.2
C.V. 0.8563
Number
of data points
25
Mult Factor =
2.75
Max. Value
13.0
µg/l
Max. Pred Cw
35.8
µg/l
Allowable Cw
343.0
µg/l
Entered by S. Wilson
Parameter = Copper
Standard = 7.0 µg/l
Date n
<
Actual Data
BDL=1/2DL
Oct-02
1
4.
4.00
2
12.
12.00
3
13.
13.00
4
10.
10.00
5
<
10.
5.00
6
6.6
6.60
7
7.3
7.30
8
<
2.
1.00
9
<
2.
1.00
10
<
2.
1.00
11
2.4
2.40
12
<
2.
1.00
13
2.
2.00
14
<
2.
1.00
15
2.3
2.30
16
<
2.
1.00
17
<
2.
1.00
18
2.2
2.20
19
4.4
4.40
20
3.2
3.20
21
<
2.
1.00
22
s.
5.00
23
4.4
4.40
24
8.2
8.20
Sep-00
25
3.8
3.80
Page 1

Facility Name = Clayton - Little Creek WRF
NPDES ## = NCO025453
Qw (MGD) = 2.5
7Q10s (cfs)= 186
IWC (Rlo) = 2.04
FINAL RESULTS
Silver
Max. Pred Cw 8.8
Allowable Cw 2.9
Acute value 1.2
RESULTS
Std Dev. 1.0618
Mean 1.5
C.V. 0.7032
Number
of data points
50
Mult Factor =
1.77
Max. Value
5.0 µg/l
Max. Pred Cw
8.8 µg/l
Allowable Cw
2.9 µgll
Entered by S. Wilson
#onJ ITO fas 1`3�
Parameter =
Silver
Action Level
Standard =
0.1
µgll
Date n
<
Actual Data
BDL=1/2DL
Oct-02 1
<
5.
2.50
2
<
5.
2.50
3
5.
5.00
4
<
5.
2.50
5
<
5.
2.50
6
<
5.
2.50
7
<
5.
2.50
8
<
5.
2.50
9
<
10.
5.00
10
<
10.
5.00
Oct-00 11
<
2.
1.00
12
<
2.0
1.00
13
<
5.0
2.50
14
<
2.0
1.00
15
<
2.0
1.00
16
<
2.0
1.00
17
<
2.0
1.00
18
<
2.0
1.00
19
<
2.0
1.00
20
<
2.0
1.00
21
<
2.0
1.00
22
<
2.0
1.00
23
<
2.0
1.00
24
<
2.0
1.00
25
<
2.0
1.00
26
<
2.0
1.00
27
<
2.0
1.00
28
<
2.0
1.00
29
<
2.0
1.00
30
<
2.0
1.00
31
<
2.0
1.00
Page 1

o c c c o o c o o V"> 0 0 0 0 0 o (D 0 0
CV CV CV cV CV N N cV N N N N N N N cV N cV cV
V V V V V V V V V V V V V V V V V V
M M M M M M M M d - dN 'MR* 4' t `"ch N
0)

Facility Name =
Clayton - Little Creek WRF
NPDES # =
NCO025453
Qw (MGD) =
2.5
7QI0s (cfs)=
1 186
IWC (%) =
2.04
FINAL RESULTS
Lead
Max. Pred Cw
31.8
Allowable Cw
1225.0
Acute value
33.8
RESULTS
Std Dev. 4.0857
Mean 4.9
C.V. 0.8362
Number
of data points
29
Mull Factor =
1.77
Max. Value
18.0 µgll
Max. Pred Cw
31.8 µg/1
Allowable Cw
1225.0 µgll
Entered by S. Wilson
Parameter = Lead
Standard = 25.0 j µg11
Date n < Actual Data BDL=1/2DL
Sep-02 1
<
10.
5.00
2
10.
10.00
3
<
5.
2.50
4
<
5.
2.50
5
13.
13.00
6
<
5.
2.50
7
5.8
5.80
8
18.
18.00
9
5.9
5.90
10
10.
10.00
11
12.
12.00
12
8.9
8.90
13
<
5.0
2.50
14
<
5.0
2.50
15
<
5.0
2.50
16
<
5.0
2.50
17
<
5.0
2.50
18
5.6
5.60
19
<
5.0
2.50
20
<
5.0
2.50
21
<
5.0
2.50
22
<
5.0
2.50
23
<
5.0
2.50
24
<
5.0
2.50
25
<
5.0
2.50
26
<
5.0
2.50
27
<
5.0
2.50
28
<
5.0
2.50
Sep-00 29
<
5.0
2.50
Page 1

Facility Name =
Clayton - Little Creek WRF
NPDES # =
NCO025453
Qw (MGD) =
2.5
7QIOs (cfs)=
186
lWC(%)=
2.04
Max. Pred Cw 476.7
Allowable Cw 2450.0
�.0
Acute value 67.0
ESULTS
d Dev. 56.2134
ean 124.4
V. 0.4518
data points 27
Factor =
1.77
Value
270.0 µg/I
Pred Cw
476.7 µg/I
sable Cw
2450.0 µg/I
Entered by S. Wilson
4t!+t' Uowiow (soNtrokoji
Parameter = Zinc
Standard = 50.0 1 µg/I
Date
n <
Actual Data
BDL=1/2DL
Sep-02
1
78.
78.00
2
118.
118.00
3
113.
113.00
4
160.
160.00
5
160.
160.00
6
20.
20.00
7
94.
94.00
8
97.
97.00
9
120.
t20.00
10
110.
110.00
11
160.
160.00
12
110.
110.00
13
10.
10.00
14
100.
100.00
15
270.
270.00
16
270.
270.00
17
180.
180.00
18
120.
120.00
19
120.
120.00
20
130.
130.00
21
110.
110.00
22
150.
150.00
23
110.
110.00
24
150.
150.00
25
110.
110.00
26
89.
89.00
9/1/00
27
100.
100.00
Page 1

Facility Name =
NPDES k =
Qw (MGD) =
7QIOs (cfs)=
IWC (%n) =
Clayton - Little Creek WRF
NCO025453
2.5
186
2.04
FINAL RESULTS
Mercury
Max. Pred Cw 0.4
Allowable Cw 0.6
ESULTS
d Dev. 0.0333
can 0.1
V. 0.3000
data points 9
Factor
Value
0.2 µg1l
Pred Cw
0.4 µgll
vable Cw
0.6 µg1I
Entered by S. Wilson
Parameter = Mercury
Standard = 0.012 µgll
Date
n
<
Actual Data
BDL=112DL
Sep-02
I
<
.2
0.10
2
<
.2
0.10
3
<
.2
0.10
4
<
.2
0.10
5
<
.2
0.10
6
<
.2
0.10
7
<
.2
0.10
8
.2
0.20
Sep-00
9
<
.2
0.10
No LItA o& Morh iOPAk7 (Gr?al2&MaQ-
(C,TIL(- qupgTeet-y W "-Mp)
Page 1

NC0025453
Facility: Clayton - Little Creek WRF
Discharge to: Neuse River, WS IV -NSW CA
Stream class and index #:
Residual Chlorine
Ammonia as NH3
(summer)
7010 (CFS)
186
7Q10 (CFS)
186
DESIGN FLOW (MGD)
2.5
DESIGN FLOW (MGD)
2.5
DESIGN FLOW (CFS)
3.875
DESIGN FLOW (CFS)
3.875
STREAM STD (UG/L)
17.0
STREAM STD (MG/L)
1.0
UPS BACKGROUND LEVEL (UG/L)
0
UPS BACKGROUND LEVEL (MG/L)
0.22
IWC (%)
2.04
IWC (%)
2.04
Allowable Conc. (ug/1)
833.00
Allowable Concentration (mg/1)
38.44
minimum = 2
Ammonia as NH3
(winter)
7Q10 (CFS)
186
Fecal Limit
200/100ml
DESIGN FLOW (MGD)
2.5
Ratio of 48.0 :1
DESIGN FLOW (CFS)
3.875
STREAM STD (MG/L)
1.8
UPS BACKGROUND LEVEL (MG/L)
0.22
IWC (%)
2.04
Allowable Concentration (mg/1)
77.64
minimum = 4
L CLAq T o tJ p 5 A M AYOr2
14. -tf LIM(TS of

to language for clayton
lk Subject: to language for clayton
Date: Fri, 07 Mar 2003 14:44:47 -0500
From: Mike Templeton <mike.templeton C ncmail.net>
To: Susan A Wilson <Susan.A.Wilson @ncmail.net>
Susan -
Here's the permit and fact sheet language for the Clayton permit.
Madolyn told me earlier to go ahead with Clayton and just send her the
final copy - no need for another review copy.
I re -arranged some of the permit language from what she and Dee saw
last, but the essence is unchanged. I'll send them a copy with some
explanation to head off any questions she might send back to you.
Let me know if you have any questions about the language.
— Mike T
Name: neuse individ pmt Lang 20030306a.doc
Type: Microsoft Word Document
M-�-_L_�-_ neuse individ pmt lang 20030306a.doc (application/msword)
Encoding: base64
Download Status: Not downloaded with message
1 of 1 3/9/03 8:46 PM

Re: Clayton
4 Subject: Re: Clayton
Date: Wed, 5 Mar 2003 09:19:35 -0500
From: Shankar Mistry <[e-mail]>
To: Susan A Wilson <[e-mail]>
Susan:
I appreciate your assistance in Clayton's NPDES Permit. I understand
your position with
re -rating and'Authorization to Operate. I will review and evaluate the
2.5 mgd re -rating
improvements, completed in July 2002, as well as all the unit
operations/processes incorporated in the plant for handling permitted
flow of 2.5 mgd.
Thanks for making me aware of the situation. Please send out a formal
letter to the Town
requesting additional information requirements for Authorization to
Operate.
Shankar
On Tuesday, March 4, 2003, at 04:50 PM, Susan A Wilson wrote:
> Shankar -
> Well, I've got good news and bad news. Here's the good news: we
> should be able to issue the permit soon and get it out to them (Mike T
> says he has resolved the issues with EPA). I'm hoping to get it
> finalized by the end of the week.
> The bad news is I have problems with the re -rating and Authorization
> to Operate. This is not directed at you Shankar, as I am well aware
> that you guys inherited this project and another consulting firm
> worked on pieces/parts of it before. I'm fine with the calculations
> you submitted with regard to the BOD5/1VH3-N removal (although I do
> have a couple of questions) - but for the most part I'm confident
> we'll work through that piece just fine.
> The Town of Clayton was informed in correspondence dated 7/10/00
> (speculative limits), as well as in correspondence dated 5/24/01
> (Authorization to Construct) that DWQ needed to have all calculations
> associated with the re -rating to 2.5 MGD submitted when the time
> came. Although we did permit construction of many components in the
> ATC issued 5124101, we notified the Town that calculations must still
> be submitted to ensure that limits and hydraulic requirements could be
> met at the 2.5 MGD flow (all of this correspondence was copied to
> their consultant as well). We also notified the Town that they built
> all components at risk - that the components approved, were only
> approved for the flow of 1.9 MGD (since there was not even a draft out
> for 2.5 MGD).
> Bottom line - I need to see calculations to ensure that all components
> can meet the requirements (both hydraulically and for limits
> compliance) for 2.5 MGD in order to issue the Authorization to
> Operate. This means pump capacities, clarifier overflow rates, etc.
> (although some of that appears to be given in the document), tertiary
> filter loading, disinfection detention times/UV requirements, etc.,
> assurances that current residuals capacity is sufficient (and if not -
> what the schedule will be for increasing residuals management), etc.,
> etc.
1 of 2 3/5/03 10:20 AM

Re: Clayton
> Re -ratings are not easy to deal with - but I had hoped through all the
> correspondence that we had with the Town and their former(?) `
> consultants that we could have run through it fairly quickly. In
> addition to the correspondence, this was also discussed in the meeting
> between the Town, DWQ, and their consultants on 4125101.
> Give me a call if you'd like to discuss this (733-5083, ext. 510).
> I'll need to send out a formalized additional information letter.
> Just wanted to give you a heads -up. Thanks.
> Susan
>
2 of 2 3/5/03 10:20 AM

Re: Comment on NCO025453
Subject: Re: Comment on NCO025453
Date: Thu, 20 Feb 2003 09:51:29 -0500
From: Mike Templeton <[e-mail]>
To: [e-mail], Dee Stewart <[e-mail]>
CC: [e-mail], Dave Goodrich <[e-mail]>
Hi, Madolyn and Dee -
Thanks for looking at the TN language in Clayton's permit. All of the permits in the Neuse River basin are
up for renewal in the first part of 2003 and the majority will include the same language. We're running a
little behind already and want to iron out any issues with these conditions quickly and avoid increasing our
backlog.
Let me respond briefly to your comment here, and we can talk about it more when you get back in the
office on Monday. Your suggestion is that the Permittee (Clayton, in this case) is in compliance if it meets
the TN limit in this individual permit *or* (your language in italics):
"the Permittee is a Member of the Neuse River Compliance Association and a Co-Permittee to that
association's group NPDES permit, ... "
I guess I should first ask whether this is a critical change or more of an editorial suggestion. We left out the
reference to the NRCA intentionally for a couple of reasons: We have to add similar language to over 100
Neuse permits. We learned from the 2000 renewals that when we are working with this many permits with
basin -specific conditions, it is *much* easier to minimize errors in permit documents when we standardize
those conditions. About 20 of the Neuse dischargers are NRCA members; there is also the possibility we
will have a second association by the end of this permit cycle. If we have to refer to each association by
name, it means we have three versions of the TN conditions (for the NRCA, for the 2nd association, and
the generic version for the rest). Of course, we can tailor each permit to include the correct references to
each members' Association. But it is more work for the permit writer and for the reviewers and will
hamper our efforts to reduce our backlog.
After we sent you the Clayton permit, we thought of adding a clarifying sentence to the end of this
paragraph, similar to: "The TN monitoring and reporting requirements in this individual permit shall
remain in effect regardless of the Permittee's membership in such an association."
rp
... and the Neuse River Compliance Association complies with the Association's TN allocation. "
The question of which TN limits apply to the dischargers came up several times during the development of
the NRCA permit. Dee has heard this already (probably still has nightmares about it), but I'll summarize
for Madolyn's benefit.
There are three types of TN limit in the Neuse: (1) individual limits in the facilities' individual permits, (2)
an aggregate limit in the Association permit, and (3) the individual allocations/limits for each Association
member, also in the Association permit.
Normally, a discharger is subject to the TN limit in its individual permit. (Only about 30 facilities have
these limits, but they account for over 95% of the point source TN load in the basin.) If a discharger joins
an association member and becomes a co-permittee, it is then governed by the TN limits in the assocation
permit. It is deemed to be in compliance with the TN limit in its individual permit so long as it remains a
member and co-permittee.
1 of 3 2/20/03 11:39 AM

Re: Comment on NC0025453
The association as a group is subject to its aggregate limit as long as its permit is in effect. If the
association is in compliance in a given year, all members are deemed to be in compliance with the
individual allocations/ limits in Appendix A. If the association exceeds its limit, the members then become
subject to those individual allocations/ limits as well. Association members are not subject *under any
circumstance* to TN limits in their individual permits until they leave the association.
Since the new phrase is not consistent with this approach, which is already built into the NRCA permit, we
believe it should be omitted.
"In this case, the Permittee's TN discharge is governed primarily by the Association's permit. "
The only change here is to create a separate sentence from the existing language. No issue.
I expect to be in the office the rest of the week. If either or both of you want to go over this, let me know -
I'd be glad to discuss it with you. Otherwise, I'll try to call you after our Monday staff meeting, around
10:30 - 11:00 a.m.
- Mike T
[e-mail] wrote:
Susan,
As mentioned in my voice mail to you today, I have a comment and
suggested language modification for the Town of Clayton permit. I
issued you a no comment letter dated January 30, 2003.
I was talking with Dee Stewart about the Neuse River Compliance
Association information and language in the permit and we have a
suggestion regarding the language.
Section A. (4)., the paragraph in (a)(2):
Our suggested language is:
the Permittee is a Member of the Neuse River Compliance Association and
a Co-Permittee to that association's group NPDES permit, and the Neuse
River Compliance Association complies with the Association's TN
allocation. In this case, the Permittee's TN discharge is governed
primarily by the Association's permit.
We suggest this language because the compliance is an either/or and
number (1.) in section A.(4). of the permit is the compliance language
for the Permittee and number (2.) therefore should be the compliance
language for the Association.
If you would like to discuss this with me, please call me at
[phone]. I will be out until Monday, February 24th.
2 of 3 2/20/03 11:39 AM

Re: Comment on NCO025453
Thank you,
Madolyn Dominy
Michael E. Templeton, P.E.
North Carolina Division of Water Quality
NPDES Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
919-733-5083 x541 FAX: [phone]
maiIto:[e-mail]
3 of 3 2/20/03 11:39 AM

A ,W
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
�m
REGION 4
ATLANTA FEDERAL CENTER
%+P44
PPROSrE°4\o2
ATLANTA, GEORGIA 0303-8960
January 30, 2003
Ms. Susan A. Wilson
North Carolina Department of Environment
and Natural Resources
Division of Water Quality
NPDES Unit
1617 Mail Service Center
RalPioh, NC 27699-1617
S'_TT_IT: Town of Clayton - Little Creev_ WRF - NPDES No. NCO025453
Dear Ms. Wilson:
FEb - 3 2003
In accordance with the EPA/NCDENR MOA, we have completed review of the permit
referenced above and have no objections to the draft permit conditions. We request that we be
afforded an additional review opportunity only if significant changes are made to the permit prior
to issuance, or if significant comments regarding the draft permit are received. Otherwise, please
send us one copy of the final permit when issued.
If you have any questions, please call me at [phone].
Si ceereelly,,� ,
O
Mado S. Dominy, End" nmental Engineer
Permits, Grants and Technical Assistance Branch
Water Management Division
SugµtlTG�D Ve28kc CottvvNTS fe. TN LcF ,jjUAI&
Irq� 58rrT. MIS Tti EP04 w4foa! 2t5ovU�. TAM &P&W CAIQ4vk5 C-
(5 fA T4G Fl A t, PC/LM rT £ A,+ w +s G:Avq v,>
Intemet Address (URL) • http:/Ywww.epa.gov
Recycled/Recyclable . Printed with Vegetable 00 Based Inks on Recycled Paper (Minimum 30% Postconsumer)

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
Alan W. Klimek, P.E., Director
January 8, 2003
MEMORANDUM
To: Michael L. Douglas
NC DENR / DEH / Regional Engineer
Raleigh Regional Office
From: Susan Wilson
NPDES Unit
Subject: Review of Draft NPDES Permit NCO025453
Clayton — Little Creek WRF
Johnston County
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RE5OURCE5
Please indicate below your agency's position or viewpoint on the draft permit and return this form by February
10, 2003. If you have any questions on the draft permit, please contact me at the telephone number or e-mail
address listed at the bottom of this page.
RESPONSE: (Check one)
Concur with the issuance of this permit provided the facility is operated and maintained properly, the stated
effluent limits are met prior to discharge, and the discharge does not contravene the designated water quality
standards.
❑ Concurs with issuance of the above permit, provided the following conditions are met
❑ Opposes the issuance of the above permit, based on reasons stated below, or attached:
Signed MA " C1 J U1 Date: \ L?
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 919 733-5083, extension 510 (fax) 919 733 \19
VISIT US ON THE INTERNE @ http://h2o.enr.state.nc.usINPDES Susan.A.Wilson® ncmail.net 0

Re: Neuse compliance info.
• Subject: Re: Neuse compliance info.
Date: Fri, 03 Jan 2003 09:07:38 -0500
From: Mike Templeton <[e-mail]>
To: Susan A Wilson <[e-mail]>
CC: Natalie Sierra <[e-mail]>
Here is the 5-year summary of Neuse enforcement actions that Vanessa put
together for us. It doesn't show any action being taken against Clayton.
That doesn't mean they've been in full compliance or that we don't have an
enforcement action in the works.
Let us know if you see violations that should (or could) have been
enforced. We are relying on this spreadsheet to give us an accurate picture
of compliance in the basin. If BIMS or our tracking systems aren't picking
up significant violations, we need to know that. Thanks much.
Oh, and a Happy New Year to ya!
- Mike T
Susan A Wilson wrote:
> Have you guys obtained overall compliance information for facilities in
> the Neuse? I'm working on Clayton and i know they've had some ammonia
> violations - didn't want to bug compliance if you already have the list
> of assessments for each facility. thanks!
1 of 1 1/3/03 9:12 AM

ON
AFFIDAVIT OF PUBLICATION
NORTH CAROLINA.
Wake County. ) Ss.
PUauC NOTICE
STATE OF NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT
CUWAISSIONNPDES UNIT
1617 MAIL SERVICE CENTER
RALEIGK NC 276W-1617
NOTIFICATION OF INTENT TO
ISSUE A NPDES WASTEWATER PERMIT
On the basis of thorough staff review and application of NC
General Statute 143.21. Public law 92-500 and other lawful
standards anal regulations, the North Carolina EnAronmen-
fol Management Commission proposes to issue a National
Pollutant Discharge Elimination System (NPDESI wastewa-
ter discharge permit tothe person (s) listed below effective d5
days from the publish date of this notice.
Written comments responding the proposed Permit will be
accepted until 30 days after the publish date of this notice. All
comments received Prior to that date are considered in the
final determinations regarding the proposed Permit The
Director W the NC Division of Water Quality moo decide Ia
hold a Public meeting for the Proposed permit should the
Division receive a significant degree of Public interest.
Copies of the draft Permit and other supporting Information
an file used to determine conditions Present in the draft
Permit are available upon rectuest and pavmentof the costs of
reproduction. Mall comments andlor requests for infarma-
flan to the NC Division of Water Quality at the above address
or call Ms. Valero Stephens at (919) 733i003, extension 520.
Plena include the NPDES Permit number (attached) In any
communication. Interested persons may also visit the Divl-
sion of Water Quality at 612 N. Solisbury Street, Raleigh, NC
276 114 between the hours of 6:00 a.m. and 5:00 P.m to
review information an file.
Before the undersigned, a Notary Public of Johnston
County North Carolina, duly commissioned and authorized to
administer oaths, affuTnations, etc., personally appeared Ivy
Marsch, who, being duly sworn or affirmed, according to law,
doth depose and say that she is Billing Manager -Legal
Advertising of The Smithfield Herald a corporation organized
and doing business under the Laws of the State of North
Carolina, and publishing a newspaper known as The
Smithfield Herald, in the City of Smithfield, Johnston County
and State aforesaid, the said newspaper in which such notice,
paper, document, or legal advertisement was published was, at
the time of each and every such publication, a newspaper
meeting all of the requirements and qualifications of Section I-
597 of the General Statutes of North Carolina and was a
qualified newspaper within the meaning of Section 1-597 of
the General Statutes of North Carolina, and that as such she
makes this affidavit; that she is familiar with the books, files
and business of said corporation and by reference to the files
of said publication the attached advertisement for NC
DIVISION .OF WATER QUALITY ' was inserted in the
aforesaid newspaper on dates as follows: 01/17/03
Account Number: 73350831
The above is correctly copied from the books and files of the aforesaid Corporation and publication. .
SEAL
Billing Manager -Legal Advertising
Sworn or affirmed to, and subscribed before me, this
20 day of JANUARY , 2003 AD
In Testimony Whereof, I have hereunto set my hand
and affixed my official seal, the day and year aforesaid.
Notary Public
My contfnission expires 2nd day of July 2005.

0001/001
01/15/2003 IVEU 15:08 FAX
Story ,#23156 System RALSZ by JDTICE Time 14:11:54 Date 1/15/03
<<ROUTS- 9MCANONaa
Siart: 1/17/03 Class: 0 Name: NC DIVISION OF WPUBLIC NOTICE - LITTLE CR
SI2e: 94 Imes 2 x 3.42 inches
Changed 1/15/03 at 14:11:64 by JDTICE. Coplod from #98545 on 1/00/03 at 14:50 by JPTEDDER.
PUBLIC NOTICE
STATE OF NORTH CAfiCILINA
ENVIRONMENTAL A KMENT
C7 MA L 60N/NPDES VNITE
1pP MIWIG !N1,, R IGE CENT R
NWIIPImTi& OFVNTE6NY 10
ISSUE A NPDES WASTEWATER PERMIT
QUn 7rre MId51a N tt"orauoO RufF r¢vlew and aoalicalion aF NC
BnMO lalvle 1131. Pvhllc law 41dW pnd mM1pr IowNl
stanapra! unit regu of Ms, the North CorNlna EnvlmMleT
ml /dnmaampnt CPmmluraIi Promfw to iuua e M lbml
Pollutant Olscnalee Elbnteolian 5)))i) l m (NPOE57 rwteWa-
terdlaahanthy mflto Iopia ,mis)Ilsledbelow oRatltveR
days ham Ib rabllnN date of little nPtlw.
Written vwnrnm moraine Ine proposed corneal will ba
twdal, of'n¢ notc. Al
mm1.MaPrartvthat date wewsdered Inthe
tletdmnalten5,
re9ordmA ene p�pnfed oermil The
Olre oralthe NC DIVI,IonmW IerG Illy muya it The
hold a public meetir, far Ind proposed psmit MiallO Inc
CIA", an racelve a slanlrlcanl decree of r4bllc Interest.
Copies of he draft Permil and ether suoPartlru Wampum
on Rk used Ia de ermino wndltlon5 areas" In the droll
rmMareaml6ala vam roavwtanpwrma Il al @ecoele of
rearto lie NC Kill qn FWae, and II mmxels for Nacere .
Ilan la the NC "Ste hWater lit Illyy� tlh, even r�onsn.
l [all Inl Valere, NPOE loer NIN /dl-0ao], BaIM9an am.
Please Indugoiha NPD1,7edd mil numberdd((w visifd)Ivan
lion of V%Citrgimlli lryr!61a iAliou"51ivi, ReIBNfni�hINC
17"1T peWettn lip npurs of also ane am15:00 p.m la
ry 1.- Mrermo:wn on Ill..
fNN PPcfDESSplPermtl Numher NCO0I593, Jill, Creek Water
V1, 7r$Zl'tlaf aDnI0IOra perrith renewal onde.ohns on for.
'null eyyei<aimLL,onI VaM'- WIN. Crack In I1�Novse wvoedr
901,111. Carrenrlr SODS, umman), r,Tdll chlorine. nilno-
ran, unit Pau Dtorw are Weiler aualily liatild. Thiy dls
:IW ma alr2t f."" alma tj N In tali ao"a al 1t9
•ecenv 5{ream.
lanum n

Date: Alos
100**1 Time: (O dD A-M
❑ Return Mr./ Mrs.
❑ Call to Address
❑ Call from _
Telephone:
Subject:
TELEPHONE RECORD
Project: C(_AV rorJ
Representing:
FAX:
NOTES/ SUMMARY
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DEC - 4 2002
December 3, 2002
WootenMs. Susan Wilson, Environmental Engineer
Cornan Permits and Engineering Section
p Y N.C. Division of Water Quality
1617 Mail Service Center
Engineering Raleigh, NC 27699-1617
Planning Re: Clayton LCWRF Improvements/Permit Modification
Architecture NPDES Permit NC 0025453
Clayton, North Carolina
Johnston County
Dear Ms. Wilson:
As per our telephone conversation this morning, I have attached copies of the
August 7, 2002 letter from the Town of Clayton requesting interim effluent
limitations during the construction of the LCWRF Nitrogen Removal Improvements
120 N. Boylan Avenue
and the November 5, 2002 response from Mr. Kenneth Schuster to the Town's
Raleigh, NO
request.
27603
We understand and respect Mr. Schuster's position on the subject matter. However,
the Town is concerned about possible violations on the NPDES Permit limits on
BOD5, NH3-N and Total Nitrogen during the construction of the Nitrogen Removal
Improvements when the two oxidation ditches, one at a time, will be taken out of
919-828-0531
service to make necessary improvements.
Fax:[phone]
The Town is also concerned about the situation that though the LCWRF
Improvements for rerating the plant capacity from 1.9 mgd to 2.5 mgd were
completed on August 15, 2002, the Town will not be able to provide additional sewer
service to new and existing sewer customers in the very near future unless the
NCDWQ issues a modified NPDES Permit for 2.5 mgd flow or the Town entered
into SOC. Accordingly, in order to seek some guidance and help from your office to
address the Town's concerns, it is requested that a meeting be arranged between the
Town and Mr. Dave Goodrich, you and other interested staff of the DWQ. Please
let us know at your earliest convenience the date, time and place of the meeting.
We sincerely appreciate your assistance in this matter. Should you have any
questions or need more information concerning this matter, please call me at (919)
828-0531.
Sincerely,
THE WOOTEN COMPANY
Since 1936
Shankar R. Mistry, Ph.D., P.E.
Enclosure
c: Mr. Steven R. Biggs, Town Manager
Mr. Kenneth Schuster, P.E., Regional Water Quality Supervisor
Mr. Daniel M. Blaisdell, Construction Grants and Loan Section
Mr. Tim Simpson, Director of Public Works
Mr. James Warren, LCWRF Superintendent

Town Of Cla)Ttor
DOUGLAS A. McCORMAC
STEVE BIGGS
Ma),or
....YP ..
Town Manager
BOB SATTERFIELD
BRUCE THOMPSON
Mayor Pi Tent{
Town Attorney
COUNCIL MEMBERS
p tt`
KERI REED
James H. Lipscomb
-'p, ti;'
Town Clerk
Robert J. Ahlert
' ... P„......
Butch Lawter
Kathleen k Bo in
y fi4imnie4err�r� >4
August 7, 2002
Mr. Ted Cashion
Raleigh Regional Office
N.C. Division of Water Quality
3800 Barrett Drive
Raleigh, North Carolina 27601
Subject: Interim Effluent Limitations During Construction
of the LCWRF Nitrogen Removal Improvements
Clayton, North Carolina
Dear Mr. Cashion:
Reference is made to our April 11, 2002 meeting at The Wooten Company's office concerning
obtaining interim effluent limitations during the construction of the LCWRF Nitrogen Removal
Improvements that are being designed at the present time. Based upon our discussions during the
meeting, we are providing the following information in support of our request for obtaining the
interim effluent limitations.
Project Background: The project background is summarized as follows:
1. The Town of Clayton operates a 1.9 mgd tertiary type wastewater treatment plant known
as LCWRF that discharges its effluent into the Neuse River in accordance with the
NPDES Permit No. 0025453.
2. In order to support the recent ongoing residential, commercial, and industrial growth in
the Clayton area, the construction for rerating of the plant capacity from 1.9 mgd to 2.5
mgd is ongoing and expected to be completed by August 15, 2002. The plant rerating
improvements under construction are designed to comply with all the speculative effluent
parameters limits, issued by the State, with the exception of the Total Nitrogen limit as
required by the NSWMS Rule .0214 and the NPDES Permit.
P.O. Box 879 • Clayton, North Carolina 27520 • [phone] • Fax [phone]

3. In order to comply with the Total Nitrogen removal requirements, the Town has
committed to join the Lower Neuse Basin Association (LNBA) for group compliance on
the nutrient removal requirements. The Town has also submitted the Amendment to the
Clayton 201 Facilities Plan for financing the nutrient removal and sludge handling
improvements by obtaining SRF.
4. The plans and specifications for the nutrient removal project with expanded sludge
handling facilities are being prepared by The Wooten Company. The plans and
specifications will be submitted to the State Construction Grants and Loan Section by
August 15, 2002 for review and permitting.
5. The project construction will begin within three months after receiving the Authorization
to Construct Permit from the State.
Need For Interim Effluent Limitations: The nutrient removal improvements design includes
modifications of the existing oxidation ditches for incorporation of first stage anoxic tanks,
denite recirculation channels and gates to achieve denitrification as a part of the Total Nitrogen
removal scheme. The modifications will allow simplified, flexible, reliable and economical
operation of the first stage anoxic tanks as an integral part of the biological nitrogen removal at
the plant. The subject modifications will require the existing oxidation ditches to be taken out of
service consecutively, during the construction. It should be noted that most of the work for
incorporation of first stage anoxic tanks can be done while the oxidation ditches are in service.
The time for one oxidation ditch to remain out of service for needed improvements is estimated
to be in the range of 1.5 to 2 months. The total time for two ditches to remain out of service,
consecutively, is estimated to be in the range of 3 to 4 months.
During construction, when the oxidation ditches are taken out of service one at a time, it is
anticipated that the plant may not be able to comply with the effluent limitations, more
particularly on BODS, NH3-N and Total Nitrogen. The attached March 2002 effluent monitoring
report represents effluent quality data when the oxidation ditches were taken out of service, one
at a time, during the ongoing construction of the plant rerating project. Effluent data from March
1 through March 20 represents the 1.15 MG capacity ditch was on line and the 0.75 MG capacity
ditch was taken out of service for aeration improvements. Effluent data from March 21 through
March 31 represents the 0.75 MG ditch was in service and the 1.15 MG ditch was taken out of
service for aeration improvements. The minimum, maximum and average values of the effluent

BOD5, NH3-N, and Total Nitrogen during the respective ditch operation, are summarized as
follows:
BOD5, mg/L
NH3-N, mg/L
Total Nitrogen, mg/L
Min.
Max.
Avg.
Min.
Max.
Avg.
Min.
Max.
Avg.
1.15 MG Oxidation Ditch in Service (3/1/02 - 3/20/02)
5.0 8.0 6.86 2.2 4.6 3.43 - - 5.1
0.75 MG Oxidation Ditch in Service (3/21/02 - 3/31/02)
4.0 8.0 6.34 4.1 10.1 6.22 1.6 5.16 3.38
The anticipated average effluent BODS, NH3-N and Total Nitrogen values during the
construction of the Nitrogen removal improvements project, with the respective ditches in
service, are listed as follows:
Ditch in Service
BOD5, mg/L
NH3-N, mg/L
Total Nitrogen, mg/L
1.15 MG oxidation ditch
0.75 MG oxidation ditch
10
12
4.5
7.5
7.5
10.5
The effluent limitations in the permit were established by the State using the 7-day, 10-year low
flow of the receiving stream. It is anticipated that during the period when the modifications take
place, the flow in the receiving stream should be significantly higher than the 7-day, 10-year low
flow and the Town's effluent discharge, with the above mentioned BOD5, NH3-N, and Total
Nitrogen concentrations, should not have adverse impacts on the receiving stream water quality.
Accordingly, in order for us to construct the necessary improvements for compliance with the
Total Nitrogen discharge limit, it is sincerely requested that the following interim effluent limits
be granted for a period of six months which include construction time for modifications to the
existing ditches and operational time for compliance with the effluent- limits of the Permit.
Effluent Parameter Effluent Limits
Monthly Average
BOD5, mg/L 12
NH3-N, mg/L 7.5
Total Nitrogen 10.5

.1
0
In order to achieve better effluent quality and minimize any short-term adverse impacts, the
Town is committed to do the following:
1. Include in the contract documents, incentives and damages for completion time for
construction of the oxidation ditches modifications related to the Total Nitrogen removal
work.
2. Work with the Division of Water Quality to schedule the project construction activities
for minimizing adverse impacts on the receiving stream water quality.
3. Operate the existing treatment system for its optimum performance in terms of BOD5,
NH3-N, and Total Nitrogen Removal.
4. Request Johnston County's official's cooperation for discharging the industrial portion of
Clayton's wastewater flow to the Johnston County WWTP to maximum extent during the
oxidation ditch modifications.
5. Continue ongoing sewer system evaluation and rehabilitation program to reduce the
infiltration/inflow in the sewer system.
6. The Town's reuse project is expected to be bid in Fall of this year and will try to expedite
the construction so that a portion of the effluent flow can be diverted to the reuse facility
(Golf course) for reducing the discharge into the receiving stream.
Considering the Town's commitments of compliance with the Total Nitrogen removal
requirements we will sincerely appreciate yourconsideration of our request for issuing interim
effluent limitations on BOD5, NH3-N and Total Nitrogen during the construction modifications
of the oxidation ditches. Should you have any questions or need more information concerning
this matter, please call me at 553-5002 or Shankar Mistry at 828-0531.
Sincerely,
R. Steven eggs
Town Manager
OD
c: Mr. Daniel M. Blaisdell, Con tio;y Grants. and 1 =n Section
Mr. Tim Simpson 6
O
r. James Warren
Mr. Shankar Mistry `/;`�Op� C '�
0 ���

04/10/2002 08:57 9195531918 TOWNOFCLAYTO:N PAGE 02
NPOES PERMIT NO. NCO026453
FACILITY NAME We Creek Water R
OPERATOR IN RESPONSIBLE CHARGE (ORC)
CERTIFIED LABORATORIES (1) TrMst
�� �x � c�c wa clwurivo
MaD ORIGINAL and ONE COPY to:
ATTN: CENTRAL FILES
DivI= at Whist OUR21y
1617 Mau Swvim Censer
Re[etgn, NC 2769-1817
EFFLUENT
DISCHARGE NO, MONTH YEAR 2002
jwmTY � —
CLASS ly couN'
warren ,
GRADE �,�[ PHONE [phone]
(2) Pace Ma lcal
PERSON(S) COLLECTING SAMPLES : Lfth Honeycutt Jimmy Creech
Bral Taylor
(SIGNAWRE OF OPERATOR IN RESPONSIBLE CHAROW
By THIS SIGNITI.[M I CERTIFY THAT THE REPORT 13
DATE

State of North Carolina
Department of Environment
and Natural Resources
Raleigh Regional Office
Michael P. Easley, Governor
William G. (Bill) Rose, secretary
Alan W. Klimek, P.E., Director
Division of Water Quality
November 5, 2002
Mr. Steve Biggs, Town Manager
Town of Clayton
P.O. Box 879
Clayton, NC 27520
Subject; Interim Effluent Limitations
Ro , ca µp N
EN p
� :rMENTOFarumce s
Clayton Little Creek Water Relamation Facility
NPDES Permit No. NCO025453
Johnston County
Dear Mr. Biggs. -
We have reviewed your letter dated August 7, 2002 to Ted Cashion of my staff regarding
interim effluent limits during the period of improvement to modify the 2 existing oxidation
ditches for biological nutrient removal.
Historically, the Division has not allowed interim effluent limits while a facility upgraded
or improved it's system, unless the facility was operating under a Special Order by Consent
(SOC). An SOC is not warranted in Clayton's case because the facility has been in substantial
compliance with the current permit
If any enforcement action is taken against the Town during the period of improvement,
the Town will have the option of requesting remission of the penalty by the Director of the
Division and/or the Environmental Management Commission, or requesting an administrative
hearing.
This office appreciates the achievements of the Town, and particularly the treatment plant
staff, over the years of protecting the environment of our State.
clayton.let
1628 Mall Service Center, Raleigh, NC 27699.1626
An Equal Opportunity AH9rmative Action Employer
Sincerely, t t
Kenneth Schuster, P.E.
Regional Water Quality Supervisor
Telephone [phone] RAA [phone]
80% raeyclod/10% posteoncarnerPapar
HN 8\1900,N £h:80 (PIAN U-UNI
Z00/i00'd 81CP 1L3 616:111

Clayton permit renewal
Subject: Clayton permit renewal
Date: Wed, 23 Oct 2002 15:09:56 -0400
From: Susan A Wilson <[e-mail]>
Organization: NC DENR DWQ
To: [e-mail]
CC: Dave Goodrich <Dave.Goodrich @ ncmail.net>,
Mike Templeton <[e-mail]>
Shankar,
I think there was a mix-up in our mail -out and I am unsure if Clayton
received their acknowledgement for the renewal of the permit.
Regardless, we did receive it and will get another letter out. I wanted
to put some statements in the acknowledgement letter about the status on
the Neuse Compliance Association. I believe this package includes the
request for expansion (which I believe we will be accepting - but we may
not be able to act on it until the Association is finalized, which
should be fairly soon). Please let your clients know. You may want to
speak with Mike Templeton regarding the status of the Compliance
Association.
Thanks. I have not had an opportunity yet to dig into the renewal.
Susan
I of 1 10/23/02 3: 10 PM

SOC Priority Project Yes No XXX
Permits and Engineering Unit
Water Quality Section
Attn: Susan Wilson
OCT 2 9 2002
Date —October 18, 2002
�` "` ` l L'E 6s„• H D S STAFF REPORT AND RECOMMENDATION
County Johnston
Permit No. NCO025453 RENEWAL
PART I - GENERAL INFORMATION
1. Facility and Address: Town of Clayton - Little Creek Water
Reclamation Facility
P.O. Box 879
Clayton, NC 27520
2. Date of Site Visit: September 9, 2002
3. Report Prepared by: Ted Cashion, Environmental Chemist
4. Persons Contacted and Telephone Number:
James Warren, Superintendent 919-553-1536
5. Directions to Site: From Raleigh: Hwy 70 east to Clayton,
cross hwy 42, turn rt into cemetery, WWTP is in back of cemetery.
6. Discharge Point(s), List for all discharge points:
*************see mar) for outfall location**********
Latitude: 35 39 5411 Longitude:78 25 53"
Attach a USGS map extract and indicate treatment facility
site and discharge point on map.
U.S.G.S. Quad No. E25NW U.S.G.S. Quad Name Clayton, NC
7. Site size and expansion area consistent with application ?
XXXX Yes No If No, explain:

8. Topography (relationship to flood plain included): Plant
appears to be located out of floodplain.
9. Location of nearest dwelling: at least 1/4 mile
10. Receiving stream or affected surface waters: Neuse River
a. Classification: WS-IV, NSW
b. River Basin and Subbasin No.: 03 04 02
C. Describe receiving stream features and pertinent
downstream uses: Johnston Co. and Smithfield water
supply
PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS
1. a. Volume of Wastewater to be permitted: 2.5 MGD(Ultimate
Design Capacity) ba6e.4 O>`-' jre4^2a : n-
b. What is the current permitted capacity of the Waste
Water Treatment facility? 1.9 mgd
C. Actual treatment capacity of the current facility
(current design capacity) 2.5 mad
d. Date(s) and construction activities allowed by. previous
Authorizations to Construct issued in the previous two
years:
A to C dated May 2001
Replace 3 centrifugal pumps with submersible pumps. Increase HP
of aerators in oxidation ditches, splitter box improvements, 65
ft. Diameter x 14 ft. SWD clarifier.
e. Please provide a description of existing or
substantially constructed wastewater treatment
facilities:
The treatment units for the 1.9 mgd WWTP consist of the following: automatic bar screen with
auger, pista grit, influent ultrasonic flow meter with 12" parshall flume, influent pump station
with 3-60 hp pumps (2 vfd, 1 backup), and a fourth 40 hp pump which is operated in the manual
mode, a percentage of flow is pumped to a clarigester, dual oxidation ditches, three clarifiers,
dual tertiary filters, dual UV disinfection units, chlorine and dechlorination backup as needed,
effluent ultrasonic flow meter with 3 foot rectangular weir with end contractions, drum sludge

thickener, 100,000 gallon sludge holding basin (full), 400,000 gallon aerobic sludge digester
(near full), drying beds (not currently used), and alum, hydroxide, and polymer addition as
needed.
f. Please provide a description of proposed wastewater
treatment facilities: Future plans are to add an anoxic zone for each
basin, deep bed methanol filters, a grit classifier, an additional drum thickener,
and an additional 400,000 gallon sludge holding tank.
g. Possible toxic impacts to surface waters: ammonia,
pharmaceutical
h. Pretreatment Program (POTWs only):
in development
approved XXXX
should be required
not needed
2. Residuals handling and utilization/disposal scheme:
a. If residuals are being land applied, please specify DWQ
permit no. W00000506 - East Coast Resources
,,.,fa 8 01 - Granville Farms
WQ0006816 - McGill Environmental
b. Residuals stabilization: PSRP XXXX
PFRP XXXX (McGill) Other
c . Landf ill:
d. Other disposal/utilization scheme (Specify):
3. Treatment plant classification (attach completed rating
sheet) : Class 4
4. SIC Code (s) : 4952
Wastewater Codes) of actual wastewater, not particular
facilities i.e.., non -contact cooling water discharge from a
metal plating company would be 14, not 56.
Primary 01 Secondary --

r
Main Treatment Unit Code: 107-3
PART III - OTHER PERTINENT INFORMATION
1. Is this facility being constructed with Construction Grant
Funds or are any public monies involved. (municipals only)? NA
2. Special monitoring or limitations (including toxicity)
requests: none
3. Important SOC, JOC or Compliance Schedule dates: (Please
indicate) NA
4. Alternative Analysis Evaluation: Has the facility evaluated
all of the non -discharge options available. Please provide
regional perspective for each option evaluated.
Spray Irrigation: Evaluation was performed and concluded
this was not feasible. We're unsure of all the specifics of this
evaluation.
Connection to Regional Sewer System: Connection to the
Raleigh WWTP is 9 miles of force main. The report states that
discussions with the City of Raleigh have proven unsuccessful.
We're unsure of all the specifics of this evaluation.
The Town can send some flow to Central Johnston WWTP as well.
Subsurface: NA
Other disposal options: NA
5. Other Special Items: See evaluations and recommendations.
PART IV - EVALUATION AND RECOMMENDATIONS
We have performed a CEI at this facility. The facility is well
operated and maintained. Modifications to the oxidation ditches
will be made soon to allow BNR. Minor compliance problems with
NH3 have occurred. No other problems noted.
The alternative analyses was not reviewed in great detail. Given
the expansion of the Central Johnston WWTP, proximity to Raleigh

WWTP, and the rural nature of Johnston County, there may be some
options for the Town.
The permit can be renewed unless a more thorough review of the
alternative analyses is required by this office.
Signature of report preparer
Water Quali Reg nal Supervisor
Dat
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ECEIVE
D
r 5EP 3 4 �
The September 30, 2002 ,
Wooten Mr. J. William Reid Supervisor WATER QUALITY
CompanyPoint Source Branch pOINT SOURCE BRANCH
N.C. Division of Water Q Yualit /NPDES Unit
1617 Mail Service Center
Engineering Raleigh, North Carolina 27699-1617
Planning Re: Permit Renewal/Modification Request
Architecture Clayton - Little Creek WRF
NPDES Permit No. NC 0025453
Wake County
Return # 2159
Dear Mr. Reid:
Reference is made to your June 10, 2002 letter concerning the Division's
determination of incomplete permit application due to a lack of certain items and
120 N. Boylan Avenue return of the application to the Town of Clayton. As suggested in the letter, we are
Raieioh. NC reapplying this permit application for renewal and expansion of the plant capacity to
21603 2.5 mgd by submitting the following items:
1. A check in the amount of $860.00 for the permit modification fee.
2. Three (3) copies of September 30, 2002 letter to Mr. Reid addressing items
listed in Mr. Reid's June 10, 2002 letter to complete the application.
919-828-0531
Fax. [phone]. Three (3) copies of the returned NPDES Permit Application for a Capacity
Expansion from 1.9 MGD to 2.5 MGD.
4. Three (3) copies of the Sludge Management Plan required for Permit
renewal/modification application.
5. Toxicity test for an organism other than Ceriodephnia is underway and the
test results will be submitted upon receiving from the laboratory
conducting the test.
We appreciate your assistance provided in this matter. Should you have any questions
or need additional information concerning this matter, please call me at (919) 828-
0531.
Sincerely,
THE WOOTEN COMPANY
a.V1Lftr R. Mi54-j
Shankar R. Mistry, Ph.D., P.E.
c: Ms. Susan A. Wilson, Point Source Branch, DWQ
Since 1936 Mr. Steve Biggs, Manager, Town of Clayton
Mr. Tim Simpson, Director of Public Works
Mr. James Warren, Superintendent of LCWRF

The September 30 2002
Wooten Mr. J. William Reid Supervisor
Company� p Point Source Branch
N.C. Division of Water Quality/NPDES Unit
1617 Mail Service Center
Engineering Raleigh, North Carolina 27699-1617
Planning Re: Permit Modification Request
Architecture Clayton - Little Creek WRF
NPDES Permit No. NC 0025453
Wake County
Return # 2159
Dear Mr. Reid:
Reference is made to your June 10, 2002 letter concerning the Division's
determination of incomplete permit application due to a lack of certain items and
return of the application to the Town of Clayton. The items required to complete the
120 N. Boylan Avenue
Raleigh, NC application package are addressed as follows:
27603
1. Incomplete fee. A stated correctly in your application document (Part 5.6
of the Analysis of Alternatives), nutrient off -set costs must be paid at the
time of application [ref. Temporary Rule, adopted February 2000, 2B
.0234 (8) (c)]. Because the Neuse Compliance Association has not yet
919-828-0531 been formed, the Division cannot accept the Town's application without
Fax [phone] the off -set cost of approximately $3.5 million. The Division will accept the
application again with the appropriate fee and off -set cost or with
confirmation of the formation of the Compliance Association along with
the Town's commitment to join, or with confirmation that the Town has
purchased additional nitrogen allocation from another point source within
the lower basin.
The- Town of Clayton has selected the option of joining the LNBA
Compliance Association. The Compliance Association has been formed.
See the attached letter from the LNBA Association. The Town of Clayton
is committed to join the Association and a copy of the Town's Resolution
to Join the Neuse River Compliance Association is attached herewith.
2. Alternative Analyses. As required by the Division's Antidegradation Policy,
alternatives to discharge must be thoroughly documented. A brief review of
the alternatives indicate that, although several alternatives are
documented, the Town will also need to document the feasibility of land
application of the expanded flow (0.6 MGD), as well as the entire ,flow (it
appears that land application of the entire flow has been documented). In
addition, documentation of the cost and feasibility of the expanded flow
Since 1936 (or any greater amount of flow) transferred to Central Johnston County
should be provided with the alternatives analysis (some of the projected
costs listed in Exhibit 4 should be clarified). Central Johnston County is
well underway to an expansion and may be able to accommodate the
Town's expanded flow; this may allow the Town a temporary solution until
planning for the 20-year projected flow is completed.

The alternatives to discharge considering land application of the expanded flow of 0.6
MGD as well as for the entire flow of 2.5 MGD were evaluated and determined to be
infeasible in terms of cost-effectiveness. Refer to the attached evaluation of the
alternative, including detailed cost breakdown.
With cooperation of Johnston County's official, the Town of Clayton has recently
purchased 75,000 gpd capacity in the Johnston County Wastewater Treatment Plant
and the Town has reserved the right to purchase an additional 175,000 gpd at a future
date after expansion of the Johnston County Wastewater Treatment Plant is completed.
It should be noted that the planned Johnston County Regional WWTP expansion
includes a maximum of 250,000 gpd for the Town of Clayton. The above 75,000 gpd
and 175,000 gpd purchases are part of the 250,000 gpd that is planned in the Johnson
County Regional WWTP expansion.
3. Permit Application. Please clarify Part B.S. of the permit application to state that
certain improvements were approved with the Authorization to Construct permit issued
May 24, 2001, but that approval did not evaluate the plant to comply with a flow of
2.5 MGD. The Town of Clayton will still be required to provide calculations to ensure
that the expansion will comply with the limits given for the expansion to 2.5 MGD.
Also, parts of the document refer to future limits of 5 mg/1 BOD5 and 2 mg/1 NH3-N -
this is incorrect. All references to limits upon expansion should indicate 5 mg/1 BODs
and I mg1L NH3-N (summer); 10 mg1L BODE and 2 mg/ I NHj-N (winter).
The improvements approved with the Authorization to Construct Permit, issued May
24, 2001 were intended to comply with design flow of 2.5 mgd. It is noticed that the
parts of the document refer to a future limit of 5 mg/L BOD5 and 2.0 mg/L NH3-N
which is incorrect. All references to limits upon expansion have been revised to
indicate 5 mg/L BOD5 and 1 mg/L NH3-N for summer months and 10 mg/L BOD5 and
2 mg/L NH3-N for winter months. It should be noted that some of the BOD5 and NH3-
N limits referred to in the document were for the wastewater treatment and disposal
alternatives considered in 1993 Amended 201 Facilities Plan. The calculations to
assure that the expansion will comply with the limits (5 mg/L BOD5 and 1 mg/L NH3-
N) given for expansion to 2.5 mgd are attached herewith.
We appreciate your assistance provided in this matter. Should you have any questions or need
additional information concerning this matter, please call me at [phone].
Sincerely,
THE WOOTEN COMPANY
4=0•"W%rL&W R. MI'Sij
Shankar R. Mistry, Ph.D., P.E.
c: Ms. Susan A. Wilson, Point Source Branch, DWQ
Mr. Steve Biggs, Manager, Town of Clayton

Lower Neuse Basin Association, Inc.
Raleigh, North Carolina
September 27, 2002
J. William Reid, Supervisor
Point Source Branch
Division of Water Quality
NC Dept. of Environment and Natural Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: Town of Clayton — Membership in the Neuse River Compliance Association
Dear Mr. Reid:
This letter is being sent at the request at the Town of Clayton in response to your
letter of June 10, 2002 concerning their application for a modification of NPDES Permit
No. NC0025453. Articles of Incorporation forming the Neuse River Compliance
Association (the "Association') have been filed, establishing the Association as a
nonprofit corporation. Furthermore, the Town of Clayton has submitted the required
resolution of intent to join the Association in a form acceptable to the Association. The
final Association membership roster and operational parameters will be completed upon
approval of the operational agreement by the Division of Water Quality and
Environmental Management Commission.
If you have any questions regarding this matter, don't hesitate to contact me at
[phone].
Sincerely,
iL?JC/�
Timothy L. Donnelly, PE
Chairman
Lower Neuse Basin Association
And Neuse River Compliance Association
Cc: Town of Clayton
The Wooten Co.
R O. Box 590 Raleigh, North Carolina 27602
[phone]

WIS/1002 14:27 9195531918 TOWNOFCLAYTO:N PAGE 02
Town of Clayton
Resolution to Join the Neuse River
Compliance Association
WHEREAS, the Lower Neuse Basin Association (LNBA formerly the Neuse Basin
Association was created in ) 994 to establish a formal, voluntw.y`agieement between itself and
the North Carolina Division of Water Quality (DWQ), by which the LNBA is responsible for
surface water monitoring, reporting, and other cooperative efforts by NPDES dischargers within
the Lower Neuse River Basin to obtain water quality information in the basin.
'AND WHEREAS, in addition to such ongoing cooperative surface water monitoring
activity and other joint efforts, the LNBA and DWQ jointly support other additional strategies to
ensure overall Total Nitrogen reduction at the mouth of the Neuse River in the Pamlico Sound as
required by the wastewater discharge requirements of the Neuse River Basin Nutrient Sensitive
Waters Management Strategy.
AND WHEREAS, the formation of another body, the Neuse River Compliance
Association (Association) is necessary to obtain a group NPDES permit for Total Nitrogen, as an
alternative framework in which interested point source dischargers in the lower Neuse River
Basin can work cooperatively to reduce their individual and collective discharge of that nutrient
pollutant and comply with applicable limits.
THEREFORE, the Town of Clayton agrees with the overall intent of the cooperative
arrangements set out in the By -Laws of the Neuse River Compliance Association and, at this
time, intends to join the Association and top ' ipate according to said Bylaws.
t° 9Vr
DouglasORcConnac
Attest:
_IX (x `
keliReed
Town Clerk
RALE1oM/01S017.0011337231 v.1
Mayor

• EVALUATION OF EXPANDED 2.5 MGD PLANT
FOR
COMPLIANCE WITH THE EFFLUENT LIMIT OF 5.0 mg/L BODs
AND 1.0 mg/L NH3-N
1.0 EVALUATION OF THE OXIDATION DITCH SYSTEM FOR BODs REMOVAL
AND NITRIFICATION
1. Design Considerations
Average daily flow = 2.5 mgd (Influent flow to 0.75 MG ditch = 0.987 mgd and
Influent flow to 1.15 MG ditch =1.513 mgd)
BODs: Influent = 230 mg/L; Effluent =
5.0 mg/L
TSS: Influent = 230 mg/L; Effluent =
10.0 mg/L
TKN: Influent = 35 mg/L; Effluent =
3.0 mg/L
NH3-N: Influent = 25 mg/L; Effluent =
1.0 mg/L
NO3-N: Influent = 0 mg/L; Effluent =
2.0 mg/L
Temperature: Winter = 12° C; Summer =
28° C
Operating MLSS Concentration =
4,000 mg/L
Sludge retention time =
16 days
Net Sludge Yield, Yn, lb solids/lb BODs removed =
0.78 _
Oxygen Requirements, lb 0211b BOD removed =
1.5 — D(�
lb 02/lb NH3-N removed =
4.6 o
2. Required Oxidation Ditch Volume
The required oxidation ditch volume is determined using the following equation:
BODR xYnxSRT
Volume, mil. gal. = MLSS x 8.34
C, '
Where BODR = (230 - 5) mg/L BODs x 8.34 x 2.5 mgd
= 4691 lb B OD/day
Yn = Net sludge yield = 0.78 lb solids/lb BODR
SRT = Sludge retention time required for complete nitrification = 16
days
MLSS = Operating mixed liquor suspended solids concentration
4,000 mg/L
-1 -

Volume, mil. gal. _
4691 x 0.78 x 16
4000 x 8.34
= 1.755 mil. gallon
The available volume in the existing carrousel oxidation ditches = 0.75 MG + 1.15 MG =
1.90 MG which is more than adequate for the required ditch volume of 1.755 MG.
3 Aeration Requirement for 0.75 MG Carrousel Ditch
a. Oxygen Requirements for BODs Removal
Considering influent flow to 0.75 MG ditch = 0.987 mgd, influent BOD5 = 230 mg/L,
effluent BOD5 = 5.0 mg/L and oxygen requirement for BOD5 = 1.5 lb OZ/lb BOD5
r
removed, the total oxygen requirement for BOD5 removal is: �( I' �� D
I D T.?J
_ (230-5) mg/L BOD5 x 8.34 x 0.987 mgd x 1.5 = 2778 lb 02/day r yP�'
b. Oxygen Requirement for Nitrification (NH3-N Removal)
Considering influent flow to 0.75 MG ditch = 0.987 mgd, 5 mg/L nitrogen
requirement for each 100 mg/L BOD5 for cell synthesis, influent TKN = 35 mg/L,
effluent NH3-N = 1.0 mg/L and oxygen requirement for nitrification = 4.6 lb 02/NH3-
N nitrified, the total oxygen requirement for nitrification is:
35 - 230 x 5 -1 )lmg/LNH 3 - N x 8.34 x 0.987 mgd x 4.6
100
= 852 lb OZlday
c. Total Oxygen Requirement
= 2778 + 852
= 3630 lb Uday �G
= 151.25 lb 02/hr.
d. Aeration Horsepower Requirement
The total required horsepower for the platform mounted mechanical aeration is
estimated as follows:
C
SOR = AOR s
(�iC-CO)
)eAT-20xa
sw o
Where: AOR = Actual oxygen requirement = 151.25 lb 02/hr
SOR = Oxygen transfer rate, lb OZ/hr at standard conditions = 3.5 lb
OZ/hp/hr
-2 -

0-
4.
Cs = Oxygen saturation value of clean water at standard conditions = 9.092
mg/L
R = Ratio of oxygen saturation value of waste to that of clean water = 0.95
Csw = Oxygen Saturation value of clean water for the site conditions of
Temperature = 28° C and actual barometric pressure (Pa=14.575 psia) _
7.76 mg/L.
Co = Residual concentration of dissolved oxygen desired during normal
operation = 2.0 mg/L.
a = Ratio of oxygen transfer in waste to that of clean water at the same ✓
temperature = 0.8
T = Design temperature = 28° C
9 = Temperature correction constant =1.024 z�S -7
S OR = 151.25 9.092
(0.95 x 7.76 — 2.0) (1.024 )28-20 x 0.8 �L
_ 1375
5.195
= 264.7 lb 02/hr OY -
Considering 3.51b 02 s�tan and oxygen transfer rate of the EIMCO platform
mounted aerator, the required horsepower is �--_,
= 264.7 lb 02 / hr /AJ
3.5 lb 02 / hr / hp
= 75.63 hp
The existing 0.75 MG ditch is equipped with one (1) - 25 hp aerator and one (1) -50
hp aerator. This will provide the total aeration horsepower of 75 hp. The required
aeration horsepower without the denitrification oxygen credit is 75.63 hp. In the
oxidation ditch some denitrification will occur that should supplement the oxygen need
for BOD5 removal. Accordingly, the current aeration capacity should be adequate to
handle the expanded 2.5 mgd flow.
Aeration Requirement for 1.15 MG Carrousel Ditch boo
a. Oxygen Requirements for BODs Removal
Considering influent flow to 1.15 MG ditch = 1.513 mgd, influent BOD5 = 230 mg/L,
effluent BOD5 = 5.0 mg/L and oxygen requirement for BOD5 = 1.5 lb 02/lb BOD5
removed, the total oxygen requirement for BOD5 removal is:
_ (230-5) mg/L BOD5 x 8.34 x 1.513 mgd x 1.5 = 4258 lb 02/day
b. Oxygen Requirement for Nitrification (NH3-N Removal)
Considering influent flow to 1.15 MG ditch = 1.513 mgd, 5 mg/L nitrogen
requirement for each 100 mg/L BOD5 for cell synthesis, influent TKN = 35 mg/L,
effluent NH3-N = 1.0 mg/L and oxygen requirement for nitrification = 4.6 lb 02/NH3-
N nitrified, the total oxygen requirement for nitrification is:
IKM

= 35 — 230 x 5 —1 mg / L NH — N x 8.34 x 1.513 mgd x 4.6
100 3
= 1306 lb 02/day
c. Total Oxygen Requirement
= 4258 + 1306
= 5564 lb 02/day
= 231.8 lb 02/hr.
d. Aeration Horsepower Requirement
The total required horsepower for the platform mounted mechanical aeration is
estimated as follows:
5-
SOR = AOR s
(R C sw — Co) B T-2o x a
Where: AOR = Actual oxygen requirement = 231.8 lb 0Jhr
SOR = Oxygen transfer rate, lb 02/hr at standard conditions = 3.5 lb 02/hp/hr
Cs = Oxygen saturation value of clean water at standard conditions = 9.092 mg/L
R = Ratio of oxygen saturation value of waste to that of clean water = 0.95
Csw = Oxygen Saturation value of clean water for the site conditions of Temperature
= 28° C and actual barometric pressure (Pa=14.575 psia) = 7.76 mg/L.
Co = Residual concentration of dissolved oxygen desired during normal operation
— 2.0 mg/L.
a = Ratio of oxygen transfer in waste to that of clean water at the s a m e
temperature = 0.8
T = Design temperature = 28° C
0 = Temperature correction constant =1.024
SOR = 231.8 9.(
(0.95 x 7.76 — 2.0)
_ 2107.5
5.195
= 405.68 lb 02/hr
12
(1.024)28-20 x 0.8 j
Considering 3.5 lb 02/hr/hp standard oxygen transfer rate of the EIMCO platform
mounted aerator, the required horsepower is:
405.68 lb 02 / hr
3.5 lb 02 / hp / hr
= 115.9 hp
= 116 hp
The existing 1.15 MG ditch is equipped with one (1) - 50 hp aerators and one 75 hp
aerator. This will provide the total aeration horsepower of 125 hp. The required
-4 -

aeration horsepower without the denitrification oxygen credit is 116 hp. Accordingly,
the current aeration capacity should be adequate to handle the expanded 2.5 mgd flow.
-5 -

e
ALTERNATIVE EVALUATION
FOR
CLAYTON LCWRF EXPANSION TO 2.5 MGD
1.0 ALTERNATIVE EVALUATION
The following alternatives which consider treatment and discharge of effluent to
Neuse River and treatment and disposal of effluent by land application, have been
evaluated to provide the most cost-effective solution to expand the Clayton LCWRF to
2.5 MGD.
1.1 ALTERNATIVE NO.1
This alternative considers: (1) upgrading and expansion of the Clayton LCWRF
to 2.5 mgd and discharge of effluent into Neuse River, (2) the Town of Clayton joining
the Neuse River Compliance Association; (3) divert up to 600,000 gpd flow, as
necessary, from the east Clayton industrial area to the Central Johnston County
Regional Wastewater Treatment Plant; and (4) purchase additional 75,000 gpd capacity
in the Central Johnston County WW`TP. A detailed description and cost analysis of this
alternative are given as follows.
1.1.1 Description
A. Clayton LCWRF Improvements
The Clayton LCWRF improvement project for upgrading and expansion to 2.5
mgd includes the following:
1. Replacement of the three existing extended shaft centrifugal pumps
with submersible centrifugal pumps, each rated at 2,170 gpm.
Provide variable frequency drive for two of the pumps.
2. Improvements to the oxidation ditches aeration capacities by: (1)
replacement of one of the 25 hp aerators in 0.75 MG oxidation ditch
with a 50 hp aerator, (2) replacement of one of the 50 hp aerators in
-1-

the 1.15 MG ditch with a 75 hp aerator, and (3) replacement of the
existing effluent weirs with adjustable weirs to control the oxygen input
in the oxidation ditches.
3. Improvements to the existing clarifier splitter box by the addition of
weir gates to allow control of flow split to each clarifier.
4. Provide one (1) 65 ft. diam. x 14 ft. SWD secondary clarifier equipped
with a sludge removal mechanism, effluent weir, scum removal,
Stamford baffle, influent dispersion well and influent feed well. The
existing plant has one (1) 55 ft. diam. x 12 ft. SWD and one (1) 65 ft.
diam. x 14 ft. SWD clarifier. The design surface overflow rate using all
three clarifiers in service is estimated to be 278 gpd/sq. ft. The design
surface overflow rate using one larger clarifier out of service is
estimated to be 440 gpd/sq. ft.
It should be noted that the Authorization to Construct Permit for the above
improvements was issued by NCDENR on May 24, 2001 and the construction of the
subject improvements have already been completed in June 2002.
B. Join the Neuse River Compliance Association
As per paragraph (9) of the Nutrient Sensitive Water Management Strategy rule
0.0214 the Town of Clayton can use the option to join a group compliance association
to collectively meet nutrient load allocations. Articles of Incorporation forming the Neuse
River Compliance Association (the "Association") have been filed, establishing the
Association as a non-profit corporation. The Town has submitted the required resolution
of intent to join the Association in a form acceptable to the Association. See attached
copy of the letter from the Association confirming the formation of Association. A copy of
the Town's resolution of intent to join the Association is also attached.
-2-

C. Divert Flow to Johnston County Regional WWTP
The Town of Clayton has an agreement with Johnston County to divert up to
6009000 gpd from the east Clayton industrial area to the Johnston County Regional
Wastewater Treatment Plant. The agreement is on the flow exchange basis, i.e., the
Town can divert flow equivalent to the wastewater flow the Town is receiving from the
Johnston County service area. However, the Town of Clayton and Johnston County
understand the wastewater needs for each other and will work together to maximize
diversion of flow to the Johnston County Regional WWTP.
D. Capacity Purchase from Johnston County Regional WWTP
The Town of Clayton has entered into an agreement with Johnston County to
purchase 75,000 gpd capacity allocation in the Central Johnston County Regional
Wastewater Treatment Plant (CJRWWTP). As per the agreement, the Town has also
reserved the right to purchase an additional 175,000 gpd capacity in the CJRWWTP at
a future date after expansion of the Johnston County WWTP is completed. As a part of
design the expanded CJRWWTP has only 250,000 gpd capacity allocation for the Town
of Clayton. The above 75,000 gpd capacity purchase to accommodate the current
ongoing growth in the Clayton area is a part of the 250,000 gpd reserve capacity for
Clayton in the CJRWWTP.
1.1.2 Construction Cost Opinion
A. Clayton LCWRF Improvements
Influent pump station and modification $ 2819208.00
Aeration basin renovations 2069119.00
New 65 ft. diameter clarifier 543,332.00
Soils and concrete testing 5,000.00
-3-

Total Construction Cost (A)
$
1,035,659.00
Contingencies (5%)
51,783.00
Engineering
78,558.00
Construction administration and inspection
63,000.00
Total Project Cost (A)
$
19229,000.00
B. Join Neuse River Compliance Association
Association Membership
$
0.00
Total Project Cost (B)
$
0.00
C. Divert Flow to Johnston County Regional WWTP
Flow diversion capital improvements (existing)
$
0.00
Total Project Cost (C)
$
0.00
D. Capacity Purchase from Johnston County Regional WWTP
Capacity purchase cost for 75,000 gpd
$
432,000.00
Total Project Cost (D)
$
4329000.00
TOTAL PROJECT COST (A+B+C+D)
$
1,661,000.00
1.1.3 Annual Operation and Maintenance Costs
Salaries, including fringe benefits
Utilities: Electric
Telephone
Chemicals: Alum
Caustic
Polymer
Maintenance and Repairs
Contracted Services:
Laboratory testing
Pretreatment
Sludge disposal
Continuing education and training
Permit fees and dues
Departmental supplies
Wastewater transmission cost
-4-
200,000.00
226,000.00
2,500.00
19500.00
1,000.00
20,000.00
50,000.00
20,000.00
10,000.00
30,000.00
2,500.00
79500.00
9,000.00
51,000.00

s
a
Insurance and Bonds 5,000.00
Capital Outlay 40,000.00
Total Annual Operation and Maintenance Cost $ 676,000.00
1.1.4 Estimated Salvage Value
Treatment Work: 1— 20 x $ L035,659.00 $ 345, 000.00
30
Total Estimated Salvage Value $ 345,000.00
1.1.5 Economic Analysis
A. Basic Considerations
a. Planning period: 20 years
.b. Capital cost of the project: $1,661,000.00
c. Annual O&M costs: $676,000.00
d. Salvage value at the end of 20 years: $345,000.00
e. Interest rate: 7.125 percent
f. Single Payment Present Worth Factor @ 7.125% for 20 years: 0.25245
g. Uniform Series PWF @ 7.125% for 20 years: 10.4918
h. Capital Recovery Factor @ 7.125 for 20 years: 0.09531
B. Present Worth Cost
a. Initial Capital Cost $ 19661,000.00
b. Present Worth of Annual O&M Costs
$676,000 x 10.4918 79092,500.00
c. Present Worth of Salvage Value
$345,000 x 0.25245 87,000.00
Net Present Worth Cost (a + b — c) $ 89666,500.00
C. Annual Equivalent Cost
$8,666,500.00 x 0.99531 $ 826,000.00
-5-

Pump Station
Grit Removal
Mechanical
Screen
Influent
Legend
Wastewater / Effluent
- - - - Sludge
-•—•— Scum
—m-- Magnesium Hydroxide Feed
A Alum Feed
Polymer Feed
P.S. Pump Station
O.B. Distribution Box
Ox. Basin No. 2 (1.15 MG)
�• �- • - —• - —• ---�- -
Scum Waste to --1---- _
Aerobic Digester -41• - - - - -
Waste Sludge to
Sludge Recirc./Waste
Thickener /
Aerobic Digester UV Disinf /
Exhibit 1
Schematic Flow Diagram of Alternative 1
Clayton LCWRF Upgrading and Expansion to 2.5 mgd
Clarifier
No. 3
Tertiary
Filters
2.5 mgd to Neuse River
Eff. Pump Sta.

1.2 Alternative No. 2
The alternative considers discharging 0.6 mgd of effluent flow by land application
and the remaining 1.9 mgd to the Neuse River for expansion of the Clayton LCWRF to
2.5 mgd. This alternative also considers: (1) the Town of Clayton joining the Neuse
River Compliance Association, (2) diverting up to 600,000 gpd flow, as necessary, from
the east Clayton industrial area to the Central Johnston County Regional WWTP, and
(3) purchase an additional 75,000 gpd capacity in the Central Johnston County WWTP.
A detailed description and cost analysis of this alternative are given as follows:
1.2.1 Description
1. Use the existing LCWRF, with the upgrading and expansion to 2.5
mgd improvements stated in Alternative No. 1, as pre -application
treatment system for discharge of 0.6 mgd effluent by land application
and the remaining 1.9 mgd effluent to the Neuse River.
2. Join the Neuse River Compliance Association
3. Divert up to 600,000 gpd flow from the east Clayton industrial area to
the Johnston County Regional Wastewater Treatment Plant as per the
terms and conditions of the agreement.
4. Purchase 75,000 gpd additional capacity in the Johnston County
Regional WWTP.
5. Provide an effluent transport system to convey the preapplication
treatment system effluent to the effluent storage lagoon at the
proposed land application site. The effluent transport system will
consist of providing an effluent pump station equipped with two 60 hp
pumps, each rated at 1,050 gpm, and 37,000 lineal feet of 12-inch
diameter ductile iron force main.
6. Provide a 36 million gallon effluent storage lagoon for storage of
effluent when land application of effluent cannot take place due to
-7-

inclement weather conditions, saturated soils and higher groundwater
conditions, cover crop harvesting and site management.
7. Provide a chlorination system for disinfection of effluent prior to land
application.
8. Provide a spray irrigation pump station equipped with three (3) —1200
gpm pumps, including one standby, with necessary controls and
piping. Provide an automatic strainer on the spray header piping to
remove solids for efficient operation of the spray irrigation system.
9. Provide header piping and solid -set type spray irrigation system for
land application of effluent. The average hydraulic application rate will
be approximately 0.75 inch/wk and area requirement for spray
irrigation of 0.6 mgd flow is estimated to be approximately 206 acres.
10. Provide monitoring wells for measurement of groundwater table and
sampling of groundwater compliance with the water quality
parameters included in the nondischarge permit.
11. Provide access roads for management and operation of the land
application system. Provide fencing for the effluent storage lagoon
and land application site to comply with the State regulatory
requirements.
12. Provide an operation and control building and a storage and
maintenance building.
1.2.2 Construction Cost Opinion
A. Clayton LCWRF Improvements
Influent pump station and modification
Aeration basin renovations
New 65 ft. diameter clarifier
Soils and concrete testing
Total Construction Cost (A)
Contingencies (5%)
Engineering
Construction administration and inspection
in
$ 281,208.00
206,119.00
543, 332.00
5,000.00
$ 1,035,659.00
51,783.00
78, 558.00
63,000.00

Total Project Cost (A)
$ 19229,000.00
B. Join Neuse River Compliance Association
Association Membership
$ 0.00
Total Project Cost (B)
$ 0.00
C. Divert Flow to Johnston County Regional WWTP
Flow diversion capital improvements (existing)
$ 0.00
Total Project Cost (C)
$ 0.00
D. Capacity Purchase from Johnston County Regional WWTP
Capacity purchase cost for 75,000 gpd
$ 4329000.00
Total Project Cost (D)
$ 432,000.00
E. Land Application of 0.6 MGD Effluent Flow
Effluent Transport System for Land Application
Effluent pump station $ 150,000.00
379000 LF of 12-inch D.I. forcemain 960,000.00
Sitework and piping 25,000.00
Electrical 20,000.00
Sub Total (Effluent Transport System) $ 1,155,000.00
Land Application System
36 mil. gal. effluent storage lagoon
$ 850,000.00
Spray irrigation pump station
250,000.00
Chlorination system
45,000.00
Spray irrigation system, including header piping
19133,000.00
Sitework and piping
1709000.00
Site preparation, liming and seeding
103,000.00
Fencing and access roads
160,000.00
Monitoring wells
10,000.00
Electrical and instrumentation
40,000.00
Operation and control building
60,000.00
Storage and maintenance building
40,000.00
Sub Total (Land Application System)
$ 2,861,000.00
In

_ Total Construction Cost (E)
$ 410169000.00
Contingencies
401,600.00
Engineering and Construction Administration
4129400.00
Geotechnical Work
10,000.00
Site evaluation by soil scientist
25,000.00
Legal and administrative
359000.00
State Construction loan fee (3%)
218,000.00
Start-up Services
15,000.00
Operation and Maintenance Manual
19,000.00
Land, 270 acres @ $5,000/ac.
$ 1.350.000.00
Total Project Cost (E)
$ 6,502,000.00
TOTAL PROJECT COST (A+B+C+D+E)
$ 89163,000.00
1.2.3 Annual Operation and Maintenance Manual (for 2.5 mgd plant)
Salaries, including fringe benefits $ 2329000.00
Utilities: Electric 286,000.00
Telephone 2,500.00
Chemicals: Alum
19500.00
Caustic
1,000.00
Polymer
20,000.00
Chlorine
2,000.00
Maintenance and Repairs
60,000.00
Contracted Services: Laboratory testing
259000.00
Pretreatment
10,000.00
Sludge disposal
30,000.00
Continuing education and training
2,500.00
Permit fees and dues
8,000.00
Departmental supplies
9,000.00
Wastewater transmission cost
51,000.00
Insurance and Bonds
5,000.00
Capital Outlay
45,000.00
-10-

Total Annual Operation and Maintenance Cost $ 7939000.00
1.2.4 Estimated Salvage Value
Treatment Work: 1— 20 x ($1,035,659+$4,016,000 — $960,000) $ 1,367,000.00
30
Forcemain: $960,000 x 0.5 $ 4809000.00
Land: $1,350,000 x 1.80611 $ 2,438,000.00
Total Estimated Salvage Value $ 412859000.00
1.2.5 Economic Analysis
A. Basic Considerations
a. Planning period: 20 years
b. Capital cost of the project: $8,163,000.00
c. Annual O&M costs: $793,000.00
d. Salvage value at the end of 20 years: $4,285,000.00
e. Interest rate: 7.125 percent
f. Single Payment Present Worth Factor @ 7.125% for 20 years:
0.25245
g. Uniform Series PWF @ 7.125% for 20 years: 10.4918
h. Capital Recovery Factor @ 7.125 for 20 years: 0.09531
i. Land appreciation factor (EPA): 1.80611
B. Present Worth Cost
a. Initial Capital Cost $ 8,163,000.00
b. Present Worth of Annual O&M Costs
$793,000 x 10.4918 89320,000.00
c. Present Worth of Salvage Value
$4,285,000.00 x 0.25245 1,082,000.00
Net Present Worth Cost (a + b — c) $ 15,410,000.00
C. Annual Equivalent Cost
$15,410, 000.00 x 0.09531 $ 1,468, 000.00
-11-

Pump Station
�-- Magnesium
Hydroxide
Grit Removal Feed or
Sodium
Hydroxide
Mechanical
Screen
Influent
Legend
Wastewater / Effluent
- — — —
Sludge
-----
Scum
—m--
Magnesium Hydroxide Feed
A
Alum Feed
Polymer Feed
P.S.
Pump Station
D.B.
Distribution Box
Ox. Basin No. 2 (1.15 MG)
O
O
D.B.
D.B. P.S.
Alum Feed -
Polymer Feed -P-/
I Clarifier
I No.1
1 O
1
I I
I O I
I
I 1
I
L Ox. Basin No.1 (0.75 MG) — — `�-- Sludge Recirc. P.S.
f- ----- --- -----fit-
Scum Waste to
Aerobic Digester — — — -" — —
Waste Sludge to
Sludge Recirc./Waste
Thickener /
Aerobic Digester UV Disinf /
Chlorination -
Dechlorination
P.S/.Q,
Scum j♦
j Clarifier
No. 2-
Eff. Pump Sta.
Exhibit 2
Schematic Flow Diagram of Alternative 2
Clayton LCWRF Upgrading and Expansion to 2.5 mgd
�l
'I I
i
'1 I
�I
r*
_ — P.S.q�,-Drain
Clarifier
No. 3
.Tertiary
Filters
1.8 mgd to Neuse River
Eff. Pump Sta.
0.6 mgd to Effluent Storage
Lagoon at Land Application
Site

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_ _ o• 1'
36 m al Storage Lagoon...
J 1 _ g g
• �! r ' '� ��' � � .. -.. Q ' �• 7. - � - _ Jam• r.r `� ��
1. 1 / M•• • ` s4•
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01
.r
Exhibit 3
Effluent Transport from Clayton WWTP to Proposed Land Application Site
Maps: USGS Clayton & Powhatan. North (''arnihin

L
1.3 Alternative No. 3
This alternative considers land application of entire 2.5 mgd flow and elimination
of the discharge to the Neuse River for expansion of the plant to 2.5 mgd. However, this
alternative was eliminated from further considerations due to the following reasons: (1)
Alternative No. 2 which considers discharging 0.6 mgd of effluent flow by land
application and remaining 1.9 mgd to the Neuse River for expansion of the plant to 2.5
mgd indicates that land application of effluent is not cost-effective, (2) at an average
hydraulic loading rate of 0.75 inc/wk, the wetted area required for land application of 2.5
mgd flow is 860 acres. Allowing area requirements for buffers, access roads, effluent
storage lagoon, and uneconomic remnant, it is estimated that the total area required for
the land application system would be approximately 1,200 acres; (3) difficulty of
acquiring land parcel(s) in close proximity needed for land application of wastewater; (4)
environmental concerns associated with transport of effluent to land application site(s)
and use of potential site(s) for land application of the effluent; and (5) significant cost
associated with the alternative.
-14-

c
C
Little Creek Water Reclamation Facility
NPDES Permit No. NCO025453
Town of Clayton, North Carolina
Sludge Management Plan
Biosolids Preparation:
Waste Activated Sludge (WAS) from the secondary clarifiers is thickened in an existing rotary
drum thickener and then transferred to the existing 90,000 gallon and 300,000 gallon aerobic
stabilization / storage tanks. The underflow from the sludge thickener is returned to the oxidation
ditches. Once stabilized, the sludge is hauled away by a contractor for off -site disposal. Decants
from the sludge stabilization / storage tanks are recycled back to the WAS pump station.
Biosolids generated by the LCWRF are prepared to meet Class B pathogen requirements
through Alternative 1 [40 CFR 503.32(b)(2)] and Alternative 2 [40 CFR 503.32(b)(3)].
Alternative 1 requires that the geometric mean of fecal coliform density, in seven samples of treated
sewage sludge, not exceed 2 million Colony Forming Units (CFU) or Most Probable Number
(MTN) per gram of sewage sludge solids. Alternative 2 requires that the sludge be treated in a
process to significantly reduce pathogens. The process currently employed by the LCWRF is
aerobic digestion. The vector attraction reduction requirements are satisfied by the sludge hauler(s),
not by the LCWRF, prior to disposal as discussed below.
Biosolids Disposal:
Biosolids generated by the LCWRF are disposed of off -site by a contract hauler. East Coast
Resources, operating under Non -Discharge Permit No. WQ0000506, is the primary hauler and
Granville Farms, operating under Non -Discharge Permit No. WQ0004801, is a backup hauler.
Both sludge haulers require that the Town prepare the biosolids to meet Class B pathogen
requirements, as discussed above, prior to removal from the LCWRF. East Coast Resources and
Granville Farms meet the vector attraction reduction requirements by employing Option 9 [40 CFR
503.33(b)(9)] and/or Option 10 [40 CFR 503.33(b)(10)]. Option 9 requires injection of the
sewage sludge below the land surface. Option 10 requires that the sewage sludge applied to the
disposal site be incorporated into the soil within 6 hours after application.
A third hauler, McGill Environmental, operating under Non -Discharge Permit No.
WQ0006816, does not require the Town to meet the Class B requirements prior to removing
sludge from the LCWRF. McGill Environmental dewaters the sludge at the plant then hauls the
sludge to their composting facilities for further processing to meet Class A pathogen and vector
attraction reduction requirements prior to disposal. The pathogen reduction requirement is met
through Alternative 1 [40 CFR 503.32(a)(3)-(8)], monitoring of fecal coliform, and/or Alternative
5 [40 CFR 503.32(a)(7)], composting PFRP. The vector attraction reduction requirement is met
utilizing Option 5 [40 CFR 503.33(b)(5)]. Option 5 requires the sewage sludge to be aerobically
treated for at least 14 days at over 40° C with an average temperature over 45° C.

Lower Neuse Basin Association, Inc.
Raleigh, North Carolina
September 27, 2002
J. William Reid, Supervisor
Point Source Branch
Division of Water Quality
NC Dept. of Environment and Natural Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: T own of Clayton — Membership in the Neuse River Compliance Association
Dear Mr. Reid:
This letter is being sent at the request at the Town of Clayton in response to your
letter of June 10, 2002 concerning their application for a modification of NPDES Permit
No. NC0025453. Articles of Incorporation forming the Neuse River Compliance
Association (the "Association") have been filed, establishing the Association as a
nonprofit corporation. Furthermore, the Town of Clayton has submitted the required
resolution of intent to join the Association in a form acceptable to the Association. The
final Association membership roster and operational parameters will be completed upon
approval of the operational agreement by the Division of Water Quality and
Environmental Management Commission.
If you have any questions regarding this matter, don't hesitate to contact me at
[phone].
Sincerely,
Timothy L. onnelly, PE
Chairman
Lower Neuse Basin Association
And Neuse River Compliance Association
Cc: Town of Clayton
The Wooten Co.
p���0WN
�l
OCT - 2 2002
c.: <<a - w A.R nu.Aurr
P, J SUuFICE GRiI -.H
P. O. Box 590 Raleigh, North Carolina 27602
(9 7 9) 890-3400

DENR/DWg
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES No. NC0025453, Clayton/ Little Creek WRF
FaciRty Information
Ap licant/FaciliName:
Town of Clayton/ Little Creek Water Reclamation Facility
Mnt Address:
P.O. Box 879, Clayton, NC 27520
Address:
Durham Street Extension
Permitted Flow
1.9 MGD (expansion request to 2.5 MGD)
Type of Waste:
- 22% Ind., -78% Domestic (at permitted flow)
Facility/Permit Status:
Renewal
County:
Johnston
Miscellaneous
Receiving Stream:
Neuse River
Regional Office:
RRO
Stream Classification:
WS-IV NSW CA
SI: 27-41.3
Quad
E25NW
Clayton ^ `
303(d) Listed?:
Yes
Permit Writer:
S. Wilson
Subbasin:
030402
Date:
Janu 003
Drainage Area (mi2):
1150
Summer 7Q10 (cfs)
186 (regulated)
Winter 7Q10 (cfs):
Average Flow (cfs):
IWC (%):
1.6
Primary SIC Code: 14952
SUMMARY
Clayton operates a 1.9 MGD wastewater treatment facility that discharges into the Neuse River.
Average annual flow has been approximately 1.4 MGD (appx. 74% of permitted flow). Due to
the exponential growth in this area outside of Raleigh, Clayton proposes to expand from 1.9
MGD to 2.5 MGD. The Town will accomplish this through some construction additions and the
re -rating of the existing plant. An 'Authorization to Operate' will have to be attained prior to
the expansion to 2.5 MGD - to ensure that all components can accommodate the increase in
flow. This expansion is not the 20 year projected flow, but will provide Clayton with some
capacity for growth. The Town is also in the process of adding biological nutrient removal,
which would ultimately decrease the nitrogen load to the Neuse River.
An alternative analysis was done to ensure that the discharge from this regional facility was the
most feasible alternative. [There are no nearby, cost effective areas for spray application of the
expanded flow. Due to the distance and cost, discharge to the City of Raleigh was not a feasible
option. Clayton continues to divert some wastewater to Johnston County. The Town has
received some grant funding for diverting re -use wastewater to a nearby golf course.].
The Clayton facility discharges to the mainstem of the Neuse River. According to the Basinwide
Water Quality Management Plan for the Neuse, the primary water quality considerations for
point sources in the basin are discharges of (1) oxygen -demanding substances and (2)
nutrients.
The Modeling Unit evaluated the impact of increased wastewater flows on dissolved oxygen
levels, using a QUAL2E model already developed for the Neuse River. The results show that,
with an increase in the Town's discharge to 2.5 MGD, the D.O. level in the river will remain
above the standard of 5.0 mg/L. Thus, the modeling results indicate the adverse impact of the
expanded discharge to be acceptable.
Point source rules regarding control of TN and TP have been passed by the EMC. To a
the nutrient reduction issue, the Town is a participant in the Neuse River Compliance
Association (this will allow the facility to comply with the nitrogen limit through the
Association). The Town also is currently in the process of seeking approval for biologil
nutrient removal through the Construction Grants & Loans section. i
NCO025453 Clayton
NPDES Renewal & Expansion to 2.5 MGD
Page I

•
Antidegradation
-6
The Town of Clayton prepared an Environmental Assessment demonstrating that the
recommended alternative is the most environmentally sound of the reasonably cost-effective
options. The Division issued a Finding of No Significant Impact (FONSI) for the expansion on
February 24, 2002. The Division of Water Quality determined that the incremental impact of
the increased discharge will not result in contravention of applicable water quality standards or
loss of the river's designated uses. The Division concluded that expansion of the existing
treatment plant and continued discharge to the Neuse River is the most feasible alternative.
The expanded plant will serve as a regional treatment facility for the area. The Division has
determined that the proposed expansion is necessary to accommodate social and economic
growth in the area and that it will not result in contravention of surface water quality
standards or loss of designated uses in the receiving stream.
TOXICITY TESTING:
Current Requirement: Chronic P/F ® 1.6% (at 1.9 MGD)
Chronic P/F at 2.0 % (at 2.5 MGD)
Clayton has had I failure during the previous 5 years (that failure was followed -up with 2
passes).
COMPLIANCE SUMMARY: BASED ON THE PREVIOUS 2 YEARS
Clayton has had some limit excursions for ammonia and BOD5 (in the past 2 years), with
values below the threshold for automatic civil penalties. Additional treatment capacity may
help eliminate these minor excursions.
INSTREAM MONITORING:
Clayton is part of the Lower Neuse Basin Association (LNBA) and is not required to perform the
instream monitoring required in this permit. (The LNBA monitors several sites for various
facilities along the Neuse River).
PROPOSED CHANGES:
Clayton has been accepted as a member of the Neuse River Compliance Association. Special
language has been inserted into the permit regarding the compliance stipulation for total
nitrogen. The total phosphorus limit of 2 mg/1 was instituted in the previous permit (and since
Clayton is a member of the Compliance Association, the 2 mg/I TP limit is applied again in this
permit).
Clayton monitors for copper, zinc, silver, and lead through the NPDES permit.
The Town of Clayton operates under an approved pretreatment program and must comply with
its Long Term Monitoring Plan (LIMP). As part of the pretreatment program, Clayton monitors
for arsenic, cadmium, chromium, mercury, molybdenum, nickel, selenium, and. cyanide (and
these will continue through the pretreatment program) - copper, zinc, silver, and lead are. also
required. Most values have been below detection level, and well below allowable levels, for all
except molybdenum. There is no water quality standard for molybdenum (and Mo will continue
to be monitored through the pretreatment program and the residuals permit), so no limit or
monitoring requirement will be imposed in the NPDES permit.
Other than conventional parameters, the parameters sampled in the application only had above
detection levels for copper, lead, silver, and zinc (which are currently monitored through the
permit). No changes are proposed based on information in the permit application.
Copper, silver and zinc will continue to be monitored due to the potential to exceed the action
level standard at the acute level. Copper and Zinc will be monitored at 1 /month due to
Clayton's "pass" on toxicity testing. Silver monitoring will be reduced to I /month. Lead
monitoring will remain at a quarterly frequency.
NCO025453 Clayton
NPDES Renewal & Expansion to 2.5 MGD
Page 2

Lead will be eliminated because the reasonable potential analysis showed that lead levels were
below the acute value. Lead will continue to be monitored quarterly via the facility's
pretreatment program LTMP.
Based on the NH3-N policy adopted October 15, 2003, weekly average NH3-N limits have been
inserted for the existing flow (1.9 MGD) and the expansion flow (2.5 MGD).
An annual priority pollutant scan has also been inserted in the permit to ensure that the
permittee complies with the requirement in the municipal permit applications.
PROPOSED SCHEDULE FOR PERMIT ISSUANCE:
Draft Permit to Public Notice: After Jan. 8, 2003
Permit Scheduled to Issue: Feb 28, 2003 (est.)
STATE CONTACT:
If you have any questions on any of the above information or on the attached permit, please
contact Susan Wilson, P.E. at [phone] ext. 510.
REGIONAL OFFICE COMMENT:
(Staff report received October 29, 2002).
NAME: t DATE:
NCO025453 Clayton
NPDES Renewal & Expansion to 2.5 MGD
Page 3

Whole Effluent Toxicity Testing Self -Monitoring Summary
November 13, 2C
FACILITY REQUIREMENT
YEAR JAN FED
MAR
APR
MAY JUN
JUL
AUG SEP
OCT
NOV DEC
Cilgo-Paw Crk Bulk Terminal Perm: 24hr LC50 ac morn cpis fthd (grab)
1998 — -••
—
2.100
— —
—
— —
--
— -
NC0021962/001 Begin:9/I/2001 Frequency: A NonComp:
1999 -- —
—
—
— 2,100
—
— —
—
— —
County. Mecklenburg Region: MRO Subbasin: CTB34
2000 2,100 —
—
—
— —
--
— —
—
— -
PF: NA Special
2001 — 2,100
—
—
— —
-•
— —
—
—
7Q10:0.0 IWC(%):100 Order:
2002 — —
--
--
— •-•
-•
— --
Claremont North ♦VWTP Perm chr lim: 13%
1998 Pass —
—
Pau
— —
Pass
— —
Pass
— --
NC0032662/001 Begin:4/l/2001 Frequency: Q Jan Apr Jul Oct + NonComp:Single
logo Pass —
—
Pass
— —
Pass
— —
Pass
— --
County: Catawba Region: MRO Subbasin: CT832
2000 Pass —
—
Pass
— —
Pass
— —
Pass
— --
PF. 0.10 Special
2001 pass -.
—
Pass
— —
Pass
— —
Pass
— -
7Q10:1.0 IWC(%):13 Order.
2002 Pass.Pass —
—
Pass
— —
Pass
— —
Pass
Claremont South WWTP Perm chr lim: 61%
lose I --
—
I
— —
l
— —
t
-•
NCO0265491001 Begin:4/I/2001 Frequency: Q Jan Apr Jul Oct + NonComp:Single
1999 1 --
—
f
-- •-
I
— -•-
I
-- --
County: Catawba Region: MRO Subbasin: CTB32
2000 1 --
—
I
— —
I
— •-
I
••' --
PF:0.10 Special
2001 I-
7QI0:0.10 IWC('/.):60.78 Order.
2002 I —
••
I
— —
I
— -
- Claremont-MeLin Creek WWTP Perm chr lim: 9%
1998 Pass —
—
Pass
— —
Pass
•-- —
Pass
— •`
NCO081370/001 Begin:6/l/2001 Frequency: Q Jan Apr Jul Oct + NonComp:Single
1999 paw —
—
Pass
— —
Pass
— —
Pass
— —
County: Catawba Region: MRO Subbasin: CTB32
2000 Pass —
—
Peas
— —
Pass
— —
Pass
— »-
PF:0.3 Special
2001 Po —
—
Pass
— —
Pass
— —
Pass
— --
7Q10:5.0 IWC('A)4 Order:
2002 Pass —
—
Pass
— —
Pass
— —
Pass
Clariant Corp. -hit. Holly Plant PERM CHR LIM: 1.8%
i loss — —
Pass
—
— Pass
—
— Pass
—
— Pass
NC0004375/001 Begin:9/1/1991 Frequency: Q P/F + Mar Jun Sep Dec NonComp:Sittgle
logo — —
Pass
—
— Pass
Pass
— NR
Pass
— NR/Pass
County: Mcddenbarg Region: MRO Subbasin: CTB34
2000 — —
Pass
—
— Pass
—
— Pass
'•
— Pass
PF:3.9 Special
2001 — ...
Pass
—
— Pass
--
— Pass
—
— Paw
7Q10:329 IWC(%):1.8 Order:
2002 — --
Pass
—
— Pass
—
— Pass
Clarkton WWTP Pem1 chr Gm: 90%
1998 Pass --
—
Fall Pass
—
Pass
— — Pass —
—
NC0021610/001 Begin:l2/1/1999 Fmq=cy:Q Jan Apr Jul Oct
+ NonComp:Single
1999 Pass —
—
Pau —
—
Fall
Pass -- Paso —
—
County. Bladen Region: FRO Subbasin: LUM58
2000 Fall 94.9
>100
Pass —
—
Pass
— — Fait 3.100
2.100
PF: 0.24 Spacial
2001 3.100 --
—
>100 —
--
Pass
-- — Pass --
—
7QI0:0.0 twc(%):100 Order:
2002 Pau —
—
Pass —
—
Pass
— —
" Perm chr Rm: 1.6%
1998 — —
Pass
— —
Pass
-•
— Pass -• ..
pass
iC 'IS453/01 Begin 9/1/2000 Frequency: Q Mar Jun Sep Dec
+ NonComp:Single
logo — =
Pass
=
Pau
—
— Pau
N
Pass
County: Johnston Region: RRO Subbasin: NEU02
2000 —
Pans
Fail
>8.84
>8.64 Pau
Pass
PF: 1.9 Special
2001 — —
pass
— —
Pass
—
— Pass — —
Pass
�9�Hib. � LWC(%):1.6 Order:
2002 — —
Pass
3.100.2100 —
Pass
—
— Pau.3.100
Cleveland Mfl1s/001 PERM CHR LEM: 2.4%; IF EXP>.78MGD ® 3.4%
1998 — —
Late
Pass •-
Pass
—
— Pau — --
Pass
NC00041201001 Begin:9/1/1993 Frequency: Q P/F + Mar Jun Sep Dec
NonComp:SINGLE
1999 — —
Pass
— —
Pass
—
— Pass — -
Pass
County: Cleveland Region: MRO Subbusin: BRD04
2000 — —
Pass
— —
Pass
—
— Pass »• •»
Pass
PF: 0.78 special
2001 — —
Pass
— —
Pass
-•
— NRIH -- —
-
7Q10:49.40 IWC(%)2.4 Order:
2002 — —
H
— —
H
—
— H
Cleveland WWTP Perm chr lim: 3.01A
1998 Pass —
Pass — — Pass — —
Pau — -• Pass
NCO049867/001 Bcgin:3/1/2000 Frequency:Q Mar Jun Sep Dec + NonComp:Singlc
loss — —
Fail Pass, — Late Pass --
Pau — — Pass
County: Rowan Region: MRO Subbasin: YAD06
2000 — —
NR/Pass — — Pass.Pass — —
Pass — — Pass
PF:0.27 Special
2001 — ..-
Pass — — Pass — —
Pass — .- Late
7QI0:14.0 IWC('/.)3.0 Order:
2002 Pass —
Pass — — Pass — —
Pass
Clinton-Larkias WPCF Perm chr lim: 90%
1998 —
-- 3-90 —
— >90 —
— >90 — — >eo
NCO020117/001 Begin:8/1/1996 Frequency: Q P/F + Mar Jun Sep Dec NonComp:Single
1999 —
— Pass —
— Pass —
— Pau — — Fad
County. Sampson Region: FRO Subbasin: CPF19
2000 Pau
>100..100 pass —
— Pass —
— Pats — — Pass
PF: 5.0 special
2001 —
.-. Pau --
-- Pau —
— Pau — — Fad
7Q10:0.0 IWC(%):100 Order:
2002 21W
3.100 Pass —
— >90 —
— 3.90
V Pre 1998 Data Available
LEGEND:
PERM - Permit Requirement LET - Administrative, Letter - Target Frequency, -Monitoring frequency: Q- Quarterly; M- Monthly BM- Bimonthly; SA- Semiannually; A. Aratually; OWD- Only whctl discharging, D- Discontinued monitoring requirement
Begin - First month required 70)0 - Receiving stream low flow criterion (cfs) += quarterly monitoring increases to monthly upon failure or NR Months that testing must occur • ex. Jat1, Apr, Jul, Oct ;!onCamp - Current C mpliance Requirement
PF - Pemlitted flow t(MGD) IWC%= Instream waste concentration P/F = Pass/Fall test AC - Acute CHR - Chronic
Data Notation: f - Fathead Minnow; • - Ceriodaphnia sp.; my - Mysid shrimp; ChV - Chronic value; P - Mortality of stated percentage at highest concentration; at - Performed by DWQ Aquatic Tax Unit; bt - Bad test
Reporting Notation: --- = Data not required; NR - Not reported Facility Activity Status: I - Inactive. N - Newly Issued(To construd); H - Active but not discharging; t-Mort data available for month in question; • = ORC signature needed
10 ,tr l
OF w

Facility Name =
NPDES # =
Qw(MGD)=
7QIOs (c(s)=
IWC (%n) =
Clayton - Little Creek WRF
NCO025243
2.5
186
2.04
FINAL RESULTS
Copper
Max. Pred Cw 35.8
Allowable Cw 343
rt-LmT VtL1.1G 7.3
RESULTS
Std Dev.
3.5555
Mean
4.2
C.V.
0,8563
Number
of data points
25
Mull Factor =
2.75
Max. Value
13.0
µg/I
Max. Pred Cw
35.8
µg/I
Allowable Cw
343.0
µg/I
Entered by S. Wilson
Parameter = Copper
Standard = 7.0 d µg/I
Date n
<
Actual Data
BDL=1/2DL
Oct-02
1
4.
4.00
2
12.
12,00
3
13.
13.00
4
10.
10.00
5
<
10.
5.00
6
6.5
6.60
7
7.3
7.30
8
<
2.
1.00
9
<
2.
1.00
10
<
2.
1.00
11
2.4
2.40
12
<
2.
1.00
13
2.
2.00
14
<
2.
1.00
15
2.3
2.30
16
<
2.
1.00
17
<
2.
1.00
18
2.2
2.20
19
4.4
4.40
20
3.2
3.20
21
<
2.
1.00
22
5.
5.00
23
4.4
4.40
24
8.2
8.20
Sep-00
25
3.8
3.80
Page 1

Facility Name = Clayton - Little Creek WRF
NPDES # = NCO025453
Qw (MGD) = 2.5
7Q105 (c. fs)= 1 186
IWC 2.04
FINAL RESULTS
Silver
Max. Pred Cw 8.8
Allowable Cw 2.9
f
Acute value 1.2
RESULTS
Std Dev. 1.0618
Mean 1.5
C.V. 0.7032
Number
of data points 50
Mult Factor =
1.77
Max. Value
5.0 µg/l
Max. Pred Cw
8.8 14g/1
Allowable Cw
2.9 14g/1
Entered by S. Wilson
Parameter =
Silver
Action Level
Standard =
0,1-
µg/l
Date n
<
Actual Data
BDL=1/2DL
Oct-02 1
<
5.
2.50
2
<
5.
2.50
3
5.
5.00
4
<
5.
2.50
5
<
5.
2.50
6
<
5.
2.50
7
<
5.
2.50
8
<
5.
2.50
9
<
10.
5.00
10
<
10.
5.00
Oct-00 11
<
2.
1.00
12
<
2.0
1.00.
13
<
5.0
2.50
14 .
<
2.0
1.00
15
<
2.0
1.00
16
<
2.0
1.00
17
<
2.0
1.00
18
<
2.0
1.00
19
<
2.0
1.00
20
<
2.0
1.00
21
<
2.0
1.00
22
<
2.0
1.00
23
<
2.0
1.00
24
<
2.0
1.00
25
<
2.0
1.00
26
<
2.0
1.00
27
<
2.0
1.00
28
<
2.0
1.00
29
<
2.0
1.00
30
<
2.0
1.00
31
<
2.0
1.00
Page 1

Facility Name = Clayton - Little Creek WRF
NPDES # = NCO025453
Qw (MGD) = 2.5
7QIOs (cfs)= 186
[WC (TO) = 2.04
FINAL RESULTS
Lead
Max. Pred Cw 31.8
Allowable Cw 1225.0
Acute value 33.8
ESULTS
d Dev. 4.0857
can 4.9
V. 0.8362
data points 29
Factor
Value
18.0 µgII
Pred Cw
31.8 µgIl
vable Cw
1225.0 µg/I
Entered by S. Wilson
L&L� 1kMrii--C4►4 i
, (/Y P
Parameter =
Lead
Standard =
3":'��(�. -'
µg"
Date
n
<
Actual Data
BDL=I2DL
Sep-02
1
<
10.
5.00
_
2 .
10.
10.00
3
<
5.
2.50
4
<
5.
2.50
5
13.
13.00
6
<
5.
2.50
7
5.8
5.80
8
18.
18.00
9
5.9
5.90
10
10.
10.00
11
12.
12.00
12
8.9
8.90
13
<
5.0
2.50
14
<
5.0
2.50
15
<
5.0
2.50
16
<
5.0
2.50
17
<
5.0
2.50
18
5.6
5.60
19
<
5.0
2.50
20
<
5.0
2.50
21
<
5.0
2.50
22
<
5.0
2.50
23
<
5.0
2.50
24
<
5.0
2.50
25
<
5.0
2.50
26
<
5.0
2.50
27
<
5.0
2.50
28
<
5.0
2.50
Sep-00
29
<
5.0
2.50
Page 1

Facility Name =
Clayton - Little Creek WRF
NPDES # =
NCO025453
Qw (MGD) =
2.5
7Q10s (cfs)=
186
1WC (%) =
2.04
FINAL RESULTS
Max. Pred Cw 476.7
Allowable Cw 2450.0
Acute value r- 67.0
RESULTS
Std Dev. 56.2134
Mean 124.4
C.V. 0.4518
rvumer
of data points
27
Mult Factor =
1.77
Max. Value
270.0 µg/1
Max. Pred Cw
476.7 µg/1
Allowable Cw
2450.0 µg/1
Entered by S. Wilson
ON mopw
Parameter = Zinc
Standard = 50:0 µg/1
Date n < Actual Data BDL=1/2DL
Sep-02 1
78.
78.00
2
118.
118.00
3
113.
113.00
4
160.
160.00
5
160.
160.00
6
20.
20.00
7
94.
94.00
8
97.
97.00
9
120.
120.00
to
110.
110.00
11
160.
160.00
12
110.
110.00
13
10.
10.00
14
100.
100.00
15
270.
270.00
16
270.
270.00
17
180.
180.00
18
120.
120.00
19
120.
120.00
20
130.
130.00
21
.110.
110.00
22
150.
150.00
23
110.
110.00
24
150.
150.00
25
110.
110.00
26
89.
89.00
9/1 /00 27
100.
100.00
Page 1

Facility Name =
NPDESA=
Qw (MGD) =
7QlOs (cfs)=
[WC (%)=
Clayton - Little Creek WRF
NCO025453
2.5
186
2.04
FINAL RESULTS
Mercury
Max. Pred Cw 0.4
Allowable Cw 0.6
d Dev. 0.0333
can 0.1
V. 0.3000
data points 9
Factor
Value
0.2 µg/l
Pred Cw
0.4 µg/1
vable Cw
0.6 µgll
Entered by S. Wilson
Parameter = Mercury
Standard = 0.012 µg/I
Date
❑
<
Actual Data
BDL--1/2DL
Sep•02
1
<
.2
0.10
2
<
.2
0.10
3
<
.2
0.10
4
<
.2
0.10
5
<
.2
0.10
6
<
.2
0.10
7
<
.2
0.10
8
.2
0.20
Sep-00
9
<
.2
0.10
NC LiMti OIL Mont; t—ori-'Jc7 a9UTA��
CST ll_ , qU A/U�l `, (nl aMp)t
Page 1

NCO025453
Facility: Clayton - Little Creek WRF
Discharge to: Neuse River, WS IV -NSW CA
Stream class and index #:
Residual Chlorine
Ammonia as NH3
(summer)
~r
f
i
_N
�
1
7Q10 (CFS)
186
7Q10 (CFS)
186
DESIGN FLOW (MGD)
2.5
DESIGN FLOW (MGD)
2.5
DESIGN FLOW (CFS)
3.875
DESIGN FLOW (CFS)
3.875
STREAM STD (UG/L)
17.0
STREAM STD (MG/L)
1.0
UPS BACKGROUND LEVEL (UG/L)
0.
UPS BACKGROUND LEVEL (MG/L)
0.22
IWC (%)
2.04
IWC (%)
2.04
Allowable Conc. (ug/1)
833.00
Allowable Concentration (mg/1)
38.44
minimum = 2
Ammonia as NH3
(winter)
7Q10 (CFS)
186
Fecal Limit
200/100ml
DESIGN FLOW (MGD)
2.5
Ratio of 48.01
DESIGN FLOW (CFS)
3.875
STREAM STD (MG/L)
1.8
UPS BACKGROUND LEVEL (MG/L)
0.22
IWC (%)
2.04
Allowable Concentration (mg/1)
77.64
minimum = 4
,pp II r�
Iv;{ L j m t 'T 5

Clayton
Subject: Clayton
Date: Fri, 16 Aug 2002 11:18:46 -0400
From: Rob Brown <[e-mail]>
Organization: DENR/DWQ/Contruction Grants and Loans
To: Susan A Wilson <[e-mail]>
Susan, still trying to tie up loose ends on Clayton's TN amendment. We
are hoping to tell them to respond to Bill Reid's June letter through
the revised Facility Plan and then let ya'll review for concurrence.
This would save them the expense of preparing 2 documents. Does that
make sense to you? How do you feel about it? If you need to call me at
715-6213, feel free.
-;� pj�IU4,A/f P f 1$ CAL- L $�11 .
((�� 6CanJ � %�.c':S$ �� "`� t N � Gt � �'
CA
e*p6(L5N ZZ, (ti PeaA IT 4pf>L t Cif o Al) . �( ,4,otI rro 12- 15 s 4 �s
,r4 of CA,, s�rL S tit C L D o C 4v,--r--// i
1�lArs �Klt-r" �r TF(� ti` t i /f cP p 1—( -C 4 r� a .._.
fur T�� �� c 47DvZs&0
So Tfl� Wi tc- ��✓c Ty �
1 of 1 8/19/02 11:11 AM

KID)E;NR.WATER
E EftTheSeptember 30, 2002 3 0 p00ZWootenMr. J. William Reid, Supervisor QUALITYCompany Point Source Branch SOURCEISRANCH
N.C. Division of Water Quality/NPDES Unit
1617 Mail Service Center
Engineering Raleigh, North Carolina 27699-1617
Planning Re: Permit Renewal/Modification Request
Architecture Clayton - Little Creek WRF
NPDES Permit No. NC 0025453
Wake County
Return # 2159
Dear Mr. Reid:
Reference is made to your June 10, 2002 letter concerning the Division's
determination of incomplete permit application due to a lack of certain items and
120 N. Boylan avenue return of the application to the Town of Clayton. As suggested in the letter, we are
Raleigh, NC reapplying this permit application for renewal and expansion of the plant capacity to
2�s03 2.5 mgd by submitting the following items:
1. A check in the amount of $860.00 for the permit modification fee.
2. Three (3) copies of September 30, 2002 letter to Mr. Reid addressing items
listed in Mr. Reid's June 10, 2002 letter to complete the application.
919-828-0531
Fax [phone]. Three (3) copies of the returned NPDES Permit Application for a Capacity
Expansion from 1.9 MGD to 2.5 MOD.
4. Three (3) copies of the Sludge Management Plan required for Permit
renewal/modification application.
5. Toxicity test for an organism other than Ceriodephnia is underway and the
test results will be submitted upon receiving from the laboratory
conducting the test.
We appreciate your assistance provided in this matter. Should you have any questions
or need additional information concerning this matter, please call me at (919) 828-
0531.
Sincerely,
THE WOOTEN COMPANY
4z),•nta.r (t• MiSiYy
Shankar R. Mistry, Ph.D., P.E.
c: Ms. Susan A. Wilson, Point Source Branch, DWQ
Since 1936 Mr. Steve Biggs, Manager, Town of Clayton
Mr. Tim Simpson, Director of Public Works
Mr. James Warren, Superintendent of LCWRF

he September 30 2002
WoToten
Dear Mr. Reid:
Mr. J. William Reid, Supervisor
Company
Point Source Branch
N.C. Division of Water Quality/NPDES Unit
1617 Mail Service Center
Engineering
Raleigh, North Carolina 27699-1617
Planning
Re: Permit Modification Request
Architecture
Clayton -Little Creek WRF
NPDES Permit No. NC 0025453
Wake County
Return # 2159
Reference is made to your June 10, 2002 letter concerning the Division's
determination of incomplete permit application due to a lack of certain items and
120 N. Boylan Avenue return of the application to the Town of Clayton. The items required to complete the
Raleigh, NC application package are addressed as follows:
27603
1. Incomplete fee. A stated correctly in your application document (Part 5.6
of the Analysis of Alternatives), nutrient off -set costs must be paid at the
time of application [ref. Temporary Rule, adopted February 2000, 2B
.0234 (8) (c)]. Because the Neuse Compliance Association has not yet
919-828-0531 been formed, the Division cannot accept the Town's application without
Fax: [phone] the off -set cost of approximately $3.5 million. The Division will accept the
application again with the appropriate fee and off -set cost or with
confirmation of the formation of the Compliance Association along with
the Town's commitment to join, or with confirmation that the Town has
purchased additional nitrogen allocation from another point source within
the lower basin.
The Town of Clayton has selected the option of joining the LNBA
Compliance Association. The Compliance Association has been formed.
See the attached letter from the LNBA Association. The Town of Clayton
is committed to join the Association and a copy of the Town's Resolution
to Join the Neuse River Compliance Association is attached herewith.
2. Alternative Analyses. As required by the Division's Antidegradation Policy,
alternatives to discharge must be thoroughly documented. A brief review of
the alternatives indicate that, although several alternatives are
documented, the Town will also need to document the feasibility of land
application of the expanded flow (0.6 MGD), as well as the entire flow (it
appears that land application of the entire flow has been documented). In
addition, documentation of the cost and feasibility of the expanded flow
Since 1936 (or any greater amount of flow) transferred to Central Johnston County
should be provided with the alternatives analysis (some of the projected
costs listed in Exhibit 4 should be clarified). Central Johnston County is
well underway to an expansion and may be able to accommodate the
Town's expanded flow; this may allow the Town a temporary solution until
planning for the 20-year projected flow is completed.

The alternatives to discharge considering land application of the expanded flow of 0.6
MGD as well as for the entire flow of 2.5 MGD were evaluated and determined to be
infeasible in terms of cost-effectiveness. Refer to the attached evaluation of the
alternative, including detailed cost breakdown.
With cooperation of Johnston County's official, the Town of Clayton has recently
purchased 75,000 gpd capacity in the Johnston County Wastewater Treatment Plant
and the Town has reserved the right to purchase an additional 175,000 gpd at a future
date after expansion of the Johnston County Wastewater Treatment Plant is completed.
It should be noted that the planned Johnston County Regional WWTP expansion
includes a maximum of 250,000 gpd for the Town of Clayton. The above 75,000 gpd
and 175,000 gpd purchases are part of the 250,000 gpd that is planned in the Johnson
County Regional WWTP expansion.
3. Permit Application. Please clarify Part B.S. of the permit application to state that
certain improvements were approved with the Authorization to Construct permit issued
May 24, 2001, but that approval did not evaluate the plant to comply with a flow of
2.5 MGD. The Town of Clayton will still be required to provide calculations to ensure
that the expansion will comply with the limits given for the expansion to 2.5 MGD.
Also, parts of the document refer to future limits of 5 mg/1 BODs and 2 mg/1 NH3-N -
this is incorrect. All references to limits upon expansion should indicate S mg/1 BOD5
and 1 mg/L NH3-N (summer); 10 mg/L BOD5, and 2 mg/ 1 NH3-N (winter).
The improvements approved with the Authorization to Construct Permit, issued May
24, 2001 were intended to comply with design flow of 2.5 mgd. It is noticed that the
parts of the document refer to a future limit of 5 mg/L BOD5 and 2.0 mg/L NH3-N
which is incorrect. All references to limits upon expansion have been revised to
indicate 5 mg/L BODs and 1 mg/L NH3-N for summer months and 10 mg/L BOD5 and
2 mg/L NH3-N for winter months. It should be noted that some of the BOD5 and NH3-
N limits referred to in the document were for the wastewater treatment and disposal
alternatives considered in 1993 Amended 201 Facilities Plan. The calculations to
assure that the expansion will comply with the limits (5 mg/L BOD5 and 1 mg/L NH3-
N) given for expansion to 2.5 mgd are attached herewith.
We appreciate your assistance provided in this matter. Should you have any questions or need
additional information concerning this matter, please call me at [phone].
Sincerely,
THE WOOTEN COMPANY
•.��«.► R. M164j
Shankar R. Mistry, Ph.D., P.E.
c: Ms. Susan A. Wilson, Point Source Branch, DWQ
Mr. Steve Biggs, Manager, Town of Clayton

Lower Neuse Basin Association, Inc.
Raleigh, North Carolina
September 27, 2002
J. William Reid, Supervisor
Point Source Branch
Division of Water Quality
NC Dept. of Environment and Natural Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: Town of Clayton — Membership in the Neuse River Compliance Association
Dear Mr. Reid:
This letter is being sent at the request at the Town of Clayton in response to your
letter of June 10, 2002 concerning their application for a modification of NPDES Permit
No. NC0025453. Articles of Incorporation forming the Neuse River Compliance
Association (the "Association") have been filed, establishing the Association as a
nonprofit corporation. Furthermore, the Town of Clayton has submitted the required
resolution of intent to join the Association in a form acceptable to the Association. The
final Association membership roster and operational parameters will be completed upon
approval of the operational agreement by the Division of Water Quality and
Environmental Management Commission.
If you have any questions regarding this matter, don't hesitate to contact me at
[phone].
Sincerely,
Timothy L. Donnelly, PE
Chairman
Lower Neuse Basin Association
And Neuse River Compliance Association
Cc: Town of Clayton
The Wooten Co.
P. O. Box 590 Raleigh, North Carolina 27602
[phone]

0.8/13/2002 14:27 9195531918 TOWNOFCLAYTO:N PAGE 02
Town of Clayton
Resolution to Join the Neuse River
Compliance Association
WHEREAS, the Lower Neuse Basin Association (LNBA Formerly the Neuse Basin
Association was created in 1994 to establish a formal, volunta y'agreement between itself and
the North Carolina Division of Water Quality (DWQ), by which the LNBA is responsible for
surface water monitoring, reporting, and other cooperative efforts by NPDES dischargers within
the Lower Neuse River Basin to obtain water quality information in the basin.
' AND WHERBAS, in addition to such ongoing coopbrative surface water monitoring
activity and other joint efforts, the LNBA and DWQ jointly support other additional strategies to
ensure overall Total Nitrogen reduction at the mouth of the Neuse River in the Pamlico Sound as
required by the wastewater discharge requirements of the Neuse River Basin Nutrient Sensitive
Waters Management Strategy.
AND WHEREAS, the formation of another body, the Neuse River Compliance
,Association (Association) is necessary to obtain a group NPDES permit for Total Nitrogen, as an
alternative framework in which interested point source dischargers in the lower Neuse River
Basin can work cooperatively to reduce their individual and collective discharge of that riutrient
pollutant and comply with applicable limits. '
THEREFORE, the Town of Clayton agrees with the overall intent of the cooperative
arrangements set out in the By -Laws of the Neuse River Compliance Association and, at this
time, intends to join the Association and to p ' ipate according to said By -Laws.
e-
Douglas cCorrnac
Attest:
keli Reed
Town Cleric
Mayor
RALF-)OW015017-001/337231 Y.l

EVALUATION OF EXPANDED 2.5 MGD PLANT
FOR
COMPLIANCE WITH THE EFFLUENT LIMIT OF 5.0 mg/L BODs
AND 1.0 mg/L NH3-N
1.0 EVALUATION OF THE OXIDATION DITCH SYSTEM FOR BODs REMOVAL
AND NITRIFICATION
1. Design Considerations
Average daily flow = 2.5 mgd (Influent flow to 0.75 MG ditch = 0.987 mgd and
Influent flow to 1.15 MG ditch =1.513 mgd)
BODs: Influent = 230 mg/L; Effluent = 5.0 mg/L
TSS: Influent = 230 mg/L; Effluent = 10.0 mg/L
TKN: Influent = 35 mg/L; Effluent = 3.0 mg/L
N113-N: Influent = 25 mg/L; Effluent = 1.0 mg/L
NO3-N: Influent = 0 mg/L; Effluent = 2.0 mg/L
Temperature: Winter = 12° C; Summer = 280 C
Operating MLSS Concentration = 4,000 mg/L
Sludge retention time = 16 days
Net Sludge Yield, Yn, lb solids/lb BODs removed = 0.78
Oxygen Requirements, lb 02/lb BOD removed = 1.5
lb 021lb NH3-N removed = 4.6
2. Required Oxidation Ditch Volume
The required oxidation ditch volume is determined using the following equation:
BODE x Yn x SRT
Volume, mil. gal. = MLSS x 8.34
Where BODR = (230 - 5) mg/L BOD5 x 8.34 x 2.5 mgd
4691 lb B OD/day
Yn = Net sludge yield = 0.78 lb solids/lb BODR
SRT = Sludge retention time required for complete nitrification = 16
days
MLSS = Operating mixed liquor suspended solids concentration
= 4,000 mg/L
-1 -

Volume, mil. gal. _
4691 x 0.78 x 16
4000 x 8.34
= 1.755 mil. gallon
The available volume in the existing carrousel oxidation ditches = 0.75 MG + 1.15 MG =
1.90 MG which is more than adequate for the required ditch volume of 1.755 MG.
3 Aeration Requirement for 0.75 MG Carrousel Ditch
a. Oxygen Requirements for BOD5 Removal
Considering influent flow to 0.75 MG ditch = 0.987 mgd, influent BOD5 = 230 mg/L,
effluent BOD5 = 5.0 mg/L and oxygen requirement for BOD5 = 1.5 lb 02/lb BOD5
removed, the total oxygen requirement for BOD5 removal is:
= (230-5) mg/L BOD5 x 8.34 x 0.987 mgd x 1.5 = 2778 lb 02/day
b. Oxygen Requirement for Nitrification (NH3-N Removal)
Considering influent flow to 0.75 MG ditch = 0.987 mgd, 5 mg/L nitrogen
requirement for each 100 mg/L BOD5 for cell synthesis, influent TKN = 35 mg/L,
effluent NH3-N =1.0 mg/L and oxygen requirement for nitrification = 4.6 lb 02/NH3-
N nitrified, the total oxygen requirement for nitrification is:
= 35 — (230 x 5 )—llmg/LNH 3 — N x 8.34 x 0.987 mgd x 4.6
100
= 852 lb 02/day
c. Total Oxygen Requirement
= 2778 + 852
= 3630 lb 02/day
= 151.25 lb 02/hr.
d. Aeration Horsepower Requirement
The total required horsepower for the platform mounted mechanical aeration is
estimated as follows:
C
S OR = AOR S
`R C — C e A T-20 x a
` sw o
Where: AOR = Actual oxygen requirement = 151.25 lb OZ/hr
SOR = Oxygen transfer rate, lb 02/hr at standard conditions = 3.5 lb
02/hp/hr
-2 -

Cs = Oxygen saturation value of clean water at standard conditions = 9.092
mg/L
(3 = Ratio of oxygen saturation value of waste to that of clean water = 0.95
Csw = Oxygen Saturation value of clean water for the site conditions of
Temperature = 28° C and actual barometric pressure (Pa = 14.575 psia) _
7.76 mg/L.
Co = Residual concentration of dissolved oxygen desired during normal
operation = 2.0 mg/L.
a = Ratio of oxygen transfer in waste to that of clean water at the same
temperature = 0.8
T = Design temperature = 28° C
9 = Temperature correction constant = 1.024
SOR = 151.25 9.092
(0.95 x 7.76 - 2.0) (1.024)28-20 x 0.8
_ 1375
5.195
= 264.7 lb 02/hr
Considering 3.5 lb 02/hp/hr standard oxygen transfer rate of the EIMCO platform
mounted aerator, the required horsepower is:
_ 264.7 lb 02 / hr
3.5 lb 02 / hr / hp
= 75.63 hp
The existing 0.75 MG ditch is equipped with one (1) - 25 hp aerator and one (1) -50
hp aerator. This will provide the total aeration horsepower of 75 hp. The required
aeration horsepower without the denitrification oxygen credit is 75.63 hp. In the
oxidation ditch some denitrification will occur that should supplement the oxygen need
for BODs removal. Accordingly, the current aeration capacity should be adequate to
handle the expanded 2.5 mgd flow.
4. Aeration Requirement for 1.15 MG Carrousel Ditch
a. Oxygen Requirements for BODs Removal
Considering influent flow to 1.15 MG ditch = 1.513 mgd, influent BODs = 230 mg/L,
effluent BODs = 5.0 mg/L and oxygen requirement for BODs = 1.5 lb 02/1b BODs
removed, the total oxygen requirement for BOD5 removal is:
= (230-5) mg/L BOD5 x 8.34 x 1.513 mgd x 1.5 = 4258 lb 02/day
b. Oxygen Requirement for Nitrification (NH3-N Removal)
Considering influent flow to 1.15 MG ditch = 1.513 mgd, 5 mg/L nitrogen
requirement for each 100 mg/L BODs for cell synthesis, influent TKN = 35 mg/L,
effluent NH3-N =1.0 mg/L and oxygen requirement for nitrification = 4.6 lb 02/NH3-
N nitrified, the total oxygen requirement for nitrification is:
-3 -

= [35 — 230 x 100 5 —1 mg / L NH 3 — N x 8.34 x 1.513 mgd x 4.6
= 1306 lb 02/day
c. Total Oxygen Requirement
= 4258 + 1306
= 5564 lb 02/day
= 231.8 lb 02/hr.
d. Aeration Horsepower Requirement
The total required horsepower for the platform mounted mechanical aeration is
estimated as follows:
SOR = AOR S
(R C SW -- Co) eT-20 x a
Where: AOR = Actual oxygen requirement = 231.8 lb 02/hr
SOR = Oxygen transfer rate, lb 02/hr at standard conditions = 3.5 lb 02/hp/hr
Cs = Oxygen saturation value of clean water at standard conditions = 9.092 mg/L
(3 = Ratio of oxygen saturation value of waste to that of clean water = 0.95
Csw = Oxygen Saturation value of clean water for the site conditions of Temperature
= 28° C and actual barometric pressure (Pa = 14.575 psia) = 7.76 mg/L.
Co = Residual concentration of dissolved oxygen desired during normal operation
= 2.0 mg/L.
a = Ratio of oxygen transfer in waste to that of clean water at the s a m e
temperature = 0.8
T = Design temperature = 28° C
9 = Temperature correction constant = 1.024
SOR = 231.8 9'(
(0.95 x 7.76 — 2.0)
_ 2107.5
5.195
= 405.68 lb 02/hr
►2 1
(1.024)28-20 x 0.8 j
Considering 3.5 lb 02/hr/hp standard oxygen transfer rate of the EIMCO platform
mounted aerator, the required horsepower is:
_ 405.68 lb 02 / hr
3.5 lb 02 / hp / hr
= 115.9 hp
116 hp
The existing 1.15 MG ditch is equipped with one (1) - 50 hp aerators and one 75 hp
aerator. This will provide the total aeration horsepower of 125 hp. The required
M

aeration horsepower without the denitrification oxygen credit is 116 hp. Accordingly,
the current aeration capacity should be adequate to handle the expanded 2.5 mgd flow.
Me

ALTERNATIVE EVALUATION
FOR
CLAYTON LCWRF EXPANSION TO 2.5 MGD
1.0 ALTERNATIVE EVALUATION
The following alternatives which consider treatment and discharge of effluent to
Neuse River and treatment and disposal of effluent by land application, have been
evaluated to provide the most cost-effective solution to expand the Clayton LCWRF to
2.5 MGD.
1.1 ALTERNATIVE NO. 1
This alternative considers: (1) upgrading and expansion of the Clayton LCWRF
to 2.5 mgd and discharge of effluent into Neuse River, (2) the Town of Clayton joining
the Neuse River Compliance Association; (3) divert up to 600,000 gpd flow, as
necessary, from the east Clayton industrial area to the Central Johnston County
Regional Wastewater Treatment Plant; and (4) purchase additional 75,000 gpd capacity
in the Central Johnston County VW11TP. A detailed description and cost analysis of this
alternative are given as follows.
1.1.1 Description
A. Clayton LCWRF Improvements
The Clayton LCWRF improvement project for upgrading and expansion to 2.5
mgd includes the following:
1. Replacement of the three existing extended shaft centrifugal pumps
with submersible centrifugal pumps, each rated at 2,170 gpm.
Provide variable frequency drive for two of the pumps.
2. Improvements to the oxidation ditches aeration capacities by: (1)
replacement of one of the 25 hp aerators in 0.75 MG oxidation ditch
with a 50 hp aerator, (2) replacement of one of the 50 hp aerators in
-1-

the 1.15 MG ditch with a 75 hp aerator, and (3) replacement of the
existing effluent weirs with adjustable weirs to control the oxygen input
in the oxidation ditches.
3. Improvements to the existing clarifier splitter box by the addition of
weir gates to allow control of flow split to each clarifier.
4. Provide one (1) 65 ft. diam. x 14 ft. SWD secondary clarifier equipped
with a sludge removal mechanism, effluent weir, scum removal,
Stamford baffle, influent dispersion well and influent feed well. The
existing plant has one (1) 55 ft. diam. x 12 ft. SWD and one (1) 65 ft.
diam. x 14 ft. SWD clarifier. The design surface overflow rate using all
three clarifiers in service is estimated to be 278 gpd/sq. ft. The design
surface overflow rate using one larger clarifier out of service is
estimated to be 440 gpd/sq. ft.
It should be noted that the Authorization to Construct Permit for the above
improvements was issued by NCDENR on May 24, 2001 and the construction of the
subject improvements have already been completed in June 2002.
B. Join the Neuse River Compliance Association
As per paragraph (9) of the Nutrient Sensitive Water Management Strategy rule
0.0214 the Town of Clayton can use the option to join a group compliance association
to collectively meet nutrient load allocations. Articles of Incorporation forming the Neuse
River Compliance Association (the "Association") have been filed, establishing the
Association as a non-profit corporation. The Town has submitted the required resolution
of intent to join the Association in a form acceptable to the Association. See attached
copy of the letter from the Association confirming the formation of Association. A copy of
the Town's resolution of intent to join the Association is also attached.
-2-

C. Divert Flow to Johnston County Regional WWTP
The Town of Clayton has an agreement with Johnston County to divert up to
600,000 gpd from the east Clayton industrial area to the Johnston County Regional
Wastewater Treatment Plant. The agreement is on the flow exchange basis, i.e., the
Town can divert flow equivalent to the wastewater flow the Town is receiving from the
Johnston County service area. However, the Town of Clayton and Johnston County
understand the wastewater needs for each other and will work together to maximize
diversion of flow to the Johnston County Regional WWTP.
D. Capacity Purchase from Johnston County Regional WWTP
The Town of Clayton has entered into an agreement with Johnston County to
purchase 75,000 gpd capacity allocation in the Central Johnston County Regional
Wastewater Treatment Plant (CJRWWTP). As per the agreement, the Town has also
reserved the right to purchase an additional 175,000 gpd capacity in the CJRWWTP at
a future date after expansion of the Johnston County WWTP is completed. As a part of
design the expanded CJRWWTP has only 250,000 gpd capacity allocation for the Town
of Clayton. The above 75,000 gpd capacity purchase to accommodate the current
ongoing growth in the Clayton area is a part of the 250,000 gpd reserve capacity for
Clayton in the CJRWWTP.
1.1.2 Construction Cost Opinion
A. Clayton LCWRF Improvements
Influent pump station and modification $ 281,208.00
Aeration basin renovations 206,119.00
New 65 ft. diameter clarifier 543,332.00
Soils and concrete testing 5,000.00
-3-

Total Construction Cost (A)
$
1,035,659.00
Contingencies (5%)
51,783.00
Engineering
78,558.00
Construction administration and inspection
63,000.00
Total Project Cost (A)
$
1,229,000.00
B. Join Neuse River Compliance Association
Association Membership
$
0.00
Total Project Cost (B)
$
0.00
C. Divert Flow to Johnston County Regional WWTP
Flow diversion capital improvements (existing)
$
0.00
Total Project Cost (C)
$
0.00
D. Capacity Purchase from Johnston County Regional WWTP
Capacity purchase cost for 75,000 gpd
$
4329000.00
Total Project Cost (D)
$
432,000.00
TOTAL PROJECT COST (A+B+C+D)
$
1,661,000.00
1.1.3 Annual Operation and Maintenance Costs
Salaries, including fringe benefits
Utilities: Electric
Telephone
Chemicals: Alum
Caustic
Polymer
Maintenance and Repairs
Contracted Services:
Laboratory testing
Pretreatment
Sludge disposal
Continuing education and training
Permit fees and dues
Departmental supplies
Wastewater transmission cost
200,000.00
226, 000.00
2,500.00
1,500.00
1,000.00
20,000.00
50,000.00
20, 000.00
10,000.00
30,000.00
2,500.00
7,500.00
9,000.00
51,000.00
-4-

Insurance and Bonds 59000.00
Capital Outlay 40,000.00
Total Annual Operation and Maintenance Cost $ 676,000.00
1.1.4 Estimated Salvage Value
Treatment Work: 1- 20 x $1,035,659.00 $ 345,000.00
30
Total Estimated Salvage Value $ 345,000.00
1.1.5 Economic Analysis
A. Basic Considerations
a. Planning period: 20 years
b. Capital cost of the project: $1,661,000.00
c. Annual O&M costs: $676,000.00
d. Salvage value at the end of 20 years: $345,000.00
e. Interest rate: 7.125 percent
f. Single Payment Present Worth Factor @ 7.125% for 20 years: 0.25245
g. Uniform Series PWF @ 7.125% for 20 years: 10.4918
h. Capital Recovery Factor @ 7.125 for 20 years: 0.09531
B. Present Worth Cost
a. Initial Capital Cost $ 1,661,000.00
b. Present Worth of Annual O&M Costs
$676,000 x 10.4918 7,092,500.00
c. Present Worth of Salvage Value
$345,000 x 0.25245 87,000.00
Net Present Worth Cost (a + b - c) $ 8,666,500.00
C. Annual Equivalent Cost
$8,666,500.00 x 0.99531 $ 826,000.00
-5-

Ox. Basin No. 2 (1.15 MG)
O
O
D.B.
D.B. P.S.�—
Pump Station
Alum Feed —A
Polymer Feed —P-/
Magnesium
Clarifier
Hydroxide
I
( No.1
Grit Removal Feed or
( O
Sodium
Hydroxide
I
I
I
Mechanical
I
I O I
Screen
( I
l
Ox. Basin No. 1 (0.75 MG) �— Sludge Recirc. I P.S.
Influent
L — — — — I
Scum Waste to —
_�
Aerobic Digester -------L---_ _—
Waste Sludge to Sludge Recirc./Waste
Thickener /
Legend
Aerobic Digester UV Disinf /
Chlorination -
Wastewater / Effluent
Dechlorination
- — — — Sludge
-- -- — Scum
—m-- Magnesium Hydroxide Feed
A— Alum Feed
Polymer Feed
P.S. Pump Station
Exhibit 1
D.B. Distribution Box
Schematic Flow Diagram of Alternative 1
Clayton LCWRF Upgrading and Expansion to 2.5 mgd
Clarifier
No. 3
i
P.S. ,
Scum
Clarifier
No. No. 2
'I
�I
I
�I I
'I
P.S."�,-Drain
— I
Tertiary
Filters
2.5 mgd to Neuse River
Eff. Pump Sta.

1.2 Alternative No. 2
The alternative considers discharging 0.6 mgd of effluent flow by land application
and the remaining 1.9 mgd to the Neuse River for expansion of the Clayton LCWRF to
2.5 mgd. This alternative also considers: (1) the Town of Clayton joining the Neuse
River Compliance Association, (2) diverting up to 600,000 gpd flow, as necessary, from
the east Clayton industrial area to the Central Johnston County Regional WWTP, and
(3) purchase an additional 75,000 gpd capacity in the Central Johnston County WVVfP.
A detailed description and cost analysis of this alternative are given as follows:
1.2.1 Description
1. Use the existing LCWRF, with the upgrading and expansion to 2.5
mgd improvements stated in Alternative No. 1, as pre -application
treatment system for discharge of 0.6 mgd effluent by land application
and the remaining 1.9 mgd effluent to the Neuse River.
2. Join the Neuse River Compliance Association
3. Divert up to 600,000 gpd flow from the east Clayton industrial area to
the Johnston County Regional Wastewater Treatment Plant as per the
terms and conditions of the agreement.
4. Purchase 75,000 gpd additional capacity in the Johnston County
Regional WWfP.
5. Provide an effluent transport system to convey the preapplication
treatment system effluent to the effluent storage lagoon at the
proposed land application site. The effluent transport system will
consist of providing an effluent pump station equipped with two 60 hp
pumps, each rated at 1,050 gpm, and 37,000 lineal feet of 12-inch
diameter ductile iron force main.
6. Provide a 36 million gallon effluent storage lagoon for storage of
effluent when land application of effluent cannot take place due to
-7-

inclement weather conditions, saturated soils and higher groundwater
conditions, cover crop harvesting and site management.
7. Provide a chlorination system for disinfection of effluent prior to land
application.
8. Provide a spray irrigation pump station equipped with three (3) —1200
gpm pumps, including one standby, with necessary controls and
piping. Provide an automatic strainer on the spray header piping to
remove solids for efficient operation of the spray irrigation system.
9. Provide header piping and solid -set type spray irrigation system for
land application of effluent. The average hydraulic application rate will
be approximately 0.75 inch/wk and area requirement for spray
irrigation of 0.6 mgd flow is estimated to be approximately 206 acres.
10. Provide monitoring wells for measurement of groundwater table and
sampling of groundwater compliance with the water quality
parameters included in the nondischarge permit.
11. Provide access roads for management and operation of the land
application system. Provide fencing for the effluent storage lagoon
and land application site to comply with the State regulatory
requirements.
12. Provide an operation and control building and a storage and
maintenance building.
1.2.2 Construction Cost Opinion
A. Clayton LCWRF Improvements
Influent pump station and modification $ 281,208.00
Aeration basin renovations 206,119.00
New 65 ft. diameter clarifier 543,332.00
Soils and concrete testing 5,000.00
Total Construction Cost (A) $ 1,035,659.00
Contingencies (5%) 51,783.00
Engineering 78,558.00
Construction administration and inspection 63,000.00

Total Project Cost (A)
$ 1,229,000.00
B. Join Neuse River Compliance Association
Association Membership
$ 0.00
Total Project Cost (B)
$ 0.00
C. Divert Flow to Johnston County Regional WWTP
Flow diversion capital improvements (existing)
$ 0.00
Total Project Cost (C)
$ 0.00
D. Capacity Purchase from Johnston County Regional WWTP
Capacity purchase cost for 75,000 gpd
$ 432,000.00
Total Project Cost (D)
$ 432,000.00
E. Land Application of 0.6 MGD Effluent Flow
Effluent Transport System for Land Application
Effluent pump station $ 150,000.00
37,000 LF of 12-inch D.I. forcemain 960,000.00
Sitework and piping 25,000.00
Electrical 20,000.00
Sub Total (Effluent Transport System) $ 1,155,000.00
Land Application System
36 mil. gal. effluent storage lagoon
$ 850,000.00
Spray irrigation pump station
250,000.00
Chlorination system
45,000.00
Spray irrigation system, including header piping
1,133,000.00
Sitework and piping
1709000.00
Site preparation, liming and seeding
103,000.00
Fencing and access roads
160,000.00
Monitoring wells
10,000.00
Electrical and instrumentation
40,000.00
Operation and control building
60,000.00
Storage and maintenance building
40,000.00
Sub Total (Land Application System)
$ 2,861,000.00
In

Total Construction Cost (E)
$ 4,016,000.00
Contingencies
401,600.00
Engineering and Construction Administration
4129400.00
Geotechnical Work
10,000.00
Site evaluation by soil scientist
25,000.00
Legal and administrative
35,000.00
State Construction loan fee (3%)
218,000.00
Start-up Services
15,000.00
Operation and Maintenance Manual
19,000.00
Land, 270 acres @ $5,000/ac.
$ 1.350.000.00
Total Project Cost (E)
$ 6,5029000.00
TOTAL PROJECT COST (A+B+C+D+E)
$ 8,163,000.00
1.2.3 Annual Operation and Maintenance Manual (for 2.5 mgd plant)
Salaries, including fringe benefits $ 2320000.00
Utilities: Electric 286,000.00
Telephone 2,500.00
Chemicals: Alum
1,500.00
Caustic
19000.00
Polymer
20,000.00
Chlorine
2,000.00
Maintenance and Repairs
60,000.00
Contracted Services: Laboratory testing
259000.00
Pretreatment
10,000.00
Sludge disposal
30,000.00
Continuing education and training
2,500.00
Permit fees and dues
8,000.00
Departmental supplies
9,000.00
Wastewater transmission cost
51,000.00
Insurance and Bonds
5,000.00
Capital Outlay
45,000.00
-10-

Total Annual Operation and Maintenance Cost $ 793,000.00
1.2.4 Estimated Salvage Value
Treatment Work: 1- 20 x($1,035,659+$4,016,000-$960,000) $ 1,367,000.00
30
Forcemain: $960,000 x 0.5 $ 480,000.00
Land: $1,350,000 x 1.80611 $ 2,438,000.00
Total Estimated Salvage Value $ 4,285,000.00
1.2.5 Economic Analysis
A. Basic Considerations
a. Planning period: 20 years
b. Capital cost of the project: $8,163,000.00
c. Annual O&M costs: $793,000.00
d. Salvage value at the end of 20 years: $4,285,000.00
e. Interest rate: 7.125 percent
f. Single Payment Present Worth Factor @ 7.125% for 20 years:
0.25245
g. Uniform Series PWF @ 7.125% for 20 years: 10.4918
h. Capital Recovery Factor @ 7.125 for 20 years: 0.09531
i. Land appreciation factor (EPA): 1.80611
B. Present Worth Cost
a. Initial Capital Cost $ 8,163,000.00
b. Present Worth of Annual O&M Costs
$793,000 x 10.4918 8,320,000.00
c. Present Worth of Salvage Value
$4,285,000.00 x 0.25245 1,082,000.00
Net Present Worth Cost (a + b - c) $ 15,410,000.00
C. Annual Equivalent Cost
$15,410, 000.00 x 0.09531 $ 1,468, 000.00
-11-

Ox. Basin No. 2 (1.15 MG)
O
O
D.B.
D.B. P.S. /�- �-
Pump Station
Alum Feed -A
Polymer Feed -P-/
Magnesium
Clarifier
Hydroxide
I
( No.1
Grit Removal
Feed or
I O
Sodium
Hydroxide
I
I
Mechanical
I I
( O I
Screen
I I
I
L Ox. Basin No.1 (0.75 MG) �- Sludge Recirc. I P.S.
I
Influent
_ _ _ -
----------A`----"-'---
Scum Waste to
Aerobic Digester �- -------1---- --�
Sludge Recirc./Waste
Waste Sludge to
Thickener /
Aerobic Digester UV Disinf /
Chlorination -
Legend
Dechlorination
Wastewater / Effluent
- - - - Sludge
-- -- - Scum
—m— Magnesium Hydroxide Feed
Eff. Pump Sta.
A— Alum Feed
Polymer Feed
Exhibit 2
P.S. Pump Station
Schematic Flow Diagram of Alternative 2
D.B. Distribution Box
Clayton LCWRF Upgrading and Expansion to 2.5 mgd
---10- P.SP X
Scum
Clarifier
No. 2-
Clarifier
No. 3
Tertiary
Filters
1.8 mgd to Neuse River
Eff. Pump Sta.
0.6 mgd to Effluent Storage
Lagoon at Land Application
Site

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PO tau . \ `� v \� l -.�,� l•.r.
-/ \ t'`4-'•"----1`.�=t ,:; - --i___ t A� ,. • • `�Llf
305 acre Land Application Site
pr
36 mgal Storage Lagoon
•`•• - `ter- ) . j
/ i • (? .B , • S • ° '� � , �\ r.� \ �. niL-R e M 258 C _J
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Exhibit 3
Effluent Transport from Clayton WWTP to Proposed Land Application Site
Maps: USGS Clayton & Powhatan, North Carolina

1.3 Alternative No. 3
This alternative considers land application of entire 2.5 mgd flow and elimination
of the discharge to the Neuse River for expansion of the plant to 2.5 mgd. However, this
alternative was eliminated from further considerations due to the following reasons: (1)
Alternative No. 2 which considers discharging 0.6 mgd of effluent flow by land
application and remaining 1.9 mgd to the Neuse River for expansion of the plant to 2.5
mgd indicates that land application of effluent is not cost-effective, (2) at an average
hydraulic loading rate of 0.75 inc/wk, the wetted area required for land application of 2.5
mgd flow is 860 acres. Allowing area requirements for buffers, access roads, effluent
storage lagoon, and uneconomic remnant, it is estimated that the total area required for
the land application system would be approximately 1,200 acres; (3) difficulty of
acquiring land parcel(s) in close proximity needed for land application of wastewater; (4)
environmental concerns associated with transport of effluent to land application site(s)
and use of potential site(s) for land application of the effluent; and (5) significant cost
associated with the alternative.
-14-

Little Creek Water Reclamation Facility
NPDES Permit No. NCO025453
Town of Clayton, North Carolina
Sludge Management Plan
Biosolids Preparation:
Waste Activated Sludge (WAS) from the secondary clarifiers is thickened in an existing rotary
drum thickener and then transferred to the existing 90,000 gallon and 300,000 gallon aerobic
stabilization / storage tanks. The underflow from the sludge thickener is returned to the oxidation
ditches. Once stabilized, the sludge is hauled away by a contractor for off -site disposal. Decants
from the sludge stabilization / storage tanks are recycled back to the WAS pump station.
Biosolids generated by the LCWRF are prepared to meet Class B pathogen requirements
through Alternative 1 [40 CFR 503.32(b)(2)] and Alternative 2 [40 CFR 503.32(b)(3)].
Alternative 1 requires that the geometric mean of fecal coliform density, in seven samples of treated
sewage sludge, not exceed 2 million Colony Forming Units (CFU) or Most Probable Number
(MPN) per gram of sewage sludge solids. Alternative 2 requires that the sludge be treated in a
process to significantly reduce pathogens. The process currently employed by the LCWRF is
aerobic digestion. The vector attraction reduction requirements are satisfied by the sludge hauler(s),
not by the LCWRF, prior to disposal as discussed below.
Biosolids Disposal:
Biosolids generated by the LCWRF are disposed of off -site by a contract hauler. East Coast
Resources, operating under Non -Discharge Permit No. WQ0000506, is the primary hauler and
Granville Farms, operating under Non -Discharge Permit No. WQ0004801, is a backup hauler.
Both sludge haulers require that the Town prepare the biosolids to meet Class B pathogen
requirements, as discussed above, prior to removal from the LCWRF. East Coast Resources and
Granville Farms meet the vector attraction reduction requirements by employing Option 9 [40 CFR
503.33(b)(9)] and/or Option 10 [40 CFR 503.33(b)(10)]. Option 9 requires injection of the
sewage sludge below the land surface. Option 10 requires that the sewage sludge applied to the
disposal site be incorporated into the soil within 6 hours after application.
A third hauler, McGill Environmental, operating under Non -Discharge Permit No.
WQ0006816, does not require the Town to meet the Class B requirements prior to removing
sludge from the LCWRF. McGill Environmental dewaters the sludge at the plant then hauls the
sludge to their composting facilities for further processing to meet Class A pathogen and vector
attraction reduction requirements prior to disposal. The pathogen reduction requirement is met
through Alternative 1 [40 CFR 503.32(a)(3)-(8)], monitoring of fecal coliform, and/or Alternative
5 [40 CFR 503.32(a)(7)], composting PFRP. The vector attraction reduction requirement is met
utilizing Option 5 [40 CFR 503.33(b)(5)]. Option 5 requires the sewage sludge to be aerobically
treated for at least 14 days at over 40° C with an average temperature over 45' C.

of WATER
,ot QG �►�
r NCDENR
0
Mr. Steve Biggs
Town of Clayton
P.O. Box 879
Clayton, North Carolina 27520
Dear Mr. Biggs:
Michael F. Easley
Governor
William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
June 102 2002
Subject Return of permit modification request
Clayton — Little River WRF
NPDES No. NC0025453
Wake County
Return #2159
In accordance with Division policy, we must hereby return the enclosed permit application and fee
check of $860.00 (paid by check #31825). After a preliminary review, the Division has determined that the
application is incomplete. The application package lacks the following items:
➢ Incomplete fee. As stated correctly in your application document (Part 5.6 of the Analysis of
Alternatives), nutrient off -set costs must be paid at the time of application [ref. Temporary Rule,
adopted February 2000, 2B .0234 (8)(c)]. Because the Neuse Compliance Association has not yet
been formed, the Division cannot accept the Town's application without the off -set cost of
approximately $3.5 million. The Division will accept the application again with the appropriate
fee and off -set cost or with confirmation of the formation of the Compliance Association, along
with the Town's commitment to join, or with confirmation that the Town has purchased
additional nitrogen allocation from another point source within the lower basin.
The Division has been working diligently with the Lower Neuse Basin Association and EPA
Region IV to resolve outstanding issues with the formation of the Compliance Association. At
this time, those issues and associated documents are expected to be completed by the end of this
year.
➢ Alternatives Analyses. As required by the Division's Antidegradation Policy, alternatives to
discharge must be thoroughly documented. A brief review of the alternatives indicate that,
although several alternatives are documented, the Town will also need to document the
feasibility of land application of the expanded flow (0.6 MGD), as well as the entire flow (it
appears that land application of the entire flow has been documented). In addition,
documentation of the cost and feasibility of the expanded flow (or any greater amount of flow)
transferred to Central Johnston County should be provided with the alternatives analysis (some
of the projected costs listed in Exhibit 4 should be clarified). Central Johnston County is well
underway to an expansion and may be able to accommodate the Town's expanded flow; this
may allow the Town a temporary *solution until planning for the 20 year projected flow is
complete.
N. C. Division of Water Quality 1 NPDES Unit Phone: [phone], extension 510
1617 Mail Service Center, Raleigh, NC 27699-1617 Fax [phone]
Internet: h2o.enr.state.nc.us e-mail: [e-mail]

Mr. Biggs
Page 2
➢ Permit Application. Please clarify Part B.S. of the permit application to state that certain
improvements were approved with the Authorization to Construct permit issued May 24, 2001,
but that approval did not evaluate the plant to comply with a flow of 2.5 MGD. The Town of
Clayton will still be required to provide calculations to ensure that the expansion will comply
with the limits given for the expansion to 2.5 MGD. Also, parts of the document refer to future
limits of 5 mg/I BOD5 and 2 mg/1 NH3-N — this is incorrect. All references to limits upon
expansion should indicate 5 mg/I BODS and 1 mg/1 NH3N (summer), 2 mg/1 NH3 N (minter).
If you wish to reapply for this permit, submit the items listed above and the items returned to you in
one package. A copy of this letter, along with the Division's EAA Guidance, is also being sent to your
Authorized Representative (Angela Mettlen of Hobbs, Upchurch & Associates).
If you or your consultants have any questions about this matter, contact Susan A. Wilson of the
NPDES Unit staff at the telephone number or e-mail address listed at the bottom of the previous page.
Sincerely, /n
J. William Reid Supervisor
Point Soutce Branch
cc: Central Files
NPDES File R
Angela Mettlen / HUA
Raleigh Regional Office / Water Quality Section

EXAMPLES: FINANCIAL IMPACTS OF NEUSE NSW MANAGEMENT STRATEGY
ON THE TOWN OF CLAYTON
Current Conditions
Potential
Future Conditions
a
(b)
c)
(d)
e) Ho
(9)
(h)
U)
Flow
TN
TN
Future
TN
TN
TN
Total TN mass over
Total Offset
(MGD)
(mg/l,
(mass
Flow
(mg/l,
(mass
(est. treatability
allocation and
Payment
conc.
allocation)
(MGD)
conc.
allocation)
concentration
subject to offset
equivalent
equivalent)
& mass equiv.).,payment
Clayton
1.9
3.7 mg/1
21,400
2.5
2.8 mg/1
21,400
3.5 mg/l (73
26,645-21,400
$3.460,000
(if TN of
lbs/yr
lbs/yr
lbs/day)
= 5,245 lbs/yr
3.5 mg/1
Less than BAT
= 26.645 lbs/yr
can be
met)
Clayton
1.9
3.7 mg/1
21,400
2.5
2.8 mg/l
21,400
3.0 mg/l (62.6
22,849 - 21,400
$ 0.956 M
(If TN of
lbs/yr
lbs/yr
lbs/day)
= 1449 lbs/yr
3.0 mg/1
Less than BAT
= 22,849 lbs/yr
$956,000
can be
met
* BAT (Best Available Technology), is considered as 3.0 mg/1 TN at this time. The projected concentration equivalent for Clayton after expansion
is 2.8 mg/l, which is less than BAT.
Ref. 15A NCAC 2B .0234 Neuse River Basin - NSW Management Strategy: Wastewater Discharge Requirements.
Parts (7) and (8) refer to new and expanding facilities, respectively.
FOOTNOTES (next page)

EXAMPLES: FINANCIAL IMPACTS OF NEUSE NSW MANAGEMENT STRATEGY
ON THE TOWN OF CLAYTON
FOOTNOTES
(a) Current permitted/design flow.
(b) The concentration equivalent (mg/1) of the total yearly nitrogen mass allocation. This value is calculated as follows (for Clayton):
PF * conc. * 8.34 = Allocation/365 d
Conc = (21,4001bs/yr * yr/365 d) / 1.9 * 8.34
= 3.7 mg/1
(c) The total nitrogen annual mass allocation (this has been set and pre -determined with implementation of the temp. rule).
(d) Hypothetical future permitted flow.
(e) The concentration equivalent (mg/1) of the total annual nitrogen mass allocation based on the hypothetical permitted future flow. This value is calculated
similarly to that shown in (b):
PF(future) * conc. * 8.34 = Allocation/365 d
Conc. _ (21,4001bs/yr * yr/365d) / 2.5 * 8.34
= 2.8 mg/1
(0 The total nitrogen mass allocation (same as (c)).
(g) The Division has made the assumption that at this time 3.5 mg/l TN is Best Available Technology - it's possible a facility may be able to achieve a lesser
concentration. However, for this example 3.5 mg/1 TN will be assumed as the proposed minimum treatment technology (and this value is also used in the
rule). Should a facility prove that a lesser value is feasible, the offset calculation may be adjusted accordingly. The calculation is as follows:
Allocation = PF(future) * 3.5 mg/1 * 8.34
=2.5*3.5*8.34
= 731bs/day * 365d/yr
a 26,645 lbs/yr
(h) The facility must pay the difference between what their present annual mass nitrogen allocation is and what the calculated load at BAT of 3.5 mg/1 is. This
means paying the difference between the load at 2.8 mg/1(concentration based on allocated load) and 3.5 mg/l for the future flow of 2.5 MGD (in the case of
Clayton)
Offset load = Load at 3.5 mg/l & 2.5 MGD - Allocated load
26,645 - 21,400
= 5245 lbs/year
(i) As stated in the rule, the offset cost must be determined based on $11 lb TN/yr for a period of 30 years at 200 9�6.
Total offset cost = Onset Load * $11 lb TN/yr * 30 yr * 2
=5245* 11 *30*2
$ 3,460,000 or $3.46 M

JOL-26-2002 09:16AM FROM -Construction Grants And Loans 9197156229
NORTH CAROUNA DEPARTMENT
or,
ENVIRONMENT AND NATURAL RESOURCES
Division of Water Quality
Construction Grants & Loans Section
M AGN AFAR TRANSMYTTAL
T-702 P.001/004 F-038
2003
Date:
zCo juIl 02
`Co:
SUSafx W �1SFY.
A ck( �
Location:
FaxNo.(
) 733-0712
Sent From:
DENR - DWQ - Construction Grants & Loans
Fax No. [phone] Tele: (919) 7 15 —62 1 3
Pages to Follow
Comments: L �T �.(1C>JJ It VGA \1e 1S1 \
or czJb�icac,� a�.y-lh�hc. -
Construction Grants & Loans
1633 Mail Service Center, Raleigh, NC 27699-1633

JUL-28-2002 09:16AU FR00-Construction Grants And Loans 919TI56229 T-T02 P.002/004 F-038
TOWN OF CLAYTON
Technical Review Comments
For Clayton 201 Facilities Plan
Project No. CS370431-05
July 26, 2002
General
1. This SRF project is being generated in order to complement an SRO/SRL project
which involves the renovation of various plant components in order to facilitate an
increase in plant capacity to 2.5 mgd. Confirm the status of tile SRG/SRL project
and discuss the affects on this SRF project associated S'' /a�y delay or
postponement of the expansion project. Note that the project actually
recommends the town apply for an NPDES expansion to 2.35 mgd.
2. A loan from the North Carolina Water Pollution Control Revolving Loan Fund is
contingent on the review and approval of the proposed loan by the Local
Government Commission.
3. Please note that approval of the facilities plan does not constitute approval of sole
source procurement. Plans and specifications must comply with N.C. General
Statute Chapter 133, Section 3, prior to their approval.
4. The owner and consulting enginccr should be advised that after approval of the 201
Facilities Plan there are several construction project permits, approvals,
certifications, etc, that must be obtained before the project plans and specifications
can be approved and the project is advertised for bids. Therefore, it is strongly
recommended that preliminary work to obtain the following items, if applicable,
begin as soon as possible:
a. Sedimentation and Erosion Control Permit, from the Division of Land
Quality, or a letter from them stating that no permit is required for this project.
b. 401 Water Quality Certification and Army Corps of Engineer's 404 Permit for
all stream crossings or letters from the Army Corps of Engineers and from the
Wetlands 401 Certification Unit stating that none is required for this project.
C. Section 10 Permit for aerial crossings of navigable waters or a letter from the
Corps stating that none is required for this project.
d. A reasonable subsurface investigation that must be made available to the
contractor. if it is not included in the specifications, the specifications must
advise where a copy of the report can be observed. Typically CG&L expects
a boring about every 500 feet and at each road crossing for linework and at all
major structures like pump stations aeration basins, and clarifiers.

JUL-26-2002 09:16AM FROM -Construction Grants And Loans 9197156229 T-702 P.003/004 F-038
e. NpDES permit when the project involves a new discharging facility or
expansion to an existing one.
5. The report references ongoing construction at the plant. Discuss the status of this
construction.
6. Please note the attached correspondence from Bill Reid (Junc 10, 2002) concerning
this project. The concerns documcntcd in the letter should be resolved and any
subsequent correspondence from Mr. Reid forwarded to this office.
1. Page 2: Finding number I recommends that Clayton join the Lower Neuse Basin
Association when it is formed. Discuss the status of formation of this group and
provide assurance of Clayton's intent to join the association.
2. The selected alternative involves joining the lower Neuse Basin Association and
buying sufficient credits so as to require meeting a total nitrogen limit of 3.5 mg/l.
This is all based on the formation of the basin association and the ability to buy the
credits. The total cost of the credit purchase should be included in the cost effective
analysis and discussion provided concerning the plant's ability to meet nitrogen
limits in the absence of the ability to purchase credits. Include any remedial action
needed to provide the plant the ability to meet the limits without the credit purchasc
and the cost of that action.
5.0 Pao ulation
I., In areas of historically fast growth, project design populations for the next ten years
may be based on the prior growth rate of the City/Town, if it seems reasonable. For
the second ten years the 201 Plan should demonstrate that the locality has or will
have adequate capacity - financially, geographically, infrastructure -wise, etc. to
support a projection of population which exceeds the County growth rate during
that same period.
6.0 Design Basis
1. Page 39: Conclusion number 9 lists a design influent of2.5 mgd. Provide
justification for this flow. Design flow should be based on existing flow plus the
projected increase in flow due to population growth or annexation. A 20 year design
period should be used unless otherwise justified. If justified, a design period of 10
years can be utilized however it must be demonstrated that the project will be
phased as to provide for the 20 year design period and that the phased project is the
most cost effective alternative. In either case (i.e. phased or not phased) a cost
effective plan to meet the 20- year needs to treat and dispose the estimated 20-year
design flow must be provided in the 2O1 plan.

JUL-26-2002 09:17AM FROM -Construction Grants And Loans 919TI56229 T-702 P-004/004 F-038
7.0 Alternatives
1. (Reference page 53) Please provide information concerning the proposed sludge
treatment and disposal that addresses how sludge management will comply with
the 40 CFR 503 Regulations including the following:
a. Sludge production calculations at the design flow and a discussion of the
methods that will be used to comply with pathogen and vector attraction
reduction.
b. Discuss the adequacy of the ultimate sludge disposal site(s) at the design flow
for the 20-year planning period.
c. Confirmation of an agreement(s) with owner(s) of permitted sludge sites, or a
modifiable permit held by a contract hauler.
2. The cost effective analysis used a present worth discount rate of 7.125%. The
updated discount rate as October 1, 2001 is 6.125%, Perform the present worth
analysis using the 6.125% rate and verify that the selected alternative is still the
most cost effective alternative.
3. Alternative 2 appears to be more energy intensive than Alternative 1. Please
discuss.
8.0 Proposed Improvements
1. (Reference page 96) Provide calculations to demonstrate that the projected user
charge will adequately cover all existing indebtedness and O&M costs as well as
those costs associated with this project and the SRGISRL project to increase plant
capacity to 2.5 tngd.

Re: [Fwd: clayton]
Subject: Re: [Fwd: clayton]
Date: Wed, 12 Jun 2002 10:10:18 -0400
From: Jenne Walker <[e-mail]>
To: Susan A Wilson <[e-mail]>
CC: Ken Schuster <[e-mail]>, Bob Sledge <[e-mail]>
Susan,
Clayton has regularly reconciled flow to the wwtp, most recently, just last
month. The plant is getting close to 80% of actual flow, but hasn't quite reached
that point (currently running at 77% of capacity per my records). They are very
high on paper flow - 97%, and they are aware of this. Very few sewerline requests
have been coming in over the past 2 years. The Town's Engineer is well aware
of the situation. To my knowledge, they are not currently on any type of flow
moratorium (but they are getting close). Let me know if you have any additional
questions!
Jenne Walker
571-4700 x 251
Ken Schuster wrote:
> Can you get back to Susan on this Jenne.
> ------------------------------------------------------------------------
> Subject: clayton
> Date: Fri, 07 Jun 2002 16:43:40 -0400
> From: Susan A Wilson <[e-mail]>
> Organization: NC DENR DWQ
> To: Ken Schuster <[e-mail]>, Bob Sledge <[e-mail]>
> Ken - are these guys still on your list as being over -allocated on
> paper? are they on any real or perceived flow moratorium? Bob -
> they're not on the 80190 list are they? thanks!
1 of 1 6/12/02 12:30 PM

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Mr. Steve Biggs
Town of Clayton
P.O. Box 879
Clayton, North Carolina 27520
Dear Mr. Biggs:
Michael F. Easley
Governor
William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
June 10, 2002
Subject: Return of permit modification request
Clayton — Little River WRF
NPDES No. NCO025453
Wake County
Return #2159
In accordance with Division policy, we must hereby return the enclosed permit application and fee
check of $860.00 (paid by check #31825). After a preliminary review, the Division has determined that the
application is incomplete. The application package lacks the following items:
➢ Incomplete fee. As stated correctly in your application document (Part 5.6 of the Analysis of
Alternatives), nutrient off -set costs must be paid at the time of application [ref. Temporary Rule,
adopted February 2000, 2B .0234 (8)(c)]. Because the Neuse Compliance Association has not yet
been formed, the Division cannot accept the Town's application without the off -set cost of
approximately $3.5 million. The Division will accept the application again with the appropriate
fee and off -set cost or with confirmation of the formation of the Compliance Association, along
with the Town's commitment to join, or with confirmation that the Town has purchased
additional nitrogen allocation from another point source within the lower basin.
The Division has been working diligently with the Lower Neuse Basin Association and EPA
Region IV to resolve outstanding issues with the formation of the Compliance Association. At
this time, those issues and associated documents are expected to be completed by the end of this
year.
➢ Alternatives Analyses. As required by the Division's Antidegradation Policy, alternatives to
discharge must be thoroughly documented. A brief review of the alternatives indicate that,
although several alternatives are documented, the Town will also need to document the
feasibility of land application of the expanded flow (0.6 MGD), as well as the entire flow (it
appears that land application of the entire flow has been documented). In addition,
documentation of the cost and feasibility of the expanded flow (or any greater amount of flow)
transferred to Central Johnston County should be provided with the alternatives analysis (some
of the projected costs listed in Exhibit 4 should be clarified). Central Johnston County is well
underway to an expansion and may be able to accommodate the Town's expanded flow; this
may allow the Town a temporary solution until planning for the 20 year projected flow is
complete.
N. C. Division of Water Quality / NPDES Unit Phone: [phone], extension 510
1617 Mail Service Center, Raleigh, NC 27699-1617 Fax: [phone]
Internet: h2o.enr.state.nc.us e-mail: [e-mail]

Mr. Biggs
Page 2
➢ Permit Application. Please clarify Part B.S. of the permit application to state that certain
improvements were approved with the Authorization to Construct permit issued May 24, 2001,
but that approval did not evaluate the plant to comply with a flow of 2.5 MGD. The Town of
Clayton will still be required to provide calculations to ensure that the expansion will comply
with the limits given for the expansion to 2.5 MGD. Also, parts of the document refer to future
limits of 5 mg/l BODS and 2 mg/1 NH3-N — this is incorrect. All references to limits upon
expansion should indicate 5 mg/1 BODS and) mg/1 NH3-N (summer), 2 mg/1 NH3-N (winter).
If you wish to reapply for this permit, submit the items listed above and the items returned to you in
one package. A copy of this letter, along with the Division's EAA Guidance, is also being sent to your
Authorized Representative (Angela Mettlen of Hobbs, Upchurch & Associates).
If you or your consultants have any questions about this matter, contact Susan A. Wilson of the
NPDES Unit staff at the telephone number or e-mail address listed at the bottom of the previous page.
Sincerely,
oral(AL Stelt4EP
J. William Reid, Supervisor
Point Source Branch
cc: Central Files
NPDES File
Angela Mettlen / HUA
Raleigh Regional Office / Water Quality Section
N