NC0025453_Permit Issuance_20100315

A?PDE!i DOCUNEN'1' SCANNINL COVER !iKEE'1'
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 15, 2010
9r2iis document is printed on reu6e paper - ignore any
coaiteait on the reYerBe Bide

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NCDENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
Mr. R. Steven Biggs, Town Manager
Town of Clayton
Post Office Box 879
Clayton, North Carolina 27520
Dear Mr. Biggs:
Division of Water Quality
Coleen H. Sullins Dee Freeman
Director Secretary
March 15, 2010
Subject: NPDES Permit Issuance
Little Creek Water Reclamation Facility
Permit No. NCO025453
Johnston County
In accordance with the application for discharge permit received and after considering comments
received at the September 2009 public hearing, the Division is forwarding herewith the subject NPDES permit.
This permit is issued pursuant to the requirements of North Carolina General Statute 143-215.1 and the
Memorandum of Agreement between North Carolina and the U.S. Environmental Protection Agency dated
October 15, 2007 (or as subsequently amended).
The Division held the public hearing to take comments on the draft permits for Clayton -Little Creek
Water Reclamation Facility (NC0025453), DuPont -Kinston (NC0003760), and Johnston County (NC0030716).
The central issue at the hearing was the upstream transfer of nitrogen allocations from UNIFI/ DuPont to
Clayton and Johnston County.
Comments relevant to the Division's water quality programs, but not directly related to the permits,
were also received. The hearing officers have worked diligently to ensure that these issues are addressed
appropriately, and we regret the delay in taking final action on these permits. The hearing officers recently
submitted their findings and recommendations to the Director for final action, and the Director has concurred
with their report. The following recommendations apply to Clayton's permit and have been incorporated:
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] \ FAX: [phone] \ Customer Service:1-877-623-6748
Internet: www.ncwaterquality.org
An Equal Opportunity \ Affirmative Action Employer
Nose Carolina
�tura!ly

a •�
The Total Nitrogen limits in the three permits are modified as proposed to implement nitrogen
transfers among the dischargers. The new limits are effective for calendar year 2010, also as proposed.
The final permit authorizes the Town of Clayton to discharge treated municipal wastewater from the
Little Creek Water Reclamation Facility to the Neuse River, a class WS-IV NSW CA water in the Neuse River
Basin. The permit includes discharge limitations or monitoring for flow, total suspended solids (TSS), BOD5,
ammonia nitrogen, dissolved oxygen, total residual chlorine, fecal coliform, total nitrogen, total phosphorus,
copper, zinc, and chronic toxicity.
The following procedure has been implemented by DWQ: Total residual chlorine (TRC) compliance
level changed to 50 ug/L Effective March 1, 2008, the Division received EPA approval to allow a 50ug/L TRC
compliance level. This change is due to analytical difficulties with TRC measurements. Facilities will still be
required to report actual results on their monthly discharge monitoring report (DMR) submittals, but for
compliance purposes, all TRC values below 50 ug/L will be treated as zero. Additional language regarding
this change has been added to footnote 4. on the effluent limitations page.
The following modifications in the August 12, 2009 draft permit remain in the final permit.
The total nitrogen discharge limit increased to 22,832 lb/year, reflecting the transfer of 3,290
lb/year of discharge allocation from DuPont — Kinston (formerly UNIFI). At the request of
the Town of Clayton, 1,4321b/year of the discharge allocation was added to the current
21,400 lb/year load (totaling 22,832 lb/year). The remaining 1,858 lb/year will be placed in
reserve in the Town's permit. The change in the TN limit would become effective on
January 1, 2010, that is, at the beginning of the upcoming calendar year. Please note
Condition A. (4). Total Nitrogen Allocations in the permit for clarification.
Monthly monitoring for silver has been removed from the permit. Based on the results of a
reasonable potential analysis, it was determined that there was no reasonable potential for
the discharge to exceed the water quality action level standard instream.
There are language changes in Condition A. (5). Chronic Toxicity Permit Limit. There are
some minor additions on DWQ forms to be submitted and clarification on reporting
pollutant data on the discharge monitoring report and AT forms.
If any parts, measurement frequencies or sampling requirements contained in this permit are
unacceptable to you, you have the right to an adjudicatory hearing upon written request within thirty (30)
days following receipt of this letter. This request must be in the form of a written petition, conforming to
Chapter 150B of the North Carolina General Statutes, and filed with the office of Administrative Hearings,
6714 Mail Service Center, Raleigh, North Carolina 27699-6714. Unless such a demand is made, this permit
shall be final and binding.
Please take notice that this permit is not transferable. The Division may require modification 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 or permits required by the Division of Land Resources,
Coastal Area Management Act, or any other Federal or Local governmental permits may be required.

_,
If you have any questions or need additional information, please contact Jacquelyn Nowell at telephone
number [phone].
Sinc y,
CoPeenH.S
Enclosure: Final permit, NC0025453
cc: Mr. James Warren, Town of Clayton (via email)
Mr. Haywood Phthisic, Executive Officer, NRCA (via email)
Raleigh Regional Office/Surface Water Protection Section (via email)
EPA Region IV (via email)
PERCS/Attn: Monti Hassan (via email)
Aquatic Toxicity Unit (via email)
NPDES File/NC0025453

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 ELIMINATION SYSTEM
In compliance with the provisions of North Carolina General Statute 143-215.1. other lawful standards
and regulations promulgated and adopted by the North Carolina 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 municipal 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, 2010.
This permit and the authorization to discharge shall expire at midnight on ............... March 31, 2013.
Signed this day ............................................ March 15, 2010.
Coleen H. Sullins, rector
Division of Water Quality
By the Authority of the Environmental Management Commission
Clayton WWTP
NPDES No. NCO025453
' 1

a
SUPPLEMENT TO PERMIT COMER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby
revoked. As of this permit issuance, any previously issued permit bearing this number is no
longer effective. Therefore, the exclusive authority to operate and discharge from this facility
arises under the permit conditions, requirements, terms, and provisions included herein.
Town of Clayton
Little Creek Water Reclamation Facility
is hereby authorized to:
1. Continue to operate 2.5 MGD wastewater treatment facility consisting of:
■ mechanical screening and grit removal system,
■ influent pump station,
• a 214,500 gallon anaerobic basin,
■ a 300,000 gallon anoxic tank,
■ oxidation basin No. 2,
• a 200,000 gallon anoxic tank
oxidation basin No. 1,
• three (3) secondary clarifiers,
■ two tertiary filters,
■ ultraviolet disinfection with back-up chlorination/dechlorination,
■ one 90,000 gallon aerated digester/sludge stabilization tank,
■ one 360,000 gallon sludge holding tank,
■ sludge loading station,
■ sludge thickening building with rotary drum thickener
■ non -potable water system using reclaimed treated wastewater
■ reclaimed water pump station
Facility is 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.
Town of Clayton
NPDES No. NCO025453
2

A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS — FINAL
During the period beginning on the effective date of the permit and lasting until 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 suecified below:
EFFLUENT
CHARACTERISTICS
EFFLUENT LIMITATIONS
MONITORING REQUIREMENTS
Monthly
Average
Weekly
Average
Daily
Maximum
Measurement
Frequency
Sample Type
Sample
Locationi
Flow
2.5 MGD
Continuous
Recording
Influent or
Effluent
BOD, 5 day (20QC)2
[April 1— October 31 ]
5.0 mg/L
7.5 mg/L
Daily
Composite
Influent &
Effluent
BOD, 5 day (204C)2
[November 1— March 31]
10.0 mg/L
15.0 mg/L
Daily
Composite
Influent &
Effluent
Total Suspended Solids2
30.0 mg/L
45.0 mg/L
Daily
Composite
Influent &
Effluent
NHs as N [April 1— October 311
1.0 mg/L
3.0 mg/L
Daily
Composite
Effluent
NHs as N [Nov 1— March 31]
2.0 mg/L
6.0 mg/L
Daily
Composite
Effluent
Dissolved Oxygen3
Daily
Grab
Effluent
Dissolved Oxygen
Week
Grab
Upstream &
Downstream
Fecal Coliform (geometric mean)
200/100 ml
400/100 ml
Daily
Grab
Effluent
Fecal Coliform (geometric mean)
Meek
Grab
Upstream &
Downstream
Total Residual Chlodne4
�728
µg/L
Daily
Grab
Effluent
TKN (mg/L)
Monitor & Report
Weekly
Composite
Effluent
NO2-N + NO3-N (mg/L)
Monitor & Report
Weekly
Composite
Effluent
TN (mg/L)5
Monitor & Report
Weekly
Composite
Effluent
Total Monthly Flow (MG)
Monitor & Report
Monthly
Calculated
Effluent
TN Load6,7
Monitor & Report
22,832 Ib/yr (effective 1/1/2010)
Monthly
Annually
Calculated
Calculated
Effluent
Effluent
Total Phosphorus 8
2.0 mg/L (Quarterly Average)
Weekly
Composite
Effluent
Temperature (4C)
Daily
Grab
Effluent
Temperature (4C)
Week
Grab
Upstream &
Downstream
Conductivity
Daily
Grab
Effluent
Conductivity
3/Week
Grab
Upstream &
Downstream
Chronic Toxicity9
Quarterly
Composite
Effluent
Total Copper
Monthly
Composite
Effluent
Total Zinc
Monthly
Composite
Effluent
pH1 0
Daily
Grab
Effluent
(Footnotes on next page)
Town of Clayton
NPDES No. NCO025453
3

A. VL 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
Association.
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 Solids 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). The Division shall consider all effluent total residual chlorine values reported
below 50 µg/L to be in compliance with the permit. However, the Permittee shall continue to
record and submit all values reported by a North Carolina certified laboratory (including field
certified), even if these values fall below 50 µg/L.
5. For a given wastewater sample, TN = TKN + NO2-N + NO3-N, where TN is Total Nitrogen, TKN
is Total Kjeldahl Nitrogen and NO2-N and NO3-N are Nitrate and Nitrite Nitrogen,
respectively.
6. TN Load is the mass load of TN discharged by the Permittee in a period of time. See Special
Condition A. (2.), Calculation of TN Loads.
7. Compliance with these limits shall be determined in accordance with Special Condition A.
(3.), 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 dubi,a) P/F at 2.0 %: 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 shall be no discharge of floating solids or visible foam in other than trace amounts.
Town of Clayton
NPDES No. NCO025453
4

1
A. (2.) CALCULATION OF TOTAL NITROGEN LOADS
a. The Permittee shall calculate monthly and annual TN Loads as follows:
i. Monthly TN Load (lb/mo) = TN x TMF x 8.34
where:
TN = the average Total Nitrogen concentration (mg/L) of the
composite samples collected during the month
TMF = the Total Monthly Flow of wastewater discharged during the
month (MG/mo)
8.34 = conversion factor, from (mg/L x MG) to pounds
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. (3.) 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
li. 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.
ft. 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
1617 Mail Service Center
Raleigh, NC 27699-1617
Town of Clayton
NPDES No. NC0025453
5

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. (4.) TOTAL NITROGEN ALLOCATIONS
a. The following table lists the Total Nitrogen (TN) allocation(s) assigned to, acquired by, or
transferred to the Permittee in accordance with _the Neuse River nutrient management rule
(T15A NCAC 02B .0234) and the status of each as of permit issuance. For compliance
purposes, this table does not supersede any TN limit(s) established elsewhere in this permit
or in the NPDES permit of a compliance association of which the Permittee is a Co-
Permittee Member.
ALLOCATION
ALLOCATION AMOUNT ���
TYPE
SOURCE
DATE
STATUS
Estuary (Iblyr)
Discharge (Iblyr)
Base
Assigned by Rule
12/7/97;
10,700
21,400
Active
(1715A NCAC 02B .0234)
4/1/03
Supplemental
Purchased from
7/5106
3,668
7,336
Reserve
South Granville WSA
(NC0026824)
Supplemental
Purchased from
8/30/2007
1,645
3,290
Mixed
UNIFI-Kinston
716
1,432
Active
(NC0003760)
929
1,858
Reserve
TOTAL
16,013
32,026
Mixed
11,416
22,832
Active
4,597
9,194
Reserve
Footnote:
(1) Transport Factor = 50%
b. Any addition, deletion, or modification of the listed allocations (other than typographical
errors) or any change in status of any of the listed allocations shall be considered a major
modification of this permit and shall be subject to the public review process afforded such
modifications under state and federal rules.
Town of Clayton
NPDES No. NCO025453
6

A. (5.) 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, auarterlu 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 H
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. If reporting
pass/fail results using the parameter code TGP3B, DWQ Form AT 1 (original) is sent to the
below address. If reporting Chronic Value results using the parameter code THP3B, DWQ Form
AT-3 (original) is to be sent to the following address:
Attention: North Carolina Division of Water Quality
Environmental Sciences Section
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Section no
later than 30 days after the end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements
and all concentration/response data, and be certified by laboratory supervisor and ORC or
approved designate signature. Total residual chlorine of the effluent toxicity sample must be
measured and reported if chlorine is employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity
monitoring is required, the permittee will complete the information located at the top of the
aquatic toxicity (AT) test form indicating the facility name, permit number, pipe number, county,
and the month/year of the report with the notation of "No Flow" in the comment area of the form.
The report shall be submitted to the Environmental Sciences Section at the address cited above.
Should the permittee fail to monitor during a month in which to,,dcity 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.
If the Permittee monitors any pollutant more frequently then required by this permit, the results
of such monitoring shall be included in the calculation & reporting of the data submitted on the
DMR & all AT Forms submitted.
Town of Clayton
NPDES No. NCO025453
7

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.) 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 K,jeldahl 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-dichlorobenzene
Copper
Vinyl chloride
3,3-dichlorobenzidine
Lead
Acid-ext actable compounds:
Diethyl phthalate
Mercury
P-chloro-m-cresol
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
Hexaclilorobenzene
Total phenolic compounds
4-nitrophenol
Hexachlorobutadiene
Volatt7e oraan(c compounds:
Pentachlorophenol
Hexachlorocyclo-pentadiene
Acrolein
Phenol
Hexachloroethane
Acrylonitrlle
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
Benzid(ne
N-nitrosodimethylamine
Chloroethane
Benzo(a)anthracene
N-nitrosodiphenylamine
2-chloroethylvinyl ether
Benzo(a)pyrene
Phenanthrene
Chloroform
3A benzofluoranthene
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.
Town of Clayton
NPDES No. NCO025453
8

�r
4. Test results shall be reported to the Division in DWQ Form- DMR-PPA1 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, Surface Water Protection Section, Central
Files, 1617 Mail Service Center, Raleigh, North Carolina 27699-1617.
Town of Clayton
NPDES No. NCO025453
9

.r
Templeton, Mike
From: [e-mail]
Sent: Wednesday, August 26, 2009 8:50 AM
To: Templeton, Mike
Subject: Re NCO030716 (Johnston Co. mod), NC0003760 (DuPont Kinston), and NCO025453 (Clayton
Little Creek) draft NPDES permits
After our review and discussion with you, EPA has concluded that the likelihood of hot spots
resulting from these nitrogen trades is small because the Neuse River is free -flowing in the
vicinity of the facility
discharge points. Based on that determination, EPA has no comments on
these draft permits. EPA does recommend that the fact sheet for each
facility reflect this consideration.
1

It
4 i MoUT V • r o P sFT�y
PUBLIC HEARING AND FINAL ACTION
Prior to the 2007 renewal cycle for Neuse River basin permits, the Neuse Riverkeepers
expressed concerns about pending nitrogen trades and requested a public hearing for the
DuPont -Kinston (NC0003760), Clayton (NC0025453), Johnston County (NC0030716) permits.
The hearing was expected to be held in the Fall of 2007.
Work on the permits was then delayed when UNIFI announced the sale of its Kinston facility to
DuPont. The sale would result in changes in operations at the facility, and it was necessary for
DuPont to submit a revised permit application reflecting the anticipated changes in production.
Permit writers resumed work on the permits once the application was received, and the
Division published notice of the draft permits in the Raleigh News and Observer on August 15,
2009. The hearing was held on September 29, 2009, at the Wayne County Public Library in
Goldsboro.
The central issue was the sale of nitrogen allocation by UNIFI, LLC to the Town of Clayton and
to Johnston County. Due to differences in the transport factors for UNIFI and for the upstream
buyers, the transfer would result in an increase in discharge allowances even though the load
delivered to the estuary would not increase. Due to uncertainties with the transport factors and
with the overall effectiveness of the Neuse River nutrient reduction efforts, the Riverkeepers
recommended against allowing the nitrogen transfers. The Riverkeepers also recommended that
the mercury limit be restored in Johnston County's permit, based on apparent violations at the
facility.
The hearing officers made three permit -related recommendations, and the Director noted her
concurrence on February 18, 2010:
• Implement the nitrogen transfer as proposed.
• Do not restore the mercury limit in Johnston County's permit. Further review showed
that the apparent mercury violations were the result of data entry error (incorrect units
of measure); thus, no violations occurred, and the limit is not warranted.
• Incorporate technical corrections in DuPont's OCPSF limits, which were not a matter of
contention at the hearing but were needed nonetheless.
The hearing officers also made several recommendations not directly related to the permits, to
address other issues raised at the hearing. The Director will address those matters separately
from the permits.
The final permits incorporate the permitting recommendations. The nitrogen limits are effective
in CY2010, as proposed. Expiration dates for the DuPont and Clayton permits remain as
proposed in order to keep them aligned with the basin permitting schedule for the Neuse River
basin; the expiration date for the Johnston County permit has been modified to bring it into
line with the schedule.
The EPA's Region 4 office reviewed the draft permits prior to the public hearing and discussed
potential issues regarding the nitrogen transfers with DWQ staff. Given that the Neuse River is
free -flowing in the vicinity of the upstream discharge points, the EPA concluded that the
likelihood of the trades resulting in 'hot spots' would be small and indicated that it had no
further comments on the draft permits.
NAME: Original signed by Jacquelyn M. Nowell DATE: 3/8/2010
NCO025453 Clayton
NPDES Renewal
Page 5

DENR/DWQ
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES No. NC0025453, Clayton/ Little Creek WRF
Facility Information
Applicant/Facility Name:
Town of Clayton/ Little Creek Water Reclamation Facility
Applicant Address:
P.O. Box 879, Clayton, NC 27520
Facility Address:
Durham Street Extension Clayton NC
Permitted Flow
2.5 MGD
Type of Waste:
- 22% Ind., -78% Domestic (at permitted flow)
Facility/Permit /Permit Status:
Renewal
County:
Johnston
Miscellaneous
Receiving Stream:
Neuse River
Regional Office:
Raleigh
eam Classification:
WS-IV NSW CA
SI: 27-41.3
Quad
E25NW
Clayton
Listed?:
Yes
Permit Writer:
Jacquelyn Nowell
Subbasin:
030402
Date:
JuIV 22, 2009
Drainage Area (mi2):
1150
Summer 7 10 (cfs)
186 (regulated)
Winter 7Q10 (cfs):
Average Flow (cfs):
IWC (%):
1.6
Primary SIC Code:
14952
SUMMARY
Clayton operates a 2.5 MGD wastewater treatment facility that discharges into the Neuse River.
(an authorization to operate at 2.5 MGD was completed during the last permitting cycle).
The plant serves approximately 12, 100 persons and the East Clayton Industrial Area. Average
annual flow has been approximately 1.23 MGD (appx. 49% of permitted flow).
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.
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. (this information is from the
previous factsheet in 2003).
Water Quality Considerations
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.
NCO025453 Clayton
NPDES Renewal
Page 1

Oxygen Demand
Prior to the issuance of the previous permit in 2003, 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.
Nitrogen
The Environmental Management Commission adopted Nutrient Management Strategy rules in
December 1997, classifying the entire Neuse River Basin as Nutrient Sensitive Waters. The
point source rule (T15A NCAC 2B .0234) sets Total Nitrogen (TN) discharge limits for all point
source dischargers larger than 0.5 MGD.
The rule also allows dischargers to form a group compliance association and work together to
reduce nitrogen; this option allows the association members added flexibility in controlling
nitrogen discharges. At the same time, the association is subject to a group NPDES permit
ensuring that the association and its individual members are accountable if they exceed the
applicable nitrogen limits.
Under the rule, there are three types of TN limit in the Neuse:
• the individual limits in the dischargers' individual permits,
• the aggregate limit in an association's group NPDES permit, and
• the individual allocations/limits for each Association member, also in that association
permit.
A discharger may be subject to the first type of limit, or to the second and third, but never to all
three at the same time. The discharger is first subject to the TN limit (if any) in its individual
NPDES permit. If becomes a co-permittee to a compliance association's group NPDES permit, it
is then governed by the TN limits in that permit. If the association complies with its group TN
limit in a given year, all members are deemed to be in compliance with their individual
allocations/ limits in the group permit. If the association exceeds its limit, the members then
become subject to their individual allocations/ limits as well.
Regardless of which permit governs a TN discharge, allocations/ limits will likely change over
time as the dischargers purchase, sell, trade, lease, or otherwise transfer nitrogen allocations.
The Division will modify the affected permits as necessary to ensure that the limits are kept up
to date and reflect any such transactions
TOXICITY TESTING:
Current Requirement: Chronic P/F at 2.0 % (at 2.5 MGD)
Testing in March, June, September and December.
Clayton has passed all toxicity tests since March 2005.
It is recommended that the quarterly chronic ceriodaphnia test be renewed.
COMPLIANCE SUMMARY:
Clayton has only had minor limit excursions for total residual chlorine (2007) and ammonia
(2005) . These violations occurred over two years ago and facility is well operated and compliant
with permitted limits.
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).
REASONABLE POTENTIAL ANALYSIS/METALS
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. 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.
NCO025453 Clayton
NPDES Renewal
Page 2

.r
Other than conventional parameters, the parameters sampled in the application only had above
detection levels for copper and zinc (which are currently monitored through the permit).
Copper and zinc will continue to be monitored in the permit due to the reasonable
potential to exceed the action level standard at the acute level. The monitoring
frequency will be 1/month because both metals are NC action level standards and due to
Clayton's excellent toxicity testing results.
Silver monitoring will be eliminated from the permit because the reasonable potential
analysis showed that silver levels were below the acute value. Silver will continue to be
monitored quarterly via the facility's pretreatment program LTMP.
The required annual priority pollutant scan was done in June 2005, October 2006, September
2007 and March 2009. There was only a hit of bis 2 ethylhexyl phthalate in June 2005 which
is considered a lab contaminant. There have no other detections of any other substances,
besides conventional contaminants, copper and zinc.
TRANSFER OF NITROGEN ALLOCATIONS
The Town of Clayton's Little Creek Water Reclamation Facility is located within the Neuse River
basin and was assigned Total Nitrogen (TN) allocation under the Neuse River Basin Nutrient
Management Strategy rule for Wastewater Discharges (T15A NCAC 02B .0234), or "the Neuse
rule." In recent years, the Town purchased discharge allocation from South Granville WSA
(SGWSA) and modified its permit in 2006. This purchased allocation has been placed in
reserve for future flows beyond 2.5 MGD.
The Town has now purchased additional allocation from an existing discharger.
UNIFI- Kinston. The Town purchased 1,645 lb/yr estuary allocation from UNIFI-Kinston (now
DuPont -Kinston) in 2007. With a transport factor of 50%, this is equivalent to a discharge (i.e.,
end -of -pipe) allocation of 3,290 lb/yr. The Town requests that 1432 lb/yr of the discharge
allocation be added to the current 21, 400 lb/year allocation in the NPDES permit. This will
have the total nitrogen allocation of 22,832 lb/year . The remaining allocation of 1858 lb/year
will be placed in reserve in Clayton's permit.
With this purchase, the total allocation assigned to the Town of Clayton Little Creek
facility is 22,832 lb/yr at the discharge, equivalent to 11,416 lb/yr at the estuary.
PERMIT SCHEDULE
The tentative schedule for this permit modification is:
Publication of Notice: August 14, 2009 +
Public Hearing: September 29, 2009
End of 30-Day Public Review Period: September 29, 2009, or as set by Hearing Officer
Permit Issued: December 15, 2009
Permit Effective: January 1, 2010
Permit Expires: March 31, 2013
STATE CONTACT:
If you have any questions on any of the above information or on the attached permit, please
contact Jackie Nowell at [phone].
NAME: Original signed by Jacquelyn M. Nowell DATE: 8/ 12/2009
NCO025453 Clayton
NPDES Renewal
Page 3

REGIONAL OFFICE COMMENT:
(Staff report received January 17, 2008).
NAME: DATE:
NC0025453 Clayton
NPDES Renewal
Page 4

Cr
REASONABLE POTENTIAL ANALYSIS
Clayton Little Creek W VTP
NCO025453
Time Period 1/2006-SM009
Ow (MOD)
2.5
7010S (Cfs)
186
7010W (Cfs)
0
3002 (Cis)
0
Avg. Stream Flow, OA (cfs)
0
Rec'valg Stream Neuse River
WWTPClass IV
1WC (%) @ 7010S 2.0408
0 701OW WA
0 3002 WA
0 OA WA
Stream Class WS-IV NSW CA
Outfall 001
Ow = 2.5 MGD
STANDARDS &
PARAMETER
TYPE
CRITERIA (2)
PQL
Units
REASONABLE POTENTIAL RESULTS
RECOMMENDED ACTION
(1)
No Was/ %FAV/
chmnk Acub
n #DA USX AndCw AbmbbCW
Acute: NIA
OA not available since flow Is regulated.
Arsenic
C
10
ugtL
13 0
3.1
No detects since 2006. Recommend---
_ _AL _
Chronic_ _: #VUE!
_con_tinu_ation_of---------------
monitoring in pretreatment LTMP.
Acute: WA
Insufficient data to determine RP.
Beryllium
C
6.5
ug/L
1 0 WA
--------------------------------
Note: n<12
Chronic: #VALUE!
Limited data set
Acute: 15
No detects since 2006. Recommend Continuation of
Cadmium
NC
2 15
ug/L
13 0
1.9
monitoring in pretreatment LIMP. _ --
_ _ _
Chronic: --- 98
_ _
Max pred. Value Is < than both chronc and allowable
concentrations.
Acute: 1,022
Max. prod. Value Is < than both chronic and allowable
Chromium
NC
50 1.022
ug/L
13 0
2.5
concentrations.
No detects since 2005. Recommend continuation of
_ _ ___
Chronic: 2,450
monitoring in pretreatment LTMP.
Acute: 7
Max Pred. Cw < chronic allowable but > acute allowable.
Copper
NC
7 AL 7.3
ug/L
54 49
83.1
tox tests passed since 2003._Since Cu fs action levelrecommend
_ _ _
continuation atmonthly monitoring
[Ali
NPOES permit.
Acute: 22
o detects since 2006. Recommend continuation of
Cyanide
NC
5 N 22
10
ug/L
14 0
5.0
in pretreatment LTMP.
--
_ _ _ _ _ _ _onitoring
Chronic: 245
_ _ _ _ _
Max prod. Value Is < than both chronic and allowable
concentrations.
Acute: WA
Fluoride
NC
1.800
uWL
0 0
NIA
_ - -
------------•-------------------
Chronic__:
9,200
Acute: 34
Max prod. Value is < than both chronic and allowable
Lead
NC
25 N 33.8
ugtL
15 0
2.5
concentrations.
No detects since 2006. Recommend continuation of
_ _ ___ _
Chronic: 1,22b
monitoring in pretreatment LIMP.
Acute: WA
Max prod. Value Is < than chronic concentrations.
Mercury
NC
12
2.0000
nWL
12 1
1.0000
One detection since 2006. Recommend continuation of
_ _ _ _ _ _ _
Chronic:_ 588
quarterly monitoring In pretreatment LIMP.
Acute: WA
OA not available since flow is regulated.
Molybdenum
A
3,500
ugtL
13 0
346.6
All values below detect since Recommend
_ _ _ _
Chronic: #VALUE!
_2006.__ _
continuation of quarterly monitoring in pretreatment LTMP.
Acute: 261
Max prod. Value Is < than both chronic and allowable
Nickel
NC
88 261
ugrL
12 0
5.0
_ _ _
•
concentrations.
No detects since 2006. Recommend continuation of
Chronic: 4,312
monitoring in pretreatment LTMP.
Acute: WA
Phenols
A
1 N
ug/L
0 0
WA
I
_ _ _ _
Chronic: #VALUE!
-----------...........
Acute: 56
Max prod. Value is < than both chronic and allowable
Selenium
NC
5.0 56
uglL
11 0 13.9
concentrations.
Note: n<12
_ _ _ _ _ _ _ _
Chrenb: 245
No detects since 2006. Recommend continuation of
Limited data set
I
monitoring in pretreatment LTMP.
Acute: 1
Max Pred. Cw < chronic allowable but > acute allowable.
Sliver
NC
0.06 AL 1.23
ug/L
53 0
2.5
All data is below detection. Since Ag is_NC_action level
_ _ _
Chronic: --- 3---
standard, recommend quarterly monitoring --------
In pretreatment LTMP. Drop monthly monitoring in permit
Acute: 67
Max Prod. Cw < chronic allowable but > acute allowable.
Zinc
NC
50 AL 67
uglL
54 54
357.6
All tox tests passed since_2003. Since Zn is NC action lave
_ _ _ _ _
Chronic: - 2,450
standard, recommend continuation of monthly monitoring
in NPDES permit
Legend. " Freshwater Discharge
C - Carcinogenic
NC = Non -carcinogenic
A = Aesthetic
25453rpa09.xis, rpa
7/21/2009

REASONABLE POTENTIAL ANALYSIS
Arsenic
Date
Data
BDL=I2DL Results
<
5.0
2.5
Std Dev.
0.2774
Mean
2,4231
C.V.
0.1145
<
5.0
2.5
n
13
Mult Factor =
1.2300
<
5.0
2.5
Max. Value
2.5
Max. Fred Cw
3.1
<
3.0
1.5
<
5.0
2.5
<
5.0
2.5
<
5.00
2.5
<
5.00
25
Mar-2008
<
5.00
25
Jul-2008
<
5.00
25
Sep-2008
<
5.00
25
5.
25
Mar-2009
5.
25
25453rpa09.xls, data
721/2009

REASONABLE POTENTIAL ANALYSIS
3
4
5
Cadmium
Chromium
Data
Data
BDL=IM2DL
Results
Date Data
BDL=I2DL Results
1
<
2.00 1.0
Std Dev.
0.2532
1
<
5.00 2.5 Sid Dev.
0.0000
1
2
Mean
0.6923
2
Mean
2.5000
2
3
C.V.
0.3657
3
C.V.
0.D000
3
4
<
2.00 1.0
n
13
4
<
5.00 2.5 n
13
4
5
5
5
6
Mutt Factor=
1.8900
6
Mutt Factor =
1.0000
6
7
<
2.00 1.0
Max. Value
1.0 uglL
7
<
5.00 2.5 Max. Value
2.5 ug4
7
8
Max. Pred Cw
1.9 ug/L
8
Max. Pred Ow
2.5 ug/L
8
9
9
9
10
<
2.00 1.00
10
<
5.00 25
10
11
11
11
12
12
12
13
<
2.00 1.00
13
<
5.00 2.5
13
14
<
1.00 0.50
14
<
5.00 2.5
14
15
<
1.00 0.50
15
<
5.00 2.5
15
16
<
1.00 0.50
16
<
5.00 2.5
16
17
Mar-2008
<
1.00 0.50
17
Mar-2008 <
5.00 2.5
17
18
Jul•2008
<
1.00 0.50
18
Ju1.2008 <
5.00 2.5
18
19
<
1.00 0.50
19
<
5.00 2.5
19
20
<
1.00 0.50
20
5. 2.5
20
21
<
1.00 0.50
21
®
5. 2.5
21
22
22
22
23
23
23
24
24
24
25
25
25
26
26
26
27
27
27
28
28
28
29
29
29
30
30
30
31
31
31
32
32
32
33
33
33
34
34
34
35
35
35
36
36
36
37
37
37
38
38
38
39
39
39
40
40
q
40
41
41
41
42
42
42
43
43
43
44
44
44
45
45
45
46
46
46
47
47
47
48
48
48
49
49
49
50
50
50
51
51
51
52
52
52
53
53
53
54
54
54
55
55
55
56
56
66
57
57
57_;
58
r
58
58
_2_
25453rpa09.xis, data
721/2009

REASONABLE POTENTIAL ANALYSIS
1 6 II 8
Copper
Cyanide
Date
Data BDL=1/2DL Results
Date
Data
BDL--1/2DL
Results
38.30 38.3
Sid Dev.
7.5570
1
Dec-2007
<
5.00
5.0
Std Dev.
0.0000
1
2.00 2.0
Mean
7.6094
2
<
5.00
5.0
Mean
5.0000
2
2,00 2.0
C.V.
0.9931
3
C.V.
0.0000
3
2.00 2.0
n
54
4
n
14
4
2.00 2.0
5
<
5.00
5.0
5
2.00 2.0
Mult Factor =
2.1700
6
Mutt Factor =
1.0000
6
2.00 2.0
Max. Value
38.3 ug/L
7
Max. Value
5.0 uglL
7
5.94 5.8
Max. Pred Cw
83.1 ug/L
8
<
5.00
5.0
Max. Fred Cw
5.0 ug/L
8
2.00 2.0
9
<
5.00
6.000
9
2.00 2.0
10
<
5.00
5.000
10
2.00 2.0
11
11
37.00 37.0
12
<
5.00
5.000
12
2.00 2.0
13
<
5.00
5.000
13
24.00 24.0
14
<
5.00
5.0
14
2.00 2.0
15
Mar-2008
<
5.00
5.0
15
10.10 10.1
16
Jul-2008
<
5.00
5.0
16
6.60 6.6
17
<
5.00
5.0
17
4.83 4.8
18
<
5.00
5.0
18
10.10 10.1
19
<
5.00
5.0
19
7.64 7.6
20
20
2.00 2.0
21
21
14.00 14.0
22
22
2.00 2.0
23
23
2.00 2.0
24
24
Dec-2007
10 10.0
25
25
14 14.0
26
26
13 13.0
27
27
16 16.0
28
28
16 16.0
29
29
12 12.0
30
30
5 2.5
31
31
11 11.0
32
32
10 5.0
33
33
10 5.0
34
34
10 5.0
35
35
10 5.0
36
36
12 12.0
37
37
Feb-2008
3 3.0
38
38
4 4.0
39
39
Mar-2008
5. 5.0
40
40
41
41
5. 5.0
42
42
11. 11.0
43
43
44
44
8. 8.0
45
45
4. 4.0
46
46
47
47
Aug-2008
6. 6.0
48
48
5 5.0
49
49
5 5.0
50
50
7 7.0
51
51
4 4.0
52
52
Jan-2009
4 4.0
53
53
5 5.0
54
54
9 9.0
55
55
7 7.0
56
56
6 6.0
57
57
58
58
25453rpa09.xls, data
-3- 7/21/2009

REASONABLE POTENTIAL ANALYSIS
9
10
Lead
Mercury
Data
Data
BDL=I2DL Results
Date
Data
BDL=1/2DLResults
<
5.00
2.5
Std Dev.
0.0000
1
<
0.20 1.0
Std Dev.
0.0000
1
Mean
2.5000
2
Mean
1.0000
2
C.V.
0.0000
3
C.V.
0.0000
3
<
5.00
2.5
n
15
4
<
0.20 1.0
n
12
4
5
5
Mull Factor =
1.0000
6
Mull Factor=
1.00
6
<
5.00
2.5
Max. Value
2.5 ug/L
7
<
0.20 1.0
Max. Value
1.0 ng/L
7
Max. Pred Cw
2.5 ug/L
8
<
0.20 1.0
Max. Pred Cw
1.0 ng/L
6
9
<
0.20 1.0
9
<
5.00
2.5
10
<
0.20 1.0
10
<
5.00
2.5
11
<
0.20 1.0
11
<
5.00
2.5
12
Mar-2008
<
0.20 1.0
12
<
5.00
2.5
13
Jul-2008
<
0.20 1.0
13
<
5.00
2.5
14
<
0.20 1.0
14
<
5.00
2.5
15
0.38 1.0
15
<
5.00
2.5
16
Mar-2009
<
0.20 1.0
16
Mar-2008
<
5.00
2.5
17
17
Jul-2008
<
5.00
2.5
18
18
<
5.00
2.5
19
19
5.
2.5
20
20
5.
2.5
21
21
25453rpa09.xls, data
.4- 7/21/2009

REASONABLE POTENTIAL ANALYSIS
11
#
13
Molybdenum
Nickel
Date
Data
BDL=I2DL Results
Date Data
BDL=I2DL Results
<
100.00 50.0 Std Dev.
17.09
1
<
10.0
5.0
Std Dev.
0.0000
1
1
<
5.00 2.5 Mean
11.54
2
Mean
5.0000
2
2
C.V.
1.48
3
C.V.
0.0000
3
3
n
13
4
<
10.00
5.0
n
12
4
4
<
100.00 50.0
5
5
5
Mult Factor =
6.9300
6
Mult Factor =
1.0000
6
6
Max. Value
50.0 ug/L
7
<
10.0
6.0
Max. Value
5.0 ug/L
7
7
<
5.00 2.5 Max. Pred Cw
346.5 ug/L
8
<
10.0
5.0
Max. Pred Cw
5.0 ug4-
8
8
<
10.0 5.0
9
<
10.0
5.0
9
9
<
10.0 5.0
10
<
10.0
5.0
#
10
<
10.0 5.0
11
<
10.0
5.0
#
11
<
10 5.0
12
10
5.0
#
12
Mar-2008
<
10 5.0
13
Mar-2008
10
5.0
#
13
Jul-2008
<
10�5.0
14
Jul-2008
5.0
#
14
<
10 5.0
15
5.0
#
15
<
10 r 5.0
16
5.0
#
16
<
10 5.0
17
#
17
18
#
18
19
#
19
20
#
20
21
#
21
22
#
22
23
#
23
24
#
24
25
#
25
26
#
26
27
#
27
28
#
28
29
#
29
30
#
30
31
#
31
32
#
32
33
#
33
34
#
34
35
#
35
36
#
36
37
#
37
38
#
38
39
#
39
40
#
40
41
It
41
42
#
42
43
#
43
44
#
44
45
#
45
46
#
46
47
#
47
48
#
48
49
#
49
50
#
50
51
#
51
52
#
52
53
#
53
54
#
54
55
#
55
56
#
56
57
#
57
58
#
58
25453rpa09.xls, data
-5. 7/21/2009

REASONABLE POTENTIAL ANALYSIS
14
15
Selenium
Silver
Date Data
BDL=I2DL Results
Date
Data
BDL=I2DL Results
<
2.00 1.0
Std Dev.
2.0181
1
<
5.00 2.5
Std Dev,
0.0000
1
Mean
3.5455
2
<
5.00 2.5
Mean
2.5000
2
C.V.
0.5692
3
<
5.00 2.5
C.V.
0.0000
3
<
2.00 1.0
n
11
4
<
5.00 2.5
n
63
4
5
<
5.00 2.5
5
Mult Factor =
2.7700
6
<
5.00 2.5
Mult Factor =
1.0000
6
. <
zoo 1.0
Max. Value
5.0 ug4-
7
<
5.00 2.5
Max. Value
2.5 ug/L
7
<
2.00 1.0
Max. Fred Cw
13.9 ug/L
8
<
5.00 2.5
Max. Pred Cw
2.5 ug/L
8
<
10.00 5.0
9
<
5.00 2.5
9
<
10.00 5.0
10
<
5-00 2.5
10
<
10.0 5.0
11
<
5.00 2.5
11
Mar-2008
10 5.0
12
<
5.00 2.5
12
Jul-2008
5.0
13
<
5.00 2.5
13
5.0
14
<
5.00 2.5
14
5.0
15
<
5.00 2.5
15
16
<
5.00 2.5
16
17
<
5.00 2.5
17
18
<
5.00 2.5
18
19
<
5.00 2.5
19
20
<
5.00 2.5
20
21
<
5.00 2.5
21
22
<
5.00 2.5
22
23
<
5.00 2.5
23
24
<
5.00 2.5
24
25
Dec-2007
<
5.00 2.5
25
26
<
5.00 2.5
26
27
<
5.00 2.5
27
28
<
5.00 2.5
28
29
<
5.00 2.5
29
30
<
5.00 2.5
30
31
<
5.00 2.5
31
32
<
5.00 2.5
32
33
<
5.00 2.5
33
34
<
5.00 2.5
34
35
<
5.00 2.5
35
36
<
5.00 2.5
36
37
Feb-2008
<
5.00 2.5
37
38
<
5.00 2.5
38
39
5. 2.5
39
40
40
41
<
5. 2.5
41
42
<
5. 2.5
42
43
43
44
<
5. 2.5
44
45
<
5. 2.6
45
46
46
47
Aug-2006
<
5. 2.5
47
48
<
5. 2.5
48
49
<
5. 2.5
49
50
<
5. 2.5
50
51
<
5. 2.5
51
52
Jan-2009
<
5. 2.5
52
53
<
5. 2.5
53
54
Mar-2009
<
5. 2.5
54
55
<
5. 2.5
55
56
<
5. 2.5
56
57
57
58
58
25453rpa09.xls, data
-6- 7/21/2009

REASONABLE POTENTIAL ANALYSIS
Zinc
Date
Data BDL=1/2DL Results
144.0
144.0
Std Dev.
89.6
89.6
Mean
59.2
59.2
C.V.
71.2
71.2
n
51.0
51.0
107.0
107.0
Mult Factor=
85.6
85.6
Max. Value
97.0
97.0
Max. Fred Cw
110.0
110.0
95.6
95.6
98.1
98.1
161.0
161.0
75.0
75.0
157.0
157.0
104.0
104.0
124.0
124.0
109.0
109.0
156.0
156.0
136.0
136.0
80.6
80.6
102.0
102.0
88.0
88.0
80.5
80.5
56.0
56.0
Dec-2007
162
162.0
175
175.0
99
99.0
144
144.0
138
138.0
Aug-2007
246
246.0
158
158.0
138
138.0
165
165.0
72
72.0
92
920
159
159.0
93
93.0
Feb-2008
107
107.0
137
1
137.0
152.
152.0
143.
143.0
261.
261.0
191.
191.0
140.
140.0
Aug-2008
97.
97.0
119
119.0
Oct-2008
104
104.0
139
139.0
Dec-2008
178
178.0
Jan-2009
135
135.0
176 176.0
110 110.0
83 83.0
113 113.0
43.0466
123.3963
0.3488
54
1.3700
261.0
357.6
25453rpa09.x1s, data
7- 7/21/2009

v
NCDEWR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue
Governor
Coleen H. Sullins
Director
August 12, 2009
To: Michael L. Douglas, P.E.
NC DENR / DEH / Public Water Supply Section Regional Engineer
Raleigh Regional Office
From: Jackie Nowell.
NPDES Western Program
Subject: Review of Draft Permit NCO025453
Clayton — Little Creek Water Reclamation Facility
Johnston County
Dee Freeman
Secretary
Please indicate below your agency's position or viewpoint on the draft permit and return this form by August 26,
2009. If you have any questions on the draft permit, please contact me at 919-807-6386 or e-mail to
[e-mail].
RRRRRRRRRRRRRRRRRRRRaRRRRRRRRRRRRRRRRRRRR
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:
Si ed/�L, Date:
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 One
Phone: [phone] t FAX: [phone] Customer Service: 1-877-623-6748 Nor. th Car. o:lina
Internet: wuvw.ncwaterquality.org y�� l//�
An Equal Opportunity ! Affirmative Action EmNatu
ployer 6

AFFIDAVIT OF PUBLICATION
NORTH CAROLINA.
Wake County. Ss.
ENVI KUNMhN 1A1_ NWVMUa ruI LtXW'I11oolV
SUBJECT:
The North Carolina Environmental Management Commission Proposes to issue the
following NPDES wastewater discharge Permits. The Commission is 1pviting public
comment on the draft Permits, and a public hearing has been schedu ml to provide
additional opportunity. for comments: "
- Permit number NC0003760: E. I. DuPont de Nemours and Co., Inc. has applied for
renewal of its permit far its Kinston Facility [mated near Kinston (Lenoir County) far
- the discharge of treated Industrial wastewater into the Neuse Riverand the discharge
of 5tormwate, and cooling water into Bmverdam Branch and unnamed tributaries.
Currently,certain OCPSF parameters,mercury, total nitrogen, and total residual
chlorine are wafer quality -limited Parameters.
Permit number NC003in 6: Johnston County has requested modification of its permit
for the Central Johnston County Wastewater Treatment Facility located near Smith.
field (Johnston County) for the discharge of treated municipal wastewater Into the
Neuse River. Currently, BOD, ammonia nitrogen, total nitrogen, and total residual
chlorine are water quality -limited parameters.
jPermit number NCONU53: The Town of Clayton has applied for renewal of its Permit
or the Little Creek Wastewater Reclamation Facility located in Clayton (Johnston
.County) for the discharge of treated municipal wastewater into the Neuse River.
Currently, BOO, ammonia nitrogen, total nitrogen, and total residual chlorine are
water gmlity-limited parameters.
Ali threp
Permit actions include changes in nitrogen limits reflecting the transfer of
nitrogen allocation among the permiftees consistent with the Neuse River Basin Nutrient
Management Strategy.
These discharges may affect discharge allowances in the watershed.
., ...,., ...I ....... .
PROCEDURE: Written comments regarding the Proposed Permit will be accepted until
30 days after the Publish date of this notice. Please mail comments to the DWO/ NPDES
Unit, 1617 Moil Service Center Raleigh, NC 27699.1617. Additional comments may be
submitted at the Public hearing. The hearing will be conducted in the following manner:
1. An explanation of the North Carolina Environmental Management Commission's
Permitting Procedure will be Presented by the Division of Water quality.
2. An explanation of the action for which each permit is required may be made by the
applicant.
3. Public Comment - Comments, statements, data and other Information may be
submitted in writing prior to or during the hearing or may be Presented orally m the
hearing. Persons desiring to speak will indicate this Intent of the time of registration
at the hearing. So that all Persons deslrin5 to speak may do so, lengthy statements
may be limited at the discretion of the hearing officer. Oral Presentations that exceed
three minutes should be accompanied by three written copies, which wl II be flled with
Division staff at the time of registration.
d. C rocs examination of Persons Presenting testimony wi l l not be allowed; however, the
hearing officer may ask questions for clarification. ,
5. Thehearing record may beclosed aftee coact usion of the hearing.
WHEN: Seplember29, 2009a17:00 p.m.
WHERE: Wayne County Public Library
Gertrude Weil Auditorium
IM1 East Ash Street
Goldsboro, North Carolina 27530 -
INMRMATION: A cmy of the draft NPDES permits and a map showing the locations of
the discharges are available by writing or calling:
Ms. Din. Sprinkle
NC Division of Water Quolitv7 NPOES Unit
.- 1617 Mail Service Center
Raleigh, North Carolina 27699-1617 -
Telephone number: (919) gNL30,1
Before the undersigned, a Notary Public of Chatham
County North Carolina, duly commissioned and authorized to
administer oaths, affirmations, etc., personally appeared Debra
Peebles, who, being duly swom or affirmed, according to law,
doth depose and say that she is Accounts Receivable Specialist
of The News and Observer a corporation organized and doing
business under the Laws of the State of North Carolina, and
publishing a newspaper ]mown as The News and Observer, in
the City of Raleigh , Wake County and State aforesaid,
the said newspaper in which such notice, paper, document, or
legal advertisement was published was, at the time of each and
every such publication, a newspaper meeting all of the
requirements and qualifications of Section 1-597 of the
General Statutes of North Carolina and was a qualified
newspaper within the meaning of Section 1-597 of the General
Statutes of North Carolina, and that as such she makes this
affidavit; that she is familiar with the books, files and business
of said corporation and by reference to the files of said
publication the attached advertisement for NC DIVISION OF
WATER QUALrIY was inserted in the aforesaid newspaper
on dates as follows: 08/15/09
Account Number: 73350833
books and files of the aforesaid Corporation and publication.
Debra Peebles, Accounts Receivable Specialist
Wake County, Notch Carolina
Sworn or affirmed to, and subscribed before me, this
17 day of AUGUST , 2009 AD ,by Debra Peebles.
In Testimony Whereof, I have hereunto set my hand
and affixed my official seal, the day and year aforesaid.
Wanet Scroggs, Notary Public
My commission expires 14" of March 2014.

Town of Clayton TN Loads
(2006 - 2009)
Date
Total Nitrogen (lbs/day)
TN Load Limit
Difference
Jul-09
1350
Jun-09
806.3
May-09
1111.
Apr-09
1582
Mar-09
2145
Feb-09
2158
Jan-09
1595
10747.3
21400
2008
19673
21400
-1727
2007
16976
21400
-4424
2006
17678
21400
-3722
1
4

NPDES REGIONAL WATER QUALITY
STAFF REPORT AND RECOMMENDATIONS
(This form is best filled out on computer, rather than hard copy. Then unprotect to
highlight in light blue as needed to make your comments more visible in the final printing.)
[But DON'T protect document again, or Word wipes out all you have entered.]
Date: /2008 County:'
To: NPDES Discharge Permitting Unit Perm'tee:
Water Reclamation Facie
Attn. NPDES Reviewer:Application/ Permit No.1kQ0025453
Staff Report Prepared By: Wh Haves
Project Name:
SOC Priority Project? (Y/N) _ If Yes, SOC No.
A. GENERAL INFORMATION
L This application is (check as that apply): ❑ New ® Renewal
❑ Modification
2. Was a site visit conducted in order to prepare this report? ® Yes or ❑ No.
a. Date of site visit: 12/17/2007
b. Person contacted and telephone number: James O. Warren 919.553.1536
c. Site visit conducted by: Mitch Hayes
d. Inspection Report Attached: ® Yes or ❑ No.
3. Keeping BRAS Accurate: Is the following BIMS information (a. through e. below) correct?
® Yes or ❑ No. If No, please either indicate that it is correct on the current application or the
existing permit or provide the details. If none can be supplied, please explain:
Discharge Point: (Fill this section only if BIMS or Application Info is incorrect or missing)
(If there is more than one discharge pipe, put the others on the last page of this form.)
a. Location OK on Existing Permit ®, OR, if not, is
OK on Application ❑, or if neither is right, provide Location:
b. Driving Directions OK on Existing Permit ®, OR, if not, is
OK on Application ❑, or provide Driving Directions (please be accurate):
c. USGS Quadrangle Map name and number OK on Existing Permit ®, OR, if not, is
OK on Application ❑, or provide USGS Quadrangle Map name and number:
d. Latitude/Longitude OK on Existing Permit ®, (check at http://w .topozone.com These are
often inaccurate) or is OK on ApplicationEl, or provide Latitude: Longitude:
e. Receiving Stream OK on Existing Permit ®, OR, if not, is
OK on Application ❑, or provide Receiving Stream or affected waters:
a. Stream Classification: WS-IV NSW
b. River Basin and Sub basin No.: 03-04-02

NPDES REGIONAL WATER QUALITY
STAFF REPORT AND RECOMMENDATIONS
c. Describe receiving stream features and downstream uses: Receiving stream is the Neuse
River. Immediately downstream use is the water supply for the Johnston County Water Plant
and the City of Smithfield.
For NEW FACILITIES Proceed to Section C. Evaluation and Recommendations
(For renewals or modifications continue to section B)
B. DESCRIPTION OF FACILITIES AND WASTE(S) (renewals and modifications only)
1. Describe the existing treatment facility: The 2.5 MGD water reclamation facility consists of the
following units: influent head works with a FRP cover system and odor control system including
mechanical screening and a vortex type grit removal system; influent pump station with ultrasonic flow
meter with back-up float alarm; a new 214,500 gallon anaerobic basin in front of oxidation basin # 2; a
new 300,000 gallon anoxic tank in front of oxidation basin # 2; a new 200,000 gallon anoxic in front of
oxidation basin # 1; three (3) secondary clarifiers; two shallow bed DAVCO traveling bridge type
tertiary filters; UV disinfection with back-up chlorination / dechlorination; effluent pump station; one
existing 90,000 gallon aerated digester/sludge stabilization tank; one new aerated 360,000 gallon sludge
holding tank; one existing aerated 360,000 gallon sludge holding tank; sludge loading station; a new
sludge thickening building containing a rotary drum thickener; sludge drying beds; in -plant non -potable
water system using reclaimed treated wastewater; a reclaimed water pump station and transmission
force main to the Pine Hollow Golf Course (scheduled completion 02/06/2008). Sludge drying beds are
not used. The clerigester, trickling filter, and secondary clarifier of the original plant are not in use and
are abandoned.
2. Are there appropriately certified ORCs for the facilities? ® Yes or ❑ No.
Operator in Charge: James O. Warren Certificate # WW-4 / 7149 (Available in BIMS or
Certification Website)
Back- Operator in Charge: Leigh S. Honeycutt Certificate # WW-3 / 6738
3. Does the facility have operational or compliance problems? Please comment: There are currently no
operational or complaance problems.
Summarize your BIMS review of monitoring data (Notice(s) of violation within the last permit cycle;
Current enforcement action(s)): There has been one NOV issued for exceeding monthly Total
Nitrogen by 0.01 mg/l.for April 2005.
Are they currently under SOC, ❑ Currently under JOC, ❑ Currently under moratorium ❑? Have
all compliance dates/conditions in the existing permit, SOC, JOC, etc. been complied with? ❑ Yes
or ❑ No. If no, please explain:
4. Residuals Treatment: PSRP ® (Process to Significantly Reduce Pathogens, Class B) or
FORM: NPDES-RRO 06/03, 9/03, 1/07 2

NPDES REGIONAL WATER QUALITY
STAFF REPORT AND RECOMMENDATIONS
PFRP ❑ (Process to Further Reduce Pathogens, Class A)?
Are they liquid or dewatered to a cake? liquid
Land Applied? Yes ® No ❑ If so, list Non -Discharge Permit No. W00023178 - Town of Clayton
Land Application Permit
Contractor Used: GFI Residuals Land Application
Program WQ0000838 as a back-up.
Landfilled? Yes ❑ No® If yes, where?
Other?
Adequate Digester Capacity? Yes ® No ❑ Sludge Storage Capacity? Yes ® No ❑
Please comment on current operational practices: Sludge is dewatered using rotary drum thickner.
Filtrate is recycled back to headworks. Thickned sludge is stored in aerated sludge holding tanks.
Thickned sludge is pumped into trucks at the sludge loading station. Sludge is land applied according
to Town of Clayton Land Application Permit W00023178.
5. Are there any issues related to compliance/enforcement that should be resolved before issuing this
permit? ❑ Yes or ® No. If yes, please explain:
C EVALUATIONAND RECOMMENDATIONS
1. Alternative Analysis Evaluation: has the facility evaluated the non -discharge options available? Give
regional perspective for each option evaluated:
Spray Irrigation:
Connect to Regional Sewer System:
Subsurface:
Other Disposal Options: In -plant non -potable water using treated wastewater effluent is utilized
throughout the plant under permit WQ0024223. The reuse generation distribution line and pump station
with force main to the Pine Hollow Golf Course is covered under permit WQ22224.
2. Provide any additional narrative regarding your review of the application: Application list wrong
permit number and contract sludge hauler. WQ0000506 was rescinded 05/28/2004. Sludge is land
applied according to the Town of Clayton Land Application Permit W00023178. Back-up contractor
for sludge application is covered under GFI Residuals Land Application Program permit number
W00000838 not W00004801 as listed in the permit.
3. List any items that you would like NPDES Unit to obtain through an additional information
request. Make sure that you provide a reason for each item:
FORM: NPDES-RRO 06/03, 9/03, 1/07

Michael F. Easley, Governor
co r
O
January 10, 2008
Mr. R. Stephen Biggs, Town Manager
Town of Clayton
P.O. Box 879
Clayton, North Carolina 27520
William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
Subject: Compliance Evaluation Inspection
Town of Clayton Little Creek WRF
NPDES Permit No. NCO025453
Stormwater Permit NCG110080
Johnston County
Dear Mr. Biggs:
Coleen H. Sullins, Director
Division of Water Quality
On December 17, 2007 Mitch Hayes of the Raleigh Regional Office conducted a compliance
evaluation inspection of the subject facility. The assistance of James Warren grade WW-4 Operator in
Responsible Charge (ORC) with this inspection was gratefully appreciated. Please find the attached
Basin Wide Information Management System (BIMS) inspection checklist summarizing each
inspection. Below is a list of recommendations and findings developed from the inspection:
1. The subject permit was modified and became effective November 01, 2006 and will expire
March 31, 2008. A permit renewal application was received on October 11, 2007 and is currently
under review. Please continue to operate under the last issued permit until a new permit is issued.
2. The 2.5 MGD water reclamation facility consists of the following units: influent head works with
a FRP cover system and odor control system including mechanical screening and a vortex type
grit removal system; influent pump station with ultrasonic flow meter with back-up float alarm; a
new 214,500 gallon anaerobic basin in front of oxidation basin # 2; a new 300,000 gallon anoxic
tank in front of oxidation basin # 2; a new 200,000 gallon anoxic in front of oxidation basin # 1;
three (3) secondary clarifiers; two shallow bed DAVCO traveling bridge type tertiary filters; LTV
disinfection with back-up chlorination / dechlorination; effluent pump station; one existing
90,000 gallon aerated digester/sludge stabilization tank; one new aerated 360,000 gallon sludge
holding tank; one existing aerated 360,000 gallon sludge holding tank; sludge loading station; a
new sludge thickening building containing a rotary drum thickener; sludge drying beds; in -plant
non -potable water system using reclaimed treated wastewater; a reclaimed water pump station
and transmission force main to the Pine Hollow Golf Course (scheduled completion 02/06/2008)
and two on -site generators to provide back-up power. The clerigester, trickling filter, and
secondary clarifier of the original plant are not in use and are abandoned.
3. At the time of inspection, the aerated digester was being used to store scum from the clarifiers.
The two aerated sludge holding tanks were approximately 50% full. Sludge hauling was to begin
early January 2008. Clarifier # 1 was offline due to low influent flow. Sludge judge readings for
North Carolina Division of Water Quality Raleigh Regional Office Surface Water Protection Phone [phone] Customer Service
Internet www.ncwatemualitv.ore 1628 Mail Service Center Raleigh, NC 27699-1628 FAX [phone].623.6748
An Equal Opportunity/Affirmative Acton Employer— 50% Recycled/10% Post Consumer Paper

Little Creek WRF CEI
Page 2�
clarifier # 2 was 3 feet and clarifier # 3 was 1 foot with both clarifiers having sidewall depths of
14 feet. Effluent appeared clear flowing evenly over the weirs with no blockage. There was no
scum noted in either clarifier. The rotary drum thickener was not being operated at the time of
inspection. Effluent flowing off the tertiary filters appeared clear with no foam or odor. Each
effluent turbine pump is scheduled to be rebuilt. Excavation around the three effluent turbine
pumps has already begun. The effluent discharge pipe was submerged at the time of inspection.
Effluent appeared clear discharging into the Neuse River with no negative impacts.
4. Biosolids are land applied under the Town of Clayton Land Application Permit WQ0023178.
Granville Farms is designated the back-up hauler to land apply biosolids under the GFI Residuals
Land Application Program under permit WQ0000838.
5. In -plant non -potable water using treated wastewater effluent is utilized throughout the plant
under permit WQ0024223. The reuse generation distribution line and pump station with force
main to the Pine Hollow Golf Course is covered under permit WQ22224. Reuse, reclaim water,
and land application permits are currently managed by the Aquifer Protection Section.
6. The laboratory was checked in a cursory manner. All instrument calibration logs are being
maintained on computer. An operator's logbook was available and being maintained. Fecal
coliform bath temperature was 44.6 degrees C and the drying oven temperature was 106 degrees.
The influent and effluent flow meters were calibrated October 07, 2007. Influent sampler
temperature was 2 degrees C. and the effluent sampler temperature was 3 degrees C.
7. Discharge Monitoring Reports (DMR's) for the period December 2006 to September 2007 were
reviewed for compliance with permit limits and monitoring requirements. The BIMS computer is
flagging monitoring violations for chronic toxicity for 12/2006, 03/2007, 06/2007, and 09/2007.
These violations appear to be caused by using the code THP3B for reporting pass/fail results for
chronic toxicity. Please use the code TGP3B when reporting pass/fail results for chronic toxicity.
Monitoring violation for silver was recorded for 01/2007. A pH value of 73 was recorded
05/07/2007 most likely should have been recorded as 7.3. Total residual chlorine is reported as
exceeding the permit limit on 09/06/2007, 09/27/2007, and 09/28/2007. This is reported under
the column TOTAL RESIDUE parameter code 00500. Currently the Little Creek WRF has no
parameter listed however, there is a total suspended residue listed. Please clarify and send in an
amended September 2007 DMR. The annual pollutant scan that is attached to the September
2007 DMR list the Total Residual Chlorine (TRC) result as 12 ug/l. The grab sample for the
TRC analyses was taken 08/23/2007 lists the results on the August 2007 DMR as 0.12ug/l.
Please clarify the August 2007 TRC result and send in an amended DMR. There were no other
violations listed for the review period.
8. Commercial lab results, chain of custody records, and bench sheets were compared with data
submitted on the DMR for the month of September 2007. No discrepancies were noted.
Stormwater Permit NCG110062
9. Inspection of the stormwater outfalls and plant site was conducted at the same time as the CEI
wastewater treatment plant. Permit NCG110062 was issued and became effective on June 27,
2003 and will expire on April 30, 2008.
10. There are three outfalls listed for the facility:
a) Outfall 001 consists of drainage from the return sludge pump station; on -site generator
area, chlorine contact chamber and effluent pump station. Flow is conveyed by concrete

Little Creek WRF CEI
Page 3
pipe and discharges to a small drainage ditch behind the on -site generator and tertiary
filter structure. There was no discharge at the time of inspection. Water in the drainage
ditch appeared clear.
b) Outfall 002 receives drainage from the grassy area in front of oxidation basin number 1,
the area in front of the aerobic digester; chemical feed building, the area around the
sludge holding tanks and the sludge loading station. These combined flows discharge into
a small ditch. There was no discharge at the time of inspection. Water in the ditch
appeared muddy most likely from recent rains.
c) Outfall 003 receives flow from the on -site generator and fuel tank behind the operations
building, and area near the aerobic digester. The combined flows discharge to low lying
area across from the right side of the operations building.
d) Outfall 004 receives flow from the parking lot and in front of the operations building.
The discharge point is across the street into a small ditch. There was no discharge at the
time of inspection. There was no water in the ditch.
e) Outfall 005 receives stormwater flow from the area around the influent pump station and
the reclaimed water pump station. Combined flows discharge to a low-lying area east of
the influent pump station. There was no discharge at the time of inspection. Water at the
discharge point appeared clear.
f) Outfall 006 is located near the tertiary filter structure. The drainage area around the return
sludge pump and secondary clarifier number 1 and 2 discharge into outfall 006. At the
time of inspection a sediment trap had been constructed from crushed stone in front of the
discharge point. Outfall 006 discharges into a wooded area. There was no discharge at the
time of inspection.
11. Qualitative monitoring for all outfalls was conducted on June 27, 2007 and December 12, 2007.
There is no vehicle maintenance done on site. There have been no spills for the 2006-2007 year.
The stormwater pollution prevention control plan was amended in 2007. Annual employee
training on spill prevention and response occurred on December 13, 2007.
I would like to thank James Warren for his time and assistance with this inspection. If you have
any question concerning the inspection or the checklists, please contact me at 919.791.4261.
Sincerely,
Mao, M�
Mitch Hayes
Environmental Specialist
Cc: Central Files
Permit Files

NPDES REGIONAL WATER QUALITY
STAFF REPORT AND RECOMMENDATIONS
Recommended Additional Information Reason
4. List specific Permit requirements that you recommend to be removed from the permit when
issued. Make sure that you provide a reason for each condition:
Recommended Removal
Reason
Remove from permit descripton The clerigester,
trickling filter, and secondary clarifier of the
original wastewater treatment plant.
These units are not in use and have been
abandoned.
Remove from permit description reference to
sludge drying beds.
These units are no longer used for sludge
drying.
5. List specific special requirements or compliance schedules that you recommend to be included in
the permit when issued. Make sure that you provide a reason for each special condition:
6. Recommendation: ❑ Hold, pending receipt and review of additional information by regional office;
❑ Hold, pending review and approval of required additional information by NPDES permitting
office; ® Issue; ❑ Deny. If deny, please state reasons:
Reminder: attach inspection report if Yes was checked for 2 d.
7. Signature of report preparer:
Signature of WQS regional supervisor:
i
Date:
D. ADDITIONAL REGIONAL STAFF RE VIEW ITEMS
Please use new description of water reclamation process units. See B (1)
t
FORM: NPDES-RRO 06/03, 9/03, 1/07

Clayton, NCO025453
A.(1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
EFFLUENT
CHARACTERISTICS
EFFLUENT LIMITATIONS
MONITORING REOUIREMENTS
Monthly
Average
Weekly
Average
Daily
Maximum
Measurement
Frequency
Sample
Type
Sample
Location 1'I
TN Load r'1
Monitor & Report (lb/mo)
Monthly Calculated E
21,400 Ib/yr (through 12/31/09)
22,831 Ib/yr (effective 1/1/10) (4)
Annually Calculated E
A.L.) TOTAL NITROGEN ALLOCATIONS
a. The following table lists the Total Nitrogen (TN) allocation(s) assigned to, acquired by, or
transferred to the Permittee in accordance with the Neuse River nutrient management rule (T15A
NCAC 0213.0234) and the status of each as of permit issuance. For compliance purposes, this table
does not supersede any TN limit(s) established elsewhere in this permit or in the NPDES permit of
a compliance association of which the Permittee is a Co-Permittee Member.
ALLOCATION
ALLOCATION AMOUNT (1)
TYPE
SOURCE
DATE
STATUS
Estuary (Ibtyr)
Discharge (Ibtyr)
Base
Assigned by Rule
12f7/97;
10,700
21,400
Active
(T15A NCAC 02B .0234)
4/1/03
Supplemental
Purchased from
3,668
7,336
Reserve
SGWASA, N00026824
Supplemental
Purchased from UNIFI-
8/30/2007
1,645
3,290
Mixed
Kinston,NC0003760
%e6
y3z
Active
QZ% 929
i9a ' 1,81A
Reserve
TOTAL
16,013
32,02 a
Mixed
11,415#
22,830
Active
%'i
46111W
Reserve
Footnote: S i
(1) Transport Factor = 50%
Town of Clayton
NPDES No. NCO025453
11

Jackie and Ron - Here is the text I used in my cover letter to address the public notice, due
date for comments, etc. You will need to customize the shaded text to fit your permit. Let me
know if I missed anyone on the CC: list. Note that we will enclose a copy of the notice text —
saves us having to enter the details in the letter.
At this time, the Division is submitting a notice to the newspaper(s) of general
circulation in Johnston County, inviting public comment on the draft permit. In
addition, the Neuse Riverkeepers have requested a public hearing regarding the
County's permit and the permits for the Town of Clayton and the DuPont -Kinston
facility (formerly UNIFI). The hearing will be held at 7 p.m. on September 29, 2009, in
Goldsboro. The Division will issue a single notice for the three permits and the public
hearing. The notice is scheduled for publication on or about August 14 and initiates a 30-
day comment period. Please provide any comments you have regarding the draft
permit to this office, in writing, no later than 30 days of receipt of this letter. You will
have the opportunity to provide additional comments at the hearing.
Following the hearing, the hearing officers will review all pertinent comments received
during the comment period and at the hearing and will recommend appropriate action
on the permits to the Director.
If you have any questions concerning the draft permit, please contact me at (919) 807-
6402 or at mike. templeton@ncdenrgov.
Sincerely,
Original signed by
Michael E. Templeton, P.E.
Point Source Branch
Enclosure: Draft permit modification, NC0030716
Public Notice text
Copies: Mr. Larry Baldwin, Neuse Riverkeeper (via email)
Ms. Alissa Bierma, Neuse Riverkeeper (via email)
Mr. Haywood Phthisic, Executive Officer, NRCA (via email)
Chief, NPDES and Biosolids Permits Section, Region IV, EPA
Raleigh Regional Office, Surface Water Protection
NPDES Files
And here's the text from the Johnston County fact sheet describing the TN transfers. Again,
you'll need to customize it to fit your permits.
Transfer of Nitrogen Allocations
Johnston County's Central W WTF is located within the Neuse River basin and was
assigned Total Nitrogen (TN) allocation under the Neuse River Basin Nutrient

nr
Management Strategy rule for Wastewater Discharges (T15A NCAC 02B .0234), or "the
Neuse rule." In recent years, the County connected two small County -owned facilities,
and the Division transferred those allocations to the Central facility by modifying its
permit in 2007.
The County has now purchased two additional allocations from existing dischargers.
The allocations are necessary for upcoming expansions of the Central facility.
UNIFI- Kinston. The County purchase 11645 lb/yr estuary allocation from UNIFI-
Kinston (now DuPont -Kinston) in 2007. With a transport factor of 50%, this is equivalent
to a discharge (i.e., end -of -pipe) allocation of 3,2901b/yr.
Town of Benson. The County purchase 3601b/yr estuary allocation from the Town of
Benson, equivalent to a discharge allocation of 7201 /yr.
With these purchases, the total allocation assigned to the Central Johnston County
facility is 71,477 lb/yr at the discharge, equivalent to 35,7391b/yr at the estuary.
ALLOCATION AMOUNT'STATUS
ALLOCATION
TYPE
SOURCE
DATE
Estuary
Discharge
Qb/yr)
Qb/yr)
Base
Assigned by Rule
1217/97;
28,102
56,203
Active
(T15A NCAC 02B .0234)
4/1/03
Supplemental
Connection of White Oak
---
2,816
5,632
Active
Plantation WWTP, formerly
NCO060330
Supplemental
Transfer from Buffalo Creek
---
2,816
5,632
Active
WWTP, formerly NC0064556, per
River Dell/ Heater Utilities
Bulk Service Agreement
Supplemental
Purchase from UNIFI-Kinston,
12121/07
1,645
3,290
Active
NC0003760
Supplemental
Purchase from Town of Benson,
4/2/08
360
720
Active
NCO020389
TOTALS
1 35,739
1 71,477
Active
PERMIT SCHEDULE
The tentative schedule for this permit modification is:
Publication of Notice: August 14, 2009 +
Public Hearing: September 29, 2009
End of 30-Day Public Review Period: September 29, 2009, or as set by Hearing
Officer
Permit Mod. Issued: December 15, 2009
Permit Mod. Effective: January 1, 2010
Permit Expires: March 31, 2013
- end of fact sheet -

NEUSE PERMITTING SUMMARY - NUTRIENTS
NOV 2007
NC0029033
CM of Raleigh
Neuse Rives WWTP
30402
50%
Y
Y
Y.
Bess
Eby RdB((T15ANCAC 02B .0234)
14OW
NA
Pd'ne
33],095
675,I90
fi83,393
1AYeak
FALLS UTILITY CO. WWTFNOSH 2
Igmerly NCW4623]
30402
6n':,
(y126033
Y
$uppbmetal
Cmnectbnd Felb UilM Ca, N00046230
—
NC0046230fl
AdNe
61
121
BOBBY L. MURRAYIPIANTATION INN
IormeM NCW27570
30402
5.r:
Iy129033
Y
Supplemental
Conned'an of PMnblbn lI NCOD27570
--
NCW27570R
Adi✓e
253
506
e: N6605Bi9"
(y)➢9316
Y
Supplemertal
Connection d MAl Run MHP, NC0056499
Pnrbup
NC00564?9fi
..,
455
910
NCO 40B
79J16
Y
Suppannenal
Connection of N.NC608W08
pencl,qq
NCO0 08R
Amve
3033
6.W
Tobl Allocations:
Ad" 341,697 683.393
NODOMn
IY IInO�) I41N3 I I 39I 42211I 4Wee
MNNY pCoadbWanbu NW20362NC206R Ade 9ASTINBROIg0263I5%I 1YI 70
Total Alb ns: AcOve 21.106 42.211
NCO030716
JohmIn County DauL01PubICU6ltiee
Cemnl Johmun CouNy4W1TP
30402
50%
Y
Y
Y.
Sass
Assigned by Rule((T15A NCAC 028.0234)
10�'
NA
Ac4ve
=
28,102
72IXi
]0.]56
Meek
JOHNSTON COUNTY/WHITE OAK
lamely NCOOW330
30402
ry)30716
Y
Supplemental
Connaclbn of While Oak NCOCW330
—
2,816
5,632
JOHNSTONCWNTY/BUFFALO CIff
lamely NC0081558
30108
Iy130]IB
Y
BupplemenWl
luqubAbnd Bdlab Creek, NC0084558
—
Aaive
2,816
5.632
UNIFI Klrmoe
from NCM7W
30405
Y
Su Iemenbl
PmehuaBan UNIFI40 NC=37W
Pendln
NC60037W.502
Aahe
Lfi45
31S0
Total Albcalbns:
Active 35,W8 70.756
NC=759 C@70f ReMipIl Smith Creek WWTP I SIM 1 50% 1 Y Y I Y. Bess Assigned by Rule l(T15A NCAC 078.0734) I 1d1N'3' NA Active 33.M 67,579 70.814 1AVeek
NCW488I9
wmdCery
NOM Ce7 WRF
30402
50%
Y
Y
Ys
Bane
Assgnedby Rda NT15ANCACC2B.0234)
1��'
NA
Adiva
67,5]9
735,750
1/3,246
1Nyeak
MORRISVILtE,TOWN OF
larmety N0005OD41
37402
..
(V)JBBi9
Y
$uyplemenbl
Cannedbn of Monisvilb, NC0050041
—
N00050041P
Arrive
2,022
4.044
MORRISVILLE WNTP TOWNOF
loan NGg50938
30402
51�:,
46879
Y
Su lamanld
Cannecibn of Morrisville. NC0050938
N00050938R
AdIve
2022
4,044
Tdal Alloallons:
Adive 71.623 143246
N00065516
Tovmdiunuay-Vedne
Tembb Creek WWrP
30403
60%
Y
Y
Base
Assigned by Rub NTTSA NCAC 02B.0234)
14�LU'
NA
AgNa
33,]90
67,579
68489
llw
SGUTHSIDE MHP
IormeM NC0030124
37103
50..
1
1
Y
Supplemental
Connedbnd Swlside MHP, NC0030720
&IT✓1998
N0(025631R
AdNe
253
506
WAKE TECHNICAL INSTITUTE
terms NCOD25631
30403
50>5
Y
Supplemental
Conm6on of Wake Technical IV. NCO025631
L8r199B
NC0033]2dR
Alive
202
404
ToWAllocations: Adlve 34.244 68.489
NCU079316 C6YofR Igh Lino Creek WWTP SIM 50% Y V Y. Base Assgnad by Rule NT15A NCAC 02B.0234) vim NA Active 10,418 20,837 22,454 tAVeek
2.

TRIENTS
Subbaain
Transport
LNBA
XRCA
TN
TN AOoo'n Typo
Albwlbn SourceSDaa
Source Pent
TN AIIoc'n
Total Nhro n
Total Phosphorus
Hearings Lou
Estuary
Discharge
E1Ruent
M°Moring Frequency
Effluent
Monitoring
Factor
Aibe'n4
Albc'n
An.n
Llmixtlon
Llmtlmbn(a)
Frequency
(rent.)
Ibyr
IbNe
Ibryr
Con..
I Mau
MI
I AYg.Per.
33105
70%
V
Y Y
Bese
Assigned by Rule ((r15A NCAC 028.0234)
1411,03:
NA
Active
24.635
11IM
WAM
VWeek
Mathes
NA
NA
1ANeek
Requested
4nro3
Devemamal
Sold toClylon, NCDD25453
.1845
.2359
V Y,
Deaemanlal
Sold b.bNW.n Ill
.1645
W.35D
Total Allocations: Active 21,345 30.493
30401
W..
Yi
Brio
Assill by Rule nrlM NCAC 02B.0234)
7197
NA
Active
MASS
334.851
335.435
IANeek
Monthly
2.0
OV.
1ANeek
W401
Y
Supplemental
Connection of Wlbwhave Country Club NC0081]
N15(19M
NGM81752A
Active
4
38
30401
Y
Supplemental
Connection of Dualem Pntlucta NGDO22M
43WIM
NC0012SMR
Active
30
3N
33401
Y
Supplemental
Connection of Mt. Sylvan UMC, NCOD43DOI
701990
NCD04MOIR
Active
4
0
30401
V
Supplemental
Connection of Person Canly School, NCDD36471
511620W
MOOM71R
Actve
16
162
30401
Y
SwDleamental
Connection of All Youth Annals NOD051071
Salm
NOD051071R
AdNe
4
40
Total Allocations: Active 33,544 335.435
3D407 1 so% I Y I Y I Y. Ills. IAssigned by Rule nTIM NCAC 028.0234) I Y1N3 I NA I AaM 1 78,8421 157,6641 157887I 1M'eek I tunably 1 2.0 1 Get. I IMeek
W405
Yt
Base
Assigned by Rare nTIM NCAC 02B.0234)
p1W
NA
AClive
132.455
189,221
199.822
lNeek
Monthly
NA
NA
1Meek
30407
Y
Supplemental
Connection of Eureka, NCO04M
—
NG0048]62R
Active
404
578
3D405
Y
Supplemental
Connection of Wayne Canty -Games IP,
—
NC003D392R
Actw
5.662
$088
30405
Y
Supplemental
Connection of WaIW Crack NCO039233
1M UM
NC0039233R
Active
1,132
1.618
3M7
iyi 23949
Y
Supplemental
Connedlon d Wayne Canty School, NGDO34801
11?'12003
NCD034BOIR
Acute
121
173
374D7
23449
Y
Su lem¢ntan
ConmxmondWayn.Ca.nvScho.K NCOOM819
IV25W003
NGDO3481OR
A.D.a
101
144
Total Allocations:
Active 139,876 199,82P
W405 I 7022 I Y I,,,1 Y"FI v+ Bas^e^eTO^„ I byNWe1TISA NCAC g2B.0iMl I �� I NA I Active I 35,47111 11.9041 126,711I 1AYuk I Mornay I NA I NA I 1ANe0c
urvm urmmu� unvnn,ala 4anfa Lama
30410
1W?
Y
Y
Y4
Base
Ass" by Rate((T15A NCAC 026.0234)
1uM'
NA
Across
SZ937
52,937
64210
1ANeek
Monthly
NA
NA
1AYeek
30410
Iv125348
V
SWplemevtlal
ConnegiondZchary To& Ill NC0M13
Z6WW2
NCOM13R
Agee
5,632
5.632
30410
Iyi 25343
V
Supplemental
Connection of Nause Woods Aple., NCO042430
SMD03
NC0056545R
AgNa
243
243
30408
(y125348
V
Supplemental
Connalbn of Craven County School, NCO02M
WN003
NCOM243OR
Act"
344
344
30410
fA 25348
Y
Supplemental
Connection of Ness Rrvar WBS, NCO070084
S72=5
NGDO70084A
Active
2.022
2,022
30410
y125346
Y
SUODIonantal
Conneclion of Cuman County WAS NOMS545
6:111r, 5
NC0029904R
Acuse
3.033
3033
T.M1Albcatbns:
Active 61,210 U210
30402
50%
V
V
Vr
Ban
Aulgned by Rule(MM NGAC 02B.OiN)
1217A97,
NA
Action
10,700
21,400
24,690
1ANOM
Math/
2.0
Cn
Week
UV03
(It25453
V
Supplametal
Pnchaud from SGWASA, NCDO26824
"I
NCO021124.PIl
Reserve
3,680
7,336
30405
Y
S lamented
Purchased horn UNIF14Cualen N00003760
I .
1645
I'm
Total AlklcaBons: Mixer! 16,013 32,026
30401
10%
Y
Ya
Baae
Assignedby Rula((r15ANCACO2B.021)
d
NA
Adana
5,860
58,599
58,599
IANeek
MNMey
2.0
Ctr.
IlWeek
09
IOt.
1
(y)26824
Y
supplemental
Purchasetl from BRMSD, NCO057011& 651"
777
CW57011/56109.SO
Reserve
6,113
61,130
10'*
26824
Y
Demamental
Soldb Clayton NC0025453
777
NG0025453PO1
Reserve
3668In
TaMl AOnnetbns:
Mixed &305 W.049
neuse kickoff pen 2Wrn)l24, summ2

NPDES/A uifer Protection Permitting Unit Pretreatment Information Request Form
PERMIT WRITER COMPLETES THIS PART:
PERMIT WRITERS - AFTER you got this form
Check all that
apply
back from PERCS:
- Notify PERCS if LIMP/STMP data we said should
be on DMRs is not really there, so we can get it for
you (or NOV POTW).
- Notify PERCS if you want us to keep a specific
POC in LTMP/STMP so you will have data for next
pennft renewal.
- Email PERCS draft permit, fact sheet, RPA.
- Send PERCS paper copy of permit (w/o NPDES
boilerplate), cover letter, final fact sheet. Email RPA
Date of Request
6
municipal renewal
V
Re uestor
K
new industries
Facility Name
—0Ad
W WTP expansion
Permit Number
N
Speculative limits
Region
stream reclass.
Basin
stream relocation
7Q10 change
other
if changes.
other
check applicable
PERCS staff:
Other Comments to PERCS:
CTB, CHO, LUM, NEW, ROA - Dana Folle 523
HIW, LTN, NEU, YAD - Monti Hassan 371
BIRD, CPF, FRB, TAR - Sarah Morison (208)
PERCS PRETREATMENT STAFF COMPLETES THIS PART:
Status of Pretreatment Program (check all that apply)
1) facility has no SIU's, does have Division approved Pretreatment Program that is INACTIVE
2) facility has no SIU's, does not have Division approved Pretreatment Program
3) facility has SIUs and DWQ approved Pretreatment Program (list "DEV" if program still under development)
3a) Full Program with LTMP
44)
3b) Modified Program with STMP
additional conditions regarding Pretreatment attached or listed below STMP time frame:
MGD Permitted Actual Time eriod for Actual Cle:
TMostent:Flow,
Industrial
Uncontrollable n/a
POC due
POC in
LTMP/
STM
Parameter of
Concern (POC)
Check List
to
NPDES/Non-
Diach Permit
Limi
Required
EPA•
Required
by 503
Slutl e•`
POC due
to SIU•••
POTW POC
(Explain
below)-
STMP
Effluent
Fre
LTMP
Effluent
Fran
NPDES_Pn&eanenLre uesthn leb2008
ReN$ed: My 24. 2007

comments on NCO025453 - Town of Clayton
Subject: comments on NCO025453 - Town of Clayton
From: [e-mail]
Date: Mon, 31 Jul 200611:12:10 -0400
To: [e-mail]
pls respond asap so I can send a no comment letter. thanks Marshall
1. In the introduction to A.2, shouldn't it say "during the period
beginning upon expiration above 1.9 MGD to expiration..."?
✓2. A.1/A.1.2 and A.2/A.2.2 - "total suspended residue" should be "total
s spended solids".
3. A.1 and A.2 - all metals should be expressed as "total".
4. A.1 and A.2 - to be consistent with A.1.11 and A.2.11, pH in the
tables should be expressed as "6.0-9.0".
N\oa''sV4\ SA� dT,4
Mfg
1 of 1

Jody L. McLeod"
MAYOR
Bruce Thompson
TOWN ATTORNEY
Steve Biggs
TOWN MANAGER non
June 18,2007
Mr. Mike Templeton
N.C. Department of Environment
and Natural Resources
1641 Mail Service Center
Dear Mr. Templeton:
COUNCIL MEMBERS
Bob Satterfield
Alexander R. Atchison
Alex Harding
Michael Grannis
Robert Ahlert
f, 41 4- a G/c..ndG 4 MAYOR PRO TEM
DI
JUN 2 2 2007
DENR . WATER DUALITY
The Town of Clayton ("Clayton") recently entered into an Agreement of Purchase and Sale with
UNIF1 Kinston, LL.0 ("LTNIFI") pursuant to which the Town of Clayton has agreed to buy
1,645L.bs/Yr of total P.itrogen ("TN") allocation at the Estuary from UNIF I. Clayton respectfully
requests that the 1,645 Lbs/Yr of TN allocation be transferred io its NPDES Permit with 715.50
estuary Lbs/Yr of TN available for immediate use and the remaining 934.50 estuary ibs,Yr o;
TN added to the permit in reserve. UNIFI Manufacturing, Inc.. the sole niember and manager of
LLN1F1 Kinston, LL.,C and the Town of Clayton Board of Crmmissineers have approvea Lids
transaction and Clayton's obligation to close is not conting;cnt on any factor other than reccipt
from DENR of a draft permit and/or other written communication indicating that DENK has
tentatively determined to issue the revised NPDES Permit to tbt Town of Clayton including the
above -described 1,645 Lbs/Yr of TN allocation at the estuary. As a resaa, the Town of Clanton
respectfully requests that you initiate the necessary procedures to modify Clayton's NPDE_S
permit to add the above -referenced allocation as described above.
If you have any questions, please Flo not hesitate to conlzct me.
Steve Biggs
Town Manager
Towm of Clayton
a0^e83961 Oi :Box 879 • Clayton, North Carolina 27528.Office [phone] • Fax [phone]

J9dy L. McLeod COUNCIL MEMBERS
MAYOR Bob Satterfield
Bruce Thompson Alexander R. Atchison
P • TOWN ATTORNEY Alex Harding
Michael Grannis
Steve Biggs Robert Ahlert
TOWN MANAGER p ConuxusitL/ • (ox Act[ae l'/c.x[lir.J. MAYOR PRO TEM
October 3, 2007
go
Ms. Frances Candelaria
NC DENR/DWQ/Poird Source Branch
as 1617 Mail Service Center
Raleigh, NC 27699-1617
Re: Request for Permit Renewal
NPDES Permit No. NCO025453
Town of Clayton, North Carolina
Dear Mrs. Candelaria:
Enclosed, please find one (1) original and two (2) copies of an application package requesting renewal of the NPDES Permit
for the Little Creek Water Reclamation Facility (LCWRF) located in Clayton, North Carolina. Each application package
contains the following:
1.
EPA NPDES Form 2A
2.
Topographic Site Map
3.
Schematic Flow Diagram
4.
Process Flow Diagram
5.
Three (3) Priority Pollutant Analyses
6.
Four (4) Chronic Toxicity Tests
7.
Sludge Management Plan
The Little Creek Water Reclamation Facility has undergone one major modification at the facility since issuance of the most
recent permit In November 2005 construction began at the plant to provide enhanced biological nutrient removal and
improved biosolids handling capabilities. The project includes construction of an anaerobic basin, two (2) pre -anoxic basins,
modifications to the two existing aeration basins, sludge thickening equipment and a sludge stabilization/storage basin.
Construction of the new improvements should be completed by early November 2007.
In 2006 Clayton purchased 3,668 lb/yr of estuary total nitrogen allocation from SGWASA. This allocation was placed in
reserve as noted in the Town's individual NPDES permit as well as in the Neuse River Compliance Association (NRCA) and
its co-permittee member's NPDES permit
Currently, the Town is completing the purchase of 1,645 lb/yr of estuary total nitrogen from Unifi Kinston, LLC. Based upon
.� the Town's transport factor of 50%, 1,645 1b/yr of estuary allocation results in 3,290 lb/yr of end of pipe total nitrogen at the
LCWRF discharge. Out of this 3,290 lb/yr we request that 1,432 lb/yr of the end of pipe allocation be added to the current
21,400 lb/yr included in the Town's individual NPDES permit As a result the Total Nitrogen Load will become 22,832 lb/yr
at the end of pipe (i.e. 2.5 mgd x 3 mg/L TN x 8.34 x 365 days/yr = 22,832 lb/yr rounded). In addition we request that the
remaining 1,858 lb/yr be placed in reserve in the Town's individual NPDES and noted in the NRCA NPDES permit similar to
the action granted in the SGWASA case. This will place the Town's total nitrogen end of pipe allocation held in reserve at
9,194 lb/yr (i.e. 7,336 lb/yr + 1,858 lb/yr = 9,194 lb/yr end of pipe or 4,597 Ib/yr at estuary).
If you have any questions or require any additional information, please do not hesitate to contact me at 919-553-5002.
Sincerely,
d&e5nBZiggs�
Town Manager
Enclosures
c: Charlie Davis, The Wooten Company
P.O. Box 879 • Clayton, North Carolina 27528.Office [phone] • Fax [phone]

a�
6
FACIL
SUP
Y NAME AND PERMIT NUMBER:
Little Creek Water Reclamation Facility,
NCO025453
PERMIT ACTION REQUESTED: RIVER BASIN:
Renewal I Neuse
PAR
t V 1 1f •. v T, ......,...::::: r: ........-.::.:...-.: ,..�ri:`r�3:::gr;:cr:,'=ii!%:;i 3.1:°`'i ir';r;a
P't is e i.T i s 1 e+. I t. • t ...._.--.�r........ - .
PART�1<.,I DUSTRIaL, In DISGHAR Y.. ;a
.-��. All treatment works receiving discharges from significant industrial users or which receive RCRA,CERCLA, or other remedial wastes must
complete part F.
GENERAL INFORMATION:
F.I. Pretreatment program. Does the treatment works have, or is subject to, an approved pretreatment program?
® Yes ❑ No
F.2. Number of Significant Industrial Users (SIUs) and Categorical Industrial Users (CIUs). Provide the number of each of the following types of
industrial users that discharge to the treatment works.
a. Number of non -categorical SIUs. 1
b. Number of CIUs. 3
SIGNIFICANT INDUSTRIAL USER INFORMATION:
Supply the following information for each SIU. If more than one SIU discharges to the treatment works, copy questions F.3 through F.8 and
provide the Information requested for each SIU.
F.3. Significant Industrial User Information. Provide the name and address of each SIU discharging to the treatment works. Submit additional pages
as necessary.
Name: Talecris Biotheraoeutics, Inc.
Mailing Address: 8368 US Highway 70 West '
Clayton. NC 27520
F.4. Industrial Processes. Describe all the industrial processes that affect or contribute to the SIU's discharge.
Extraction Machines
F.S. Principal Product(s) and Raw Material(s). Describe all of the principal processes and raw materials that affect or contribute to the SIU's
discharge.
Principal product(s): Biological Medical Products
Raw material(s): Blood Plasma
F.6. Flow Rate.
a. Process wastewater flow rate. Indicate the average daily volume of process wastewater discharge into the collection system in gallons per
day (gpd) and whether the discharge is continuous or intermittent.
300,000 gpd (XX continuous or intermittent)
b. Non -process wastewater flow rate. Indicate the average daily volume of non -process wastewater flow discharged into the collection system
In gallons per day (gpd) and whether the discharge Is continuous or intermittent.
100,000 gpd (XX continuous or intermittent)
F.7. Pretreatment Standards. Indicate whether the SIU is subject to the following:
a. Local limits ® Yes ❑ No
b. Categorical pretreatment standards ® Yes ❑ No
If subject to categorical pretreatment standards, which category and subcategory?
CFR 439.20
M" EPA Form 3510-2A (Rev. 1-99). Replaces EPA forms 7550-6 & 7550-22. Page 19 of 24

Poll
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Intl
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ME1
M
M
M
FACILITY NAME AND PERMIT NUMBER:
PERMIT ACTION REQUESTED:
RIVER BASIN:
Little Creek Water Reclamation Facility,
Renewal
Neuse
NCO025453
F.S. Problems at the Treatment Works Attributed to Waste Discharge by the SIU. Has the SIU caused or contributed to any problems (e.g.,
upsets, interference) at the treatment works in the past three years?
❑ Yes ® No If yes, describe each episode.
RCRA HAZARDOUS WASTE RECEIVED BY TRUCK, RAIL, OR DEDICATED PIPELINE:
F.B. RCRA Waste. Does the treatment works receive or has it In the past three years received RCRA hazardous waste by truck, rail or dedicated pipe?
❑ Yes ® No (go to F.12)
F.10. Waste transport. Method by which RCRA waste is received (check all that apply):
❑ Truck ❑ Rail ❑ Dedicated Pipe
F.11. Waste Description. Give EPA hazardous waste number and amount (volume or mass, specify units).
EPA Hazardous Waste Number Amount Units
CERCLA (SUPERFUND) WASTEWATER, RCRA REMEDIATION/CORRECTIVE ACTION
WASTEWATER, AND OTHER REMEDIAL ACTIVITY WASTEWATER:
F.12. Remediation Waste. Does the treatment works currently (or has it been notified that it will) receive waste from remedial activities?
❑ Yes (complete F.13 through F.15.) ® No
F.13. Waste Origin. Describe the site and type of facility at which the CERCLA/RCRA/or other remedial waste originates (or is excepted to origniate in
the next five years).
F.14. Pollutants. List the hazardous constituents that are received (or are expected to be received). Include data on volume and concentration, If
known. (Attach additional sheets if necessary.)
F.15. Waste Treatment.
a. Is this waste treated (or will be treated) prior to entering the treatment works?
❑ Yes ❑ No
If yes, describe the treatment (provide Information about the removal efficiency):
b. Is the discharge (or will the discharge be) continuous or Intermittent?
❑ Continuous ❑ Intermittent If Intermittent, describe discharge schedule.
l i j
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+.•�. �.r - W � ..... .., ....:..1.. i. ...,..,.. ..� .... ..... .•. C, .Y .. S�"e . .=�•"r::.• ... .SI:L.• .. _ :.::r]�'.i", 1..r�.�:�Y
r"'� EPA Form 3510-2A (Rev. 1-99). Replaces EPA forms 7550-6 & 7550-22. Page 20 of 24

b St
:FACILITY NAME AND PERMIT NUMBER:
Little Creek Water Reclamation Facility,
NCO025453
C. Number of non -categorical SIUs. 1
d. Number of CIUs. 3
PERMIT ACTION REQUESTED: RIVER BASIN:
Renewal I Neuse
SIGNIFICANT INDUSTRIAL USER INFORMATION:
1 0-
Supply the following Information for each SIU. If more than one SIU discharges to the treatment works, copy questions F.3 through F.8 and
provide the information requested for each SIU.
F.3. Significant Industrial User Information. Provide the name and address of each SIU discharging to the treatment works. Submit additional pages
as necessary.
Name: Novo Nordisk Pharmaceutical Industries, Inc.
Mailing Address: 3612 Powhattan Road %
Clayton NC 27520
F.4. Industrial Processes. Describe all the industrial processes that affect or contribute to the SIU's discharge.
Mixing and Packaging
F.S. Principal Product(s) and Raw Material(s). Describe all of the principal processes and raw materials that affect or contribute to the SIU's
discharge.
Principal product(s): Insulin for I.V. Iniection
Raw materal(s): Insulin Crystals
F.6. Flow Rate.
C. Process wastewater flow rate. Indicate the average daily volume of process wastewater discharge Into the collection system In gallons per
day (gpd) and whether the discharge is continuous or Intermittent.
90.500 gpd (XX continuous or intermittent)
d. Non -process wastewater flow rate. Indicate the average daily volume of non -process wastewater flow discharged Into the collection system
in gallons per day (gpd) and whether the discharge is continuous or intermittent.
34.200 gpd (XX continuous or Intermittent)
F.7. Pretreatment Standards. Indicate whether the SIU is subject to the following:
a. Local limits ® Yes ❑ No
b. Categorical pretreatment standards ® Yes ❑ No
If subject to categorical pretreatment standards, which category and subcategory?
CFR 439.40
EPA Form 3510-2A (Rev. 1-99). Replaces EPA forms 7550-6 & 7550-22. Page 21 of 24

FOR
OR
i:ACILITY NAME AND PERMIT NUMBER:
PERMIT ACTION REQUESTED:
RIVER BASIN:
Little Creek Water Reclamation Facility,
Renewal
Neuse
NCO025453
F.8. Problems at the Treatment Works Attributed to Waste Discharge by the SIU. Has the SIU caused or contributed to any problems (e.g.,
upsets, interference) at the treatment works in the past three years?
❑ Yes ® No If yes, describe each episode.
RCRA HAZARDOUS WASTE RECEIVED BY TRUCK, RAIL, OR DEDICATED PIPELINE:
F.9. RCRA Waste. Does the treatment works receive or has it in the past three years received RCRA hazardous waste by truck, rail or dedicated pipe?
❑ Yes ® No (go to F.12)
F.10. Waste transport. Method by which RCRA waste is received (check all that apply):
❑ Truck ❑ Rail ❑ Dedicated Pipe
F.11. Waste Description. Give EPA hazardous waste number and amount (volume or mass, specify units).
EPA Hazardous Waste Number {: Amount Units
CERCLA (SUPERFUND) WASTEWATER, RCRA REMEDIATIONICORRECTIVE ACTION
WASTEWATER, AND OTHER REMEDIAL ACTIVITY WASTEWATER:
FA 2. Remediation Waste. Does the treatment works currently (or has It been notified that It will) receive waste from remedial activities?
❑ Yes (complete F.13 through F.15.) ® No
F.13. Waste Origin. Describe the site and type of facility at which the CERCLA/RCRA/or other remedial waste originates (or is excepted to origniate in
the next five years).
F.14. Pollutants. List the hazardous constituents that are received (or are expected to be received). Include data on volume and concentration, if
known. (Attach additional sheets if necessary.)
F.15. Waste Treatment.
C. Is this waste treated (or will be treated) prior to entering the treatment works?
❑ Yes ❑ No
If yes, describe the treatment (provide information about the removal efficiency):
d. Is the discharge (or will the discharge be) continuous or intermittent?
❑ Continuous ❑ Intermittent If Intermittent, describe discharge schedule.
_ _.�_ _,,.__ _
_ ..._.._____.____ _______-.___r-- -- - - - --- - - —
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Fort EPA Form 3510-2A (Rev. 1-99). Replaces EPA forms 7550-6 & 7550-22. Page 22 of 24

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ICI
*ACILITY NAME AND PERMIT NUMBER:
PERMIT ACTION REQUESTED:
RIVER BASIN:
Little Creek Water Reclamation Facility,
Renewal
Neuse
NCO025453
.-........ .........-...........:...:.. ......:.::.
.SUPPLE 9 1VTAL, APPLT QN�i1NF RM Tom'
._.__�-....—.....__«.-�.r--•-�•.« .. .. :..—'^:F..,.,...,.'mow.•--.�+-'........,. 1,'.^....`.:...`._'.�^
F Nb STR1�L• USE DISCHA G S ��11 @R�1/CE G SiT ' '°
.PAR . . , _
All treatment works receiving discharges from significant Industrial users or which receive RCRA,CERCLA, or other remedial wastes must
complete part F.
GENERAL INFORMATION:
F.I. Pretreatment program. Does the treatment works have, or is subject to, an approved pretreatment program?
® Yes ❑ No
F.2. Number of Significant Industrial Users (SIUs) and Categorical Industrial Users (CIUs). Provide the number of each of the following types of
industrial users that discharge to the treatment works.
e. Number of non -categorical SIUs. 1
f. Number of CIUs. 3
SIGNIFICANT INDUSTRIAL USER INFORMATION:
Supply the following information for each SIU. If more than one SIU discharges to the treatment works, copy questions F.3 through F.8 and
provide the Information requested for each SIU.
F.3. Significant Industrial User Information. Provide the name and address of each SIU discharging to the treatment works. Submit additional pages
as necessary.
Name: Hosaira Inc
Mailing Address: 8484 U.S. 70 West
Clayton NC 27520
F.4. Industrial Processes. Describe all the industrial processes that affect or contribute to the SIU's discharge.
Mixing and Packaging --
F.5. Principal Product(s) and Raw Material(s). Describe all of the principal processes and raw materials that affect or contribute to the SIU's
discharge.
Principal product(s): I.V. Nutritional Products
Raw material(s): Soybean Oil Egg Yolks, Glycerin, Amino Acids
F.6. Flow Rate.
e. Process wastewater flow rate. Indicate the average daily volume of process wastewater discharge Into the collection system in gallons per
day (gpd) and whether the discharge is continuous or intermittent.
65.000 gpd (XX continuous or intermittent)
f. Non -process wastewater flow rate. Indicate the average daily volume of non -process wastewater flow discharged into the collection system
In gallons per day (gpd) and whether the discharge Is continuous or intermittent.
35,000 1 gpd (XX continuous or intermittent)
F.7. Pretreatment Standards. Indicate whether the SIU is subject to the following:
a. Local limits ® Yes ❑ No
b. Categorical pretreatment standards ® Yes ❑ No
If subject to categorical pretreatment standards, which category and subcategory?
CFR 439.40
F" EPA Form 3510-2A (Rev. 1-99). Replaces EPA forms 7550-6 & 7550-22. Page 23 of 24

M Tr
- � 1 �s�i S�._+ vx`+ � r--r1 R II � 'S ��"•f / ♦ � �� .` �� • fy `T :. 4 iE � �� � - ` 7'� a, /� '� '' �� i V . � � ! E !
°, � :. �! �, J i - � '' rc=r�+ �=" 1 �� �� � ,``• '1 ` �, �+a7. � ��` Y ' 1• e � 1�� `I l' i I� t✓. f I - �i- �� •11��-.� "�
LEGEND
� `-�-�`—n �5+� � ''. ,� �. _' ' '�; `�� ,I i ,,-,-� � �+�i 1—� � f YJ l; �� '� • r1.• f r r_ r � � � ' � `. ' H : ,
l� 3 +`�, -, - � \; �� •\ �.- ��,---�,.['y _ EFFLUENT FORCE MAIN
'cs�a�� ' � `~ '� ` •�J.1�\ ,_ •�,l 1` - �'�7 r :,i \\\� � }� j -���� � �1 ����..� � r� •• �v� ''�� `� f � ` � � � .�� �' ~ dti
MOTAVA
,k, •� - 7 ��,� ��� 1.:,,;; I DISCHARGE �'n EFFLUENT OUTFALL
31
POINT 001 i o
_
ti I
r _.� t rlv�l�,� e.f Y -- `' _ '`` —' •� ram-- 7 �• 4 `_� � LAT. 35°39' S0" � t �\ta _ INFLUENT SEWER
y' = n j a/ �� J . pv% ., f� , �i�., LONG. 78° 25' 26" �. !!r 1•' ',�� ' _
�,��
�%�� 1 �' '� an•,.p�:-��!I�� `f `�!`��'� 29�� r } �•t�f'% �� LITTLE CREEK WRF
,•I'•�\ 11• r I,¢` -=rl=per-` C`•v~"! ,i•d�r �! "0•. f �-1�� r ,i� �� •J �l N �� ��'~ �+t� i.
_ , k) V f L �-- •` y � i. � i� '�• J {_ ' � S J� t\�f\ l., i \I�,r_. �� �ti
i� �•, - fa�' }` f 4 I t` �.$',• p .•�"•1�_ _;� �}1 • _ / r L� / 1 • }�`V� 1 ,��
`
• ' k. I ` / , / �l ``l� EFFLUENT
OUTFALL
EXISTING 24"
INF.
. SEWER � •, �� 1'� � _ ` ' a� �� �1—w ;?� �l � -
EXISTING 18"�� ` f• ' �'�� , ��__� I�. tY,i ,1 ti 1 ;'� .
- ✓ INF- SEWER F �j
THE WOOTEN COMPANY
ENGINEERING I PLANNING i ARCHITECTURE
> , y— • r x ^ - I 120 North Boylan Avenue Raleigh NC 27603-1423
.� f f ✓ i n ��r' ,- • v; \ `` _y{- S �f5 1 �- 11 -} 1 919,828.0531 fax [phone]
-�� �' \• .� 7 r >�''� , . 1 � t 7 111 1 0 �i to � t : , ` �tr� r~ •'•� / �-�� . x \ �-�� � "l �J (� W
� �� �•�� = ( � �^•,� ,tr �%%�� i � �-- E EFFLUENT
° �' �r'l ..� �` �- FORCE MAIN
``�N--} ` {�� , r , f -_ 5sal _ % �tl- ,�v TOWN OF CLAYTON
•� �. — _% a; , ''`` �. �� ^.� LITTLE CREEK 12�., c%k �;�� LITTLE CREEK WATER
•" - � � f � � � 1
WATER RECLAIIAATION f�f �'RECLAMATION FACILITY
FACILITY , ' 7 y� ,� , t ; �1 - NPDES PERMIT NO. NCO025453
� � � r/ [�'' `� V� � � .�' 1 � �� ? � . ( ll` 1 �\ � ���I� } p �r r�� +1 � '.i i � �, \\•, � � 7 l� ,O �=_-- �� _ J r.
USGS QUAD: CLAYTON, NC 2002
i' `1 �/ � -`�R , _„ -_; � I -w � �' ,,`Y; t ' � �` � 1 L� �--•/ �r •; �- � .-� � `-, I ��11� �,/ � , F=--=-:- 1��
SCALE: 1'=2000'
t f t •'' V li• " rl , . J ui
_ 552 •� ,� w`. ��� V `• t f -�•_ r ` �f �� RECEIVING STREAM: NEUSE RIVER
r is '� n . II, { t• • ; �-- RIVER BASIN: NEUSE RIVER BASIN

Existing Process Train
- - - ,-Existing Process
❑ D.B.
I
r
I I
p
I I
Clerigester
I
Trickling I I
F i Iter -'
P.S.
Secondary I i
Clarifier
P.S
I nfluent /
Influent = T.F.P.S.
2Z
Screening
& Grit Rem.-�
Chemical
Stor. Are,
Aerobic
D igester -
e�
Sludge
Loading
Sta.
I nfluent
Pump Sta.
Sludge
Stabilization/
Storage Tank
Sludge
Drying Beds
Chem Feed
& Sludge
Thick. Bldg.
M
Anaerobic Selector Tank
Legend
Wastewater / Effluent
- Sludge
- - - - - Decant / Filter Backwash / Bed Underdrainage
----- Scum
(aa wo Flow Balance at
Design Average Daily Flow
Clar. Dist. Box
Scum /
1 r
- -A7 -- P.S 0:
l I 0274 RIO Ox. Basin No. 1 S Nolari1er �� /'/Clarifier
No.2--,
-I
r *
\ I P.S.
\ I First Stage Anoxic Tank �� Drain
- First Stage Anoxic Tank
___1/ - Ox. Basin No. 2
Fo-
I,q F J
CID
C&M "go
1 Dist. Box_T_ iv
m
II
�� I ��'---------_ ------ -
Waste Sludge Sludge Recirc. I
/ \ Sludge TT
Thickening Bldg.
- —►
Decant - Sludge UV Disinf /
Drying Beds Chlorination -
Dechlorination
Sludge
Stabilization/
Storage Tank -
EXHIBIT 1
Schematic Flow Diagram of Clayton LCWRF
1K
THE
WOOTEN
COMPANY
ENGINEERING
PLANNING
Clarifier No. 3 ARCHITECTURE
Filter Backwash
-Tertiary
Filters
To Neuse River
Eff. Pump Sta.

f. Lot
0.
'Q
o .,s
0-
�� al
wmo
vN
Ll-
k41
i
HEADWORKS .
EX. INFLUENT
PUMP STATION
L. L— V L— 1 r Lr
PROCESS FLOW — —
RAS FLOW,
WAS FLOW
PIPE
WATER PIPE
STRUCTURE 0
FENCE
91
If
TREE LINE
EX6'
- _
WATERLINE
BBFFPP
__
ACCESS ROAD
• A95EMMY
` 101fILT
SLUDGE SLUDGE
STABILIZATION / HOLDING STABILIZATION / HOLDING
TANK No 1 TANK No 2
� t
EXHIBIT 2
PROCESS FLOW DIAGRAM OF CLAYTON LCWRF
¢v uwrnnrx�.i •AS„
SLUDGE rRETURN SLUDGE
SLUDGE
PUMPSTATION
f SCUM
PS-
T YL.
VAUI
i U WATER
UNE
4 � �
_ CHLOPoNE CNLO.
SLUDGE CONTACT BLDG.
THICKENER CHAMBER
BUILDING _ _ Oa
a ORux uxE
EFFLUENT
PUMPSTA-,IUN
J ' �