NC0025453_Environmental Assessment_20020411

NPDE:i DOCUWENT SCANNINO 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:
April 11, 2002
This �3ocument is printed on reuBe paper - igziore any
content on the reirerse side

DIVISION OF WATER QUALITY
April 11, 2002
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
Amendment to 201 Plan
NPDES No. NC0025453
Johnston County
I have reviewed the Amendment to the 201 Plan submitted by The Wooten Company on
behalf of the Town of Clayton. The 201 Plan Amendment represents the flow expansion
of the Little Creek Wastewater Reclamation Facility from 1.9 MGD to 2.5 MGD and,
specifically, addresses how the Town will comply with nutrient limits. Some of the
issues regarding alternatives to discharge may be addressed within this 201
Amendment or, if not within the 201 Amendment, these issues must be addressed as
part of the permit application for expansion to 2.5 MGD. Adequate alternative analyses
are required both through the Antidegradation Policy, 15A NCAC .0201(c), and through
the Neuse River Basin - Nutrient Sensitive Waters Management Strategy, 15A NCAC
.0234 (8)(a & b).
Formation of a Compliance Group
As discussed in the meeting held April 25, 2001, depending on the tinning 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/l TN referred to in 15A NCAC 2B .0234 (8). 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 the
formation of any Compliance Association.

N
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 application of a permit for 2.5 MGD.
Per 15A NCAC 2B .0234 (8) (c), the Town of Clayton will be required to pay the offset
payment at the time of application for expansion (unless the Compliance Association
is formed). For comparison purposes this initial cost should be included as an up-
front capital cost for each appropriate alternative. Therefore, each alternative
should include a pathway with and without formation of the Compliance
Association. The estimated up -front capital cost has been included with this
document (the listings are based on a projected TN equivalent effluent concentration
of 3.5 mg/1 or 3.0 mg/1).
As of this date, the Compliance Association and resultant Memorandum of
Agreement has not been formed legally. Unless the status of this agreement
changes between now and Clayton's application for the increase in flow, the Town
will be subject to stringent nutrient limits (as correctly stated in paragraph 2 of the
Summary, p.1 and Item No. 2, p.2).
Specific Comments on Alternatives
The Division is encouraged by the Town's pursuit of reuse wastewater at the golf course
and recommends that the Town further investigate other avenues for reuse of
wastewater. Are there other public areas where reuse may be feasible? Pursuit of this
alternative should be documented in greater detail.
The amended plan indicated that Clayton also sought to discharge a portion of
wastewater to the City of Raleigh and that the City rejected this request. The Town of
Clayton should also provide documentation that they have contacted Johnston County
about transfer of wastewater (at least with regard to the 0.6 MGD of wastewater).
Johnston County is also in the process of expansion to at least 7 MGD. Since the
County is further along in the process at this time than the Town, this should be
actively pursued and documented.
The Town also pursued the possibility of relocation of the discharge to the Cape Fear
River Basin, specifically to Kenneth Creek. This alternative was deleted for a variety of
reasons. The Division would have rejected this alternative due to the impaired status of
Kenneth Creek - this Creek is currently listed on the state's 303 d list of impaired
waters.
2

Long -Term Planning
The Division is also concerned that this expansion is only a short-term solution to long
term growth. The Town should, even at this time, be moving forward with long range
planning and documentation to meet the continued growth issues occurring in the
County. The document states that Clayton may need to expand to at least 4 MGD in
the future to meet its projected growth. IYs likely by the time the expansion to 2.5
MGD, and subsequent nutrient reduction is attained, Clayton may again need to
expand. The Division encourages the Town to begin planning for this inevitability now.
cc: Bobby Blowe, Construction Grants & Loans
Ken Schuster, RRO/WQ
3

EXAMPLES: FINANCIAL IMPACTS OF NEUSE NSW MANAGEMENT STRATEGY
ON THE TOWN OF CLAYTON
Current Conditions
Potential
Future Conditions
(a)
(b)
(c)
(d)
(e) 1 (0
)
h)
0)
Flow
TN
TN
Future
TN
TN
TN
Total TN mass over
Total Offset
(MGD)
(mg/l,
(mass
Flow
(mg/l,
(mass
(est. treatability
allocation and
Payment
conc.
allocation)
(MGD)
conc.
allocation)
concentration
subject to offset
e iv -lent
equivalent)
& mass equiv.)
payment
Clayton 1.9
3.7 mg/1
21,400
2.5
2.8 mg/l
21,400
3.5 mg/1 (73
26,645-21,400
$3,460,000
(If TN of
lbs/yr
lbs/yr
lbs/day)
= 5,245 lbs/yr
3.5 mg/1
Less than BAr
= 26,645 lbs/yr
can be
met)
Clayton
1.9
3.7 mg/l
21,400
2.5
2.8 mg/1
21,400
3.0 mg/l (62.6
22,849 - 21,400
$ 0.956 M
(If TN of
lbs/yr
lbs/yr
lbs/day)
= 1449 lbs/yr
3.0 mg/1
Less than BAr
= 22,849 lbs/yr
$956,000
can be
met)
* BAT (Best Available Technology), is considered as 3.0 mg/l TN at this time. The projected concentration equivalent for Clayton after expansion
is 2.8 mg/1, which is less than BAT.
Ref. 15A NCAC 2B .0234 Neuse River Basin - NSW Management Strategy: Wastewater Discharge Requirements.
Parts (7) and (8) refer to new and expanding facilities,* respectively.
FOOTNOTES (next page)

EXAMPLES: FINANCIAL IMPACTS OF NEUSE NSW MANAGEMENT STRATEGY
ON THE TOWN OF CLAYTON
FOOTNOTES
(a) Current permitted/design flow.
(b) The concentration equivalent (mg/1) of the total yearly nitrogen mass allocation. This value is calculated as follows (for Clayton):
PF * conc. * 8.34 = Allocation/365 d
Conc = (21,4001bs/yr * yr/365 d) / 1.9 * 8.34
= 3.7 mg/1
(c) The total nitrogen annual mass allocation (this has been set and pre -determined with implementation of the temp. rule).
(d) Hypothetical future permitted flow.
(e) The concentration equivalent (mg/1) of the total annual nitrogen mass allocation based on the hypothetical permitted future flow. This value is calculated
similarly to that shown in (b):
PF(future) * conc. * 8.34 = Allocation/365 d
Conc. _ (21,400 lbs/yr * yr/365d) / 2.5 * 8.34
= 2.8 mg/l
(0 The total nitrogen mass allocation (same as (c)).
(g) The Division has made the assumption that at this time 3.5 mg/1 TN is Best Available Technology - it's possible a facility may be able to achieve a lesser
concentration. However, for this example 3.5 mg/1 TN will be assumed as the proposed minimum treatment technology (and this value is also used in the
rule). Should a facility prove that a lesser value is feasible, the offset calculation may be adjusted accordingly. The calculation is as follows:
Allocation = PF(future) * 3.5 mg/1 * 8.34
=2.5*3.5*8.34
73 lbs/day * 365d/yr
26,645 lbs/yr
(h) The facility must pay the difference between what their present annual mass nitrogen allocation is and what the calculated load at BAT of 3.5 mg/1 is. This
means paying the difference between the load at 2.8 mg/1(concentration based on allocated load) and 3.5 mg/l for the future flow of 2.5 MGD (in the case of
Clayton)
Offset load = Load at 3.5 mg/l & 2.5 MGD - Allocated load
= 26,645 - 21,400
= 5245 lbs/year
(1) As stated in the rule, the offset cost must be determined based on $11 lb TN/yr for a period of 30 years at 200
Total offset cost = Offset Load * $11 lb TN/yr * 30 yr * 2
=5245* 11 *30*2
_ $ 3.460,000 or $3.46 M

Clayton
Subject: Clayton
Date: Tue, 12 Mar 2002 08:50:24 -0500
From: Rob Brown <[e-mail]> Rogv�l 2
Organization: DENR/DWQ/Contruction Grants and Loans
To: Susan A Wilson <[e-mail]>
Susan, Larry Horton said you may have a question on the Clayton FP. We
have two Clayton projects currently in house; one is a 4th round grant
PER for reuse at the plant. The other (the one I think you are
interested in) is an FP for upgrading the the existing plant once it is
rerated to 2.5 mgd. Apparently, when rerated the plant (currently 1.9
mgd) will not have the ability to handle the nutrient loading. This
project adds a couple of anoxic basins and tertiary filters. There is
mention that this is a 10 year plan and that 20 year planning would
involve expansion to 4.0 mgd. We have not reviewed the project yet but
in my conversations with the AE they indicate that the town, for
economic reasons, can only afford to go to 2.5 mgd now and will expand
in the future if Clayton continues its explosive growth. They don't seem
to think they can stay in the receiving stream at 4.0 mgd and probably
not even on the existing site. Mail me or buzz me at 715-6213 if you
have any questions or need to talk about the project.RB
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I of 1 3/12/02 8:53 AM

mrcnae, r. cas,ey, governor
William G. Ross Jr., Secretary
i North Carolina Department of Environment and Natural Resources
r
r Gregory J. Thorpe, Ph.D.
Acting Director
Division of Water Quality
February 24, 2002
Michael Wicker
Hobbs, Upchurch, and Associates
290 SW Broad Street, PO Box 1737
Southern Pines, North Carolina 28388
FES „ 6 2002
�J
Re: SCH File #02-E-4300-0275, WWTP Capacity Increase for Clayton Water
Reclamation Facility
Dear Mr. Wicker:
On January 16, 2002, the State Clearinghouse deemed the North Carolina Environmental
Policy Act review on the above project complete (see attached letter from the Clearinghouse). It
is now acceptable to proceed with your permit applications through the Division of Water Quality
for the proposed project. No further actions on the Environmental Assessment are required.
If there is anything I can assist you with, please do not hesitate to give me a call at (919)
733-5083, ext. 366.
Sincerely,
Milt Rhodes
Watershed Planner
Attachments: (SCH Sign Off Letter, FONSI w/Conditions)
cc. Ken Schuster, Supervisor Raleigh Regional Office
Kim Colson, Supervisor Non -discharge Permitting Unit
Dave Goodrich, Supervisor NPDES Permitting Unit
N. C. Division of Water Quality 1617 Mail service Center Raleigh, NC 27699-1617 [phone]
Customer Service
1 800 623-7748

01
North Carolina
Department of Administration
Michael F. Easley, Governor
January 16, 2002
Mr. Milt Rhodes
N.C. Dept. of Env. & Nat. Resources
Div. of Water Quality
Archdale Bldg. - 1617 MSC
Raleigh, NC 27699-1617
Dear Mr. Rhodes:
Gwynn T. Swinson, Secretary
Re: SCH File # 02-E-4300-0275; Environmental Assessment/Finding of No Significant Impact Town
of Clayton - Proposal to Increase Treatment Capacity from Clayton's Water Reclamation Facility
from 1.9 MGD to 2.5 MGD
The above referenced environmental impact information has been reviewed through the State
Clearinghouse under the provisions of the North Carolina Environmental Policy Act.
No comments were made by any state/local agencies in the course of this review. Therefore, no further
environmental review action on your part is required for the compliance with the Act.
Best regards.
cc: Region J
Sincerely,
6 114V�l
Ms. Chrys Baggett
Environmental Policy Act Coordinator
116 West Jones Street Raleigh, North Carolina 27603-8003 Telephone [phone]
An Egrial Opportunity / Affirmative Action Employer

Ile
FINDING OF NO SIGNIFICANT Il"ACT
Environmental Assessment for the
Town of Clayton Water Reclamation Facility Upgrade and Expansion
Johnston County
December 7, 2001
An environmental assessment (EA) has been prepared pursuant to the requirements of the
North Carolina Environmental Policy Act, for the proposed Town of Clayton Water Reclamation
Facility and discharge to Little Creek in Johnston County. The Town of Clayton desires to
increase their water reclamation facility treatment plant capacity from 1.9 mgd to 2.5 mgd and
upgrade facilities at the current plant site. The treated wastewater would continue to be
discharged into the Neuse River at the same location.
This project will upgrade the existing facility located between SR 1700 and NC 42 in
northwest Johnston County. This facility presently discharges into Little Creek near US 70. The
project will involve minor modifications to existing structures on site. The upgrades planned for
construction on this previously disturbed 10-acre site should disturb less than 1 acre and not
involve extensive construction activity. The project also seeks to expand permit limits in order
to optimize treatment capacity and make upgrades to pumps, piping and other facility
components.
The Town of Clayton desires this expansion and upgrade to meet current and expected
growth demands in the East Clayton industrial area, East Clayton Elementary School, and the
interchange area associated with Interstate 40 and NC 42. This service area also includes the
Cleveland community. This project does not increase service area for the town of Clayton. It is
anticipated that this service area will grow faster than projected growth rates generated in earlier
201 Facility Plans for the Town, thus necessitating this project.
This project has been designed to m" i izE environmental impacts. As the immediate
project impacts will be located on an existing site, there are no prime farmlands or agricultural
areas that will be impacted through this project. The service area contains numerous wetland
areas and supports a variety of upland and wetland habitats. The surface waters are nutrient
sensitive and special regulations are in place to assist in the protection of these resources. The
Neuse River basin is also of particular concern because of eutrophication associated with
increased nutrients and the accumulation of these nutrients in the lower portion of the basin,
therefore special care and consideration is required for projects. Much of the Neuse is classified
as WS IV- NSW, however, Little Creek is classified as Class C — NSW.
Six alternatives were evaluated in this project proposal; (1) No Action, (2) Optimize
operation of existing waste water treatment plant, (3) Modify the existing wastewater treatment
plant and convey to a separate site for land application, (4) Divert flow as necessary from east
Clayton area to the Central Johnston County Regional Plant and upgrade Clayton Plant to treat
remaining waste stream and discharge to the Neuse River with effluent limits of 10/4/02 and

t
future effluent limits of 5/2/2, (5) Modify existing wastewater treatment facility for preliminary
flow and discharge to City of Raleigh treatment facility, and (6) Modify existing treatment
facility for preliminary treatment and discharge to Central Johnston County Regional Facility.
Each alternative was also evaluated for fiscal impact to service area. These alternatives were first
evaluated in 1993 in a 201 Facility Plan. These alternatives were refined and modified for this
specific permit expansion request.
Upon review of these alternatives, the preferred approach. is to pursue alternative 4. This
alternative provides the most economical alternative, and allows for a more efficient treatment of
wastewater yielding a higher quality effluent and satisfies sewer service demands.
This project has been designed to minimize direct and secondary and cumulative impacts.
However, a large number of rare, threatened and endangered amphibian, fish, and mollusk
species in the streams of the project area (particularly Swift Creek) are noted in the document.
The Town of Clayton has a number of programs established to minimize the long term and
indirect impacts associated with the expansion of sewer capacity in the area. These programs
include the Water Supply Watershed Protection Program, incorporation of local buffer
regulations that surpass (though minimally) state mandated Neuse Buffer Rules, creation of local
stormwater control ordinances that serve to minimize impacts of new developments, and a
number of local growth and strategic planning efforts being implemented to help shape where
growth occurs.
Based on the findings of the EA and on the impact avoidance/mitigation measures contained
therein, it is concluded that the proposed project will not result in significant impacts to the
environment. This EA and Finding of No Significant Impact (FONSI) are prerequisites for the
issuance of the permit actions by the Division of Water Quality. Pending approval by the State
Clearinghouse, the environmental review for this project will be concluded and future concerns
and issues will be resolved during subsequent permit application and review. An environmental
impact statement will not be prepared for this project.
Division of Water Quality
December 7, 2001

Y
Town of Clayton CT9905
Environmental Assessment for WWTP Expansion
11. Forest Resources
No forested lands exist at the WWTP site; therefore, will not be any direct or
indirect disturbance or change in forested lands as result of this expasion project or
its subsequent operation.
12. Shellfish or Fish and Their Habitats
There are no direct or indirect impacts from the proposed project to any of the
Natural Heritage Waters. In addition, there does not appear to be any adverse _
impacts, direct or indirect, on shellfish, fish and their habitats by the construction of
this WWTP expansion project. _
While species of interest of concern may exist in the Neuse River, it . is not anticipated
that this operation of this expansion project would have any significant negative impact
on their habitat. The Division of Water Quality monitoring does not indicate any
significant impacts as a result of the Town of Clayton discharge and this relatively small
increase in flow will not result in a disproportionate change in impacts.
13. Wildlife and Natural Vegetation
The construction and operation of the WWTP expansion site will not have direct or
indirect impacts on wildlife habitat or natural vegetation. _
14. Introduction of Toxic Substances
Construction and subsequent operation of the expansion project should not result in. -
introduction of toxic substances into the environment, through either direct or
indirect means. The continued use of ultra -violet radiation for disinfection and the
-. continued adherence to the pretreatment program will allow the Town to remain
compliant with the toxicity limits in the NPDES permit.
F. ..MITIGATIVE MEASURES
The proposed project will result in minimal adverse environmental impacts, most of
which are considered to be insignificant in their effects, as discussed in the previous
section. Therefore, only Item 10, Water Resources, will be dealt with in this section.
Water Resources
Rules were drafted that require all dischargers below the Falls Dam that have a design
flow of 0.5 MGD or greater (major dischargers) to meet annual nitrogen loads based on
their permitted flow and a concentration of approximately 3.7 mg/1 TN. The current point
source rule contains limits of 5.5 mg/l TN for major dischargers above Falls Dam. A
mechanism was also established that allowed the point sources to meet the nitrogen
reduction goal collectively. The intent of this rule was to achieve a 30% reduction in
HUA Page 48 12/13/00

Town of Clayton CT9905
Environmental Assessment for WWTP Expansion
point source loading at the estuary. Currently, point sources are discharging 4.1 million
pounds of nitrogen per year to the Neuse River. In order to achieve a 30 percent
reduction, dischargers must reduce their nitrogen contribution to 2.8 million pounds per
year. This rule equitably allocates the 2.8 million pounds per year between 3 different
groups of dischargers within the Neuse basin. The nitrogen is to be allocated to the
individual dischargers based upon the ' ratio of their permitted flow, with each facility's
permitted flow established in the rule, to the sum total permitted flow of these discharges
below the Falls Lake Dam. Under the proposed Neuse River Rules, dischargers have the
option to join a coalition of dischargers to allow implementation of point source controls
in a more cost-effective manner throughout the basin.
The Town of Clayton currently treats its wastewater to the state of the art for tertiary
treated wastewater. The proposed expansion continues to treat the wastewater to tertiary
limits. The Town of Clayton will continue to evaluate the . operations of the wastewater
treatment plant to address nitrogen reduction below 3.5 mg/l in the effluent. Methods
such as biological nutrient removal, chemical treatment and reuse are being evaluated for
implementation into the proposed expansion prior to the 2003 NPDES permit deadlines.
The Town is also participating with the Upper Neuse Basin Association, and as such, the
proposed capacity expansion. of the WWTP should be mitigated by the tighter limits
required to be met by this plant on its.own and in conjunction with its participation in this
Association.
The Division of Water Quality stormwater rules apply to the 10 largest municipalities and
5 counties within the Neuse River Basin. The rules require DWQ and the local
governments to develop a model stormwater management plan that addresses new
development, public education, illegal discharges, and identifying _ sites that could,
potentially, be retrofitted with stormwater controls. Local governments have an additional
18 months to develop a local plan that includes the same components as the model plan.
The Neuse River Basin Rule also requires the basin's most heavily populated and fastest
growing local . governments to take responsibility for managing their stormwater. Under
this program, the affected local governments would be required to work cooperatively
with DWQ to develop and implement a local stormwater management program to reduce
nitrogen by 30 percent. The affected local governments include ten municipalities (Cary,
Durham, Garner, Goldsboro, Havelock, Kinston, New Bern, Raleigh, Smithfield and
Wilson) and five counties (Durham, Johnston, Orange, Wake.and Wayne). The program
must include reviewing new development plans to ensure that they have adequate
nitrogen controls, educating the public on how to reduce nitrogen loading from their
homes and businesses, and identifying areas suitable for adding vegetated areas, wetlands
and other measures for removing nitrogen from urban areas. The Neuse Rule further
requires that riparian (Streamside) areas be protected and maintained on both sides of
streams, river, lakes and estuaries. A total of 50 feet of riparian area would be required
on each side of the waterbody. This 50-foot area would consist of 30 feet of virtually
undisturbed forest vegetation and 20 feet of grass, vegetation or trees that could be
harvested.
HUA Page 49 12/13/00

CT9905
Town of Clayton
Environmental Assessment for WWTP Expansion
Appropriate erosion control during construction, and operation within permitted
limitations will mitigate any negative impact to water supplies. The Town of Clayton has
implemented these rules into their existing zoning requirements and has adopted a
Watershed Management Plan and a Strategic Growth Plan, and therefore, any, additional
this expansion project
nonpoint source impact, such as stormwater runoff, as a result of
will be effectively mitigated through these measures.
G. REFERENCES
Amendment No. I to Clayton 201 Wastewater Treatment Facilities Plan, McKim & Creed
Engineers, November 1992.
Ad
dendum No.1 to Amendment No. 1 to Clayton 201 Wastewater Treatment Facilities
Plan, McKim & Creed Engineers, April 1993.
Needs Survey for the Town of Clayton, McKim & Creed Engineers,1997.
1999 Capital Improvements Plan, Town of Clayton, July 1999.
Town of Clayton Zoning Ordinance, Town of Clayton Planning Department, January
1993.
Town of Clayton Wastewater Treatment Plant Upgrade Evaluation, Hobbs, Upchurch & ^
Associates, P.A., June 1999. ,
Neuse River Basinwide Water Quality Plan, NCDENR, Division of Water Quality, Water
Quality Section, December 1998. _.
Neuse Letter, North Carolina Cooperative Extension Service, September 1997.
Soil Survey of Johnston County, North Carolina, USDA, Soil Conservation Service, ^ -
October 1994. -.
File Correspondence, Staff Reports, Raleigh Regional Office, NCDENR, Division of ^
Water Quality, October 1999. - -
H. EXHIBITS (See Attached)
I. STATE AND FEDERAL PERAHTS REQUIRED
An amendment to the existing NPDES permit issued by the Division of Water Quality
will be required to increase the flow from 1.9 mgd to 2.5 mgd and issue new permit limits
at the expanded flow. An authorization to construct permit from the Division of Water Quality will be required to re -rate the WWTP to a design capacity of 2.5 mgd. Plans and
specifications for the minor plant modifications and the recent engineering evaluation by
Page 50
12/13/00
HUA

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clayton's Ea follow-up
Subject: clayton's Ea follow-up
Date: Mon, 20 Aug 2001 14:48:40 -0400
From: Susan Wilson <[e-mail]>
To: Milt Rhodes <[e-mail]>
do you need a written response from me on this one? let me
know...elsewise the following is my response.
We're delighted with their efforts to perform some wastewater re -use and
pleased that they have received funding to do so. Their re -iteration of
the possible implications of formation (or not) of the Compliance
Association is adequate. I think we can recommend proceeding forward
with this one (although in the future, all permittees need to formulate
a 20 year plan with any EA).
1 of 1 8/20/01 2:49 PM

Facility Name
Clayton
Parameter =
Lead
NPDES #
NC0025453
Standard =
25
erg/I
33.8 ug/I - Acute value
Ow (MGD)
1.9
7010s (cfs)
186
_
n
BDL=1 /2DL
ctual Data
RESULTS_
1 WC (%)
1.56
_
1
2.5
<5
Std Dev.
1.899997655
c'ving Stream
Neuse River
2
2.5
_ 2.5
<5
Mean
1 C.V.
3.397058824
0.559306669
Stream Class
31
_
<5
4
2.5
<5
--
-
FINAL RESULTS
5
_ 2.5
<5
Lead
6
5.6
5.6
Mult Facto
1.9
Max. Pred Cw
18.05
ug
7
2.5
<5
Max. Value
9.5
Ng/i...
Allowable Cw
33.8
ug
8
2.5
<5
Max. Pred
18.05
Ng/t::::
Max. Value
9.5
9
2.5
<5
Allowable
33.80
Ng/f::;
10
2.5
<5
-----
11
2.5
<5
Y
12
2.5
<5-fpr
-
s 'OQ
_
MAq 01 _
13
2.5
<5
14
2.5
<5
15
2.5
<5
Y
16
2.5
<5
17
2.5
<5
18
2.5
<5
19
2.5
<5
---
20
2.5
<5
21
9.5
9.5
_-
_
22
23
6.6
7.3
6.6
7.3
� -�---
24
7.8
7.8
25
261
2.5
2.5
<5
<5
_
-- -
27
2.5
<5
_
_
_
28
_
2.5
<5
_
29
2.5
<5
_
30
2.5
<5
31
2.5
<5
_
i
32
2.5
33
34
6.2
5
_<5
6.2
<10
_
35
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7/13/01 Clayton

Hobbs, Upchurch & Associates, P.A.
Consulting Engineers
NO 300 S.W. Broad Street • Post Office Box 1737 • Southern Pines, NC 28388
July 23, 2001
Mr. Milt Rhodes
Division of Water Quality
Planning Branch
1621 Mail Service Center
Raleigh, NC 27699-1621
Re: Environmental Assessment Comment Response
Town of Clayton - Little Creek Wastewater Reclamation Facility Upgrade
Johnston County
NPDES Permit NC0025453
RUA Project No. CT9905
Dear Mr. Rhodes:
Thank you for your letter dated May 23, 2001, which included comments from the NCDENR—
Division of Water Quality (DWQ) and the NC Wildlife Resources Commission. The concerns
have been addressed in the Environmental Assessment; however, from these comments, it was
clear that clarification was necessary for each agency. This correspondence has been prepared
to address these issues so that the environmental review process can proceed as expeditiously as
possible.
NCDENR—DWO Comments
The NPDES Unit provided comments based on their concerns with regard to the more
stringent nutrient limits, specifically those for total nitrogen, and the ultimate ability for the
Town of Clayton to meet these limits with the flow expansion of the Little Creek Wastewater
Reclamation Facility to 2.5 MGD.
In response, Hobbs, Upchurch & Associates provides the following information in order to
adequately address the comments.
The Environmental Assessment that has been prepared is for a wastewater facility upgrade
project. An Authorization to Construct was received by the Town of Clayton on May 24,
2001 for upgrades to the existing wastewater treatment facility. These upgrades are located
on the existing plant site and have very little environmental impact from construction. While
it is recognized that these approved improvements will help to facilitate the re -rating to 2.5
MGD, additional measures to reduce Total Nitrogen are necessary and will be addressed in
the submittal for an Authorization to Construct for the re -rating of the plant. This submittal
will follow the approval of the Environmental Assessment and the NPDES request for the
expansion to 2.5 MGD. It should be noted that the environmental impacts of this flow
Southem Pines, NC • Telephone [phone] • Fax [phone] • e-mail: [e-mail]
Myrtle Beach • Nags Head • Raleigh • Charlotte

4 ,1
Town of Clayton EA Comment Response
July 23, 2001
expansion are addressed in this Environmental Assessment since the speculative discharge
limits are presented and evaluated. The discharge of Total Nitrogen is set at 21,400 lbs/yr;
therefore, the direct impacts of the increased discharge from 1.9 MGD to 2.5 MGD to the
Neuse River from Total Nitrogen are minimal.
It is further recognized, however, that the comments from the NPDES Unit are more
proactive in nature and are requesting that the Town recognize and plan for these lower
limits, which will be associated with both the implementation of .the Neuse Rules and the
NPDES permit modification process for the increased flows. The Town of Clayton does
recognize this eventuality and has been and continues to evaluate and study all alternatives
for nutrient reduction.
The Environmental Assessment contains an Alternatives Analysis for the purpose of
demonstrating both the economic and environmental feasibility of each alternative *open to
the Town of Clayton. Based on the comments from DWQ, an additional discussion of the
nutrient reduction options allowed under the Neuse River Basin Rules is also needed. The
following paragraphs provide this discussion.
1. Nutrient Offset Payments
The Neuse Rules allow for wastewater dischargers to individually or collectively
reduce their respective nitrogen loadings through nutrient offset payments. If a
permitted wastewater discharger chooses this option, they are required to have
made an offset payment in an amount that is great enough to cover nitrogen
reduction for a period of 30 years. In addition, these payments are required to be
made prior to a NPDES permit reissuance.
A Nutrient Removal Study was performed for the Town of Clayton by The
Wooten Company and was completed in October 2000. In this study, numerous
alternatives were discussed; including the use of the nutrient offset payments.
Based on this study, the calculated total nitrogen annual mass permit limit at a
flow rate of 2.5 MGD is 26635.87 lb TN/yr. At the nutrient offset payment rate
of 200 percent of the cost at $11.00 lb TN/yr, Clayton would need to make a
minimum payment in excess of $3,455,000.00 in order to operate the facility at
2.5 MGD with a nitrogen discharge limit of 26635.87 lb TN/yr. (26635.87 —
21,400 = 5235.87 lb TN/yr for 30 years).
While this represents an option, the costs must be weighed against those costs for
the addition of a nutrient removal system at the wastewater treatment facility.
The primary difference in the level of these costs is that the entire nutrient offset
payment must be made at the time of the application for the permit modification,
whereas, the costs for the nutrient removal can be spread over a number of years.
Therefore, the option of using nutrient offset payments is still one that is feasible;
however, the immediate costs would certainly be greater than other options
available to the Town.

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Town of Clayton EA Comment Response
July 23, 2001
2. Basin Associations
Under the rules, a group of wastewater dischargers can collectively come together
to form an association for the purposes of working jointly to reduce their
collective nutrient loadings to the Neuse River. The association members must
enter into an agreement with the Division of Water Quality to establish annual
loading goals for the totality of the nutrient loading for all members. The
Environmental Management Commission must then formally approve the
agreement for it to in effect. Each individual discharger that is a member of the
association would not be subject to an individual total nitrogen limit but rather the
group's discharges could not exceed the total allocation calculated for the
association. Each individual discharge would also have a quarterly total
phosphorus limit of 2.0 mg/L.
Clayton is very interested in this option and has consistently expressed its
willingness to participate in this kind of alliance with the other wastewater
dischargers in the lower Neuse River Basin when the opportunity becomes
available.
The current Lower Neuse Basin Association was established in 1994 upon the
execution of a Memorandum of Agreement (MOA) with the DWQ in order to
design and implement a water quality monitoring program in the Neuse River.
This association, however, has not yet reached an agreement with DWQ with
regard to the collective nutrient loadings as has been done in the Tar -Pamlico
Basin.
If such an agreement can be reached, the participation in this association would be
one of the most feasible options for the Town; however, they are proceeding with
all necessary projects under the assumption that this alternative will not be
available to them within the time frame during which they will apply for the
NPDES permit modifications to increase the plant flow to 2.5 MGD.
3. Nutrient Trading
Another option allowed by the Neuse Rules is the trading of nutrient allocations
between discharge facilities within the basin. This requires one facility to
voluntarily agree to trade some portion of its nutrient allocation to another facility
and for the two to enter into an agreement for the long-term commitment of this
allocation transfer at an agreed upon rate.
While this represents an alternative to the Town of Clayton, it is not one that is
realistic given the situation with most all dischargers in the Neuse Basin. Clayton
would have to identify an entity with excess allocation, which is willing to trade
some portion of it to Clayton in exchange for some unknown rate of payment.
This is considered a very unlikely option for the Town.

Town of Clayton EA Comment Response
July 23, 2001
4. Treatment Optimization
The optimization of treatment to limit nutrient loading to the Neuse River is the
primary goal of the rules. The other alternatives discussed are used to supplement
treatment and to provide a resource for the restoration of wetlands and riparian
areas within the basin. If a facility were able to meet the stringent nitrogen limits
established, then it would be in compliance with the discharge requirements.
Treatment optimization can come through the upgrade of existing facilities by the
installation of nutrient removal systems, through the use of land application
practices, or through wastewater reuse, to name several alternatives. Each of
these can also be used in combination with nutrient offset payments, basin
associations, or nutrient trading to achieve the required limits.
This alternative represents the most feasible alternative to the Town of Clayton
and the one with which they are proceeding. To that end, the Town was recently
awarded a grant for the purpose of the construction of a wastewater reuse project.
It will allow treated effluent to be sent to the Pine Hollow Golf Course, a 150-acre
18-hole public course, for use as irrigation water. Based on initial calculations for
an irrigation rate of approximately 150,000 gpd, this reuse component will result
in an estimated total nitrogen reduction of 1,351 lb TN/yr. This project is
demonstrative of the Town's aggressive pursuit for all available options to meet
the stringent nutrient limits imposed by the Neuse Rules. The estimated cost of
this reuse project is $733,000.00. Using this option in concert with the nutrient
offset payments could also amount to a savings to the Town of $891,660.00, if
those payments were elected as the means of providing for the necessary nitrogen
reduction.
The preliminary route of the forcemain to transport the effluent to the Pine
Hollow Golf Course follows within existing road rights -of -way and will utilize
the golf course's existing irrigation system. These measures will minimize al
impacts associated with the construction of this reuse project.
The upgrade project for which this Environmental Assessment has been prepared
does include components necessary for the reuse project. Specifically, through
the upgrades to the existing clarifiers and oxidation ditches, these treatment
components will also be evaluated for optimal operation and used to achieve the
maximum level of nutrient removal possible.
In addition as stated in the Nutrient Removal Study, additional biological and
chemical treatment to reduce nitrogen will be necessary at the existing wastewater
treatment facility. These units would include anaerobic/anoxic basins, recycle
pump stations, chemical addition from existing caustic, alum, polymer, and
chlorine facilities, and supplemental methanol treatment, if necessary. The
treatment plant design will be optimized to remove nitrogen and phosphorus. The
preliminary construction costs for the necessary upgrades are estimated at
$5,417,000.00 from the Wooten Study.

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Town of Clayton EA Comment Response
July 23, 2001
Based on the above discussion, the following paragraphs represent the
modifications to the original Alternatives Analysis contained , in the
Environmental Assessment.
1. Do nothing (no action)
The first alternative of no action remains an unacceptable option to all parties
involved due to the inevitable restrictions on residential, commercial, and
industrial growth in the Town's wastewater service area, and a risk .of future
NPDES permit renewals with more stringent limits than the current facilities are
capable of achieving. As previously stated, the Town of Clayton is within 2-3
years of achieving flow rates, which would result in sewer moratoriums in the
area.
2. Regional Wastewater Treatment System
The second option of optimizing operation of the existing wastewater treatment
plant is currently being accomplished. While the Town currently sends 600,000
gpd to the Central Johnston County Regional Wastewater Treatment Plant
(CJCRWWTP) from its industrial area, this facility does not have the capacity to
accept additional flows from Clayton. Treatment levels at this facility would be
the same as those being faced at Clayton's Little Creek plant. Therefore, Clayton
would still need to purchase into the expansion of the CJCRWWTP in much the
same level as is needed for its facility. The costs for this option are contained in
the Environmental Assessment and are estimated at $5,740,000.00 for only a
600,000 gpd commitment. The Town would still be required to incur the costs to
upgrade their 1.9 MGD WWTP to the nutrient removal levels required by 2003.
While this is a feasible option, this option is not the best option at this time. It
requires more cost to the Town of Clayton, requires more extensive construction
impacts for the conveyance system, expansion of the Johnston County facilities,
and still requires construction at the Town of Clayton WWTP for nutrient
removal. The Regional WWTP options appear more attractive in the future
should additional growth in the Town of Clayton area require more extensive
expansions to the facilities beyond 2.5 MGD.
3. Land Application
The third option of land application was evaluated extensively in the original 201
facilities plan. Exhaustive efforts were made to locate adequate disposal sites in
the 201 area. Although site characteristics were conducive to the actual disposal
design criteria, it was impossible to locate sufficient land area within an
approximate 5 mile distance of the Town on even a semi -contiguous basis, i.e.,
perhaps half the land area in one site and the remainder distributed among two or
three separate sites in reasonable proximity. Further, at that time given the flow
projections and then anticipated application rates, the amount of land to be located
was approximately half of what would be required at this juncture. Accelerated
residential development demand pressure has made the land in the Clayton area
even more expensive and more difficult to obtain and locate. Therefore, the

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Town of Clayton EA Comment Response
July 23, 2001
viability of this option is virtually nil. As an illustrative example land application
of wastewater at 1" per acre per week requires approximately 750 acres of wetted
area to irrigate the entire amount necessary to eliminate the discharge.
Additionally 225 million gallons of storage lagoons would be needed to store
wastewater during inclement weather. The recent example of the Town of Garner
land application treatment facility being closed to divert their wastewater to the
City of Raleigh system indicates the unattractiveness of this option to an area
where residential growth is utilizing desirable land. The cost estimates for this
alternative are also contained in the Environmental Assessment and are estimated
to exceed $17,000,000.00.
4. Wastewater Reuse
The fourth alternative involves the reuse of wastewater and is considered to be a
feasible option for limited portions of Clayton's effluent. The Town has just
recently received a grant for the construction of a wastewater reuse project where
effluent will be set to the Pine Hollow Golf Course for use as irrigation water. The
initial estimates indicate that the implementation of this project will take
approximately 0.15 MGD of Clayton's discharge and divert it to the golf course.
The cost estimate for this project based on the Wooten Study is $733,000.00;
however, additional alternatives must be used in conjunction with this project in
order to enable the Little Creek treatment facility to operate at the eventual
expanded flow of 2.5 MGD.
5. Treatment Optimization
The alternative of optimizing operation of the existing wastewater treatment plant
is currently being accomplished. The evidence indicates that the facility will meet
current and immediately renewed NPDES permit limits at the proposed design
flow capacity of 2.5 MGD. This option continues to divert 600,000 gpd to the
CJCRWWTP from the industrial area while continuing to serve the Town of
Clayton residential and commercial district and the additional flow from the
County residents and commercial enterprises near Cleveland. The flow rating of
the WWTP would be increased to 2.5 MGD. The treatment optimization would
be used in conjunction with the wastewater reuse project and would require the
addition of biological and nutrient removal at the plant. The estimated costs for
the upgrade and optimization of the plant combined with the addition of the BNR
components are $6,147,000.00. This does represent one of the most feasible
options for the Town, as it will allow the use of multiple of projects either already
designed or funded, while also accomplishing the necessary nutrient reduction
that was required by 2003 for the existing 1.9 MGD WWTP. The above costs
include approximately $5 million dollars of cost to reduce nitrogen regardless of
the expansion of the WWTP to 2.5 MGD. The cost of this option may be reduced
during design by the conversion of the existing trickling filter plant structures to
anoxic/aeration basins or fermentation tanks. The estimated costs consider the
construction of all new structures for conservative cost estimating. Because the
existing units can be modified and upgraded for relatively minor construction
costs and all the construction can be accomplished on the existing site without

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Town of Clayton EA Comment Response
July 23, 2001
extensive construction impacts this option appears the most cost-effective
environmentally feasible option for the Town to expand their WWTP to current
needs, postpone the threat of sewer moratorium, and address the TN limit by
2003. Should the DWQ not permit these improvements to the level of treatment
required to meet the TN limit (approximately 2.8 ppm, 2.99 ppm with reuse
credit), then the Town of Clayton will purchase the extra TN required from the
Restoration Fund.
In summary, the Town of Clayton does recognize and is planning for the known eventuality .
of the reduction in the nitrogen limits for their discharge to the Neuse River. This evident by
the completion of the Nutrient Removal Study and the recent grant commitment received for
the wastewater reuse project. The Town also understands that it must be able to demonstrate
the effect that all of these projects, including the plant upgrade, will have on their ability to
remove adequate amount of nitrogen from their effluent at the time of the re -rating of the
plant and will be prepared to do so to the satisfaction of the DWQ.
At this time, however, the treatment plant, upgrades are of primary concern in this
Environmental Assessment. These upgrades are necessary not only to provide for the
wastewater treatment needs of the community but to optimize the operations of the plant in
preparation for the wastewater reuse project and the eventual increase in flows that will be
requested later through the NPDES permit modification process.
The Division of Water Quality has expressed concern that the expansion to 2.5 MGD does
not consider a 20-year planning period. To reiterate this expansion is not intended for a 20-
year planning period. The Town of Clayton recently has been threatened with a sewer
moratorium by the Division of Water Quality for exceeding allocations to the WWTP. While
flows have not yet exceeded the 80/90 rule requirements, everyone. acknowledges that the
growth in the Town of Clayton sewer service area will require additional capacity in the near
future. The Town of Clayton recognized that the existing 1.9 MGD WWTP was required to
meet TN requirements by 2003 and have addressed this by the Nutrient Removal Study by
the Wooten Company. In addition Hobbs, Upchurch & Associates, P.A. have evaluated the
optimization of the existing facility and concluded that 2.5 MGD is a feasible flow through
the existing WWTP with minor modifications. The Town recognized that for the costs of the
upgrade and nutrient removal projects that the Town could expand the NPDES permit to 2.5
MGD at the existing site. The Town also recognizes that this expansion may be no more
than a 5-year "solution" if growth continues in the area as is currently being seen. The Town
is preparing to enter into a 20 year planning period evaluation of the sewer needs of the
Town of Clayton. As discussed on several occasions in our meetings with DWQ this
planning will include additional reuse projects and cooperation with Johnston County to meet
the sewer needs of both governmental entities. The Town and the County already operate in
a spirit of cooperation, with intergovernmental agreements for sewer connections. The Town
and County both interchange flow where is feasible to reduce the costs of conveyance. The
20-year plan will certainly continue this evaluation of these options. The proposed expansion
to 2.5 MGD allows the Town of Clayton to prepare and implement such a 20-year plan. The
implementation of such plans is often a 5-year process.

aS
Town of Clayton EA Comment Response
July 23, 2001
NC Wildlife Resources Commission Comments
The primary comment received from this agency was in reference to the Town of Clayton's
streamside buffers requirements set forth in their protective ordinances. A memorandum was
sent directly to Mr. Bennett Wynne for clarification of the Town's requirements. Mr. Wynne
responded with a memorandum stating that the clarification provided by Hobbs, Upchurch &
Associates adequately addressed the concerns of the NC Wildlife Resources Commission.
Copies of these memoranda are attached for reference.
Eight copies of the final Environmental Assessment for the Little Creek Wastewater Treatment
Facility upgrades are included with this transmittal, each with a copy of this correspondence and
associated attachments addressing the final concerns. Please notify me as soon as possible upon
the drafting of the Finding of No Significant Impact and submittal to the State Clearinghouse so
that I can immediately notify the Town for planning purposes. Thank you for your prompt
consideration and review.
Sincerely,
Hobbs, Upchurch & Asso 'ates, P.A.
NNW
Water/Wastewater Division
Attachments
cc: Steve Biggs, Town of Clayton
Tim Simpson, Town of Clayton
James Warren, Town of Clayton
Michael Wicker, P.E., Hobbs, Upchurch

07/03/2001 02:42
2525229736
B WYNNE
PAGE 01/01
-
h Carolina Wildlife Resources Commi
Charles R- Fullwood, Executive Director
TO: Melba McGee
Office of Legislative and Intergovernmental Affairs
Angie Mettlen
Hobbs, Upchurch & Associates, P.A.
FROM: Bennett Wynne
Habitat Conservation Program
DATE: July 3, 2001
SUBJECT: Follow-up on our March 7, 2001 comments re: Town of Clayton W WTP
Expansion Environmental Assessment (EA), Johnston County, North Carolina.
Project Number: 1101.
Per a fax received July 3, 2001, project consultants have clarified that the Town of
Clayton's Watershed Protection and Strategic Growth Plans require streamside buffers a
minimum of 55 ft. in total width. This exceeds the Neuse Buffer Rules total width requirement of
50 ft. and will afford listed aquatic species some additional protection. Based on this clarification,
we now concur with the EA.
Thank you for the opportunity to Further comment on this project. If you have questions,
please call me at [phone].
Mailing Address: Division of Inland Fisheries • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] ext. 281 • Fax: [phone]

MEMO
Hobbs, Upchurch
141 & Associates, P.A.
Consulting Engineers
P.O. Box 1737
300 S. W. Broad Street
Southern Pines, North Carolina 2838*0
[phone] FAX [phone]
TO: Bennett Wynne FAX NUMBER: 252-522-9736
North Carolina Wildlife Resources
Commission
Habitat Conservation Program
FROM: Angie Mettlen HUA PROJECT # CT9905
Hobbs, Upchurch & Associates, P.A.
DATE: July 3, 2001
RE: NC Wildlife Resources Commission Comments
Town of Clayton Wastewater Treatment Plant Upgrade/Expansion Environmental Assessment
Johnston County, North Carolina
Wildlife Project No: 1101
MESSAGE: Bennett —
Per our telephone discussion on Monday, July 2, 2001, the following information is provided as a
response to the NC Wildlife Resources Commission comments with regard to the referenced
Town of Clayton Environmental Assessment.
Wildlife Comment: "We noticed that the [Town's Watershed Protection and Strategic Growth
Plans] specify only 30 ft. buffers along streams. Given the sensitivity of the proximal streams
with their prevalence of listed biota, we recommend that vegetated streamside buffers be a bare
minimum of 50 ft. in width. A 50 ft. buffer width should also be consistent with the Neuse
Buffer Rules."
Response: The Town Clayton's buffer requirements are consistent with those of the Neuse
Buffer Rules. These Rules require a total 50-foot buffer to be maintained along streams. Thirty
feet of this buffer area is required to be maintained as completely vegetated, where the remaining
20 feet can be used for utility easements, etc. as specified by the approved usages outlined in the
Neuse Rules. The Town of Clayton requires a total streamside buffer area of 55 feet; a
minimum of 35 feet for a vegetative buffer (this was just increased within the last month from 30
feet) and the balance of 20 feet for approved usage such as utility easements, etc. as outlined
above. Based on this information, Clayton's buffer requirements are actually more stringent than
those required by the Neuse Buffer Rules.
As we discussed, Mr. Milt Rhodes of the NCDENR-DWQ would like to have your concurrence
that this information addresses your concerns when we resubmit the Environmental Assessment
for continuation of review through the State Clearinghouse. A facsimile with your comments
will be sufficient to serve this purpose. My fax number is [phone].
Your assistance is greatly appreciated. If you have any questions or need additional information,
please feel free to contact me at [phone].