NC0025453_Instream Assessment_19880520

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DIVISION OF ENVIRONMENTAL MANAGEMENT
May 20, 1988
MEMORANDUM
TO: Carolyn McCaskill
FROM: Juan Carlos Mangles
THROUGH: Trevor Clements��
Steve Tedder
SUBJECT: Instream Assessment for Town of Clayton WWTP
NPDES Permit NCO025453
Johnston County
JOC Case No. 87-21
SUMMARY
T1ie Town of Clayton has requested a Judicial Order to fulfill a
stipulation of a previous SOC ( WQ 81-72 Ad III ) . No additional flow
allocation is requested. Based on results of a Level_ B model analysis,
dated February 4, 1988, the current SOC limitations will have little
additional impact. on the stream. These limitations should be main-
tained in the requested Judicial Order. It is recommended that no addi-
tional flow be allocated to the treatment facilities in the interim
since the present level of discharge is severely polluting the stream.
BACKGROUND INFORMATION
Little Creek extends a total of 6.4 miles before its confluence
with Swift Creek. At a distance of 2.4 miles below the Clayton outfall,
the stream widens into a pond 0.3 miles long and 400 ft. wide. The
stream is classified at the discharge point as " C "; 7Q10 = 0.2 cfs;
Qavg = 6.8 cfs and D.A = 5.96 sq. miles.
A first time SOC ( WQ 81-72 ) was issued to Clayton on September
10, 1981. The facility, unable to comply with final effluent limita-
tions, entered into an SOC to discharge 0.068 MGD of additional waste-
water to the treatment works, thus reaching the plant's designed
capacity. A second SOC ( WQ 81-72 Ad ) went into effect February 1,
1985 as per the Town's request to add 0.050 MGD of wastewater to their
treatment plant. An interim flow of 0.750 MGD was granted by DEM.
On October 20, 1987, Clayton requested a flow increase of 0.083
MGD of wastewater into the treatment works. Also, a request for a Judi-
cial Order was made on the same date with a revised schedule of con-
struction.

An instream assessment, dated February 4, 1988,. was performed to
satisfy the SOC request ( see attached ) . The results suggested interim
limits of. 30 mg/l BOD, 12 mg/l NH3 as N, and 6 mg/l D.O. The modeling
results satisfy official SOC requirements; although, anoxic conditions
were predicted within the pond.
SOC WQ 81-72 Ad III entered into effect on February 19, 1988.
It stipulates beginning of construction on or before December 1, 1987
and to enter into a Judicial Order on or before June 30, 1988. It also
allows an additional 77, 180 GPD of wasteflow into the plant. It pro-
vides the following interim limitations:
Flow 0.750 MGD
BOD 30 mg/l
TSS 40 mg/l
NH3 as N 12 mg/l
D.0 6 mg/1
A review of the self-monitoring data for toxicity indicated that the
subject facility failed to submit two quarterly chronic toxicity reports
previous to the March, 1988 report. This report indicated' that the
facility failed the test. The RRO has informed 'technical Services that
construction began on December 1 , 1987.
ANALYSIS AND DISCUSSION
This Judicial Order is to comply with a stipulation of the latest
SOC. It is not a request for flow increase. Therefore, a modeling ana-
lysis is not required since no change in flow or other effluent char-
acteristics is requested and/or proposed. No maximum flow analysis was
performed due to a) unsatisfactory effluent toxicity test results; b)
previous modeled downstream anoxic conditions and c) low downstream
D.O. concentrations in pre-SOC DMR's:
MONTH UPSTREAM D.O. DOWNSTREAM D.O.
July, 1979 6.5 mg/l 4.4 mg/l
August, 1979 5.2 mg/1 2.0 mg/1
September,1979 6.6 mg/l 4.3 mg/l
June, 1981 3.1 mg/1 2.3 mg/1
July, 1981 4.4 mg/1 2.6 mg/1
( No recent instream data is available )
Thus, based on the attached February 4, 1988 instream assessment,
it is recommended that the following interim effluent limitations be
included in the Judicial Order:
PARAMETER LIMIT
Flow 0.750 MGD
i30D 30 mg/1
NH3 as N 12 mg/l
D.O. 6 mg/1
TSS 40 mg/l
Fecal Coliform 1000/100 ml
PH 6 - 9 s.u.
Chronic Toxicity should be performed quarterly

The following instream parameters should be monitored weekly dur-
ing the summer months ( Apr-Oct ) and monthly during the winter months
( Nov-Mar ): D.O. , temperature, pH, conductivity, fecal coliform and
BOD.
Upstream samples should be taken at NC 42. Downstream samples
should be taken at the upper mouth of the pond ( D.O. sag point ).
DEM should not allocate additional flow to this facility which is
currently exceeding its design flow by more than 20 percent_. The cur-
rent level of pollutants found in the effluent of the subject facility
is severely degrading the water quality of Little Creek.
Attachment
cc: George Everett
Kent Wiggins
Steve Reid
Ken Eagleson

--_DIVISION OF ENVIRONMENTAL MANAGIImENT
February 4, 1988
MEMORANDUM
TO: Carolyn McCaskill
FROM: Steve Zoufaly 6�-
THRU: Trevor Clement ,
Steve Tedder
SUBJECT: Instream Assessment, Case No. 81-72 Ad. III
Town of Clayton WWTP, Johnston County
NC0025453
The Town of Clayton has requested an amendment to their current SOC for
an additional 0.08328 MGD of wasteflow. The facility is located in Johnston
County and discharges to Little Creek (classified as "C", 7QlOs = 0.2 cfs).
Clayton is permitted for 0.6 MGD at 10 mg/l BOD,, 3 mg/1 NH,N and 5
mg/1 D.O. However the facility has been under SOC agreements since 1981 due
to non-compliance with BODS and NH,-N effluent limitations. Under their
existing SOC, Clayton has been allowed a total of 0.118 MGD additional flow
with interim limits of:
BOD, 40 mg/l
NH,N 15 mg/1
D.O. 5 mg/1
The Raleigh Regional Office recommends that these limits remain intact.
According to compliance data, Clayton should not have any trouble continuing
to meet their since they have been averaging 15 mg/1 BOD, 6.1 mg/1 NH
3N and
8.5 mg/l D.O. for the past year.
A model was run using the pre-SOC wasteflow of 0.5685 MGD and compared
with the modeled results for the past-SOC wasteflow of 0.7695 MGD (0.118 +
0.083 MGD). The results of the analysis indicated that the change in D.O.
minimum concentration was greater than 0.5 mg/1 and the stream profile
showed an expanded anoxic zone below the plant from none to 1.1 miles.
Anoxic conditions are expected to occur in a small pond further downstream
under both conditions. A recommendation for granting an SOC can therefore
not be made.
Another set of analyses at the pre and post SOC wasteflows were con-
ducted using SOC interim limits of 30 mg/1 BOD,, 12 NH.,N and 6 mg/1 D.O.
Clayton should be able to comply with these limits and the modeling results
satisfy official SOC requirements. The D.O. minimum below the plant is

expected to drop from 2.5 mg/l to 2.2 mg/l with the total SOC flow. Anoxic
conditions are still expected_ p__aacur within the small pond under both pre
and post SOC conditions, however.
In addition, according to Technical Services records, the Town has not
fulfilled their toxicity testing requirements. They have not submitted to
the Division the required test results and, therefore, the Division has no
way of knowing whether the effluent is toxic. Normally, Technical Services
does not recommend increasing flows through an SOC if the existing effluent
is shown to be toxic. Therefore, we recommend obtaining information regar-
ding the existing effluent toxicity prior to making any final decision
regarding the Special Order.
Finally, it is worth questioning the wisdom of permitting a facility
that is currently exceeding its design flow by an average of 14 percent to
further exceed its design. The additional flow would push exceedance to 28
percent. Undoubtedly, this will reduce treatment efficiency and probably
result in sludge being discharged into the receiving waters.
If you have any questions, please contact either Trevor Clements or
myself.
SZ:gh
cc: George Everett
Kent Wiggins

. f
DIVISION OF ENVIRONMENTAL MANAGEMENT
January 28, 1988
M E M O R A D U M
TO Steve Tedder
Assistant Chief
Technical Services Branch
FROM Carolyn McCaskill' I "
Water Quality Supervisor
SUBJECT Instream Request
Town of Clayton
Special Order by Consent ( 67b)
EMC WQ NO. 81-72 Ad III
NPDES Permit No. NC0025453
Johnston County
The Town of Clayton has requested an amendment to the
Special Order by Consent currently in effect to add
83 , 280 gpd additional flow to the plant. Attached is the
request form for an instream assessment and the DMR data
from December, 1983 through November, 1987. The first SOC
was entered into on September 10, 1983 .
If any additional information is needed for your
review, please advise.

Request Form for In-stream Assessment for 67B
• Name of Faciltiy: Town of Clayton WWTP Subbasin: 03-04-02
County: Johnston Design Flow: 0.60 m d(existin )
1.5mgd(expansion)
Receiving Stream: Little Creek
Background Data
A. Why is SOC needed? The facility is unable to comply with
final NPDES Permit limitations without first constructing
additional facilities. Construction is underway for an
expansion to this facility; began 12/1/87.
B. History of SOC requests: The first SOC (EMC WQ NO.81-72)
issued on September 10, 1981. An amendment (EMC WQ NO.
81-72 Ad) was issued on February 1, 1985. An instream
for this additional flow was completed on January 17,
1985 (copy attached) . A request for a third amendment
was requested by the Town but this was returned and not
processed.
1. Monthly Average waste flow prior to any SOC?
No DMR data available prior to EMC WQ No.81-72.
Period: 8312 to 8411 Avg: 0.5685 m d
Period: 8412 to 8511 Avg. 0.5831 mgd
Period: 8512 to 8611 Avg: 0.5598-mgd
Period: 8612 to 8711 Avg: 0.6840 mgd
2. Previously approved SOC's:
Date: 810910 flow: 0.068 mgd
Date: 850201 flow: 0.050 mgd
Total of previously
approved SOC flow: 0.118 mgd
3. Flows lost from plant-flow: _0 mgd
(facilities off line)
4. Current SOC request flow: 0.083 mgd
(83,280 gpd)
5. Total Plant flow post-SOC
(sum of original flow and
SOC minus losses) flow: 0.6840 mgd

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6. Is this an accurate flow balance for plant?
Why or why not? No it is not.
The plant experiences a lot of inflow and
infiltration. For the reporting period December
through November,1987, the February and March
flows were unusally high; 0.9535 mgd and 0.9345
mgd, respectively. Prior to these two months,
the flow averaged 0.5598 mgd for December
through November, 1986.
C. A copy of the data is attached for your review
(December, 1983 through November, 1987) .
CURRENT SOC RE, U
A. Request is for domestic or industrial waste? If it is a
combination, please specify percentages.
Domestic 81,700 gpd 98.10
Industrial 1580 gpd 1.90
B. What type of industry? Please attach any pertinent data.
Car Wash
C. The region proposes the following SOC limits:
BOD5 40 mg/1
NH3 15 mg/l
DO 5.0 mg/l
TSS 40 mg/l
Fecal Coliform 1000 #/100ml
pH 6.0-9.0 s.u.
other parameters none
D. What is the basis for these limits? These are the
existing li.mts contained in the SOC currently in effect.
The plant can do better, however the plant personnel seem
to be running the plant as well as can be expected and
not running it just within the limits given by the SOC.

Request Form for In-stream Assessment for JOC
Name of Faciltiy: Town of Clayton WWTP Subbasin: 03-04-02
County: Johnston Design Flow: 0.60 mgd(existing)
1.5mgd(_expansion)
Receiving Stream: Little Creek
Background Data :
A. Why is JOC needed? The facility is unable to comply with
final NPDES Permit limitations without first constructing
additional facilities. Construction is underway for an
expansion to this facility; began 12/1/87.
B. History of SOC requests:
1. Monthly Average waste flow prior to any SOC?
No DMR data available prior to EMC WQ No.81-72.
Period: 8601 to 8603 Avg: 0.5264 mgd
Period: 8604 to 8703 Avg. 0.6646 mgd
Period: 870.4 to 8611 Avg: 0.6512 mgd
2. Previously approved SOC`s:
EMC WQ NO. 81-72 Date: 810918 flow: 0.068 mgd
EMC WQ NO. 81-72 Ad Date: 850201 flow: 0.050 mgd
EMC WQ NO. 81-72 AdII returned
EM_C_W_Q NO. 81-72 AdIIIDate: 880219 flow: 0.07718 mgd
Total of previously
approved SOC flow: 0.19518 mgd
3. Flows lost from plant-flow: 0 mgd
(facilities off line)
4. Current SOC request flow: 0 mgd
5. Total Plant flow post-SOC
(sum of original flow and
SOC minus losses) flow: 0.72158 mc�d

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6. Is this an accurate flow balance for plant?
Why or why not? No it is not.
The plant experiences a lot of inflow and
infiltration. For the reporting period December
through November,1987, the February and March
flows were unusally high; 0.9535 mgd and 0.9345
mgd, respectively. Prior to these two months,
the flow averaged 0.5598 mgd for December
through November, 1986. Original flow data was
not available for the calculation.
C. A copy of the data is attached for your review
(January 1986 through March 1988) .
CURRENT JOC REQUEST:
A. Request is for domestic or industrial waste? If it is a
combination, please specify percentages. n/a
Domestic gpd. %
Industrial gpd %
B. What type of industry? Please attach any pertinent data.
C. The region proposes the following JOC limits:
BOD5 _ 30 mg/l
NH3 15 mg/1
DO 6.0 mg/l
TSS _40 mg/1
Fecal Coliform 1000 #/100ml
pH 6.0-9.0 s.u.
other parameters Toxicity
Flow .750 mgd
D. What is the basis for these limits? These are the
limits which the RRO staff believes the plant can meet if
it is properly operated and maintained in the interim.

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