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HomeMy WebLinkAboutWQ0000957_Final Permit_20221215ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director NORTH CAROLINA Environmental Quality December 15, 2022 ROYAL WITCHER — SENIOR VICE PRESIDENT DARLING INGREDIENTS, INC. POST OFFICE BOX 3588 WINCHESTER, VIRGINIA 22604 Subject: Permit No. WQ0000957 Darling Ingredients — Wadesboro WWTP Wastewater Irrigation System Anson County Dear Mr. Witcher: In accordance with your permit change of ownership request received October 7, 2022, we are forwarding herewith Permit No. WQ0000957 dated December 15, 2022, to Darling Ingredients, Inc. for the continued operation of the subject wastewater treatment and irrigation facilities. This permit shall be effective from the date of issuance through October 31, 2029, shall replace Permit No. WQ0000957 issued April 4, 2018, and shall be subject to the conditions and limitations therein. The Permittee shall submit a renewal application no later than May 4, 2029. Please pay attention to the monitoring requirements listed Attachments A, B, and C for they may differ from the previous permit issuance. Failure to establish an adequate system for collecting and maintaining the required operational information shall result in future compliance problems. The Division has removed the following permit condition since the last permit issuance dated April 4, 2018: ➢ Old Condition VL2 — This condition has been removed because this permit is not voidable. The following permit conditions are new since the last permit issuance dated April 4, 2018: ➢ Condition 11.11 — The setbacks in this permit have been updated to correspond to the setbacks at the time of the permit modification. This replaces Old Condition IL 11.a. ➢ Condition 11.12 — The setbacks in this permit have been updated to correspond to the setbacks at the time of the permit modification. This replaces Old Condition IL 11.b. ➢ Condition IV.7 — This condition has been updated to require submission of Form NDMLR because Plant Available Nitrogen (PAN) parameter has been restored to this permit (PAN was mistakenly removed in the last permit). This condition replaces Old Condition IV.7. ➢ Attachment A — PAN parameter is to be reported. ➢ Attachment B — Application limitation for PAN parameter has been added. D � North Carolina Department of Environmental Quality i Division of Water Resources 512 North Salisbury Street 11617 Mail Service Center I Raleigh, North Carolina 27699-1617 NOR�HCAROLINA ©.'roMtor 919,707.9000 Mr. Royal Witcher December 15, 2022 Page 2 of 2 If any parts, requirements, or limitations contained in this permit are unacceptable, the Permittee has the right to request an adjudicatory hearing upon written request within 30 days following receipt of this permit. This request shall 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 at 6714 Mail Service Center, Raleigh, NC 27699-6714. Otherwise, this permit shall be final and binding. If you need additional information concerning this permit, please contact Ehsan Bagheri at (919) 707-3661 or ehsan.bagheri&ncdenr.gov. Sincerely, Richard E. Rogers, Jr., Director Division of Water Resources cc: Anson County Health Department (Electronic Copy) Fayetteville Regional Office, Water Quality Regional Operations Section (Electronic Copy) Laserfiche File (Electronic Copy) Digital Permit Archive (Electronic Copy) NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION DEPARTMENT OF ENVIRONMENTAL QUALITY RALEIGH WASTEWATER 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 Regulations PERMISSION IS HEREBY GRANTED TO Darling Ingredients, Inc. Anson County FOR THE operation of a 220,000 gallon per day (GPD) based on 5.5 days per week wastewater treatment and irrigation facility (with approximately 45,000 GPD evaporated in a cooling tower and shell tube condenser) consisting of the: continued operation of an 84,500 gallon flow equalization basin (FEB 92) receiving waste from the stored evaporator and truck wash, with a 60 horsepower (hp) surface aerator, and a 40 hp recirculating pump; a raw wastewater pump station receiving wastewater from the stored evaporator and the rendering plant drainage and wash down; a Sweco screening system with a screen effluent pump; a 16,000 gallon cone bottom flow equalization basin (FEB41); a dissolved air flotation (DAF) cell flocculation tube (91); a DAF cell (91) with chemical feed system, and a recycle pressurization pump; a DAF sludge storage tank with a DAF solids pump; a 1.5 million gallon (MG) oxidation ditch, receiving wastewater from the DAF and raw 320-U cooker condensate, raw feather condensate, and Venturi effluent, with a 45 hp surface aerator, a 25 hp surface aerator, two 15 hp surface aerators, two 2,340 cubic feet per minute (CFM) blowers, a 75 hp recirculation pump, two 1,918 CFM blowers, and two submersible pumps; a 165,000 gallon clarifier in the center of the oxidation ditch; a circular concrete wet well pump station with two submersible 300 gallon per minute (GPM) pumps, and 6-inch force main lines; a DAF cell flocculation tube (92); a DAF cell (92) with chemical feed system; two wastewater holding ponds in series with a total capacity of 16.25 MG; an irrigation pump station with two 1,000 GPM pumps with flow recorder and totalizer; an irrigation force main and irrigation equipment for Fields 1 through 12; approximately 3,500 linear feet (LF) of 6-inch force main and irrigation equipment for irrigation Fields 12 through 20 (previously covered under Permit No. WQ0007504) for irrigation on a total of 135.77 acres; and all associated piping, valves, controls, and appurtenances; and the continued operation of a wastewater holding pond #3 to serve as an FEB Anoxic Reactor Basin #1 during summer months and as a variable volume holding pond during other months, consisting of a 2.7 MG basin with 12-inch thick clay liner demonstrating a hydraulic conductivity no greater than 10-7 centimeters per second (cm/s), two 1,200 GPM transfer pumps, eight 40 HP mixers, an effluent flow meter; an oxidation ditch being used as Nitrification Reactor #2 consisting of a 1.5 MG oxidation ditch and one nitrate recycle flow meter and all associated piping to be operated in such configuration during months of high nitrogen loading; and all associated piping, valves, controls, and appurtenances to serve the Darling Ingredients — Wadesboro WWTP, with no discharge of wastes to surface waters, pursuant to the application received October 7, 2022, and in conformity with the Division -approved plans and specifications considered a part of this permit. WQ0000957 Version 3.1 Shell Version 200201 Page 1 of 9 This permit shall be effective from the date of issuance through October 31, 2029, shall replace Permit No. WQ0000957 issued April 4, 2018, and shall be subject to the following conditions and limitations: I. SCHEDULES 1. The Permittee shall request renewal of this permit on Division -approved forms no later than May 4, 2029. [15A NCAC 02T .0105(b), 02T .0109] II. PERFORMANCE STANDARDS The Permittee shall maintain and operate the subject non -discharge facilities so there is no discharge to surface waters, nor any contravention of groundwater or surface water standards. In the event the facilities fail to perform satisfactorily, including the creation of nuisance conditions due to improper operation and maintenance, or failure of the irrigation areas to assimilate the effluent, the Permittee shall take immediate corrective actions, including Division required actions, such as the construction of additional or replacement wastewater treatment or disposal facilities. [15A NCAC 02T .0108(b)(1)(A)] 2. This permit shall not relieve the Permittee of their responsibility for damages to groundwater or surface water resulting from the operation of this facility. [15A NCAC 02T .0108(b)(1)(A)] Groundwater monitoring wells shall be constructed in accordance with 15A NCAC 02C .0108 (Standards of Construction for Wells Other than Water Supply), and any other jurisdictional laws and regulations pertaining to well construction. [15A NCAC 02C .0108] 4. Effluent quality shall not exceed the limitations specified in Attachment A. [15A NCAC 02T .0505(b)] 5. Application rates, whether hydraulic, nutrient, or other pollutant, shall not exceed those specified in Attachment B. [15A NCAC 02T .0108(b)(1)(A)] 6. Wastewater irrigation fields permitted on or after December 30, 1983 have a compliance boundary that is either 250 feet from the wastewater irrigation area, or 50 feet within the property boundary, whichever is closest to the wastewater irrigation area. Any exceedance of groundwater standards at or beyond the compliance boundary shall require corrective action. Division -approved relocation of the compliance boundary shall be noted in Attachment B. Multiple contiguous properties under common ownership and permitted for use as a disposal system shall be treated as a single property with regard to determination of a compliance boundary. [ 15A NCAC 02L .0106(d)(2), 02L .0107(b), 02T .0105(h), G.S. 143-215.1(1), G.S. 143-215.1(k)] 7. The review boundary is midway between the compliance boundary and the wastewater irrigation area. Any exceedance of groundwater standards at or beyond the review boundary shall require preventative action. [15A NCAC 02L .0106(d)(1), 02L .0108] 8. The Permittee shall apply for a permit modification to establish a new compliance boundary prior to any sale or transfer of property affecting a compliance boundary (i.e., parcel subdivision). [ 15A NCAC 02L .0107(c)] 9. No wells, excluding Division -approved monitoring wells, shall be constructed within the compliance boundary except as provided for in 15A NCAC 02L .0107(g). [15A NCAC 02L .0107] WQ0000957 Version 3.1 Shell Version 200201 Page 2 of 9 10. Except as provided for in 15A NCAC 02L .0107(g), the Permittee shall ensure any landowner who is not the Permittee and owns land within the compliance boundary shall execute and file with the Anson County Register of Deeds an easement running with the land containing the following items: a. A notice of the permit and number or other description as allowed in 15A NCAC 02L .0107(f)(1); b. Prohibits construction and operation of water supply wells within the compliance boundary; and c. Reserves the right of the Permittee or the State to enter the property within the compliance boundary for purposes related to the permit. The Director may terminate the easement when its purpose has been fulfilled or is no longer needed. [15A NCAC 02L .0107(f)] 11. The facilities herein were permitted per the following setbacks: a. The irrigation sites were modified March 26, 2004. The setbacks for spray irrigation sites originally permitted or modified from February 1, 1993 to August 31, 2006 are as follows (all distances in feet): i. Each habitable residence or place of assembly under separate ownership: 400 1 ii. Each private or public water supply source: 100 iii. Surface waters: 100 iv. Groundwater lowering ditches: 100 v. Surface water diversions (upslope): 100 vi. Surface water diversions (downslope): 100 vii. Each well with exception of monitoring wells: 100 viii. Each property line: 150 '` ix. Top of slope of embankments or cuts of two feet or more in vertical height: 15 x. Each water line: 10 xi. Each swimming pool: 100 xii. Public right of way: 50 xiii. Nitrification field: 20 xiv. Each building foundation or basement: 15 ' Habitable residences or places of assembly under separate ownership constructed after the facilities herein were originally permitted or subsequently modified are exempt from this setback. 2 Setbacks to property lines are not applicable when the Permittee, or the entity from which the Permittee is leasing, owns both parcels separated by the property line. [15A NCAC 02H .02190)(5)] WQ0000957 Version 3.1 Shell Version 200201 Page 3 of 9 b. The storage and treatment units were modified March 5, 2012. The setbacks for storage and treatment units originally permitted or modified from September 1, 2006 to August 31, 2018 are as follows (all distances in feet): I. Each habitable residence or place of assembly under separate ownership: 1001 ii. Each private or public water supply source: 100 iii. Surface waters: 50 iv. Each well with exception of monitoring wells: 100 v. Each property line: 50 2 ' Habitable residences or places of assembly under separate ownership constructed after the facilities herein were originally permitted or subsequently modified are exempt from this setback. 2 Setbacks to property lines are not applicable when the Permittee, or the entity from which the Permittee is leasing, owns both parcels separated by the property line. [15A NCAC 02T .0506(b), 02T .0506(e), 02T .0506(f)] III. OPERATION AND MAINTENANCE REQUIREMENTS 1. The Permittee shall operate and maintain the subject facilities as a non -discharge system. [15A NCAC 02T .0500] 2. The Permittee shall maintain an Operation and Maintenance Plan, which shall include operational functions, maintenance schedules, safety measures, and a spill response plan. [15A NCAC 02T .0507(a)] 3. Upon the Water Pollution Control System Operators Certification Commission's (WPCSOCC) classification of the subject non -discharge facilities, the Permittee shall designate and employ a certified operator in responsible charge (ORC), and one or more certified operators as back-up ORCs. The ORC or their back-up shall operate and visit the facilities as required by the WPCSOCC. [15A NCAC 02T .0117] 4. The Permittee shall maintain vegetative cover on the irrigation sites, such that crop health is optimal, allows even effluent distribution, and allows inspection of the irrigation system. [15A NCAC 02T .05 07(b)] 5. The Permittee shall take measures to prevent effluent ponding in or runoff from the irrigation sites listed in Attachment B. [15A NCAC 02T .0507(c)] 6. The Permittee shall not irrigate treated effluent during inclement weather, or when the soil is in a condition that will cause ponding or runoff. [15A NCAC 02T .0505(x)] 7. Irrigation equipment shall be tested and calibrated once per permit cycle. [15A NCAC 02T .0507(d)] 8. Only treated effluent from the Darling Ingredients — Wadesboro WWTP shall be irrigated on the sites listed in Attachment B. [15A NCAC 02T .0501] 9. The Permittee shall not allow vehicles or heavy machinery on the irrigation area, except during equipment installation or maintenance activities. [15A NCAC 02T .0507(e)] 10. The Permittee shall prohibit public access to the wastewater treatment, storage, and irrigation facilities. [15A NCAC 02T .0505(q)] 11. The Permittee shall dispose or utilize generated residuals in a Division -approved manner. [15A NCAC 02T .0508, 02T .I 100]. WQ0000957 Version 3.1 Shell Version 200201 Page 4 of 9 12. The Permittee shall not divert or bypass untreated or partially treated wastewater from the subject facilities. [15A NCAC 02T .05050)] 13. Freeboard in the wastewater holding ponds shall not be less than two feet at any time. [15A NCAC 02T .0505(d)] 14. Gauges to monitor waste levels in the wastewater holding ponds shall be provided. These gauges shall have readily visible permanent markings, at inch or tenth of a foot increments, indicating the following elevations: maximum liquid level at the top of the temporary liquid storage volume; minimum liquid level at the bottom of the temporary liquid storage volume; and the lowest point on top of the dam. [15A NCAC 02T .0507(f)] 15. A protective vegetative cover shall be established and maintained on all berms, pipe runs, erosion control areas, surface water diversions, and earthen embankments (i.e., outside toe of embankment to maximum allowable temporary storage elevation on the inside of the embankment). Trees, shrubs, and other woody vegetation shall not be allowed to grow on the earthen dikes or embankments. Earthen embankments shall be kept mowed or otherwise controlled and accessible. [ 15A NCAC 02T .0507(g)] 16. Metering equipment shall be tested and calibrated annually. [15A NCAC 02T .0507(d)] IV. MONITORING AND REPORTING REQUIREMENTS The Permittee shall conduct and report any Division required monitoring necessary to evaluate this facility's impact on groundwater and surface water. [15A NCAC 02T .0108(c)] 2. A Division -certified laboratory shall conduct all analyses for the required effluent, groundwater, and surface water parameters. [15A NCAC 02H .0800] Flow through the treatment facility shall be continuously monitored, and daily flow values shall be reported on Form NDMR. Facilities with a permitted flow less than 10,000 GPD may estimate their flow from water usage records provided the water source is metered. [15A NCAC 02T .0105(k), 02T .0108(c)] 4. The Permittee shall monitor the treated effluent at the frequencies and locations for the parameters specified in Attachment A. [ 15A NCAC 02T .0108(c)] 5. The Permittee shall maintain records tracking the amount of effluent irrigated. These records shall include the following information for each irrigation site listed in Attachment B: a. Date of irrigation; b. Volume of effluent irrigated; c. Site irrigated; d. Length of time site is irrigated; e. Continuous weekly, monthly, and year-to-date hydraulic (inches/acre) loadings; f. Continuous monthly and year-to-date loadings for any non -hydraulic parameter specifically limited in Attachment B; g. Weather conditions; and h. Maintenance of cover crops. [15A NCAC 02T .0108(c)] 6. Freeboard (i.e., waste level to the lowest embankment elevation) in the wastewater holding ponds shall be measured to the nearest inch or tenth of a foot, and recorded weekly. Weekly freeboard records shall be maintained for five years, and shall be made available to the Division upon request. [15A NCAC 02T .0108(c)] WQ0000957 Version 3.1 Shell Version 200201 Page 5 of 9 7. Three copies of all monitoring data (as specified in Conditions IV.3. and IVA.) on Form NDMR for each PPI, three copies of all operation and disposal records (as specified in Conditions IV.5. and IV.6.) on Form NDAR-1 for every site in Attachment B, and three copies of all mass loading records (as specified in Condition IV.5.£) on Form NDMLR for every site in Attachment B shall be submitted on or before the last day of the following month. NDMLR data shall include cover crop type and PAN loading for each month, as well as cumulative PAN loading for the previous 12 months (i.e., 12 month floating total). 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 Resources Information Processing Unit 1617 Mail Service Center Raleigh, North Carolina 27699-1617 [I5A NCAC 02T .0105(1)] 8. The Permittee shall maintain a record of all residuals removed from this facility. This record shall be maintained for five years, and shall be made available to the Division upon request. This record shall include: a. Name of the residuals hauler; b. Non -Discharge permit number authorizing the residuals disposal, or a letter from a municipality agreeing to accept the residuals; c. Date the residuals were hauled; and d. Volume of residuals removed. [15A NCAC 02T .0508(b)] 9. A maintenance log shall be kept at this facility. This log shall be maintained for five years, and shall be made available to the Division upon request. This log shall include: a. Date of flow measurement device calibration; b. Date of irrigation equipment calibration; c. Visual observations of the plant and plant site; and d. Record of preventative maintenance (e.g., changing of equipment, adjustments, testing, inspections and cleanings, etc.). [I5A NCAC 02T .0507(h)] 10. Monitoring wells MW-1, MW-2, MW-3, MW-5, MW-6, MW-7, MW-8, and MW-9 shall be sampled at the frequencies and for the parameters specified in Attachment C. 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 1. [15A NCAC 02T .0105(m)] 11. Two copies of the monitoring well sampling and analysis results shall be submitted on a Compliance Monitoring Form (GW-59), along with attached copies of laboratory analyses, on or before the last working day of the month following the sampling month. The Compliance Monitoring Form (GW-59) shall include this permit number, the appropriate well identification number, and one GW-59a certification form shall be submitted with each set of sampling results. All information shall be submitted to the following address: Division of Water Resources Information Processing Unit 1617 Mail Service Center Raleigh, North Carolina 27699-1617 [15A NCAC 02T .0105(m)] WQ0000957 Version 3.1 Shell Version 200201 Page 6 of 9 12. An annual representative soils analysis (i.e., Standard Soil Fertility Analysis) shall be conducted on each irrigation site listed in Attachment B. These results shall be maintained at the facility for five years, and shall be made available to the Division upon request. Each Standard Soil Fertility Analysis shall include the following parameters: Acidity Exchangeable Sodium Percentage Phosphorus Base Saturation (by calculation) Magnesium Potassium Calcium Manganese Sodium Cation Exchange Capacity Percent Humic Matter Zinc Copper pH [15A NCAC 02T .0108(c)] 13. Noncompliance Notification: The Permittee shall report to the Fayetteville Regional Office, telephone number (910) 433-3300, within 24 hours of first knowledge of the following: a. Treatment of wastes abnormal in quantity or characteristic, including the known passage of a hazardous substance. b. Any process unit failure (e.g., mechanical, electrical, etc.) rendering the facility incapable of adequate wastewater treatment. c. Any facility failure resulting in a discharge to surface waters. d. Any time self -monitoring indicates the facility has gone out of compliance with its permit limitations. e. Ponding in or runoff from the irrigation sites. Emergencies requiring reporting outside normal business hours shall call the Division's Emergency Response personnel at telephone number (800) 662-7956, (800) 858-0368, or (919) 733-3300. All noncompliance notifications shall file a written report to the Fayetteville Regional Office within five days of first knowledge of the occurrence, and this report shall outline the actions proposed or taken to ensure the problem does not recur. [15A NCAC 02T .0108(b)(1)(A)] V. INSPECTIONS 1. The Permittee shall perform inspections and maintenance to ensure proper operation of the wastewater treatment and irrigation facilities. [15A NCAC 02T .0507(i)] 2. The Permittee shall inspect the wastewater treatment and irrigation facilities to prevent malfunctions, facility deterioration, and operator errors that may result in discharges of wastes to the environment, threats to human health, or public nuisances. The Permittee shall maintain an inspection log that includes the date and time of inspection, observations made, and maintenance, repairs, or corrective actions taken. The Permittee shall maintain this inspection log for a period of five years from the date of the inspection, and this log shall be made available to the Division upon request. [15A NCAC 02T .0507(h), 02T .0507(i)] 3. Division authorized representatives may, upon presentation of credentials, enter and inspect any property, premises, or place related to the wastewater treatment and irrigation facilities permitted herein at any reasonable time for determining compliance with this permit. Division authorized representatives may inspect or copy records maintained under the terms and conditions of this permit, and may collect groundwater, surface water, or leachate samples. [G.S. 143-215.3(a)(2)] WQ0000957 Version 3.1 Shell Version 200201 Page 7 of 9 VI. GENERAL CONDITIONS 1. Failure to comply with the conditions and limitations contained herein may subject the Permittee to a Division enforcement action. [G.S. 143-215.6A, 143-215.613, 143-215.6C] 2. This permit is effective only with respect to the nature and volume of wastes described in the permit application, and Division -approved plans and specifications. [G.S. 143-215.1(d)] 3. Unless specifically requested and approved in this permit, there are no variances to administrative codes or general statutes governing the construction or operation of the facilities permitted herein. [15A NCAC 02T .0105(n)] 4. The issuance of this permit does not exempt the Permittee from complying with all statutes, rules, regulations, or ordinances that other jurisdictional government agencies (e.g., local, state, and federal) may require. [15A NCAC 02T .0105(c)(6)] 5. If the permitted facilities change ownership, or the Permittee changes their name, the Permittee shall submit a permit modification request on Division -approved forms. The Permittee shall comply with all terms and conditions of this permit until the permit is transferred to the successor -owner. [G.S. 143- 215.1(d3)] 6. The Permittee shall retain a set of Division -approved plans and specifications for the life of the facilities permitted herein. [15A NCAC 02T .0105(o)] 7. The Permittee shall maintain this permit until the proper closure of all facilities permitted herein, or until the facilities permitted herein are permitted by another authority. [15A NCAC 02T .01050)] 8. This permit is subject to revocation or modification upon 60-day notice from the Division Director, in whole or part for: a. violation of any terms or conditions of this permit or Administrative Code Title 15A Subchapter 02T; b. obtaining a permit by misrepresentation or failure to disclose all relevant facts; c. the Permittee's refusal to allow authorized Department employees upon presentation of credentials: I. to enter the Permittee's premises where a system is located or where any records are required to be kept; ii. to have access to any permit required documents and records; iii. to inspect any monitoring equipment or method as required in this permit; or iv. to sample any pollutants; d. the Permittee's failure to pay the annual fee for administering and compliance monitoring; or e. a Division determination that the conditions of this permit are in conflict with North Carolina Administrative Code or General Statutes. [15A NCAC 02T .0110] WQ0000957 Version 3.1 Shell Version 200201 Page 8 of 9 9. Unless the Division Director grants a variance, expansion of the facilities permitted herein shall not occur if any of the following apply: a. The Permittee or any parent, subsidiary, or other affiliate of the Permittee has been convicted of environmental crimes under G.S. 143-215.613, or under Federal law that would otherwise be prosecuted under G.S. 143-215.613, and all appeals of this conviction have been abandoned or exhausted. b. The Permittee or any parent, subsidiary, or other affiliate of the Permittee has previously abandoned a wastewater treatment facility without properly closing the facility. c. The Permittee or any parent, subsidiary, or other affiliate of the Permittee has not paid a civil penalty, and all appeals of this penalty have been abandoned or exhausted. d. The Permittee or any parent, subsidiary, or other affiliate of the Permittee is currently not compliant with any compliance schedule in a permit, settlement agreement, or order. e. The Permittee or any parent, subsidiary, or other affiliate of the Permittee has not paid an annual fee. [15A NCAC 02T .0120(b), 02T .0120(d)] 10. This permit shall not be renewed if the Permittee or any affiliation has not paid the required annual fee. [15A NCAC 02T .0120(c)] Permit issued this the 15th day of December 2022 NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION 7L 4 Richard E. 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