NC0063746_Fact Sheet_20230703

DENR/DWR
EXPEDITED FACT SHEET - NPDES PERMIT DEVELOPMENT
NPDES Permit: NCO063746
2023 Renewal
This form must be completed by Permit Writers for all expedited permits which do not require full Fact Sheets.
Expedited permits are generally simple 100% domestics (e.g., schools, mobile home parks, etc.) that can be
administratively renewed with minor changes, but can include facilities with more complex issues (Special
Conditions, 303(d) listed water, toxicity testing, instream monitoring, compliance concerns).
Facility and Stream Information
Applicant/ Facility Name:
Clarke Utilities, Inc. / Deer Chase WWTP
Applicant Address:
223 Hwy 70 East; Suite 115; Garner, NC 27529
Facility Address:
3504 Donner Trail; Wake Forest, NC
Facility Class/Permit Status:
Grade II Biological WPCS / Renewal
Permitted Flow [as built]
0.22 [0.05] MGD
Type of Waste
100% Domestic
Receiving Stream
Toms Creek
Stream Class / ID
C; NSW / 27-24
River Basin
Neuse
Subbasin
03-04-02
HUC
030202010704
USGS Too
Wake Forest D24NE
7Q10 Sum Win cfs
0 1.4
1 30Q2 cfs
0.5
Avg. Stream Flow cfs
5.0
1WC % s/w [as -built]
100 19.6; 0 5.3
County
Wake
Regional Office
RRO
Basic Information for
Expedited Permit Renewal
Permit Writer / Date
Bradley Bennett / April 21, 2023
Does permit need daily max NH3 limits?
Yes - Already in permit
Does permit need TRC limits/language?
Yes - Already in permit
Does permit have toxicity testing?
Yes - See Discussion Below; Propose Removal
Does permit have Special Conditions?
Yes -Calculation & Reporting of TN; TN
Allocations; and Neuse Re -opener
Does permit have instream monitoring?
Yes - Temp, DO and Fecal
Stream on 303(d) List? For w/parameter?
Exceeding criteria for benthos & state-wide
mercury
Any compliance concerns?
See discussion below
Any modifications since lastpermit?
None noted in the application
New expiration date:
January 31, 2028
FACILITY OVERVIEW:
This facility is 100% domestic waste and treats a subdivision serving 160 residential connections and a
population of 400 people. The facility has a permitted flow of 0.22 MGD and as built flow rate of 0.05 MGD. The
permit also contains an intermediate phase flow of 0.11 MGD. The treatment system includes the following
wastewater treatment components:
• Influent pump station
• Influent bar screen
• Aeration basin
• Two sludge holding tanks (7,500 gallons
and 12,000 gallons)
• Clarifier
• UV Disinfection
• Contact chamber (used for flow
measurement purposes and backup
chlorination)
• Effluent pump station
• Post Aeration
• Sludge drying beds

APPLICATION
The application does not indicate any changes in the facility or treatment since the last modification of the
permit in 2018. The treatment system is owned and operated by Clarke Utilities, Inc. The annual average daily
flow is indicated as 0.029 MGD over the last two years, so the facility is operating at well below its designed and
permitted capacity.
The permittee had submitted a modification request in 2019 that appears to be to add in wastewater from a
water treatment plant (Glen Greek Subdivision in Garner). DWR requested additional information on this
modification request, but the permittee never provided a response to the request. The Add -Info requested
noted that if there was no response the application would be deactivated. This did not happen at the time, and
the modification request was still in BIMS. The modification was returned in BIMS as part of this review
(January 2023) and is no longer under review.
INSPECTION
The most recent inspections occurred on February 2, 2023. Recent DMR violations were discussed, and the
report noted that the sludge holding tank was full but was being pumped within the next week. The inspection
did not note any issues of concern with the facility.
MONITORING DATA REVIEW:
Parameter Units
Min
Max
Avg
Permit Limit
Comments
Flow (MGD)
0.0
0.2
0.0
0.05 MA
No MA exceedances
Total Monthly Flow (MG)
0.0
1.1
0.8
BOD (m /L) Summer
1.0
12.0
1.7
18 MA 27 DM
BOD (m /L) Winter
1.0
13.0
2.9
29 MA 43.5 DM
TSS (m /L)
0.8
18.0
2.2
30 MA 45 DM
Temp (C) - Upstream
0.0
29.8
17.7
One high value removed for analysis
Temp (C) - Effluent
2.4
27.8
19.2
Temp (C) - Downstream
0.0
29.9
17.7
One high value removed for analysis
NH3-N m L Summer
0.0
16.5
1.3
5 MA 25 DM
NH3-N m L Winter
0.0
17.3
2.3
12 MA 35 DM
DO (mg/L) - Upstream
0.0
12.5
5.9
Four high values removed, may have
missing decimal.
DO m L - Effluent
5.2
25.1
7.6
5 DA
DO (mg/L) - Downstream
0.0
12.7
6.4
_
One high value removed, may have
missing decimal.
Fecal # ml - Upstream
1.0
3,3500.0
1,787.6
High U D Values but Effluent very low
Fecal # ml - Effluent
0.5
21.0
1.0
200 MA 400 DM
No value >21; 90 reported less than 1
Fecal # ml - Downstream
1.0
2,6000.0
1,622.9
High U D Values but Effluent very low
TRC µ L
0.0
48.0
9.6
17 DM
One exceedance but < compliance level
Total Nitrogen m L
0.5
16.8
4.2
-
TN Monthly lbs month
1.7
116.4
28.9
TN Annual lbs ear
228.5
498.3
356.1
Total Phosphorus m L
0.0
5.7
1 1.5
H su
6.8
7.4
1 N/A
>-6 and s9
MA - Monthly Average DM - Daily Max QA -Quarterly Average DA - Daily Average Summer - April through Oct Winter - Nov through March
The data reviewed for the renewal is from February 2018 through January 2023.
REVIEW OF PERMIT LIMITS:
Flow - The facility is operating on average at around 58% of the as -built flow (0.05MGD) allowed by the permit.
None of the 60 monthly average values was above 0.034 MGD. These data assessments included removing one
outlier value of 344 MGD reported in December 2022. This value was four orders of magnitude higher than
other reported values and was obviously inaccurate.
Deer Chase WWTP Fact Sheet
NPDES Renewal 2023 - April 21, 2023
Page 2

BOD / Fecal- There were no violations of BOD and Fecal limits. The facility monitors upstream and downstream
for fecal in addition to effluent monitoring. U/D monitoring for fecal show regular values that are high. 291
instream fecal values out of 520 total instream samples were above 200 (#/mL). It is unclear why these
instream values are high. The effluent fecal values reported have never been above 21/mL. Nearly 90% of
effluent fecal values have been reported as less than 1. So it is apparent that the discharge is not a fecal issue.
TSS- The were no violations for TSS in this permit cycle.
Ammonia (NH3-N) and Whole Effluent Toxicity (WETS- Under the current active flow limit (0.05MGD) this
facility has had NH3-N limits and WET requirements since the early 1990's. Documentation in this time frame
shows that the permittee accepted the addition of WET requirements and existing NH3-N limits rather than
receiving more stringent NH3-N limits. Revised ammonia criteria, consistent with EPA requirements, no longer
allow for the use of action level standards (like WET testing in this case) to be used in place of otherwise
required chemical limitations (more stringent NH3-N limits). In response to this adjustment the WET
requirement in this permit has been reviewed for removal. Removal of the WET requirements would also result
in changes to the NH3-N limits in the permit as well. These issues are discussed below
The facility is a 100% domestic wastewater discharger that has been in compliance with the WET testing
requirements over the last five years. The facility did have some toxicity failures in the first quarter of the
permit (early 2018) but has had no issues since that time. The Aquatic Toxicology Branch and Raleigh Regional
Office staff have been contacted about removal of the WET requirement (emails attached). No issues were
raised with removal of the WET requirement in the permit.
Over the last permit cycle there was one violation of NH3-N summer limits that resulted in an NOV. With the
removal of the WET requirements the Division has evaluated passed permit renewals to determine the
necessary permit limits for NH3-N. Previous Waste Load Allocation (WLA) files were reviewed to assess
modeling results for the potential impact of NH3-N from the discharge as an oxygen consuming waste. In
addition, the WLA spreadsheet completed and attached in this Fact Sheet was evaluated for the potential impact
of NH3-N as a toxicant. The most stringent limit applicable for the 0.05 MGD flow from these assessments was
determined and resulted in a change in the summer NH3-N limits. The proposed summer limits are - monthly
average of 2.0 mg/L and a daily max of 10.0 mg/L. The winter limit is unchanged.
Based on the eDMR data from the previous permit cycle it is possible that these limit changes could have
resulted in a few additional limit violations for the permittee. Consideration will have to be given to any needed
operational adjustments to assure ongoing compliance with the new limits. The draft permit proposes to allow
an eighteen (18) month compliance period for this change with the new limits being effective 18 months from
the effective date of the issued permit. The previous summer limits (5 and 25) will remain in place for the first
18 months of the permit.
Nutrients
Total Nitrogen load numbers over the permit cycle included a maximum annual load of slightly over 498 lbs.
This annual load is well below that discharge allocation load of 4,448 lbs. Total Phosphorous is monitoring only
in the permit with no limit and values do not appear to show any issue. The permit effluent tables previously
included an eDMR code of 00600 for the TN loading numbers. These codes have been corrected to QM600 for
monthly load and QY600 for annual load.
COMPLIANCE:
This facility had four (4) violations during the permit term. Three of these violations were in the first quarter of
2018 after the permit was first renewed and were for WET violations. These WET violations resulted in one
enforcement case with a $3,000 penalty and $60.20 enforcement cost. There have been no additional WET test
failure since that time. Aquatic Toxicology has noted one recent reporting issue in January 2023. In this
Deer Chase WWTP Fact Sheet
NPDES Renewal 2023 — April 21, 2023
Page 3

instance the permittee reported a passing WET test requirement in eDMR but did not submit the separate AT
form. The permittee has failed to pay enforcement assessments from 2017 and 2018 totaling $3,349.47.
FILE HISTORY REVIEW SUMMARY
• Permit was originally issued in December 1985
• June 3, 1988 -Waste Load Allocation (WLA) -Class C Waters Design flow = 0.11 MGD s7Q10 =0 cfs
w7Q10 = 0 cfs; 30Q2 = - cfs Avg cfs = 2.85
Season
BODS
m L
NH3-N
m L
DO
m L
TSS
m L
Fecal
# 100 ml
pH
std units
Summer
12
7
6
30
1,000
6-9
Winter
20
15
6
30
1,000
6-9
The document discussed 7Q10 flows from USGS as being overestimated because they did not account for
impoundment upstream of the discharge. Division staff inspected the creek and proposed the flows to be
used.
August 21,1987 WLA - This WLA is done for two flows, 0.11 MGD and 0.22 MGD with flow numbers set at
7010(sl= 0: 7010(w) = 0.85 cfs; 3002 = 0.30 cfs and average flow = 3.0 cfs. Stream classification is C:
Flow
BODS
NH3-N
DO
TSS
Fecal
pH
MGD
m L
m L
m L
m L
# 100 ml
std units
(w
0.11
6
30
1,000
6-9
10(w
4
(w
0.22
6
30
1,000
6-9
10(w
4
Also instream monitoring U,D for DO, Temp, Fecal and Conductivity. The permittee had requested less
stringent limits for BOD and NH3-N but that requested change was not approved.
June 27, 1990 WLA - This WLA is done for two flows, 0.11 MGD and 0.22 MGD with flow numbers set at
7Q10(s)= 0; 7Q10(w) = 1.4 cfs; 30Q2 = 0.50 cfs and average flow = 3.0 cfs. Stream classification is C; NSW:
Flow
BODS
NH3-N
DO
TSS
Fecal
pH
MGD
(m /L)
(m /L)
m /L)
(mg/L)
(#/100 ml)
(std units)
0.11
1 s)
6
30
200
6-9
12(w
(w)
0.22
10(w
4
6
30
200
6-9
Also instream monitoring U,D for DO, Temp, pH, Fecal and Conductivity. This package also outlines that the
WLA resulted in more stringent NH3-N limits, but the permittee choose to maintain exiting limits and add
WET testing requirements. The document did not clearly indicate what levels the NH3-N limits would be at
without the addition of WET requirements. Documents note that existing flow is at 0.05 MGD and there
have been no requests for ATC for expansion. The documents also discuss need for alternatives analysis for
any expansion and notes that the facility is existing and therefore does not have TP or Chlorine limits at this
time. A letter on Chlorine toxicity and the need to eventually meet 17µg/L limit was also in the WLA
package.
February 25, 1993 WLA - This WLA is done for three flows, 0.05 MGD, 0.11 MGD and 0.22 MGD with flow
numbers set at 7Q10(s)= 0; 7Q10(w) = 1.4 cfs; 30Q2 = 0.50 cfs and average flow = 5.0 cfs. Stream
classification is C; NSW
Flow
BODS
NH3-N
DO
TSS
Fecal
pH
Total P
TRC
MGD
(mg/L)
(mg/L)
(mg/L)
(mg/L)
(#/100ml)
(std units)
(mg/L)
(µg/L)
MA
MA
DA
MA
MA
quarter avg
DM
0.05
9 w)
�)
6
30
200
6-9
Monitor
Monitor
12
0.11
(w
6
30
200
6-9
2
17
10
4 w)
0.22
6
30
200
6-9
2
17
10((w)
4 ( )
Deer Chase WWTP Fact Sheet
NPDES Renewal 2023 — April 21, 2023
Page 4

Also required TN monitoring and reporting (quarterly) and toxicity testing for the 0.05 flow only. Instream
monitoring for temperature, DO, conductivity and fecal. Flows were recalculated based on USGS report, but
not utilized due to impact of beaver dam along the creek.
July 19, 1999 - Authorization to Construct (ATC) - Authorization for modification to existing 0.05 MGD
system to install a 12,000 gallon sludge holding tank; alter existing blowers and add additional piping,
valves etc. as needed.
• October 11, 2000 Permit Renewal.
Flow
BOD5
NH3-N
DO
TSS
Fecal
pH
Total N
Total P
TRC
MGD
(mg/L)
(mg/L)
(mg/L)
(mg/L)
(#/100ml)
(std
(mg/L)
(mg/L)
(µg/L)
MA/DM
MA
DA
MA/DM
MA/DM
units
DM
0.05
5 sw
(w
6
30/45
200/400
6-9
Monitor
Monitor
Monitor
29843
12
0.11
(s)
(w)
6
30/45
200/400
6-9
Monitor
Monitor
17
0/ 15
4
0.22
(w
6
30
200
6-9
Monitor
Monitor
17
10(w
4
Total N reporting is concentration (2/month) along with monthly load (lbs/month) and annual load
(lbs/year). The permit also includes Temperature monitoring (E,U,D), DO (U/D) and Fecal (U/D) and
Quarterly WET monitoring at the 0.05 MGD flow. The permit includes Special Conditions for WET; Total N
load calculation; Wastewater Management Plan within 180 days and an Alternative Analysis prior to
expiration of the permit. The WET requirement is noted as being maintained due to the facility's failed tests
in the past and no good information on the cause of the failures. The review document notes that
connection to the Town of Wake Forest WWTP doesn't appear to be an option because the plant is within
the limits of Rolesville. This draft was prepared in 1998 but was part of a request for Public Hearing for a
large number of facilities by the Neuse River Foundation. As Neuse River Management Strategy rules were
developed, these permits were finalized.
• Wastewater Management Plan - Submitted April, 2001 to meet permit condition for Plan submittal.
• March 17, 2003 - Memo to Division staff about relocation plan for an aeration structure on the effluent force
main.
• April 17, 2003 Permit Renewal - Package included the Wastewater Management Plan and Alternatives
Analysis required in the previous permit. The alternatives analysis looked at potential options including
connection to the Wake Forest WWTP, onsite non -discharge, spray irrigation systems, etc. All of these
alternatives were found to be cost prohibitive or not technically possible. The permit documents also
include a 2002 Assessment Report for the Toms Creek Watershed that notes chlorine from the Deer Chase
WWTP as one possible factor in stream impairment. The permit included modification of NH3-N limits to
add DM limits under each flow level. For 0.05MGD NH3-N DM limits (S and W) of 25 and 35mg/L. For 0.11
and 0.22MGD flows DM limits of 10 and 20 mg/L. All flows included the addition of TRC daily max limit of
17µg/L that became effective 18 months after the effective date of the permit. The permit required, for all
three flows, that the components of TN be reported separately and set the DO limit at 5mg/L. The permit
also included a Special Condition to update the Engineering Alternatives Analysis prior to any expansion of
the WWTP.
• June 20, 2003 - Permit Modification to clarify toxicity test sampling months (Jan, April, July and Oct.)
• November 21, 2003 - Permit Modification to correct toxicity test effluent concentration of 90% rather than
5.5%.
• April 13, 2004 - Permit Name/Ownership Change - Permit issued to Clarke Utilities, LLC as new owner.
• March 12, 2007 - ATC for installation of a dechlorination system utilizing sodium sulfite under the fast -track
system and in accordance with minimum design criteria.
• March 21, 2007 -ATC for modifications to the existing 0.05 MGD WWTP for the installation of a UV
disinfection system with audible and visible alarms. The chlorinator and dechlorinator remain in place as
backup.
• May 15, 2008 - Permit Renewal - The permit includes updated treatment system components to account for
the added UV system. Also adjusts owner name to Clarke Utilities, Inc., and updates WWTP location to 3504
Donner Trail. The permit adds special conditions for Annual Limits for Nitrogen and Total Nitrogen
Allocations. The permittee had asked for reduction in WET requirements, but the Division did not approve
Deer Chase WWTP Fact Sheet
NPDES Renewal 2023 — April 21, 2023
Page 5

any changes because the system discharges to waters impaired for biological integrity. Notes from Wake
County staff that had inspected the facility indicated one sludge holding tank not operational due to
corrosion damage to the wall of the tank.
• July 13, 2013 - Permit Renewal - The permit increased nutrient monitoring from monthly to 2/month and
also removed the special condition for Total Nitrogen limits since the facility doesn't have TN mas limits.
The permit updated treatment system components to note that both sludge holding tanks were operational.
• January 6, 2018 - Permit Renewal - This renewal added electronic submittal language for DMRs, added
regulatory citations and updated the permit map.
• September 11, 2019 - Permit Modification Documents - Various information is included in the files related
to a modification request that seeks to add WTP wastewater from the Glen Creek Subdivision.
• January 27, 2020 - Additional Information Request (in LF) - The Division asks for additional information on
the 2019 modification request before review of the request can continue. The letter indicates that if there is
no response within 60 days, the project will be deactivated. This modification request was still showing as
under review in BIMS when the initial review for the 2023 renewal started. After emails with the permit
reviewer, RRO staff and other DWR staff it was determined that no response was ever received from the
permittee on this add -info request. The project was deactivated by Returning the application in BIMS on
January 18, 2023.
PROPOSED PERMIT CHANGES:
• Updated eDMR requirements to be consistent with final EPA rule.
• Added or updated regulatory citations throughout permit as needed.
• Language in paragraph 2 of the Supplement to Permit Cover Page has been adjusted to outline
requirements prior to operating at the 0.11 and 0.22 MGD levels.
• eDMR codes for BOD, TSS, NH3-N, TN and TP updated to replace initial 0 with C. Added code for Total
flow - 82220.
• eDMR codes for TN load have been corrected to note QM600 for monthly and QY600 for annual load.
• Footnotes in the effluent tables have been updated with current language where needed.
• Corrected descriptive language above effluent table in Section A. (3.) to refer to 0.22MGD flow.
• Permit map information updated including correcting location of the discharge point that was inaccurate
in 2018 permit.
• Added Special Condition for Nutrient Re -opener in section A.(7.).
• Monitoring requirements for WET have been removed from the permit. This has also resulted in a change
in the summer NH3-N monthly average limit from 5.0 mg/L to 2.0 mg/L. This will also result in the daily
max limit being reduced to 10.0 mg/L (five times the monthly average). These changes will be given an
18-month compliance schedule from the effective date of the permit.
PROPOSED SCHEDULE FOR PERMIT ISSUANCE:
Draft Permit to Public Notice: May 2, 2023
Permit Scheduled Effective Date: August 1, 2023
STATE CONTACT:
If you have questions concerning the above or the attached documents, please contact Bradley Bennett at
[e-mail]. .
Deer Chase WWTP Fact Sheet
NPDES Renewal 2023 — April 21, 2023
Page 6

AFFIDAVIT OF PUBLICATION
Account #
Order Number
Identification
Order PO
Amount
Cols
Depth
19489
422814
Print Legal Ad-IPL01234100 - IPLO123410
$549.90
1
51 L
Attention: Wren Thedford STATE OF NORTH CAROLINA
DEPARTMENT OF WATER RESOURCES - RALEIGH COUNTY OF WAKE, COUNTY OF DURHAM
1617 MAIL SERVICE CENTER Before the undersigned, a Notary Public of Dallas
RALEIGH, NC 276991617 County, Texas, duly commissioned and authorized to
administer oaths, affirmations, etc., personally
[e-mail]
appeared Tara Pennington, who being duly sworn or
affirmed, according to law, cloth depose and say that he
Public Notice
or she is Accounts Receivable Specialist of the News &
North Carolina Environmental Man-
Observer Publishing Company, a corporation organized
agement Commission/NPDES Unit
and doingbusiness under the Laws of the State of North
1617 M
1617 Mail Service Center
Raleigh, NC 27699-1617
Carolina, and publishing a newspaper known as The
Notice of Intent Issue a NPDES
News & Observer, Wake and State aforesaid, the said
Wastewater Permit it NC0063746 Deer
Chase WWTP, and NCO073318 Whip-
newspaper in which such notice, paper, document, or
poorwill Valley WWTP The North Caro-
legal advertisement was published was, at the time of
lina Environmental Management Com-
mission proposes to issue a NPDES
each and every such publication, a newspaper meeting
wastewater discharge permit to the
qualifications of Section 1d l all of the requirements an
q q
person(s) listed below. Written com-
ments regarding the proposed permit
597 of the General Statutes of North Carolina and was a
will be accepted until 30 days after
qualified newspaper within the meaning of Section 1-597
qg
the publish date of this notice. The ;
Director of the NC Division of Water
of the General Statutes of North Carolina, and that as
Resources (DWR) may hold a public
such he or she makes this affidavit; and is familiar with
hearing should there be a significant
degree of public interest. Please mail
the books, files and business of said corporation and by
comments and/or information re-
;
reference to the files of said publication the attached
quests to DWR at the above address.
Interested persons may visit the DWR
advertisement for DEPARTMENT OF WATER RESOURCES -
at 512 N. Salisbury Street, Raleigh, NC
RALEIGH was inserted in the aforesaid newspaper on
27604 to review the information on
file. Additional information on NPDES
dates as follows:
permits and this notice may be found
on our website: https://deq.nc.gov/
1 insertion(s) on:
public-notices-hearings,or by calling
published
[phone]. Clarke Utilities, Inc ;
05/19/23
[223 Hwy 70 East; Suite 115; Garner,
NC 27529] has requested renewal
of NPDES permit NCO063746 for the
Deer Chase WWTP, located in Wake
County. This permitted facility dis-
charges 100% domestic wastewater
to Toms Creek, a class C; NSW water
in the Neuse River Basin. Some of the
parameters in the permit are water
F
quality limited. This discharge may
r
affect future allocations in this seg-
ment of Toms Creek. Clarke Utilities,
Lr
Inc [223 Hwy 70 East; Suite 115; Gar-
ner, NC 27529] has requested renewal
I certify or declare) under penalty of perjury that the
of NPDES permit NCO073318 for the
Whippoorwill Valley WWTP, located in
foregoing is true and correct.
Wake County. This permitted facility
discharges 100% domestic wastewa-
ter to Smith Creek, a class C; NSW
water in the Neuse River Basin. Some
of the parameters in the permit are
water quality limited. This discharge
{Wr
may affect future allocations in this
segment of Smith Creek,
Notary Public in and for the state of Texas, residing in
Dallas County
IPL0123410
May 19 2023
'�"' '• STEPHANIE HATCHER
= - x• ;.
:x: •= My Notary I # 1335YA06
�; e:
E)Orss 4anuary 14, 2026
Extra charge for lost or duplicate affidavits.
Legal document please do not destroy!

Bennett, Bradley
From: Hayes, Mitch
Sent: Monday, May 15, 2023 9:14 AM
To: Bennett, Bradley
Cc: Manuel, Vanessa
Subject: RE: Draft Permits to Notice - Whippoorwill Valley (NC0073318) and Deer Chase
(NC0063746) WWTPs
Bradley,
I did not see any errors or corrections to be made for the two draft permits. Nice job in writing these up.
Mitch
Mitch Hayes
Environmental Specialist 1
3800 Barrett Drive
Mail Service Center 1628
Raleigh, NIC 27609-1628
919.791.4261
mitch. hayes(a_)deg.nc.gov
Raleigh Regional Office
Regional Operations Section
NICDEQ — Division of Water Resources
Dl-,.E Q:>
NORTH CAROLINA
Department of Environmental Quality
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
From: Bennett, Bradley <[e-mail]>
Sent: Thursday, May 4, 2023 4:37 PM
To: Hayes, Mitch <mitch. [e-mail]>
Cc: Manuel, Vanessa <[e-mail]>
Subject: Draft Permits to Notice - Whippoorwill Valley (NC0073318) and Deer Chase (NC0063746) WWTPs
Hey Mitch,
These two draft permits have been forwarded on for public notice. That should happen within the next week I hope.
have forwarded copies of the drafts to Joel Clarke also. I attached the drafts here again. I sent the Fact Sheets earlier
but if you need them again, let me know and I'll forward them to you.
Thanks for your help on these two drafts!
[37

Bradley Bennett
Compliance and Expedited Permitting Phone: [phone]
NC Division of Water Resources
1617 Mail Service Center Email: bradley.bennett(o)ncdenr.gov
Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public records laws
DEQ is updating its email addresses to @deq.nc.gov in phases from May 1st to June 91h 2023.
Employee email addresses may look different, but email performance will not be impacted.

Bennett, Bradley
From: JOEL CLARKE <[e-mail]>
Sent: Monday, May 8, 2023 2:45 PM
To: Bennett, Bradley
Subject: [External] Re: Draft Permits for Whippoorwill Valley (NC0073318) and Deer Chase
(NC0063746)
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
From: Bennett, Bradley <[e-mail]>
Sent: Thursday, May 4, 2023 4:26 PM
To: JOEL CLARKE <[e-mail]>
Subject: Draft Permits for Whippoorwill Valley (NC0073318) and Deer Chase (NC0063746)
Mr. Clarke,
I have attached the draft permits for the two Clarke Utilities WWTPs noted in the subject line above. These draft
permits will be going to public notice within the next week. Please take a look at the cover letters and permits for each
and let me know if you have any questions or comments.
Please respond to this email to verify that you received the draft permits and that you were able to download, open
and print the files for your records.
Thanks
Bradley Bennett
Compliance and Expedited Permitting Phone: [phone]
NC Division of Water Resources
1617 Mail Service Center Email: [e-mail]
Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public records laws
DEQ is updating its email addresses to @deq.nc.gov in phases from May 1st to June 9th 2023.
Employee email addresses may look different, but email performance will not be impacted.

Bennett, Bradley
From: Nicholson, Molly
Sent: Friday, May 5, 2023 8:48 AM
To: Bennett, Bradley; Moore, Cindy
Subject: RE: Draft Permit for Deer Chase WWTP - NCO063746
Good morning,
Thank you for sending this over. I will make a note in our database.
Best,
Molly Nicholson
Environmental Specialist II - Compliance and Enforcement
Aquatic Toxicology Branch
N.C. Division of Water Resources - Water Sciences Section
N.C. Department of Environmental Quality
919-743-8440 Office
919-743-8517 Fax
[e-mail]
Please note: My email address will change to [e-mail] on May 18t", 2023
1621 Mail Service Center, Raleigh, NC 27699-1623
Submit AT Forms electronically to: [e-mail]
, c, - DE " 7' `
kl;
NORTH CAROLINA -
Department of Environmental Quality
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
From: Bennett, Bradley <[e-mail]>
Sent: Thursday, May 4, 2023 4:47 PM
To: Moore, Cindy <[e-mail]>; Nicholson, Molly <[e-mail]>
Subject: Draft Permit for Deer Chase WWTP - NCO063746
Hey Guys,

Just wanted to forward this draft permit for Deer Chase WWTP — NCO063746 to you for review. This is one of the ones
we are removing WET requirements from, so not much for you to look at, but I did want you to see the draft that is
headed for public notice.
Thanks for your input on this one.
MM
Bradley Bennett
Compliance and Expedited Permitting Phone: [phone]
NC Division of Water Resources
1617 Mail Service Center Email: bradley.ben nett(o)ncdenr.gov
Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public records laws
DEQ is updating its email addresses to @deq.nc.gov in phases from May 1st to June 9th 2023.
Employee email addresses may look different, but email performance will not be impacted.

Bennett, Bradley
From: Bennett, Bradley
Sent: Thursday, May 4, 2023 4:44 PM
To: Kinney, Maureen
Subject: Two Draft Permits for Clarke Utilities
Attachments: NC0073318_Draft Permit and Cover Ltr_2023.pdf; NC0063746_Draft Permit and Cover
Ltr_2023.pdf, NC0063746_Fact Sheet Binder_2023.pdf; NC0073318_Fact Sheet Binder_
2023.pdf
Hey Maureen,
Here are two draft permits for your review. They are both Clarke Utilities facilities — NCO073318 — Whippoorwill Valley
WWTP and NCO062746 — Deer Chase WWTP. Let me know if you have any questions/comments on these. They have
been forwarded on for public notice hopefully within the next week or so.
Thanks
L3.3
Bradley Bennett
Compliance and Expedited Permitting Phone: [phone]
NC Division of Water Resources
1617 Mail Service Center Email: [e-mail]
Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public records laws
DEQ is updating its email addresses to @deq.nc.gov in phases from May 1st to June 91h 2023.
Employee email addresses may look different, but email performance will not be impacted.

Bennett, Bradley
From: Carpenter, Sydney
Sent: Wednesday, April 26, 2023 1:48 PM
To: Bennett, Bradley
Subject: RE: Draft Permit for Deer Chase WWTP (NC0063746)
Hey Bradley,
I didn't find any issues with this draft permit. Excellent job!
Have a great rest of your week!
Sydney Carpenter (she/her)
Environmental Specialist II
Compliance and Expedited Permitting Unit
Division of Water Resources
N.C. Department of Environmental Quality
Office: 919-707-3712
sydney.carp enterPncdenr.gov
1617 Mail Service Center
Raleigh, NC 27699-1617
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Bennett, Bradley <[e-mail]>
Sent: Friday, April 21, 2023 8:47 AM
To: Carpenter, Sydney <[e-mail]>
Subject: Draft Permit for Deer Chase WWTP (NC0063746)
Hey Sydney,
Here is another Clarke Utilities, Inc. Draft renewal. This one is for Deer Chase WWTP — NC0063746. Let me know what
you think.
M NCO063746 - Clarke Utilities - Deer Chase WWTP
Hope you have had a good week! I know you are glad to be winding down on that SOC.
L3.3
Bradley Bennett
Compliance and Expedited Permitting
NC Division of Water Resources
1617 Mail Service Center
Phone: [phone]
Email: bradley.ben nettCaMcdenr.gov

Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public records laws

Bennett, Bradley
From: Moore, Cindy
Sent: Tuesday, April 18, 2023 12:35 PM
To: Bennett, Bradley; Nicholson, Molly
Subject: Re: Permit Renewal - Removing WET requirements for Deer Chase WWTP (NC0063746)
I agree to remove the WET test per the 1999 WET guidance document which specifies domestic facilities
would not be under the WET testing requirements. The other parameters within the permit would tell us if
there are problems with this facility.
Thanks for your consideration.
From: Bennett, Bradley <[e-mail]>
Sent: Tuesday, April 18, 2023 12:30 PM
To: Moore, Cindy <[e-mail]>; Nicholson, Molly <[e-mail]>
Subject: RE: Permit Renewal - Removing WET requirements for Deer Chase WWTP (NC0063746)
Over the permit cycle they have had one NH3-N violation. They also started out the cycle in 2018 with some tox issues
for the first quarter. No issues since that time, all pass. They did, however, fail to send you guys their AT form in
January which led to an NOV from you guys. But they did pass that test and noted it in the eDMR.
L3_J
From: Moore, Cindy <[e-mail]>
Sent: Tuesday, April 18, 2023 12:27 PM
To: Bennett, Bradley <[e-mail]>; Nicholson, Molly <[e-mail]>
Subject: Re: Permit Renewal - Removing WET requirements for Deer Chase WWTP (NC0063746)
I am assuming this facility is meeting all of its monitoring parameters, correct? If they are meeting all their
their parameters, I am fine with removing the WET tests.
From: Bennett, Bradley <bradley. ben [e-mail]>
Sent: Tuesday, April 18, 2023 12:24 PM
To: Moore, Cindy <[e-mail]>; Nicholson, Molly <[e-mail]>
Subject: RE: Permit Renewal - Removing WET requirements for Deer Chase WWTP (NC0063746)
Cindy, Molly
Guess I should have mentioned one other thing on this one. They discharge to Toms Creek which is listed as impaired
for Benthos. Does that change how you might feel about taking the toxicity testing out?
m
From: Moore, Cindy <[e-mail]>
Sent: Tuesday, April 11, 2023 9:49 AM
To: Bennett, Bradley <[e-mail]>; Nicholson, Molly <[e-mail]>
Subject: Re: Permit Renewal - Removing WET requirements for Deer Chase WWTP (NC0063746)

I would agree to remove the toxicty testing due to this facility being a domestic facility.
thx,
Cindy
From: Bennett, Bradley <bradley. ben [e-mail]>
Sent: Tuesday, April 11, 2023 9:47 AM
To: Moore, Cindy <[e-mail]>; Nicholson, Molly <[e-mail]>
Subject: Permit Renewal - Removing WET requirements for Deer Chase WWTP (NCOO63746)
Hey Guys,
Here is another one of the 100% domestic discharges that currently has WET testing. It looks like they have been in
compliance for the last few years. Any concerns about removing the requirements for this one?
Thanks
m
Bradley Bennett
Compliance and Expedited Permitting Phone: [phone]
NC Division of Water Resources
1617 Mail Service Center Email: [e-mail]
Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public records laws

Bennett, Bradley
From: Hayes, Mitch
Sent: Tuesday, April 11, 2023 9:48 AM
To: Bennett, Bradley
Cc: Manuel, Vanessa
Subject: RE: Permit Renewals for Clarke Utilities permits - Whippoorwill Valley (NC0073318) and
Dear Chase (NC0063746)
Joel Clarke, ORC, is operating the plant very well with no issues that I saw. I do not see any concerns in eliminating WET
from the permit.
Mitch
Mitch Hayes
Environmental Specialist 1
3800 Barrett Drive
Mail Service Center 1628
Raleigh, NC 27609-1628
919.791.4261
Raleigh Regional Office
Regional Operations Section
NCDEQ — Division of Water Resources
D- E-
�
NORTH CAROLINA C1110)
Department of Environmental quality
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
From: Bennett, Bradley <[e-mail]>
Sent: Tuesday, April 11, 2023 9:32 AM
To: Hayes, Mitch <mitch. [e-mail]>
Cc: Manuel, Vanessa <[e-mail]>
Subject: Permit Renewals for Clarke Utilities permits - Whippoorwill Valley (NC0073318) and Dear Chase (NC0063746)
Hey Mitch,
Hope you are doing well. I am working on permit renewals for these two Clarke Utilities facilities and noticed that you
had done the most recent inspections earlier this year. I just wanted to get in touch and see if you had any comments
about the renewals that you wanted to pass along. I have a draft for Whippoorwill Valley in the works now and have
done a little work on Deer Chase. I hope to send these to you for review soon and then on to notice. One thing I
wanted your input on for Deer Chase is their WET requirements. It looks like they have been consistently passing these
and recently the Aquatic Tox staff have indicated that we should remove WET requirements for these 100% domestic
discharges if there are no noted problems. Do you have any concerns about potentially eliminating WET requirements
for Deer Chase?

Thanks for tour help.
Bradley Bennett
Compliance and Expedited Permitting Phone: [phone]
NC Division of Water Resources
1617 Mail Service Center Email: bradley.ben nett(o)ncdenr.gov
Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public records laws

NH3/TRC WLA Calculations
Facility: Clarke Utilities - Deer Chase WWTP
Permit No. NC0063746
Prepared By: Bradley Bennett
Enter Design Flow (MGD): 0.05
Enter s7Q10 (cfs): 0
Enter w7Q10 (cfs): 1.4
Total Residual Chlorine (TRC)
Daily Maximum Limit (ug/1)
s7Q10 (CFS)
DESIGN FLOW (MGD)
DESIGN FLOW (CFS)
STREAM STD (UG/L)
Upstream Bkgd (ug/1)
IWC (%)
Allowable Conc. (ug/1)
Fecal Coliform
Monthly Average Limit:
(If DF >331; Monitor)
(If DF<331; Limit)
Dilution Factor (DF)
Design
0
0.05
0.0775
17.0
0
100.00
17
0.22 <= Permitted Flow if Different from Design
0
1.4
Permitted
0
0.22
0.341
17
0
100.00
17
Ammonia (Summer)
Monthly Average Limit (mg NH3-N/1)
s7Q10 (CFS)
DESIGN FLOW (MGD)
DESIGN FLOW (CFS)
STREAM STD (MG/L)
Upstream Bkgd (mg/1)
IWC (%)
Allowable Conc. (mg/1)
< 1 MGD Policy Applies
Ammonia (Winter)
Monthly Average Limit (mg NH3-N/1)
Design
0
0.05
0.0775
1.0
0.22
100.00
1.0
Permitted I
0
0.22
0.341
1.0
0.22
100.00
1.0
Design Permitted
Design
Permitted
w7Q10 (CFS)
1.4
1.4
200/100m1 200/100m1 DESIGN FLOW (MGD)
0.05
0.22
DESIGN FLOW (CFS)
0.0775
0.341
STREAM STD (MG/L)
1.8
1.8
1.00 1.00 Upstream Bkgd (mg/I)
0.22
0.22
IWC (%)
5.25
19.59
Allowable Conc. (mg/1)
30.3
8.3
Total Residual Chlorine
1. Cap Daily Max limit at 28 ug/I to protect for acute toxicity
Ammonia (as NH3-N)
1. If Allowable Conc > 35 mg/I, Monitor Only
2. Monthly Avg limit x 3 = Weekly Avg limit (Municipals)
3. Monthly Avg limit x 5 = Daily Max limit (Non-Munis)
If the allowable ammonia concentration is > 35 mg/L, no limit shall be imposed
* By Policy dischargers < 1 MGD get limits no lower than 2 & 4 due to BAT
* From 2B .0404(c) - Winter Limits can be no less stringent than 2 times the summer limits
Fecal Coliform
1. Monthly Avg limit x 2 = 400/100 ml = Weekly Avg limit (Municipals) = Daily Max limit (Non -Muni)

Whole Effluent Toxicity Testing and Self Monitoring Summary
Davidson River Village WWTP (EBDC, Da
NC0000078/001
County:
Transylvania
Ceri7dPF
Begin:
9/1/2021
Cerio pf lim: 2.9%
NonComp: Single
J
F M
A
M
2019
Pass
- -
Pass
-
2020
Pass
- -
Pass
-
2021
Pass
- -
Pass
-
2022
H
- -
Pass
-
2023
H
Pass -
-
-
Davidson Water Inc. WTP
(NCG590021)
NCO084425/001
County:
Davidson
Ceri7dPF
Begin:
10/1/2017 Chr Monit: 0.25%
NonComp:
J
F M
A
M
2019
-
Fail -
-
-
2020
2021
-
- Fail (INVALID)
Pass
-
Deer Chase Subdivision
WWTP
NCO063746/001
County:
Wake
Ceri7dPF
Begin:
2/1/2018
chr lim: 90% @ 0.05
NonComp: Single
J
F M
A
M
2019
Pass
- -
Pass
-
2020
Pass
- -
Pass
-
2021
Pass
- -
Pass
-
2022
Pass
- -
Pass
-
2023
NR
- -
-
-
Dempsey E. Benton WTP
NCO088285/001
County:
Wake
Ceri7dPF
Begin:
5/1/2014
Chr Lim: 90% (re -rout
NonComp:
J
F M
A
M
2019
H
H
2020
H
H
2021
H
H
2022
H
H
2023
H
-
Denton WTP, Town of
NCO082949/001
County:
Davidson
Ceri7dPF
Begin:
5/1/2014
Chr Monit: 90%
NonComp:
J
F M
A
M
2019
-
Pass -
-
Pass
2020
-
Pass -
-
Pass
2021
-
Pass -
-
Pass
2022
-
Fail -
-
Pass
Region: ARO Basin: FRB01 Jan Apr Jul Oct SOC JOC:
7Q10: 154 PF: IWC: 21 Freq: Q
J J A S O N
- Pass - - Pass -
- Pass - - Pass -
- Pass - - Pass -
- Pass - - Pass -
Region: WSRO
7Q10:
J
Basin: YAD04
PF: 0.3 IWC:
l A
SOC JOC:
Freq: A
S O N
Region:
RRO
Basin:
NEU02
Jan Apr Jul Oct
SOC JOC:
7Q10: 0.0
PF: 0.05 IWC:
100 Freq: Q
J
J
A
S
O
N
-
Pass
-
-
Pass
-
-
Pass
-
-
Pass
-
-
Pass
-
-
Pass
-
-
Pass
-
-
Pass
-
Region:
RRO
Basin:
NEU02
Jan Apr Jul Oct
SOC JOC:
70.30: NA
PF: 4.0
IWC:
NA Freq: Q
l
l
A
S
O
N
H
H
H
H
H
H
H
H
Region:
WSRO
Basin:
YAD08
Feb May Aug Nov
SOC JOC:
7Q10:
PF:
IWC:
Freq: Q
l
J
A
S
O
N
-
-
Pass
-
-
Fail
-
-
Pass
-
-
Pass
-
-
Pass NR
-
-
Pass
-
-
Pass
-
-
Pass NR
C
D
H
C
D
C
NR
Leizend: P= Fathead minnow (Pimohales Dromelas). H=No Flow (facilitv is active), s = SDlit test between Certified Labs Page 31 of 112

Bennett, Bradley
From:
Denard, Derek
Sent:
Wednesday, January 18, 2023 11:32 AM
To:
Bennett, Bradley
Subject:
Re: Questions About Deer Chase WWTP - NC0063746
Bradley
They never responded to the add info. I think they decided otherwise. Unless they asked to add the for their
renewal, I would just proceed with the renewal.
Derek C. Denard
Environmental Program Consultant, Division of Water Resources
North Carolina Department of Environmental Quality
Office: [phone]
[e-mail]
UpaMmenl oe EnxJrunrnontal 4uallry
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
From: Bennett, Bradley <[e-mail]>
Sent: Wednesday, January 18, 2023 11:16 AM
To: Denard, Derek <[e-mail]>
Subject: Questions About Deer Chase WWTP - NC0063746
Hey Derek,
Hope you are doing well. I had a quick question about this one. The permit expires at the end of the month and has
been assigned to me. When I started looking at info in BIMS and Laserfiche on it I found that there was a permit
application that looks like a Mod to maybe add in some water treatment plant discharge to the system. This started in
2019 and looks like you sent an add info in early 2020 that they never responded to? The application still shows as in
draft in BIMS. In the letter you indicated that if we did not receive a response from them the project would be
deactivated, but it is still in BIMS. Can you give me any more info on what happened with this one. They have not
submitted an actual renewal application since that submittal so I think they need to do that because it looks like this
request didn't go anywhere?

Thanks for any help you can give. If we need to talk let me know and we can set up a Teams call.
Bradley Bennett
Compliance and Expedited Permitting
NC Division of Water Resources
1617 Mail Service Center Email: [e-mail]
Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public records laws

Bennett, Bradley
From: Joel Clarke <[e-mail]>
Sent: Thursday, January 26, 2023 7:41 AM
To: Bennett, Bradley
Subject: Re: [External] Re: Permit Renewal Applications Overdue for Deer Chase (NC0063746)
and Whippoorwill Valley (NC0073318) WWTPs
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
No problem.
Joel Clarke
Clarke Utilities, Inc.
223 Hwy 70 East
East Pointe -Suite 115
Garner, NC 27529
Phone: [phone]
www.clarkeutilities.com
[e-mail]
[e-mail]
On Wednesday, January 25, 2023 at 09:36:12 AM EST, Bennett, Bradley <bradley. ben [e-mail]> wrote:
Joel,
Cassidy just forwarded the electronic copies of the two applications to us. However, you still need to forward signed hard
copies to our office. According to federal rules we still need to get the hard copies with your original signature. Please
send these to:
Wren Thedford
Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
1

Thanks
Bradley Bennett
Compliance and Expedited Permitting Phone: [phone]
NC Division of Water Resources
1617 Mail Service Center Email: [e-mail]
Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public records laws
From: Joel Clarke <[e-mail]>
Sent: Tuesday, January 24, 2023 4:34 PM
To: Bennett, Bradley <bradley. ben [e-mail]>
Subject: [External] Re: Permit Renewal Applications Overdue for Deer Chase (NC0063746) and Whippoorwill Valley
(NC0073318) WWTPs
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
attachment to Report Spam.
The permit renewal applications were sent to Cassidy Kurtz on Dec. 30, 2022.
Let me know if you cant find them.
Thanks
Joel
Joel Clarke
Frarke Utilities, Inc.
223 Hwy 70 East
East Pointe -Suite 115
Garner, NC 27529
Phone: [phone]

www.clarkeutilities.com
0oel(a-clarkeutilities.com
clarkej(aD-bellsouth.net
On Tuesday, January 24, 2023 at 09:30:15 AM EST, Bennett, Bradley <bradley. bennett(a�ncdenr.gov> wrote:
Mr. Clarke,
After our call yesterday I checked with other staff in the central office and our Raleigh Regional Office and was not able to
track down permit renewal submittals for either of these permits. You mentioned talking with someone I think about
getting your submittal routed to the right person. Do you remember who you talked with?
At this point it would be helpful if you could forward copies of the applications if you have copies you could send.
Thanks
Bradley Bennett
Compliance and Expedited Permitting Phone: [phone]
NC Division of Water Resources
1617 Mail Service Center Email: brad ley. bennett(@ncdenr.gov
Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public records laws
From: Bennett, Bradley
Sent: Monday, January 23, 2023 10:46 AM
To: clarkei(obellsouth.net
Subject: Permit Renewal Applications Overdue for Deer Chase (NC0063746) and Whippoorwill Valley (NC0073318)
WWTPs

Mr. Clarke,
The NPDES discharge permits for the two WWTPs mentioned in the Subject line above expire on January 31, 2023. At
this point our records do not show receipt of permit renewal applications for either of these facilities. Renewal
applications are due 180 days before expiration of the current permit. This deadline is established in Federal and State
requirements [33 USC 1251, 40 CFR 122.21 (b), and 15 NCAC 21-1.0105 (e)] and in the conditions of your exiting permit
[Part 11 Section B. Paragraphs 9. and 10.] Discharge of wastewater without a valid permit is a violation of Federal and
State requirements.
If no renewal application is received, the Division is required to make the permit Inactive. If no response is received by
1/31/2023, the Division may take action to make the permits Inactive.
The renewal application form (Modified EPA Form 2A) can be found here:
https://deq. nc.gov/water-quality/aquifer-protection/afo/permits/2021-npdes-modified-epa-form-2a/download
Information on the permitting and renewal process can be found at:
https://deq. nc.gov/about/divisions/water-resources/water-quality-permitting/npdes-wastewater/npdes-permitting-
process/npdes-individual-permit-applications
Please complete and submit the form to:
Ms. Wren Thedford
NC DEQ / DWR / NPDES
1617 Mail Service Center
Raleigh NC 27699-1617
Only the completed original form is required — no extra copies need be submitted.
Thanks for your attention to this matter.
Bradley Bennett

Compliance and Expedited Permitting
NC Division of Water Resources
1617 Mail Service Center Email: brad ley. bennett(@ncdenr.gov
Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public records laws