NC0025453_Permit Modification_20010820

WDES DOCUWENT SCANNIM6 COVER SHEET
NPDES Permit:
NC0025453
Clayton WWTP
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Application
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
August 20, 2001
This docuiaeat is priurtea on reuse paper - igazore ariy
coaiteat oa tlhe reYerse side

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
Gregory J. Thorpe, Ph.D., Acting Director
Mr. R. Steven Biggs, Town Manager
Town of Clayton
P.O. Box 879
Clayton, North Carolina 27520
Dear Mr. Biggs:
4 plawhA
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
August 20, 2001
Subject: NPDES Permit Modification
Clayton/ Little Creek WRF
NPDES Permit No. NCO025453
Johnston County
A letter of request for a permit modification from the Town of Clayton was received by the Division of Water Quality June
8, 2001. The letter requested that the lead monitoring data be reviewed, and the provision for the implementation of a
lead limit by August 1, 2001 be removed. Additionally, the request for clarification of monitoring and sampling was also
reviewed.
The monitoring data for lead was reviewed from January 2000 through May 2001 (most recent data). The data did not
show a "reasonable potential" to exceed the chronic or acute instream criteria for total lead. Therefore, the Division has
modified the permit to require quarterly monitoring (no limit) only.
A provision has been added to the footnote of the permit stating, in essence, that sampling (be that stream and/or
influent/effluent) is not required when flow or weather conditions pose a substantial risk of injury or death to persons
collecting samples [ref. 15A NCAC 2B .0505 (c)(4)].
Please find enclosed the modified section of the permit. Replace the original section in your permit with the attached
sheet. All other terms and conditions contained in the original permit remain unchanged and in full effect.
If any parts contained in this permit modification 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 a written petition
conforming to Chapter 150B of the North Carolina General Statutes, filed with the Office of Administrative Hearings, Mail
Service Center 6714, Raleigh, North Carolina 27699-6714. Unless such demand is made, this decision shall be final and
binding.
This permit does not affect the legal requirement to obtain other permits which may be required by the Division of Water
Quality, the Division of Land Resources, Coastal Area Management Act, or any other Federal or Local government permit that
may be required.
If you have any questions concerning this modification, please contact Susan Wilson at [phone], ext. 510.
Sincerely,
�egory J. Thorpe, Ph.D.
cc: James Warren, ORC Town of Clayto
Raleigh Regional Office/ Water Quality
Point Source Compliance & Enforcement
Central Files & NPDES Files
EPA Region IV
1617 MAIL SERVICE CENTER, RALEIGH, NORTH CAROLINA 27699-1617 - TELEPHONE [phone]/FAX [phone]
AN EQUAL OPPORTUNITY AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/ 10% POST -CONSUMER PAPER
VISIT US ON THE WEB AT http://h2o.enr.state.nc.us/NPDES

A. (I.) EFFLUENT LINIITATIONS 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 1.9 MGD of municipal wastewater from outfall 001. Such
discharges shall be limited and monitored by the Permittee as specified below:
Effluent Characteristics
Limits
Monitoring Requirements
Monthly
Average
Weekly
Average
Daily
Maximum
Measurement
Frequency
Sample Type
Sample
Locationl
Flow
1.9 MGD
Continuous
Recording
Influent or
Effluent
BOD, 5 day (202C)2
[April 1 -October 31 ]
5.0 mg/I
7.5 mg/I
Daily
Composite
Influent &
Effluent
BOD, 5 day (209C)2
[November 1- March 31 ]
10.0 mg/I
15.0 mg/l
Daily
Composite
Influent &
Effluent
Total Suspended Residue2
30.0 mg/I
45.0 mg/I
Daily
Composite
Influent &
Effluent
NH3 as N Aril 1- October 31
2.0 mg/I
Daily
Composite
Effluent
NH3 as N [November 1- March 311
4.0 mg/I
Daily
Composite
Effluent
Dissolved Oxygen3
Daily
Grab
Effluent
Dissolved Oxygen
3Meek
Grab
Upstream &
Downstream
Fecal Coliform(geometric mean
200/100 ml
400/100 ml
Daily
Grab
Effluent
Fecal Coliform (geometric mean)
3Meek
Grab
Upstream &
Downstream
Total Residual Chlorine4
28 µg/I
Daily
Grab
Effluent
Total Nitrogen
(NO2-N + NO3-N + TKN) 5
No
Effluent Limit (mg/1)
Weekly
Composite
Effluent
No Effluent Limit Iblmonth
( )
Monthly
Calculated
Effluent
21,400 lb/year (Annual Mass Loading) 6
Annually
Calculated
Effluent
Total Phosphorus 7
2.0 mg/L (Quarterly Average)
Weekly
Composite
Effluent
Temperature 'C
Daily
Grab
Effluent
Temperature (-C)
3Meek
Grab
Upstream &
Downstream
Conductivity
Daily
Grab
Effluent
Conductivity
3Meek
Grab
Upstream &
Downstream
Chronic Toxicity8
Quarterly
Composite
Effluent
Lead
Quarterly
Composite
Effluent
Copper
Monthly
Composite
Effluent
Zinc
Monthly
Composite
Effluent
Silver
2/Month
Composite
Effluent
H9
6-9
Daily
Grab
Effluent
(Footnotes on next page)
Town of Clayton
NPDES No. NCO025453

4 . • i F
A. (I.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - FINAL
(Continued)
Footnotes:
I. 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
Associatton.
Per 15A NCAC 2B .0505(c)(4), stream sampling (as well as influent/effluent sampling) may be
discontinued when flow conditions could result in injury or death of the person(s) collecting
the samples. In such cases, on each day that sampling is discontinued, written justification
shall be specified in the monitoring report for the month in which the event occurred.
2. The monthly average effluent BOD5 and Total Suspended Residue concentrations shall not
exceed 15% of the respective influent value (85% removal).
3. The daily average dissolved oxygen effluent concentration shall not be less than 6.0 mg/1.
4. Total residual chlorine is required only if chlorine is used as a disinfectant (or elsewhere in the
process).
5. See Special Condition A. (2.), Total Nitrogen Monitoring.
6. The annual mass loading limit for total nitrogen shall become effective with the calendar year
beginning on January 1, 2003 unless it is provisionally waived per Special Condition A.(3.),
Annual Limits for Total Nitrogen.
7. 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).
8. Chronic Toxicity (Ceriodaphnia dubia) P/F at 1.6% March, June, September, and December
[see Special Condition A. (4)] . Toxicity monitoring shall coincide with metals monitoring.
9. 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 shah be no discharge of floating solids or visible foam in other than trace amounts.
Town of Clayton
NPDES No. NCO025453

TOWN OF C LAYTO N
"SERVICE" OPERATIONS CENTER
ELECTRIC SERVICE
,.,• AyT
[phone]-
1
VEHICLE MAINTENANCE
[phone]
May 31, 2001
Susan Wilson
NCDENR
Division of Water Quality
NPDES Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Re: NPDES Permit Addendum NCO025453
Dear Ms. Wilson:
"ENVIRONMENT'
PUBLIC WORKS
[phone]
WATER RECLAMATION
[phone]
- - it '•�`'
-
PO1Nt SOi1RGE BRAtiCH
I purpose of this letter is to request that the lead limits be removed from the Town's
current NPDES permit, and the frequency reduced to quarterly. This quarterly monitoring
would be performed when the long term monitoring data is collected.
Attached is a table of monitoring results for lead for the year 2000 and the first four
months of 2001. The data demonstrates that the POTW is not experiencing problems in
regards to effluent quality. In addition, the 2000 sludge analysis showed a lead
concentration of 33 mg/kg, which is considerably lower than the sludge ceiling
concentration of 840 mg/kg.
Please zontact me directly at 9 i9-553-1536 if you have any questions.
Sincerely
0/
Ines Warren
ORC, Town of Clayton
xc: Steve Biggs
Tim Simpson
653 Highway 42 West • P.O. Box 879 • Clayton, North Carolina 27520 • [phone] • Fax [phone]

•or V
Effluent Lead Concentrations
Town of Clayton POTW
Date:
Concentration ppb
1/6/00
6.2
1 /12/00
<
10
2/3/00
<
5
2/10/00
<
5
3/2/00
<
5
3/9/00
<
5
4/6/00
<
5
4/14/00
<
5
5/4/00
<
5
5/10/00
<
5
6/8/00
7.3
6/15/00
7.8
7/7/00
9.5
7/13/00
6.6
8/3/00
<
5
8/11 /00
<
5
9/2/00
<
5
9/14/00
<
5
10/5/00
<
5
10/13/00
<
5
11 /2/00
<
5
11 /8/00
<
5
12/8/00
<
5
12/14/00
<
5
1 /4/01
<
5
1/11/01
<
5
2/5/01
<
5
2/10/01
<
5
3/8/01
<
5
3/16/01
5.6
4/6/01
<
5
4/12/01
<
5

DIVISION OF WATER QUALITY
May 22, 2001
To: Milt Rhodes
Local Government Assistance Unit
Through: David A. Goodrich, Supervisor
NPDES Unit
From: Susan A. Wilson, Environmental Engineer
NPDES Unit
Subject: Town of Clayton - Little Creek Wastewater Reclamation Facility
Environmental Assessment
NPDES No. NCO025453
Johnston County
I have reviewed the Environmental Assessment (EA) submitted by Hobbs. Upchurch,
and Associates on behalf of the Town of Clayton. The EA represents the flow expansion
of the Little Creek Wastewater Reclamation Facility from 1.9 MGD to 2.5 MGD.
The NPDES Unit of the Division of Water Quality discussed concerns regarding the EA.
as well as other issues, during the meeting held with Town officials and their
consultants, April 25, 2001. The following comments represent the potential problems
the Town may face with the expansion to 2.5 MGD. As long as the Town is aware of the
problems discussed below. the NPDES Unit has no objection to the proposed project.
As discussed in the meeting, depending on the timing of the expansion and the
proposed formation of the Group Compliance Association, there are two different
pathways to compliance with Clayton's nutrient load allocation to the Neuse River
basin, which are outlined below:
Resolution and formation of the proposed Compliance Association for the Neuse Basin
Should the proposed Compliance Association be contractually formed (with Clayton
as a member in good standing) at the date of permit application for the expansion to
2.5 MGD, the Town will not have to meet the individually limited total nitrogen (TN)
load of 21,400 lbs/year and will not be required to design for a nitrogen limit
equivalent to 3.5 mg/1 TN referred to in 15A NCAC 2B .0234 (8). However, the
Division is unaware at this time what may be required for the Town to comply with
conditions that may be stipulated by the Compliance Association for expanding
facilities. We encourage the Town to contact Glenn Dunn and/or other Local
Government members of the proposed Compliance Association. Additionally, a total
phosphorus limit of 2 mg/l, based on a quarterly average will be required if the
Compliance Association is formed. All other limits presented in the speculative
limits letter dated July 10, 2001 are correct and will be applicable regardless of any
Compliance Association.
2. No formation of a Compliance Association. If no Compliance Association has been
formed, the Town will be subject to the individual total nitrogen load of 21,400

lbs/year and the Town will be required to design for an equivalent nitrogen limit of
3.5 mg/l. Current treatment technologies for total nitrogen removal may not allow
the Town to comply with the total nitrogen load. Therefore, it may be necessary that
Clayton acquire additional allocation from nonpoint sources through the Wetlands
Restoration Fund. The Town will be required to obtain (make payment) for 30,years
allocation at, or prior to, renewal of a permit for 2.5 MGD.
To address all eventualities, the EA should reflect both possible paths and
evaluate each accordingly (including analyses of alternatives).
The current EA states that "...nutrient removal projects are for later consideration and
are not part of the proposed project ...." The Town of Clayton should be aware that
proceeding forward without nutrient removal could be problematic, whether or
not a compliance group is formed.
The EA should clearly document the Town's future (20 year) planning. This should
include an explanation as to how this expansion phase fits into long range planning
efforts. Also, the Division is interested in how the county and other local governments
will be involved with Clayton's future efforts.
Furthermore, a revised model for nutrient effects on the Neuse River is currently under
review by the Division and EPA. Additionally, EPA is currently running a separate
model for nutrient effects on the Neuse River. It is possible that upon Phase II review of
the nutrient TMDL for the Neuse River Basin, nitrogen loads may be reduced even
further. It is imperative that the Town plan for future nutrient reduction either
via increased treatment capability and/or effluent flow reduction.
cc: Bobby Blowe, Construction Grants & Loans
Ken Schuster/Tim Baldwin, RRO/WQ

Town of Clayton.__________
pOUGLAS A. MXORMAC
Mayor--
_
RONALD E. GURGANUS
,,,GVAYTg
C
Mayor Pro Tent
STEVEN BIGGS
Town Manager
}, i
JASON J. KAUS
• v�e� !-�
a,
I
U
}
Town Attorney
CAµN,......'
y
y
JESSICA COUTU, CMC
Ic
Off
O al
Town Clerk=
April 30, 2001
VIA FACSIMILE AND U.S. MAIL
Mr. David Goodrich
North Carolina Dept. of Environment
and Natural Resources
Division of Water Quality
1601 Mail Service Center
Raleigh, North Carolina 27699-1601
Re: Town of Clayton; Little Creek Wastewater Reclamation Facility
Dear Mr. Goodrich:
CIL MEMBERS
'.RT J. AHLERT
i H. LIPSCOMB
SATTERFIELD
CH LAWTER
Thank you for meeting with me, Mayor Douglas A. McCormac, the Town of Clayton's (the
"Town") other representatives and agents, Johnston County's representatives, and the Department of
Environment and Natural Resources' (the "Department") other representatives on April 25, 2001, to
discuss the Town's July 2000 submittal for an Authorization to Construct (the "ATC") certain
improvements to the Town's Little Creek Wastewater Reclamation Facility (the "LCWRF").
Thank you, too, for committing on behalf of the Department to process the Town's
application for the ATC on or before May 25, 2001. We are pleased that the Town's application
finally will be processed by the Department, since it was submitted more than nine months ago.
As you requested during our meeting, I am writing to confirm that the Town recognizes the
Department's granting of the ATC will not constitute either express or implicit approval to expand
the permitted capacity of the LCWRF from 1.9 million gallons per day ("mgd") to 2.5 mgd.
However, as we discussed during our meeting, please note that the proposed improvements to the
LC WRF authorized by the ATC will facilitate and enhance the Town's request for an expansion of
the LC WRF's permitted capacity to 2.5 mgd, and the Town is effecting those improvements, in part,
based on the intention to submit a future application for the needed permit expansion.
Finally, please note that the Town reserves all of its rights in connection with the pending
request for an expansion of the LC WRF's permitted capacity, as well as all of its rights concerning
P.O. Box879 • Clayton, North Carolina27520 • [phone] • Fax[phone]

Mr. David Goodrich
April 30, 2001
Page 2
the ATC pursuant to 15A N.C.A.C. 2H.0112, Chapter 150B of the North Carolina General Statutes,
and all other applicable rights under North Carolina law.
Thank you again for your assistance with this matter. If you have any questions or concerns
about this letter or any of the above -referenced matters, please call me at [phone].
With best wishes,
Sincerely yours,
e�even
.
Town Manager
cc: The Honorable Allen Wellons
The Honorable William Creech
Mayor and Town Council
Jason J. Kaus, Esq.

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Re: question
1
Subject: Re: question
Date: Tue, 24 Apr 2001 17:27:51 -0400
From: Joe Pearce <[e-mail]>
Organization: NC DENR DEH OSWW
To: Susan Wilson <[e-mail]>
Susan,
Yes, a ditch can get a 1 mg/l ammonia with 18 hours detention time, all you
have to do is run the mixed liquor concentration up. Have the consultant
provide you with the MLSS and the sludge age at the winter temperature?
Better have 10 day sludge Age at 10C. If MLSS greater than 5000 mg/l,
raise hell. Also have the consultant complete a 02 calc to make sure you
have enough oxygen for the summer endogenous demand at the max. temp.
By the way, make sure Greg Thorpe knows I am providing you with free
assistance.
Its an inside joke, Greg will laugh.
Family is doing fine. You should come by sometime, and meet the baby imp.
Hope you are doing well,
Joe
Susan Wilson wrote:
> OK, i have a question for you, former Kruger guy - oxidation ditch
> specialist. Do you think it's possible for an oxidation ditch to meet a
> summer ammonia limit of 1 mg/1 and winter of 2 mg11 with only an 18 hr
> detention time? i haven't looked at this too hard yet, but it's a plant
> trying to do a "re -rating" - and using some type of carousel
> configuration with surface rotor aerators (i think) . right off the bat,
> i wouldn't think that detention time would allow a plant to meet a
> stringent ammonia limit.
> and. ..how ya doin'?
1 of 1 4/25/01 8:56 AM

RE: Clayton meeting
Subject: RE: Clayton meeting
Date: Tue, 24 Apr 2001 10:04:53 -0400
From: Michael Wicker <[e-mail]>
To: Susan Wilson <susan.a.wi ]son @ncmail.net>
CC: [e-mail]
the Town wants to begin at the last 201 plan and historically come to
today's issues and the Town's intent for this expansion to 2.5 mgd for now
and then also discuss the future 20 year plan.
They want to address the p-4, 80/90 rule issues and sewer moratorium,
They want to address the ATC for the work at the existing WWTP,
the current review of the EA for the expansion permit to 2.5 mgd,
the NPDES submittal and possiblities of the 2.5 mgd,
to address TN issues such as reuse, treatment requirements, coalition , etc
as it relates to both existing permit and 2.5 mgd permit,
>----------
> From: Susan Wilson f SMTP: susan. a. [e-mail]]
> Sent: Monday, April 23, 2001 12:09 PM
> To: Michael Wicker
> Subject: Clayton meeting
> Michael,
> I think I have a pretty good idea of what needs to be discussed in the
> meeting with Clayton, but would you mind sending me a list of topics
> prior to Wed. just to make sure? I'll put together an agenda after
> that. Thank you.
1 of 1 4r,.4/01 10:09 AM

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Town of Clayton
avL
DOUGLAS A. McCORMAC
Mayor
RONALD E.GURGANUS
Mayor Pro Tern
STEVEN BIGGS
Town Manager
JASON J. KAUS
Town Attorney
JESSICA COUTU, CMC
Town Clerk
November 20, 2000
Mr. Kerr T. Stevens
Division Director
Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
RE: Town of Clayton
Wastewater Treatment Plant Improvements
NPDES No. NC 0025453
Johnston County
Dear Mr. Stevens:
COUNCIL MEMBERS
ROBERT J. AHLERT
JAMES H. LIPSCOMB
BOB SATTERFIELD
BUTCH LAWTER
NOV 3 0 2000
As you may be aware, the Town of Clayton is preparing an Environmental Assessment
and NPDES application to expand the existing 1.9 mgd wastewater treatment facility to
2.5 mgd. We will be maintaining our existing discharge point on the Neuse River. Our
consultants have performed a desktop evaluation of the existing wastewater treatment
plant and, following minor construction, believe we can re -rate the treatment capacity of
the existing wastewater treatment plant from 1.9 mgd to 2.5 mgd. We have submitted
plans and specifications to DWQ for these minor modifications.
On July 10, 2000, the Town of Clayton received speculative limits from DWQ. The
speculative limits appear to follow those expected for expansions of existing WWTP's in
the Neuse River Basin; however, the Town of Clayton requests a clarification of a
statement in the speculation limit letter which states "To reiterate, design considerations
must include the ability to achieve an annual load based on a concentration of 3.5 mgd at
2.5 mgd, regardless to the Town's chosen route of compliance. " This statement implies
that the Town of Clayton must design and construct treatment facilities capable of
treating wastewater TN to 3.5 mg/L in any capacity expansion. Currently, the Town is a
member of the group compliance association and should not be subject to individual
permit limitations per our understanding of 15A NCAC 2B.0234. Our interpretation is
that our allocation purchase from the association or wetlands restoration fund would
increase from 21,400 lbs/yr at 1.9 mgd to 26,636 lbs/yr at 2.5 mgd in order to maintain
compliance with these regulations; however, our interpretation is also that because of
P.O. Box 879 • Clayton, North Carolina 27520 • [phone] • Fax [phone]

Mr. Kerr T. Stevens
November 20, 2000
Page 2
such membership, the regulations would not require additional treatment facilities be
constructed to treat to 3.5 mg/L TN.
Consultants for the Town have recently completed a nutrient removal study, which
indicates the existing WWTP will require significant construction in order to discharge a
TN of 3.5 mg/L. The Town would prefer to increase the permit to 2.5 mgd without the
initial expense of the construction of this nutrient removal treatment.
The trading/purchasing of nutrient credits will allow the Town to maintain compliance
with the regulations while phasing in additional construction costs. Prior to the Town
proceeding to construction on our minor construction items, we request this clarification
from DWQ by January 15, 2001. This clarification will allow the Town to continue to
implement wastewater improvements needed to meet demands from continued growth of
the area and for protection of the Neuse River.
If you have any questions about this matter, please contact either myself or our consultant
engineer, Mr. Michael Wicker, PE of Hobbs, Upchurch & Associates.
Si el ,
Steve Biggs
Town Manager
cc: Tim Simpson
James Warren
Michael Wicker
Russell Byrd
Ken Schuster
Dave Goodrich

Hobbs, Upchurch & Associates, P.A.
Consulting Engineers
300 S.W. Broad Street • Post Office Box 1737 • Southern Pines, NC 28388
December 13, 2000
Mr. Milt Rhodes
Division of Water Quality
Planning Branch
1621 Mail Service Center
Raleigh, NC 27699-1621
Re: Town of Clayton WWTP Upgrade
Environmental Assessment
Johnston County
HUA Project No. CT9905
Dear Mr. Rhodes:
Please find attached one copy of the revised Environmental Assessment for the Town of
Clayton WWTP upgrade. This environmental review is for the increase of the wastewater
treatment permit from the existing 1.9 mgd capacity to 2.5 million gallons per day capacity
and has been revised based upon comments received from your office dated February 14,
2000. Please note that the wastewater will be tertiary treated in an advanced wastewater
treatment facility and all portions of the proposed project will be constructed solely on this
existing WWTP site. The treated wastewater will continue to be discharged into the Neuse
River. As previously stated, the permitted increase to 2.5 mgd will be requested upon
completion of the EA process. With regard to the prior review of this document, there were
24 comments noted by the Division of Water Quality. A copy of this review letter is attached
for reference purposes. Each of the comments have been addressed accordingly in this
revised Environmental Assessment as follows:
Comment 1: Each category discussion was reviewed and the contents were placed
in the order of the level of significance from county to site specific. Two maps have
also been included in the Exhibits Section to better illustrate the boundaries of the
Town of Clayton's current service area, the WWTP site, and the discharge point.
Comment 2: The area to be served by this expansion project is the same as the
Town's current service area. This area is shown on one of the maps referenced in
Comment I above.
Comment 3: A Table of Contents has been added to the document.
Comment 4: Information regarding the Town's Strategic Growth Plan, Zoning
Ordinances, and Watershed Management Plan has been included by reference and
discussion in the appropriate sections of the document. In addition, all of these
documents are included in the Exhibits Section.
Southern Pines, NC • Telephone [phone] • Fax [phone] • e-mail: [e-mail]
Myrtle Beach • Nags Head • Raleigh • Charlotte

Page Two
December 13, 2000
Town of Clayton Environmental Assessment
Comment 5: Wetlands issues have been clarified in this revised EA. This proposed
project will not impact any wetlands.
Comment.6: There is only one water body within the area adjacent to the project
site. Detailed information on this stream, Little Creek, is included in the document.
Comment 7: Information on prime farmlands is included in the revised EA.
Comment 8: The various terms used in previous draft have been clarified and all
appropriate terminology has been defined.
Comment 9: The map referenced by this comment was an older map created prior
to the Town's discharge point being moved from Little Creek to the Neuse River and
has been removed from the Exhibits Section. The map noted in Comment 1 shows
the location of the current discharge point.
Comment 10: The reference to the table containing fecal coliform data has been
clarified and labeled.
Comment 11: The information included in the first draft of the EA for the Town of
Clayton covered additional references and data which went beyond the scope of this
current project and its projected effects. The information, which was not relevant to
this particular project, has been removed.
Comment 12: Impacts from the proposed increased discharge from the Town of
Clayton are discussed based on their own significance.
Comment 13: Specific impact statements are included in Section E: Predicted
Environmental Effects of the Proposed Project.
Comment 14: The project site area for this proposed expansion project has been
clarified. All construction will take place entirely on the current WWTP site.
Comment 15: The source for this information has been identified and cited.
Comment 16: There will not be any pipeline construction other than that which is
contained entirely on the grounds of the WWTP site. This statement has been
removed.
Comment 17: The statement claiming that the increase in the Town of Clayton's
discharge will have insignificant impacts to the use of the Neuse River by the Town
of Smithfield and Johnston County has been supported using current data.
Comment 18: The comparative statement has been removed.

Page Three
December 13, 2000
Town of Clayton Environmental Assessment
Comment 19: The buffer size, as contained in the Town's Watershed Management
Plan, is the same (minimum of 30 ft.) regardless of the development density.
Additional setbacks, yard footage, and permitted density restrictions are also included
in the Town's Plan regarding cluster development.
Comment 20: The paragraph regarding wastewater treatment and disposal has been
moved to Section B: Purpose and Need for the Project.
Comment 21: The locations of the exhibits are referenced accordingly.
Comment 22: This map has been removed and replaced by those maps denoted in
Comment 1.
Comment 23: A cover sheet with appropriate contact information has been included
in the document.
Comment 24: Based on a review of the most recent data, there are no mollusk
populations in the Neuse River downstream of the Town's discharge point.
Upon review of this revised Environmental Assessment, please contact either myself or
Angie Mettlen of this office immediately if you should have any additional questions or need
more copies of this report. We understand additional copies will be requested upon
completion of your initial review. Thank you for your prompt consideration and review.
Sincerely,
Hobbs, Upchurch & Associates, P.A.
Michael C. Wicker, P.E.
Environmental Division Manager
cc: Steve Biggs, Town of Clayton
Tim Simpson, Town of Clayton
James Warren, Town of Clayton
Russell Byrd, Hobbs, Upchurch
Attachments

Town of Clayton
QOUGLAS A. McCORMAC
Mayor
RONALD E. GURGANUS
Mayor Pro Tern
STEVEN BIGGS
Town Manager
JASONJ.KAUS
Town Attorney
JESSICA COUTU, CMC
Town Clerk
November 20, 2000
Mr. Kerr T tevens
Division irector
Divisi of Water Quality
1617 ail Service Center
iQh, NC 27699-1617
`Y }
Town of Clayton
Wastewater Treatment Plant Improvements
NPDES No. NC 0025453
Johnston County
Dear Mr. Stevens:
COUNCIL MEMBERS
ROBERT I. AHLERT
JAMES H. LIPSCOMB
BOB SATTERFIELD
BUTCH LAWTER
Nov 2 7WAT2001
D►DIRECTORES 0 FICEY
As you may be aware, the Town of Clayton is preparing an Environmental Assessment
and NPDES application to expand the existing 1.9 mgd wastewater treatment facility to
2.5 mgd. We will be maintaining our existing discharge point on the Neuse River. Our
consultants have performed a desktop evaluation of the existing wastewater treatment
plant and, following minor construction, believe we can re -rate the treatment capacity of
the existing wastewater treatment plant from 1.9 mgd to 2.5 mgd. We have submitted
plans and specifications to DWQ for these minor modifications.
On July 10, 2000, the Town of Clayton received speculative limits from DWQ. The
speculative limits appear to follow those expected for expansions of existing WWTP's in
the Neuse River Basin; however, the Town of Clayton requests a clarification of a
statement in the speculation limit letter which states "To reiterate, design considerations
must include the ability to achieve an annual load based on a concentration of 3.5 mgd at
2.5 mgd, regardless to the Town's chosen route of compliance. " This statement implies
that the Town of Clayton must design and construct treatment facilities capable of
treating wastewater TN to 3.5 mg/L in any capacity expansion. Currently, the Town is a
member of the group compliance association and should not be subject to individual
permit limitations per our understanding of 15A NCAC 2B.0234. Our interpretation is
that our allocation purchase from the association or wetlands restoration fund would
increase from 21,400 lbs/yr at 1.9 mgd to .26,636 lbs/yr at 2.5 mgd in order to maintain
compliance with these regulations; however, our interpretation is also that because of
P.O. Box 879 • Clayton, North Carolina 27520 • [phone] • Fax [phone]

° Mr. Kerr T. Stevens
November 20, 2000
' Page 2
such membership, the regulations would not require additional treatment facilities be
constructed to treat to 3.5 mg/L TN.
Consultants for the Town have recently completed a nutrient removal study, which
indicates the existing WWTP will require significant construction in order to discharge a
TN of 3.5 mg/L. The Town would prefer to increase the permit to 2.5 mgd without the
initial expense of the construction of this nutrient removal treatment.
The trading/purchasing of nutrient credits will allow the Town to maintain compliance
with the regulations while phasing in additional construction costs. Prior to the Town
proceeding to construction on our minor construction items, we request this clarification
from DWQ by January 15, 2001. This clarification will allow the Town to continue to
implement wastewater improvements needed to meet demands from continued growth of
the area and for protection of the Neuse River.
If you have any questions about this matter, please contact either myself or our consultant
engineer, Mr. Michael Wicker, PE of Hobbs, Upchurch & Associates.
Si el ,
A
Steve Biggs
Town Manager
cc: Tim Simpson
James Warren
Michael Wicker
Russell Byrd
Ken Schuster
Dave Goodrich

TOWN OF CLAYTON
"SERVICE" OPERATIONS CENTER
ELECTRIC SERVICE
L��rToti
[phone]
,•
VEHICLE MAINTENANCE
i
i-�. <�
[phone]
September 6, 2000
Dave Goodrich
NCDENR
Division of Water Quality
NPDES Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Re: NPDES Permit Addendum NCO025453
Dear Mr. Goodrich:
"ENVIRONMENT'
PUBLIC WORKS
[phone]
WATER RECLAMATION
[phone]
I purpose of this letter is to request an addendum to the recently issued NPDES Permit #
NCO025453 to the Town of Clayton. We are requesting that the following language be
added to the Effluent limitations and Monitoring Requirements.
A(5.)
In accordance with 15A NCAC 2B. 0505 (c) (4), stream sampling may be discontinued 1
when 11ow conditions could re:;ult 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.
This provision also applies to influent and effluent sampling.
1 look forward to your response, please contact the at 919-553-1536 if you have any
questions.
ely,
i4l _
Lames Warren
ORC, Town of Clayton
xc: Steve Biggs
Tim Simpson
S E P 1 1 2000
DFNR -
F0!hT
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653 Highway 42 West • P.O. Box 879 • Clayton, North Carolina 27520 • [phone] • Fax [phone]

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