WQ0018708_Adjudication_20080104

Lake Creek: Corporation
Subject:. Lake Creek Corporation
From: "Oliver, Jane" <[e-mail]>
Date: Thu, 3 Ju12008 11':55:02 -0400
To: "David Goodrich" <[e-mail]>, "Kim Colson'; <[e-mail]>,
"ART BARNHARDT" <[e-mail]>, "Jim Barber�l <[e-mail]>
Lake Crk Corp filed a voluntary dismissal in the case (even though they are still haggling about one condition in
the permit). The case has not been formally closed by OAH but the ALJ's assistant let me know yesterday that
the case was being taken off the docket and that OAH would send out a notice oficlosurenext week.
(Thanks, Dave, for your perseverance and patience — and for keeping meinformed!)
1 of 1 7/7/2008 10:13 AM

Re: Lake Creek Corporation WWTP Permit
Subject: Re: Lake Creek Corporation WWTP Permit
From: David Goodrich <[e-mail]>
Date: Thu, 03 Ju12008 09:21:57 -0400
To: [e-mail]
CC: "Barwick, Brooks" <[e-mail]>, "Dail, Harry" <LHDai1@aolibm>, Jim Barber
<[e-mail]>, ART BARNHARDT <[e-mail]>, "Oliver, Jane"
<[e-mail]> '
b•[e-mail] wrote:
David,
Per our phone conversation yesterday, I am providing youtwith a -few questions
that need to be addressed prior to our moving forward with the Lake Creek
Corporation WWTP expansion design.
1. We are currently reviewing.the different treatment options for
the Lake Creek Corporation WWTP expansion. One option is to
construct a facultative pond. If the facultative pond is
designed for a treatment capacity of 50,000 gallons p'er day, can
it be permitted at a lower rate of 30,000 gallons per, day? Then
later, when the additional capacity is needed, re -rated -for
50,000 gallons. I.
2. The draft permit stated that the complete design of the
expansion shall be submitted sixty (60) days from the date of
the permit. Lake Creek Corporation would like to extend the
time to ninety (120) days.
Please call me if you have any questions.
Brian Cox, PE
Engineering Services, PA
Garner, NC
919-662-7272
Brian,
In response to your questions, a facultative pond designed to;treat 50,000 gallons
per day_can be permitted at a lower rate .of 30,000.gallonsaper day, and subsequently
permitted for its full 50,000 gallons per day capacity. However, its design and
construction would have to conform to the "2T" Regulationsi(15A NCAC 02T)
The permit will be changed to allow ninety (90) days (instead! of 60 days) after the
date of permit issuance for the design plans to be submitted "to the Aquifer
Protection Section for approval.
Please contact me at your earliest convenience regarding the
answers.
David Goodrich
Aquifer Protection Section
adequacy of these
1 of 1 7/7/2008 10:14 AM

STATE OF NORTH c-AROLLNA
COUNTY OF BLADEN
FILED
OFFICE OP
Ai:001001'61E HEARINGS?
100t4lihi 2008
!'
THOOFFICEOF
ADMINISTR4T1YETIEAMGS
08.
Lake Creek Corporation OM • ) . , • 11
Bay Tree Utilities. . )• j '
' Petitioner' - - ' )• II
' I i
II • —
• Vs. 1 .. , D1,0TIqE.cwlzmpigrovbED
,
itiEww
• 1 i' ' -•
N. C. Department of Environment and
Natural Resources, Aquifer Protection
Section, Division of Water Quality
Respondent
II
NOTICEJS ligg,..E;13Y:QINTEN thatthe'llearinOn thivcontested 4ae, previously
scheduled for May 12, 2008;,,it rescheduled
bAtEt Wedndaday; June 11, 2008.
TIME: 9:00 aln
PLACE: Old Cumberland County Courthouse
Room #3
130 GillespieStreet
:Fayetteville, NorthCarolina
ThiMPlItlf,04Y M4Ng0,

Re: Harnett County Utilities WQ0007066
n
Subject: Re: Harnett County Utilities WQ0007066
From: David Goodrich <[e-mail]>
Date: Mon, 23 Jun 2008 13:54:39 -0400
To: Jim Barber <[e-mail]>
Jim Barber wrote:
David;
I'll check the file
Jim Barber
and send to you by scanning and email.
{
BTW, how are things going with Baytree Lakes? I read the'e4i1 traffic
concerning the hearing that was continued. Based on yourcoinmunications and
permit revisions for Baytree; has the need for adjudicatng���the permit been
resolved? 1 it
David Goodrich wrote:
Jim, •
I received your site visit comments regarding this permit!
However, the site maps and -email that were evidently supposed to be attached
to the package never made it to me. Could you send me the site maps and email
in either hard copy form or electronically?
Thanks!
David -
Jim,
As for Baytree Lakes, I was` out of the office last week -on 'vacation, and was
somewhat surprised to find no email or voicemail messages xelatingto this when I
returned to, work this morning. I have been trying to contact the Attorney General's
Office to get an update on this, and it is my most recent understanding that we are
getting very close to a settlement with" this
David
1 of 1
7/7/2008 10:16 AM

Re: Bay Tree Utilities -hearing - continued
Subject: Re: Bay Tree Utilities hearing - continued
From: David Goodrich <[e-mail]>
Date: Mon, 09 Jun 2008 10:27:11 -0400
To: "Oliver, Jane" <[e-mail]>
CC: Kim Colson <[e-mail]>, ART BARNHARDT
<[e-mail]>, Jim Barber <Jim.Barber@ncmailnet>, "Leach, Janet"
<[e-mail]>
!. r
Oliver, Jane wrote:
I received a call from OAR on Friday. The hearing that was scheduled for Wed 6/11
has been continued. Dave and I talked this morning and we both agreed to.'work to
get this case resolved as soon as possible. As you know, lhelhas redrafted the
permit - again- based upon new input from -the utility.
{
In addition to the email/attached latest permit.draft whic1 I!sent to Mr. Barwick_
and copied to everyone this morning, ,I left a voicemail message for_him on his
cellphone voicemail system. I expect to hear from him today.
1 of 1 I 7/7/2008 10:16 AM

Bay Tree Utilities hearing -continued
Subject: Bay Tree Utilities hearing - continued
From: "Oliver, Jane" <[e-mail]>
Date: Mon, 9 Jun 2008 10:21:14 -0400
To: "David Goodrich" <[e-mail]>, "Kim Colson"; <[e-mail]>,
"ART BARNHARDT" <[e-mail]>, "Jim Barber"i, <[e-mail]>
CC: "Leach, Janet" <[e-mail]> j I
I received a call from OAH on Friday. The hearing that was scheduled for Wed 6/11 has been continued. Dave
and I talked this morning and we both agreed to work to get this case resolved:as soon as possible. As you
know, he has redrafted the permit — again -.based upon new input from the utility.
1 of 1 - 7/7/2008 10:17 AM

Re: Revised Bay Tree Lakes Draft Permit
.
Subject: Re: Revised Bay Tree Lakes Draft Permit
From: David Goodrich <[e-mail]>
Date: Mon, 09 Jun 2008 09:35:16 -0400
To: Jim Barber <[e-mail]>
CC: Joel Shields <[e-mail]>
Jim Barber wrote:
David;
Based on this latest, last minuterequest by Baytree, will we still need to have
the hearing Weds morning thellth here in Fayetteville??
Art is out of the office this week, but myself and Joel will be present at the
hearing. Let me know if you plan to come to the Fayetteville office prior to the
-hearing with Jane Oliver or if you wish to meet at the Old Courthouse. The old
courthouse is just a couple hundred yards from our office and is within walking •
distance.
Jim Barber
David Goodrich wrote:
Jim,
Dear Brooks,
1
I have made some changes in the permit draft to allow greater freedom in the
design of the modifications, that are intended for the subject wastewater
treatment system. 1
These changes consist of adding verbage to the beginning of the second
paragraph of the narrative description of Page 1 to allow greater freedom of
design;
and making the changes in the system cited in Permit Condition I.1, less
specific.
Please send your comments to me your earliest convenience.
David Goodrich
Aquifer Protection Section
I contacted -Jane Oliver. of"the AGO a few minutes ago, and she informed me that the
hearing has been officially postponed. However, it is possible that it has only been
postponed for a week or two, so we should work with.Bay Tree to resolve the issues
as soon as possible.
David
1 of 1 1 7/7/2008 10:17 AM

Re: Attachments A, B and C
Subject: Re: Attachments A, B and C
From: David Goodrich <[e-mail]>
Date: Fri, 30 May 2008 07:22:15 -0400
To: BBarwick <[e-mail]>, ART BARNHARDT <[e-mail]>, Jim
Barber <[e-mail]>, Kim Colson <[e-mail], "Oliver, Jane"
<[e-mail]>
'BBarwick wrote:
David
I
We -have received your revised draft'perm'it and appreciate the modifications you
have made. I have inserted the -attachments from your email dated 4-17-08.
Please updated Attachment A indicating your most recent changes.
Sincerely
Brooks Barwick'
Bill Stafford
Brooks,
I,am attaching' the revised Attachment A, which is intended toconform to thelatest
revision of the permit draft. I think that the other two at:tachments'(B and C)-are
:supposed to remain as they are (WQ0018708attB0804.xls_and WQ0018708attC0804.xls).
David Goodrich'
Aquifer Protection Section
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WQ0018708attA080520adjrev x1s i
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1. .,
1 of 1
5/30/2008 11:33 AM

ATTACHMENT A - EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
LAKE CREEK CORPORATION
001 WWTP Effluent
Permit Number: WQ0018708 Version 2.0
EFFLUENT CHARACTERISTICS
EFFLUENT LIMITS
J MONITORING REQUIREMENTS..
Measurement
Frequency
Sample
Type
Parameter Description - PCS Code
Monthly Average
Units
Weekly Average
Units
Daily Maximum
Units
BOD, 5-Day (20 Deg. C) - 00310
-
4 X year
Grab
Solids, Total Suspended - 00530
4 X year
Grab
Nitrogen, Ammonia Total (as N) - 00610
4 X year
Grab
Nitrogen, Nitrate Total (as N) - 00620
4 X year
Grab
Solids, Total Dissolved- 180 Deg.0 - 70300
3 X year
Grab
Chloride,(as CI) - 00940
3 X year
Grab
Nitrogen, Kjeldahl, Total (as N) - 00625
4 X year
Grab '
Nitrogen,.Total (as N) - 00600
4 X year
Grab
pH' - 00400
2 X month
Grab
Chlorine, Total Residual - 50060
2 X month
Grab
Coliform, Fecal MF, M-FC Broth,44.5C - 31616
4 X year
Grab
Flow, in conduit or thru treatmentplant - 50050
20,000
gpd
Continuous
Recorder
002 Expanded WWTP Treatment System Effluent
EFFLUENT CHARACTERISTICS
EFFLUENT LIMITS
MONITORING REQUIREMENTS •.
Parameter Description - PCS Code
Monthly Average
Units
Weekly Average
Units
Daily Maximum
Units
Frequency
Type
Nitrogen, Total (as N) - 00600
4 X year
Grab
BOD, 5-Day (20 Deg. C) - 00310
4 X year -
Grab
Solids,Total Suspended' - 00530
4 X year
Grab
Solids, Total Dissolved- 180 Deg.0 - 70300
3 X year
Grab
Nitrogen, Nitrate Total (as N) = 00620 _.
; - _
__..
=
4-X year - -- -- ----
Grab- ---- _-
Nitrogen, Ammonia Total (as N) - 00610
-, J- -
- _
4 Xyear_ _____
Nitrogen, Kjeldahl, Total (as N) - 00625
4 X year
Grab
Chloride (as CI) - 00940
-
3 X year
Grab
pH - p0400
2 X month
Grab
Chlorine, Total Residual - 50060
2 X month
Grab
Coliform, Fecal MF, M-FC Broth,44.5C - 31616
-
4 X year
Grab
Flow, in conduit or thru treatment plant - 50050"
30,000
gpd,
Continuous
Recorder
3 X year sampling shall be conducted every March, July and November.
4 X'year sampling shall beconducted every March, July, September and November.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
WQ0018708
Attachment A
Page 1 of 1

[Fwd: Re: Bay Tree Utilities; 08 EHR 0030]
Subject: [Fwd: Re: Bay Tree Utilities; 08 EHR 0030]
From: Art Barnhardt <[e-mail]>
Date: Wed, 28 May 2008 16:54:27 -0400
To: Jim Barber <[e-mail]>
Subject: Re: Bay Tree Utilities; 08 EHR 0030
From: David Goodrich <[e-mail]>
Date: Wed, 28 May 2008 07:30:17 -0400
To: "Oliver, Jane" <[e-mail]>, ART BARNHARDT
<[e-mail]>, Jim Barber <Jim.Barber@ncmail:net, Kim Colson
<[e-mail]> Ij
Oliver, Jane wrote:
Dave
•
Hope you had a nice holiday. Any updates on this case? Its seemed like "we" were
yery, very close to a resolution. l
Please let me know when you get- a chance.
Thanks. Jane Oliver
Jane,
I.have modified the draft permit in accordance with the latest internal comments,
and am awaiting the responses of Art and Jim. I realize.tht time is short on this!
David Goodrich j
Aquifer Protection Section
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IRe: Bay Tree Utilities; 08 EHR 0030;,
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1 of 1 ! 7/7/2008 10:17 AM

• FILED
01!10.54. 9.17:
- • ADMINISTRA.-LIVE*AltiNGS.
STATE OF, NORTI-1:CARQLINA,
COuNT OF BLADEN
Lake Creek Corporation dibia
Bay Tree Utilities
Petitioner
VS.
May 13 10 Si 414 .2094
• IN TIE :OkFICE OF
ADMINISTitATIVE'HEARKOS
08:EI-ER :0301
N. C. Department ofEnvironment and
Natural -Resources, Aquifer Protection
Section, Division of 'Water ,Quality
RespOnderit
; ' I.
) NOTICE OF RESCHEDULED
HEARINP,
)
)
)
)
)
, II
NOTICEISi:i.g.ftP3YOWElq*atifidlidAringittthiS),Contdste4 p.i'd.; preyfosly
scheduled for May 12., 2008;-it reSChediiled-sa:s- follows:'
1
DATE: Wednesday, June 11, 2008
TIME: ,9:00 am`
PLACE: Old Cumberland County Courthouse
,100,71#
1,39 GilleSpieStreet
Fayetevilld,
This The 13th day of May, 2008,
;I

Re: Requested changes to Bay Tree Lakes' WQ0018708 Permit
Subject: Re: Requested changes to Bay Tree Lakes' WQ0018708 Permit
From: Jim Barber <[e-mail]>
Date: Mon, 19 May 2008 08:42:01 -0400
To: Kim Colson <[e-mail]>
CC: David. Goodrich <[e-mail]>, ART BARNHARDT
<[e-mail]>
Folks;
In reviewing the FRO file on Baytree Lakes, the following comments are to address Kim Colson's
comments below:
1. The FRO has a as-built/record drawing dated 2/15/08 that addresses the items in I.4.
2. The only stamped, approved plans currently in the regional file are the ones prepared by T. Robert
Lyons dated 22 May 2000, approved 22 August 2001. These plans address4 d the transition of the
facility to non -discharge from NPDES and upgrade the facility from 20,00'0 gpd to 40,000 gpd with
the added infrastructure that Baytree Lakes hasn't constructed/doesn't want to construct.
3.The facility on a daily basis has exceeded 20,000 gpd under the premise that they had a 40,000 gpd
approval (their thinking and reading of the original permit). If you average the month and/or entire
year with the days reported (since they have such a time with keeping the flow meter operational due
to lightning, power surges, breaker problems, etc.) then the facility has exceeded the 20,000 gpd from
the NDMR's that I have looked over with Joel Shields.
4. I concur with this statement.
5. I concur with this statement.
Thanks for -the assistance.
Jim Barber
Kim Colson wrote:
Here are my comments:
• With the description changes to the irrigation system do we need with the map required in I.
4. irrigation as-builts?
• Do we need the specific description for expansion versus waiting until plans are submitted
and approved? Either way, we need to removed the "construction and operation" part of
that paragraph since, as I understand it, they do not currently have approval for these plans
(and therefore construction and operation)
• Do we need to limit them to a time frame for expansion (I. 1.);since flow is limited? Or are
they already over the flow limit (i.e., 20k gpd)?
• It seems that we could simplify I. 1. and just say they need to submit plans for expansion to
30k that meet our requirements.
• I'm not sure I. 2. is needed since plan approval would be in the form of apermit
modification. 1
Jim Barber wrote:
IDavid;
1 of 3
5/28/2008 4:45 PM

Re: Requested changes to Bay Tree Lakes' WQ0018708 Permit
rf
I concur with your comments concerning the last request from Baytree Lakes.
One comment as it relates to section I. - SCHEDULES. Although the facility is limited to
20,000 gpd until modifications to the facility are made and certified by a registered engineer
(I.3), would it be appropriate in this case to add a time limit that all modifications approved
shall be completed within a specified time window (i.e. 180, 270, 360 days etc.)?
1
Condition II.3 should be removed since residuals have been land applied in the past during
the facilities first attempt to modify the facility. I wouldn't want Baytree Lakes to think that
they get another free pass on land application in the future based upon the current
modification that is being negotiated.
Thanks for your assistance.
Jim Barber
David Goodrich wrote:
Everyone,
Upon examining the requested changes to this permit, my comments areas follows:
1) I have no issues with the improvements in the technical description of the facility, as
described by their engineer, Brian Cox. 1,
2) The facility already has a disinfection process that reportedly works as intended. I
recommend that we include the word "continue" in Condition I.1. s',o that it reads:
"Within sixty (60) days of permit issuance, design plans to upgrade, and expand the
treatment system, as described above, shall be submitted to the Aquifer Protection
Section for approval. The design plans will continue to include a disinfection process that
will function as intended by the designer. The plans shall be prepared, signed and sealed
by a Professional Engineer who is licensed in North Carolina."
3) As for measuring the pH and Total Residual Chlorine in the effluent twice a month
instead of weekly, our policy allows a facility of their size to perform monthly
measurements of Total Residual Chlorine if the facility applies only once a month. I think
that we should allow sampling twice a month, with the provision that they will have to
revert to weekly measurements if the data indicate or suggest wide Lange fluctuations.
4) As for performing empirical testing and calibration of the spray system every five
years instead of every year, I think that every five years is too seldom to be of any real
benefit. The purpose of gathering data in this fashion is to verif i the consistency of the
application(s) and subsequently adjust the system as necessary. I would not recommend
testing and calibrating the system any less frequently than once every two years.
Please copy everyone on your comments, and let me know if we should discuss any of
this amongst ourselves to reach a consensus.
Thanks for your help!
2 of 3
5/28/2008 4:45 PM

Re: Requested changes to Bay Tree Lakes' WQ0018708 Permit
David Goodrich
i
3 of 3
5/28/2008 4:45 PM

Baytree Lakes Revisions WQ0018708
' •I
Subject: Baytree Lakes Revisions WQ0018708 j.
From: David Goodrich <[e-mail]>
Date: Mon, 19 May 2008 08:34:53 -0400
To: Kim Colson <[e-mail]>, ART BARNHARDT
<[e-mail]>, Jim Barber <[e-mail]>
Everyone,
I have received the comments on my draft from Kim and Jim, and have modified the draft permit.
Most of their suggested changes have been made to the draft.
I have simplified Condition I.1., and have removed the requirement for them to submit a detailed site
map, with the idea that this requirement can be included in the forthcoming; modified permit, and that
the map that is made at that time can include the as -built construction modifications.
I removed the "residuals application" Condition, as per Jim's recommendation. I think that the
schedule for constructing the modifications would be better included in the forthcoming modified
permit instead of in the present one we are now working on.
I have also included the following sentence in the cover letter:
"Upon approval of the upgrade plans described in the permit, a request to modify this permit shall be submitted
to the Division by the Lake Creek Corporation."
Please examine my modifications and let me know what you think.
Thank you for your help!
David
WQ0018708p080520adjrev.doca
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5/28/2008 4:43 PM

May 20, 2008
D. Stephen Jones, President
Lake Creek Corporation
33 West Bay Ridge Road
Harrells, NC 28444
Dear Mr. Jones:
Michael F. Easley,.Govemor
1' :William G. Ross Jr.; Secretary ..
North Carolina Department of Environment and Natural Resources :.
Coleen H. Sullins; Director '
Division of Water. Quality
Subject: Permit NO.. WQ0018708.
Lake Creek Corporation • .
Wastewater Surface Irrigation'. •
131aden County
In accordance with your application for permit renewal received;; February 10, 2006, we are.
forwarding herewith Permit No. WQ0018708, dated May 20, 2008,to the Lake Creek Corporation for the
continued operation of the subject wastewater treatment and surface irrigation facilities.
This permit shall be effective from the date of issuance until April 30; 2013, -shall void Permit No.
WQ0018708 issued December 12, 2007; and shall be subject to the conditions and limitations as specified
therein.. This. revised permit includes changes discussed during a meeting ;at our. Fayetteville Regional
Office on February 28, 2008. Please 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. Upon approval of the upgrade plans described in
the permit, a request to 'modify. this permit "shall be submitted to the Division by the, Lake Creek
Corporation:
Please note that on September .I, 2006 State.Adniinistrative Code 15A NCAC Subchapter 02T.
Waste not Discharged to. Surface Water was •ado pted: This permit incorporates the requirement of the new
rules. Remember to take the time to review this permit thoroughly, as some of the conditions contained
therein may have been added; changed, or, deleted from thok. in. previously issued permits
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 thirty (30) days following receipt of
this permit. 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,-6714Mail Service..
Center, Raleigh, NC 27699-6714.- Unless such demands are made this permit ;shall be final and binding.
If you need additional information concerning this matter, please contact d ct David Goodrich at (919)
715-6162 or [e-mail].
cc:
Sincerely,
for Coleen H. Sullins
Bladen County Health Department
Fayetteville Regional Office, Aquifer Protection Section
Technical Assistance and Certification Unit
APS. Central Files.
LAU Files
Aquifer Protection. Section . .1636 Mail Service Center..
Internet: www.ncwaterquality.org Location: 2728 Capital Boulevard
An Equal Opportunity/Affirmative Action Employer— 50% Recycled/l0%o Post Consumer Paper
Raleigh; NC 27699-1636.
Raleigh, NC 27604 .;
I
1
Telephone : . • .: [phone]
Fax l:. [phone].
Fax 2: [phone]
Customer Service: [phone]

•
NORTH CAROLINA
ENVIRONMENTAL` MANAGEMENT COMMISSION ..
DEPARTMENT OF. ENVIRONMENT AND. NATURAL RESOURCES
RALEIGH
I
!I
SURFACE IRRIGATION SYSTEM 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 Regu ations
PERMISSION IS HEREBY GRANTED TO
LAKE CREEK CORPORATION
Bladen County .. ;
FOR THE
continued operation of a 20,000 gallon per day. (GPD) wastewater treatment and spray irrigation facility
consisting of an influent flow. monitor, a barscreen, thecontinued use of''a storage lagoon with a volume
of at least thirty (30) days storage, a hypo -chlorite injection system for disinfection prior to irrigation, and
design and submission of plans to construct and operate a 30,000 gallon pert day GPD) expanded system
(10,000)GPD expansion) consisting of an expansion of the existing 20,000 GPD extended aeration system
to a 30,000 GPD unit, a new.sludge holding a hypo -chlorite injection system for -disinfection. prior to
irrigation; raising the berm of the existing lagoon to the site elevation of 95.00 feet, with
385 feet of 6 inch force main, 820 feet of 4 inch force main, 2260 feet of 2 'inch force main, a 5.08 acre..
spray irrigation area covered with coastal Bermuda, six (6). 7.2 gpm forty=nine foot radius and twenty-six
(26)' 19.4 gpm with sixty-five foot radius spray irrigation heads and all associated, piping, valves, and
appurtenances to serve Bay Tree Lakes, with no discharge of wastes to the surface waters, pursuant to the
application received February 10, 2006, .and in conformity with the project plan, 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 April 30, ''2013, shall void Permit No:
W00018708 issued December" 12,2007;and shall be subject to the following specified conditions and
limitations:. .
I: SCHEDULES
1. Design plansto upgrade- and expand the treatment system, as described above; . shall be submitted to
the Aquifer Protection Section for approval: The plans shall beprepared, signed and sealed by a
Professional .Engineer who is licensed in North Carolina.
WQ0018708 Version 2.0.
Shell Version 070531

2. Until an Engineer's Certification is received for the installation of all approved facilities, flow will be
limited to 20,000 GPD. A certification (see attached form) must ;be (received from a professional
engineer certifying that the permitted facility has been installed in accordance with this permit, the
approved plans and specifications, and other supporting. materials including the location of all
monitoring wells as applicable. If this project into be completed in phases and partially certified, you
shall retain the responsibility to track further construction approved under the same permit, and shall
provide a final certificate of completion once the entire project .has been completed. Mail the
Certification to the Aquifer Protection Section, Division of Water Quality, 1636 Mail Service Center,
Raleigh, NC 27699-1636.
3. No later than six (6) months prior to the expiration of this permit, the Permittee shall request renewal
of this permit on official Division form(s). Upon receipt of the request; the Division will review the
adequacy of the facilities described therein, and if warranted, will extend the permit for such period of
time and under such conditions and limitations as it may deem appropriate. Please note that Rule
15A NCAC .02T .0105(d) requires an updated site map to be submitted with the permit renewal
application.
II. PERFORMANCE STANDARDS
1. The surface irrigation facilities shall be effectively maintained and oper11
ated at all times so that there
is no discharge to the surface waters, nor any contravention of groundwater or surface water
standards. In the event that the facilities fail to perform satisfactorily, including the creation of
nuisance conditions or failure of the irrigation area to adequately' assimilate the wastewater, the
Permittee shall take immediate corrective actions including those action that may be required by the
Division, such as the construction of additional or replacement wastewater treatment and disposal
facilities.
The issuance of this permit shall not relieve the Permittee of the responsibility for damages to ground
or surface waters resulting from the operation of this facility.
3. Effluent limitations shall not exceed those specified in Attachment A.
4. Application rate(s), whether hydraulic, nutrient, or other pollutant shall riot exceed those specified in
Attachment B.
{
5. The compliance boundary for the disposal system is specified by rules in 15A NCAC 02L,
Groundwater Classifications and Standards. This disposal system was individually permitted on or
after December 30, 1983; therefore, the compliance boundary is established at either 250 feet from
the waste disposal area, or 50 feet within the property boundary, which!lever is closest to the waste
disposal area. An exceedance of groundwater standards at or beyond the compliance boundary is
subject to remediation action according to 15A NCAC 02L .0106(d)(2) as well as enforcement
actions in accordance with North Carolina General Statute 143-215.6A through 143-215.6C.
6. The Permittee shall apply for a permit modification prior to any sale or transfer of property that
affects a compliance boundary to establish a new compliance boundary. 1,
7. In accordance with 15A NCAC 02L .0107(d), no wells, other than monitoring wells, shall be
constructed within the compliance boundary except as provided .by 15A NCAC 02L .0107(g).
8. The review boundary is established around the disposal systems midway between the compliance
boundary and the perimeter of thewaste disposal area. Any exceedance of standards at the review
boundary shall require action in accordance with 15A NCAC 02L .0106.
9 The facilities permitted herein must be constructed according to the, following setbacks:
WQ0018708 Version 2.0 Shell Version 070531 Page 2 of 9

a. The setbacks for Irrigation sites shall be as follows (all distances, in feet):
i. Any habitable residence or place of public assembly under separate ownership:
ii. Any habitable residence or place of public assembly owned by lithe permittee:
iii. Any private or public water supply source:
iv. Surface waters:
v. Groundwater lowering ditches:
vi. Surface water diversions:
vii. Any well with exception of monitoring wells:
viii.Any property line:
1,
ix. Top of slope of embankments or cuts of two feet or more in 'vertical height:
x. Any water line from a disposal system:
xi. Subsurface groundwater lowering drainage systems:
xii. Any swimming pool:
xiii.Public right of way:
xiv. Nitrification field:
II
xv: Any building foundation or basement: I
b. The setbacks for Treatment and storage units shall be as follows (all distances in feet):
i. Any habitable residence or place of public assembly under separate ownership: 100
ii. Any private or public water supply source: I' 100
iii. Surface waters: 50
iv. Any well with exception of monitoring wells: I. 100
v. Any property line: I! 50
III. OPERATION AND MAINTENANCE REQUIREMENTS
tl
1. The facilities shall be properly maintained and operated at all times. Theifacilities shall be effectively
maintained and operated as a non -discharge system to prevent the discharge of any wastewater
resulting from the operation of this facility. The Permittee shall maintain an Operation and
u Maintenance Plan pursuant to ,15A NCAC 02T .0507 including operational functions, maintenance
schedules, safety measures, and a spill response plan. i,
2. Upon classification of the wastewater .treatment and irrigation facilities 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 facilities in accordance with 15A NCAC 08G 1L0200. The ORC shall visit
the facilities in accordance with 15A NCAC 08G .0200 or as specified, in this permit and shall comply
with all other conditions specified in these rules.
400
200
100
100
100
25
100
150
15
10
100
100
50
20
15
3. A suitable year round vegetative cover of Coastal Bermuda shall be maintained such that crop health
is optimized, allows for even distribution of effluent, and allows inspection of the irrigation system.
4. Adequate measures shall be taken to prevent wastewater ponding or runoff from the irrigation field.
5. Irrigation shall not be performed during inclement weather or when the ground is in a condition that
will cause ponding or runoff. u
6. No application of waste activities shall be undertaken when the seasonal high water table is less than
one foot below land surface.
WQ0018708 Version 2.0 Shell Version 070531
Page 3 of 9

7. All waste application equipment must be tested and calibrated at least, once every two (2) years.
Records of the calibration must be maintained for five years. This testing includes the calibration of
all flow meters, as well as the calibration of the spray equipment itself' (spray guns) in accordance
with the document entitled "Irrigated Acreage Determination Procedures+ for Wastewater Application
Equipment: Stationary Sprinkler System" by the North Carolina Cooperative Extension Service,
available at http://www.bae.ncsu.edu/programs/extension/manure/awm/program/land .ap.htm.
i,
8. No type of wastewater other than that from Bay Tree Lakes shall be irrigated onto the irrigation area.
9. No traffic or equipment shall be allowed on the disposal area except while installation occurs or while
normal maintenance is being performed. Ij
10. Public access to the' land application sites shall be controlled during active site use. Such controls may
include the posting of signs showing the activities being conducted at each site.
11. The residuals generated from these treatment facilities must be disposed 1/ utilized in accordance with
15A NCAC 02T .1100. The Permittee shall maintain a residual management plan pursuant to 15A
NCAC 02T .0508.
12. Diversion or bypassing of the untreated wastewater from the treatment facilities is prohibited.
13. Freeboard in the storage lagoon and daily holding basin shall not be less than two feet at any time.
14. Waste -level gauges, to monitor waste levels in the storage lagoon and daily holding basin, shall be
provided. These gauges shall have readily visible permanent markings indicating the maximum
liquid level at the top of the temporary liquid storage volume, mininiuml liquid level at the bottom of
the temporary liquid storage volume, and the lowest point on top of the dam elevations. Caution must
be taken not to damage the integrity of the liners when installing the gauges.
15. Future spray irrigation fields noted on plans shall be held in reserve.
16. A protective vegetative cover shall be. established and maintained on all earthen basin embankments
(outside toe of embankment to maximum allowable temporary storage elevation on the inside of the
embankment), berms, pipe runs, erosion control areas, and surface water diversions. Trees, shrubs,
and other woody vegetation shall not be allowed to grow on the earthen ,basin dikes or embankments.
Earthen basin embankment areas shall be kept mowed or otherwise controlled and accessible.
IV. . MONITORING AND REPORTING REQUIREMENTS
1. Any monitoring' (including groundwater, surface water, soil or ;plant tissue analyses) deemed
necessary by the Division to ensure surface and ground water protection will be established and an
acceptable sampling reporting schedule shall be followed.
2. All laboratory analyses for effluent, ground waters, or surface waters shall be made by a laboratory
certified by the Division for the required parameter(s) under 15A NCACI02H .0800.
WQ0018708 Version 2.0 Shell Version 070531
Page 4 of 9

:1
3. Flow through the treatment facility shall be continuously monitored,; and daily flow values shall be.
reported on Form NDMR. I,
The Permittee shall install and maintain an appropriate' flow measurement device consistent with
approved engineering and scientific practices to ensure the accuracy and reliability of flow
measurement. Flow measurement devices selected shall be, capable 'of measuring flows with a
maximum deviation of less than 10 percent from true flow, accurately icalibrated at a .minimum of
once per year, and maintained to ensure that the accuracy of the measurements is consistent with the
accepted capability of that type of device. The Permittee shall keep records of flow measurement
device calibration on file for a period of at least three years.` At a minimum, data to be included in
this documentation shall be:
a. Date of flow measurement device calibration,
b. Name of person performing calibration, and
c. Percent from true flow.
4. The effluent from the subject facilities shall be monitored by the Permittee at the frequency(ies) and
location(s) for the parameter(s) specified in Attachment A. Monitorm4 for pH and Total Residual
Chlorine will be performed twice a month, but may be changed to weekly for either parameter, if the
Division determines that the data for that parameter indicate or suggest wide range fluctuations.
5. The Permittee tracking the amount of wastewater disposed shall maintain adequate records. These
records shall include, but are not necessarilylimited to, the following information::
I
a. Date of irrigation,
b. Volume of wastewater irrigated,
c. Field irrigated,
d. Length of time field is irrigated,
e. Continuous weekly, monthly, and year-to-date hydraulic (inches/acre) loadings for each field,
f. Continuous monthly and year-to-date loadings for any non -hydraulic parameter specifically
limited in Attachment B for each field,
g. Weather conditions, and
h. Maintenance of cover crops.
6. Freeboard (waste level to the lowest elevation on the top of the embankment) in the the storage
lagoon and daily holding basin shall be recorded weekly.
7. Monitor wells shall be sampled at the frequencies :and for the parameters specified in Attachment
All mapping, well construction forms, well abandonment forms, and monitoring data shall refer to the
permit number and the well nomenclature as provided in Attachment C and Figure 2.
8. Two (2) copies of the results of the sampling and analysis must be received on Form GW-59.
(Groundwater Quality Monitoring: Compliance Report Form), along with attached copies of
laboratory analyses, by the Division of Water Quality, Information ;Processing Unit„ 1617 Mail
Service Center, Raleigh, North Carolina 27699-1617 on or before the last working day of the month
following the sampling month. Form GW-59 shall include the :number of this permit and the
appropriate well identification number. One Form GW-59a certificate i�n form shall be provided for
each set of sampling results submitted.
WQ0018708 Version 2.0 Shell Version 070531
Page 5 of 9

9. Three (3) copies of all monitoring data [as specified, in Conditions N. 3. and N. 4.] on Form NDMR
for each PPI and three (3) copies of all operation and disposal records [as specified in Conditions N.
5 and N. 6.] on Form NDAR-1 for every field shall be submitted on or before the last day of the
following month. If no activities occurred during the monitoring month, monitoring reports are still
required documenting the absence of the activity. All information shall be submitted to the following
address:
Division of Water Quality
Information Processing Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
10. An annual representative soils analysis (Standard Soil Fertility Analysis) shall be conducted on each
irrigation field and the results maintained on file by the Permittee for a minimum of five years. The
Standard Soil Fertility 'Analysis shall include, but is not necessarily limited to, the following
parameters:
Acidity
Manganese
11 Potassium
Calcium
Percent Humic Matter
1j Sodium
Copper
pH
Zinc
Magnesium
Base Saturation (by calculation)
', Phosphorus
Cation Exchange Capacity
Exchangeable Sodium Percentage
11. Noncompliance Notification:
The Permittee shall report by telephone to the Fayetteville Regional Office, telephone number (910)
433-3300, 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 at the wastewater treatment facility which results ii the treatment of significant
amounts of wastes which are abnormal in quantity or characteristic; such as the dumping of the
contents of a sludge digester; the known passage of a slug of hazardous substance through the
facility; or any other unusual circumstances including ponding in the irrigation field or runoff
from the irrigation fields. '
b. Any process unit failure, due to known or unknown reasons, that render the facility incapable of
adequate wastewater treatment such as mechanical or electrical 'failures of pumps, aerators,
compressors, etc.
c. Any failure of disposal system resulting in a by-pass directly to receiving waters.
d. Any time that self -monitoring information indicates that the facility has gone out of compliance
with its permit limitations including, but not limited to, freeboard measurements, effluent
limitations, exceedances of groundwater standards, or overloading of any field.
For any emergency that requires immediate reporting (e.g., discharges, to surface waters, imminent
failure of a storage structure, etc.) outside normal business hours must be reported to the Division's
Emergency Response personnel at telephone number [phone], [phone], or (919) 733-
3300. Persons reporting such occurrences by telephone shall also file a written report in letter form
within five (5). 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.
V. INSPECTIONS
1. Adequate inspection and maintenance shall be provided by the Permittee to ensure proper operation
of the subject facilities.
WQ0018708 Version 2.0 Shell Version 070531 Page 6 of 9

2. The Permittee or his designee shall inspect the wastewater treatment and!disposal facilities 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 keep 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 upon request to the Division or other permitting authority:.
3. 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 disposal site or
facility at any reasonable time for the purpose of determining compliance with this permit; may
inspect or copy any records that must be maintained under the terms and conditions of this permit,
and may obtain samples of groundwater, surface water, or leachate.
VI. GENERAL CONDITIONS
1. 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 Statute 143-
215.6A to 143-215.6C.
2. This permit shall become voidable unless the facilities are constructed in accordance with the
conditions of this permit, the approved plans and specifications, and other supporting data.
3. This permit is effective only with respect to the nature and volume 1 of wastes described in the
application and other supporting data. No variances to applicable rules governing the construction
and / or operation of the permitted facilities are granted unless specifically requested and granted in
this permit.
4. The issuance of this permit "does not exempt the Permittee from complying with any and all statutes,
rules, regulations, or ordinances, which may be imposed by other government agencies (local, state,
and federal) that have jurisdiction. Of particular concern to the Division are applicable river buffer
rules in 15A NCAC 02B .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 02B .0200 and 02H .0500.
5. In the event there is a desire for the facilities to change ownership, or there is a name change of the
Permittee, a formal permit request must be submitted to the Division op official Division form(s),
documentation from the parties involved, and other supporting materials as may be appropriate. The
approval of this request will be considered on its merits and may . or ;}nay not be approved. The
Permittee of record shall remain fully responsible for compliance until a permit is issued to the new
owner.
6. The Permittee shall retain a set of approved plans and specificationsifor the lifeofthe facilities
permitted herein. 1:
7. The Permittee shall maintain this permit until all permitted facilities *rein are properly closed or
permitted under another permit issued by the appropriate permitting authority.
WQ0018708 Version 2.0 Shell Version 070531 Page 7 of 9

The Permittee must pay the annual fee within thirty (30) days after being billed by the Division:.
Failure to pay the fee accordingly maycause. the Division to initiate action to, revoke this permit
pursuant to 15A NCAC 02T`.0105(e).
Permit issued this the 20th of May, 2008.,
NORTHCAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
Coleen H:.Sullins, Director. '
Division of Water .Quality
By Authority of the. Environmental Management Commission
WQ0018708 Version 2.0
Shell Version 070531.

materials.
Permit No: WQ0018708
12/12/2007
ENGINEER'S CERTIFICATION
Partial Final
, 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 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 tube built within substantial
compliance and intent of this permit, theapproved plans and specifications, and other supporting
Signature
Registration No.
WQ0018708 Version 2,0.
Shell Version 070531

ATTACHMENT A - LIMITATIONS' AND MONITORING REQUIREMENTS
. PPI-### - PPI NAME
Permit Number: WQ00##### Version: #.#
•
EFFLUENT CHARACTERISTICS
EFFLUENT LIMITS
MONITORING REQUIREMENTS
Parameter Description - PCS 'Code
Monthly Average
Weekly Average.
Daily Maximum
Measurement
Frequency
Sample
Type
WQ00#####;Version #.#
Attachment A
Page 1. of 2

THIS PAGE BLANK
WQ00##### Version #.#
Attachment A
Page 2 of 2

•
ATTACHMENT B - APPROVED LAND APPLICATION SITES AND LIMITATIONS _ Permit Number:.WQ00#####
PERMITTEE —.FACILITY
UTILIZATION AREA INFORMATION
Version: #.#
APPLICATION LIMITATIONS
Field/
Basin
Owner
County
Latitude
Longitude
Net
Acreage
Dominant
Soil Series
Parameter •
Rate
Yearly.
Max
Units
Total
WQ00##### Version #.#
Attachment B
Page 1 of 2

THIS PAGE BLANK
WQ00#####. Version #.#
Page 2 of 2.

ATTACHMENT C — GROUNDWATER MONITORING AND LIMITATIONS Permit Number: WQ00#####
Monitoring wells: MW-!, MW-2, ETC.
Version: #.#
GROUNDWATER CHARACTERISTICS
GROUNDWATER STANDARDS
MONITORING REQUIREMENTS
Parameter Description.- Parameter Code
Daily Maximum
Frequency:Measurement
Sample Type
Footnotes -
a: 3 X year monitoring shall be conducted in March, July & NOvember;:Annual monitoring shall be conducted every November.
The measurement of water levels shall be made prior to purging the Wells. The depth to water in each well shall be measured from the surveyed point on the top of the casing. The measurement
Of pH shall be made after purging and prior to sampling for the remaining parameters ' •
c. The measuring points (top of well casing) of all monitoring wells shall be surveyed to provide the relative elevation of the measuring Point for each monitoring well. The measuring points (top
of casing) of all monitoring wells shall be surveyed relative to a common datum.
Volatile Organic Compounds (VOC) 7 In November only analyze by one of the following methods
Standard Method 6230D, PQL at 0.5 µg/L or less • , . •
2. : Standard Method 62-10D, PQL at 0.5 µg/L or less
3. EPA Method 8021, Low Concentration, PQL at 0.5 µg/L or less
4. EPA Method 8260,,Low Concentration, PQL-at-0.5- µg/L orless-
5. Another method with prior approval by the Aquifer Protection Section Chief _ _ _
Any method used must meet the following qualifications:,
a: A laboratory must be DWQ certified to run any method used.
b. The method used must, at a minimum, include all the constituents listed in Table VIII of Standard Method 6230D.
The method used must provide a PQL 140.5 µg/L or less that must be supported by laboratory proficiency studies as required by the DWQ Laboratory Certification Unit Any constituents
detected above the MDL but below the PQL of 0:5 µg/L must be qualified (estimated) and reported.
e. If any volatile organic compounds (VOC) are detected as a result of monitoring as provided in Attachment C, then. the REGIONAL OFFICE Regional Office Aquifer Protection Supervisor,
telephone number (YYY) YYY YYYY, must be contacted immediately for further instructions regarding any additional follow-up analyses required.
f. If TOC concentrations greater than 10 mg/1 are detected in any downgradient monitoring 'well, additional sampling and analysis • must be conducted to identify the individual constituents
comprising this TOC condentration. If the TOC concentration as measured in the background Monitor well exceeds 10 mg/I, this concentration will be taken to represent the naturallY,occurring
TOC concentration. Any exceedances Of this naturally occurring TOC concentration in the downgradient Wells shall be subject to the additional sampling and analysis as described above.
Monitoring wells shall be reported consistent with the nomenclature and location information provided in Figure ¥ and this attachment
g.
WQ09##### Version #.1t Attachment C Page 1 of 1
.

Re: Requested changes to Bay Tree Lakes' WQ0018708 Permit
Subject: Re: Requested changes to Bay Tree Lakes' WQ0018708 Permit
From: Jim Barber <[e-mail]>
Date: Fri, 16 May 2008 15:15:19 -0400
To: David Goodrich <[e-mail]>
CC: Kim Colson <[e-mail]>, ART BARNHARDT
<[e-mail]>
David;
I concur with your comments concerning the last request from Baytree Lakes.
One comment as it relates to section I. - SCHEDULES. Althoughllthe facility is
limited to 20,000 gpd until modifications to the facility are'Imade and certified by
a registered engineer (I.3), would it be appropriate in this case to add a time
limit that all modifications approved shall be completed within a specified time
window (i.e. 180, 270, 360 days etc.)?
Condition 1I.3 should be removed since residuals have been land applied 'in the past
during the facilities first attempt to modify the facility. Iiwouldn't want Baytree
Lakes to think that they get another free pass on land application in the future
based upon the current modification that is being negotiated.',
Thanks for your assistance.
Jim Barber
David Goodrich wrote:
Everyone,
Upon examining
1) I have no
facility, as described by their engineer, -Brian Cox.
the requested changes to this permit, my comments are as follows:
issues with the improvements in the technical description of the
2) The facility already has a disinfection process that reportedly works as
intended. I recommend that we include the word "continue" inCondition I.1. so
that it reads: "Within sixty (60) days of permit issuance, design plans to
upgrade and expand the treatment system, as described above,1 shall be submitted
to the Aquifer Protection Section for approval. The design plans will continue to
include a disinfection process that will function as intended by the designer.
The plans shall be prepared, signed and sealed by a Professi'pnal Engineer who is
licensed in North Carolina."
3) As for measuring the pH and Total Residual Chlorine in,the effluent twice a
month instead of weekly, our policy allows a facility of their size to perform
monthly measurements of Total Residual Chlorine if the faciliity applies only once
a month. I think that we should allow sampling twice a month!, with the provision
that they will have to revert to weekly measurements if the ,data indicate or
suggest wide range fluctuations. ;1
4) As for performing empirical testing and calibration of the spray system every
five years instead of every year, I think that every five years is too seldom to
be of any real benefit. The purpose of gathering data in this fashion is to
verify the consistency of the application(s) and subsequently adjust the system
as necessary. I would not recommend testing and calibrating the system any less
frequently than once every two years.
Please copy everyone on your comments, and let me know if we should discuss any
of this amongst ourselves to reach a consensus.
Thanks for your help!
David Goodrich
1 of 1 5/28/2008 4:46 PM

Re: Lake Creek Corp
Subject: Re: Lake Creek Corp
From: David Goodrich <[e-mail]>
Date: Fri, 16 May 2008 11:50:59 -0400
To: "Oliver, Jane" <[e-mail]>
CC: ART BARNHARDT <[e-mail]>, Jim Barber
<[e-mail]>, "Leach, Janet" <[e-mail]>, Kim Colson
<[e-mail]> •
Oliver, Jane wrote:
See attached Notice of Hearing
Everyone,
[
The hearing has been re -scheduled for June llth, which is less than four weeks away
, J
and after a major holiday weekend
Please email your comments to me at your earliest convenience regarding the draft
permit that I sent out the other day so that we can discuss the changes as needed.
Thank you.
David Goodrich
Aquifer Protection Section
" \
1 of 1
7/7/2008 10:17 AM

RE: [Fwd: Additional Request]
•
Subject: RE: [Fwd: Additional Request]
From: 'Oliver, Jane" <[e-mail]>
Date: Thu, 15 May 2008 11:24:01 -0400
To: "David Goodrich" <[e-mail]>, "Kim Colson", <Kim:[e-mail]>,
"ART BARNHARDT" <[e-mail]>, "Jim Barber"j<[e-mail]>,
"Leach, Janet" <[e-mail]>
Dave, thanks for sending me all the info. rget the sense .that both
sides are working to find a resolution and that you might be close..
Appreciate it! Jane
Original Message
From: David Goodrich [mailto:[e-mail]]
Sent: Thursday, May 15, 2008 7:54 AM
To: Kim Colson; ART BARNHARDT; Jim Barber; Leach, Janet; Oliver, Jane
Subject: [Fwd: Additional Request]
1 of 1
7/7/2008 10:17 AM

Requested changes to Bay Tree Lakes' WQ0018708 Permit
Subject: Requested changes to Bay Tree Lakes' WQ0018708 Permit 1.
From: David Goodrich <[e-mail]>
Date: Thu, 15 May 2008 08:34:16 -0400
To: Kim Colson <[e-mail]>, ART BARNHARDT
<[e-mail]>, Jim Barber <[e-mail]>
Everyone,
Upon examining the requested changes to this permit, my comments are as follows:
1) I have no issues with the improvements in the technical description of the
facility, as described by their engineer, Brian Cox.
2) The facility already has a disinfection process that reportedly works as
intended. I recommend that we include the word "continue" in Condition I.1. so that
it reads: "Within sixty (60) days of permit issuance, design plans to upgrade and
expand the treatment system, as described above, shall be submitted to the Aquifer
Protection Section for approval. The design plans will continue to include a
disinfection process that will function as intended by the 'designer. The plans shall
be prepared, signed and sealed by a Professional Engineer who is licensed in North
Carolina."
3) As for measuring the pH and Total Residual Chlorine in the effluent twice a month
instead of weekly, our policy allows a facility of their size to perform monthly
measurements of Total Residual Chlorine if the facility applies only once a month.
I think that we should allow sampling twice a month, with the provision that they
will have to revert to weekly measurements if the data indicate or suggest wide
range fluctuations.
4) As for performing empirical testing and calibration of the spray system every
five years instead of every year, I think that every five years is too seldom to be
of any real benefit. The purpose of gathering data in this fashion is to verify the
consistency of the application(s) and subsequently adjust t'he'system as necessary.
I would not recommend testing and calibrating the system any less frequently than
once every two years.
Please copy everyone on your comments, and let me know if we should discuss any of
this amongst. ourselves to reach a consensus.
Thanks for your help!
David Goodrich
1 of 1 5/28/2008 4:44 PM

FILED:
'ADMINISTRATIVEHEARINGS'
;May 13 ,1051°ANI :2U08
STATE OF NORTH CAROLINA;
COUNTY OF BLADEN
IN THE $FFICE OF
ADMINISTRATIVE HEARINGS
08 EHR 003A
Lake Creek Corporation d/,b/a
Bay Tree Utilities
Petitioner
vs.
N C, Department of Environment and
Natural Resources, Aquifer'Protection
Section, Division: of Water Quality
Respondent
NOTICE OF:RESCHEDULED.
HEARING:
NOTICE IS HEREBY GIVEN that the:hearing n this contested case, previously
scheduled for May 12, 2008; is scheduled as'follows: ;1
DATE: Wednesday, June 11,190,8
TIME; 9:00. am
PLACE: 'Old Cumberland CountyCourt raise (-
Room #3
130 Gillespie Street'
_Fayetteville,North" Carolina
This the 13thday -of May, 2008.

RE: Bay Tree hearing continued to week of 6/9
iy
Subject: RE: Bay Tree hearing continued to week of 6/9
From: "Oliver, Jane" <[e-mail]>
Date: Tue, 13 May 2008 14:58:50 -0400
To: "David Goodrich" <[e-mail]>, "Art Barnhardt"
<[e-mail]>
CC: "Kim Colson" <[e-mail]>, "Jim Barber" <[e-mail]>
Thanks, everyone! Sounds like things are moving along. Dav, I will
review any documents you send me. Please keep me informed about any
concerns you might have, status, etc. THANKS!
Art, I think you should come back in during another vacation
week
(presumably the reason you'll be out) to go to court! I'm still
impressed about your dedication in the freedman farms case. By the way,
I called OAH today and the case has been tentatively set for 5/28 - but
they have not been able to find a room for the hearing. Theylare still
working on it.
Original- Message
From: David Goodrich [mailto:[e-mail]]
Sent: Tuesday, May 13, 2008 8:15 AM
To: Art Barnhardt
Cc: Oliver, Jane; Kim Colson; Jim Barber
Subject: Re: Bay Tree hearing continued to week of 6/9
Art Barnhardt wrote:
Jane:
I will not be 'available any of that week. Plus I do not think I will
be needed because I was not involved in any direct manner. Call if we
need to talk.
On settling, should be able to if the petitioners do what they
indicated they would do in a technical discussion meeting ajwhile
back. I do not know if we should expect them to come through on their
pledge to address their problems or not. I do not see where:they have
submitted a new application which is what we are basically needing. Am
I on the right page Jim, David, .Kim?
ArtB.
Oliver, Jane wrote:
The Lake Creek Developers d/b/a Bay Tree Utilities hearing has been
continued to the week of June 6. It has also been reassigned to an
ALJ (Webster) who is not likely to give us another continuance.
Is there a way that we can settle this case before the hearing? -No
rush - just get back with me when you can.
Thanks. Jane
Everyone,
The status of this situation is that I sent the revised draft of the
permit with its three Attachments to Brooks Barwick on April 17.
One week ago today, I spoke with him by telephone and he informed me
that he had been out of his office for a week and had not yet had the
opportunity to examine the documents in depth. He had, however;
forwarded the documents to Bill Stafford, the ORC, who reportedly has
some comments and wants some changes. They intend to contact their
consulting engineer, Brian Cox, regarding the design plans, schedule for
1 of 2 7/7/2008 10:18 AM

RE: Bay Tree hearing continued to week of 6/9
construction, etc. and to get back to us very soon.
I told Mr. Barwick that the best way to handle the Changes that Bill
desires is to send us all a detailed email that explicitly states their
requested revisions so that we can discuss them and respond to them.
I intend to contact Brooks today (5/13) to check on the status of their
response to our draft, and will update you immediately'as soon as I know
anything.
David Goodrich
2 of 2 7/7/2008 10:18 AM

Re: Bay Tree hearing continued to week of 6/9
N
Subject: Re: Bay Tree hearing continued to week of 6/9
From: David Goodrich <[e-mail]>
Date: Tue, 13 May 2008 10:21:58 -0400
To: Art Barnhardt <[e-mail]> -
CC: "Oliver, Jane" <[e-mail]>, Kim Colson <[e-mail]>, Jim Barber
<[e-mail]>
Art Barnhardt wrote:
Jane:
I will not be available any of that week. Plus I do not think I will be needed
because I was not involved in any direct manner. Call if we!need to talk.
On settling, should be able to if the petitioners do what they indicated they
would do in a technical discussion meeting a while back. I do not know if we
should expect them to come through on their pledge to address their problems or
not. I do not see where they have submitted a new application which is what we
are basically needing. Amon the right page Jim, David,' Kim?
ArtB.
Oliver, Jane wrote:
The Lake Creek Developers d/b/a Bay Tree Utilities hearing has been continued
to the week of June 6. It has also been reassigned to an ALJ (Webster) who is
not likely to give us another continuance.
Is there a way that we can settle this case before the hearing? No rush - just
get back with me when you can.
Thanks. Jane
Everyone,
I just reached Brooks Barwick by telephone, and he told me that he will be meeting
with Bill Stafford tomorrow to discuss the permit draft and will sending us an email
describing requested changes and comments.
I am expecting to receive the email tomorrow (5/14), and willlforward it to all of
you if he does not copy it to you.
David Goodrich
1 of 1 I 7/7/2008 10:18 AM

Re: Bay Tree hearing continued to week of 6/9
Subject: Re: Bay Tree hearing continued to week of 6/9
From: David Goodrich <[e-mail]>:
Date: Tue, 13 May 2008 08:15:16 -0400
To: Art Barnhardt <[e-mail]>
CC: "Oliver, Jane" <[e-mail]>, Kim Colson <[e-mail]>, Jim Barber
<[e-mail]>
Art Barnhardt wrote:
Jane: ;
I will not be available any of that week. Plus I do not think I will be needed
because I was not involved in any direct manner. Call if weneed.to talk.
On settling, should be able to if the petitioners do what they indicated they
would do in a technical discussion meeting 'a while back. I do not know if we
should expect them to come through on their pledge to address their problems or
not. I do not see where they have submitted a new application which is what we
are basically needing. Am I on the right page Jim, David, Kim?
ArtB.
Oliver, Jane wrote:
The Lake Creek Developers d/b/a Bay Tree Utilities hearing has been continued
to the week of June 6. It has also been reassigned to an ALJ (Webster) who is
not likely to give us another continuance.
Is there a way that we can settle this case before the hearing? No rush - just
get back with me when you can.
Thanks. Jane
Everyone,
The status of this situation is that I sent the revised draft of the permit with
its three Attachments to Brooks Barwick on April 17.
One week ago today, I spoke with him by telephone and he informed me that he had
been out of his office for a week and had not yet had the opportunity to examine
the documents in depth. He had, however, forwarded the documents to Bill Stafford,
the ORC, who reportedly has some comments and wants some changes. They intend to
contact their consulting engineer, Brian Cox, regarding the design plans, schedule
for construction, etc. and to get back to us very soon.
I told Mr. Barwick that the best way to handle the changes that Bill desires is to
send us all a detailed email that explicitly states their requested revisions so
that we can discuss them and respond to them.
it
I intend to contact Brooks today (5/13) to check on the status' of their response to
our draft, and will update you immediately as soon as I know anything.
David Goodrich
1 of 1
7/7/2008 10:18 AM

Re: Bay Tree hearing continued to week of 6/9
Subject: Re: Bay Tree hearing continued to week of 6/9
From: Art Barnhardt <[e-mail]>
Date: Mon, 12 May 2008 16:32:08 -0400
To: "Oliver, Jane" <[e-mail]>,'Kim Colson <[e-mail]>, DAVID
GOODRICH <[e-mail]>, Jim Barber <[e-mail]>
Jane:
I will not be available any of that week. Plus I do not thinlOI will be needed
because I was not involved in any direct manner. Call if we need to talk.
On settling, should be able to if the petitioners do what the indicated they would
do in a technical discussion meeting a while back. I do not know if we should
expect them to come through on their pledge to address their problems or not. I do
not see where they have submitted a new application which is what we are basically
needing. Am Ion the right page Jim, David, Kim?
ArtB.
Oliver, Jane wrote:
The Lake Creek Developers d/b/a Bay Tree Utilities hearing has been continued to
the week of June 6. It has also been reassigned to an ALJ (Webster) who is not
likely to give us another continuance.
Is therea way that we can settle this case before the hearing? No rush - just
get back with me when you can.
Thanks. Jane
1 of 1 7/7/2008 10:18 AM

RE: Lake Creek Dev d/b/a Bay Tree Utilities
Subject: RE: Lake Creek Dev d/b/a Bay Tree Utilities
From: "Oliver, Jane" <JOLIVER@ncdoj:gov>
Date: Tue, 6 May 2008 09:43:11 -0400
To: "Kim Colson" <[e-mail]>
CC: "David Goodrich" <[e-mail]>, "Art Barnhardt"
<[e-mail]>, <[e-mail]>
Excellente!!! Thanks for the quick response. I'm off to Wilimington.
From: Kim Colson [mailto:[e-mail]]
Sent: Tuesday, May 06, 2008 9:02 AM
To: Oliver, Jane
Cc: David Goodrich; Art Barnhardt; [e-mail]
Subject: Re: Lake Creek Dev d/b/a Bay Tree Utilities
No
Oliver, Jane wrote:
Do any of you oppose my trying to continue the hearing in this matter?
1 of 1 7/7/2008 10:18 AM

Re: Lake Creek Adjudication WQ0018708
Subject: Re: Lake Creek Adjudication WQ,0018708
From: David Goodrich <[e-mail]>
Date: Fri, 07 Mar 2008 07:11:36 -0500
To: Jim Barber <[e-mail]>
CC: Art Barnhardt <[e-mail]>
Jim Barber wrote:
David;
Your comments look fine and address all issues discussed. By the way, did Kim C.
received the NPDES permit for Town of White Lake that I faxed the afternoon of 28
Feb? If you need a hard copy mailed to your attention (if the fax copy is of poor
quality), let me know and I will send the copy I have for the AP files.
Jim Barber
David Goodrich wrote:
Everyone,
I have been in contact with Jane Oliver of the AJO and the hearing date is
approximately two months away. We may be able to resolve the issues
associated with this permit before that time.
Pursuant to our meeting at the FRO last week with the Lake Creek
representatives, I am summarizing our progress and resolutions herewith:
1) We are going to change the PPI Effluent Sampling Schedule of 4 times a year
to agree with the 3 times a year sampling schedule and the groundwater
sampling schedule. This will mean that "4 X/year" will be, March, July,
September, and November. The schedule of "3 X/year" and the groundwater
sampling schedule will both remain the same, as March, July, and November
2) The Permittee's commitment to stay with grab sampling instead of composite
sampling will force their permit to be limited to an effluent flow of 30,000
gallons or less, and they understand this limitation.
3)The Permittee is reluctant to sample the effluent 5 times a week, and the
ORC claims that the Town of White Lake's NPDES permit (upon which our
sampling policies are based) requires monitoring for pH and Chlorine only once
a week. We are going to look into this reported conditionjby examining the
NPDES permit.
4)We intend to remove the pH limits from Attachment A.
it
5) Permit Condition III.7 of the 12/12/07 permit requires the testing and
calibration of all waste application equipment at least once a year. The
Permittee wants this requirement restricted to the flow meters. However, the
intent of this Condition is to include the flow meters and the performance of
a field calibration (in accordance with a Cooperative Extension Guidance
Document) that will empirically calibrate the spray guns by using catch cans,
etc. We may expand the existing Permit Condition to include explicit reference
to this document to add clarification.
6) The (revised) design requirements of the plant will include a disinfection
process that will have to work as intended by the designer. There are
presently no requirements for the plant to achieve secondary or tertiary
standards of wastewater treatment.
7) Everyone anticipates that it will require their design engineer, Brian Cox,
at least 30 days to design the expansion of the system.
8) We intend to change the current permit to reflect the changes and
resolutions described herein.
We plan to create a revised permit and send the draft to Lake Creek for their
1 of 2 7/7/2008.10:20 AM

Re: Lake Creek Adjudication WQ0018708
approval.
9)In the future, after Brian Cox has completed his design plans for the
expansion of the system, the.Lake Creek people will submit a permit
modification request that reflects these upgrades.
Please let me know if I have missed anything! Thank you for your assistance.
David Goodrich
Thanks, Jim. I will check with Kim on the status of that fax transmission - I don't
know if he received it.
David
2 of 2 7/7/2008 10:20 AM

Lake Creek Adjudication WQ0018708
Subject: Lake Creek Adjudication WQ0018708
From: David Goodrich <[e-mail]>
Date: Thu, 06 Mar 2008 11:14:27 -0500
To: ART BARNHARDT <[e-mail]>, Jim Barber
<[e-mail]>, Kim Colson <[e-mail]>
Everyone,
I have been in contact with Jane Oliver of the AJO and the hearing date is
approximately two months away. We may be able to resolve the issues associated with
this permit before that time.
Pursuant to our meeting at the FRO last week with the Lake Creek representatives, I
am summarizing our progress and resolutions herewith:
1) We are going to change the PPI Effluent Sampling Schedule of 4 times a year to
agree with the 3 times a year sampling schedule and the groundwater sampling
schedule. This will mean that "4 X/year" will be March, July,)September, and
November. The schedule of "3 X/year" and the groundwater sampling schedule will both
remain the same, as March, July, and November.
2) The Permittee's commitment to stay with grab sampling instead of composite
sampling will force their permit to be limited to an effluent1flow of 30,000 gallons
or less, and they understand this limitation. it
3)The Permittee is reluctant to sample the effluent 5 times alweek, and the ORC
claims that the Town of White Lake's NPDES permit (upon whichlour sampling policies
are based) requires monitoring for pH and Chlorine only once a week. We are going to
look into this reported condition by examining the NPDES permit.
4)We intend to remove the pH limits from Attachment A.
5) Permit Condition III.7 of the 12/12/07 permit requires theItesting and
calibration of all waste application equipment at least once a year. The Permittee
wants this requirement restricted to the flow meters. However; the intent of this
Condition is to include the flow meters and the performance of a field calibration
(in accordance with a Cooperative Extension Guidance Document) that will
empirically calibrate the spray guns by using catch cans, etc. We may expand the
existing Permit Condition to include explicit reference to this document to add
clarification.
6) The (revised) design requirements of the plant will include a disinfection
process that will have to work as intended by the designer. Tliere are presently no
requirements for the plant to achieve secondary or tertiary, standards of wastewater
treatment.
7) Everyone anticipates that it will require their design engineer, Brian Cox, at
least 30 days to design the expansion of the system.
8) We intend to change the current permit to reflect the changes and resolutions
described herein.
We plan to create a revised permit and send the draft to Lake treek for their
approval.
9)In the future, after Brian Cox has completed his design plans for the expansion of
the system, the Lake Creek people will submit a permit modification request that
reflects these upgrades.
Please let me know if I have missed anything! Thank you for.your assistance.
David Goodrich
1 of 1 7/7/2008 10:20 AM

ROY COOPER
ATTORNEY GENERAL
TO:
State of North Carolina
Department of Justice
9001 Mail Service Center
Raleigh, NC 27699-9001
P. O. Box 629
Raleigh, NC 27602-0629
MEMORANDUM
Reply to:
Jane Oliver, Assistant AG
[phone]/Phone
[phone]/Fax
[e-mail]
Kim Colson, Aquifer Protection Section ("APS"), Central Office, DWQ;
David Goodrich, APS, Central Office, DWQ;
Jim Barber, APS, Fayetteville Regional Office, DWQ;
Art Barnhardt, APS, Fayetteville Regional Office, DWQ
FROM: Jane L. Oliver, Assistant Attorney General/by: Janet Leach
DATE: February 13, 2008
RE: Permit Appeal by Lake Creek Corporation d/b/a Bay Tree Utilities
Bladen County - Wastewater Surface Irrigation Permit WQ0018708
Please note that I have been assigned to handle the above referenced contested ease. I will need to
begin preparing our case as soon as possible. Please review the important dates listed below and provide
me with the requested information by either inter -office mail or by hand delivery to the Attorney
General's Office. If you need a copy of the Petition let me know.
February 11, 2008 Documents Constituting Agency Action and Prehearing.
Statement was filed on this date. I have a copy of the signed
Permit. Please forward. a copy of all other documents related
to this case.
April 28, 2008
Week Beginning
May 12, 2008
All discoveries must be completed by
his date.
Hearing is set in Fayetteville, NC with Melissa
Owens. Lassiter, Administrative Law Judge presiding. If you
If you have any questions or comments regarding this case, please call me at: [phone]. If
I am not available, you may contact Janet Leach for immediate assistance at (9119) 716-6948.

Re: response
A
Subject: Re.: response
From: David Goodrich <[e-mail]>
Date: Tue, 22 Jan 2008 07:27:55 -0500
To: BBarwick <[e-mail]>, ART BARNHARDT <[e-mail]>, Jim
Barber <[e-mail]>, Kim Colson <[e-mail]>
BBarwick wrote:
David
We received your letter dated 1-16-08. Due to time constraints of Bay Tree personnel out of the office for
the next week, we hope this email suffices as a reply to your letter. We will look forward to meeting with
you at a later determined date.
)I
Please provide us with the rule concerning permit condition number 111.7. Also please provide the rule of
PH and TRC testing at 5 times a week. Our contract engineer is in the process of determining flow rates
under out current WWTP configuration.
We will contactyou to schedule a meeting when we get all parties back from vacation. We would prefer to
meet at Bay Tree sowe can visit our facilities if necessary.
Sincerely
Bill Stafford
Brooks Barwick
Mr. Stafford and Ms. Barwick:
Thank you for your response to my January 16, 2008 letter. Both Permit Condition III.7. and the
5-day/week sampling frequency requirement for pH and TRC in the effluent are policies.
We will look forward to meeting with you at a time of everyones' earliest mutual convenience.
David Goodrich
Aquifer Protection Section
1 of 1 ! 1/23/2008 9:28 AM

Re: Lake Creek Corporation
Subject: Re: Lake Creek Corporation
From: Art Barnhardt <[e-mail]>
Date: Wed, 16 Jan 2008 10:16:46 -0500
\,_) To: David Goodrich <[e-mail]>
CC: Jim Barber <[e-mail]>, Kim Colson <Kim.Colson
I think the letter is
said at this point.
ArtB.
David Goodrich wrote:
nCmail.net>
very well written and contains everything that needs to be
II forgot to attach the letter.
1 of 1 1/16/2008 11:14 AM

Response to Lake Creek Corporation
Subject: Response to Lake Creek Corporation
From: David Goodrich <[e-mail]>
Date: Wed, 16 Jan 2008 07:22:34 -0500
To: Jim Barber <[e-mail]>, ART BARNHARDT ! i'
<[e-mail]>, Kim Colson <Kim.Colson@ncmail.n'et>
Jim and Art,
With Kim's assistance, I have put together a response to.the January 4, 2008 letter
we received from Brooks Barwick and Bill Stafford relative'tolthe adjudication of
Permit WQ0018708. I would appreciate your examining it and 'advising me on anything
else that should be included, or other changes that may be.appropriate.
I would like to send it out ASAP. Thank you for your help with this!
David
1 of 1
1/16/2008 11:12 AM

Re: Adjudication of Lake Creek Corporation's WQ0018708 Permit
-�i
Subject: Re: Adjudication of Lake Creek Corporation's WQ0018708 Permit
From: Jim Barber <[e-mail]>
Date: Mon, 14 Jan 2008 15:19:54 -0500
To: David Goodrich <[e-mail]>, Art Barnhardt <[e-mail]>
David;
My schedule is open for Tuesday 15 Jan at 9am. Art B. is not available Tuesday and
I'm not available on Tuesday 22 Jan. Art said for me to conference with you and Kim
tomorrow and I can fill him in later in the week. Give me a time that is best to
call you and Kim C tomorrow and which telephone number you wish for me to call.
Jim Barber
David Goodrich wrote:
Jim Barber wrote:
David;
A couple of other issues that the ORC, Bill Stafford of White Lake WWTP,
called about are as follows:
Bill Stafford, ORC for Baytree Lakes and White Lake WWTP, lindicated in a
phone call that the increase in sampling frequencies in the Attachment A
would cost Baytree additional operating expense.
He also pointed out a misprint? on section 002 of the Attachment A for
Nitrogen sampling. Should the type of sampling be composite verses
continuous? If this is a misprint; I informed Bill Stafford that this issue
could be addressed by a administrative change. -
Bill also inquired as to why a draft permit wasn't issued prior to the final
version. His rationale is that he receives a draft permit when permits are
issued to White. Lake WWTP and White Lake has the ability during the draft
permit phase to object to permit conditions and/or has the ability to argue
their case to have a permit condition changed prior to the final permit being
issued.
I plan to contact Bill Stafford to address other comments he had concerning
our (FRO) impression on what we would being looking for during inspection of
the facility concerning operational documentation for certain permit
conditions.
If you feel that it would be beneficial to have a phone call with you, Kim
Colson, Art Barnhardt and myself this afternoon; let Art know by email or
call. I will be back in the office around 2pm.
Thanks
Jim Barber
Art Barnhardt wrote:
It is about flow being restricted until the permitted system is completed.
Some of the system is not built as their Engineer Designed.
ArtB.
David Goodrich wrote:
Jim and Art,
I am attaching copies of the petition and cover letter�l.
I am not clear on what the issues are. Do you know what their specific
.issues are
with the specific Conditions of the permit we just issued to them?
David
Art and Jim,
1 of 2 • 7/7/2008 10:21 AM

Re: Adjudication of Lake Creek Corporation's WQ0018708 Permit
4
I have gotten with Kim about setting up a good time for us to teleconference
about the issues concerning the Lake Creek Corporation's adjudication of Permit
WQ0018708.
It appears as though any time tomorrow (1/15) after 9:00 AM, or on the 22nd
(next Tuesday) would work for us.
Do either of these dates look good for your schedules?
David
2 of 2
7/7/2008 10:21 AM

Re: Adjudication of Lake Creek Corporation's WQ0018708 Permit
Subject: Re: Adjudication of Lake Creek Corporation's WQ0018708 Permit
From: Jim Barber <[e-mail]>
Date: Mon, 14 Jan 2008 10:48:16 -0500
To: Art Barnhardt <[e-mail]>
CC: David Goodrich <[e-mail]>
David;
A couple of other issues that the ORC, Bill Stafford of White;
about are as follows:
Lake WWTP,
Bill Stafford, ORC for Baytree Lakes and White Lake WWTP, indicated in a phone call
that the increase in sampling frequencies in the Attachment,A would cost Baytree
additional operating expense.
He also pointed out a misprint? on section 002 of the Attachment A for Nitrogen
sampling. Should the type of sampling be composite verses continuous? If this is a
misprint; I informed Bill Stafford that this -issue could be addressed by a
administrative change..
Bill also inquired as to why a draft permit wasn't issued prior to the final
version. His rationale is that he receives a draft permit when permits are issued to
White Lake WWTP and White Lake has the ability during the draft permit phase to
object to permit conditions and/or has the ability to argue their case to have a
permit condition changed prior to the final permit being issued.
I plan to contact Bill Stafford to address other comments he had concerning our
(FRO) impression on what we would being looking for during,inspection of the
facility concerning operational documentation for certain permit conditions.
I
If you feel that it,would be beneficial to have a phone call ,with you, Kim Colson,
Art Barnhardt and myself this afternoon; let Art know by email or call. I will be
back in the office around 2pm.
Thanks
Jim Barber
Art Barnhardt wrote:
It is about flow being restricted until the permitted system is completed. Some
of the system is not built as their Engineer Designed.
ArtB.
David Goodrich wrote:
Jim and Art,
I am attaching copies of the petition and cover letter.
I am not clear on what the issues are. Do you know what their specific issues
are
with the specific Conditions of the permit we just issued to them?
David
1 of 1
7/7/2008 10:21 AM

Adjudication of Lake Creek Corporation's. WQ0018708 Permit
L;.
Subject: Adjudication of Lake Creek Corporation's WQ0018708 Permit
From: David Goodrich <[e-mail]>
Date: Wed, 09 Jan 2008 15:06:19 -0500
To: Jim Barber <[e-mail]>, ART BARNHARDT <[e-mail]>
Jim and Art,
I am attaching copies of the petition and cover letter.
I am not clear on what the issues are. Do you know what thei
with the specific Conditions of the permit we just issued to
David
specific issues are
them?
'i Content -Type: application/pdf
SK1VIBT_60008010914490.pdf
,; Content -Encoding: bas'e64
1 of 1 7/7/2008 10:22 AM

Lake Creek Corporation
33 West Bay Ridge Road
Harrells, North Carolina 28444
[phone]
Fax [phone]
Ms. Coleen H. Sullins
Aquifer Water Section
Division of Water Quality
1636 Mail Service Center
Raleigh, NC 27699-1636
01-04-08
Dear Ms Sullins:
C(-
RECEIVED / DENR / DWQ
AQUIFER'PROTECTI0N SECTION
JAN .11 9 2008
Enclose you will find a petition for an adjudicatory hearing filed January 4, 2008 with
the Office of Administrative Hearings. This is you copy of the petition as required by
NCGS 150-B.
Please call Brooks Barwick at the above numbers if you have any questions.
Sincerely:
D. S
President, Lake Creek poration

PLEASE PRINT CLEARLY OR TYPE
STATE OF NORTH CAROLINA
COUNTY OF (l)Bladen
IN THE OFFICE OF
ADMINISTRATIVE HEARINGS
(2)Lake Creek Corporation dba Bay Tree Utilities
(your name) PETITIONER,
v.
(3)__NC Department of Environmental and Natural Resources
Aquifer Protection Section Division of Water Quality
RESPONDENT.
(The State agency or board about which you are complaining)
PETITION
FOR A
CONTESTED CASE HEARING
I hereby ask for a contested case hearing as provided for by North Carolina General Statute § 150B-23 because the Respondent has:
(Briefly state facts showing how you believe you have been harmed by the State agency or board.)
Lake Creek Corporation was issued Waste Water Permit Number WQ0018708 to operate a wastewater surface irrigation facility. If uncontested the
permit shall be effective December 12, 2007. This renewed permit, if not amended will cause financial hardships to our small subdivision. We
respectfully petition for an adjudicatory hearing. If the permit is enforced as issued, unnecessary construction and operations to the wastewater
treatment facility would occur and produce unnecessary financial burden to our small residential operation.
'1
(If more space is needed, attach additional pages.)
(4) Because of these facts, the State agency or board has: (check at least one from each column)
deprived me of property;
ordered me to pay a fine or civil penalty; or
X _otherwise substantially prejudiced my rights;
(5) Date: 01-04-08
(7) Print your full address:
(8) Print your name- ! eshens residet
(9) Your signature:
33 W. Bay Ridge Road
(street address/p.o. box)
You must mail or deliver a COPY of thi
Petition to the
board to determine the name of the person to be served.
AND
exceeded its authority or jurisdiction;
acted erroneously;
failed to use proper procedure;
X_acted arbitrarily or capriciously; or
failed to act as required by law or rule.
(6) Your phone number: (910) 588-4-432
Harrells
NC 28337
(city) (state) (zip)
t�e ag ncy or board named on line (3) of; this form. You should contact the agency or
CERTIFICATE OF SERVICE
1 certify that this Petition has been served on the State agency or board named below by depositing a copy of it with the United States Postal Service
with sufficient postage affixed OR by delivering it to the named agency or board:
(10) Coleen H. Sullins Director
(name of person served)
(12) 1636 Mail Service Center
(street address/p.o. box)
(13)
(14)
H-06 (1 l/99)
4th /i a of n Janua
Raleigh
(city)
Division of Water Quality (1 I)
(State agency or board listed on line 3)
NC 27699-1636
(state) ' (zip code)
,20 08 .

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleen H. Sullins, Director
Division of Water Quality
January 16, 2008
Ms. Brooks Barwick, Development Manager
Mr. Bill Stafford, ORC for Bay Tree Utilities
Lake Creek Corporation
33 West Bay Ridge Road
Harrells, North Carolina 28444
I;
• 1
Subject: Adjudication of Permit No. WQ0018708
Lake Creek Corporation
Wastewater Surface Irrigation
Bladen County
Dear Ms. Barwick and Mr. Stafford:
The Aquifer Protection Section is in receipt of your letter of January 4, 2008 detailing the concerns with
the most recently issued permit (dated December 12, 2007) that have prompted the filing of a Petition for a
Contested Case Hearing with the Office of Administrative Hearings. !would like to respond by stating possible
changes that could be made to the permit to address those concerns.
The additional 20,000 GPD expansion of the aeration system was part of the system's design, and was
permitted in this context. It is our understanding that this expansion was recommended, designed, and
endorsed by a licensed engineer and was based upon the present and projected needs of the community
served by the wastewater treatment system. Design of wastewater treatment facilities is practicing engineering
per the Board of Registration of Engineers... Therefore, our Division is only able,to issue permits for wastewater
treatment systems that have been designed and endorsed by a licensed engineer. Any design changes to an
approved system would have to be performed by a licensed engineer before the, altered system could receive a
permit from our Division.
Permit Condition No. 111.7. reads as follows: "All waste application equipment must be tested and
calibrated at least once per year. Records of the calibration must be maintained for five years." This condition
pertains to the testing and calibration of the irrigation system.
Referring to Attachment A, the monitoring of the treated wastewater effluent for pH and Total Residual
Chlorine must be performed five times a week. As long as the flow rate is less than or equal to 30,000 GPD, the
sample type can be "grab" for all of. the analytes. Samples taken for Total Nitrogen a'p alysis from the PPI-002
Expanded WWTP Treatment System Effluent can be grab as well. With the exceptions of pH, Total Residual
Chlorine and Flow, the monitoring schedules for the effluent sampling parameters listed in Attachment A could
all be set to the same frequency (such as March, June, September and November). ,The monitoring schedule
for the groundwater parameters listed in Attachment C could also be set to correspond to those months (March,
June, and November only).
Aquifer Protection Section 1636 Mail Service Center
Internet: www.ncwaterquality.org Location: 2728 Capital Boulevard
An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10% Post Consumer Paper
NorthCarolina
Naturally
Raleigh, NC 27699-1636 ; Telephone: [phone]
Raleigh, NC 27604 Fax 1: [phone]
Fax 2: [phone]
Customer Service: [phone]

We would welcome meeting with you, at a time of mutual convenience, at our regional office in
Fayetteville to discuss your position on these issues and how they might be resolved without going through the
process of adjudicating the permit.
Sincerely,
David Goodrich, LG
Aquifer Protection Section
Cc: Fayetteville Regional Office, Aquifer Protection Section
APS Central Files

ADMINISTRATIVE LAW JUDGE:
Rjr Petitioner or
D Attorney for Petitioner
This the
Rev. 11/99 (dc)
I I -
HEARING ASSISTANT/COURT REpORTER
REQUEST FORM
TO: Calendaring Clerk
Office of Administrative 11=rings
6714 Mail Service Center
Raleigh NC 27699-6714
919-733-2698
CASE NUMBER: 08 MIR 0030
CASE NAME: Lake Creek Corporation dibia
Bay Tree Utilities
v.
N. C. Department of Environment and
Natural Resources, Aquifer Protection
Section, Division of Water Quality
Melissa Owens Lasisiter
o Respondent or
[3 Attorney for Respondent
I request that the above -styled hearing be recorded using the following method (check one):
ErHearing Assistant (Provided by the Office of ilkdMinistrative Hearings)
Court Reporter (Party requesting Court Reporter is responsible for the Court
Reporter's fees)
day of 1 , 2008.
4104-.-
ture
r. 0 k5 j q At
Please print or toe narup
r•k3 'O5i, Kira/15 e
Stre: or Post Office e Box
k7r g.t-levc(
Cit341( a
anAciii2
Area Code and TelepluMe Number
0 T 39Vd
rno daVMOMMON
I I
88'90 -9IL -616 bi:ZT 800Z/TO/Z0

BBarwick
From: David Goodrich [David_Goodrich©NCMail.net]
Sent: Tuesday, January 22, 2008 8:28 AM
To: Marwick; ART BARNHARDT; Jim Barber; Kim Colson
Subject: Re: response
• BBarwick wrote:
David
We received your letter dated 1-16-08. Due to time constraints of Bay Tree
next week, we hope this email suffices as a reply to your letter. We will !co
later determined date.
personnel out of the office for the
forward to meeting with you at a
Please provide us with the rule concerning permit condition number 111.7.i Also please provide•the rule of PH and
TRC testing at 5 times a week. Our contract engineer is in the process of determining flow rates under out
current WWTP configuration.
We will contact you to schedule a meeting when we get all parties back from vacation. We would prefer to meet
at Bay Tree sowe can visit our facilities if necessary..
Sincerely
Bill Stafford
Brooks Barwick
Mr. Stafford and Ms. Barwick:
Thank you for your response to my January 16, 2008 letter. Both Permit Condition 111.7. and the 5-day/week
sampling frequency requirement for pH and TRC in the effluent are policies: Y
We will look forward to meeting with you at a time of everyones' earliest mutual convenience.
David Goodrich
Aquifer Protection Section
60 3Jdd
1 ' lO M f dN83QDN
,8850-5TL-6T6 OT:zT 800Z/TO/7O

• Michael F. Easley, Governor
William G. Ross Jr., Seery
1Vorth CartiRna Department of Environment and Natural Resources
Colecn H. Sullins, Director
Division of Water ()milky
January 16, 2008
Ms. Brooks Barwick, Development Manager
Mr. Bill Stafford, ORC for Bay Tree Utilities
Lake Creek Corporation
33 West Bay Ridge Road
Harrel's, North Carolina 28444
Subject Adjudication of Permit No. WQ0018708
Lake Creek Corporation
Wastewater Surfface Irrigation
Bladen County
Dear Ms. Barwick and Mr. Stafford:
The Aquifer Protection Section is in receipt of your letter of January 4, 2008 detailing the concerns with
the most recently issued permit (dated December 12, 2007) that have prompted the filing of a Petition for a
Contested Case Hearing with the Office of Administrative Hearings.l would like to respond by stating possible
changes that could be made to the permit to address those concems.
The additional 20,000 GPD expansion of the aeration system was part of the system's design, and was
permitted in this context It is our understanding that this expansion was recommended, designed, and
endorsed by. a licensed engineer and was based upon the present and projected needs of the community
served by the wastewatertreatment system. Design of wastewater treatment faalities is practicing engineering
per the North Carolina Board of Examiners for Engineers and Surveyors. Therefore, our Division is only able to
issue permits for wastewatertreatment systems that have been designed and endorsed by a licensed engineer.
My design changes to an approved system would have to be performed by'a licensed engineer before the
altered system could receive a permit from our Division.
' Permit Condition No. 111.7. reads as follows: "All waste application equipment must be tested and
calibrated at least once per year, Records of the calibration must be maintained for five years." This condition
pertains to the testing and calibration of the irrigation system.
Referring to Attachment A, the monitoring of the treated wastewater effluent for pH and Total Residual
Chlorine must be performed five times a week. As long as the flow rate is less than or equal to 30,000 GPD, the
sample type can be "grab" for all of the analytes. Samples taken for Total Nitrogen analysis from the PPI-002
Expanded 1NWTP Treatment System Effluent can be grab as well. With the exceptions of pH, Total Residual
Chlorine and Flow, the monitoring schedules for the effluent sampling parameters listed in Attachment A could
all be set to the same frequency (such as March, June, September and November). The monitoring schedule
for the groundwater parameters listed in Attachment C could also be set to correspond to those months (March.
June, and November only).
1 nAhCar'olina
Naturally
Aquifer Protection Section 1636 Mal Service Center Raleigh, NC 27699-1636 Telephone:
Internet: ten wr.newaterquality.pa Location: 2728 Capital Boulevard Raleigh, NC 27604 Fax 1:
[phone]
[phone]
(01n 7t5,AnAQ
LO 3Jdd
1dfD i'131"M/ZINB3QDN
;8850-9TL-6T6 OT:ZT 8003/T0/ZO

We would welcome meeting with you, at a time of mutual convenience, at our regional office in
Fayetteville to discuss your position on these issues and how they might be resolved without going through the
process of adjudicating the permit: }
rely` .
David Goodrich, LG.
Aquifer Pro iection Section
Cc: Fayetteville Regional Office, Aquifer Protection Section
APS Central Files
•
80 3EVd
1tofl° J31dMIZINS3QDN ',8850-9TL-6T6 0T:ZT 800Z/TO/Z0

Re: Adjudication of Lake Creek Corporation's WQ0018708 Permit
Subject: Re: Adjudication of Lake Creek Corporation's WQ0018708 Permit
From: David Goodrich <[e-mail]>
Date: Mon, 14 Jan 2008 10:59:15 -0500
To: Jim Barber <[e-mail]>
CC: Art Barnhardt <[e-mail]>
Jim Barber wrote:
David;
A couple of other issues
about are as follows:
that the ORC, Bill Stafford of White Lake WWTP, called
Bill Stafford, ORC'for Baytree Lakes and White Lake WWTP,; indicated in a phone
call that the increase in sampling frequencies in the Attachment A would cost
Baytree additional operating expense.
tl
He also pointed out a misprint? on section 002 of the Attachment A for Nitrogen
sampling. Should the type of sampling be composite verses clontinuous?,If-this is
a misprint; I informed Bill Stafford that this issue could be addressed by a
administrative change.
Bill also inquired as to whya draft permit wasn't issued prior to the final
version. His rationale is that he receives a draft permit when permits are
issued to White Lake WWTP and White Lake has the ability during the draft permit
phase to object to permit' conditions and/or has the abilitylto argue their case
to have a permit condition changed:prior to the.final permit being issued.
ti
I plan to contact Bill Stafford to address other comments he had concerning our
(FRO) impression on what we would being looking for during 'inspection of the
facility concerning operational documentation for certain p'ermit.conditions:
1 I
If you feel that it would be beneficial to have a phone call with you, Kim
Colson, Art Barnhardt and myself -this afternoon; let Art;knpw by -email or call.
I will be back in the office around 2pm.
Thanks
Jim Barber
Art Barnhardt wrote:;
It is about flow being restricted until the permitted system -is completed.
Some of the system is not built as their Engineer Designeid..
ArtB.
David Goodrich wrote:
Jim and Art,
I am attaching copies of the petition and cover letter.t
I am not clear on what the issues are. Do you know what their specific
issues are
with the specific Conditions of the permit we just issued to•them?
David
Jim and Art,
A conference call sounds like an
his schedule will allow us to do so this. afternoon.
Thank you for the update on this!
David
excellent idea. I will get up with Kim to see if
1 of 1,
1/14/2008 3:00 PM

Re: Adjudication of Lake'Creek Corporation's WQ0018708 Permit
Subject: Re: Adjudication of Lake Creek Corporation's WQ0018708 Permit
From: Jim Barber <[e-mail]>
Date: Mon, 14.Jan 2008 16:47:39--0500
To: David Goodrich <[e-mail]>
David;
Thanks for the reply and I'll call at 9:30 sharp.
Jim Barber
avid Goodrich wrote:
Jim Barber. wrote:
David;
My schedule is open
'Tuesday and I!m not
conference with you
Give me a time that
number you wish for
Jim Barber
for Tuesday 15 Jan at'9am. Art B. is not available
available .on Tuesday 22 Jan. Art saidfor me to ;
and Kim tomorrow and'I can fill him in later in the'week.
is best to call you and Kim C tomorrow and which telephone
me to call.
David Goodrich wrote:
Jim Barber:wrote:. 1
David;
-A couple of other issues that the,ORC, Bill Stafford of White Lake
WWTP, called about are as follows:
Bill Stafford, ORC for Baytree Lakes and White Lake: WWTP, indicated in
a phone call that the increase in sampling frequencies in the
Attachment A would cost Baytree additional operating expense.
He •also'pointed out ,a misprint? on 'section '002 of the Attachment A for
Nitrogen sampling. Should the type of sampling be composite verses
continuous?. If this is a misprint; -•I informed Bill Stalfford that this
issue could be addressed by a administrative change
Bill also.inquired,as to why a draft permit wasn't issued prior to the
final version. His rationale is that he receives 'a draft permit when
permits are issued to White Lake WWTP and White Lake has the ability
during the draft permit phase to object to permit conditions and/or has
the ability to argue their case to"•have a permit -•condition changed
prior to the final permit being issued.
I plan to contact Bill Stafford to address other comments he had
concerning our'FRO) impression on what we would beinglooking for
during inspection of the facility concerning operational documentation
for 'certain permit conditions.
h
If you feel that it would be. beneficial to have a phone call with you,
Kim Colson, Art Barnhardt and thyself this afternoon;, let Art know by
email'or call.,I will,be:back in'the office around 2pmd
Thanks
Jim Barber
Art Barnhardt wrote:
It is. about flow being restricted'until the permitted system is
completed. -Some of the system is not built as their•Engineer.
Designed.
ArtB. .
David Goodrich wrote:'
•1 of 2 1/14/2008 4:47 PM

Re: Adjudication of Lake Creek Corporation's WQ0018708 Permit
J. c .
Jim -and Art,
I am attaching. copies of the petition and cover letter.
I am not clear on what the issues are. Do you know what their
specific issues are,
with the specific Conditions of the permit we jiust issued to
them?
David
i
Art and Jim,
I have gotten with Kim about setting=up a goodtime forlus to
teleconference about the issues concerning the Lake Creek Corporation's
adjudication of Permit WQ0018708. I
It appears as' though any time.tomorrow (1/15) after 9,00 AM, or on the
22nd (next Tuesday) would work for us.
Do either'of these dates look good for'your schedules?
David
Jim: I
You can call us at Kim's Office Number, [phone]),at! 9:30 tomorrow morning.
i
Talk to you then!
,David
2 of 2
1/14/2008 4:47 PM

Re: Adjudication of Lake Creek Corporation's WQ0018708 Permit
CJ
Subject: Re: Adjudication of Lake Creek Corporation's WQ0018708 Permit
From: Art Barnhardt <[e-mail]>
Date: Thu, 10 Jan 2008 17:19:42 =0500
To: David Goodrich <[e-mail]>
CC: Jim Barber <[e-mail]>
It is about flow being restricted until the permitted
the system is not built as their Engineer Designed.
ArtB.
David Goodrich wrote:
Jim and Art,
system
completed. Some of
I am attaching copies of the petition and- cover letter.
I am not clear on what the issues are. Do you know what their specific issues
are II
with the specific Conditions of the permit we just issued; to them?
David
1 of 1
1/14/2008 10:34 AM

Adjudication of Lake Creek Corporation's WQ0018708 Permit
Subject: Adjudication of Lake Creek Corporation's WQ0018708 Permit
From: David Goodrich <[e-mail]>' •
Date: Wed, 09 Jan 2008 ,15:06:19-0500
To: Jim Barber <[e-mail]>, ART BARNHARDT <[e-mail]>
Jim and Art,
I am attaching copies. of the petition and cover letter. -
I am not clear on what the issues are. Do you know what their specific issues are
with the specific Conditions. of. the permit we just issued to them?
David
Content -Type: ,. app ication/pdf
SKMBT 60008010914490.0
Content -Encoding: base,64
1 of l
1/14/2008 10:32 AM

Lake Creek Corporation
,33 West Bay Ridge Road
Harrells„North Carolina 28444
- [phone]--
Fax [phone]
Ms. Coleen H. Sullins
Aquifer Water Section
Division of Water Quality
1636 Mail Service Center
Raleigh, NC 27699-1636
01-04-08
Dear Ms Sullins:
Enclose you will find a petition for an adjudicatory hearing filed January 4, 2008 with
the Office of Administrative Hearings. This is you copy of the petition as required by
NCGS 150-B.
I -
Please call Brooks:Barwick at the above numbers if you have any qu stions.
RECEIVED / DENR DINQ
AQUIFERPRDTECTION SECTION
JAN ,I) 9 2008
Sincerely:
D. S - o'- 'pes
President, Lake Creek
oration

PLEASE PRINT CLEARLY OR TYPE
STATE OF NORTH CAROLINA
COUNTY OF (I )_Bladen
IN THE OFFICE OF
ADMINISTRATIVE HEARINGS
(2)Lake Creek Corporation dba Bay Tree Utilities
(your name) PETITIONER,
v.
(3)__NC Department of Environmental and Natural Resources
Aquifer Protection Section Division of Water Quality
RESPONDENT.
(The State agency or board about which you are complaining)
PETITION
FOR A
CONTESTED CASE HEARING
1
Ihereby ask for a contested case hearing as provided for by North Carolina General Statute § 150B-23 because the Respondent has:
(Briefly state facts showing how you believe you have been harmed by the State agency or board.)
Lake Creek Corporation was issued Waste Water Permit Number WQ0018708 to operate a wastewater surface irrigation facility. If uncontested the
permit shall be effective December 12, 2007. This renewed permit, if not amended will cause'financiail hardships to our small subdivision. We
'respectfully petition for an adjudicatory hearing. If the permit is enforced as issued, unnecessary construction and operations to the wastewater
treatrnent facility would occur and produce unnecessary financial burden to our small residential operation.
I,
!I
II
(If more space is needed, attach additional pages.)
(4) Because of these facts, the State agency or board has: (check at least one
deprived me of property;,
ordered me to pay a fine or civil penalty; or
_X _ otherwise substantially prejudiced my rights; AND
(5) Date: 01-04-08
(7) Print your full address: 33 W. Bay Ridge Road
(street address/p.o. box)
(8) Print your nam - e hens ,y es /'reside
(9) Your signatur
` 411
You must mail or deliver a COPY of thi Petition to the
board to determine the name of the person to be served.
from each column) I]
exceeded its'authority or jurisdiction:
acted erroneously;
failed to use.proper procedure;
_X_acted arbitrarilyjlor capriciously; or
failed to act as required by law or rule.
(6) Your phone number:'( 910) 588-4432
Harrells, NC ' j, 28337
(city) (state) , (zip)
e ag
ncy or board named on line (3) of this form. You should contact the agency or
I.
CERTIFICATE OF SERVICE
I certify that this Petition has been served on the State agency or board named below by depositing a copy of it with the United States Postal Service
with sufficient postage affixed OR by delivering it to the named agency or board:
(10) Coleen H. Sullins Director
(name of person served)
(12) 1636 Mail Service Center
(street address/p.o. box)
(13)
(14)
H-06 (1 I/99)
4th /i�a of Janua
Division of Water Quality
(State agency or board listed on line 3)
NC 27699-1636
(state) , (zip code)
Raleigh
(city)
,2008 .

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A & D Water Service, Inc.
PO Box 1407 '
828-884-
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1049 '
Pisgah Forest, NC 28768-8798 ;
9772
8632
W-
ABC&D PROPERTIES,
370 midland drive ;;
828-444-
1191
LLC
ASHEVILLE NORTH
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1746
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ALBEMARLE
201 OCEAN HIGHWAY
252-426-
1189
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HERTFORD, NC 27944
1128
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1133
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Bay Tree UtiiityCompany, - .
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a
Baytree Waterfront
Properties, Inc.
202 MACKENAN COURT
CARY, NC 27511
C/O DIMITRIS RENTZIOS
787 EAST BELLEVIEW
AVENUE, STE 200
ENGLEWOOD, CO 80111
SUITE 400
4643 S ULSTER STREET
DENVER, CO 80237-2897
Suite 400
4643 S Ulster Street Denver,
CO 80237=2897
SUITE 400
4643 S ULSTER STREET
DENVER, CO 80237-2897
P 0 BOX 8489
ASHEVILLE, NC 28814
5328 Lakewood Drive, SW
Shallotte, NC 28470-5137
4 Stanley Avenue
Thomasville, NC 27360
919-653-
5770
303-291-
0222
303-244-
0692
303-291-
0222 •
303-244-
0692
828-667-
3399
919-579-
7988
910588
0,1
336-475-
9186
919-460-
1788
303-294-
9946
336-475-
6019
W-966 Beacon's Reach Master PO Box 989
252-247-