NC0082376_Permit Issuance_20041229

A2A
NCDENR
Mr. H Dale Crisp, P.E.
Public Utilities Director, City of Raleigh
P.O. Box 590
Raleigh, North Carolina - 27602
Dear Mr. Crisp:
Michael F. Easley
Governor
William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
December 29, 2004
Subject: Issuance of NPDES Permit Na082376
City of Raleigh — E.M. Johnson WTP
Wake County
Attached to this letter is the final NPDES permit for the Caty of Raleigh's — E.M. Johnson Water Treatment Plant
(WIT'), NPDES Permit No. NCO082376 (for the treatment of wastewater associated with the water treatment plant).
This permit is issued pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum
of Agreement between North Carolina and the US. Environmental Protection Agency dated May 9, 1994 (or as
subsequently amended).
In response to the Public Hearing held on May 29, 2003 and the subsequent Hearing Officer's Report
Recommendations, the following changes are being incorporated into this final permit:
■ A stipulation has been added to the permit to characterize the flow from the wastewater treatment plant
(Special Condition A.(6.)). The flow should be characterized over a continuous 7 dayperiod. Should you have
any questions regarding this requirement, please contact Susan A. Wilson, P.E. at (919) 733 — 5083, ext. 510.
The results should be submitted as a report to the NPDES Unit (East), the Aquatic Toxicology Unit, as well as
the Division's Raleigh Regional Office. The study should be compiled and submitted prior to August 1, 2005.
■ A condition has also been added to the permit to clarify discharge monitoring report (DMR) submittals (Special
Condition A.(7 )). A monthly report must be submitted for Outfall 001. Additionally, if there is a discharge
from the raw water reservoir — this should be noted as part of the DMR form This clarification is in response
to verbal comments expressed by EPA during their inspection conducted November 19, 2003.
■ The permit (WQ0022036) for the reclaimed water distribution program (and associated approvals and
components) has been referenced in the Supplement to the Permit Cover Sheet.
■ The City's comments on the draft permit were received June 4, 2003 and were reviewed by Division staff.
Unfortunately, the Division could not comply with your requests for changes to the draft permit at this time.
Extensive metals monitoring is being required with this permit, as was the case with the draft perrrnnit. The City
may request that the Division re-evaluate the data after one year of sampling (for monthly monitoring) or two
years of sampling (for quarterly monitoring) to determine if monitoring is still necessary. Should evaluation of
the data indicate no reasonable potential to exceed North Carolina water quality standards or federal criteria,
the Division may reduce or eliminate the monitoring requirement.
As specified in Condition A.(5), please submit a fil SRPP prior to May 1, 2005. In the copy of your letter to
Mr. David Parker of EPA Region IV dated December 3, 2004, a final SRPP report was completed September
2004. Please make sure the Raleigh Regional Office receives a copy of the report (if you have not done so
already).
N. C. Division of Water Quality 1 NPDES Unit Phone: [phone]
1617 Mail Service Center, Raleigh, NC 27699-1617 fax: [phone]
Internet: h2o.enr.state.nc.us DENR Customer Service Center 1 800 623-7748

Mr. H. Dale Crisp, P.E.
NPDES Permit Issuance
Permit No. NO]082376
City of Raleigh- E.M. Johnson WTP
Page 2
If any parts, measurement frequencies, or sampling requirements contained in this permit are unacceptable to )uu, you
have the right to an adjudicatory heating upon written request within thirty (30) days following receipt of this letter.
This request must be in the form of a written petition, conforming to Chapter 150B of the North Carolina General
Statutes, and filed with the office of Administrative Hearings, 6714 Mail Service Center, Raleigh, North Carolina 27699-
6714. Unless such a demand is made, this permit shall be final and binding.
Please take notice that this permit is not transferable except after notice to the Division. The Division may require
modification or revocation and reissuance of the permit. This permit does not affect the legal requirements to obtain
other permits that may be required by the Division of Water Quality, the Division of Iand Resources, the Coastal Area
Management Act, or any other federal or local governmental permit. If you have any questions concerning this permit,
please contact Susan A. Wilson, P.E. at telephone number [phone], ext. 510.
Sincerely,
Alan W. Klimek, P.E.
CC: Raleigh Regional Office, Surface Water Protection
Aquatic Toxicology Unit
Central Files
NPDES File 1
EPA Region IV, Roosevelt Childress
Dean Naujoks, Upper Neuse Riverkeeper
Neuse River Foundation
112 S. Blount St.
Raleigh, NC 27601

Permit NCO082376
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards
and regulations promulgated and adopted by the North Carolina Environmental Management
Commission, and the Federal Water Pollution Control Act, as amended, the
City of Raleigh
is hereby authorized to discharge wastewater from a facility located at the
E.M. Johnson Water Treatment Plant (WTP)
10301 Falls of Neuse Road
Raleigh
Wake County
to receiving waters designated as an unnamed tributary to the Neuse River (outfall 001) and
an unnamed tributary to Honeycutt Creek - arm of Falls Lake (Outfall 002 and Outfall 003) in
the Neuse River Basin
in accordance with effluent limitations, monitoring requirements, and other conditions set
forth in Parts I, II, III, and IV hereof.
The permit shall become effective February 1, 2005.
This permit and the authorization to discharge shall expire at midnight on February 28, 2008.
Signed this day December 29, 2004.
Alan W. Klimek, P. E!. , Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit NCO082376
SUPPLEMENT TO PERMIT COVER SHEET
The City of Raleigh is hereby authorized to:
I. Continue to discharge treated filter backwash water and associated wastewater
from residuals processing (from Outfall 002), which includes the following
components:
♦ Two backwash clarifiers
♦ Filtrate pump station
♦ Flow splitter box
♦ Three sludge thickeners
♦ Parshall flume
♦ Polymer and caustic feed systems
♦ Thickened sludge pump station
(with diversion to blending tanks or sludge disposal facility)
♦ Four sludge blending tanks
(residuals pumped to sludge disposal facility or filter presses)
♦ Three belt filter presses (drainage to filtrate pump station)
truck hauling and concrete pad for residuals
belt filter press washwater pumps
belt conveyors
♦ Sand drying beds (drainage to filtrate pump station) / containment pad
♦ Refer to Permit No. WQ0008431 for components specific to the sludge disposal
facility
♦ Dechlorination and automatic pH control system
♦ Refer to Permit No. WQ0022036 for the bulk reclaimed water distribution program
(and associated approvals and components).
001- Discharge from reservoir and possible discharge of treated water/wastewater
(located across Falls of the Neuse Road from the water treatment plant).
002 - Discharge of wastewater associated with the treatment of water for drinking
purposes (main wastewater discharge).
003 - Discharge of stormwater and miscellaneous wastewater from the culvert directly
upstream of Outfall 002.
This facility is located at the E.M. Johnson Water Treatment Plant at 10301 Falls of
Neuse Road in Wake County.
2. Discharge from Outfall 001 (across -Falls of the Neuse Road from the treatment
plant) at the location specified on the attached map into an unnamed tributary of
the Neuse River, classified as C-NSW waters in the Neuse River Basin.
3. Discharge from Outfalls 002 and 003 at the locations specified on the attached map
into an unnamed tributary to Honeycutt Creek (arm of Falls Lake), classified as WS-
IV-NSW-CA waters in the Neuse River Basin.

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Permit NCO082376
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS — FINAL
During the period beginning on the effective date of the permit and lasting until expiration, the
Permittee is authorized to discharge wastewater associated with the water treatment plant from
Outfalls 001 (outfall located across Fails of the Neuse) and 002 (main wastewater outfa o. Such
discharges shall be limited and monitored by the Permittee as specified below:
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Weekly
Grab
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Effluent
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Monitor & Report
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Composite
Effluent
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Monitor & Report
Monthly
Composite
Effluent
TN (mgA)4
Monitor & Report
Monthly
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Effluent
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Monitor & Report
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Monitor & Report
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Monthly
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Monthly
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Total Copper
Weekly
Composite
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Total Iron
Weekly
Composite
Effluent
Total Manganese
Weekly
Composite
Effluent
Total Aluminum
Quarterly
Composite
Effluent
Total Barium
Quarterly
Composite
Effluent
Total Calcium
Quarterly
Composite
Effluent
Total Lead
Quarterly
Composite
Effluent
Total Magnesium
Quarterly
Composite
Effluent
Total Nickel
Quarterly
Composite
Effluent
Total Zinc
Quarterly
Composite
Effluent
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Permit NCO082376
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS — FINAL
(Continued)
NOTES:
1. Upstream at a feasible location above the discharge point; Downstream at a feasible location
below the discharge point.
2. The discharge shall not cause the turbidity of the receiving water to exceed 50 NTU. If the
turbidity exceeds these levels due to natural background conditions, the discharge level
cannot cause any increase in the turbidity in the receiving water.
3. The total residual chlorine limit shall be implemented three months from the effective date of
the permit.
4. TN means Total Nitrogen. For a given wastewater sample, TN is the sum of Total Kjeldahl
Nitrogen and Nitrate -Nitrite Nitrogen: TN = TKN + NO2-N + NO3-N.
5. TN Load is the mass load of TN discharged by the Permittee in a period of time. See Special
Condition A.(3.), Calculation of TN Loads.
6. Annual TN load must be reported. Annual TN load is not limited for this permit cycle. See
Special Condition A.(3.), Calculation of TN Loads.
7. Chronic Toxicity (Ceriodaphnia dubia) Monitoring at 90%: February, May, August, and
November [see Special Condition A.(4). Quarterly metals monitor shall coincide with
quarterly toxicity monitoring.
8. The pH shall not be less than 6.0 nor greater than 9.0 standard units.
All samples collected should be representative of the discharge.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
There shall be no discharge of waste or chemicals that do not directly result from the
responsible treatment of raw water.

N.,
Permit NCO082376
A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS — FINAL
During the period beginning on the effective date of the permit and lasting until expiration, the
Permittee is authorized to discharge wastewater associated with drainage from Outfall 003
(drainage from the culvert above Outfali 002). Such discharges shall be limited and monitored
by the Permittee as specified below:
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Effluent
Total Suspended Solids
Monthly
Grab
Effluent
Settleable Solids
Monthly
Grab
Effluent
Total Residual Chlorine
Monthly
Grab
Effluent
NH3-N (mg/1)
Monthly
Grab
Effluent
TN (mg/1)
Monthly
Grab
Effluent
Total Phosphorus
Monthly
Grab
Effluent
Total Copper
Monthly
Composite
Effluent
Total Iron
Month
Composite
Effluent
Total Manganese
Monthly
Composite
Effluent
Total Aluminum
Quarterly
Composite
Effluent
Total Barium
Quarterly
Composite
Effluent
Total Calcium
Quarter
Composite
Effluent
Total Lead
Quarterly
Composite
Effluent
Total Magnesium
Quarterly
Composite
Effluent
Total Nickel
Quarterly
Composite
Effluent
Total Zinc
Quarterly
Composite
Effluent
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Monthly
Grab
Effluent
NOTES:
All samples collected should be representative of the discharge.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
There shall be no discharge of waste or chemicals that do not directly result from the
responsible treatment of raw water.

Permit NCO082376
A. (3.) CALCULATION OF TOTAL NITROGEN LOADS
a. The Permittee shall calculate monthly and annual TN Loads as follows:
i. Monthly TN Load (lb/mo) = TN x TMF x 8.34 ,
where:
TN = the average Total Nitrogen concentration (mg/L) of the composite samples
collected during the month
TMF = the Total Monthly Flow of wastewater discharged during the month (MG/mo)
8.34 = conversion factor, from (mg/L x MG) to pounds
H. Annual TN Load (lb/yr) = Sum of the 12 Monthly TN Loads for the calendar year
b. The Permittee shall report monthly Total Nitrogen results (mg/L and lb/mo) in the
discharge monitoring report for that month and shall report each year's annual results
(lb/yr) in the December report for that year.
A. (4.) CHRONIC TOXICITY MONITORING (QUARTERLY)
The permittee shall conduct chronic toxicity tests using test procedures outlined in the "North
Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure", Revised February 1998 or
subsequent versions.
The effluent concentration defined as the Instream Waste Concentration (IWC) shall be 90%.
The chronic value will be determined using the geometric mean of the highest concentration
having no detectable impairment of reproduction or survival and the lowest concentration that
does have a detectable impairment of reproduction or survival. The definition of "detectable
impairment," collection methods, exposure regimes, and further statistical methods are
described by the document referenced above.
The permit holder shall perform at a minimum, quarteriu monitoring using these procedures to
establish compliance with the permit condition. The tests will be performed during the months
of February, May, August, and November. Effluent sampling for this testing shall be
performed at the NPDES permitted final effluent discharge below all treatment processes.
All toxicity testing results required as part of this permit condition will be entered on the
Effluent Discharge Monitoring Form (MR-1) for the months in which tests were performed,
using the parameter code THP3B. Additionally, DWQ Form AT-3 (original) is to be sent to the
following address:
Attention: Environmental Sciences Branch
North Carolina Division of
Water Quality
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch
no later than 30 days after the end of the reporting period for which the report is made.

v '
Permit NCO082376
A. (4.) CHRONIC TOXICITY MONITORING (QUARTERLY) -Continued
Test data shall be complete, accurate, include all supporting chemical/physical measurements and all
concentration/response data, and be certified by laboratory supervisor and ORC or approved designate
signature. Total residual chlorine of the effluent toxicity sample must be measured and reported if
chlorine is employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity
monitoring is required, the permittee will complete the information located at the top of the
aquatic toxicity (AT) test form indicating the facility name, permit number, pipe number,
county, and the month/year of the report with the notation of "No Flow" in the comment area of
the form. The report shall be submitted to the Environmental Sciences Branch at the address
cited above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required,
monitoring will be required during the following month.
Should any test data from this monitoring requirement or tests performed by the North
Carolina Division of Water (duality indicate potential impacts to the receiving stream, this
pen -nit may be re -opened and modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum
control organism survival, minimum control organism reproduction, and appropriate
environmental controls, shall constitute an invalid test and will require immediate follow-up
testing to be completed no later than the last day of the month following the month of the initial
monitoring.
A. (5.) SPILL RESPONSE AND PREVENTION PLAN
The City has three months from the effective date of the permit to submit a final SRPP for the
water treatment plant. One copy should be submitted to the Raleigh Regional Office and one
copy to the NPDES Unit (East) of the Surface Water Protection Section [the addresses are listed
in Condition A.(6.), Item No. 3].
A. (6.) FLOW CHARACTERIZATION
1. No later than 120 days after the effective date of this permit (by June 1, 2005), the Permittee
shall characterize the discharge at Outfall 002 and submit a written report of its findings to
the Division's NPDES Unit, as described below.

Permit NCO082376
FLOW CHARACTERIZATION, continued
• The Permittee shall monitor the discharge through one continuous 7-day period
as follows:
Parameter
Monitoring
Frequency
Sample
Type'
Flow
1/ 'A hour
Instantaneous
Conductivity
1/ hour
Grab
Settleable Solids
11 hour
Grab
Acute Toxicity
Once 2
Grab
Footnotes:
(1) Location: existing effluent monitoring point for
Outfall 002.
(2) Acute Toxicity, 48-hr LC50 test. Ceriodaphnim grab
sample shall be taken during a representative peak flow
period. See Item No. 2 of this Special Condition, Acute
Toxicity Monitoring.
• The Permittee shall make a reasonable attempt to choose a study period that is
representative of facility operations and discharge. The study period shall
coincide with chronic toxicity monitoring at Outfall 002.
2. ACUTE TOXICITY MONITORING
The permittee shall conduct an acute toxicity test using protocols defined as definitive in
E.P.A. Document EPA/600/4-90/027F entitled "Methods for Measuring the Acute Toxicity
of Effluents to Freshwater and Marine Organisms." The monitoring shall be performed as a
Ceriodaphnia dubia 48 hour static test. Effluent samples for self -monitoring purposes must
be obtained during representative effluent discharge below all waste treatment. The tests
will be performed one time during the 7 day study.
The parameter code for this test is TAA3B. The toxicity testing result required as part of
this permit condition may be submitted as part of the special 7 day study. Additionally,
DWQ Form AT-1 (original), along with the 7 day study report, should be sent to the following
address:
Attention: North Carolina Division of Water Quality
Environmental Sciences Section/Aquatic Toxicology
1621 Mail Service Center
Raleigh, N.C. 27699-1621
Test data shall be complete and accurate and include all supporting chemical/physical
measurements performed in association with the toxicity tests, as well as all dose/response
data. Total residual chlorine of the effluent toxicity sample must be measured and reported
if chlorine is employed for disinfection of the waste stream.
Should any test data from either these monitoring requirements or tests performed by the
North Carolina Division of Water Quality indicate potential impacts to the receiving stream,
this permit may be re -opened and modified to include alternate monitoring requirements or
limits.

c
w
Permit NCO082376
41
FLOW CHARACTERIZATION, continued
NOTE: Failure to achieve test conditions as specified in the cited document, such as
minimum control organism survival and appropriate environmental controls, shall
constitute an invalid test and will require immediate follow-up testing.
A North Carolina certified laboratory must be used for this test.
3. STUDY REPORT
The 7 day study report shall be completed within 120 days of the effective date of the permit
(as stated in Item No. 1, above) and shall be compiled and submitted within 180 days (by
August 1, 2005) of the effective date of the permit. The report shall be submitted to:
NPDES Unit (East), Surface Water Protection Section, 1617 Mail Service Center, Raleigh,
NC 27699-1617
Surface Water Protection, Raleigh Regional Office, 3800 Barrett Drive, Raleigh, NC
27609
Environmental Sciences Section, Aquatic Toxicology Unit, 1621 Mail Service Center,
Raleigh, NC 27699-1621 (as listed in Item No. 2)
A. (7.) ADDITIONAL STIPULATIONS REGARDING DISCHARGE MONITORING
REPORT (DMR) FORMS
1. The City must submit a DMR form for Outfall 001, whether a discharge occurs or does
not occur. If there is no discharge from Outfall 001 during a month, the monthly report
must be submitted with the notation "No Flow".
2. For Outfall 003, the City should state whether a discharge has occurred from the
overflow of the raw water reservoir (this may be submitted as a notation on the DMR or
as an appendix to the DMR).

DENR/DWg
FACT SHEET AMENDMENT, 11/10/04
NPDES No. NC0082376, E.M. Johnson WTP (Raleigh)
Facility Information
Applicant/Facility Name:
City of Raleigh/ E.M. Johnson WTP
Applicant Address:
P.O. Box 590, Raleigh, NC 27602
Facility Address:
10301 Falls of the Neuse Road
Permitted Flow
Variable (no limit); average, 2002 = 2.53 MGD
Type of Waste:
100% Non -domestic
Facility/Permit Status:
Renewal
County:
Wake
Miscellaneous
Receiving Stream:
UT Honeycutt
Creek/arm of
Falls Lake (002
& 003)
Ur Neuse River
(001)
Regional Office:
RRO
Stream Classification:
WS-IV NSW CA
(002 & 003)
C NSW
(001)
Quad
D24NE
Wake Forest
303(d) Listed?:
No - TMDL in
lace
Permit Writer:
S. Wilson
Subbasin:
030402
Date:
November 10, 2004
Drainage Area (mf2):
AOMP
Summer 7 10 (cfs)
0
Winter 7Q10 (cfs):
Average Flow (cfs):
IWC (%):
1 100%
Primary SIC Code:
BACKGROUND
Some modifications/changes have been made to the draft permit based on the hearing officer's
recommendations (from the hearing held May 29, 2003), as well as some clarification based on
preliminary comments from EPA's field inspection (November 19, 2003).
Outfall 001 - The City wishes to retain this outfall for future use. This outfall and Outfall 002
have identical requirements.
Outfall 002 - This outfall is the current treated effluent discharge (resulting from the water
treatment process).
Outfall 003 - This is a new designated outfall; this is the culvert prior to 002. It
may contain some stormwater, groundwater, leakage from clearwell finish water,
and possible overflow from the raw water reservoir. This outfall has similar
constituents as Outfalls 001 and 002 (except that toxicity testing is not included).
Sampling is required monthly (except Al, Cd, Cr, Pb are required quarterly, as with
002).
RESOLUTION TO COMMENTS
Based on public comments and concern over the characterization of the main
effluent discharge (002), a special condition has been added to the final permit
requiring the City of Raleigh to perform flow characterization of this outfall [refer to
Condition A.(6.) of the permit].
NCO082376
Fact Sheet Amendment - NPDES Renewal
Page I

The City of Raleigh has an approved bulk reclaimed water distribution program,
which is permitted via WQ0022036 (the facility has also sought permission from
DEH to use backwash water for reuse and to divert backwash water to the raw
reservoir on an 'as -needed' basis). This permit will be referenced in the NPDES
permit.
DWQ believes EPA's concerns (expressed during their inspection) regarding the
overflow pipe from the raw reservoir have been addressed through the designation
and requirements for Outfall 003. (This outfall requires essentially the same
monitoring as 001 and 002 - see description above).
DWQ will state in a special condition to the permit that the City must document and
provide DMRs even if there is no discharge (with regard to Outfall 001). The City
will also be required to state on the DMR if a discharge has occurred from the raw
reservoir (should be noted on the DMR for 003). These requirements should also
satisfy EPA's concerns expressed during their inspection.
There was some public comment regarding the exact name of the creek in which 002
and 003 discharge. Technically, the discharge goes into an unnamed tributary to
Honeycutt Creek (and was so designated in the draft permit). However, this should
likely be further described as an arm of Falls Lake.
A comment was submitted to classify the Operator in Responsible Charge (ORC) as a
Grade II. Per Technical Assistance and Certification Unit, as well as the Raleigh
Regional Office, based on the existing rules and their judgment of those rules and
their knowledge of the Raleigh WTP, they believed that Grade I was appropriate for
this facility.
STATE CONTACT:
If you have any questions on any of the above information or on the attached permit, please
contact Susan Wilson, P.E. at [phone] ext. 510.
NC0082376
Fact Sheet Amendment - NPDES Renewal
Page 2

0� WAT�c
�Q
Michael F. Easley, Governor
G
State of North Carolina
CO
William G. Ross, Jr., Secretary
Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
April 2, 2004
MEMORANDUM
TO: Alan W. Klimek, P.E.
FROM: Boyd DeVane
SUBJECT: Report and Recommendations: Neuse River Discharge Permit Hearings
I. INTRODUCTION
As you directed, I served as Hearing Officer for a public hearing held in Raleigh on May 29, 2003.
The hearing was held at the request of the Neuse River Foundation (NRF) and pertained to the
NPDES Unit's proposed renewal of ten wastewater discharge permits in the Neuse River Basin. The
ten facilities are as follows, in approximate upstream -to -downstream order:
• NCO082376 - City of Raleigh - E. M. Johnson WTP
• NCO029033 - City of Raleigh - Neuse River WWTP
• NCO038784 - Neuse River Village (former Riverview Mobile Home Park) WWTP
• NCO056499 - Uniprop, Inc. - Mill Run Mobile Home Park WWTP
• NCO049034 - Mount Auburn Training Center WWTP
• NCO040266 - Knightdale Estates Mobile Home Park WWTP
• NCO064246 - Pace Mobile Home Park WWTP
• NCO035181 - NC Center for Mature Adults WWTP
• NCO064149 - Town of Princeton WWTP
• NCO064891 - Town of Kenly Regional WWTP
The hearing provided the Neuse River Foundation and others an opportunity to voice their
concerns regarding the permitted facilities and the proposed permits; and it gave the permittees an
equal opportunity to respond to those concerns.
In the course of preparing for and conducting this hearing, I received numerous public comments,
visited each of the- treatment plants, considered discharger monitoring reports and other Division
records, and discussed the relevant issues with Division staff. This memorandum presents my
findings and recommendations to you on these matters.
II. HISTORY/BACKGROUND
The Neuse River basin has experienced tremendous growth and development pressures during the
last 20 years or so. During this same period, nutrient enrichment problems have been documented
in the upper basin (upstream of the Falls of the Neuse Reservoir) and the estuary (downstream of
Streets Ferry). This basin was one of the first basins in North Carolina to receive the supplemental
classification of nutrient -sensitive waters (NSW). Dissolved oxygen levels in the river are also of
concern and are closely monitored. A field -calibrated QUAL2E model was developed in the early

Report of Proceedings �
May 2003 Public Hearing
NPDES Permits, Neuse River Basin
1990's to establish a reliable tool for predicting impacts of oxygen -consuming waste inputs to the
river system.
III. HEARING PROCESS AND SITE VISITS
The Division held two similar public hearings, in May 2000, also at the request of the Neuse River
Foundation. The Unit worked with the Foundation to clarify the group's objectives for those
hearings. Ultimately, the NRF focused its request on 15 of the 168 permits originally requested for
hearing, based on specific concerns it had with their wastewater planning, facility operation,
and/or permit compliance.
The Division believes the approach used in 2000 was successful in focusing attention on treatment
facilities with poor compliance records and in initiating steps toward improved compliance. The
NPDES Unit contacted the NRF again in 2003 to gauge its interest in using the same approach for
the then -upcoming renewals. Ms. Natalie Baggett, president of the Foundation at that time,
supported the approach, and she and Mr. Dean Naujoks, the Upper Neuse Riverkeeper, led that
effort on behalf of the Foundation. The review of permit and compliance records and consideration
of other information resulted in a list of ten candidate facilities, all located in the upper half of the
river basin. The NRF noted concerns with several facilities in the lower part of the basin but elected
to comment on those permits during each permit's public review period.
The hearing was advertised once in The News & Observer (Raleigh) at least 30 days prior to the
hearing date.
Prior to the hearings, regional office staff, NPDES Unit members, and I visited each of the ten
treatment plant sites. Kent Penny from Wake County Health Department joined us at several of the
Wake County sites. Plant operators represented permit holders at each of the sites, and in some
cases the plant managers, local elected officials, or their consultants joined us as well.
The hearing was held in the Ground Floor Hearings Room of the Archdale Building and was
attended by approximately 40 members of the public plus Division staff. I extended the comment
period by approximately two weeks to allow adequate time for interested parties to submit written
comments.
IV. PERMIT -RELATED FINDINGS AND RECOMMENDATIONS
POSITIVE PARTICIPATION OF STAKEHOLDERS
As with the May 2000 hearings, I would like to first commend the Neuse River Foundation for
expressing its concerns over the potential impacts of these discharges in the Neuse Basin. Through
the actions of its members, the Foundation focused its attention on significant problems with the
permitted facilities. My recommendations in this report include several of their proposals.
I also want to commend those dischargers who have made conscientious efforts to maintain and
improve the performance of their wastewater systems and who enlightened us as to the challenges
they face in doing so.
PERMIT -RELATED FINDINGS
For the purposes of this report, I have divided the findings and recommendations into two groups:
those pertaining to specific permit issues and one that is a broader, programmatic issue.
2

Report of Proceedings
May 2003 Public Hearing
NPDES Permits, Neuse River Basin
Most of the issues we heard, of course, came from public comments received at the hearing or
during the comment period that followed. In addition, the Division's staff identified other issues
during the pre -hearing site visits and their discussions with the NRF and the permittees. The
comments and concerns are summarized below. Please refer to Attachment D for a copy of the
written comments we received.
Permit Non -Compliance
Most of the facilities considered in this hearing were selected because of their poor compliance
records in recent years. Most had been assessed multiple penalties for NPDES permit violations
since 2000. The NRF also requested the hearing for the City of Raleigh water and wastewater
treatment facilities, where they felt management and operation were deficient.
It was clear during our site visits that some of the treatment facilities are sub -standard,
including the Neuse River Village and NC Center for Mature Adult WWTPs. Several other
facilities seemed adequate but appeared to be operated and/or maintained inconsistently or at a
sub -standard level; these include the Knightdale Estates and Pace Mobile Home Park WWTPs.
We also visited two facilities - the Kenly and Princeton WWTPs - at which the permittees had
already undertaken substantial efforts to correct their compliance problems.
Two facilities, the Neuse River Village (formerly Riverview MHP) and the Mill Run Mobile
Home Park, were also among the 15 considered in the May 2000 hearings. They were included
in this hearing because they had not complied with the special conditions added to their
permits as a result of those earlier hearings.
Neuse River Village. Under its previous owner, the Neuse River Village WWTP had a
poor compliance record and its collection system was subject to overflows, which posed
a public health threat to its residents. The owner showed little interest in correcting the
problems and questioned the Division's authority to regulate his facility. As a result of
the hearings, his 2000 permit required him to take certain measures to address the health
and water quality issues, but he apparently ignored those requirements. He has paid
none of the approximately $14,000 in penalties assessed since 2000, and these cases have
been referred to the AG's Office for further action.
In late 2002 or early 2003, Mr. Brian Unger purchased the mobile home park and its
water and wastewater systems from the previous owner. Plant performance has
improved to some degree (the only violation in 2003 prior to the hearing was a 0.2%
flow exceedance), but our original concerns have not been fully resolved.
Uniprop - Mill Run Mobile Home Park. The Mill Run facility was considered at the 2000
hearing because it had repeatedly violated its permit limits (BOD, NH3-N, fecal
coliforms, and flow) and monitoring requirements. The facility discharges to an
unnamed tributary to Swift Creek that is a low -flow stream. The Division assessed
approximately $20,000 in penalties from 1998 through 2002, and the permittee has (as of
2003) paid all of these.
As a result of the 2000 hearings, the facility's last permit called for a Wastewater
Management Plan consisting of a new analysis of discharge alternatives, facilities
assessment and optimization plans, and a communications plan to educate its tenants
about grease disposal and other problem practices. Uniprop did not submit the Plan but
did install a new package plant in the summer of 2003 (ATC issued 2001). Uniprop
submitted an alternatives analysis in August 2003 but has not provided the remainder of
3

Report of Proceedings
May 2003 Public Hearing •
NPDES Permits, Neuse River Basin
the Plan. In September 2003, the Division assessed Uniprop $1,286.85 for failure to
submit the Plan. The Division also assessed the facility $1,041.40 for violating its BOD
and TSS limits in January 2003. Neither case has been resolved as of this date.
Inadequate Biosolids Management
Raleigh's Neuse River WWTP appeared to be well operated and maintained. However,
biosolids management at the plant received considerable public attention in 2002 and early
2003. Records show that the City has over -applied biosolids on its permitted application sites
(adjacent to the WWTP), and monitoring indicates that nutrient levels are elevated in both the
underlying groundwater and the surface runoff from the sites. The City submitted a
"Supplemental Site Assessment, September 2003" to begin the process of characterizing the
impacts of its practices. The document is currently under review by the Division.
The City's wastewater discharge to the Neuse River is subject to an annual mass allocation for
Total Nitrogen. The City and the Division agree in principle that the City's nitrogen discharge
should include the contribution from the application sites as well as its wastewater discharge.
The City is actively working to determine what the indirect contribution is, but that work has
not yet been completed.
Biosolids management was also an issue to varying degrees at several other facilities. The
Princeton WWTP had difficulty controlling its solids inventory, because its "boat -style"
clarifiers did not effectively capture and return biosolids to the aeration basins; the Town is in
the process of replacing the clarifiers with conventional units. The NC Center for Mature
Adults, Neuse River Village, Knightdale Estates, Pace MHP, and Mill Run MHP plants are all
small, extended aeration systems, in which proper sludge management is essential to a healthy
sludge and effective treatment.
Representative Sampling
There is some concern that, due to the intermittent nature of the discharge at the Raleigh water
treatment plant, the composite sampling required in the City's permit might not yield
sufficiently representative results.
Discharge Identification Signs
Commenters noted that residents, especially children, commonly swim or play in the receiving
streams near several of the permitted discharges and could come into direct contact with treated
wastewater. Permittees are rarely required to mark these discharge points, and exposure to
properly treated wastewater should not present a public health threat. Still, it seems reasonable
in situations such as this that residents should be aware of the discharges and allowed to decide
for themselves (or their children) whether to use those waters for recreation.
PERMIT -RELATED RECOMMENDATIONS
Attachment E contains a summary sheet and presents my detailed findings and recommendations
for each of the ten permits considered at this public hearing. Two of the ten permittees - the Towns
of Kenly and Princeton - have already taken steps to address the issues at their facilities, and I am
not proposing any further action other than to monitor their progress. I am recommending specific
actions for the remaining eight facilities, and toward that end the summary sheets include specific
language to be added to each of the affected permits.
4

Report of Proceedings
May 2003 Public Hearing
NPDES Permits, Neuse River Basin
Permit Non -Compliance
Several of the smaller facilities need to take a fresh look at their wastewater management needs
and then undertake appropriate corrective action. Since the 2000 hearings, the NPDES Unit has
required permittees in similar situations to develop and submit a Wastewater Management
Plan to identify those needs and actions. The specific requirements of the Plan vary from case to
case, depending on the specific needs.
The following are my key recommendations to address these needs. In some cases, the
individual requirements would be combined in the permit as a requirement for a Wastewater
Management Plan.
Discharge Alternatives Analyses. It is my opinion as hearings officer and the opinion of other
Division staff that the Division should pursue the elimination of several of these discharges,
especially where connection with larger neighboring facilities is feasible. Toward that end, I
recommend that three permittees - the Neuse River Village, Knightdale Estates, and NC Center
for Mature Adults - be required to complete a discharge alternatives analyses to determine
whether regionalization or other non -discharge option is feasible at this time. I recommend that
the Division notify Pace MHP that it will be required to conduct a similar analysis if it does not
comply with its permit limits on a more consistent basis.
Facility Assessment and Optimization. The staff and I believe there is considerable opportunity
ity
to improve the operation and maintenance at some of the wastewater treatment plants we
reviewed and that this would lead to improved plant performance and better water quality in
the receiving streams. I recommend that the NC Center for Mature Adults and Pace MHP be
required to complete an assessment and optimization study of their treatment plants and
submit those for Division approval. In a similar vein, I also recommend that Mt. Auburn
Training Center (1) evaluate the feasibility of covering its sand filters and (2) verify that
wastewater is being distributed properly on its sand filter beds.
Communications Plans. Facilities that serve rental properties have experienced operational
problems due to the actions or lifestyles of their residents. I recommend that Knightdale Estates
MHP, Mill Run MHP, and Neuse River Village be required to develop communications plans to
educate residents about proper water use and disposal.
Increased Monitorin&. It is my opinion some facilities' poor compliance record stems, at least in
part, from inadequate monitoring. I recommend that the Neuse River Village and Knightdale
Estates MHP be required to monitor their discharges more frequently until they demonstrate
consistent compliance with their permit limits.
Inadequate Biosolids Management
The City of Raleigh's site assessment report is currently under review. It is too early to even
roughly estimate the site's nutrient contribution to the Neuse River, but we expect that we will
have the tools to do that, well within the term of the proposed permit. It is our intent that the
contribution from the application site should be counted toward the Neuse River WWTP's
nitrogen discharge allocation.
I recommend that we include a re -opener clause in the Neuse River WWTP permit allowing the
Division to make appropriate modifications once a method of estimating the added
contribution has been developed.

Report of Proceedings
May 2003 Public Hearing
NPDES Permits, Neuse River Basin
I also recommend that the NC Center for Mature Adults be required to develop a biosolids
operations protocol to promote optimum performance in the treatment system.
Representative Sampling
I recommend that, for a period of seven days, the City of Raleigh be required to characterize its
Outfall 002 discharge at the E. M. Johnson WTP. The Division should review the results and
determine whether changes in the outfall's monitoring requirements are necessary to obtain
representative samples of the discharge.
Discharge Identification Signs
I recommend that discharge identification signs be required at three facilities where there is a
reasonable likelihood that direct exposure to treated wastewater could occur: Knightdale
Estates MHP, Mill Run MHP, and Pace MHP. The signs will notify visitors of the discharges
and warn them to not drink the water. The signs will also list telephone numbers so that citizens
can easily contact the discharger or the Division if they see evidence of improper treatment or
other problem. The signs should be bilingual. The Division staff can provide a template for the
signs (a sample template, in English only, is attached).
V. ADDITIONAL FINDINGS AND RECOMMENDATIONS
This section presents findings and recommendations for another issue that arose during the site
visits, the hearing, and related discussions but is not specifically related to any one permit or group
of permits. This is similar to an issue identified in the 2000 hearings report, and I repeat it here just
to be sure that we do not lose sight of it.
ADDITIONAL FINDINGS
Need for Improved Compliance Monitoring
The Neuse River Foundation pointed out in 2000 that some dischargers had not met certain
permit requirements, such as looking at alternative discharge options, and that the Division had
not taken enforcement action for these failures. While we have made some improvements since
then, this is still a problem. Regional staffing and priorities still do not allow us to track
compliance of smaller dischargers adequately and consistently.
ADDITIONAL RECOMMENDATIONS
Improved Compliance Monitoring
Most of the new nutrient requirements we have implemented in the Neuse River basin permits
and most of the permit Special Conditions I recommend in this report must be tracked
'manually,' if at all. As a result, we do not always discover violations in a timely way. Given the
high profile of the water quality issues and the nutrient control efforts in the Neuse River basin,
it is essential that the Division do a better job of following up on the permit requirements and
ensuring compliance. I recommend that the Division consider options for dedicating more
resources to this effort.
0

s
Report of Proceedings
May 2003 Public Hearing
NPDES Permits, Neuse River Basin
VI. ATTACHMENTS
A. Request for Public Hearing
B. Announcement of Public Hearings
C. Handouts from Public Hearings
D. Written Comments Received
E. Summary and Recommendations Sheets
•
NCO082376 -
City of Raleigh - E. M. Johnson WTP
•
NCO029033 -
City of Raleigh - Neuse River WWTP
•
NCO038784 -
Neuse River Village (former Riverview Mobile Home Park) WWTP
•
NCO056499 -
Uniprop, Inc. - Mill Run Mobile Home Park WWTP
•
NCO049034 -
Mount Auburn Training Center WWTP
•
NCO040266 -
Knightdale Estates Mobile Home Park WWTP
•
NCO064246 -
Pace Mobile Home Park WWTP
•
NCO035181 -
NC Center for Mature Adults WWTP
•
NCO064149 -
Town of Princeton WWTP
•
NCO064891 -
Town of Kenly Regional WWTP
7

DENR/DWQ
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES No. NC0082376, E.M. Johnson WTP (Raleigh)
FaciHty Information
Applicant/Facility Name:
City of Raleigh/ E.M. Johnson W'IP
Applicant Address:
P.O. Box 590, Raleigh, NC 27602
Facility Address:
10301 Falls of the Neuse Road
Permitted Flow
Variable (no limit); average, 2002 = 2.53 MGD
I)rpe of Waste:
100% Non -domestic
Facility/Permit Status:
Renewal
Co
Wake
Miscellaneous
Receiving Stream:
UT Honeycutt
Creek (002 &
003)
UT Neuse River
(001)
Regional Office:
RRO
Stream Classification:
WS-IV NSW CA
(002 & 003)
C NSW
(001)
Quad
D24NE
Wake Forest
303(d) Listed?:
No - TMDL in
lace
Permit Writer:
S. Wilson
Subbasin:
030402
Date:
Aril 23, 2003
Drainage Area (mi2):
Summer 7Q10 (cfs)
0
Winter 7Q10 (cfs):
Average Flow (cfs):
IWC (%):
100%
Primary SIC Code:
SUMMARY
The City of Raleigh submitted a permit renewal application for the E.M. Johnson water
treatment plant (WTP) on August 22, 2002 (the previous permit was issued June 28, 1999 with
an expiration date of February 28, 2003). The WTP treats surface water from Falls Lake for
distribution as drinking water to the City of Raleigh's residents. Wastewater from this process
is generated from the backwashing of the filters at the water treatment plant [frequent
backwashing is required by the Division of Environmental Health to ensure drinking water
safety]. Residual solids from the water treatment process are also separated and treated
through the wastewater treatment system.
The City of Raleigh treats the backwash water and solids from the water treatment process
through a series of solid/liquid separators [ref. Supplement to Permit Cover Sheet as well as
flow chart with permit application for list of treatment units].
The treated wastewater is discharged through Outfall 002 into an unnamed tributary to
Honeycutt Creek (which flows to Falls Lake).
Outfall 003 has been created due to the leakage from the treated water clearwell, which is
connected to a storm drain/culvert that discharges above Outfall 002. Monthly monitoring of
the same constituents as Outfall 002 is required with this outfall. Should the leak be repaired,
or no parameters of concern be detected from this outfall - monitoring may be reduced or
eliminated.
NCO082376
NPDFS Renewal
Page I

Outfall 001 has been retained at the City's request. This outfall is directed to an unnamed
tributary to the Neuse River downstream of the dam at Falls Lake. No discharge has occurred
from this outfall during this permit cycle. Monitoring/limits for this outfall are identical to
Outfall 002 (should this outfall be used).
All three outfalls discharge to subbasin 030402 in the Neuse River Basin. In this subbasin, the
Neuse River is not listed on the 303 (d) list of impaired waters. However, due to chlorophyll -a
standard violations in the estuary, nutrient impacts (total nitrogen) on the Neuse River Basin
are a concern. A TMDL for total nitrogen has been developed for the Neuse River Basin.
Nutrient monitoring has been required with this permit (no limit is required as this is not a
domestic -type discharge - more monitoring needs to be conducted to determine the amount of
nutrients the facility is contributing to the Neuse basin).
A benthic study was conducted August 29, 2002 on the main unnamed tributary that Outfall
002 discharges to (at the behest of DWR and the NRF). In addition to the discharge, this area
is subjected to urban development. The summary of the report stated:
Data from this survey indicate some adverse toxic impact to the benthic
macroinvertebrate community from the WTP discharge. However, it should be noted
that this is a very small stream that is already adversely affected upstream by the
drought conditions that persist in the area and sediment loading caused by
urbanization.
Based on this information - chronic toxicity monitoring is recommended for Outfall 002 (and
001) with this permit. In addition to the benthic sampling, an analysis was conducted on the
black substrate found below the discharge. Total metals were analyzed upstream and
downstream of the discharge. Copper, calcium, magnesium, manganese, and sodium were
found at levels greater downstream than upstream. It is unknown if any of the metals detected
in the substrate could be considered "bioavailable" (in a form which may be toxic to aquatic
life). Effluent values for iron were greater than the action level standard. Weekly monitoring
has been recommended for parameters of concern in which NC has a water quality standard
(copper, iron, manganese) . Quarterly monitoring is required for other parameters of concern.
The City has made (and is in the process of making) improvements at the treatment plant.
Dechlorination is being added, along with continuous pH metering to be able to more
accurately adjust pH via caustic addition. Dechlorination is to be applied at the effluent (002)
as well as the leakage water from the clearwell (new designated Outfall 003).
TOXICITY TESTING:
Current Requirement: There is no current toxicity requirement for any outfall at the water
treatment plant.
The City has conducted several Chronic Value tests between September 2002 and February
2003. Only one provided a Chronic Value > 100% (deemed passable).
Due to this concern and the benthic sampling results, Chronic Value test monitoring on a
quarterly basis is recommended.
Recommended Requirement (outfalls 001 and 002) : Chronic Value testing (Monitoring only)
No toxicity monitoring is recommended for Outfall 003 at this time.
COMPLIANCE SUMMARY: BASED ON THE PREVIOUS 2 YEARS
There has been one limit violation case against the facility during this permit cycle (1999).
However, as stated above, there is concern regarding the lack of benthic species downstream of
the discharge. The proposed permit should help address those concerns and provide DWQ, as
well as the City, with information to be better able to determine the source of the problem.
INSTREAM MONITORING:
Since this is not a domestic -type discharge and inorganics (as opposed to organic constituents)
are the main concern, no instream monitoring is recommended (with the exception of turbidity).
NCO082376
NPDES Renewal
Page 2

PROPOSED CHANGES:
Many of the proposed changes have been discussed in the text above. Changes, by Outfall
number, are discussed below:
Outfall 001- This outfall has not been used during this permit cycle. The City wishes to
retain this outfall for future use. This outfall and Outfall 002 have identical requirements.
OutfaU 002 - current treated effluent discharge. Changes are outlined below.
Outfalls 001 and 002
Parameter
Action
Basis
Total residual chlorine
Limited
Adoption of residual chlorine as
a WQ limit (and a parameter of
concern).
NH3-N and Nitrogen
Monitoring added/specified
NH3-N added as a parameter of
series
concern.
Nitrogen series added to more
fully assess impact of nutrients.
Copper, manganese,
Weekly monitoring
Parameters of concern - added
iron
at a weekly frequency.
Calcium, magnesium,
Quarterly monitoring
Potential parameters of concern
sodium, barium, zinc,
(coincide with tox testing)
- need to gather data.
nickel, lead -
Aluminum
Monitoring reduced to quarterly
NC has no water quality
standard for aluminum - not
considered to be bioavailable.
Monitoring has been conducted
during the past permitting cycle
- reduced to quarterly. (Not
believed to be a parameter of
concern, but will continue to
monitor due to detection levels
in influent and effluent) . Alum
is no longer used at the facility.
Chronic toxicity
Chronic Value Toxicity monitoring
Monitoring added to further
assess toxicity. Chronic value
chose to provide as much
information as possible within
the tox test.
Sampling type
Many previously required grab
Modified to obtain representative
samples changed to composite.
sample (due to variability of
discharge flow).
Outfall 003 - (New outfall - this is the culvert prior to 002. It contains some
stormwater, groundwater, and leakage from clearwell finish water) . Similar
constituents as Outfalls 001 and 002 (except that toxicity testing is not included) .
Sampling is required monthly (except Al, Cd, Cr, Pb are required quarterly, as with
002).
PROPOSED SCHEDULE FOR PERMIT ISSUANCE:
Draft Permit to Public Notice: After April 28, 2003
Hearing scheduled: May 29, 2003 (cannot estimate time of issuance)
STATE CONTACT:
If you have any questions on any of the above information or on the attached permit, please
contact Susan Wilson, P.E. at [phone] ext. 510.
NCO082376
NPDES Renewal
Page 3

REGIONAL OFFICE COMMENT:
Staff report received September 27, 2002. Major comments - 1) investigate or add toxicity
testing (added to OWalls 001 & 002); 2) Review aluminum sampling (reviewed and reduced to
quarterly); 3) Require continuous flow monitoring (done); 4) Possibly require flow limit (not
requiring at this time); 5) Require spill response and prevention plan (will require as special
condition).
Received additional comments from the regional office via e-mail. Will pass these along to the
hearing officer for potential changes. One recommendation was for composite sampling (for
appropriate parameters - the draft permit reflects this) .
NCO082376
NPDES Renewal
Page 4

Re: [Fw& [Fwd: [Fwd: Raleigh WTP111
Subject: Re: [Fwd: [Fwd: [Fwd: Raleigh WTP]II
From: Susan Wilson <susan.a.wllson®ncmail.neU
Date: Wed, 03 Nov 2004 16:19:18 -0500
To: Shannon Langley <shannon.langley®ncmail.net>
CC: Carrie Wafer <Carrle.Wafer®ncmall.net>, Judy Garrett <Judy.garrett®ncmail.net>
Thanks for the comments. I'll leave the SPCC plan in the permit and remind them that we need a final copy (in the draft letter). We'll
also just leave the permit as -is with regard to the ORC classification (based on TACU and your comments).
Shannon Langley wrote:
SAW,
I concur. The P/C grade 2 is reserved for primarily chemical methods of treatment and specifically states that RO, electrodialysts and
ultra8ltration systems w81 be considered as Class 2. 1 don't think it should apply to Raleigh WTP after reading the rule again.
Also, I found a copy of the SPCC plan for the Raleigh WTP. We were given it last fall during a site visit with EPA. It is stamped
"DRAFT' and we havent got another copy. Leaving that in the permit is fine with me.
Shannon Langley
Susan Wilson wrote:
hey - got this from Steve. let me know if you think differently.
-------- Original Message--------
Subject:[Fwd: [Fwd: Raleigh WTP]I
Date.-Tue, 02 Nov 2004 15:41:50 -0500
From:Steve Reid <steve.reid®ncmail.net>
Drganfzatfon:DENR-DWQ
To:Pugh, James <James.Pugh®ncmail.net>
CC:Susan A Wilson <Susan.A.WilsonDncmaff.net>
James -
I spoke w/Susan re: this Issue ... we decided that according to the rule for PCs, there was no way to justify PC2 grade requirement. We
will leave it at PC].
sr
-------- Original Message--------
Subject:[Fwd: Raleigh WTP]
Date-Tue, 02 Nov 2004 14:43:38 -0500
From:Susan Wilson <susrm.a.wilson®nemail.net>
To:Steve Reid <Steve.Refd®nemail.neb, James Pugh <James.Pugh®nanail.net>
Hey - did you guys get this message and can you help me with this? (the effluent discharge from this facility is appx. 2.5 mgd). Let
me know If I should forward this to someone else. Thanks.
------- Original Message--------
Subject:Raleigh WTP
Date:Fri, 29 Oct 2004 15:18:24 -0400
From:Susan Wilson <susan.a.w!lson®ncmail.net>
To:Steve Reid <Steve.Reid®ncmail.neb, James Pugh <James.Pugh®ncmall.net>
Steve/James,
I'm a little confused about your chem/physical ORC requirements (and who
should be Grade I or II). I'm trying to finalize (finally!) the NPDES
permit for the Raleigh WTP. One of the public comments we received was
a request to have the ORC classifed as II instead of I. I can't tell
from your rules if we are allowed to do that. Could one of you let me
know? It's a large system - so I was going to try and push this along
if possible and legal. Thanks.
Susan
Steve Reid. Extension Education & Training Specialist
NCDWQ,Technical Assistance and Certification Unit
of 2 11/3/2004 4:20 PM

Re: [Fwd: [Fwd: [Fwd: Raleigh WTP]]]
1618 Mail Service Center
Raleigh, NC 27699-1618
919.733.0026 x314
919.733.1338 Fax
steve.reid®ncmail.net
http://h2o.enr.state.ne.us/tacu/
"When a defining moment comes along, you either define the moment or the moment defines you."- Roy Tin Cup' McAvoy
Mr. E. Shannon Langley
Environmental Specialist
Raleigh Regional Office
NC Division of Water Quality
of 2 11 /3/2004 4:20 PM

[Fwd: EPA comments on City of Raleigh Inspec...
Subject: [Fwd: EPA comments on City of Raleigh Inspection]
From: Shannon Langley <[e-mail]>
Date: Tue, 22 Jun 2004 16:05:22 -0400
To: Susan Wilson <[e-mail]>
Some comments I sent to Dave and Bob in January. I think Judy's email covers all of this
in greater detail but just to be sure I'm sending it to you.
SL
-------- Original Message--------
Subject:EPA comments on City of Raleigh Inspection
Date:Wed, 07 Jan 2004 17:29:27 -0500
From:Shannon Langley <[e-mail]>
To.Bob Sledge <[e-mail]>, Dave Goodrich
<Dave. Goodrich@ncmail. net>
Gentlemen,
I wanted to pass along a couple of items we got as feedback from EPA Region 4 staff after
they performed a CEI at the Raleigh WTP and WWTP in November. Many of the issues he
"found" were not really deficiencies with Raleigh but could be more appropriately termed
"issues between EPA and the State". Anyway, I feel my sixth sense telling me that these
might pop up in the future and wanted to give you a heads up. Share this as you feel
appropriate. Some of the cited deficiencies were:
1. Raleigh monitors M-Ffor parameters required to be monitored daily. This differsfrom
the fed definition according to Chet. We discussed the state reg definition of "daily" and
provided a copy of our regs. Not sure what will happen here.
2. As a major, Raleigh should be submitting the EPA DMR form as is required by Federal
Law. The state form does not include all of the required information. Bob, do we have a
blessing of our form from "way back when"?
3. Raleigh is sending all of its solids to McGill (-6 truckloads per day). Therefore they are
not using the digesters as described in the NPDES permit and this is an bypass. (May not
apply elsewhere but I thought it was interesting enough to share with you as an FYI on
EPA position) a 062 wWW
4. Raleigh should be submitting a DMR for pipe 002 with no flow on it each month.
(possibly a correct assertion). The reuse has not been used yet so I assume it is still
inactive on our system. I talked briefly with Mike Templeton and he said it was likely that
outfall could come out of the NPDES permit as it is covered by permit # WQ0016222. That
is consistent with the way Cary North and South are permitted.
5. They had a lot of questions about the reporting of qualified data (BOD). Judy is
referring him to the lab on this one.
The other issues, I'll spare you from as they don't likely apply across the board.
Hope all is well down there and keep up the good work.
Shannon Langley
1 of 2 6/22/2004 4:09 f M

[Fwde EPA Inspections of City of Raleigh Plants...
Subject: [Fwd: EPA Inspections of City of Raleigh Plants- Concerns Raised]
From: Shannon Langley <[e-mail]
Date. Tue, 22 Jun 2004 16:03:54 -0400
To: Susan Wilson <[e-mail]
Overview as drafted by Judy Garrett...
-------- Original Message--------
Subject:EPA Inspections of City of Raleigh Plants- Concerns Raised
Date:Thu, 29 Apr 2004 16:02:42 -0400
From:Judy Garrett <][e-mail]>
[e-mail]
November 17, 2003- Shannon Langley and Judy Garrett met Chetan Gala with
the EPA at RDU Airport and he followed us back to RRO. He met with
Public Water Supply Representatives, Groundwater representatives and WQ
representatives and went over reasons for his visit(Neuse River Keeper
Letter Allegations) and proposed schedule.
November 18, 2003- Neuse River Plant- Judy and Shannon met with 2 EPA
people from Athens, GA , including Trent Rainey who set up samplers on
the influent and effluent of the WWTP and did a diagnostic evaluation
inspection of the plant. Also present at the plant was an EPA
wetlands specialist who met with Danny Smith of the Wetlands Unit of DWQ
and a Raleigh Representative. There were also 2 vans from EPA with 6
groundwater people who sampled the monitoring wells.
E. M. Johnson WTP- Chetan Gala with EPA, Atlanta inspected the Water
Treatment Portion of the WWTP.
November 19, 2003- Shannon Langley and Judy Garrett met Chetan Gala for
an inspection of the Wastewater Treatment Portion of the E. M. Johnson
Water Treatment Plant with Jerry Keene, John Gardner and Larry Macmillan
with the City of Raleigh . We walked through the plant and then
reviewed the records. The main concerns raised were as follows:
1) There are 2 raw water reservoirs. Both of them have the potential to
have the contents discharged to surface waters, in an emergency. The
raw water reservoir across Falls of Neuse Road from the plant has an
assigned outfall number and monitoring requirements( Outfall 001). Chet
voiced a concern that the City submits reports of no discharge from this
outfall without any written records to back this up. Jerry Keene stated
that the lagoon is checked several times per day to verify that there is
no discharge. He said they will begin documenting their visits. We at
the RRO think that this outfall doesn't need to be in the permit since
it is just water that has been pumped from the Lake.
2) The raw water reservoir on the same side as the WTP has the
potential to receive up to 10 % of recycled water from the treatment
facilities. Since the reservoir could be discharged at the anoroximate
1 of 4
6/22/2004 4:09 PM

[Fiv& EPA Inspections of City of Raleigh Plants...
location of the 002 pipe, Chet was concerned that this outfall was not M*W
listed in the WWTP. We have recommended that an additional pipe be added tit,
to the draft NPDES Permit for this outfall. Chet was also concerned :5,
rrK
about the lack of documentation of no discharge inspection at this
outfall.
3) Chet stated that the plant needs an SPCC plan for diesel fuel. NC 1 0-
is not delegated for this program. The City of Raleigh must deal
directly with EPA for this requirement.
4) Sample collection in the permit requires grab samples. The WTP is
collecting composite samples based upon a request from DWQ due to
concerns that grab samples might not be as representative of the
discharge. Chet noticed that these samples are being collected time
proportionally. He pointed out that the samples must be collected flow
proportionally as required by the monitoring regulations.
5) The data review was uneventful for the NPDES Parameters though Chet
did bring up the issue of the need for internal chains of custody.
Shannon Langley, Chetan Gala and Judy Garrett arrived at the Neuse River
WWTP at 3 PM on November 19, 2003
We review laboratory records until about 5 pm.
November 20, 2004- Shannon Langley and Judy Garrett met Mike Hom in
Garner and he followed us to the WWTP. There he met Randy Jones from
our office, and Tim Woody with the City of Raleigh. Mike conducted a
compliance inspection of the Residual Solids portion of the WWTP. They
also visited McGill Composting in Moncure, NC. Mike has sent us a draft
his portion of the WWTP inspection. He also sent an inspection report
and letter to McGill Composting.
Chet Gala continued his inspection of the Neuse River WWTP. His major
concerns were:
1) Pipe 002 is listed as the reuse pump station. He said that even
though the City has not completed the reuse system and the line is not
complete, the City needs to submit reports for this pipe indicating "no
discharge" .
2) Permittee and ORC signatures on the DMR forms. Chet questioned
whether Dale Crisp and T.J. Lynch have authority to sign in the
respective spaces on the DMR forms.
3) SPCC Plan- Chet indicated that the City must submit and have a plan
approved. This program is not delegated to NC but Chet suggested we
address the requirement in our NPDES Inspections.
4) We discussed the filter bypass amounts which the Neuse River Keeper
brought up again in the most recent letter. Ms. Garrett stated that
she was present when the calibration was attempted by the contract
2 of 4 6/22/2004 4:09 PM

[Fwd: 9,PA Inspections of City of Raleigh Plants...
engineer and that both the SCADA and the on -site flow meters were found
to be off. The bypass flow amount for the January 2002 bypass was
revised due to findings of the calibration. We believe that the exact
amount of the bypass was not as important as the total flow which was
discharged from the plant which was recorded and the composite sample
which included the bypass flows. The sample indicated the the plant was
out of compliance for that bypass and the City was fined for the
violations which occurred. Metering of the bypass flow is not required.
5) A review of the laboratory data was completed for 4 months of the
past 5 years. Two phosphorus values were found to have been left out of
the July 2000 report. The City has since resubmitted the report. The
omitted data did not affect the facility's compliance status. Chet
Gala was concerned that not all of the City's copies of DMRs were signed
by the Permittee. Mr. Lynch stated that the City would obtain the
completed copies from the Division's Central Files and that future
copies would have the Permittee signature.
6) Mr. Gala brought up the need for internal chains of custody within
the facility.
7) A walkthrough of the WWTP was completed by Chet Gala, T.J. Lynch,
Judy Garrett, Shannon Langley and Marla Dalton with the City of Raleigh
Neuse River WWTP Laboratory, after dark. Since the City is not using
the digesters at the plant, Mr. Gala wondered if that constitutes
bypassing a treatment unit. The City is currently dewatering the
residual solids and either lime stabilizing for land application as
Class A material or transporting to McGill composting for further
processing. Our feeling about this is that the bypass language in the
permit is meant to pertain to the main treatment train of wastewater in
the plant.
We stopped by the Walnut Creek lift station which had been mentioned in
the Neuse River Keeper's letter due to a generator failure on December
5, 2002 which resulted in a 9 MG spill to the Neuse River. As you will
recall, the City brought in another generator to run this 100 gpd pump
station. Due to a wiring problem, this generator would not run either.
January 7, 2004- Judy Garrett spoke with Chet Gala on the phone and
spoke about his concerns about the definition of daily monitoring, our
most recent laboratory Certification inspection, permittee signature
requirements and the July 2002 DMR. I faxed him copies of this
information. He also stated that he was going to ask his laboratory
inspections people to inspect the City of Raleigh Laboratories.
January 8, 2004- Mr. Wayne Turnbull from EPA's Athens office called Judy
Garrett to inform the Department of his plans to inspect the City of
Raleigh Laboratories the on January 21 and 22, 2003. He indicated that
John Williams who is an inspector for WTP laboratories would be coming
with him. Judy Garrett informed the PWS in the RRO and Laboratory
Certification of the planned visit.
January 21, 2004- Judy Garrett met with Wayne Turnbull and John Williams
3 of 4 6/22/2004 4:09 PM

f'
[F�vcf : EPA Inspections of City of Raleigh Plants...
from EPA Athens, T.J. Lynch and Marla Dalton
with the City of Raleigh at the Neuse River W ]rP. Ms. Garrett took the
EPA inspectors copies of the NPDES Permits and stayed for 2-3 hours of
the inspection
of the WWTP laboratory. Concerns that were brought up during that time
were:
1) Mr. Turnbull stated .that he thinks the NPDES Permit monitoring
requirements should state 5/week instead of Daily.
2) Mr. Turnbull and Mr. Williams stated that the plant was not meeting
the holding requirement for Ammonia because the composite sampler runs
from 12 am to 11:59 pm and the sample isn't run until 7 am. The City
stated that they would change sampling times to meet the holding
requirements.
3) D.O. Meter calibration is performed using the Winkler Method. The
inspectors stated that the City should use air calibration instead.
Everyone seemed to have trouble calibrating the D.O. meter in the
calibration bottle.
4) Neuse River WWTP Pipe 002. Mr. Turnbull told Mr. Lynch that he
should be accounting for the effluent reuse within the WWTP on the DMRs
for Pipe 002. This office later told Mr. Lynch that we disagree since
this water is retreated within the plant and passes out Pipe 001.
The inspection continued that day with no DWQ representative present.
January 22, 2004- Mr. Turnbull and Mr. Williams inspected the E.M.
Johnson laboratory for water treatment and wastewater with no DWQ or
DENR representative present as far as we know.
Shannon Langley
Environmental Specialist
Raleigh Regional Office
NC Division of Water Quality
4 of 4 6/22/2004 4:09 PM

neuse hearing report and permits
Subject: neuse hearing report and permits
From: Mike Templeton <[e-mail]>
Date: Fri, 02 Apr 2004 10:14:18 -0500
To: Jackie Nowell <jackie.nowellQncmail.net>, Joe Corporon <[e-mail]>,
Tom Belnick --�[e-mail]>, Susan Wilson <[e-mail]>
CC: Dave Goodrich <[e-mail]>
Boyd just signed the report for the May 2003 Neuse permit public hearing, and I will get
that to Alan today for his review. I expect that he will turn it around in the next week or
two, longer if he has issues with it.
In the meantime, we need to crank these permits and fact sheets back up and get them
finalized based on Boyd's recommendations. Ideally, the permits will be ready for Alan to
sign as soon as he approves the hearing report. These are excellent candidates for next
week's blitz. Look through the final recommendations for your permits in the final
worksheets, now on the NPDES server in the SANeuse Permits 2003 folder. (I don't expect
major changes as the result of Alan's review, but if there are we can incorporate those once
we get them.) Dave and/or I should sit down with each of you next week to go over the
recommendations with you. See you then.
- Mike T
1 of 1 4/7/2004 1:18 PM

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City Of 6Raleigh
.North Carolina
November 5, 2003
Ms. Susan Wilson, Environmental Engineer
N.C. Division of Water Quality
NPDES Permitting Unit
1617 Mail Service Center L
Raleigh, NC 27699-1617
� aJl�t'i •
..ill. �.
Subject: Renewal of NPDES Permit No. NCO082376 E. M. Johnson WTP
Dear Ms. Wilson:
We have previously requested renewal of the NPDES Permit No. NCO082376 for the
discharge at the E. M. Johnson WTP. We are currently developing a Bulk Reuse Water
Distribution Program to beneficially reuse the discharge from the facility. Therefore, we
request that the NPDES permit be modified to allow the conjunctive use of reuse water
from the facility.
The Bulk Reuse Water Program has been submitted to the Non -Discharge Permitting
Unit, which has issued a draft permit (Permit No. WQ0022036). We have provided
comments to the draft permit and are currently obtaining additional water quality data as
requested by Ms. Marie Doklovic, PE of the Non -Discharge Permitting Unit.
Please contact us, or our consulting engineer Mike Shafer (919-462-7521), if you have
any questions regarding this request.
KR
es Director
cc: Russell Allen
Marie Doklovic
John Garland
Jack Moyer
Mike Shafer
Tim Woody
Marti Gibson
OFFICES • 222 WEST HARGETT STREET • POST OFFICE BOX 590 • RALEIGH, NORTH CAROLINA 27602
Recycled Paper

Re: City of Raleigh - EM Johnson WTP NPDES Renewal
Subject: Re: City of Raleigh - EM Johnson WTP NPDES Renewal
Date: Mon, 3 Nov 2003 10:37:20 -0500
From: "Marie Doklovic" <[e-mail]>
To: "Susan A Wilson" <[e-mail]>
Susan,
FYI - Below is the permit condition Mike refers to in his message below:
5. The Permittee, within 12 months following issuance of this permit, shall request modification of NPDES
Permit Number N00082376 issued to the E.M. Johnson Water Treatment Plant. The modification shall amend the
existing NPDES permit to allow the conjunctive use of reclaimed water as provided for in this permit.
<?xml:namespace prefix = o ns = "urn: schemas-microsoft-com: office: office" />
Thanks, Marie
K. Marie Doklovic, PE
Environmental Engineer
Division of Water Quality
Non -Discharge Permitting Unit
---- Original Message -----
From: Shafer, Michael B. St��'/�'t by •conk
To: 'susan.wilson @ncmail.net'; 'marie.doklovic @ ncmail. net'
Sent: Friday, October 31, 2003 11:24 AM
Subject: City of Raleigh - EM Johnson WTP NPDES Renewal
I am working with the City of Raleigh to develop a reuse system at the EM
Johnson WTP. We have received a draft permit from Ms. Marie Doklovic for
the reuse system. In her letter, Marie indicated that we need to get the
plant's NPDES permit modified to reflect the reuse system.
Susan, are you the one responsible for the EMJohnson NPDES renewal? If not,
can you help us determine who is? We will send a letter requesting the
change to the permit.
Thanks,
Michael B. Shafer
Black & Veatch
International Company
[phone]
[e-mail]
Name: WQ0022036dp030917.doc
W00022036dp0309.17.doc Type: Microsoft Word Document (application/msword)
Encoding: base64
Download Status: Not downloaded with message
of 2 11/3/03 10:40 AM

[Fwd: City of Raleigh - EM Johnson WTP NPDES Renewal]
Subject: [Fwd: City of Raleigh - EM Johnson WTP NPDES Renewal]
Date: Fri, 31 Oct 2003 11:33:59 -0500
From: Susan Wilson <[e-mail]>
To: Susan.A.Wilson@ncmai].net
Susan,
Another one for you.
Susan M. Wilson
Subject: City of Raleigh - EM Johnson WTP NPDES Renewal
Date: Fri, 31 Oct 2003 10:24:16 -0600
From: "Shafer, Michael B." <[e-mail]>
To: "'[e-mail]"' <[e-mail]:�
"'[e-mail]"' <[e-mail]>
I am working with the City of Raleigh to develop a reuse system at the EM
Johnson WTP. We have received a draft permit from Ms. Marie Doklovic for
the reuse system. In her letter, Marie indicated that we need to get the
plant's NPDES permit modified to reflect the reuse system.
Susan, are you the one responsible for the EMJohnson NPDES renewal? If not,
can you help us determine who is? We will send a letter requesting the
change to the permit.
Thanks,
Michael B. Shafer
Black & Veatch
International Company
[phone]
[e-mail]
I of 1 11/3/03 9:41 AM

Frank LeBron
M25 Fonviile Rd.
Wake Forest, NC
27587
919-846-9518
Boyd Devane
NCDENR / DWQ / Planning Branch
1617 Mail Service Center
Raleigh; 27607-1617.
June 19th 2003
Sir,
I was an operator at The E M Johnson Treatment Plant and 1 can testify to first hand to violations
and evasions of the old NPDES permit. I hope that the new permit will be very stringent. Some of
the problems with the old permit and the City's interpretation of the permit are.
Chronic toxicity was ignored by the plant administration, there should be strict and frequent tox
tests
Flow metering should be required on all outfalls and flow equalization installed.
All samples should be reported to the state including the "process samples"
There should be continuous c12 monitoring,
Grab samples must be taken at peak flow periods not when the plant is shut down.
The out fall from the clearwell drains and old reservoir drain should have flow monitoring.
Any increase in water plant capacity should trigger a new waste permit. The plant went from
60 to 86 mgd with no review of the environmental impact to the discharge stream.
Any change in the treatment process at the WTP should trigger an review of the permit.
There are dozen or more areas that I could address, should you require additional information
you can contact me at 919 5561070
Thanks
Frank LeBron

City Of Raleigh
°TVorth Carolina
June 3, 2003
Mr. Alan Klimek, Director
N. C. Division of Water Quality
1617 Mail Service Center
Raleigh, N.C. 27699-1617
Subject: City of Raleigh Draft NPDES Permits for E.M. Johnson Water Plant
and Neuse River Wastewater Treatment Plant
Dear Mr. Klimek:
Thank you for this opportunity to comment on the subject two (2) draft permits that
DWQ has prepared in response to the City's request to renew the existing NPDES
permits for the discharge of treated wastewater from the E.M. Johnson Water Plant
(permit # NC0082376) and the Neuse River Wastewater Treatment Plant (permit #
NC0029033). Obviously these permits are of crucial interest to the City of Raleigh's
water and sewer customers and to the protection of water quality in the Neuse River
Basin. As you know, the City has had an excellent record of compliance with both of
these current permits. The City is committed to maintaining this record and even
improving this level of permit compliance performance in the renewed permits.
Our Public Utilities Department staff and our engineering consultants at Hazen and
Sawyer have reviewed the draft permits prepared by DWQ. We have found some errors
in the draft permits and also have some concerns and objections to changes that are being
proposed by DWQ. We have summarized our comments in the enclosed sheets and
supporting tables. Once your NPDES permit writing staff has had an opportunity to
review our comments, we would welcome an opportunity to discuss these concerns in a
meeting with your staff.
We look forward to working with DWQ to getting these permits finalized and re -issued
to the City.
0�Y R OFFICES • 222 WEST HARGETT STREET • POST OFFICE BOX 590 • RALEIGH, NORTH CAROLINA 27602
0 Recycled Paper

Please contact me at 890-3070 or Dale Crisp at 890-3400, if you have any questions or to
let us know when we can meet with the DWQ staff.
Sincerely,
9-av-&'
J. Russell Allen
City Manager
Cc: Public Utilities Director
Asst. Public Utilities Director
Construction Projects Administrator
Water Plant Superintendent
Wastewater Treatment Plant Superintendent
Bob DiFiore & Bob Berndt - Hazen and Sawyer, P.C.
Steve Levitas - Kilpatrick and Stockton
Natalie Sierra, Susan Wilson, Boyd Devane - DWQ

DRAFT NPDES PERMIT FOR
CITY OF RALEIGH
E.M. JOHNSON WATER TREATMENT PLANT
City of Raleigh Comments on Draft Permit
1. The City requests the deletion of quarterly monitoring for barium, calcium, lead,
magnesium, nickel and zinc. Most of these parameters are ubiquitous in nature,
and are present in the raw water supply from Falls Lake. The City has
investigated the chemicals added to the raw water during the potable water
treatment process, and these parameters are not present in significant quantities
in the chemicals added in the process.
With regard to the proposed change for aluminum monitoring from weekly to
quarterly, the City requests that the monitoring for aluminum be deleted entirely.
The City no longer adds alum for coagulation and aluminum is not a component
of any of the chemicals the City does add.
2. With regard to the proposed requirement for quarterly toxicity testing, the City
requests that this monitoring requirement be deleted. Following an investigation
of NPDES permits for other water treatment plants in the area, the City is not
aware of any water treatment plants for which the NPDES permit includes a
toxicity monitoring and compliance requirement. At a minimum, the City requests
additional time to monitor effluent water quality for toxicity after the dechlorination
facilities are in operation. These facilities were placed in operation in May 2003.
It is believed the parameter present which would impact effluent toxicity is
chlorine residual, which the City has taken the voluntary initiative to eliminate by
construction and operation of the dechlorination facilities. The City proposes that
effluent toxicity monitoring be considered for addition in the next NPDES permit
renewal cycle if effluent water quality testing after dechlorination continues to
indicate that toxic constituents may be present.
3. Regarding the proposed monitoring of the new Outfall 003, the City requests that
monthly monitoring for the parameters required for Outfalls 001 and 002 be
deleted for Outfall 003. Other than groundwater or stormwater, the only water
treatment plant discharge to this outfall is leakage from the clearwell. The City is
repairing the clearwell and will eliminate or greatly reduce this leakage by
January 2004. Since the water treatment plant impact on this outfall is only from
the finished potable water leaking from the clearwell, the City requests that
monitoring for this outfall be limited to chlorine residual only, and that monitoring
be as grab samples. The City is also dechlorinating this outfall to minimize any
water quality or toxicity concerns related to chlorine residual in the leakage from
the clearwell.
4. The City understands that DWQ is now implementing a statewide policy change
to limit chlorine residuals in all water plant effluent discharges to the extremely
low level proposed in the City's draft permit and therefore accepts the
compliance limit DWQ has proposed.

DRAFT NPDES PERMIT FOR
• CITY OF RALEIGH
NEUSE RIVER WASTEWATER TREATMENT PLANT
Citv of Raleiqh Comments on Draft Permit
1. The City requests the deletion of the proposed monitoring requirements and
compliance limits for cadmium, chromium, lead, selenium and cyanide. There
are no feasible wastewater treatment improvements for a 60 MGD capacity
facility that the City can add to the existing treatment processes at the plant to
insure compliance with these proposed extremely low level metal limits. The
City's Industrial Pretreatment Program has been frequently reviewed by DWQ
staff and very favorably rated, with no mention that these metals are a source
concern for the plant.
The City has been monitoring the plant effluent for these parameters on a weekly
basis (twice a month for cyanide) and does not believe the initial reasonable
potential analyses are valid for these parameters. Effluent data (summary
attached as Table 1) for these parameters has been analyzed for the 33-month
period from July 2000 through March 2003, and the results of this analysis are
summarized for each parameter below, along with other relevant information
including an updated reasonable potential evaluation.
Before water standards based effluent limits are proposed, there must be a
reasonable potential evaluation of monitoring data for each parameter. The
reasonable potential effluent evaluation consists of gathering and evaluating the
data to address outliers, unreliable data and data below the detection limit. The
edited data is then evaluated to determine the coefficient of variation (the
standard deviation divided by the mean). An EPA table provides a parameter
specific multiplier depending on the coefficient of variation and the number of
samples (as a conservative assumption, the number of samples is assumed to be
61 for the evaluations below). It is important to note the EPA table is based on
the assumption the effluent concentration is log normally distributed, and the 99th
percentile confidence level and 99% probability basis are used. This multiplier is
then multiplied by the highest value in the edited database to determine the
maximum predicted effluent concentration. This is a very conservative approach
which establishes a maximum predicted effluent concentration about twice the
maximum observed concentration even when there are over 100 data points.
The maximum predicted effluent concentration is then compared with the
allowable effluent concentration which is based on the instream dilution at 7Q10
flow conditions, assuming the water quality parameter is noncarcinogenic. If the
maximum predicted effluent concentration is below the maximum allowable
effluent concentration, then a permit condition is not justified. If the parameter is
considered to be a carcinogen then the average annual flow is used. Based on
these guidelines each of the proposed parameters is evaluated for reasonable
potential to exceed the allowable instream waste concentration (AIWC). The
updated reasonable potential evaluations for the parameters of interest are
presented in Table 2.
CADocuments and Settingslcrispd\Local Setlings\Temporary Internet Files10LK22130810-002NeuseRiverPemrt1A= Page 1

a. Cyanide
The proposed compliance limits for total cyanide are a weekly average of
10 ug/L and a daily maximum of 22 ug/L. Based on the initial reasonable
potential evaluation, only 26 data points were considered rather than the
full data set. Plant data over the 33-month period includes 68 data points,
none of which exceeded the proposed weekly average limit of 10 ug/L.
The highest value was 8.7 ug/L. Assuming elimination of the highest 5%
of the values as outliers, (which is the accepted practice) the maximum
value is 6.3 ug/L. Once the top 5% of the data are excluded, the attached
reasonable potential evaluation (Table 2) clearly indicates there is no
reasonable potential for cyanide at 9.45 ug/L exceeding the allowable
maximum allowable effluent concentration of 10 ug/L. It is important to
recognize there are considerable analytical difficulties with cyanide and
historically the reported values tend to overestimate the actual
concentrations. Based on this data, we do not consider that there is a
reasonable potential that the water quality standard will be violated for this
parameter, and request that monitoring and limits be deleted from the
subject NPDES permit.
b. Cadmium
The proposed compliance limit for total cadmium is a weekly average of
4 ug/L and a daily maximum of 15 ug/L. The initial reasonable potential
evaluation considered 58 data points. All of the measurements were
below the detection limit of 2.0 ug/L except for a single value of 3.87 ug/L.
When the full data set of 137 measurements is considered the single
measured value is the 3.87 ug/L with the other 136 values being below the
method detection limit. Hence, if the highest 5% of the values are
excluded all data is below the detection limit of 2.0 ug/L. Based on the
standard assumption that the value is equal to Y2 of the method detection
limit, all of the cadmium results would be considered 1.0 ug/L and the
coefficient of variation would be undefined as the standard deviation is
zero. Hence, there is no reasonable potential for exceeding the allowable
maximum allowable effluent concentration and neither a permit limit, nor
continued monitoring is warranted.
C. Chromium
The proposed compliance limits for total chromium are a weekly average
of 103 ug/L and a maximum daily value of 1022 ug/L. The initial
reasonable potential evaluation considered only 58 of the 137 available
measurements now available. The maximum value when all data is
considered is 47.65 ug/L. When the upper 5% outliers are eliminated, the
maximum value is 17.0 ug/L. When the highest 5% of measurements are
excluded as outliers and a reasonable potential evaluation is performed
(see Table 2), the maximum predicted value is 33.95 ug/L which is below
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the maximum allowable effluent concentration of 103 ug/L. Therefore, the
permit limit is not required and continued monitoring is of little value.
d. Lead
The proposed compliance limits for total lead are a weekly average of
52 ug/L and a daily maximum of 33.8 ug/L. (Note the proposed permit
includes a daily maximum limit for lead which is lower than the weekly
average. We assume this is an error.) The initial reasonable potential
evaluation considered only 58 of the 137 available data points. The
unedited data had a maximum value of 190.21 ug/L. Once the top 5
percent of data are eliminated as outliers, the maximum value of the 130
data points is 5.8 ug/L. A reasonable potential evaluation on the edited
data (see Table 2) indicates there is no need for either a numerical limit or
continued monitoring lead with a maximum predicted concentration of
9.28 ug/L being less than 20% of the maximum allowable effluent
concentration.
e. Selenium
The proposed compliance limit for total selenium is a weekly average of
10 ug/L. The initial reasonable potential evaluation had 58 data points
and includes some data which appears mistyped, since it could not be
found in our review of Raleigh's data. Also during this period the ICP
method was believed to be producing erroneous results due to
interferences as discussed below.
Based on the analysis of effluent values over the 33-month period, a
significant increase in selenium concentrations occurred in late 2002
through March 2003. A possible cause for this increase is a change in
testing procedures. Based on information from the plant laboratory staff,
prior to November 2002 selenium testing was being performed using a
Perkin Eimer 5100 Zeeman Graphite Furnace. Beginning in November
2002, the City has been reporting selenium values based on selenium
testing using a Fisons 3560 ICP. A significant increase in selenium values
occurred during and after November, and there appears to be a direct
correlation between the increase in values for this time period and the
change in testing method. According to Standard Methods (18t" Edition),
iron and dissolved organic matter are interferences when analyzing for
selenium. When using the graphite furnace technique, a matrix modifier is
used to help eliminate these interferences. There is no such matrix for the
ICP. The City has begun split sampling for selenium beginning with the
May 2003 samples. The City will continue to analyze for selenium using
the ICP, and will also send the samples to a certified lab for analysis by
graphite furnace and ICP.
CADocuments and SetHngslcdspolLocat Seftgffemporary Internet FfleslOLK22130810.002NeuseRiverPerfttl.doc Page 3

Based on the requirement for reliable data, only the data from July 2000 to
October 2002 should be used for reasonable potential evaluation. This
data consists of 116 measurements with a maximum value of 2.69 ug/L.
When a reasonable potential evaluation is performed on this data set with
the upper 5% of the data excluded, the maximum value of the remaining
110 data points is 1.4 ug/L and the maximum predicted value is 3.08 ug/L,
which is well below the maximum allowable effluent concentration of
10 ug/L. Therefore, a permit numerical limit is not warranted for selenium.
Similarly the edited data set of 110 points indicates continued long term
monitoring is not warranted.
2. The cover letter with the draft permit indicated that the total nitrogen allocation
has been updated to reflect the addition of the nitrogen allocations for the
Bobby L. Murray Plantation Inn WWTP and the Falls Village WWTP. However,
the total nitrogen allocation actually decreased from 676,496lb /year in the
current permit to 676,417 lb /year in the draft permit. We assume the value in the
draft permit is incorrectly stated as the result of a typographical error and will be
corrected to the current permit limit of 676,496 lb /year, which already includes
the allocations from the Plantation Inn and Falls Village plants that were removed
and connected to the City sewer system.
3. The supplement to the permit cover sheet lists two belt filter presses. There are
three belt filter presses at the Neuse River Plant.
C.0oaiments and SettingskdspolLocal SettingsUemporary Internet FIesIOLK 130810-002NeuseRiverPermitl.doc Page 4

Table 1
• City of Raleigh, Nuese River VWVTP Effluent
Metals Monitoring Data
July 2000 to March 2003
Metals Non -Metal
Date Cadmium Chromium Lead Selenium Date Sampled Cyanide (mg/L)
Sampled ug/L ug1L ug/L ug/L
07/05/00
1
1
2.5
0.5
8/2/2000
0.002
07/10/00
1
1
2.5
0.5
8/16/2000
0.002
07/17/00
1
1
2.5
0.5
9/7/2000
0.0046
07/24/00
1
1
2.5
0.5
9/20/2000
0.0043
08/10/00
1
1
5.220
0.5
10/19/2000
0.0063
08/14/00
1
1
1
0.5
10/31 /2000
0.002
08/21 /00
1
1
1
0.5
11 /1 /2000
0.002
08/28/00
1
1
1
0.5
11 /16/2000
0.002
09/04/00
1
1.226
2.5
0.5
12/11 /2000
0.002
09/11 /00
1
0.5
2.5
0.5
12/21 /2000
0.002
09/18/00
1
0.5
5.803
0.5
1 /8/2001
0.002
09/25/00
1
0.5
2.5
0.5
1 /18/2001
0.002
10/02/00
1
2.950
5
0.5
2/6/2001
0.002
10/09/00
1
2.927
5
0.5
2/22/2001
0.002
10/16/00
1
3.095
5
0.5
3/6/2001
0.002
10/23/00
1
3.490
5
0.5
3/21 /2001
0.002
10/30/00
1
5.113
5
1.200
4/6/2001
0.002
11 /06/00
1
1
1
1.800
4/16/2001
0.002
11 /13/00
1
1
1
0.5
5/3/2001
0.0083
11 /20/00
1
1
1
1.300
5/24/2001
0.002
11 /27/00
1
1
1
1.400
6/7/2001
0.002
12/04/00
1
1
2.5
0.5
6/19/2001
0.002
12/11 /00
1
1
2.5
0.5
7/6/2001
0.002
12/18/00
1
1
2.5
0.5
7/17/2001
0.002
12/27/00
1
1
2.5
0.5
8/17/2001
0.002
01 /02/01
1
1
1
0.5
8/28/2001
0.0051
01/08/01
1
1.381
1
0.5
9/6/2001
0.0058
01 /15/01
1
10.697
1
0.5
9/25/2001
0.002
01 /22/01
1
0.5
1
0.5
10/17/2001
0.0087
01 /29/01
1
1.081
1
0.5
10/31 /2001
0.002
02/05/01
1
4.001
5
0.5
11 /8/2001
0.002
02/12/01
1
0.5
5
0.5
11 /19/2001
0.002
02/19/01
1
23.025
5
0.5
12/3/2001
0.002
02/26/01
1
2.046
5
0.5
12/13/2001
0.002
03/05/01
1
3.632
5
0.5
1 /10/2002
0.002
03/12/01
1
1.071
5
0.5
1 /22/2002
0.002
03/19/01
1
1.484
5
0.5
2/12/2002
0.0042
03/26/01
1
1.566
5
0.5
2/27/2002
0.0052
04/02/01
1
7.722
5
0.5
3/13/2002
0.0042
04/09/01
1
3.784
5
0.5
3/25/2002
0.0073
04/16/01
1
7.229
5
0.5
4/15/2002
0.002
04/23/01
1
2.826
5
0.5
4/25/2002
0.002
04/30/01
1
3.135
5
0.5
5/16/2002
0.002

Table 1
05/07/01
1
2.616
5
0.5
05/14/01
1
1 -
5
0.5
05/21 /01
1
1
5
0.5
05/28/01
1
1
5
0.5
06/04/01
1
1.849
2.5
0.5
06/11 /01
1
6.437
2.5
0.5
06/18/01
1
1
2.5
0.5
06/25/01
1
1
2.5
0.5
07/09/01
1
1
1
0.5
07/16/01
1
1
1
0.5
07/23/01
1
1
1
0.5
07/30/01
1
1
1
0.5
08/06/01
1
2.5
2.5
0.5
08/13/01
1
4.772
2.5
0.5
08/20/01
1
1
2.5
0.5
08/27/01
1
1
2.5
0.5
09/03/01
1
0.5
5
1.184
09/10/01
1
0.5
5
0.5
09/17/01
1
3.071
5
0.5
09/24/01
1
0.5
5
0.5
10/08/01
1
4.674
2.5
0.5
10/15/01
1
1
2.5
0.5
10/22/01
1
1
2.5
0.5
10/29/01
1
4.007
2.5
0.5
11 /05/01
1
2.5
5
0.5
11/12/01
1
2.5
5
0.5
11 /19/01
1
2.5
5
0.5
11 /26/01
1
2.5
5
0.5
12/03/01
1
2.788
2.5
0.5
12/10/01
1
2.463
2.5
0.5
12/17/01
1
10.147
2.5
0.5
12/26/01
1
2.298
2.5
0.5
01 /07/02
1
2.5
2.5
0.5
01 /14/02
1
2.5
2.5
0.5
01 /22/02
1
2.5
2.5
0.5
01 /28/02
1
2.5
2.5
0.5
02/04/02
1
2.5
2.5
0.5
02/11/02
1
2.5
2.5
0.5
02/18/02
1
2.5
2.5
0.5
02/25/02
1
2.5
2.5
0.5
03/04/02
1
3.577
2.012
0.5
03/11 /02
1
3.491
190.213
0.5
03/18/02
1
1.718
8.693
0.5
03/25/02
1
1.213
3.786
0.5
04/08/02
1
1.158
0.5
0.5
04/15/02
1
0.5
1.698
0.5
04/22/02
1
1.404
3.709
0.5
04/30/02
1
2.260
0.5
0.5
05/06/02
1
2.5
2.5
0.5
05/13/02
1
2.5
2.5
0.5
05/20/02
1
2.5
2.5
0.5
05/28/02
1
7.770
158.188
0.5
5/28/2002
0.002
6/5/2002
0.002
6/17/2002
0.002
7/2/2002
0.002
7/16/2002
0.002
8/1 /2002
0.002
9/16/2002
0.002
9/19/2002
0.002
10/1 /2002
0.002
10/15/2002
0.002
10/28/2002
0.002
11 /2/2002
0.002
11 /13/2002
0.002
11 /23/2002
0.002
12/3/2002
0.002
12/13/2002
0.002
1 /3/2003
0.002
1 /13/2003
0.002
1 /23/2003
0.005
2/3/2003
0.002
2/13/2003
0.002
2/25/2003
0.002
3/6/2003
0.002
3/18/2003
0.002
3/31 /2003
0.002

Table 1
06/03/02
1
17.406
3.116
0.500
06/10/02
1
5.226
1.219
0.5
06/17/02
1
4.037
0.5
0.5
06/24/02
1
2.824
1.198
0.5
07/05/02
1
1.098
2.5
0.5
07/09/02
1
1.403
2.5
0.5
07/15/02
1
0.5
2.5
0.5
07/25/02
1
3.393
2.5
0.5
07/29/02
1
1.613
2.5
0.5
08/05/02
1
4.754
1
5
08/12/02
1
4.257
1
5
08/19/02
1
3.911
1
5
08/26/02
1
3.355
1
5
09/02/02
1
23.174
7.244
2.690
09/09/02
1
23.863
2.652
1.727
09/16/02
1
17.926
1
2.536
09/23/02
1
16.975
2.519
1.759
09/30/02
1
15.920
1
1.585
10/07/02
1
3.020
1
0.5
10/ 14/02
1
2.806
1
1.354
10/21 /02
1
2.489
1
0.5
10/28/02
3.87
47.656
1
0.5
11 /04/02
1
11.129
2.71
14.918
11 /13/02
1
8.327
1
10.727
11 /18/02
1
5.576
6.725
17.568
11 /25/02
1
8.748
2.964
13.859
12/02/02
1
12.230
2.5
13.898
12/09/02
1
7.038
2.5
1
12/16/02
1
5.833
2.5
7.418
12/30/02
1
6.906
2.5
14.274
01 /06/03
1
5.505
2.5
2.5
01 /13/03
1
6.375
2.5
5.497
01 /21 /03
1
4.966
5.000
9.038
01 /27/03
1
5.586
2.5
2.5
02/03/03
1
4.500
1
13.230
02/ 10/03
1
4.942
1
17.289
02/ 17/03
1
4.252
1
15.304
02/24/03
1
4.284
1
11.785
03/03/03
1
2.663
1
18.335
03/10/03
1
5.523
2.191
15.572
03/17/03
1
2.075
10.176
13.309
03/24/03
1
2.171
1
13.809

Table 2
City of Raleigh, Nuese River Wastewater Treatment Plant, July 2000 to Mar 2003
Reasonable Potential Evaluation with Outliers (upper
5%) Deleted
Metals
Non -Metal
Cadmium
Chromium
Lead
Selenium
Cyanide
u�c' /L
ucL
u�c IL
u9/L
ug/l
1
1
2.5
0.5
2
1
1
2.5
0.5
2
1
1
2.5
0.5
4.6
1
1
2.5
0.5
4.3
1
1
5.220
0.5
6.3
1
1
1
0.5
2
1
1
1
0.5
2
1
1
1
0.5
2
1
1.226
2.5
0.5
2
1
0.5
2.5
0.5
2
1
0.5
5.803
0.5
2
1
0.5
2.5
0.5
2
1
2.950
5
0.5
2
1
2.927
5
0.5
2
1
3.095
5
0.5
2
1
3.490
5
0.5
2
1
5.113
5
1.200
2
1
1
1
0.5
2
1
1
1
1.300
2
1
1
1
1.400
2
1
1
1
0.5
2
1
1
2.5
0.5
2
1
1
2.5
0.5
2
1
1
2.5
0.5
2
1
1
2.5
0.5
5.1
1
1
1
0.5
5.8
1
1.381
1
0.5
2
1
10.697
1
0.5
2
1
0.5
1
0.5
2
1
1.081
1
0.5
2
1
4.001
5
0.5
2
1
0.5
5
0.5
2
1
2.046
5
0.5
2
1
3.632
5
0.5
2
1
1.071
5
0.5
4.2
1
1.484
5
0.5
5.2
1
1.566
5
0.5
4.2
1
7.722
5
0.5
2
1
3.784
5
0.5
2
1
7.229
5
0.5
2
1
2.826
5
0.5
2
1
3.135
5
0.5
2
1
2.616
5
0.5
2
1
1
5
0.5
2
1
1
5
0.5
2
1
1
5
0.5
2

Table 2
1 1.849
5
0.5
1. 6.437
2.5
0.5
1 1
2.5
0.5
1 1
2.5
0.5
1 1
2.5
0.5
1 1
1
0.5
1 1
1
0.5
1 1
1
0.5
1 2.5
1
0.5
1 4.772
2.5
0.5
1 1
2.5
0.5
1 1
2.5
0.5
1 0.5
2.5
1.184
1 0.5
5
0.5
1 3.071
5
0.5
1 0.5
5
0.5
1 4.674
5
0.5
1 1
2.5
0.5
1 1
2.5
0.5
1 4.007
2.5
0.5
1 2.5
2.5
0.5
1 2.5
5
0.5
1 2.5
5
0.5
1 2.5
5
0.5
1 2.788
5
0.5
1 2.463
2.5
0.5
1 10.147
2.5
0.5
1 2.298
2.5
0.5
1 2.5
2.5
0.5
1 2.5
2.5
0.5
1 2.5
2.5
0.5
1 2.5
2.5
0.5
1 2.5
2.5
0.5
1 2.5
2.5
0.5
1 2.5
2.5
0.5
1 2.5
2.5
0.5
1 3.577
2.5
0.5
1 3.491
2.012
0.5
1 1.718
3.786
0.5
1 1.213
0.5
0.5
1 1.158
1.698
0.5
1 0.5
3.709
0.5
1 1.404
0.5
0.5
1 2.260
2.5
0.5
1 2.5
2.5
0.5
1 2.5
2.5
0.5
1 2.5
3.116
0.5
1 7.770
1.219
0.5
1 5.228
0.5
0.500
1 4.037
1.198
0.5
1 2.824
2.5
0.5
1 1.098
2.5
0.5
2
2
2
2
2
2
2
2
2
2
2
2
5
2
2
2
2
2
2
St Dev.
1.0646
Mean(Ave)
2.4108
Co. of Variation
0.44
Multiplier
1.5
Max Pred. Conc
9.45
All. IWC
10
Limit Needed
No

Table 2
1
1.403
2.5
0.5
1.
0.5
2.5
0.5
1
3.393
2.5
0.5
1
1.613
1
0.5
1
4.754
1
0.5
1
4.257
1
5
1
3.911
1
5
1
3.355
2.652
5
1
16.975
1
5
1
15.920
2.519
0.5
1
3.020
1
1.354
1
2.806
1
0.5
1
2.489
1
0.5
1
11.129
1
1
8.327
1
1
5.576
2.71
1
8.748
1
1
12.230
2.964
1
7.038
2.5
1
5.833
2.5
1
6.906
2.5
1
5.505
2.5
1
6.375
2.5
1
4.966
2.5
1
5.586
5.000
1
4.500
2.5
1
4.942
1
1
4.252
1
1
4.284
1
1
2.663
1
1
5.523
1
1
2.075
2.191
1
2.171
1
St Dev
0
2.91267
1.520376
0.851743
Mean (Ave)
1
3.121229
2.712191
0.69764
Co of Var
Indetermin.
0.933
0.56
1.221
Multiplier
NA
2
1.6
2.2
Max Pred.0
Less Than 1
33.95
9.28
3.08
Allow. IWC
4
103.1
52
10
Limit Needed
No
No
No
No
St Dev.
Mean(Ave)
Co. of Variation
Multiplier
Max Pred. Conc

Summary and Neuse River Basin Public Hearings
g
Recommendations May 29, 2003
City of Raleigh
E.M. Johnson WTP
NCO082376
Facility Description
The City of Raleigh owns and operates the E.M. Johnson WTP. The plant treats surface water from
the Falls of the Neuse Reservoir in order to produce potable water for the City of Raleigh's residents.
The water treatment produces wastewater in the form of filter backwash water. Residual solids in
the wastewater are removed by gravity settling.
Permit Summary
The current permit has two designated outfalls:
• Outfall 002 — The treated wastewater discharge from the water treatment process.
• Outfall 001— Retained at the City's request as a potential additional outfall location for the
discharge from the water treatment process. This outfall has never been used (and no plans are
in place to use this outfall right now). It has the same requirements as Outfall 002.
The draft permit proposes the following changes:
• Outfall 003 - The permit designates an existing stormwater outfall as the new Outfall 003. In
addition to stormwater runoff, this drain/culvert discharges leakage from the WTP's treated
water clearwell, at a point upstream of Outfall 002. Residual chlorine is a potential parameter of
concern. The City received an ATC to install a dechlorination system at this outfall.
• Outfall 003 — Monthly monitoring of various parameters.
• Total residual chlorine is limited at 17 ug/L (daily maximum) at outfall 003 (already limited at
Outfall 001); compliance schedule of 90 days from the effective date of the permit.
• Quarterly chronic toxicity monitoring is added at Outfalls 001 and 002, to be reported as a
Chronic Value.
• Quarterly monitoring for Ba, Ca, Pb, Mg, Ni, Zn; weekly monitoring for Cu, Fe, Mn are added at
Outfalls 001 and 002. Al monitoring reduced to quarterly.
• Composite sampling required for appropriate parameters. Continuous flow monitoring.
• Spill Response and Prevention Plan (SRPP) — required 90 days from the effective date.
Public Comments
Dean Najouks — Upper Neuse Riverkeeper:
• Pleased to see additional monitoring requirements in the draft permit.
• The City has been unresponsive — won't accept responsibility for damage caused by the
discharge.
• Received complaints from residents and investigated the creek himself — adverse impact from
discharge.
• High chlorine levels.
• Substrate in stream with high levels of metals — result of sludge discharge into stream.
• City manager acknowledged (finally) that the discharge adversely affected aquatic life. NRF
disappointed in the way the City has handled the matter.

Summary and Recommendations
E.M. Johnson WTP, NCO082376
• Request that the City perform monitor whole effluent toxicity on a monthly basis instead of just
quarterly as recommended in draft permit. This would provide more information and help the
state with its study on water treatment plants. Would also like for the City to perform test on
daily grab sample when the filters are being backwashed.
• If different treatment chemicals are used — monitoring requirements should reflect the chemicals
being used in the treatment process. State should require use of specific chemicals or require
review of the permit any time treatment process is changed.
• Request that the City provide in-house monitoring reports to the state — where they test their
effluent prior to discharge. North and South basin samples should be reported.
• Should require continuous monitoring on 003 (chlorine is an issue, sources say sludge has been
discharged through 003). Permanent monitoring should be placed on 003, similar to that at 002.
• Permit should include a flow limit for the facility's discharge; this will help determine how
much the discharge makes up of the stream (and impact). The permit gives "UT to Honeycutt
Creek" as the receiving water; should be "UT to Falls Lake" because flow never reaches the
creek before it reaches Falls Lake.
• Should be a Class II facility; thus, the ORC will have to be certified for Class II as well.
• Recommend requiring an Engineering Alternatives Analysis (EAA) within 180 days, exploring
re -use options and discharge to WWTP.
• Remove line in draft permit (he meant cover letter), commending the City for moving forward
with construction of dechlorination facilities. City has known it needed to do something for
years and that the discharge was damaging the stream.
Frank LeBron (former operator at WTP, in written comments):
• There have been violations and evasions of the NPDES permit.
• The permit should require frequent toxicity tests. Flow metering should be required on all
outfalls and flow equalization installed. All "process samples" should be reported. Continuous
chlorine monitoring should be required. Samples should be collected at peak flow periods, not
when plant is shut down.
• Outfall from clearwell drains and the old reservoir drain should have flow monitoring.
• Any increase in plant capacity should trigger a new wastewater permit. Plant went from 60 to
86 MGD (drinking water production) with no review of environmental impact. Any change in
treatment process should trigger a review of the permit.
City of Raleigh (in written comments):
The City provided written comments on the draft permit's requirements for metals monitoring,
toxicity monitoring, and the new monitoring requirements at Outfall 003. The comments did not
respond to issues raised at the hearing.
DWO Response and Discussion
The NPDES Unit will consider the City's comments on the draft permit separately from the issues
raised in the hearing.
Although composite sampling is required for many parameters of concern, the Division shares some
of the concerns that, given the normal variability in wastewater flows, samples collected at Outfall
002 may not be sufficiently representative of the discharge. We should probably have the City
characterize the discharge flows at this point.
Some of the other concerns are already addressed in the draft permit; with others, the measures
proposed by the commenters are not consistent with the Division's permitting policies or practices.
-2-

. • Summary and Recommendations
E.M. Johnson WTP, NCO082376
Recommended Action(s)
In addition to changes already proposed in the draft permit, the NPDES Unit should add the
following special condition to the final permit along with a companion condition describing the
toxicity testing requirements:
A.(--,.) FLOW CHARACTERIZATION
1. No later than 120 days after the effective date of this permit, the Permittee shall characterize the
discharge at Outfall 002 and submit a written report of its findings to the Division's NPDES
Unit, as described below.
• The Permittee shall monitor the discharge through one continuous 7-day period as
follows:
Parameter
Monitoring
Frequency
Sample
Type
Flow
1l % hour
Instantaneous
Conductivity
1/ hour
Grab
Settleable Solids
1/ hour
Grab
Acute Toxicity
Once 2
Grab
Footnotes:
(1) Location: existing effluent monitoring point for Outfall 002.
(2) Acute Toxicity, 48-hr LC50 test, Ceriodaphnia; grab sample shall be
taken during a representative peak flow period. See Condition
A.(—.), Acute Toxicity Monitoring.
• The Permittee shall make a reasonable attempt to choose a study period that is
representative of facility operations and discharge. The study period shall
coincide with chronic toxicity monitoring at Outfall 002.
-3-

E.M. Johnson Water Treatment Plant
NCO082376
When I first decided to challenge this permit I was primarily interested in additional monitoring
requirements. I only recently had a chance to look at the new draft permit and I must say that I
am definitely pleased with the additional monitoring requirements in the new permit. I applaud
the efforts the state is making to finally crack down on this facility. This Public Utilities
department has literally gotten away with murder. It has been an uphill battle just to get Dale
Crisp, the Public Utilities Director to accept any responsibility for the damages this facility has
caused this stream. Unfortunately again, the state is responding long after the receiving stream
has been severely impacted. The state needs to be much more proactive in the future. They could
have implemented some of these changes in the permit when it was up for renewal five years
ago. They had an opportunity 7 years ago to crack down on this facility (Potassium
permanganate spill).
Federal antidegradation policy (Tier 1) ensures that no discharge authorized under an NPDES
permit will harm an existing use. This is an absolute *"floor" of protection for all water bodies.
This facility, I believe as do many others, has also impacted Falls Lake. Bass Fisherman have
told me that they have not caught fish in Honeycutt Bay (in -Falls Lake) since at least 1996. It
does not seem that the state is protecting existing uses in this case.
BACKGROUND
I had received complaints from both Public Utilities employees and residents living in Sheffield
Manor (who live adjacent to the receiving stream the water treatment plant discharges into) that
the water treatment plant had discharged sludge and was killing off the aquatic life living in the
stream. When the city manger ignored these concerns, I was forced to investigate these concerns
on my own with the help of Dave Wojonowski, Stream Watch Coordinator for NC Division of
Water Resources (DWR) and Kathy Herring from NC Division of Water Quality (DWQ).
Both state agencies acknowledged that the E.M. Johnson Plant was having a significant
impact on the stream that tows into Falls Lake. One report stated that the plant was
actually "killing all the aquatic life in" the stream. According to Ernie Seneca from
DWQ, the plant is currently under investigation due to the impacts the plant is having on
aquatic organisms in the stream, possible unpermitted sludge disposal into the stream and
conducting uncertified lab work for almost three years for testing Alum (found in sludge).
State officials have also raised concerns about recent chemical spills and operational
issues.
According to the plants NPDES permit, under Chronic Toxicity Protection, it "requires
that toxic substances shall not render waters injurious to aquatic life or wildlife,
recreational activities, public health or impair water for any designated uses." Dale
Crisp reported to the N&O that Raleigh conducted 'its own tests on water it releases into
the creek and preliminary results found that it is not toxic." After reviewing the Effluent
Aquatic Toxicity Report from 9-16 and 9-17-02, the chlorine levels reported to the media
indicated that they were below 0.1 mg/l. Levels as high as .25 mg/1 of free chlorine

would have a profound impact on aquatic life in the stream, with the ability to kill off fish
fingerlings in a mere five hours.
• More recent testing conducted by the city indicated chlorine levels of .40 mg/l, .53mg/1
and .66 mg/L according to. Aquatic Toxicity Reports taken later in October and
November. Mortality rates for aquatic life are extremely high at these levels.
November's report demonstrated a 100% kill off rate of the Ceriodaphina (water fleas)
with only 24% of the effluent.
• The City has submitted an application to construct a dechlorination system to treat their
effluent before it enters the stream, as well as explore potential options for reuse and
possibly recycling part of their effluent. Yet, Dale Crisp and Russell Allen continued to
deny that the plant is having an impact on the stream and contend that the city was
operating within their permit. Ernie Seneca from DWQ publicly stated that "there may
be other chemicals impacting [the stream]" as well.
• In a review of Analytical Data (11-18-02) based on "black precipitate found covering
rocks" downstream from the water treatment plant, DWQ's Aquatic Toxicology Unit
acknowledged that "several metals --were present at levels potentially adequate to cause
probable ecological effects, presuming they are bioavailable in form, these include iron,
manganese, and nickel. Cadmium, mercury and zinc were also present at concentrations
of potential threshold effects...Magnesium and barium were both present at levels of
potential chronic toxicity, both upstream and downstream. Aluminum was present at
potentially toxic levels upstream only." Copper, calcium, and sodium were also found.
The report recommends "further analysis and toxicity testing may provide a more
adequate assessment of potential ecological effects." While more testing might be
required to determine the ecological effects, the issue of why these substances are even in
the stream has not been addressed. Manganese, aluminum, and iron are components
of sludge. Discharging sludge into this stream (and consequently into Falls Lake) is not a
permitted activity under the plant's NPDES permit.
• John Garland, the water treatment plant superintendent, has publicly- stated, "there has
never been sludge or illegal discharges into the stream." According to files obtained from
DWQ, there have been illegal discharges. In 1996, roughly 100,000 gallons of a
potassium permanganate chemical solution (2,377 total pounds of potassium
permanganate) was intentionally discharged into the stream over the course of three
days, turning the stream bright red. All told, nine separate General Statute violations and
rules violations had been determined in the enforcement action of the City of Raleigh
regarding this incident. Dale Crisp contended that no violation of the permit or water
quality standards had occurred, stating "the city was permitted to discharge RMnO4
(potassium permanganate) via NPDES permit No. NC0082376." The state disagreed.
Residents living in Sheffield Manor contend that they have personally witnessed the
stream running bright red and noticed "a black sludge looking substance" in the stream
more recently than the 1996 incident.

• In an email dated 12-9-02, Dale Crisp maintained that the water treatment plant has not
"impacted the aquatic life diversity in the effluent receiving stream," contending that they
are not violating Chronic Toxicity Protection within their permit because the permit does
not technically indicate "a specific effluent concentration where the aquatic toxicity
exists." Yet, he acknowledges that the city has repeatedly failed the tests that are used to
determine chronic toxicity. "We are certainly disappointed that the October and
November results indicated toxicity at any effluent concentration." Crisp also stated, "we
have not discharged sludge into this receiving stream We have experienced a few
monthly permit limit exceedances in our turbidity and suspended solids." In regard to
illegal discharges he stated; "I'm sure there have been some."
On December 11, 2002, I received a letter from the Raleigh City Manger Russell Allen
finally acknowledging, "that its [the E.M Johnson Plant] discharge appears to have
adversely affected aquatic life diversity in the receiving stream." It took nearly six
months for the city to publicly acknowledge that there was even a problem out at the
stream.
I have been thoroughly disgusted by the attitude and behavior of Raleigh Public Utilities. I truly
hope that the state continues to scrutinize how these Raleigh facilities are being managed,
considering that same public utilities department is still managing them.
ADDITIONAL PROVISONS NRF WOULD LIKE TO SEE IN NPDES PERMIT
What NRF would like to see in this permit is a monthly multiple dilution, whole effluent toxicity
(WET) testing on the wastewater treatment effluent rather than quarterly testing. We feel this is
an opportunity to use the data to better understand how large water treatment plants are affecting
aquatic communities, which in turn can be incorporated into the Division of Water Quality's
statewide study. We would also file to see this facility perform a daily grab sample from
discharge (not stream), which should be performed while backwashing filters (in conjunction
with the composite sampling).
If there are any additional changes in the treatment process, such as using aluminum
polychloride instead of Ferric (iron), monitoring requirements should reflect the chemicals being
used in the treatment process in the discharge permit. Water plants switch quagulants on a
regular basis. There is no guarantee this water treatment plant will not revert back to using Alum.
The state should either require that this facility continue using Ferric or require a review of the
discharge permit any time treatment process is changed. Waiting another 5 years to address
these changes is unacceptable, considering the damage this facility has already caused to this
stream
We request that the daily "creek sheet" in-house monitoring reports, where they test their
effluent before it reaches the outf ill into the stream, be submitted to the state from now on.
Likewise, all samples must be reported, particularly samples taken from North and South Basin.
We support the idea of continuous monitoring of outfall 001 because of the pretreatment going
into the reservoir. This discharge could potentially release dangerous chemicals such as caustic,

and Kmn04 (potassium permanganate), as well as carbon into the stream that flows through Falls
River Subdivision. There should also be continuous monitoring of outf dl 003 (which is even
more important). This is the bottom valve/drain valve for the old reservoir. Chlorine leaking
from the clear well could potentially discharge high levels of chlorine into the receiving stream.
According to my sources, sludge has been discharged throughout fall 003 into the receiving
stream in the past. There are currently two pumps leading up to the old reservoir, which could
allow discharge from entire plant to be diverted from outfall 002 to outfall 003, should the plant
fail to meet their effluent limits. Permanent stringent monitoring should be imposed on this out
fall (003), similar to the requirements of outf dl 002.
We strongly recommend that a discharge limit/flow limit be developed for this facility. Right
now, there is no limit on the discharge into Falls Lake. I think it is important to note that the
current permit indicates that EM Johnson Plant discharges into an UT of Honeycutt Creek. This
is incorrect. The EM Johnson plant actually discharges into a UT that flows directly into Falls
Lake. As a result, the effluent is not diluted because it is discharged into a very low flow stream,
never reaching Honeycutt Creek before it enters Falls Lake. Calculations in a permit are usually
based on how much your discharging into the receiving waters. This goes back to the issue of
existing uses I mentioned earlier. The current permit does not take into consideration the existing
uses that are being threatened in Falls Lake.. I think the state needs to take a hard look at this. The
permit should reflect these changes.
This facility should be upgraded to from a Class I to at least a Class II facility, requiring more
qualified operators. This is considered a physical and chemical treatment system (because of the
dechlorination process), not a biological. system. State law requires that this facility be upgraded
due to the change in the treatment. We have seen the environmental damages a water treatment
plant can cause. It is important to have a competent operator running this facility, if for nothing
else, the fact this plant will provide more drinking water than any other WTP in the state (other
than perhaps Charlottes WTP). We need qualified people running this facility. &ov- ,, z a-aa ,�u4-r-w JS)
We would like to see an alternatives analysis be completed within 180 days, requiring the city to
explore reuse options (ie; to nearby golf courses etc.) rather than recycling part their treated
effluent. Part of the alternatives analysis should require the city to explore discharging effluent to
the Neuse River WWTP instead of discharging into the current receiving stream. Considering
the additional monitoring requirements and the damage this facility has caused to the stream, it
might be more cost effective to discharge the effluent to the cities waste treatment system. It is
doubtful that unless this facility significantly reduces all the chemicals being used in the
treatment of drinking water, impacts to this stream and Falls Lake will cease.
Last but not least, we would like the line removed from the draft permit that commends the city
"for moving forward with construction of dechlorination facilities prior to its requirement in the
permit." The city was well aware for eight years that they were killing off the stream,
discharging sludge and other chemicals into Falls Lake. Like wise, they knew they were
contaminating ground water at the Neuse River Plant and subjecting their workers to horrible
working conditions for many years. This public utilities department has only acted and done the
right thing when it was forced to do it. It is unacceptable for the state to commend this

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department and this facility when they have had to be policed idce little children. Let's not forget
the price tag the Raleigh taxpayers have to pay to fix the damages this department has caused.

AFFIDAVIT OF PUBLICJAT'IAY ' 20M
NORTH CAROLINA. - - _
Wake County. ) Ss. `
n JIIle uF VUHLIC HEARING
TO BE HELD BY
THE NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
SUBJECT:
A Public hearing hod seen schedules concerning the proposed renewal and issuance of fhe
following NPDES Permits:
Permit number NC0040266 to the Keightdole Estates Mobile Home Limited
Partnership far the Knightdale EstatesMainlyHome Pork located in Knightdole
( Wake County) for the discharge of treated domestic wastewater into an unnamed
Iribulvey to the Neuse River.
Permit number NCM784 to the Neuse River Utilities LLC for the Riverview Mobile
Home Park located in Raleigh ( Wake County) for the discharge of treated domestic
wastewater into the Neuse River.
rinmebnt81hhNC
aetreticatemerioana(WakCouy) fODWor the
dicrgeof treated wswn
unnamed tributary to Middle Creek.
- Perm if number NCO035181 to the NC Center for Motu, Adults located In FuquOy.vm
,Ina (Woke County) for the discharge of treated domestic wastewater into an
unnamed tributary to Middle Creek.
Permit number NCO026M2 to the Town of Princeton for the Princeton Wastewater
Treatment Plant located in Princeton (Johnston County) for the discharge of treated
municipal wastewater into the Little River.
Permit number NCO082376 to the City of Raleigh for the E.M. Johnson Water
Treatment Plant located in Raleigh (Woke County) for the discharge of treated
wastewater from a municipal dunking water plant into an unnamed tributary tatter
Neuse River.
o vtetl in Garner (WakeeCount,) foci the tl Inc.
rgeOf treateRdudomes is waste hater
info an unnamed tributary to Swift Creek.
Permit number NC0064891 to the Town of Kenly for the Kenly Regional Wastewater
Treatment Plant located in Kealy (Johnston County) for the discharge of treated
municipal Wastewater into the Little River.
- Permit number NCO049034 to Wake County for the Mount Aubum Training Center
located In Garner (Wake County) for the discharge of treated domestic wastewater
into on unnamed tributary to While Oak Creek.
- Permit number NCOOM246 to Jerry Pace for the Pare Mobile Home Park
Wastewater Treatment Plant located in Clayton (Johnston County) for thedischorge
of treated domestic wastewater into On unnamed tributary to Buffalo Creek.
Permit number NCM9033 to the City of Raleigh for the Raleigh Neuse River
Wastewater Treatment Plant located in Raleigh ( Wake County) for the discharge of
treated municipal Wastewater. thin the Neuse River.
PURPOSE:
Each of these facdllles has cap' ad for renewal of their NPDES Permit for the d"chorge
of treatetl domestic or municipal wastewater me waters of the Neuse River basin. On The
hosts of preliminary staff review and application of AR tide 21 of Chapter 143. General
Sfo . of North Camlino, antl other lawfal standards and regulations, the North
Carol tna Envi ranment-Management Commission proposes to issue a NPDES perm", far
each facility subjecttosPecilic pollutant limitations an saeclal mettions. the Director
of the" Sean of Water Quality pursuant to NCGS Ida-215.IIc)is) antl Regulation IS
NCAC 2 e .y'oni .o100 has determined that if is in the public interest ,hat a meeting he
beltl to receive all Pertinent public comment on whether Ia issue- modify, or deny Ihr.
Permit.
PROCEDURE:
The haling will be conducted in the following manner
1. An explanation of the North Carolina Environmental Management Commission's
Permitting. procedure WM be presented by the Division of Water Quality,
2. An explanation of Ina action for which each Permit is required may be made by the
applicant.
3. Public Comment . Comments, statements. data and other information may be
sub,litled In writing prior to Or during the meeting Or may be presented orally at the
meeling. Persons desiring to $Peak will indicate this intent at the time of registration at
the meeting. 5o that all persons desiring to speak may do sP lengthy statements may be
limited of the discretion of the meeting officer. Oral Presentations that exceed three
minutes should be OCCOmponied by l hree writ ten con— nhirh villbefillo.th Division
staff at the time of registration
C Cross examination of Persons presenting testimOnv w, 1 ant he nllowed: however the
hearing officer may ask questions for Clarification
5. The hearing record may be losedl at the ronrl slur ar ran meeting.
WHEN:
May 29. 2003 of ZOO P.m.
WHERE:
Archtlota Building
Ground FIa.r Hearing Room
512 N. Salisbury Sheet
Raleigh, North Carolina
INFO
AcMhTeIdO
t NPDES Permit($) and a map showing the Iarntem of the discharge(,)
One available by writing or calling
Mrs. Votary Stephens
NC Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 276W 1617
Telephone number: (919) 733-%83, extension 320
The 00PUPOtions antl other information are on file at the Division Of Water Quality, 512
North Salisbury Street, Room 925 of the Archdale Building in Raleigh, North Carolina and
at the Division's Raleigh Regional Office (3800 Barrett Olive in Raleigh. NC). They may
be inspected during normal office hours Copies of the information on file are available
upon request and payment of the Costs Of reproduction All such comments and req.ests
regarding this matter should Pink, referenre to In, nermn lumber($) listed above.
N8.0: April 26, 2003
Before the undersigned, a Notary Public of Johnston
County North Carolina, duly commissioned and authorized to
administer oaths, affirmations, etc., personally appeared Ivy
Marsch, who, being duly sworn or affirmed, according to law,
doth depose and say- that she is Billing Manager -Legal
Advertising of The News and Observer a corporation
organized and doing business under the Laws of the State of
North Carolina, and publishing a newspaper known as The
News and Observer, in the City of Raleigh , Wake
County and State aforesaid, the said newspaper in which such
notice, paper, document, or legal advertisement was published
was, at the time of each and every such publication, a
newspaper meeting all of the requirements and qualifications
of Section 1-597 of the General Statutes of North Carolina and
was a qualified newspaper within the meaning of Section 1-
597 of the General Statutes of North Carolina, and that as such
she makes this affidavit; that she is familiar with the books,
files and business of said corporation and by reference to the
files of said publication the attached advertisement for
WATER QUALITY BUDGET OFFICE was inserted in the
aforesaid newspaper on dates as follows: 04/26/03
Account Number: 73370151
books and files of the aforesaid Corporation and publication.
Bi*finganageor-Leg:a!�Advertising
Sworn or affirmed to, and subscribed before me, this
28 day of APRIL , 2003 AD
In Testimony Whereof, I have hereunto set my hand
and affixed my official seal, the day and year aforesaid.
NotaryPublic
My commission expires 2nd day of July 2005.

36 0.038
37 0.205
38 0.023
39 0.034
40 0.019
41 0.022
42 0.024
43 0.014
44 0.054
45 0.139
46 0.050
47 0.050
48 0.134
49 0.160
50 0.107
51 0.140
52 0.131
53 0.050
54 0.050
55 0.053
56 0.265
57 0.111
58 0.072
59 0.050
60 0.050
61 0.076
62 0.103
63 0.088
64 0.105
65 0.126
66 0.075
67 0.087
68 0.067
69 0.094
70 0.036
71 0.058
72 0.069
73 0.082
74 0.034
LESST
LESST
LESST
LESST
38.00
205.00
23.00
34.00
19.00
22.00
24.00
14.00
54.00
139.00
50.00
50.00
134.00
160.00
107.00
140.00
131.00
25.00
25.00
53.00
265.00
111.00
72.00
25.00
25.00
76.00
103.00
88.00
105.00
126.00
75.00
87.00
67.00
94.00
36.00
58.00
69.00
82.00
34.00
Page 2

Facility Name =
Raleigh WTP
NPDES # =
NCO082376
Qw (MGD) =
4
7QIOs (cfs)=
0
IWC (%) =
100.00
FINAL RESULTS
Aluminum
Max. Pred Cw 7314.9 ug/1
Allowable Cw 87.0 ug/l
RESULTS
Std Dev.
303.2804
Mean
110.3
C.V.
2.7493
Number
of data points
112
Mult Factor =
2.32
Max. Value
3150.0
µg/1
Max. Pred Cw
7314.9
µg/l
Allowable Cw
87.0
µg/l
Entered by S. Wilson
Data from 1/2001 to 2/2003
Actual values in mg/l
NOTE: There is no state water quality standard for Aluminum.
Aluminum is a ubiquitous parameter in this state and it cleaves to
NC's clay soils. It is not considered a parameter of concern.
There is a federal criteria for Aluminum (only under certain pH
conditions). This is only presented for comparison purposes.
Parameter = Aluminum
Standard = 870 µgll • .
Date n <
Actual Data
BDL=1/2DL
1
0.170
170.00
2
0.400
400.00
3
0.030
30.00
4
0.050
50.00
5
0.050
50.00
6
0.060
60.00
7
0.050
50.00
8
0.100
100.00
9
0.040
40.00
10
0.110
110.00
11
0.150
150.00
12
0.150
150.00
13
0.060
60.00
14
0.025
25.00
15
0.030
30.00
16
0.060
60.00
17
0.040
40.00
18
0.010
10.00
19
0.010
10.00
20
0.050
50.00
21
0.020
20.00
22
0.020
20.00
23
0.010 LESST
5.00
24
0.020
20.00
25
0.010 LESST
5.00
26
0.034
34.00
27
0.025
25.00
28
0.020
20.00
29
0.032
32.00
30
0.018
18.00
31
0.020
20.00
32
0.020
20.00
33
0.020
20.00
34
0.010
10.00
35
0.038
38.00
Page 1

75 0.036
76 0.023
77 0.023
78 0.046
79 0.067
80 0.330
81 0.049
82 0.029
83 0.059
84 0.159
85 0.132
86 0.106
87 0.120
88 0.010
89 0.016
90 0.049
91 0.265
92 0.234
93 0.312
94 0.472
95 0.394
96 0.050
97 0.364
98 0.080
99 0.085
100 0.050
101 0.050
102 0.084
103 0.070
104 3.150
105 0.050
106 0.050
107 0.050
108 0.050
109 0.091
110 0.078
111 0.092
112 0.158
LESST
LESST
LESST
LESST
LESST
LESST
LESST
36.00
23.00
23.00
46.00
67.00
330.00
49.00
29.00
59.00
159.00
132.00
106.00
120.00
10.00
16.00
49.00
265.00
234.00
312.00
472.00
394.00
25.00
364.00
80.00
85.00
25.00
25.00
84.00
70.00
3150.00
25.00
25.00
25.00
25.00
91.00
78.00
92.00
158.00
Page 3

Facility Name =
Raleigh WTP
NPDES # =
NCO082376
Qw (MGD) =
4
7QIOs (cfs)=
0
IWC (%) =
i 100.00
FINAL RESULTS
Iron
Max. Pred Cw 46.7 mg/I
Allowable Cw 1.0 1
mg/I
RESULTS
Std Dev. 5.1892
Mean 4.7
C.V. 1.0957
Number
of data points 112
Mult Factor
Max. Value 28.0 mg/1
Max. Pred Cw 46.7 mg/1
Allowable Cw 1.0 mg/l
Entered by S. Wilson
Data from 1/2001 to 2/2003
Actual values in mg/l
NOTE: Iron is an Action Level NC water quality standard.
No limit will be implemented at this time.
(A procedure is in place to implement action level standards
as limits - more monitoring data related to toxicity testing is
necessary)
Parameter = Iron
Standard = 'f'1'0 ,,Ez! mg/l
Date n < Actual Data
BDL=1/2DL
1
10.9
10.90
2
28.
28.00
3
1.06
1.06
4
.92
0.92
5
1.6
1.60
6
1.58
1.58
7
1.19
1.19
8
3.6
3.60
9
1.03
1.03
10
1.74
1.74
11
1.74
1.74
12
9.24
9.24
13
2.49
2.49
14
.482
0.48
15
1.401
1.40
16
2.612
2.61
17
1.514
1.51
18
.373
0.37
19
.37
0.37
20
.571
0.57
21
.646
0.65
22
.95
0.95
23
.69
0.69
24
2.09
2.09
25
.59
0.59
26
1.26
1.26
27
1.2
1.20
28
2.32
2.32
29
1.39
1.39
30
0.94
0.94
31
.58
0.58
32
.4
0.40
33
.48
0.48
34
.36
0.36
35
2.34
2.34
Page 1

36
2.41
2.41
37
2.06
2.06
38
0.93
0.93
39
4.97
4.97
40
2.99
2.99
41
3.32
3.32
42
2.34
2.34
43
3.38
3.38
44
9.63
9.63
45
22
22.00
46
10.5
10.50
47
10.9
10.90
48
1.68
1.68
49
4.08
4.08
50
4.8
4.80
51
3.37
3.37
52
3.46
3.46
53
5.01
5.01
54
3.42
3.42
55
5.23
5.23
56
11.5
11.50
57
5.01
5.01
58
3.67
3.67
59
2.02
2.02
60
4.68
4.68
61
22.80
22.80
62
13.80
13.80
63
9.26
9.26
64
12.70
12.70
65
13.20
13.20
66
6.06
6.06
67
15.40
15.40
68
7.67
7.67
69
14.70
14.70
70
7.33
7.33
71
8.09
8.09
72
10.23
10.23
73
11.00
11.00
74
9.37
9.37
Page 2

75
3.91
3.91
76
3.93
3.93
77
3.25
3.25
78
3.72
3.72
79
4.79
4.79
80
18.33
18.33
81
7.62
7.62
82
2.65
2.65
83
1.76
1.76
84
6.58
6.58
85
6.65
6.65
86
8.25
8.25
87
1.99
1.99
88
1.09
1.09
89
2.49
2.49
90
3.93
3.93
91
3.88
3.88
92
4.67
4.67
93
5.17
5.17
94
7.77
7.77
95
16.60
16.60
96
0.97
0.97
97
1.54
1.54
98
2.19
2.19
99
3.65
3.65
100
0.51
0.51
101
0.57
0.57
102
2.52
2.52
103
1.43
1.43
104
3.13
3.13
105
0.76
0.76
106
0.72
0.72
107
1.19
1.19
108
1.93
1.93
109
2.00
2.00
110
1.05
1.05
111
0.81
0.81
112
2.83
2.83
Page 3

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State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
Alan W. Klimek, P.E., Director
April 25, 2003
MEMORANDUM
To: Michael L. Douglas
NC DENR / DEH / Regional Engineer
Raleigh Regional Office
From: Susan Wilson
NPDES Unit
Subject: Review of Draft NPDES Permit NCO082376
City of Raleigh - E. M. Johnson WTP
Wake County
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Please indicate below your agency's position or viewpoint on the draft permit and return this form by May 26,
2003. If you have any questions on the draft permit, please contact me at the telephone number or e-mail
address listed at the bottom of this page.
RESPONSE: (Check one)
Concur with the issuance of this permit provided the facility is operated and maintained properly, the stated
effluent limits are met prior to discharge, and the discharge does not contravene the designated water quality
standards.
❑ Concurs with issuance of the above permit, provided the following conditions are met
❑ Opposes the issuance of the above permit, based on reasons stated below, or attached:
L/ / /- t�AfP'✓
1617 Mail Service Center, Raleigh, North Carolina 27699.1617 919 733-5083, extension 510 (fax) 919 733-0719
VISIT US ON THE INTERNET0hitpJ/h2o.enr.state.nc.us1NPDES [e-mail]

City Of q�aleigh
-Worth earohna
April 24, 2003
Ms. Susan Wilson
NCDENR
Division of Water Quality
NPDES Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Re: City of Raleigh E.M. Johnson WTP
NPDES Permit NCO082376 Renewal
Dear Ms. Wilson:
The City of Raleigh has applied for a permit amendment / modification to its current
non -discharge permit (Permit No. WQ0008431) for the sludge disposal facility at the
E.M. Johnson Water Treatment Plant (WTP). In the process of the review by the
DWQ Non -Discharge Permitting Unit, several issues were raised regarding the
NPDES permit for the water plant residuals treatment facilities at the E.M. Johnson
WTP (Permit No. NC0082376), and the process units listed in the NPDES permit
supplement to the permit cover page (See March 7, 2003 letter from Shannon Mohr
Thornburg attached). Based on the comments by the Non -Discharge Permitting Unit,
the following changes to the NPDES permit are recommended:
• Change the "dual (north and south) settling basins listed in the supplement
to the permit cover page to the "two backwash clarifiers".
• Clarify that the "sludge basin" listed in the supplement to the permit cover
page (also referred to as the "sludge lagoon" in the materials submitted with
the NPDES permit renewal) is the "sludge disposal facility" covered by the
non -discharge permit (Permit No. WQ0008431).
• Clarify that the "sludge pumps" listed in the supplement to the permit cover
page include both the thickened sludge pumps and the belt filter press feed
pumps.
• Add the belt filter press washwater pumps to the supplement to the permit
cover page.
• Add the belt conveyors to the supplement to the permit cover page.
• Change the "sand drying beds" in the supplement to the permit cover page
to the "sand drying beds/containment pad". The containment pad was

Ms. Susan Wilson
Page 2
April 24, 2003
constructed by removing the divider wall between two drying beds and
replacing the sand with a concrete slab. Seven drying beds remain in the
row of drying beds next to the containment pad, and eight drying beds
remain in the other set of drying beds, for a total of 15 drying beds. For the
group of eight drying beds, three drying beds are currently used for filtering
of decant water from the sludge disposal facility. Also, one former sand
drying bed is used for an emergency spill containment basin to capture an
accidental release of the chemicals used at the water plant for potable water
treatment. Figure 1, which shows the process flow schematic for the
residuals treatment system, as it has been revised to show the current
operation for the sand drying beds and the sludge disposal facility. A copy
of the revised Figure 1 is attached.
The City would like the above items considered and included in drafting the renewal
of the NPDES permit for the E.M. Johnson WTP, currently being processed by the
NPDES Unit. If you need any additional information on these items, please contact
me (890-3400) and I or Bob Berndt (833-7152) our consultant at Hazen and Sawyer,
P.C.
We will be happy to meet with you or provide any additional information necessary.
Thank you very much for your assistance.
Sincerely,
wk
H. Dale Crisp .E.
Raleigh Publi Utilities Director
Enclosure
cc: Mr. Robert A. Berndt, P.E.
Ms. Donna Jackson, P.E.
Mr. John Garland
Wilson 04.08.03lte.2

FIGURE 1
1
RAW WATER
FROM PRETREATMENT
RESERVOIRS WATER TREATMENT
FACILITIES
FLOW
SPUTTER
BOX
TSL
SLUDGE
THICKENERS
(3)
TS
THICKENED
SLUDGE TS
PUMP
STATION
I
I
I
I
I
1
1
I
I
r
THICKENED SLUDGE
TO SLUDGE DISPOSAL
FACILITY
(ALTERNATE)
HAZEN AND SAWYER
Environmental Engineers & Scientists
POLYMER — — T SLUDGE
I FROM
SL SEDIMENTATION
TANKS
MANHOLE
NO. 2
--- POLYMER
I
CAUSTIC
TO TO
PARSHALL
FLUME
F
BTD
SLUDGE
BLENDING TS P TS
TANKS
(4)
LEGEND
- FINISHED WATER
BCS BACKWASH
CLARIFIER SLUDGE
BTD BLENDING TANK DECANT
DS DEWATERED
SLUDGE
F FILTRATE
FILTER BACKWASH
SL SLUDGE
TO THICKENER
OVERFLOW
TS THICKENED
SLUDGE
© PUMPS
r — — — — — — — DISCHARGE TO
I OUTFALL 001
I (FUTURE)
I
I
BACKWASH
I
I
I
CLARIFIERS
DISCHARGE TO
(2)
OUTFALL 002
BCS
P TO IRRIGATION
SYSTEM
POLYMER WASHWATER
BELT
FILTER
DS
TRUCK
CONTAINMENT
TRUCK
PRESSES
HAULING
PAD
HAULING
RECYCLE
(3)
TO A CONTRACTOR
F
SAND
DRYING
BEDS
F FILTRATE (8)
PUMP
STATION
UNDERDRAIN NC0082376
THICKENED SLUDGE -
TO SLUDGE DISPOSAL E.M. JOHNSON WTP
FACILITY DECANT FROM
SLUDGE DISPOSAL CITY OF RALEIGH
FACILITY
RESIDUALS TREATMENT SYSTEM
PROCESS FLOW SCHEMATIC

Re: Raleigb WTP
f
Subject: Re: Raleigh WTP
Date: Wed, 23 Apr 2003 13:50:55 -0400
From: Judy Garrett <j udy. garrett @ ncmail .net>
To: Susan A Wilson <susan.a.wilson @ncmail.net>
No enforcements were written last year for this facility. I think we
were going to address the issues causing toxicity in the renewal. The A
to C for dechlorination of the effluent and clearwell leakage was issued
on December 13, 2002. The City had already installed effluent dechlor on
a temporary basis prior to the issuance of the A to C. The chlorine
limits can probably take effect immediately.
Susan A Wilson wrote:
> Judy -
> Was any enforcement action ever taken against Raleigh in the past year
> (esp. re. the benthic issues, etc.)? Or did we agree to just address
> those issues with the permit renewal, etc. (and give them a chance to
> add dechlor)?
> I only saw one LV for them - from 1999. Anything else? Thanks.
1 of 1 4/23/03 2:02 PM

Re: Raleigh WTP treatment units
f
i
w
Subject: Re: Raleigh WTP treatment units
Date: Wed, 23 Apr 2003 13:33:20 -0400
From: Shannon Thornburg <[e-mail]>
Organization: NC DENR DWQ
To: Susan A Wilson <[e-mail]>
The only things that I might suggest adding are:
Sludge feed pump (or do you count as part of the belt filter press units?)
Belt filter press washwater pump (or do you count as part of the belt filter
press units?)
Containment pad (converted sand drying beds in which dewatered residuals are
stored prior to hauling by a contractor) - This may be a definite because
this is where Randy found what appeared to be outlets during our site visit,
which he subsequently requested in writing be plugged or removed.
Otherwise, looks good to me. Go for it!
Shannon
Susan A Wilson wrote:
> hey - here's what i have going in the permit: (oops - dots turned into
> question marks!)
> ? Dual backwash clarifiers
> ? Filtrate pump station
> ? Flow spl i t t er box
> ? Three sludge thickeners
> ? Parshall flume
> ? Polymer and caustic feed systems
> ? Thickened sludge pump station
> (with diversion to blending tanks or sludge disposal facility)
> ? Four sludge blending tanks
> (residuals to sludge disposal facility or filter presses)
> ? Three belt filter presses (drainage to filtrate pump station)
> (truck hauling and concrete pad for residuals)
> ? Sand drying beds (drainage to filtrate pump station)
> I probably need to add in that the sand filters receive decant from the
> sludge disposal facility and need to add dechlor (future).
> I think this is it - your diagram was slightly different than mine - and
> yours was more up-to-date, so i used it.
> Any glaring errors, let me know. I hardly ever get this specific in a
> supplement page (only in an ATC), but thought it was necessary with this
> one. Thanks!
1 of 1 4/23/03 1:38 PM

Re: Raleigh WTP site visit
Subject: Re: Raleigh WTP site visit
Date: Tue, 15 Apr 2003 16:47:23 -0400
From: Shannon Thornburg <[e-mail]>
Organization: NC DENR DWQ
To: Susan A Wilson <[e-mail]>
CC: Shannon Langley <[e-mail]>,
Randy Jones <[e-mail]>
Oh. Sorry about that! I wasn't aware that you knew that we are working on a
permit involving this facility, so I just thought that there was a compliance issue
on the point source side.
We did do a site visit on March 26, 2003. The permitting action that we are
working on involves the permitting of a relocated conveyance pipeline from the
residuals management facilities (most of which are permitted under your permit) to
the surface disposal unit. I've just sent out a draft permit for review and
comment. I have attached a copy to this e-mail for your reference. So, we are
basically done (for now); therefore, I think that I'll pass on this opportunity.
Thanks for asking though! I wish that I had know that y'all were working on the
facility as well, since then you could have tagged along with us.
As an aside, Randy did issue a letter to the City on 03/31/2003 regarding issues
that we noticed during the site visit. Two of these had to do more with your
permitted facilities rather than ours. I sent the carbon copy of the letter that
Randy sent to me down to Central Files in the files for WQ0008431. Check it out!
Shannon
Susan A Wilson wrote:
> No - that was really meant for you. I just recalled you guys were doing some
> work for them and wasn't aware you'd already done a site visit. Haven't
> perused the file well enough yet to know what exactly you guys were doing for
> them!
> But... Shannon Langley - if you'd
> would be interested in going (or
> fine) .
> Shannon Thornburg wrote:
> > Susan,
like to pass this on to Vanessa and see if she
if you're interested in going that would be
> > Did you mean maybe to send Shannon Langley this e-mail?
> > I am working on a permit modification for the E.M. Johnson WTP right now,
> > but Randy and I just performed a site visit a couple of weeks ago. Also, I
> > hopefully should be wrapping my review up as soon as the City reviews a
> > draft of the permit.
> > Have a great weekend!
> > Shannon
> > Susan A Wilson wrote:
> > > Shannon - we're set to go to the WTP on 4116, 1:30 pm, if any of you
> > > guys want to go. We're piggy -backing that with a couple of other site
> > > visits - so if you want to meet us there that's fine. Natalie and I are
> > > going with Boyd DeVane (the hearing officer for the Neuse permits) .
> > > We've let the region know as well.
1 of 2 4/16/03 8:27 AM

\OaOF 1NA7-,( G Michael F. Easley, Governor
William G. Ross Jr., Secretary
� y North Carolina Department of Environment and Natural Resources
r
—1 Alan W. Klimek, P.E., Director
< Division of Water Quality
April 21, 2003
MR. H. DALE CRISP, P.E., PUBLIC UTILITIES DIRECTOR
CITY OF RALEIGH
POST OFFICE BOX 590
RALEIGH, NORTH CAROLINA 27602
Subject: Permit No. W00008431
City of Raleigh
E.M. Johnson Water Treatment Plant
Surface Disposal of Residual Solids (503 Exempt)
Wake County
Dear Mr. Crisp:
In accordance with your permit modification application package received on October 8, 2002 as
well as the additional information received on February 28, 2003 and April 7 2003, we are forwarding
herewith Permit No. W00048431, dated April 2t,'2003, to the City of Raleigh for the continued
operation of modified residuals conveyance facilities and a surface disposal unit at its E.M. Johnson
Water Treatment Plant.
This permit shall be effective from the date of issuance until October 31, 2004; shall void Permit
No. W00008431, issued on February 22, 2000; and shall be subject to the conditions and limitations as
specified therein.
This permit approves the operation of a relocated combination residuals conveyance/supernatant
return pipeline at the surface disposal unit. This pipeline, which used to be installed above -grade, was
relocated below -grade following a notice of violation (NOV) that was issued ,by the Water Quality
Section of the Division of Water Quality's (Division) Raleigh Regional Office on August 23, 2002. No
formal approval was requested or granted by the Division prior to the relocation of the pipeline; however,
it is noted that the City may have thought that, by immediately relocating the pipeline, it was responding
to the Divisions NOV satisfactorily. Please note for future reference, that. operation, alteration,
expansion, and/or change of any residuals facility/management program without a valid permit is a
violation of North Carolina General Statute §143-215.1 and may subject the owner/operator of the
facility/program to enforcement action in accordance with North Carolina General Statute § 143-215.6.
In addition to the approval of the above -referenced modification, significant modifications have
been made to this permit, including the approval of the City of Raleigh's request to remove plant
available nitrogen and sulfate from the list of parameters for which the residuals must be monitored on a
regular basis and a provision to allow future mining of residuals from the surface disposal unit.
Therefore, please take the time to review this permit thoroughly as many of the conditions contained
therein may have been added, changed, or deleted since this permit was last issued. In particular, please
note the following:
Non -Discharge Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
N5ENR
Internet httpJ/h2o.enr.state.nc.us/ndpu
Telephone [phone] Fax [phone]
DENR Customer Service Center
An Equal Opportunity Action Employer
Telephone [phone]
50 % recycled/10% post -consumer paper

♦ This permit allows residuals to be conveyed from the surface disposal unit from three
different points in the residuals management process (i.e., following the residuals blending
tanks, from the residuals clarifiers, or from the thickened residuals pump station).
♦ During a site visit performed by the Division on March 25, 2003, it was noted that the level
gauge that is currently existing to monitor freeboard within the surface disposal unit was not
installed such that freeboard is monitored at a location where the unit's embankment is at its
lowest elevation. Therefore, Condition I. 1. requires that the City of Raleigh relocate the
level gauge within a 90-calendar day period. A certification from a North Carolina -licensed
professional engineer is required to be submitted to serve as proof of compliance with this
requirement.
♦ Condition I. 12. allows relocation of the temporary above -ground residuals distribution
pipeline without prior approval from the Division as long as certain requirements are met.
Note also that special attention to this pipeline is required during the inspections stipulated in
Section V. of this permit.
Pay particular attention to the monitoring requirements in this permit. Failure to establish an
adequate system for collecting and maintaining the required operational information will result in future
compliance problems. Please also make note of this permit's expiration date and the fact that a permit
renewal is due to the Division of Water Quality (Division) no later than six months prior to that date, as
the Division does not send reminders to apply for permit renewal.
If any parts, requirements, or limitations contained in this permit are unacceptable, you have the
right to request an adjudicatory hearing -upon written request within 30-days following receipt of this
permit. This request must be in the form of a written petition, conforming to Chapter 150B of North
Carolina General Statutes, and filed with the Office of Administrative Hearings, 6714 Mail Service
Center, Raleigh, NC 27699-6714. Unless such demands are made, this permit shall be final and binding.
One copy of the Division -approved plans is enclosed herein for your files. If you need any
additional information concerning this matter, please contact Ms. Shannon Mohr Thornburg by telephone
at [phone], extension 353, or via e-mail at [e-mail].
Sincerely,
for Alan W. Klimek, P.E.
Enclosure
cc: Mr. Robert A. Berndt, P.E., Hazen & Sawyer, P.C.
Wake County Health Department
Mr. Tracy E. Davis, P.E., NCDENR-DLR (Land Quality Section/Mining Program)
Central Office -Groundwater Section
Raleigh Regional Office -Water Quality Section
Raleigh Regional Office -Groundwater Section
Technical Assistance and Certification Unit
Water Quality Central Files
NDPU Files
NDPU Residuals Program Coordinator

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
RALEIGH
SURFACE DISPOSAL OF RESIDUAL SOLIDS (503 EXEMPT) PERMIT
In accordance with the provisions of Article 21 of Chapter 143, General Statutes of North Carolina as
amended, and other applicable Laws, Rules, and Regulations
PERMISSION IS HEREBY GRANTED TO
City of Raleigh
Wake County
FOR THE
continued operation of residuals conveyance facilities and a surface disposal unit consisting of the
following minimum components: one XXX-gallon per minute progressive cavity residuals conveyance
pump; one XXX-gallon per minute diesel -powered portable 'supernatant -return pump; approximately
1,419 linear feet of below -ground six-inch p' eline to convey 'I esiduals to the surface disposal unit and
return supernatant from the surface disposal unit for treatment or disposal; a temporary above -ground six-
inch pipeline (i.e., see Condition I. (2.) to dstibue residuals throughout the surface disposal unit; three
3,750-square foot sand filtration beds (i.e., approved to operate under NDPES Permit No. NC0082376)
for the filtration of returned supernatant before its introduction for treatment or disposal; one six -acre
surface disposal unit with a total net capacity of 26 million gallons; as well as all associated piping,
valves, electrical and instrumental/control systems, and other appurtenances necessary to make complete
and functional residuals conveyance facilities and surface disposal unit for the conveyance and disposal of
up to 1,500 dry tons per year of ferric residuals from the City of Raleigh's E.M. Johnson Water Treatment
Plant located at 10301 Falls of the Neuse Road in Raleigh, North Carolina. The normal mode of
operation for the residuals conveyance facilities and surface disposal unit is to convey residuals on an as -
needed (i.e., emergency) basis only, from a point in the residuals management process after the four
25,000-gallon residuals blending tanks (i.e., approved to operate under NDPES Permit No. NC0082376).
Alternate conveyance points that may be used include either directly from the three 50-foot residuals
clarifiers or from the thickened residuals transfer pump station (i.e., contains three 250-gallons per minute
centrifugal pumps). The clarifiers as well as this pump station are approved to operate under NPDES
Permit No. NC0082376).
The activities associated with the residuals conveyance facilities and surface disposal unit shall not result
in a discharge of wastes to surface waters; shall be pursuant to the permit modification application
package received on October 8, 2002 as well as the additional information received on February 28, 2003
and April 7, 2003; and shall be in conformity with the project plans, specifications, and other supporting
data subsequently filed and approved by the Department of Environment and Natural Resources and
considered a part of this permit.

This permit shall be effective from the date of issuance until October 31, 2004; shall void Permit
No. W00008431, issued on February 22, 2000; and shall be subject to the following specified conditions
and limitations:
I. PERFORMANCE STANDARDS
The level gauge currently in the surface disposal unit shall be relocated within 90 calendar
days of the issuance of this permit. The new location shall be selected such that it shall meet
the criteria for monitoring freeboard levels as stipulated in Condition H. 4. Care shall be
taken not to damage the integrity of the unit's liner when installing the gauge. The
certification from the North Carolina -licensed professional engineer required in Condition I.
e. shall serve as proof of compliance with this condition.
2. Within 30 calendar days of completing the level gauge relocation, a certification shall be
received from a North Carolina -licensed professional engineer certifying that the level gauge
has been installed in accordance with this permit. The Permittee shall mail one copy of the
final certification to the NDPU Residuals Program Coordinator, NCDENR-DWQ, Water
Quality Section, Non -Discharge Permitting Unit, 1617 Mail Service Center, Raleigh, NC
27699-1617.
3. The Division of Water Quality (Division) shall be notified in writing at least 90 calendar days
prior to the date that the Permittee desired to initiate mining of residuals from the surface
disposal unit. A formal surface disposal unit mining plan, containing site -specific
information regarding the proposed activities, shall be submitted at that time. The mining
activities shall not proceed until the Division provides written approval of the plan and makes
any modifications to this permit at it deems necessary. Subnufour copies of the surface
disposal unit mining plan to thePU Residuals Program Coordinator, NCDENR-DWQ,
Non -Discharge Permitting Unit. 1617 Mail Service Center, Raleigh, NC 27699-1617.
4. The residuals conveyance facilities and surface disposal unit shall be effectively maintained
and operated as a non -discharge system to prevent the discharge of any wastes resulting from
the operation of the unit.
5. The issuance of this permit shall not relieve the Permittee of the responsibility for damages to
surface waters or groundwater resulting from the operation of the residuals conveyance
facilities and/or surface disposal unit.
6. In the event that the residuals conveyance facilities and/or surface disposal unit are not
operated satisfactorily, including the creation of nuisance conditions, the Permittee shall
cease stabilizing residuals, conveying residuals to the unit, and/or disposing of the residuals
in the unit as appropriate, contact the Water Quality Section of the Division's Raleigh
Regional Office, and take any immediate corrective actions as may be required by the
Division.
No residuals other than those generated by the following residuals source -generating facilities
shall be approved for disposal in the surface disposal unit in accordance with this permit:
Source County Permit Number Maximum Dry Tons per Year
City of Raleigh - E.M. Johnson Water Treatment Plant:
Ferric Residuals Wake PWSS Permit No. 03-92-010 1,500

8. Only residuals that are non -hazardous under the Resource Conservation and Recovery Act
(RCRA) shall be disposed of in the surface disposal unit.
9. The pollutant concentrations in the residuals that will be disposed of in the surface disposal
unit shall not exceed the following Ceiling Concentrations (i.e., dry weight basis):
Parameter
Ceiling Concentration
(milligrams per kilogram)
Arsenic
34
Chromium
220
Nickel
240
10. The surface disposal unit shall have a liner of natural material at least one foot thick that has
been installed and compacted in six-inch layers and meeting a 95-percent standard proctor
dry density and a hydraulic conductivity no greater than 1 x 10-6 centimeters per second or
other lining system deemed by the Division to be acceptable through the issuance of
approved plans and specifications.
11. Level gauges shall be maintained at all times to monitor freeboard levels in the surface
disposal unit.
12. The above -ground six-inch polyvinyl chloride (PVC) pipeline used for distributing the
residuals within the surface disposal unit shall be relocated at any time without prior
notification to or approval from the Division. The distribution pipeline may be constructed
above ground as long as it is placed on the interior embankment of the unit only.
13. Appropriate in ures shall ,be takenAt'o'
c the surface disposal unit
during active use and for the 302 od g t last residuals disposal event.
Such controls may include fencing as g o sign dicating the activities being
conducted at the_huit.- _ `_ ___
14. The following buffer zones shall be maintained:
a. 50 feet between the residuals conveyance facilities and any property line;
b. 400 feet between an active surface disposal unit and any habitable residence;
c. 100 feet between an active surface disposal unit and any public or private water supply
source, all streams classified as WS or B, waters classified as SA or SB and any Class I
or Class II impounded reservoir used as a source of drinking water;
d. 100 feet between an active surface disposal unit and any stream, lake, river, or natural
drainage way;
e. 50 feet between an active surface disposal unit and property lines (if the original permit
was issued with the buffer distance to property line as 100 feet, updated maps must be
submitted and new acreage delineated for the buffer to be reduced);
f. 10 feet between an active surface disposal unit and any interceptor drains or surface water
diversions (upslope);
g. 25 feet between an active surface disposal unit and any interceptor drains or surface water
diversions (downslope); and

II.
It. 25 feet between an active surface disposal unit and any groundwater lowering and surface
drainage ditches.
Some of the buffers specified above may not have been included in previous permits for these
residuals conveyance facilities and this surface disposal unit. These buffers are not intended
to prohibit or prevent modifications that are required by the Division to improve performance
of the existing facilities/unit. These buffers do, however, apply to modifications of the unit.
These buffers do also apply to any expansion or modification of the facilities/unit and apply
in instances in which the sale of property would cause any of the buffers now complied with,
for the facilities/unit, to be violated. The Permittee is advised that any modifications to the
existing facilities/unit shall require a permit modification.
15. The surface disposal unit shall not be located in an unstable area.
16. The surface disposal unit shall not restrict the flow of a base flood.
OPERATION AND MAINTENANCE REQUIREMENTS
The residuals conveyance facilities and the surface disposal unit shall be properly maintained
and operated at all times.
2. Upon classification by the Water Pollution Control System Operators Certification
Commission (WPCSOCC), the Permittee shall designate and employ a certified operator to
be in responsible charge (ORC) and one or more certified operator(s) to be back-up ORC(s)
of the residuals conveyance facilities and surface disposal unit in accordance with 15A
NCAC 8G .0 The ORC, shall visit the facil' ' nd; unit ordance with 15A NCAC
8G .0204 or as Iiecified in this pe6it and `shall cb, ply with Flo her conditions specified in
these rules.
3. A copy of this peiinit shall- be mattnn aine"d- on site when "residuals are being stabilized,
conveyed, and/or disposed of in the surface disposal unit during the life of this permit. A
spill prevention and control plan shall be maintained on site at all times.
4. Freeboard of the surface disposal unit shall not be less than two feet at any time. The
freeboard levels in the unit shall be monitored by an individual level gauge that has readily
visible permanent markings indicating the maximum liquid level at the top of the temporary
liquid storage volume, minimum liquid level at the bottom of the temporary liquid storage
volume, and top of the dam (i.e., at it lowest elevation within the unit) elevations. Freeboard
levels the unit shall be monitored and recorded daily (i.e., excluding weekends and State
holidays).
5. Supernatant from the surface disposal unit shall be collected and returned to the E.M.
Johnson Water Treatment Plant for treatment and disposal as necessary to maintain the
required freeboard.
6. Adequate provisions shall be taken to prevent wind erosion from conveying pollutants or
residuals from the surface disposal unit onto the adjacent property or into any surface waters.
0

Adequate provisions shall be taken to prevent any surface runoff from occurring from the
surface disposal unit. If runoff cannot be prevented, a collection system shall be installed
with the capacity to handle runoff from a 24-hour, 25-year storm event. All collected runoff
shall be disposed in a manner approved by the Division.
8. A protective vegetative cover shall be established and maintained on the embankments of the
surface disposal unit (i.e., outside toe of embankment to maximum liquid level), berms, pipe
runs, erosion control areas, and surface water diversions. Trees, shrubs, and other woody
vegetation shall not be allowed to grow on the unit dikes or embankments. All embankment
areas shall be kept mowed or otherwise controlled and accessible.
9. Food crops, feed crops, and/or fiber crops shall not be grown on the surface disposal unit,
unless approval has been requested and received from the Division.
10. Animals shall not be grazed on the surface disposal unit, unless approval has been requested
and received from the Division.
11. Appropriate measures shall be taken to control public access to the surface disposal unit
during active use and for the 36-month period following closure of the surface disposal unit.
Such controls may include fencing and the posting of signs indicating the activities being
conducted at the unit.
M. MONITORING AND REPORTING REQUIREMENTS
1. Any monitoring (i.e.. including groundwater, surface w to residuals, soil, or plant tissue
analyses) deemednecessary by tit Divi to i rep ec n the environment shall be
established and at acceptable sam ling po edul hall be followed.
2. Residuals generated by the approved residuals-source-gener facility listed in Condition I.
7. shall be analyzed to demonstrate that they are non -hazardous under RCRA annually. A
corrosivity, ignitability, and reactivity analysis as well as a Toxicity Characteristics Leaching
Procedure (TCLP) analysis shall be conducted on residuals generated by each approved
residuals source -generating facility. If residuals generated by a particular residuals source -
generating facility are disposed of in the surface disposal unit at a frequency less than
annually, the analyses shall be required for each disposal event. The results of all analytical
determinations shall be maintained on file by the Permittee for a minimum of five years.

The TCLP analysis shall include the following parameters (i.e., note the regulatory level in
milligrams per liter in parentheses):
Arsenic (5.0)
Barium (100.0)
Benzene (0.5)
Cadmium (1.0)
Carbon tetrachloride (0.5)
Chlordane (0.03)
Chlorobenzene(100.0)
Chloroform (6.0)
Chromium (5.0)
m-Cresol(200.0)
o-Cresol (200.0)
p-Cresol(200.0)
Cresol (200.0)
2,4-D (10.0)
1,4-Dichlorobenzene (7.5) Nitrobenzene (2.0)
1,2-Dichloroethane (0.5)
Pentachlorophenol(100.0)
1, 1 -Dichloroethylene (0.7)
Pyridine (5.0)
2,4-Dinitrotoluene (0.13)
Selenium (1.0)
Endrin (0.02)
Silver (5.0)
Hexachlorobenzene (0.13)
Tetrachloroethylene (0.7)
Heptachlor (and its hydmx;de) (0.008) Toxaphene (0.5)
Hexachloro-1,3-butadiene (0.5)
Trichloroethylene (0.5)
Hexachloroethane (3.0)
2,4,5-Trichlorophenol (400.0)
Lead (5.0)
2,4,6-Trichlorophenol (2.0)
Lindane (0.4)
2,4,5-TP (Silvex) (1.0)
Mercury (0.2)
Vinyl chloride (0.2)
Methoxychlor(10.0)
Methyl ethyl ketone (200.0)
3. A representative analysis shall be conducted on residuals generated by the approved residuals
source -generating facility listed in Condition I. 7. quarterly by the Permittee, and the results
of all analytical determinations shall be maintained on file by the Permittee for a minimum of
five years. The analysis shall include but is not necessarily limited to the following
parameters:
I Arsenic Nickel uH I
4. Laboratory analyses as required by Condition IIL 1., Condition III. 2., Condition III. 3. shall
be performed/gathered on the residuals,as they are to be disposed of in the surface disposal
unit. Furthermore, analytical determinations madepursuant to the monitoring and reporting
requirements of this permit shall-be-irtade by a laboratory -certified by the Division for the
required parameter(s) under 15A NCAC 2H .0800 or 15A NCAC 2H .1100.
5. Proper records shall be maintained by the Permittee tracking all disposal activities associated
with the surface disposal unit. All records shall be kept by the Permittee for a minimum
period of five years from the date of disposal. These records shall include, but shall not
necessarily be limited to, the following information:
a. Date and freeboard level measurements in of the surface disposal unit;
b. Source and date of residuals disposal in or mining from the surface disposal unit;
c. Volume of residuals disposed of in or mined from the surface disposal unit in gallons per
year, dry tons per year, or kilograms per year;
d. Cumulative volume of residuals disposed of in or mined from the surface disposal unit in
gallons or cubic yards (i.e., excluding freeboard);
e. Remaining volume in the surface disposal unit in gallons or cubic yards (i.e., excluding
freeboard); and
f. An estimate of the remaining useful disposal life for the surface disposal unit in years
(i.e., excluding freeboard).

IV.
6. Three copies of all required monitoring and reporting requirements as specified in Condition
III. L, Condition III. 2., Condition III. 3., Condition III. 4., and Condition M. 5. shall be
submitted annually on or before March 1st of the year following the disposal event to the
following address:
NCDENR-DWQ
Water Quality Section
Non -Discharge Compliance/Enforcement Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
7. Noncompliance Notification:
The Permittee shall report by telephone to the Water Quality Section of the Division's
Raleigh Regional Office, telephone number [phone], as soon as possible, but in no
case more than 24 hours or on the next working day following the occurrence or first
knowledge of the occurrence of any of the following:
a. Any occurrence with surface disposal activities that results in the disposal of significant
amounts of wastes that are abnormal in quantity or characteristic.
b. Any failure of the surface disposal activities resulting in a release of material to receiving
waters.
c. Any time that self -monitoring information indicates that the surface disposal unit has
gone out of compliance with the conditions and limitations of this permit or the
parameters on which the system was designed.
d. Any process unit failure, due to known or unknown reasons, that renders the surface
disposal unit incapable of adequate residual treatment:'
e. Any spillage or discharge from a vehicle or piping syst transporting residuals to the
surface disposal unit.
Persons reporting such occurrences by telephone shall also file a written report in letterform
within five days following first knowledge of the occurrence. This report must outline the
actions taken or proposed to be taken to ensure that the problem does not recur.
Applicable Boundaries:
a. The COMPLIANCE BOUNDARY for the surface disposal unit is specified by
regulations in 15A NCAC 2L (i.e., Groundwater Classifications and Standards). The
Compliance Boundary for surface disposal units individually permitted after December
31, 1983, shall be established at either (1) 250 feet from the unit or (2) 50 feet within the
property boundary, whichever is closest to the unit. An exceedance of Groundwater
Quality Standards at or beyond the Compliance Boundary is subject to immediate
remediation action according to 15A NCAC 2L .0106 (d)(2).
b. The REVIEW BOUNDARY shall be established around the surface disposal unit
midway between the Compliance Boundary and the perimeter of the surface disposal
unit. Any exceedance of Groundwater Quality Standards at the Review Boundary shall
require action in accordance with 15A NCAC 2L .0106 (d)(1).

2. Other Requirements:
a. Any additional groundwater quality monitoring, as deemed necessary by the Division,
shall be provided.
V. INSPECTIONS
1. The Permittee or his designee shall inspect the residuals conveyance facilities and/or surface
disposal unit to prevent malfunctions and deterioration, operator errors and discharges which
may cause or lead to the release of wastes to the environment, a threat to human health, or a
nuisance. The Permittee shall maintain an inspection log or summary including at least the
date and time of inspection; observations made; and any maintenance, repairs, or corrective
actions taken by the Permittee. This log of inspections shall be maintained by the Permittee
for a period of five years from the date of the inspection and shall be made available to the
Division or other permitting authority, upon request.
Note that special attention shall be paid by the Permittee to inspection of the above -ground
six-inch PVC pipeline used for distributing the residuals within the surface disposal unit. The
pipeline shall be repaired or replaced immediately at any time that such inspection shows that
the pipeline material has deteriorated such that a leaktrupture has occurred or is imminent.
2. Any duly authorized officer, employee, or representative of the Division may, upon
presentation of credentials, enter and inspect any property, premises, or place on or related to
the residuals conveyance facilities and/or surface disposal unit at any reasonable time for the
purpose of determining compliance with this permit; inspect or copy any records that must be
kept under the terms and conditions of this permit and obtain samples of groundwater,
surface water, or,leachate -
VI. GENERAL CONDITIONS _..__.
A set of all plans and specifications approved by the Division as well as any as -built plans for
the residuals conveyance facilities and surface disposal unit shall be retained by the Permittee
for the life of the facilities/unit.
2. This permit shall become voidable unless the disposal activities are carried out in accordance
with the conditions of this permit, the supporting materials, and in the manner approved by
this Division.
This permit shall be effective only with respect to the nature and volume of wastes described
in the application and other supporting data.
4. This permit shall not be automatically transferable. In the event that there is a desire for the
residuals conveyance facilities and surface disposal unit to change ownership or a name
change of the Permittee, a formal permit request shall be submitted to the Division
accompanied by documentation from the parties involved and other supporting materials as
may be appropriate. The approval of this request shall be considered on its merits and may or
may not be approved.

Failure to abide by the conditions and limitations contained in this permit may subject the
Permittee to an enforcement action by the Division in accordance with North Carolina
General Statutes §143-215.6A through §143-215.6C.
6. The annual administering and compliance fee shall be paid by the Permittee within 30 days
after being billed by the Division. Failure to pay the fee accordingly may cause the Division
to initiate action to revoke this permit as specified by 15 NCAC 211.0205 (c)(4).
7. The issuance of this permit does not preclude the Permittee from complying with any and all
statutes, rules, regulations, or ordinances which may be imposed by other government
agencies (i.e., local, state, and federal) which have jurisdiction, including, but not limited to,
applicable river buffer rules in 15A NCAC 2B .0200, erosion and sedimentation control
requirements in 15A NCAC Chapter 4 and under the Division's General Permit NCG010000,
and any requirements pertaining to wetlands under 15A NCAC 2B .0200 and 15A NCAC 2H
.0500.
8. The Permittee, at least six months prior to the expiration of this permit, shall request its
extension. Upon receipt of the request, the Division shall review the adequacy of the
residuals conveyance facilities and surface disposal unit described therein and, if warranted,
shall extend the permit for such period of time and under such conditions and limitations as it
may deem appropriate.
9. This permit may be modified, or revoked and/or reissued to incorporate any conditions,
limitations, and monitoring requirements the Division deems necessary in order to protect the
environment and public health adequately.
10. The Division shall be notified in writing at least 180 calendar days prior to closing of the
surface disposal unit. A formal closure plan and a post -closure; management care program for
the surface disposal unit shall be submitted at that time. This information shall be specific to
the surface disposal unit as well as. relate ,to the-Permittee's future plans for the land. A
schedule for implementing both the closure plan and the post -closure management care
program shall be provided as well. The Division will accept a submittal that has been
prepared in accordance with the document entitled "Process Design Manual: Surface
Disposal of Sewage Sludge and Domestic Septage (EPA/625/R-95/002)," published by the
United States Environmental Protection Agency's Office of Research and Development.
Submit four copies of all information to the NDPU Residuals Program Coordinator,
NCDENR-DWQ, Non -Discharge Permitting Unit, 1617 Mail Service Center, Raleigh, NC
27699-1617.
Permit issued this the twenty-first day of April, 2003.
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
for Alan W. Klimek, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission
Permit Number W00008431

Permit No. WQ0008431
April 21, 2003
ENGINEER'S CERTIFICATION
Partial Final
I, , as a duly registered Professional Engineer in the State
of North Carolina, having been authorized to observe (periodically, weekly, full time) the construction of
the project,
Project Name
Location and County
for the Permittee, do hereby state that, to the best of my abilities, due care and diligence was used in the
observation of the construction such that the construction was observed to be built within substantial
compliance and intent of this permit, the approved plans and specifications, and other supporting
materials.
Signature
Date
Registration No.
10

City Of 6Paleigh
5Vorth Carolina
April 3, 2003
Wayne Munden PE
Public Water Supply
N. C Division of Environmental Health
1634 Mail Service Center
Raleigh, NC 27699-1634
Subject: Request for Recycling Effluent from the Filter Backwash / Sedimentation Basin Residuals
Treatment Facilities to West Raw Water Reservoir at Raleigh's E.M. Johnson Water Plant
Dear Mr. Munden
Thank you for taking the time to meet with John Garland (our Water Plant Division Superintendent),
Randy Hildebran (our consultant from Arcadis) and I back on December 9, 2002. 1 apologize for the
delay in submitting this request letter to you as we discussed at our meeting.
The City and the N. C. Division of Water Quality (DWQ) began investigating a possible water quality /
effluent issue in the unnamed tributary downstream from the E. M. Johnson Water Treatment Plant last
summer in August. Although this investigation has not produced conclusive results, we are speculating
that the current NPDES discharge of clarified filter backwash / sedimentation basin residual 'Waste
water effluent' from the E. M Johnson WTP is having a negative impact on the diversity of aquatic biota
within this stream.
As a result of these concerns, the City is in the process of installing a chemical feed system for effluent
water dechlorination and pH adjustment, as a part of the E.M. Johnson 'waste water" treatment
system. Before writing this letter to you, I had hoped that we would have completed the installation of
these additional facilities; however, our contractor has not completed the work on the schedule as had
been contracted. I did not wish to wait any longer, before sending you this request letter, since our initial
meeting on this issue was now several months ago. I will notify you when these improvements are
completed which we now expect at the end of April.
We are also investigating several other options for reducing the impact of this effluent discharge on the
receiving stream such as effluent recycling, effluent reuse, relocation of the point of discharge, or
making other modifications to the waste facilities. The option that the City wishes to consider with DEH
as a means of addressing this issue is to restore the previous practice of effluent recycling all or part of
the treated water back to the existing west raw water reservoir. Based on our discussions during the
above referenced meeting, and our review Section 0404(k) of the current Rules Governing Public
Water Supplies, we understand the guidelines for recycling treated supernatant water from the 'Waste
water"facilities to the raw water reservoir are as follows:

• The supernatant should be pumped back to the existing pre -settling reservoir at a rate not to
exceed 10 percent of the daily plant treatment rate.
• The NPDES permit will remain in effect as an alternate means of supernatant disposal.
• The quality of the supernatant will be treated to a quality that will not be detrimental to the
water treatment process as generally indicated by supernatant water quality being equal to or
better than the quality of water being pumped from the Falls Lake. Enclosed is a summary
comparison of the "waste water effluent" water quality compared to the raw water quality of the
water pumped from Falls Lake into the City's raw water reservoir at the head of the plant.
Based on compliance with the guidelines as set forth above, we are hereby requesting approval from
Public Water Supply to resume the practice of recycling, to be performed at the City's discretion at the
E. M Johnson Water Treatment Plant. The City staff would of course notify the DEH regional staff
immediately upon initiating recycle and provide written reports of the amount and quality of "effluent'
that is recycled, if approval is granted to resume recycling.
Please let us know if you need additional information. You can reach John at 870-2870, Randy at 854-
1282 and me at 890-3400. We look forward to your favorable response.
Sincerely,
H. Dale Crisp PE
Raleigh Public Utilities Director
Cc City Manager
Assistant Public Utilities Director
Water Plant Superintendent
Randy Hildebran, P.E. - Arcadis

y
EMJ Water Plant Laboratory
NPDES EFF
Falls Lake
NPDES EFF
Falls Lake
NPDES EFF
Falls Lake
NPDES EFF
Falls Lake
NPDES EFF
Falls Lake
NPDES EFF
Falls Lake
Date
2002
pH
units
pH
units
Aluminum
Mg/1
Aluminum
Mflfi
Iron
m /l
Iron
MU/1
Total
Nitrogen
m /l
Total
Nitrogen
Mg/1
Total
Phosophous
m /1
Total
Phosophous
m 4
Total
Suspend Solids
m 4
Total
Suspend Solids
m /l
January
6.78
6.58
0.11
0.135
5.4
0.347
8
Februa
6.49
6.86
0.071
0.07
4.3
0.387
4
March
6.53
6.7
0.135
0.07
3.5
0.203
0.75
0.76
<0.05
0.043
4
April
6.55
6.79
0.073
0.03
13.3
0.257
26
May
6.7
7.54
0.023
0.02
3.4
0.152
9
June
6.6
6.72
0.076
0.02
1.94
0.19
1.44
0.75
<0.05
0.03
7
8
July
6.74
6.78
0.018
0.05
0.46
0.04
3
August
6.82
7.18
0.026
0.04
1.42
0.08
3
September
6.48
6.64
0.01
0.006
1.08
0.118
5
October
6.95
NA
0.02
NA
0.7
NA
2.5
0.91
<0.025
0.053
4
6
November
6.81
6.721
0.0391
0.22
1.5
0.53
2.86
0.82
<0.05
0.043
7
December
6.87
6.87
0.12
0.2
3.8
0.566
1
1
11

City of Raleigh - E.M. Johnson WTP Alum Sludge Handling Facilities IqVzw 0—P
/U4f4
From: Shannon Thornburg <shannonahornburg tilnemail.net> Thu 5:34 Pitil
Subject: City of Raleigh - F..M. Johnson WTP Alum Sludge Handling Fac lities._a
To: Charlcs Weaver <[e-mail]>, Tony Chen <Tony.Chen@ncmaiLnet>
CC: Randy Jones <[e-mail]>
Charles and Tony,
We are working on a modification to Permit No. WQ0008431, which covers
the operation of a surface disposal unit for the disposal, on an
emergency basis only, of alum sludge generated at the E.M. Johnson WTP.
One of the issues that I was trying to address during this review is
under what permit the various unit processes involved with management of
the alum sludge are approved for construction/operation. The City has
provided me with a process flow diagram and a list of the unit processes
and a statement as to which permit the unit processes are covered. In
reviewing this information, it does not seem quite accurate. Can the
both of you either e-mail me or fax me the most -recent issuance of your
permits (NPDES Permit No. NC0082376 and PWSS ID No. 03-92-010) for this
facility to me so that I can compare what I am being told to reality?
Just for your information, here is a list of the alum sludge management
unit processes and under what permit the City has told me their
operation is approved:
* For alum sludge from sedimentation tanks to hauling:
- Flow splitter box
- 3 gravity thickeners (NPDES)
- thickened sludge pump station w/ 3 transfer pumps (NPDES)
- 4 sludge blending tanks (NPDES)
- 3 belt filter press sludge feed pumps (NPDES)
- 3 polymer feed pumps (NPDES)
- 3 belt filter presses (NPDES)
- 3 belt filter press washwater pumps (NPDES)
- belt conveyor (non -discharge... NOT TRUE, per our permit)
- containment pad (NPDES)
* For alum sludge sent to surface disposal unit (from either the
thickened sludge pump station or following the sludge blending tanks):
- transfer pump and force main (proposed for non -discharge)
- surface disposal unit (non -discharge)
- 8 sand drying beds (non -discharge... NOT TRUE, per our permit)
- filtrate pump station w/ two pumps (NPDES)
* For filter backwash and gravity thickener overflow:
- parshall flume w/ chemical addition (NPDES)
- 2 clarifiers (NPDES)
- discharge line to outfall (NPDES)
From what I have been told internally, the NPDES permit only covers the
actual discharge to the outfall and that the PWSS approvals covers the
operation of the unit processes. Tony called me a minute ago and
suggested that we ask for specific approval numbers so that he can check
it against their approved plans to see if everything is covered.
Thanks for any assistance that you may be able to provide,
Shannon
J �V'� k_ I �A J �' " - 9 4 4
I of 1 6V
3/7/2003 7:53 AM

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Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
March 17. 20031
MR. H. DALE CRISP. P.E., PUBLIC UTILITIES DIRECTOR
CITY OF RALEIGH
POST OFFICE BOX 590
RALEIGH. NORTH CAROLINA 27602
Dear Mr. Crisp:
Alan W. Klimek, P.E., Director
Division, of Water Quality
Subject: Application No. 'AIQ00084 31
Additional Information Request II
Cite of Raleigh
E.M. Johnson 'dater Treatment Plant
Surface Disposal of Residual Solids (501 Exempt)
Vdake County
The Division of 'Water Quality's (Division) Non -Discharge Permitting Unit has completed a
technical review of the additional information received on February, 28. 2003 in support of the subject
PA modification application package. At this time. additional information is required before we may
continue our review. Note that a detailed technical revie,,N- of the package has not yet been completed by
the 'dater Quality Section of the Division's Raleigh Regional Office. Therefore, additional requests for
information may be necessary to address any comments generated by that review. However, please
address the following items no later than April 7, 2003:
A✓1. There is still confusion as to under what approval document the various unit processes
associated with alum residuals management are covered. Therefore. please address the
following items:
014 ✓+ The submitted information states that the belt conveyor from the three belt filter presses
as well as the containment pad are permitted to operate under the non -discharge permit.
From a review of the existing permit, which was issued on February 22, 2000. this unit
process is not listed in the description of the approved facilities.
✓� The submitted information states that the eight sand filter beds are permitted to operate
under the non -discharge permit. From a review of the existing permit. which was issued
on February 22, 2000, this unit process is not listed in the description of the approved
facilities. Note. however, that this unit process is listed in the supplement to th Tee
t
cover page for the current NPDES permit. in C. 106 t c� u t? r 3 e aS
v 3cd, lror • C ct ; c� 44 e d�e C X -1 � c) &4-erg
e ✓� The submitted information states that the remaining un t processes are permitted to
operate under the NPDES permit. In reviewing the supplement to the permit cover page
for the current NPDES permit, the following items are noted:
✓ The supplement lists "dual (north and south) settling basins." Are these the same as
the two clarifiers discussed in the submitted information? yes
� '� ✓ The supplement lists a "sludge basin." To what unit process does this refer? GDO
NMENR
Non -Discharge Permitting Unit Internet http://h2o.enr.state.nc.us/ndpu
1617 Mail Service Center, Raleigh, NC 27699-1617 Telephone [phone] Fax [phone]
DENR Customer Service Center Telephone [phone]
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PV✓ The supplement lists "sludge pumps." Do this refer to the thickened sludge
transfer pumps, the belt filter feed pumps, or oth
✓ ✓ The supplement does not list the belt filter press washwater pumps. 66001d bL
You may want to request a minor modification of the NPDES permit so that you all unit
GK processes associated with residuals management (i.e.. other than those listed below) are
approved for continued operation accordingly:
014'4 The Division suggests that the non -discharge permit be drafted to approve the operation
of the one progressive cavity W4m residuals transfer pump, the six-inch4thm residuals
transfer/decant water return pipeline, the six-inch ??? pipeline (i.e., see Item No. 5), the
surface disposal unit, and the diesel -powered portble decant water return pump only.
Please verify that you concur with this approach. INC r eS, d&nztQ .
p Tmation e1."70
I The following item included in the January 3, 2003 additional inrequest was not
addressed adequately:
aV-✓ ♦ Item 111.4. on Page 2 of 9 of the submitted application form states that a maximum of 26
dry tons per year of residuals are disposed of in the surface disposal unit. From a review
of the submitted annual reports, the volume of residuals disposed of in the unit has ranged
from approximately 253 dry tons per year to 1,317 dry tons per year. Please clarify this
apparent discrepancy. Note that the Division needs a conservative estimate of this
maximum volume in order to draft the modified hermit nronerly.
Based on historical data, the Division suggests that ,500 dry tors per year a set as the
maximum volume that may bt1 sed of in the su ace isposa unit. lease verify that
you concur with this value.
i�✓3. The Division understands that the alum residuals transfer pump is 'a progressive cavity pump
located near the filter backwash clarifiers. Please verify that there is only one pump, and
comment on the issue of reliability accordingly. ►: �e� cs5d s 1 &..ep
1K✓4. The process flow diagram that was prepared by Hazen & Sawyer, P.C. shows that alum
residuals may be transferred to the surface disposal from a location that is alternate from the
one described in Item No. 3 above. Specifically, the alum residuals may be pumped from the
thickened sludge pump station. Please explain how this is achieved (i.e., using one of the
three centrifugal pumps and what pipeline?).
d/ . Sheet No. G1, entitled "Sludge Facility Force Main OeneraI-Plan and Profile" that was
prepared by Hazen & Sawyer, P.C. shows an above -ground six-inch polyvinyl chloride
(PVC) pipeline. This pipeline connects between the recently -installed six-inch alum residuals
transfer/decant water return pipeline and the surface disposal unit. Please explain the
function of this pipeline in the overall residuals management program. In addition, clarify
whether or not there are any plans and associated time schedule to bury this pipeline, as the
Division does not typically allow above -ground PVC pipe installations. A.bd N d' lions, V
S r d 5.
a 6. The Division is enclosing a copy of the acknowledged certification for your records. No 4r Ou-M
action is required to address this item. r S
2

t
7. As was requested in the, January 3, 2003 additional information request, please provide a .
copy of the drawing entitled "Site Plan" that was prepared by Hazen & 'Sawyer, P.C. that has
been signed, sealed, and dated by a North Carolina -licensed professional engineer. This plan,
along with Drawing No. Gl, will be stamped approved by the Division and returned to you to
retain on file for the life of the surface disposal unit.
Please reference the subject permitARplication number,when providing the requested information.
Three copies of all revised information should be submitted to my attention at the address on the first
page of this correspondence.
Be aware that you are responsible for meeting all requirements set forth in North Carolina rules
and regulations. Any oversights that occurred in the review of this application package are still the
responsibility of the applicant. In addition, any omissions made in responding to the requested additional
information items may result in future additional information requests and delays in the issuance of a final
permit. Therefore, read each additional information item carefully, and provide the information that is
requested as well as any information that results from changes made as a result of this additional
information request. If there is any question about what information is being requested or is desired.
please do not hesitate to contact me at any time at [phone], extension 353, or at
[e-mail], and I will be happy to provide additional explanation as required.
Thank you in advance for your cooperation and assistance.
rely,eonnn Mohr Thornburg
Environmental Engineer
Enclosure
cc: Mr. Robert A. Berndt, P.E., Hazen & Sawyer, P.C.
Mr. Randy Jones, Raleigh Regional Office - Water Quality Section
Permit File WQ0008431
3

NCDENR
NQKm (;wOUr 06PAHfM OF
ENMROHMr MO NallRAL He OURC�
NEW I" IALIN& ADDRE55:
Raleigh Regional Office
Department of Ernvlrorirrent
and Natural Resources
1626 Hall Service Center
Raleigh, NC 27099-1028
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moiling oddre5a)
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Raleigh, NC 27009
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FROM: (201leydoa
5U6JEC7: l AI_flac , WTP ` DATE: �I' 11 �Z—
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Divislon of Water Quality
Aqualic roxlcology Unit
November 18, 2002
M N_N1(71ZAN,()Sl
To: Ken Schuster
DWQ Supervisor, RRO
Through: Jimmie Overton
Ntanch !lead, F.nvirotlmenlal Science Brunch
i+rom: Sandy Mort /. R
flnvimnmcnhi l3iolagiat, Aqaalic Toxicology Unit
Subject: Review of Analytical Data, lZnleigil WTP
Sty„iuy
AIV reVIOW4d analytical diva from black prccipilalc nlata•111 scr.,ped from rocks
downstrcam of the Raleigh WTI' riper backwasli discharge point, and walor column samples
WWII upstream and downstream of the sail:$ discharge. Iilgh conconh•ations of "tomal"
Inclal$ wore found ill the black precipitate, at Iovel4 When present ill a bioavailable form,
adequate In potenitally cause ecological cffeels to fnshwater botmhie organlsnls in u sediment
exposure SCUq;a'io. As °total' metal levels do not represent bionvallable Imis, the actual
toxicity of this nt:deritil to sediment orgnni..iins Cannot be assessed with this data. To proVjdo
Lill tlsvuss,ncnl of water column bionvuilability urlhe pivcipltalo mciols 2-day old
Cer'fodnplwin clubm ware exposed at ATU to the black precipitate. over a 46-hour period,
With Ito acute toxicity effects observed, Purther mnly:ala and toxicity testing may provldc a
inom tlticqualo LlSesslilcnt o7 potential ecelng(cal effect$. Water column duta wits compared
to NC WQS and NAWQC, Witter column data indicntod rive total metal coneenwations
incruntiM dgwimirealn of the discharge. while three were lower. The downstream mringancsc
Ievel ilicTeilsed by>21 t1mC5 LIpS11-MI1111CV013, and was detected ut downstream levels
potentially ctlpable or dating ohronic toxicity to aqundc organisms, it present In a
bioavaiiahlo form. Magnesium and barium were both present at levels of potential chronic )r me.11Zo
tuxicily, hoth up.wea n and downstream. Altultinum was present at potentially toxic levels q , t"
upstiratn only, Although mulilple metals were Identified in the black precipitate and the %DO
wrter colunin exceeding levels with the potential to cause toxicity effects to aquatic
organisms tllo biouval►ability of the metals, and thus The ulgmatc toxicity, was not asaossed. pt
Changes to the chomistry of the aquatic system may arlbct bivavnilabiltly and thus polcnlial
toxicity of Iha Lleteeted mclnls,
PJ'. gti; pirnl
KV was psked to reviow two sets of analytical data collected front 11w Hilleigh WTI' slle
ware submitted to A'T LI for reyipw. One set was lnctal and orgnnlc data nil it black
procipilota found i ivoring tank$ in the mcelying stiaain downstream of the WTY's filter
NO d 810 ICS 61618.L
OM MI]ON
IZ:H (Rn1)l0,6l-'ICON

backwash cliychallp. '1'Ilo second set of data was writer column irnutal,s cIeltz CQ1k+CtCd1'iUtr
the ,S411lu ruk.46 i 19 sticartf, Upstream and downstrenrn or the W1`P's titter buckwnsit
C1i rch at'gu,
DOW for 19 metals wcm repoilcd for the black precipitate H11, IysiS, 13Iscci on reported
analytic tail data the 19 Meths coMprisad 3.1% of the Inatedal. To provide sonic indicaliotl of
the potcnLlal ecolc,ricnl effects of Elks material the individual tnetal conecntt-ntions were
compared to scein,e,tt toxicity bench marks C1'13) roulinely used by ATU for cedlorlcal risk
a�sicss�mcm. A peat deal of uncertainty Qxists ill tllia atlalysia as sediment toxicity
hurichnarirkg arclutcnded to assess the potential ecological effect& of benthic orgsili9sils
LApoked to a sediment envixorinicnt. Toxicity i,5 olso a function of bloavaliftbility. If the
0"'lyOU11 4 QC the mtltedril evaltirttcd arc not bioavailablo to the ucit adc biota, then toxicity
will not l,je e-Vic1t:11t, C;onlpndson to sediment Us indicated Lbat Sevc:lal metals were prosent
-it lcvcls Potentially adequato to crctiise prahn1110 ccolaglcal wffects, presunihig they iirc in a
111oavailable forni, these include lion, manganesc, aild nickol. Cadmium, mercury and zinc
were ;1190 presort at crnce:ltrt1tiorls or potanlinl thivshold c;rtects. Table I lists rcportcrl ltto[Al
conec:utrations for the black precipitate add sediment THs used for tho evaluation. 11n7.arci
quotient ([IQ) analysis w:1S used for tho ct)tnpurisolis (TIQ jnic1n11/T6). HQs > 1.0 indlcato
lire t�c�tcllli�ll ft r tnxiCity, wltL'n the C1hc,�ble
Icat is Presont in a biomYe�ilararm, HQs for
Chum''s or compounds naling by the satna t0xichY mar-hullism, or ucting on tho Samc Largat
organ, (nay b1: stlrritned to cvahinte colnbined orlacis. X11Qs arks calculcited for the cl;�lrt,
C011SON-tll;-110secl haznrd quotients (McUoticld, Ingersoll and,13ergur, 2000) wcrc used as the
primary source of sadimatit. T13s for comparison. Those volues cite a complintion or acciilncnt
0711Ly Zuidolhio-q from nihltii3le sources, grouped into n consarvtttivc T.0 (T73C, threshold
affeot conCenlrations balow which haLi-rif it affects on sediment -dwelling
ori;:inismS are ilot onlected) and less conservadve'I'lls (p8cp probabio affaet conventrgtions,
comenlrutin. ns ilb()vc Which ha,1711fu1 effects would be expoeted). Semi-vn;;itilo organic
aimly4Ia daw MIS Uit-rc nark ablt:, with two tiilitlentifled cclmpaunds detected.
To cvaluaLe the. bio;tvill 461lity of the metals in the block precipitate npproximntely 2.t1gy old
Cr. riodapluila dubla WeVe exposed in two titAltnelit sceller•IQs. Rocks covarud wish the
jlr,rc,lpitfftc 11ild l7r•ecip(tttto scraped off Of the rocks wel-a preparegi In 2 t2•etit MAA in non -toxic
stirfilce Miter Mutitiely used by ATU for toxicity testing. The, orgtuiisins were monitored for
m0041hy 1111d sub -lethal orfects for 48-houns. No atonality wa,s obscrved, and reproduction
wills noted in both lruattnents over the obiervadon period. Although older than organisms
MIL11111Cly usccifor toxicity testilig, and thug p ieiititilly, tzot as sensitive, the Jack orobservcd
crt'cci ts would ndicaw th;lL antler thL, 48-huur exposure scellarlo the metals were not prosont
A Icvcls VINS1119 mute toxtCity. CAC pH r,r the ireatnienul WCrc t pproxInintely 71 Ambient
V11 lcvols lower than this level niny sign!l'Ictrnlly ill== LIM 10,KiClty of soma metals.)
TI10 up frown elatd clowngtroorn w jrtct- coltunrl sainples were also compared to toxicity
bunc:ltntnrk.4, inc hiding NC DWQ ficghwatcr Standards for aquatic lira, Ind U.ShJ'A NAWQC
:Ictd Tir.rtl(&ecurlt�lcuy'1 HS, wlicr� PWQ vrlluoa wcrc nQt��vailablc.� (NAWQC: wcrc adatls(ecl
for site-sl1aali'Ict hue dn�sti ,curl convatjt;d f"ic71jj dt,ssolvccl to tvttll cancGntralIons using
reforeneed conversion fnetons) Sdverril clownstrc=irn mr:t., conecntrativns wC .0 cicvtllcd OYci•
the unctrn1111 V,llcies, iliC'Lidlns copper, c"Icitrrn,111agnesiam, mang.11io5c:, and sodium,
MagT)011111, m.-inganese, and bnriul)l wore 131rsent .it levels in the c owrintreani stini )lu (hilt
09eacxtrcl Lhe rererenectl TB.q. AluMInum, niagnogiuni and badurn exc eccleci their T13 In Lhc
Alvirtwinsfiral Sriolees 1)rolic(1 11alviell nP darn, pace 2 Water Quality 3crr/ni1
HO 'd 810 13 616:191 ONE MGM IN1 (M) za ,61- UN

tipaIr"'mm samples, Downstroom M4111juncso levels wcrc >21 times upstrouM 14Yels and
graintiy e.x. crdaLl the uvcilhiblc clircmlo T13, Wslor col"I'll, data and PrIls arc lislctl In T.-Iblc 2,
Aunc,hnionts
cc: Mutt Mii(thews, ATU
Nicely It;tyol RRO
POO 'd 810 i! S 6I6:931 M NN30ON ZN i (3(ls) ZO ,61- 'AON

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T" 1. Raleigh MW black IpmeWitate conceaftwdoas-eraluared vs. freshwater sediment TBs.
IISEPA
black PFt
COnsensuS-
Cubseasns-
Item, i�
Raleigh
based TEC
based PEC
effects
UISEPA Reg.
coampouad
WTP, mg/kg
TEC SQs
PEC HQs
i20011}
(2000)
value
IIuMfDu=
11000
0.19
arsenic, gal
0.5
0.06
0.02
9.79
33.0
7.24
i .24
crviiium
<2.0
cadndum
1.8
1.92
4.36
d
4.98
0.676
1
caJ�,0au
c8romiarn- (Graf
6.4
0.15
0.06
43.4
1 I1
52.3
523
cobak
270
copper
26
0.82
4.;7
31.6
149
18.7irm
18.7
77.000
3.85,
1.93
lead
3.8
011
0.03
35.8
128
302
30
httimm
iz
Mag sium
1200
rrr:'t ac�acz
240.1090
521-74
216M
rrwxcur%'
0.22
1.22)
0.21
0.119
1.06
013
0.13
ckeI
17
7.49
3.50
7
48.6
I5.90
159
sereFi=
0.
Diver
<0.22
0.733
2
sodium
430
zia-
170
1.40
037
121
459
124
124
SUAIQs
539 Z2I
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NCDENR
JAMES B. HUNT JR.
GOVERNOR
BILL HOLMAN
SECRETARY
COLEEN H. SULLINS
CHAIRMAN
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
votes-
pur Wee"
o�.
$&r
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WATER POLLUTION CONTROL SYSTEM OPERATORS CERTIFICATION COMMISSION
1618 MAIL SERVICE CENTER, RALEIGH, NORTH CAROLINA 27699-1618
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/10% POST -CONSUMER PAPER

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Table?. Ra]ni�h:lTE' ralerculualnanefaIsdata. C'ustrearnauddrarn irramvraters.arunle,.dawrtaturted4R6J02
tu:9ai
RTY
ap;lreau>,
ugJL
11'T1'
dunTls[rcanl,
ur L
NVD`.t'Q
heslnvaler
C('['. u_ L_
1.utc
(CWQ
\ 1ll'QC, .
m1 J1_ (1 }
Cisua::
((ITI
\:al'(lt:,
uG'i . f [)
USEPA Tier
fI
Srcurldan
Acerle "ll!,
ogR.
I USLM Ver
![I $CCJBd3:j
C}a wuc'lll,
UL!I-
►F[i'
ups[reaar
chrm is IIQ
►YTP
dom scream
chronic HQ
Cr
<251
<25
60'_
29
Cu
3.81
5.9
_
7 AL
4.0
3_ii
U34
R8i
N,
<10
<10
151
16.I
-Pb
<10
<10
10
0.58
_
Za
<10
<10
38.5
38.5
As
<5.0
<5.4
0.4!
NA
Al
98
53
Si
_
1.13
0.61
Be
<I0
<19
Ca
67W
7100
73CI
0.921
037
Co
c0
00
Fe
87U
-160
1000I' L
0.87
DA6
L.1
<25
Q5
M-�
23001
3000
200
115
15.[HI
Ain
65
1400
.c'dA
2al0
216
0.54
11.67
Na
5800
22,U00
400MOU
0.01
0.06
As
<10
<10
Sc
<5.0
v_0
Eff
<02
<02
1)a
28
24
NA
110
4
7_99
3.43
harducss.melLCaM
262
30:1
SUM of cluouic NQs
22.5
33.0
NA = MR a\at.a0le
(1) \AWQC ace as di ;elvedmwdsat 100 okg& hardness_
10.79QG vallas for Cd. Cr, Cu, !r0. Vi,.Rg,"La n ec adjusted to total iccovemblemeWs
N al'Ei o-3p=cirzchzrd3ress.
v TB - torieity beaeom d
^' Tic 1I vziues are c2kul2ttd by iht same rnnhndas NA\yIZC. wish kss dzu
tlQ=haard quatimL rigs evalmnion, 13Q=lsi!e)!1'B, li(1 +=1.0 indxatcs po'en6c1 [ta kuticjrC
F' AL=seslomlevcl
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SOC PRIORITY PROJECT: Yes _No_X_
If Yes, SOC No.
To: Permits and Engineering Unit
Water Quality Section
Attention: (Susan Wilson)
Date Seltmeber 25, 2002
NPDES STAFF REPORT AND RECOMMENDATION
County wake
Permit No. NC0082376
�F�
C p
2 7 2,002
PART I - GENERAL INFORMATION
1. Facility and Address:E.M. Johnson Water Treatment Plant
P.O. Box 590
Raleigh, NC 27602
(Location) 10301 Falls of the Neuse Road
Raleigh, NC 27615
2. Date of Site Visit: June 28th and August 5th, 2002
3. Report Prepared by: Charles Brown
4. Persons Contacted and Telephone Number: Jerry Keene,
ORC and John Garland, Plant Supervisor 870-2870
5. Directions to Site: Six Forks Road north to Strickland
Road, Turn Right onto Strickland, then travel approximately
3 miles and turn left onto Falls of the Neuse Road. The WTP
is about 5 miles on the left.
6. Discharge Point(s), List for all discharge points:
Discharge Point #1 - UT to Neuse River
Latitude: 350 54' 38" Longitude: 780 35' 25"
Discharge Point #2 - UT to Honeycutt Creek
Latitude: 350 54' 56" Longitude: 781 35' 59"

. SOC PRIORITY PROJECT: Yes No X
If Yes, SOC No.
Attach a USGS map extract and indicate treatment
facility site and discharge point on map.
U.S.G.S. Quad No.D 24 NE U.S.G.S. Quad Name Wake Forest
7. Site size and expansion area consistent with
application ?
X Yes No If No, explain:
8. Topography (relationship to flood plain included):
Not located within the floodplain,
9. Location of nearest dwelling:
2000 feet
10. Receiving stream or affected surface waters:
Discharge 001
a. Classification: C NSW
b. River Basin and Subbasin No.:Neuse 03-04-02
C. Describe receiving stream features and
pertinent downstream uses: Discharge from
City of Raleigh WWTP and Water Supply for
Johnston County (Town of Smithfield) ,
fishing, canoeing, recreation
Discharge 002
a. Classification:WS-IV NSW CA
b. River Basin and Subbasin No.:Neuse 03-04-02
C. Describe receiving stream features and
pertinent downstream uses:Drinking water
source for City of Raleigh, fishing, boating
and recreation
PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS
1. a. Volume of Wastewater to be permitted:
MGD(Ultimate Design Capacity) Volume is based on the amount that the
filters back wash and supernatant from the sludge handling system.
The past year of DMR's reviewed (June 2001 - May 2002) indicates a
monthly average flow of 4.49 MGD.
b. What is the current permitted capacity of the Waste
Water Treatment facility? N/A.

SOC PRIORITY PROJECT:
If Yes, SOC No.
Yes No —X—
C. Actual treatment capacity of the current facility
(current design capacity)? N/A
d. Date(s) and construction activities allowed by previous
Authorization to Construct issued in the previous two years:
None issued the past two years.
e. Please provide a description of existing or
substantially constructed wastewater treatment facilities:
The treatment system consists of dual settling basins for
filter back wash water, sludge basin, flow splitter box,
three sludge thickeners, four sludge holding tanks, three
belt filter presses, polymer feed system, sludge pumps,
filtrate pumps, sand drying beds (one side for spill
containment and the other for residuals stockpiling,
parshall flume for flow measurement.
f. Please provide a description of proposed wastewater
treatment facilities: N/A
g. Possible toxic impacts to surface waters:Potassium
promanganate, ferric sulfate, polymer, hydrate lime,
caustic, carbon, corrosion inhibitor, chlorine,
ammonia, hydrofluosilicic Acid
h. Pretreatment Program (POTWs only):
in development approved
should be required not needed X
2. Residuals handling and utilization/disposal scheme:
a. If residuals are being land applied, please specify DEM
permit no.WQ0008431
Residual Contractor
Telephone No.
b. Residuals stabilization: PSRP
PFRP Other
C. Landfill:WQ0008431 Landfill on site.

SOC PRIORITY PROJECT: Yes_No_X_
If Yes, SOC No.
d. Other disposal/utilization scheme (Specify):
3. Treatment plant classification (attach completed rating
sheet) : Class I
4. SIC code (s):4941
Wastewater Code(s) of actual wastewater, not particular
facilities i.e.., non -contact cooling water discharge from a
metal plating company would be 14, not 56.
Primary 21 Secondary
Main Treatment Unit Code: 5 1 0 3
PART III - OTHER PERTINENT INFORMATION
1. Is this facility being constructed with Construction Grant
Funds or are any public monies involved. (municipals only)?
N/A
2. Special monitoring or limitations (including toxicity)
requests:
The recent field data collected by the intensive survey unit
regarding the degradation of the downstream site would lead to
the possibility of a toxic impact to the surface waters. The
Division should look into the requirement of toxicity sampling
for the larger water treatment plants.
They have requested to have the sampling for aluminum dropped
from the permit at this time. It was stated in their request that
they had a letter from Kerr T. Stevens if they showed no
detection for aluminum for a 12 month period we would consider
dropping this from the permit. The data sent by the City revealed
that the effluent closely tracked the raw water for aluminum.
However the results of the sampling are in question. The lab was
decertified for Aluminum during the period in question. If they
can provide data from a certified lab the Division should
consider dropping the sampling for Aluminum. Another alternative
would be to keep it in and have no sampling unless they go back
to alum.
The flow is reported now as weekly estimate. The City has a
parshall flume in place and reports daily continuous flow. The
new permit should be reflected as such requiring daily continuous
flow measurement.

SOC PRIORITY PROJECT: Yes No X
If Yes, SOC No.
The City discharged an average of 4.49 MGD from a period of June
2001 to May 2002. There is not a monthly average for the
discharge from water treatment plants. The concern would be that
the facility could not handle the flow that is being sent to the
settling basins. That is what is the design capacity of the
treatment system and are they going over the design flow.
3. Important SOC, JOC or Compliance Schedule dates: (Please
indicate)
Date
Submission of Plans and Specifications
Begin Construction
Complete Construction
4. Alternative Analysis Evaluation: Has the facility evaluated
all of the non -discharge options available. Please provide
regional perspective for each option evaluated.
Spray Irrigation:N/A
Connection to Regional Sewer System:N/A
Subsurface:N/A
Other disposal options:
5. Other Special Items: They are in the process of obtaining a
reuse permit for the WTP grounds. They have been using the
effluent to water the grounds at this time without a permit.
PART IV - EVALUATION AND RECOMMENDATIONS
The facility treats raw water for the City of Raleigh from Falls
Lake. The components are the same with no new addition except
that they have a discharge pipe to the sludge landfill from the
four sludge holding tanks that allow them to discharge if they
have a problem with the filter press. The City has indicated that
the sludge landfill may have solids pumped back to the filter
presses and sent to the compost facility it currently sends
residuals to now. It may be a long term storage site. The City
has been asked what the long term plan is concerning this to
ensure that it is permitted correctly as either storage or
disposal.

SOC PRIORITY PROJECT
If Yes, SOC No.
Ye s_No_X_
This office recommends the renewal of the permit with the
sampling requirements in III. 2. A list of the chemicals they
provided a list to have on file for the product, concentration
and the total amount stored on site would be good to have listed.
A spill response and prevention plan is needed due to the amount
of spills being reported at this time.
Signature of -report preparer
�{ '�z51d2
yWater Quality Regional Supee i�sor
Date
-&,re �ritwiA
c
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s �nc-' s"--'-41.

City Of CPaleigh
5Vorth G3arolina
September 12, 2002
VIA Hand Delivery
Ms. Coleen Sullins
Division of Water Quality
North Carolina Department of Environment and Natural Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
RE: E.M. Johnson Water Treatment Plant
NPDES Permit NCO082376
Wake County
Dear Coleen:
Thank you for taking the time to meet with representatives of the City of
Raleigh yesterday to discuss potential improvements to the waste treatment facility at
the City's water plant. I am writing to summarize the action items we agreed to at -
yesterday's meeting.
As we discussed, based on biological assessments that have recently been
performed in the unnamed tributary to which the waste treatment facility discharges,
it appears that there may be some negative impact to the stream biota associated with
the facility's treated effluent. Since a large portion of the discharge consists of filter
backwash water from the water plant, which has been disinfected with chloramines,
the most likely explanation for any stream biota impact is residual chlorine, although
other residual parameters in the effluent could be implicated as well. The Division
OFFICES • 222 WEST HARGETT STREET • POST OFFICE BOX 590 • RALEIGH, NORTH CAROLINA 2'602
Recycled Paper

acknowledged that this problem is not unique to Raleigh's water treatment plant and
will be the subject of a statewide study to be conducted by the Division.
To address the receiving stream problem, the City proposed to take the
following steps, with which the Division concurred:
(1) The City has already begun work on the design of an effluent dechlorination
system to be installed at the waste treatment facility. We hope to be able to submit an
application for an Authorization to Construct the system by the end of this month,
which the Division agreed to process expeditiously. You confirmed that a
modification to the City's NPDES permit for the waste treatment facility is not
necessary in connection with the addition of a dechlorination system.
(2) The City agreed to explore with the Division of Environmental Health, Water
Supply Section (DEH), whether DEH would be willing to allow recycling of any
portion of the treatment facility effluent to the City's raw water reservoir. Also,
relocation of the City's effluent discharge outfall pipe to a downstream location will
be discussed with both your agency and DEH. If these options are available, the City
would still need to determine whether they are technically and economically feasible.
We have already initiated contact with DEH and will pursue these options as quickly
as possible.
(3) The City is very interested in potential reuse options for the treated effluent that
would reduce or potentially eliminate the current discharge. We will continue to
explore these aggressively.
(4) In an effort to identify the cause of the biota impact problem, the City has already
undertaken analysis of its effluent for a range of parameters, as well as performing
multiple dilution whole effluent toxicity testing. We will advise the staff of DWQ's
aquatic toxicology unit of the analytical work that is underway and seek their advice
as to whether additional testing is needed. We will report all results to DWQ and
consult with you about whether any action beyond those discussed above appears to
be needed.
In addition, as we stated yesterday, the City would be happy to assist DWQ in
any way it can in connection with DWQ's planned study of discharges to surface
waters from water treatment plants.
I hope that I have accurately summarized the key points of yesterday's
meeting. If I have omitted or misstated any material point, or if you require anything
further from the City at this time, please let me know (919)-890-3400.
The City wishes to address this problem as quickly as possible and will do so with the
help of our consultants and the DENR staff.

Thank you again for the time and attention that you and the DWQ staff have given to
this matter.
SincerInji
,
H. DalE
Public rector
cc: Dave Goodrich
Ken Schuster
Russell Allen
Steve Levitas
John Garland
Randy Hildebran
Bob Berndt

G�ri,✓/csl� Gt/�,�'l�_s .
— , N,v.
Division of Water Quality (--- -- - ,,
Biological Assessment Unit
11 September, 2002 LSEP 12 2P12
MEMORANDUM --- —t�
To: Jimmie Overton i
Through: Trish Finn MacPhersonQ
�Yu et �M
From: Kathy Herring
Subject: Benthic macroinvertebrate survey of Unnamed Tributary to Falls
Lake above and below discharge tributary from Raleigh E.M.
Johnson WTP, Wake County, Nauss River Subbasin 01.
BACKGROUND
At the request of the Raleigh Regional Office, BAU staff, on August 29, 2002, conducted a.
benthic macroinvertebrate community survey on an unnamed tributary above and below the
confluence of the discharge stream from the Raleigh E.M. Johnson Water Treatment Plant.
This survey was requested to determine if the WTP discharge was adversely affecting the
macroinvertebrate community of this unnamed tributary (UT) to Falls Lake.
The Raleigh EM Johnson WTP discharges into a very small (1 m wide) tributary to another
small (2.5 m wide) tributary to the Honeycutt Creek arm of Falls Lake (Figure 1). Average
flow from the plant from January through June 2002, ranged from 1.46 million gallons per day
(MGD) in March to 3.54 MGD in January. The discharge is continuous.
An assessment performed on the main UT, below the discharge stream, by David Wcjnowski
of Division of Water Resources and Dean Naujoks the Upper Neuse River Keeper on August
23, 2002 resulted in only aquatic worms. They found a more diverse fauna in the main UT
upstream of the WTP discharge stream.
No historical data exists for this stream.
SITE DESCRIPTIONS (Figures 1, 2 and 3)
The main UT to Falls Lake, where the sampling sites were located, is a small stream
originating just south of Durant Road, near the E.M. Johnson Raleigh WTP in Wake County
(Figure 1). The WTP's discharge is located on a smaller stream that is tributary to the main
UT that flows into Falls Lake. Upstream of the confluence of the discharge stream, the main
UT stream is very small (2.5 m) and has had very little to no flow for much of this summer
due to the drought conditions experienced in the area.
The watershed of the main UT above the WTP discharge stream is mostly urban. It
originates just north of Durant Road and flows through the Sheffield Manor subdivision, then
through a forested area into Falls Lake, just south of SR 2002, Raven Ridge Road. Habitat
conditions in the main UT are generally good at both sites however, the upstream site at
Bentham Drive suffers more from erosion and embeddedness due to sedimentation than the
downstream site. The habitat at both sites should be adequate to support a diverse benthic
macroinvertebrate community. The upstream site at Bentham Drive received a habitat score
of 79 and the downstream site at SR 2002 received a score of 85.

Water levels were very low at the upstream site during this survey, filling less than 75% of the
available channel. Water levels at the downstream site were higher because of the
discharge.
There was a mudlike, black substance covering the substrate at the downstream site (SR
2002) that was not present upstream of the WTP at Bentham Drive (Figure 3). This
substance covering the tops of the instream rocks and woody debris decreases the area
available for benthic macroinvertebrate habitat.
Table 1. Site Locations and Descriptions for UT to Falls Lake, Wake Co., 8/29/02.
Bentham Dr
SR 2002
Sheffield Manor
Raven Ridge Rd
Upstream WTP
Downstream WTP
Width (m)
1.5
3
Average Depth (m)
0.2
0.2
Canopy(%)
90
90
Aufwuchs
Abundant
None
Bank Erosion
Severe
Moderate
Substrate (%)
Boulder
30
0
Rubble
10
40
Gravel
30
30
Sand
30
20
Silt
0
10
Habitat Score
79
85
Conductivity (µmhos/cm)"
97
227
Temperature (°C)
21
24
DH
7.0
7.0
'corrected to 25"C

Fiqure 1. Map of Studv Area

Figure 2. UT Falls Lake, Bentham Dr., Upstream of the Raleigh WTP.
r „}
w y
UT Falls Lake, Bentham Dr.
Figure 3. UT Falls Lake, SR 2002 (Raven Ridge Road), Downstream of the Raleigh WTP.
of WTP
WMZ15N
4

METHODS
Benthic macroinvertebrates were collected using methods intended to assess between -
station differences in water quality in streams that cannot be assigned a bioclassification
because of small size or hydrology (lack of flow during the summer months). Small streams
(< 4 m wide) generally support a less diverse macroinvertebrate fauna than larger streams.
Current DWQ criteria are not appropriate for assigning bioclassifications to these small
streams. However, the benthic communities can still be compared in upstream/downstream
situations to indicate if there are any adverse impacts to the community from pollution
sources.
A composite of five samples was taken at each site: 1 kick, 1 sweep, 1 leafpack, 1 rock/log.
wash and visual collections. All macroinvertebrate groups were collected and identified. The
primary output was a taxa list, with some indication of relative abundance for each taxon.
Organisms were classified as Rare (1-2 specimens), Common (3-9 specimens), or Abundant
L10 specimens).
Several data -analysis summaries (metrics) can be produced from such samples to detect
water quality problems. These metrics are based on the idea that unstressed streams and
rivers have many invertebrate taxa and are dominated by intolerant species. Conversely,
polluted streams have fewer numbers of invertebrate taxa and are dominated by tolerant
species. The diversity of the invertebrate fauna is evaluated using taxa richness counts; the
tolerance of the stream community is evaluated using a biotic index.
Total taxa, EPT taxa richness, and the Biotic Index values were compared between sites. In
general, higher EPT taxa richness values and lower Biotic Index values indicate better water
quality.
Habitat assessments were performed at each sampling location- using DWQ's Mountain/Piedmont
Habitat Evaluation Form. This evaluation is based on best professional judgment of 8 habitat
metrics: including analysis of channel modification, four instream habitat measurements, one
streambank measurement, and two riparian zone measurements. Scores are given for each of
the eight metrics and are then totaled (100 points possible). Streams, or monitoring stations,
within major ecoregion types and size categories can be compared to one another and to
reference locations.
Documentation of habitat characteristics at a sampling site can 'identify limiting factors that
can affect biological communities. Habitat assessment provides baseline information on
stream conditions so that changes resulting from natural or human causes can be identified
or predicted. Habitat assessments can also determine the consequences on the biota of
alteration of stream conditions, such as land use changes (in this case, urbanization) and
channelization.
RESULTS AND SUMMARY
Seven different EPT taxa were collected upstream of the WTP discharge and none were
collected downstream. There were also more total taxa collected upstream of the WTP (34)
discharge stream than below (17). The Biotic index was higher at the downstream site
(7.41), indicating a community dominated by more pollution tolerant organisms. Upstream,
the BI was 6.33 (Table 2).
The EPT taxa most numerous at the upstream site were facultative EPTs such as Caenis and
Stenonema modestum (Appendix 1). The highly pollution tolerant midge Cricotopus bicinctus
was dominant at the downstream site. Most of the midge taxa collected at the upstream site

were indicative of low Dissolved Oxygen/low flow conditions: Tribelos, Procladius,
Polypedilum illinoense, Microtendipes, and Phaenopsectraa flavipes.
The absence of EPT taxa at the downstream site plus the abundance of the midge
Cricotopus bicinctus are indicative of some toxic effect.
Even though the data from the upstream (Bentham Dr.) site indicate a less pollution tolerant
benthic community than the downstream (SR 2002) site, the upstream site is still suffering
from low diversity. An unimpacted stream this size would be expected to support a more
diverse and productive benthic macroinvertebrate community. A rateable (at least 4m wide)
stream in the Piedmont ecoregion would have at least 14 EPT taxa to rate Good -Fair.
Table 2. Taxa Richness and Summary Values, UT Falls Lake, Wake Co., 8/29/02.
Stream
UT Falls Lake
UT Falls Lake
Location
Bentham Dr
SR 2002
Upstream WTP
Downstream WTP
Date
8/29/02
8/29/02
Ephemeroptera
4
0
Plecoptera
0
0
Trichoptera
3
0
Coeoptera
6
3
Odonata
3
5
Megaloptera
0
2
Diptera: Chironomidae
9
2
Misc. Diptera
2
3
Oligochaeta
3
1
Crustacea
1
1
Mollusca
3
0
Other
0
0
Total Taxa Richness
34
17
EPT Richness
7
0
EPT Abundance
20
0
Biotic Index
6.33
7.41
Data from this survey indicate some adverse toxic impact to the benthic macroinvertebrate
community from the WTP discharge. However, it should be noted that this is a very small
stream that is already adversely affected upstream by the drought conditions that persist in
the area and sediment loading caused by urbanization.
CC: Ken Schuster — Raleigh Regional Office
David Goodrich — NPDES Unit
Ernie Seneca— Public Information Officer DWQ
David Wojnowski — Division of Water Resources
Brad Boris — Water Process Supervisor
City of Raleigh
Public Utilities Dept.
10301 Falls of Neuse Rd
Raleigh, NC 27602-0590

Appendix 1. Taxa List with Indication of Relative Abundance (A=Abundant, C=Common, R=Rare), LIT Falls Lake, Wake
Co., 8/29/02
Stream
UT Falls Lake
UT FaJls Lake
Location
Bentham Dr
SR 2002
Date
8/29/02
8.29 02
EPHEMEROPTERA
BAETIS FLAVISTRIGA
R
BAETIS PROPINQUUS
R
CAENIS SPP
C
STENONEMA MODESTUM
C
TRICHOPTERA
CHEUMATOPSYCHE SPP
A
CHIMARRA SPP
R
NEOPHYLAX CONSIMILIS
R
COLEOPTERA
ANCYRONYX VARIEGATUS
A
R
DUBIRAPHIA VITTATA
R
HELICHUS SP
A
C
HYDROPORUS SPP
C
R
MACRONYCHUS GLABRATUS
A
PSEPHENUS HERRICKI
R
ODONATA
ARGIA SPP
R
R
CALOPTERYX SPP
R
R
ENAL.LAGMA SPP
R
GOMPHUS SPP
R
MACROMIA SPP
R
R
MEGALOPTERA
CORYDALUS CORNUTUS
R
NIGRONIA SERRICORNIS
R
DIPTERA: CHIRONOMIDAE
CRICOTOPUS BICINCTUS: C/O SP1
A
CONCHAPELOPIA GROUP
R
CORYNONEURA SPP
R
DICROTENDIPES NEOMODESTUS
R
R
MICROTENDIPES SPP
R
POLYPEDILUM FALLAX
R
POLYPEDILUM lWNOENSE
C
PHAENOPSECTRA FLAVIPES
R
PROCLADIUS SPP
C
TRIBELOS SPP
R
MISC. DIPTERA
EMPIDIDAE
R
LIMONIA SPP
R
R
TIPULA SPP
R
R
OLIGOCHAETA
AULODRILUS UMNOBIUS
R
LUMBRICULIDAE
C
C
STYLARIA LACUSTRIS
R
CRUSTACEA
CAMBARUS SPP
C
R
GASTROPODA
FERRISSIA SPP
R
PHYSELLA SPP
R
PSEUDOSUCCINEA COLUMELLA
R

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[Fwd: Meeting with City of Raleigh]
From: Coleen Sullins <Coleen.Sullins @ncmail.net> 4:15 PM
Subject: [Fwd: Meeting with City of Raleigh]
To: Ken Schuster <[e-mail]>, Dave Goodrich <[e-mail]>,
Shannon Langley <[e-mail]>
here are the specifics. Coleen
From: "Levitas, Steve"<[e-mail]> 4:04 PM
Subject:Meeting with City of Raleigh
To: "'Coleen. [e-mail]"' <[e-mail]>
CC:"'[e-mail]"'<[e-mail]�-
"'[e-mail]"' <[e-mail]-
"'[e-mail]"' <[e-mail]>
Coleen -- Thank you for agreeing to meet with representatives of the City of
Raleigh and me next Wednesday at 3:00 p.m. at your office. I want to give
you some information about what we'd like to talk about so that you can have
the appropriate staff present.
DWQ staff, as well as David Wojnowski of DWR, have recently conducted
biological assessments of the receiving stream into which the City
discharges wastewater from its water plant residuals treatment process.
Although we have not yet received a report from DWQ, David concluded that
the discharge is adversely affecting aquatic life in the receiving waters.
The City has a permit renewal application pending. We would like to talk
with you about modifying the application to address the problem that has
been identified. The solution may be as simple as adding dechlorination,
but we would like to get the benefit of DWQ's input before developing a plan
and submitting the modification request. I would also note that for many
years the City did not discharge wastewater from this process but recycled
it to its raw water reservoir. My understanding is that DEH discourages
that practice, but if you think it would be helpful to put that option back
on the table, we may want to try to include DEH in this meeting as well. If
you have any questions or require any additional information, please let me
know. Thanks very much for your assistance.
Steve
1 of 1 9/6/02 4:41 PM

City Of (�Raleig
.9Yorth Carolina
August 22, 2002
Mr. Charles H. Weaver, Jr.
NCDENR
Division of Water Quality
NPDES Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Dear Mr. Weaver:
p [ECEPdE
3 D
AUG 2 2002
OENR-WATER QUALITY
POINT SOURCE BRANCH
Re: City of Raleigh
E.M. Johnson WTP
NPDES Permit Renewal
Permit No. NCO082376
Enclosed is the permit renewal package for the NPDES Permit for the E.M. Johnson
Water Treatment Plant (WTP) for the City of Raleigh, North Carolina. The package
includes the following information:
This cover letter.
A completed NPDES Permit Application — Short Form C
A Sludge Management Plan for the E.M. Johnson WTP Facilities
No changes have been made to the facilities since the last permit was issued.
However, since the coagulant used for the water treatment process is currently ferric
sulfate, we hereby request your consideration of the removal of the aluminum
monitoring requirement for this permit renewal. A letter from Mr. Kerr T. Stevens on
August 24, 1999 indicated that submission of effluent data showing no detection of
aluminum in the effluent for a period of 12 months may allow removal of the aluminum
monitoring requirement. Attached is a spreadsheet showing raw water and effluent
aluminum concentrations for the 12-month period from June 2001 through May 2002.
We believe that the data does not show a significant increase in aluminum in the
effluent over the amount in the raw water. Therefore, we request that the aluminum
monitoring requirement be removed from the permit.
OFFICES • 222 WEST HARGETT STREET • POST OFFICE BOX 590 • RALEIGH, NORTH CAROLINA 27602
Recycled Paper

Mr. Charles H. Weaver, Jr.
Page 2
August 22, 2002
The City also currently uses a small portion of the effluent for irrigation on the water
treatment plant grounds. The City is in the process of applying for a reuse permit for
this irrigation, plus planned future expansions of the irrigation facilities for use on other
areas of the plant site or use off -site.
Please let me know if you have any questions or comments on this renewal package.
Very truly yours,
H. Dale Crisp, P. .
Public Utilities Director
Cc: City Manager
Water Plant Superintendent
Construction Projects Coordinator
HDC/bpr
Enclosures
Weaver 08.08.02 ue.

E.M. Johnson WTP Performance Summary -- Effluent Quality
RAP-inh_ NC
Effl.
Flow
Aluminum
Raw
Water Aluminum
Water
Produced
Month
Avg.
Max.
Avg.
Max.
No. of
Samples
Avg.
Max.
No. of
Samples
Avg.
Max.
No. of
Sam les
an d
an d
m /L
m /L
m /L
m /L
an d
an d
JUN 01
6.76
10.85
0.05
0.12
4
0.12
0.39
J U L
7.79
17.20
0.11
0.16
4
0.04
0.11
52.3
62.0
AUG
6.42
9.71
0.10
0.33
5
0.03
0.06
53.5
69.4
SEP
7.50
9.57
0.03
0.04
4
0.04
0.07
52.5
61.3
OCT
5.47
7.13
0.06
0.08
4
0.04
0.10
53.5
63.4
NOV
3.94
5.30
0.09
0.13
5
0.05
0.09
50.2
58.1
DEC 01
3.97
5.25
0.09
0.11
4
0.08
0.43
38.5
47.1
JAN 02
3.54
6.41
0.11
0.27
5
0.09
0.23
37.8
40.0
FEB
1.48
3.25
0.07
0.13
4
0.06
0.15
38.2
40.8
MAR
1.46
2.15
0.14
0.16
4
0.04
0.11
40.4
51.7
APR
2.31
3.20
0.07
0.14
4
0.01
0.03
47.6
56.4
MAY 02
3.24
8.31
0.02
0.03
5
0.01
0.01
55.6
66.9
JUN 02
62.2
72.1
Avg.
4.49
0.08
0.05
48.5
Max.
7.79
17.20
0.14
0.33
0.12
0.43
62.2
72.1
Min.
1.46
0.02
0.01
37.8
Total
52
362
Detailed Effl. Data
EMJohnson Permit Application

NPDES PERMIT APPLICATION - SHORT FORM C
For manufacturing or commercial facilities with a discharge < 1 MGD (or WTPs)
N. C. Department of Environment and Natural Resources
Division of Water Quality / NPDES Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
North Carolina NPDES Permit Number NC00 82376
Please print or type
1. Applicant and facility producing discharge
A. Name E.M. Johnson Water Treatment Plant
B. Mailing address of applicant:
Street address P.O. Box 590
City Raleigh County. Wake
State NC Zip Code 27602
Telephone Number [phone]
Fax Number [phone]
e-mail address Dale.Crisg0_ci.raleigh.nc.us
C. Location of facility:
Contact Person H. Dale Crisp
Street 10301 Falls of the Neuse Road
City Raleigh County. Wake
State NC Zip Code 27615
Telephone Number [phone]
2. Standard Industrial Classification (SIC) code(s):
3. Number of employees: 50
4. Principal product(s) produced: Treated drinking water
Principal raw material(s) consumed: Chemicals (see additional information)
5. Principal process(es): See additional information
6. Amount of principal product produced (or raw material consumed)
11 ict cnaf-ifio- mmmintc ennciimprl andlnr tinifc of nrnrluctinnl
Product Produced or Raw Material Consumed
AVERAGE
Product Produced or Raw Material Consumed
PEAK
per Day
48.5
72.1
per Month
NIA
N/A
per Year
NIA
N/A
7. Check here if discharge occurs all year XO , or
Circle the month(s) in which discharge occurs: January February March April
May
June July August September October November December
Page 1 of 2 Version-1112000
D nNP18 M Form C.doc

NPDES PERMIT APPLICATION - SHORT FORM C
For manufacturing or commercial facilities with a discharge < 1 MGD (or WTPs)
Days per week discharge occurs: 7
NOTE: If the facility has separate discharge points (outfalls) or multiple industrial processes, include a schematic diagram
of wastewater flow at the facility.
8. Types of wastewater discharged to surface waters only (check as applicable).
Discharge per operating day
Flow
GALLONS PER OPERATING DAY
Volume treated before discharging
PERCENT
Sanitary - daily average
N/A
N/A
Cooling water, etc. - daily average
N/A
N/A
Process water - daily average
4.5 mgd
100
Maximum per operating day for
total discharge (all types)
17.2 mgd
100
9. If any of the types of wastewater identified in item 8 (either treated or untreated) are discharged to places
other than surface waters, record the amount(s) discharged below:
A. Municipal sewer system N/A gpd
B. Underground well N/A gpd
C. Septic tank N/A gpd
D. Evaporation lagoon or pond N/A gpd
E. Other, specify, Approximately 9,000 gpd (Reuse water)
10. Number of separate discharge points: Two
11. Name of receiving stream(s):Unnamed tributary to Honeycutt Creek (002): unnamed tributary to
Neuse River (001)
12. Does your discharge contain or is it possible for your discharge to contain one or more of the following
substances added as a result of your operations, activities, or processes? Circle all that apply:
aluminum ammonia beryllium cadmium chromium chlorine (residual)
copper cyanide lead mercury nickel oil an grease
phenols selenium zinc None of the above
certify that I am familiar with the information contained in the application and that to the best of my
knowledge and belief such information is true, complete, and accurate.
H. Dale Crisp Public Utilities Director
Printed name o Per S' 'ng Title
Signature of Applicant Date
North Carolina General Statute 1U1215.613 (i) provides that Any person who knowingly makes any false statement representation, or certification in any application, record,
report, plan, or other document files or required to be maintained under Article 21 or regulations of the Environmental Management Commission implementing that Article, or
who falsifies, tampers with, or knowingly renders inaccurate any recording or monitoring device or method required to be operated or maintained under Article 21 or
regulations of the Environmental Management Commission implementing that Article, shall be guilty of a misdemeanor punishable by a fine not to exceed $10,000, or by
Imprisonment not to exceed six months, or by both.
(18 U.S.C. Section 1001 provides a punishment by a fine of not more than $10,000 or imprisonment not more than 5 years, or both, for a similar offense.)
Page 2 of 2
03TFMP13bort ram CAW
Version—1112000

Additional Information
Item 4. Principal raw materials consumed
WATER TREATMENT PROCESS
CHEMICAL
Potassium permanganate (oxidant)
Ferric sulfate (coagulant)
Polymer (coagulant aid)
Hydrated lime (pH control)
Caustic (pH control)
Carbon (odor control)
Polymer (filter aid)
Corrosion inhibitor
Hydrofluosilicic Acid (fluoride)
Chlorine (disinfectant)
Ammonia (disinfectant)
Pre ozone
Intermediate Ozone
DOSAGE
1.6 mg/L
58 mg/L
0.10 mg/L
3.44 mg/L
12 mg/L
0
0
1.45 mg/L
0.95 mg/L
6.21 mg/L
1.0 mg/L
3 mg/L
1 mg/L
DATEMPIPermit NC0082376.doc

Additional Information (Continued
Item 5. Principal Processes
Water treatment processes include rapid mixing, ozonation, flocculation, sedimentation, filtration
and disinfection with chlorine (sodium hypochlorite) and ammonia. Residuals from the water
treatment plant process include solids settled in the sedimentation tanks, filter backwash water,
and decant water from a sludge lagoon.
The solids from the sedimentation tanks are discharged to a splitter box, which distributes the
solids to three sludge thickeners. A fourth sludge thickener is planned to be added to
supplement the existing three thickeners. The thickened sludge is pumped to four sludge
blending tanks, from which the sludge is pumped to three belt filter presses for dewatering:
Polymer is added to the thickened sludge to the belt presses for solids conditioning before
dewatering. The dewatered cake is hauled by truck to 17 sand drying beds for storage. The
dewatered cake is hauled from the drying beds and recycled to a contractor. Belt filter press
filtrate, decant water from the sludge lagoon and backwash clarifier solids are returned to the
splitter box for treatment with the solids from the sedimentation tanks.
The filter backwash water is discharged to two backwash clarifiers, which also receive decant
water from the sludge thickeners and sludge blending tanks. A Parshall flume with an ultrasonic
flow meter is used for measuring the decant water flow rate from the sludge thickeners. Caustic
is added to the flow from the thickeners to the backwash clarifiers for pH control of the filter
backwash water. The backwash clarifier effluent is the only discharge to the receiving stream
from the treatment facilities.
The sludge lagoon is used for storage of thickened sludge from the sludge blending tanks when
one or more of the presses are out of service for maintenance or repairs. The sludge lagoon is
periodically decanted using a portable pump, and returned to the belt filter press filtrate pump
station for return to the splitter box.
A schematic of the wastewater treatment processes at the E.M. Johnson WTP is included in
Figure 1.
Item 9.E. Water used for irrigation of approximately 2 acres on plant site. Irrigated a total
of nine times in 2002.
JAPRIVATEMPFILESIMIMPermit NC0082376.doc 2

FIGURE 1
1
RAW WATER
FROM PRETREATMENT
RESERVOIRS WATER TREATMENT
FACILITIES
FLOW
SPUTTER
BOX
TSL
SLUDGE
THICKENERS
(3)
TS
THICKENED
SLUDGE TS
PUMP
STATION
I
I
I
I
I
1
1
I
I
r
THICKENED SLUDGE
TO SLUDGE DISPOSAL
FACILITY
(ALTERNATE)
HAZEN AND SAWYER
Environmental Engineers & Scientists
POLYMER — — T SLUDGE
I FROM
SL SEDIMENTATION
TANKS
MANHOLE
NO. 2
--- POLYMER
I
CAUSTIC
TO TO
PARSHALL
FLUME
F
BTD
SLUDGE
BLENDING TS P TS
TANKS
(4)
LEGEND
- FINISHED WATER
BCS BACKWASH
CLARIFIER SLUDGE
BTD BLENDING TANK DECANT
DS DEWATERED
SLUDGE
F FILTRATE
FILTER BACKWASH
SL SLUDGE
TO THICKENER
OVERFLOW
TS THICKENED
SLUDGE
© PUMPS
r — — — — — — — DISCHARGE TO
I OUTFALL 001
I (FUTURE)
I
I
BACKWASH
I
I
I
CLARIFIERS
DISCHARGE TO
(2)
OUTFALL 002
BCS
P TO IRRIGATION
SYSTEM
POLYMER WASHWATER
BELT
FILTER
DS
TRUCK
CONTAINMENT
TRUCK
PRESSES
HAULING
PAD
HAULING
RECYCLE
(3)
TO A CONTRACTOR
F
SAND
DRYING
BEDS
F FILTRATE (8)
PUMP
STATION
UNDERDRAIN NC0082376
THICKENED SLUDGE -
TO SLUDGE DISPOSAL E.M. JOHNSON WTP
FACILITY DECANT FROM
SLUDGE DISPOSAL CITY OF RALEIGH
FACILITY
RESIDUALS TREATMENT SYSTEM
PROCESS FLOW SCHEMATIC

E.M. Johnson WTP
Sludge Management Plan
Residuals from the E.M. Johnston Water Treatment Plant (WTP) include solids from the
sedimentation tanks and filter backwash water. The residuals are treated in a residuals
treatment system that includes the following:
• One Flow Splitter Box (for Flow to Sludge Thickeners)
• Three Sludge Thickeners
• Four Sludge Blending Tanks
• Three Belt Filter Presses (BFPs)
• Seventeen Sand Drying Beds
• One Sludge Lagoon
• Two Backwash Clarifiers
• Thickened Sludge Pumps
• BFP Feed Pumps
• Polymer Feed System (for BFPs)
• Filtrate Pumps
• Caustic Feed System (for Filter Backwash Water)
• Parshall Flume (for Sludge Thickener Decant/Overflow)
Filter backwash water is treated in the backwash clarifiers. Effluent from the backwash clarifiers
is currently discharged to receiving waters through Outfall 002.
Solids from the sedimentation tanks, along with backwash clarifier solids, are distributed to the
sludge thickeners for thickening by gravity. The thickened sludge is pumped to the sludge
blending tanks for storage, and from there pumped to the belt filter presses for dewatering. The
dewatered sludge is discharged from the belt filter presses to trucks for hauling to the sand
drying beds for storage and additional dewatering. From the sand drying beds, the dewatered
sludge is hauled by truck for recycling to a contractor.
JAPRNATEMPFILESWIISCWermit NCOW2376.doc

Ncoo 82�>76
�jf 4Gf�^
MEMORANDUM
To:
Through:
From:
Subject:
Division of Water Quality
Biological Assessment Unit
28 August, 2002
Jimmie Overton
Trish Finn MacPherson
Kathy Herring 0
Study Plan for UT to Falls Lake above and below Raleigh E.M.
Johnson WTP, Neuse River Subbasin 01
The FRO has requested macroinvertebrate sampling above and below the Raleigh E.M.
Johnson water treatment plant in response to an assessment performed by David Wojnowski
of DWR on 8-23-02. During this survey, aquatic worms were the only organisms collected
downstream of the WTP discharge. A more diverse fauna was found upstream of the WTP
discharge.
Due to the small, unrate-able size of this stream, BAU staff will collect a Qual5 sample above
and below the discharge to determine the degree of impact to the macroinvertebrate
community. This sample consists of a kick, a sweep, a leaf pack, a rock/log wash and
visuals.
CC: Ken Schuster —Raleigh Regional Office
David Goodrich —NPDES Unit

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