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Home My WebLink About20110260 Ver 1_Approval Letter_20111010 �� (�� North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H Sullins Dee Freeman Governor Director Secretary November 10 2011 University of North Carolma at Chapel Hill 300 South Building Chapel Hill NC 27599 Re Carolina North Orange County DWQ#20110260 USACE Act�on ID No SAW 2010 10840 Crow Branch Creek [030606 16 41 I 15 2 2 B NSW] APPROVAL of 401 Water Qual�ty Certificahon wtth Add�honal Condihons R�VIS�YD � Dear S�r or Madam Attached hereto is a copy of Certificat�on No 3870 issued to the Un�vers�ty of North Carolma at Chapel Hill dated November 10 2011 This letter shall also act as your approved Authonzat�on Cert�ficate for impacts to the protected r�par�an buffers per 15A NCAC 2B 0267 'i'h�s Cert�fication Approval and Buffer Author�zat�on reptace the Cerhficahon Approval and Buffer Author�zat�on�ssued October 27,2011 In addrtion you should get any other federal state or local permits before you go ahead with your proJect mcludmg(but not limited to)Solid Waste Sediment and Erosion Control Stormwater Dam Safety Non discharge and Water Supply Watershed regulations If we can be of further assistance do not hesitate to contact us Smc ely � � Coleen H Sullms CHS/kah/ym Attachments Cert�ficate of Completion NCDWQ 401 WQC Summary of Permanent Impacts and Mit�gation Requirements cc Becky Fox EPA 1307 F�refly Road Whittier NC 28789 Andy Williams USACE Raleigh Regulatory Field Office Lauren Witherspoon DWQ Raleigh Regional Office DLR Rale�gh Regional Office F�le Copy Ren ivins Orange County Plannmg 200 South Cameron Street P O Box 8181 Hillsborough NC 27278 Sue Burke PE CFM Town of Chapel H�ll 208 N Columb�a Street Chapel Hill NC 27514 Kevm Nunnery Biohabrtats Inc 8218 Creedmoor Road Suite 200 Rale�gh NC 27613 Fdename 110260Carolmallorth(Orange)40l_JBR_IC_Rev�sed NleUands Buffers Stonrnvaler Compliancz anri Permitt�ng Unit(WeBSCaPe� 1650 Mail Service Center Raleigh Noiih Carolina 27699 1650 Phone 919 807 63001 FAX 919 807 6494 Internet htfp//portal ncdenr org�efebl�vqlU An Equal Opportunity 1 Atbrmalive Arfion Employei The Univers�ry of North Carolma at Chapel Hill Page 2 of 8 November 10 2011 NORTH CAROLINA 401 WATER QUALITY CERTIFICATION THIS CERTIFICATION is issued m conformrty with the requirements of Section 401 Public Laws 92 500 and 95 217 of the United States and sub�ect to the North Carol�na D�vision of Water Qualrty(DWQ) Regulations in 15 NCAC 2H Section 0500 and approved authorizat�on for�mpacts to the protected ripar�an buffers per 15A NCAC 2B 0267 to theUmversity of North Cazolma at Chapel H�II who have perm�ssion to fill or otherw�se �mpact 2 412 acres of 404/Wetland and 622 Imear feet of stream(378 linear feet of permanent impact to stream 701inear feet temporary impact to stream and 174 of permanent impact to ephemeral stream and 23 605 square feet of Zone 1 Jordan Lake protected r�parian buffers and 14 637 square feet of Zone 2 Jordan Lake basm protected npazian buffers to construct the proposed Carolma North pro�ect(an expans�on of the Un�versity of North Carolma at Chapel Hill campus) which �s located wrthin the northwest and southwest quadrants of the mtersection of Martm Luther Kmg Jr Boulevard and Estes Dr�ve m the Towns of Chapel Hill and Canboro Orange County North Carolma pursuant to an application dated March 18 2011 and received by the DWQ on March 22 2011 and by Public Notice tssued by the USACE on Apr�18 2011 and received by the DWQ on Aprt18 2011 and by additional mformation recerved on June 6 2011 June 29 2011 July 1 2011 and September 21 2011 The application and supporting documentation provides adequate assurance that the proposed work w�l( not result m a violation of applicable Water Qualrty Standards and discharge guidelmes Therefore the State of North Carolma certifies that this activrty will not violate the applicable portions of Sect�ons 301 302 303 306 307 of PL 92 500 and PL 95 217 if conducted m accordance with the application the supporting documentation and conditions heremafter set forth This approval �s for the purpose and design subm�tted m the application materials and as descnbed m the Public Notice If the proJect is changed pr�or to not�fication a new applicat�on for a new Certificat�on is requ�red if the property is sold the new owner must be given a copy of the Cert�ficat�on and approval letter and is thereby responsible for complymg w�th all condrtions of this Certification Any new owner must notify the Div�sion and request the Cert�fication be issued m their name Should wetland or stream fill be requested in the future addit�onal compensatory mrtigation may be required as descnbed m 15A NCAC 2H 0506(h)(6)and(7) If any plan revisions from the approved site plan result m a change m stream or wetland impact or an mcrease m impervious surfaces the DWQ shall be not�fied m wntmg and a new application for 401 Certification may be required For this approval to be val�d compliance wrth the conditions listed below is required Cond�hons of Cerhficahon ` 1 Impacts Approved The followmg impacts are hereby approved as long as all of the other spec�fic and general conditions of this Certificat�on(or Isolated Wetland Permrt)are met No other impacts to wetlands streams and/or buffers are approved �ncludmg mcidental �mpacts T e of Wetland Amount A roved n�ts Plan Locat�on or Reference Phase#1 404/Wetlands—n anan 0 005(acres) A lication Stream 41 [(lmear feet)31 lmeaz feet Application permanent impact and 10 lmear feet , tem o un act] Buffers Zone I 0 00(s uare feet) A lication Buffers Zone II 0 00(s uare feet) A I�cation Phase#2 404/Wetlands—ri ar�an 2 407(acres) A l�cation The Univers�ty of North Carolma at Chapel Hill Page 3 of 8 November 10 2011 Stream 581 [(lmear feet)3741mear feet Appltcation permanent stream impact 60 lu►ear feet temporary stream impact and 174 lmear permanent ephemeral stream im act] Buffers Zone I 23 605(s uare feet) A lication Buffers Zone II 14 637(s uare feet) A hcahon � Sediment and Erosion Control 2 Eros�on and sediment control practices must be m full compltance with all specifications governmg the proper design mstallatton and operat�on and mamtenance of such Best Management Practices in order to protect surface waters standards a The erosion and sediment control measures for the pro�ect must be designed �nstalled operated and mamtamed m accordance wrth the most recent version of the North Carolrna Sedrment and Erosion Control Plannrng and Desrgn Manual b The design mstallat�on operation and mamtenance of the sediment and erosion control measures must be such that they equal or exceed the requirements specified m the most recent version of the North Carolina Sediment and Erosion Control Manual The devices shall be maintamed on all construction s�tes borrow sites and waste pile(spoil)pro�ects mcludmg contractor owned or leased borrow prts associated with the pro�ect c Sufficient materials requ�red for stabilizat�on and/or repair of erosion control measures and stormwater routmg and treatment shall be on site at all times 3 No waste spoil solids or fill of any kmd shall occur u►wetlands waters or r�parian areas beyond the footpnnt of the impacts depicted m the 404/401 Pertnrt Application All construction activities mcludmg the design mstallation operation and mamtenance of sediment and erosion control Best Management Practices shall be performed so that no v�olations of state water qualrty standards statutes or rules occur 4 Sediment and erosion control measures shall not be placed m wetlands or waters without prior approval from the Division If placement of sediment and erosion control devices m wetlands and waters �s unavoidable design and placement of temporary erosion control measures shall not be conducted m a manner that may result in dis equ�librium of wetlands or stream beds or banks ad�acent to or upstream and down stream of the above structures All sediment and erosion control devices shall be removed and the natural grade restored wrthin two(2)months of the date that the Div�s�on of Land Resources or locally delegated progam has released the pro�ect 5 Protective Fencmg The outside buffer wetland or water boundary and along the construction corridor wrthm these boundaries approved under this authorization shall be clearly marked with orange warning fencing(or similar high v�sibil�ty material)for the areas that have been approved to mfrmge w�thm the buffer wetland or water prior to any land disturbmg act�vrties Contmum�Compliance 6 The University of North Carolma at Chapel Hill shall conduct construction activities m a manner consistent with State water qualrty standards(mcluding any requtrements resultmg from compliance w�th sect�on 303(d)of the Clean Water Act}and any other appropriate requirements of State law and federal law If the Div�s�on determmes that such standards or laws are not being met (mcludmg the fa�lure to sustam a des�gnated or achieved use)or that State or federal law�s be�ng v�olated or that further condrtions are necessary to assure compliance the Div�sion may reevaluate The Un�verstty of North Carolma at Chapel Hill Page 4 of 8 November 10 2011 and mod�fy this Cert�ficat�on to mclude condit�ons appropr�ate to assure compl�ance with such standards and requirements m accordance w�th 15A NCAC 2H 0507(d) Before modifymg the Certificat�on the Div�s�on shall notify the Umversity of North Carol�na at Chapel Hill and the US Army Corps of Eng�neers provide publ�c not�ce m accordance w�th 15A NCAC 2H 0503 and provide opportunity for publ�c hearing in accordance with I SA NCAC 2H 0504 Any new or rev�sed condrtions shali be provided to the Un�vers�ty of North Carolma at Chapei Hill m wrrtmg shall be provided to the Un�ted States Army Corps of Engmeers for reference m any Permit issued pursuant to Sect�on 404 of the Clean Water Act and shall also become conditions of the 404 Permit for the pro�ect Mrti ahon 7 Compensatory Mitigation Usmg the Ecosystem Enhancement Program(EEP) M�t�gat�on must be provided for the proposed impacts as spec�fied m the table below We understand that you w�sh to make a payment to the Wetlands Restoration Fund administered by the NC Ecosystem Enhancement Program(EEP)to meet this mitigat�on requtrement This has been determmed by the DWQ to be a su�table method to meet the mitigation requ�rement Until the EEP rece�ves and clears your check(made payable to DENR—Ecosystem Enhancement Program Office) no �mpacts spec�fied m this Authorizat�on Cert�ficate shall occur The EEP should be contacted at(919) 716 1921 if you have any questtons concernmg payment mto a restoration fund The m�hgat�on wdl be phased as shown in the table below T e of Wetland Com ensato M�t� at�on Re uired River and Sub basm Number Phase#1 404/Wetlands—n arian 0 005(acres) Ca e Fear/03030002 Stream( erenn�al) 31 (lmear feet) Ca e Fear/03030002 Buffers Zone I 0 00(s uare feet) Ca e Fear/03030002 Buffers Zone II 0 00(s uaze feet) Ca e Fear/03030002 Phase#2 404/Wetlands—n anan 2 407(acres) Ca e Fear/03030002 Stream( erenmal) 347(lmear feet) Ca e Fear/03030002 Buffers Zone I 70 815(s uare feet) Ca e Fear/03030002 Buffers Zone II 21 956(s uare feet) Ca e Feaz/03030002 8 Construchon Stormwater Permrt NCGO 10000 Upon the approval of an Eros�on and Sedimentation Control Plan issued by the D�vis�on of Land Resources(DLR)or a DLR delegated local erosion and sed�mentation control program an NPDES General stormwater permrt(NCGO10000)admmistered by DWQ is automatically issued to the pro�ect This General Permrt allows stormwater to be discharged durmg land disturbing construction activities as stipulated by condrtions m the perm�t If your pro�ect is covered by this perm�t [app(icable to construct�on pro�ects that d�sturb one(1)or more acres] full compliance with permit cond�tions mcluding the sedimentation control plan self monitormg record keepmg and reportmg requ�rements are requtred A copy of this permit and monitormg report forms may be found at htt�//portal ncdenr org/c/document l�brar,�/,�et file�uuid=dl Se7ee8 cb50 443f 9dcf 049b001337ac&groupld=38364 � The Umversity of North Carolma at Chapel Htll Page 5 of 8 November 10 2011 9 Culvert Installation All work m or ad�acent to stream waters shall be conducted m a dry work area Approved BMP measures from the most current version of NCDOT Construction and Mamtenance Act�v�t�es manual (http//www ncdot or doh/operat�onsBMP manuaUdownload/BMP Manual pd� such as sandbags rock berms cofferdams and other diversion structures shall be used to prevent excavation m flowmg water � Culverts required for this pro�ect shall be mstalled in such a manner that the original stream profiles are not altered Existmg stream dimensions(mcludmg the cross section dimensions pattern and longitudmal profile)must be mamtamed above and below locat�ons of each culvert Culverts shall be designed and mstalled to allow for aquatic life movement as well as to prevent head cutting of the streams If any of the existmg ptpes are or become perched the appropriate stream grade shall be re established or if the pipes installed �n a perched manner the pipes shall be removed and re mstalled correctly Culvert(s)shall not be msta.11ed m such a manner that will cause aggadation or eros�on of the stream up or down stream of the culvert(s) Existmg stream dimensions(mcludmg the cross sectton dimensions pattern and longitudmal profile)shall be maintamed above and below locations of each culvert Placement of any new culverts as opposed to extensions of existing culverts and other structures m ' waters streams and wetlands must be placed below the elevation of the streambed by one foot for all culverts with a diameter greater than 48 mches and 20 percent of the culvert diameter for culverts havmg a d�ameter less than 48 mches to allow low flow passage of water and aquatic life Design and placement of culverts and other structures mcludmg temporary erosion control measures shall not be conducted m a manner that may result m dis equilibrium of wetlands or streambeds or banks ad�acent to or upstream and down stream of the above structures The appl�cant�s required to provide evidence that the equilibnum shall be mamtamed if requested m wrrtrng by DWQ The establishment of native woody vegetation and other soft stream bank stabilization techniques must be used where practicable mstead of rip rap or other bank hardemng methods If rip rap is necessary it shall not be placed m the stream bed unless specifically approved by the Division of Water Quahty Installation of culverts m wetlands must ensure continuity of water movement and be designed to adequately accommodate htgh water or flood condrtions Upon completion of the pro�ect the Applicant shall complete and return the enclosed Certificate of Completion form to notify NCDWQ when all work mcluded in the §401 Certification has been completed The responsible party shall complete the attached form and return �t to the 401/Wetlands Unrt of the NC Division of Water Qualrty upon completion of the pro�ect Please send photographs upstream and downstream of each culvert site to document correct installation along wrth the Certrficate of Compdetion form 10 Deed Notifications Deed notificat�ons or s�m�lar mechanisms shall be placed on all retamed�urisdictional wetlands waters and protective buffers m order to assure compliance for future wetland water and buffer �mpact These mechan�sms shall be put m place at the time of recordmg of the property or of mdividual lots whichever�s appropriate A sample deed nottfication can be downloaded from the Wetlands Buffers Stormwater Compliance and Permittmg Unit(WeBSCaPe)web site at The Un�versity of North Carolma at Chapel Hill Page 6 of 8 November 10 2011 http//portal ncdenr or�/c/document library/�et file�uu►d=ef84d0e1 Sfc9 4183 87b5 2�d7eb152e0&groupId=38364 The text of the sample deed notificat�on may be modified as appropriate to surt to this pro�ect 11 Stormwater Management Plan(SMP)Approval Required and Stormwater Approval Phasmg Before the impacts specified m th�s Certification may occur the appl�cant must meet all of the provtsions set forth m the document Protocol for Stormwater Management Plaa (SMP) Approval and Implemeutat�on,available at http//portal ncdenr org/c/document l�brar�get file�uuid=0c509d61 6dd6 4da8 9342 7079fe478688& roupld=38364 SMP approval and implementat�on procedures shall be as follows • The SMP must be approved m wr�tmg by to the Wetlands Buffers Stormwater Compltance and Permittmg(WeBSCaPe) Umt or if the pro�ect�s sub�ect to another state stormwater program or may be revtewed by a certified local government a copy of the approval letter and approved SMP must be submitted before any�mpacts author�zed m th�s certification occur If a development �s phased then the SMP for each future phase must approved by the Wetlands Buffers Stormwater Compliance and Permittmg(WeBSCaPe)Unit or �f the proJect is sub�ect to another state stormwater program or a cert�fied local government a copy of the approval letter and approved SMP must be submitted before any impacts associated wrth that phase may occur • The approved SMP must be constructed and operational before any permanent buildmg or other structure is occupied at the srte If a development is phased then the approved SMP for each future phase must be constructed and operational before any permanent bu�ldmg or other structure assoc�ated w�th that phase is occupied • The approved SMP as well as dramage patterns must be mamtamed �n perpeturty • The SMP may not be modified wrthout pnor written authorizat�on from the SMP approval authorrty If the SMP falls under another state stormwater program then a copy of the approval letter and the modified SMP must be submitted to the 401 Oversight/Express Un�t prior to the commencement of the modifications A final written stormwater management plan for each phase of this proJect shall be subm�tted to for rev�ew and approval No land dtsturbance assoc�ated w�th any phase may be conducted until a stormwater management plan for that phase has been submitted to and approved by the DWQ another State stormwater program or a certified local government No bu�ldmgs associated w�th any phase may be occupied unt�l the stormwater management plan is constructed and operational for that phase If submittmg your plan to DWQ the stormwater management plan submittal must mclude a BMP Supplement Form with all required items The BMPs must be designed to treat runoff from all impervious surfaces mcludmg the road and must comply wrth the version of the NC DENR Stormwater BMP Manual that is in effect on the date of the submittal of the stormwater management plan (SMP) The SMP must meet the requ�rements m the version of SMP Regulations for non DOT in effect at the time of submittal The University of North Carolma at Chapel Hill Page 7 of 8 Navember 10 2011 12 Diffuse Flow All constructed stormwater conveyance outlets shall be directed and maintamed as diffuse flow at non erosive velocities through the protected stream buffers such that it will not re concentrate before dtschargmg mto a stream as identified withm 15A NCAC 2B 0267(5) If this is not possible �t may be necessary to provide stormwater fac�lrties that are considered to remove n�trogen(and phosphorus if m the Tar Paml�co River Basm) This may requ�re addittonal approval from this Office Re o ener Clause 13 Mr Richard Mann and University of North Carolma at Chapel Hill and �ts authorized agents shall conduct its act�vit�es m a manner consistent with State water qualrty standards(includmg any requirements resultmg from compliance with section 303(d)of the Clean Water Act)and any other appropriate requirements of State law and federal law Mr Richard Mann and University of North _ Carolina at Chapel Hill shall require rts contractors(and/or agents)to comply wrth all of the terms of this Cert�fication and shall prov�de each of�ts contractors(and/or agents)a copy of this Certificatton A copy of this Cert�fication shall be mcluded m the construct�on contract and available on the�ob srte at all times If DWQ determmes that such standards or laws are not being met(mcludmg the fatlure to sustatn a designated or achieved use)or that State or federal law is bemg v�olated or that further condrtions are necessary to assure compliance DWQ may reevaluate and modify th�s certification to include condit�ons appropr�ate to assure compliance w�th such standards and requirements m accordance wrth 15A NCAC 02H 0507(d) Before modifymg the certification DWQ shall notify Mr R�chard Mann and Umversity of North Carolma at Chapel Hill and the US Army Corps of Engmeers prov�de public notice m accordance wrth 15A NCAC 02H 0503 and prov�de opportun�ty for public heanng m accordance with 15A NCAC 02H 0504 Any new or revised condrt�ons shall be provided to Mr Richard Mann and Universrty of North Carolina at Chapel Hill m wrrtmg shall be provided to the United States Army Corps of Engtneers for reference m any permit issued pursuant to Section 404 of the Clean Water Act and sha[I also become conditions of the 404 Permtt for the pro�ect 14 Cerhficate of Completion � Upon complet�on of all work approved w�thm the 401 Water Quality Certification or applicable Buffer Rules and any subsequent modifications the applicant is required to return the attached certificate of completion to the Wetlands Buffers Stormwater Compliance and Permitting Umt (WeBSCaPe) North Carolma Division of Water Qualrty 1650 Ma�l Service Center Raleigh NC 27699 1650 The University of North Carolma at Chapel Hill Page 8 of 8 November 10 2011 Also,th�s approval to proceed with your proposed impacts or to couduct�mpacts to waters as dep�cted m your applicat�on shall expire upon exp�ration of the 404 or CAMA Permit If this Certificat�on is unacceptable to you you have the right to an ad�udicatory hearmg upon wr�tten request wrthin sixty(60)days followmg rece�pt of th�s Cert�fication This request must be m the form of a written petrtion conforrnmg to Chapter 150B of the North Carolina General Statutes and filed with the Office of Admmistrative Hearmgs 6714 Mail Service Center Raleigh N C 27699 6714 If modifications are made to an origmal Certification you have the right to an ad�udicatory hearing on the mod�fications upon wr�tten request w�thm sixty(60)days following receipt of the Cert�fication Unless such demands are made th�s Certification shall be final and bmdmg Thts the 10�'day of Novemb 2011 DNIS N OF W LITY � oleen H Sullms 3870 CHS/kah/i�m ��►� �D N� North Carolma Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H Sullms Dee Freeman Governor Director Secretary North Carolina Divis�on of Water Quality 401 Water Qual�ty Cert�ficat�on Summary of Perm�tted Impacts and M�tigat�on Requirements In accordance w�th 15A NCAC 2H 0500 Mr R�chard Mann and Untversity of North Carolina at Chapel Hill who have permtssion to fill or otherw�se�mpact 2 412 acres of 404/Wetland and 622 Imear feet of stream(378 Imear feet permanent impact to stream 70 Imear feet temporary impact to stream and 174 lmear feet permanent�mpact to ephemeral stream)and 23 605 square feet of Zone 1 Jordan Lake protected riparian buffers and 14 637 square feet of Zone 2 Jordan Lake basm protected r�par�an buffers to construct the proposed Carolma North pro�ect(an expans�on of the Unrvers�ty of North Carolma at Chapel H�II campus) which�s located w�thm the northwest and southwest quadrants of the mtersect�on of Martm Luther Ktng Jr Boulevazd and Estes Drrve m the Towns of Chapel H�II and Carrboro Orange County North Carolma All activ�t�es associated wtth these authorized�mpacts must be conducted w�th the conditions I�sted m the attached Permit transmittal letter THIS CERTIF[CATION IS NOT VALID WITHOUT THE ATTACHMENTS COMPENSATORY MITIGATION REQU[REMENTS ECOSYSTEM ENHANCEMENT PROGRAM DWQ PROJECT# 20110260 NC EEP NAME Carohna North LOCATION Chapel H►ll COLlNTY Orange BASIN/SUB BASIN Cape Fear/03020002 As requ�red by i 5A NCAC 2H 0500 and the condrtions of th�s Cert�ficat�on you are requ�red to compensate for the above m�tigable�mpacts through the restorat�on creat�on enhancement or preservation of wetlands surface waters and npartan buffers as outlined below pnor to conductmg any act�vit�es that impact or degrade the waters of the state Note Acreage requ�rements proposed to be mit�gated through the Ecosystem Enhancement Program must be rounded to one quarter acre mcrements and lmear foot requirements must be rounded up to the nearest foot accordmg to 15 2R 0503(b) Im acts M�t� at�on 2 412 Acres Ri ariari Wetlands 2 412 Acres Ri arian Wetlands 378 Lmear Feet of Stream 378 Lmear Feet of Stream 23 605 S uare Feet of Buffer 70 815 S uare Feet of Buffer 14 637 S uaze Feet of Buffer 21 956 S uaze Feet of Buffer One of the opt�ons you have available to satisfy the compensatory m�t�gat�on requ�rement�s through the payment of a fee to the Wetlands Restorat�on Fund per NCAC 2R 0503 If you choose thts opt�on please stgn this form and mail the form along with a copy of your 401 Certificat�on or Buffer Approval to the Ecosystem Enhancement Program at the address below An�nvo�ce for the appropr�ate amount of payment w�ll be sent to you upon rece�pt of th�s form PLEASE NOTE THE ABOVE IMPACTS ARE NOT AUTHORIZED UNTIL YOU RECEIVE NOTIF[CATION THAT YOUR PAYMENT HAS BEEN PROCESSED BY THE ECOSYTEM ENHANCMENT PROGRAM S�gnature Date ECOSYSTEM ENHANCEMENT PROGRAM 1652 Mail Serv�ce Center RALEIGH N C 27699 1652 (919)715 2219 Fdename 110260Carolmallorth(Orange)401_JBR_IC_EEP fetlantls Buffers Stormwater Compliance antl Permitting Unil(WeBSCaPe) �50 Mail Service Center Raleigh North Carolina 27699 1650 hone 919 807 6300 1 FAX 919 807 6494 �lernet http l/porfal ncdenr org�weblwqlws n Equal Opportunity 1 Affirmaiive Action Employer