NC0025453_Speculative Limits Request_20240125

MAYOR
Jody L. McLeod

TOWN MANAGER
Richard D. Cappola, Jr.

TOWN ATTORNEY
Cauley Pridgen, P.A.

MAYOR PRO TEM
Michael Sims
COUNCIL MEMBERS
Ruth Anderson
Andria Archer Porter Casey Gretchen Williams

PO Box 879 • Clayton, NC 27528 • 919-553-5002 Fax [phone] • ClaytonNC.org • Page 1 of 2
January 24, 2024
Mr. Michael Montebello
Section Chief, Water Quality NPDES Permitting Section
Division of Water Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Subject: Request for Speculative Limits for Surface Water Discharge for the Town of Clayton
Permit NC0025453
Johnston County, NC
Dear Mr. Montebello:
The Town of Clayton (Town) is requesting that the North Carolina Department of Environmental Quality’s
Division of Water Resources (DWR) consider the issuance of speculative limits for a fifteen (15) million
gallons per day (MGD) discharge to the Neuse River at the Sam’s Branch Water Reclamation Facility’s
(WRF) current discharge location pursuant to NPDES Permit No. NC0025453.
The 6 MGD Sam’s Branch WRF is currently under construction to provide capacity for immediate needs.
NPDES Permit No. NC0025453 also provides for expansion of the Sam’s Branch WRF to 10 MGD.
However, new growth projections indicate that capacity may be exceeded within the 20-year planning period
necessitating the need to begin planning for expansion beyond 10 MGD.
The Town previously requested speculative limits for 10 MGD August 7, 2020, and those limits were
provided by DWR on September 4, 2020. These limits were incorporated into NPDES Permit No.
NC0025453 on January 15, 2021. That speculative limits request included a report from Dewberry
Engineers on river modeling indicating the additional discharge would still be protective of water quality in
the Neuse River. As indicted in DWR’s September 4, 2020, speculative limits approval, biochemical oxygen
demand and ammonia-nitrogen limits were based on review of a 2020 QUAL2K model that demonstrated
that the proposed limits are protective of the dissolved oxygen water quality standard.
The QUAL2K model was obtained from DWR and used to conduct additional analysis to support this
request. Please see the attached Expanded Surface Water Discharge Evaluation Technical Memorandum
for additional information on the analysis. We understand that the City of Raleigh has also requested
speculative limits for the Neuse River Resource Recovery Facility, and this was taken into consideration in
the evaluation. The model files will be shared with DWR’s Modeling and Assessment Branch.

PO Box 879 • Clayton, NC 27528 • 919-553-5002 Fax [phone] • ClaytonNC.org • Page 2 of 2
Speculative limits will provide the Town with a reliable basis of planning for wastewater reclamation needs.
Speculative limits will also assist in regional planning efforts with partners that include the City of Raleigh
and Johnston County. The Town of Clayton appreciates your consideration of this request. Please do not
hesitate to contact me at [phone] or [e-mail].
Sincerely,
Richard D. Cappola Jr.
Town Manager

Attachments:
• Town of Clayton, Sam’s Brach WRF Expanded Surface Water Discharge Evaluation Technical Memorandum (HDR,
December 2023)

CC: Josh Baird, PE, CFM, Town of Clayton
Louis Duffie, EI, Town of Clayton
Adam Sharpe, HDR
Kim Colson, PE, HDR