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HomeMy WebLinkAboutWQ0000165_Final Permit_20070116W ATFRQG Michael F. Easley, Governor o�0F William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources p Alan W. Klimek, P.E. Director Division of Water Quality January 16, 2007 Terry K. Barbour Sands Villa Utilities, Inc. 1400 East Fort Macon Road Atlantic Beach, North Carolina Subject: Permit No. WQ0000165 Sands Villa Utilities, Inc. Sands Villa Resort Wastewater Rotary Distributor Facilities Carteret County Dear Mr. Barbour: In accordance with your permit modification request received September 11, 2006, and subsequent additional information received October 4, 2006, we are forwarding herewith Permit No. WQ000165, dated January 16, 2007, to Sands Villa Utilities, Inc. for the construction and continued operation of the subject wastewater treatment and high rate infiltration facilities. This permit shall be effective from the date of issuance until December 29, 2011, shall void Permit No. WQ000165 issued May 31, 2005, and shall be subject to the conditions and limitations as specified therein. 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. 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, 6714 Mail Service Center, Raleigh, NC 27699-6714. Unless such demands are made this permit shall be final and binding. One set of approved plans and specifications is being forwarded to you. If you need additional information concerning this matter, please contact Matthew Fleahman at (919) 715-6 3. Sincerely 11�Alan W. Klimek, P.E. cc: Carteret County Health Department Wilmington Regional Office, Aquifer Protection Section Gary MacConnell, P.E. — MacConnell & Associates, P.C. Technical Assistance and Certification Unit APS Central Files LAU Files one NorthCarolina atuna!!y North Carolina Division of Water Quality 1636 Mail Service Center Raleigh, NC 27699-1636 Phone (919) 715-0295 Customer Service Internet: www.ncwaterquality.org 2728 Capital Boulevard Raleigh, NC 27604 FAX (919) 715-6048 1-877-623-6748 An Equal Opportunity/Affirmative Action Employer — 50% Recycled/ 10% Post Consumer Paper NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION 0 DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES RALEIGH HIGH RATE INFILTRATION 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 Sands Villa Utilities, Inc. Carteret County FOR THE construction and operation of a 43,000 gpd wastewater treatment facility consisting of a 10,750 gallon flow equalization tank with a 1'/4" manual cleaned bar screen, 3/4"coarse bubble diffusers, dedicated 30 cfin blower and dual '/i hp (65gpm @19' TDH) pumps, flow splitting device, dual train 27,000 gallon sequencing batch reactors each with %"coarse bubble diffusion, two (2) 15 hp 383 cfm blowers, ''/z hp WAS pump (100 gpm @ 15' THD), two submersible mixers and floating decanters, a 6,450 gallon post equalization tank, with dual '/� hp pumps (65 gpm @ 19' TDH) and high water alarm, dual 48 square feet Pyradeck upflow filters with 0.4 hp submersible dewatering pumps, dual Trojan Model 3000 PTP UV disinfection units, an effluent pumping station with tank used for high rate filter dosing and filter clearwell including dual 60 gpm (0.75 hp) pumps (for rotary system option), dual 60 gpm (0.5 hp) pumps (for spray irrigation option), or dual 100 gpm (0.5 hp) pumps (for low pressure pipe option), a '/z hp wash water pump, two 80 gallon fiberglass pressure tanks, a "non -drinkable water" yard hydrant, an effluent flow meter, a turbidity meter, an 11,000 gallon sludge holding tank with coarse bubble diffusers and dedicated 2 hp 40 cfm blower including a gravity decanting pipe, a 100 KW auxiliary generator with automatic transfer switch, alarms, pipes, valves and treatment system controller. subsequent abandonment of a 43,000 gpd wastewater treatment and rotary distributor facility consisting of a 10,627 gallon aerated flow equalization basin with dual submersible pumps, dual 37,965 gallon aeration basins (each with a 6,250 gallon clarifier), a 7,755 gallon sludge holding tank, two (2) 188 cfin blowers with a standby unit, a 75,000 gpd capacity tertiary filter system, a 1,562 gallon capacity chlorine contact tank with a tablet type chlorinator, and a 5,000 gallon effluent dosing tank with dual 195 gpm submersible pumps. continued operation of the two (2) high rate irrigation fields (each with a diameter of 100 feet), each consisting of one of the following: the repaired or replaced rotary distributors; twelve (12) 'h"sprinkler head irrigation system with 3" supply lines; or a low pressure pipe distribution system with two (2) 6" header pipes, thirty four (34) 1'/4" lateral pipes with orifice shields and a 5" and 9 5/8" orifice spacing. continued operation of a wastewater collection system consisting of approximately 1,448 linear feet of 8 -inch gravity sewer, a 195 gpm pump station with dual pumps, high water alarm, standby power, approximately 500 linear feet of 4 -inch force main, and all the associated piping, valves, and appurtenances to serve Sands Villas Resort and Island Quay Subdivision, with no discharge of wastes to the surface waters, pursuant to the renewal request received September 11, 2006, and subsequent additional information received by the Division, 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 December 29, 2011, shall void Permit No. WQ000165 issued May 31, 2005, and shall be subject to the following specified conditions and limitations: I. PERFORMANCE STANDARDS Upon completion of construction and prior to operation of this permitted facility, a certification 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. If this project is to 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 Land Application Unit, 1617 Mail Service Center, Raleigh, NC 27699-1617. 2. The Wilmington Regional Office, telephone number (910) 796-7215, shall be notified at least forty- eight (48) hours in advance of operation of the installed facilities so that an in-place inspection can be made. Such notification to the regional supervisor shall be made during the normal office hours from 8:00 a.m. until 5:00 p.m. on Monday through Friday, excluding State Holidays. In the event that the facilities fail to perform satisfactorily, including the creation of nuisance conditions, the Permittee shall take immediate corrective actions, including those actions that may be required by the Division of Water Quality (Division), such as the construction of additional or replacement wastewater treatment or disposal facilities. 4. This permit shall become voidable if the soils fail to adequately assimilate the wastes and may be rescinded unless the facilities are installed, maintained, and operated in a manner which will protect the assigned water quality standards of the surface waters and ground waters. The ponding of wastewater on the surface of the distribution field when the dosing cycle commences shall be considered as evidence of failure of the soils to adequately assimilate the wastewater. Additionally, such failure shall be interpreted as a violation of this permit condition. 5. The residuals generated from these treatment facilities must be disposed in accordance with General Statute 143-215.1 and in a manner approved by the Division. 6. Adequate measures shall be taken to divert stormwater from the high rate infiltration area and to prevent wastewater runoff. 7. Diversion or bypassing of the untreated wastewater from the treatment facilities is prohibited. 8. Effluent from the facility shall only be distributed to the high rate infiltration fields. The connection of effluent from the facility to the existing Sands Villa irrigation system is prohibited. 9. The issuance of this permit shall not relieve the Permittee of the responsibility for damages to surface or groundwaters resulting from the operation of this facility. 10. The following buffers shall be maintained: a. 10 feet between high rate infiltration unit and any on -property residential units that are to be sold (e.g., condominiums, subdivisions), b. 500 feet between high rate infiltration unit and any impounded public surface water supply or public shallow (less than 50 feet deep) ground water supply, c. 100 feet between high rate infiltration unit and any private or public water supply source, d. 200 feet between high rate infiltration unit and any streams classified as WS or B, e. 200 feet from mean high water between high rate infiltration unit and any "SA" or "SB" classified surface waters, f. 200 feet from normal high water between high rate infiltration unit and any other stream, canal, marsh, or coastal waters, g. 200 feet from normal high water between high rate infiltration unit and any Class I or Class R impounded reservoir used as a source of drinking water, h. 200 feet between high rate infiltration unit and any other lake or impoundment, 0 i. 200 feet between high rate infiltration unit and any Drainage systems (ditches, drains, surface water diversions, etc.) and from any groundwater lowering and surface drainage ditches, j. 50 feet between high rate infiltration unit and property lines, k. 50 feet between treatment units and property lines, and 1. 50 feet between high rate infiltration unit and public right of ways. Some of the buffers specified above may not have been included in previous permits for this waste treatment and disposal system. These buffers are not intended to prohibit or prevent modifications, which are required by the Division, to improve performance of the existing treatment facility. These buffers do, however, apply to modifications of the treatment and disposal facilities which are for the purpose of increasing the flow that is tributary to the facility. These buffers do apply to any expansion or modification of the high rate infiltration areas and apply in instances in which the sale of property would cause any of the buffers now complied with, for the treatment and disposal facilities, to be violated. The applicant is advised that any modifications to the existing facilities will require a permit modification. 11. A usable green area shall be maintained for wastewater disposal. The green area shall have the capability of accommodating the average daily flow of the facility being served without exceeding the loading rates of the green area. A "green area", as defined in 15A NCAC 2H .0404 (g)(7), is an area suitable for waste disposal, either in its natural state or which has been modified by planting a vegetative cover of grasses or low growing shrubbery. II. OPERATION AND MAINTENANCE REQUIREMENTS 0 1. The facilities shall be properly maintained and operated at all times. 2. Upon classification of the wastewater treatment and spray 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 8G .0201. The ORC shall visit the facilities in accordance with 15A NCAC 8G .0204 or as specified in this permit and shall comply with all other conditions specified in these rules. 3. The application rates for the high rate infiltration system shall not exceed 10 gpd/ft'. 4. The facilities shall be effectively maintained and operated as a non -discharge system to prevent the discharge of any wastewater outside of the high rate infiltration disposal area, which result from the operation of this facility. 5. No traffic or equipment shall be allowed on the disposal area except while installation occurs or while normal maintenance is being performed. 6. The rotary distribution fields `shall be raked twice weekly during the months April through October and once a week during the months of November through March. 7. The screenings removed from the wastewater treatment plant shall be properly disposed in a sanitary landfill or by other means that have been approved by this Division. 0 8. Vegetative growth must be kept out of the rotary distribution areas at all times. All vegetation must be removed manually so that minimal disturbance will occur to the disposal area. NOR L 75 9. ' The application of chemicals to the distribution field(s) is expressly prohibited. 10. An automatically activated standby power source shall be on site and operational at all times. If a generator is employed as an alternate power supply, it shall be tested weekly by interrupting the primary power source. 11. Diffusers shall be cleaned as needed to ensure that adequate aeration is provided. Records of this maintenance shall be maintained by the Permittee. III. MONITORING AND REPORTING REQUIREMENTS 1. Any monitoring deemed necessary by the Division to insure surface and ground water protection will be established and an acceptable sampling reporting schedule shall be followed. 2. Influent flow shall be continuously monitored and daily flow values shall be reported on Form NDMR. The Permittee shall install an appropriate flow measurement device consistent with approved engineering and scientific practices to ensure the accuracy and reliability of influent 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 calibrated 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. Records of flow measurement device calibration shall be kept on file by the Permittee 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 C. Percent from true flow 3. As an indicator of proper operation and maintenance, the facility shall produce an effluent in compliance with the following limitations: a c Parameter Monthly Average Daily Maximum Flow 0.043 MGD BODS (5 -day, 20°C) 10 mg/1 NH3 as N 4 mg/l TSS 20 mg/l Total Nitrogen 10 mg/1 b Fecal Coliform 14 per 100 ml 43 per 100 ml The effluent pH shall not be less than 6.0 standard units nor greater than 9.0 standard units. a Monthly averages for all but fecal coliform shall be the arithmetic mean of all samples collected during the reporting period. b Monthly average for fecal coliform shall be the geometric mean of all samples collected during the reporting period. C Daily maximum shall be the maximum value of all samples collected during the reporting period. 4 4. The effluent from the subject facilities shall be monitored, by the Permittee, at the point prior to discharge to the rotary distributors for the following parameters: Parameter Sampling Point Sampling Frequency Type of Sample /Flow Influent or Effluent Continuous Recording -"BODS (5 -day, 20°C) Effluent *2/Month Composite NH3 as N Effluent *2/Month Composite ✓TSS Effluent *2/Month Composite -'Fecal Coliform Effluent *2/Month Grab 'Settleable Matter Effluent Daily Grab -Residual Chlorine Effluent Daily Grab `NO3 Effluent **Triannually Grab - TDS Effluent * *Triannually Grab -TOC Effluent **Triannually Grab Total Nitrogen Effluent **Triannually Grab Chloride Effluent * *Triannually Grab -pH Effluent **Triannually Grab * 2/Month sampling frequency only during the months of April through October. During the remainder of the year, these parameters shall be monitored monthly. ** Triannually sampling shall be conducted during March, July, and November. If Groundwater sampling indicates or predicts problems with compliance with of the Groundwater Standards, this permit will be modified to include additional and/or more restrictive limitations. 5. Three (3) copies of all monitoring data (as specified in condition III 2 and III 3) on Form NDMR-1 1 and three (3) copies of all operation and disposal records (as specified in condition lII 4) on Form NDAR-2 shall be submitted on or before the last day of the following month. All information shall be submitted to the following address: NCDEIVR-DWQ Information Processing Unit 1617 Mail Service Center Raleigh, North Carolina 27699-1617 6. A record shall be maintained of all residuals removed from this facility. The record shall include the name of the hauler, the permit authorizing the disposal or a letter from a municipality agreeing to accept the residuals, the date the residuals were hauled, and the volume of residuals removed. 7. A maintenance log shall be maintained at this facility including, but not limited to, the following items: a. Daily sampling results including dissolved oxygen in the aeration basin and at the clarifier weir; b. Visual observations of the plant and plant site; c. Record of preventative maintenance (changing of filters, adjusting belt tensions, alarm testing, diffuser inspections and cleanings, etc.); d. Date of calibration of flow measurement device; e. Date and results of power interruption testing on alternate power supply; and f. Dates fields were raked and arms inspected. 5 8. ' Noncompliance Notification: The Permittee shall report by telephone to the Wilmington Regional Office, telephone number (9 10) 792-7215, 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 in the treatment of significant amounts of wastes which are abnormal in quantity or characteristic, such as the dumping of the contents of a basin or tank, the known passage of a slug of hazardous substance through the facility, or any other unusual circumstances; b. Any process unit failure, due to known or unknown reasons, that renders the facility incapable of adequate wastewater treatment, such as mechanical or electrical failures of pumps, aerators, compressors, etc.; c. Any failure of a pumping station, sewer line, or treatment facility resulting in a by-pass of all or any portion of the influent to such station or facility; or d. Any time that self-monitoring information indicates that the facility is not in compliance with its permit limitations. Occurrences outside normal business hours may also be reported to the Division's Emergency Response personnel at telephone number (800) 662-7956, (800) 858-0368, 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. IV. GROUNDWATER REQUIREMENTS 114W 1. Sampling Requirements: a. Existing monitoring wells MW -3, MW -4, MW -5 and MW -6 shall be sampled every March, July and November for the following parameters: Water Level pH Chlorides Total Dissolved Solids (TDS) Fecal Coliforms Total Organic Compounds (TOC) Nitrate Nitrogen (NO3-N) Total Ammonia (NH3) Orthophosphate Volatile Organic Compounds - In November only using one of the following: Water levels in the groundwater monitoring wells shall be measured prior to sampling the groundwater for the remaining parameters. The depth to water in each well shall be measured from the surveyed point on the top of the casing, which shall be surveyed relative to a common datum. b. Volatile organic compounds (VOCs) shall be analyzed using one of the following methods: (A) Standard Method 6230D, PQL at 0.5 ug/L or less (B) Standard Method 6210D, PQL at 0.5 ug/L or less (C) EPA Method 8021, Low Concentration, PQL at 0.5 ug/L or less (D) EPA Method 8260, Low Concentration, PQL at 0.5 ug/L or less (E) Another method with prior approval by the Division Any of the referenced methods used for VOCs shall, at a minimum, include all of the constituents listed in Table VIII of Standard Method 6230D. The method used shall provide a PQL at 0.5 ug/L or less, which shall be supported by laboratory proficiency studies as required by the Division's Laboratory Certification Unit. Any constituents detected above the MDL, but below the PQL at 0.5 ug/L, shall be qualified (i.e., estimated) and reported. c. If total organic carbon (TOC) concentrations greater than 10 mg/l are detected in any downgradient groundwater monitoring well, additional sampling and analysis shall be conducted to identify the individual constituents comprising this TOC concentration. If the TOC concentration as measured in the background monitor well exceeds 10 mg/l, 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 in this permit. d. Any laboratory selected to analyze parameters shall be Division -certified for those parameters required. 2. Reportins /Documentation Requirements: a. The results of the sampling and analysis shall be received on the most -recent version of "Groundwater Quality Monitoring: Compliance Report Form" (i.e., GW -59 Form), with copies of. the laboratory analyses attached, by the Division's Information Processing Unit on or before the last working day of the month following the sampling month. b. All reports, maps, and other documents required in the "Groundwater Requirements" section of this permit shall be mailed to the following address: NCDENR-DWQ Information Processing Unit 1617 Mail Service Center Raleigh, NC 27699-1617 Updated blank reporting and other forms may be downloaded from the web site for the Division's Aquifer Protection Section at http://Qw.ehnr.state.nc.us/ or requested from the address listed above. c. Any person conducting or controlling an activity which is conducted under the authority of a permit issued by the Division of Water Quality and which results in an increase in the concentration of a substance in excess of the standards: I- at or beyond a review boundary, shall demonstrate, through predictive calculations or modeling, that natural site conditions, facility design and operational controls will prevent a violation of standards at the compliance boundary; or submit a plan for alteration of site conditions, facility design or operational controls that will prevent a violation at the compliance boundary, and implement that plan upon its approval by the Division of Water Quality. II- at or beyond a compliance boundary, shall assess the cause, significance and extent of the violation of standards and submit the results of the investigation, and a plan and proposed schedule for corrective action to the Wilmington Regional Office Aquifer Protection Section. The permittee shall implement the plan as approved by and in accordance with a schedule established by the Aquifer Protection Section. In establishing a schedule, the Groundwater section shall consider any reasonable schedule proposed by the permittee. 3. Applicable Boundary Requirements: a. The COMPLIANCE BOUNDARY for the disposal system is specified by regulations in 15A NCAC 2L, Groundwater Classifications and Standards. The Compliance Boundary is for the disposal system constructed after December 31, 1983 is established at either (1) 250 feet from the waste disposal area, or (2) 50 feet within the property boundary, whichever is closest to the waste disposal area. An exceedance of Groundwater Quality Standards at or beyond the Compliance Boundary is subject to immediate remediation action in addition to the penalty provisions applicable under General Statute 143-215.6A(a)(1). b. In accordance with 15A NCAC 2L, a REVIEW BOUNDARY is established around the disposal systems midway between the Compliance Boundary and the perimeter of the waste disposal area. Any exceedance of standards at the Review Boundary shall require remediation action on the part of the permittee. 4. Other Requirements: V. Any additional groundwater quality monitoring, as deemed necessary by the Division, shall be provided 1. Adequate inspection, maintenance, and cleaning shall be provided by the Permittee to insure proper operation of the subject facilities. 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 maintain 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 three years from the date of the inspection and shall be made available to the Division or other permitting authority, upon request. 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. 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. 2. This permit is effective only with respect to the nature and volume of wastes described in the application and other supporting data. 3. This permit is not transferable. 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 accompanied by an application fee, 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 may not be approved. 4. The subject wastewater treatment and disposal facilities shall be connected to an operational publicly owned wastewater collection system within 180 days of its availability to the subject facilities, if the ' subject wastewater treatment or disposal facilities are in noncompliance with the terms and conditions of this non -discharge permit or the governing statutes or regulations. Prior to the initiation of these connection activities, appropriate approval must be received from this Division. 5. The annual administering and compliance fee must be paid by the Permittee within thirty (30) days after being billed by the Division. Failure to pay the fee accordingly may cause the Division to initiate action to revoke this permit as specified by 15A NCAC 02T .0105(e). 6. 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. 7. 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) which have jurisdiction, including but not limited to applicable river buffer rules in 15A NCAC 2B.0200, erosion and sedimentation control requirements in 15A NCAC Chapter 4 and under the Division's General Permit NCGO10000, and any requirements pertaining to wetlands under 15A NCAC 2B.0200 and 2H.0500. 8. A set of approved plans and specifications for the subject project must be retained by the Permittee for the life of this project. 9. The Permittee, at least six (6) months prior to the expiration of this permit, shall request its extension. Upon receipt of the request, the Commission 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. Permit issued this tjif 16th day of January 2007 O NORTH C A ENV NMENTAL MANAGEMENT COMMISSION i flan W. Klimek, P.E., Director Division of Water Quality By Authority of the Environmental Management Commission Permit Number WQ000165 Permit No' WQ000165 January 16, 2007 CENGINEER'S CERTIFICATION Partial Final I, , 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 to be built within substantial compliance and intent of this permit, the approved plans and specifications, and other supporting materials. Signature Date C C 10 Registration No. Sands Villas Resort WQ0000165 1. l •I • `' ISO 75 0 150 Feet K' E S Z1 "d 9t`ZQ-LiZ Ja9QUDN RlJadDJ d DBS=6D SD 6() unC -7 CT. 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