WQ0008431_Final Permit_20051118

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Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
November 18, 2005
MR. H. DALE CRISP, P.E., PUBLIC UTILITIES DIRECTOR
CITY OF RALEIGH
POST OFFICE BOX 590
RALEIGH, NORTH CAROLINA 27602
Dear Mr. Crisp:
Alan W. Klimek, Q.E., Director
Division of Water Quality
Subject: Permit No. WQ0008431
City of Raleigh
E.M. Johnson Water Treatment Plant
Surface Disposal of Residual Solids (503 Exempt)
Wake County
In accordance with your permit renewal application package received on May 14, 2004 as well as
the additional information received on November 4, 2004, we are forwarding herewith Permit No.
WQ0008431, dated November 18, 2005, to the City of Raleigh for the continued operation of residuals
conveyance facilities and a surface disposal unit at its E.M. Johnson Water Treatment Plant.
This permit shall be effective from the date of issuance until October 31, 2010; shall void Permit
No. WQ0008431, issued on May 9, 2003; and shall be subject to the conditions and limitations as
specified therein. Make note of this permit's expiration date and the fact that a permit renewal application
is due to the Division of Water Quality (Division) no later than six months prior to that date (i.e., see
Condition VI. 8.), as the Division does not send reminders to apply for permit renewal.
This permit approves the continued operation of the residuals conveyance facilities and surface
disposal unit for another five-year permit cycle. In addition, minor language changes have been made to
the facilities/unit description as well as Condition II. 5. to reflect the fact that the Permittee has made
some modifications to the solids handling facilities at the E.M. Johnson Water Treatment Plant.
Specifically, the Permittee now has the ability to route supernatant from the surface disposal unit to a
pump station which will convey it to a sanitary sewer for disposal.
Please take the time to review this permit thoroughly as many of the conditions contained
therein may have been added, changed, or deleted since this permit was last issued. 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 30 days following receipt of this
permit. This request must be in the form of a written petition, conforming to Chapter 150fl of 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.
Aquifer Protection Section 1636 Mail Service Center Raleigh, NC 27699-1636
Internet: http://l12o.enr,state.nc.us 2728 Capital Boulevard Raleigh, NC 27604
An Equal CpportunitylAffirmaNe Action Employer- 50% Recycled/10% Post Consumer Paper
No hCarolina
—aturAllr�
Phone [phone] Customer Service
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Fax .[phone]

Mr. H. Dale Crisp, P.E_
November 18, 2005
Page 2
If you need any additional information concerning this matter, please contact Ms. Shannon Mohr
Thornburg by telephone at [phone]or via e-mail at [e-mail].
Sincerely,
�4 11ze
for Alan W. Klimek, P.E.
CC' Mr. Robert A. Berndt, P.E., Hazen & Sawyer, P.C.
Wake County Health Department
Mr. Max Fowler, RE,, NCDENR-DLR (Land Quality Section/Dam Safety Program)
Raleigh Regional Office - Aquifer Protection Section
Technical Assistance and Certification Unit
APS Central Files
APS Files
LAU Residuals Program Coordinator

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
RALEIGH
SURFACE DISPOSAL OF RESIDUAL SOLIDS (503 EXEMPT) 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
City of Raleigh
Wake County
FOR THE
continued operation of residuals conveyance facilities and a surface disposal unit consisting of the
following minimum components: one 200 -gallon per minute progressive cavity residuals conveyance
pump; one 1,600 -gallon per minute diesel -powered portable supernatant return pump; approximately
1,419 linear feet of below -ground six-inch pipeline to convey residuals to the surface disposal unit and
return supernatant from the surface disposal unit for treatment or disposal; a temporary above -ground six-
inch pipeline (i.e., see Condition 1. 10.) to distribute residuals throughout the surface disposal unit; one
pump station (i.e., approved to operate under NDPES Permit No. NC0082376) for the conveyance of
returned supernatant to the sanitary sewer (i.e., Disposal Option No. 1); three 3,750 -square foot sand
filtration beds (i.e., approved to operate under NDPES Permit No. NC0082376) for the filtration of
returned supernatant before its introduction for treatment or disposal (i.e., Disposal Option No. 2); one
six -acre surface disposal unit with a total net capacity of 26 million gallons; as well as all associated
piping, valves, electrical and instrumentation/control systems, and other appurtenances necessary to make
complete and functional residuals conveyance facilities and surface disposal unit for the conveyance and
disposal of up to 1,500 dry ions per year of ferric residuals from the City of Raleigh's E.M. Johnson
Water Treatment Plant located at 10301 Falls of the Neuse Road in Raleigh, North Carolina. The normal
mode of operation for the residuals conveyance facilities and surface disposal unit is to convey residuals
on an as -needed (i.e., emergency) basis only, from a point in the residuals management process after the
four 25,000 -gallon residuals blending tanks (i.e., approved to operate under NDPES Permit No.
NC0082376). Alternate conveyance points that may be used include either directly from the three 50 -foot
residuals thickeners or from the thickened residuals transfer pump station (i.e., contains three 250 -gallons
per minute centrifugal pumps). The clarifiers as well as this pump station are approved to operate under
NPDES Permit No. NC0082376).

The activities associated with the residuals conveyance facilities and surface disposal unit shall
not result in a discharge of wastes to surface waters; shall be pursuant to the permit renewal application
package received on May 4, 2004 as well as the additional information received on November 4, 2004;
and shall be in conformity with the project plans, 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 October 31, 2010; shall void Permit
No. WQ0008431, issued on May 9, 2003; and shall be subject to the following specified conditions and
limitations:
I. PERFORMANCE STANDARDS
The Division of Water Quality (Division) shall be notified in writing at least 90 calendar days
prior to the date that the Permittee desires to initiate removal of residuals from the surface
disposal unit. A formal surface disposal unit residuals removal plan, containing site-specific
information regarding the proposed activities, shall be submitted at that time. The residuals
removal activities shall not proceed until the Division provides written approval of the plan
and makes any modifications to this permit that it deems necessary. Submit two copies of the
surface disposal unit residuals removal plan to the NCDENR-DWQ, Aquifer Protection
Section, Land Application Unit, c/o LAU Residuals Program Coordinator, 1636 Mail Service
Center, Raleigh, NC 27599-16136.
2. The residuals conveyance facilities and surface disposal unit shall be effectively maintained
and operated as a non -discharge system to prevent the discharge of any wastes resulting from
the operation of the unit.
The issuance of this permit shall not relieve the Permittee of the responsibility for damages to
surface waters or groundwater resulting from the operation of the residuals conveyance
facilities and/or surface disposal unit.
4. In the event that the residuals conveyance facilities and/or surface disposal unit are not
operated satisfactorily, including the creation of nuisance conditions, the Permittee shall
cease conveying residuals to the unit and/or disposing of the residuals in the unit as
appropriate, contact the Aquifer Protection Section of the Division's Raleigh Regional Office,
and take any immediate corrective actions as may be required by the Division.
5. No residuals other than those generated by the following residuals source -generating facilities
shall be approved for disposal in the surface disposal unit in accordance with this permit:
Source County Permit Number Maximum Dry Tons per Year
City of Raleigh - E.M. Johnson Water Treatment Plant:
Ferric Residuals Wake PWSS Permit No. 03-92-010 1,500
6. Only residuals that are non -hazardous under the Resource Conservation and Recovery Act
(RCRA) shall be disposed of in the surface disposal unit.
2

7. The pollutant concentrations in the residuals that will be disposed of in the surface disposal
unit shall not exceed the following Ceiling Concentrations (i.e., dry weight basis):
Parameter
Ceiling Concentration
(milligrams per kilogram)
Arsenic
34
Chromium
220
Nickel
240
The surface disposal unit shall have a liner of natural material at least one foot thick that has
been installed and compacted in six-inch layers and meeting a 95 -percent standard proctor
dry density and a hydraulic conductivity no greater than 1 x 10-6 centimeters per second or
other lining system deemed by the Division to be acceptable through the issuance of
approved plans and specifications.
9. Level gauges shall be maintained at all times to monitor freeboard levels in the surface
disposal unit.
10. The above -ground six-inch polyvinyl chloride (PVC) pipeline used for distributing the
residuals within the surface disposal unit shall be relocated at any time without prior
notification to or approval from the Division. The distribution pipeline may be constructed
above ground as long as it is placed on the interior embankment of the unit only.
11. Appropriate measures shall be taken to control public access to the surface disposal unit
during active use and for the 36 -month period following the last residuals disposal event.
Such controls may include fencing and the posting of signs indicating the activities being
conducted at the unit.
12. The following buffer zones shall be maintained:
a. 50 feet between the residuals conveyance facilities and any property line;
b. 400 feet between an active surface disposal unit and any habitable residence;
c. 100 feet between an active surface disposal unit and any public or private water supply
source, all streams classified as WS or B, waters classified as SA or SB and any Class I
or Class II impounded reservoir used as a source of drinking water;
d. 100 feet between an active surface disposal unit and any stream, lake, river, or natural
drainage way;
e. 50 feet between an active surface disposal unit and property lines (if the original permit
was issued with the buffer distance to property line as 100 feet, updated maps must be
submitted and new acreage delineated for the buffer to be reduced);
f. 10 feet between an active surface disposal unit and any interceptor drains or surface water
diversions (upslope);
g. 25 feet between an active surface disposal unit and any interceptor drains or surface water
diversions (downslope); and
h. 25 feet between an active surface disposal unit and any groundwater lowering and surface
drainage ditches.
3

Some of the buffers specified above may not have been included in previous permits for these
residuals conveyance facilities and this surface disposal unit. These buffers are not intended
to prohibit or prevent modifications that are required by the Division to improve performance
of the existing facilities/unit. These buffers do, however, apply to modifications of the unit.
These buffers do also apply to any expansion or modification of the facilities/unit and apply
in instances in which the sale of property would cause any of the buffers now complied with,
for the facilities/unit, to be violated. The Permittee is advised that any modifications to the
existing facilities/unit shall require a permit modification.
13. The surface disposal unit shall not be located in an unstable area.
14. The surface disposal unit shall not restrict the flow of a base flood.
II. OPERATION AND MAINTENANCE REQUIRE, MENTS
1. The residuals conveyance facilities and the surface disposal unit shall be properly maintained
and operated at all times.
2. Upon classification 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 residuals conveyance facilities and surface disposal unit in accordance with 15A
NCAC 8G .0201. The ORC shall visit the facilities and unit 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. A copy of this permit shall be maintained on site when residuals are being conveyed and/or
disposed of in the surface disposal unit during the life of this permit. A spill prevention and
control plan shall be maintained on site at all times.
4. Freeboard of the surface disposal unit shall not be less than two feet at any time. The
freeboard levels in the unit shall be monitored by an individual level gauge that has readily
visible permanent markings indicating the 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 top'of the dam. (i.e., at it lowest elevation within the unit) elevations. Freeboard
levels at the unit shall be monitored and recorded every day that a residuals disposal event
occurs, every day that a supernatant decanting event occurs, and not less than weekly
otherwise.
Supernatant from the surface disposal unit shall be collected and returned to the wastewater
treatment facilities at the E.M. Johnson Water Treatment Plant for treatment and disposal or
collected and drained to a pump station for conveyance to the sanitary sewer for disposal as
necessary to maintain the required freeboard. Diversion or bypassing of supernatant shall be
strictly prohibited.
6. Adequate provisions shall be taken to prevent wind erosion from conveying pollutants or
residuals from the surface disposal unit onto the adjacent property or into any surface waters.
0

7. Adequate provisions shall be taken to prevent any surface runoff from occurring from the
surface disposal unit. If runoff cannot be prevented, a collection system shall be installed
with the capacity to handle runoff from a 24-hour, 25 -year storm event. All collected runoff
shall be disposed in a manner approved by the Division.
A protective vegetative cover shall be established and maintained on the embankments of the
surface disposal unit (i.e., outside toe of embankment to maximum liquid level), benns, pipe
runs, erosion control areas, and surface water diversions. Trees, shrubs, and other woody
vegetation shall not be allowed to grow on the unit dikes or embankments. All embanlanent
areas shall be kept mowed or otherwise controlled and accessible.
9. Food crops, feed crops, and/or fiber crops shall not be grown on the surface disposal unit,
unless approval has been requested and received from the Division.
10. Animals shall not be grazed on the surface disposal unit, unless approval has been requested
and received from the Division.
11. Appropriate measures shall be taken to control public access to the surface disposal unit
during active use and for the 36 -month period following closure of the surface disposal unit.
Such controls may include fencing and the posting of signs indicating the activities being
conducted at the unit.
III. MONITORING AND REPORTING REQUIREMENTS
1. Any monitoring (i.e., including groundwater, surface water, residuals, soil, or plant tissue
analyses) deemed necessary by the Division to insure protection of the environment shall be
established and an acceptable sampling and reporting schedule shall be followed.
2. Residuals generated by the approved residuals source-gencrating facility listed in Condition 1.
5. shall be analyzed to demonstrate that they are non -hazardous under RCRA annually. A
corrosivity, ignitability, and reactivity analysis as well as a Toxicity Characteristics Leaching
Procedure (TCLP) analysis shall be conducted on residuals generated by each approved
residuals source -generating facility. If residuals generated by a particular residuals source -
generating facility are disposed of in the surface disposal unit at a frequency less than
annually, the analyses shall be required for each calendar year in which a disposal event
occurs. The results of all analytical determinations shall be maintained on file by the
Permittee for a minimum of five years.

The TCLP analysis shall include the following parameters (i.e., note the regulatory level in
milligrams per liter in parentheses):
Arsenic (5.0)
Barium (100.0)
Benzene (0.5)
Cadmium (1.0)
Carbon tetrachloride (0.5)
Chlordane (0.03)
Chlorobenzene (100.0)
Chloroform. (6.0)
Chromium (5.0)
m -Cresol (200.0)
o -Cresol (200.0)
p -Cresol (200.0)
Cresol (200.0)
2,4-D (10.0)
1,4 -Dichlorobenzene (7.5) Nitrobenzene (2.0)
1,2-Dichioroethane (0.5)
Pentachlorophenol (100.0)
1, 1 -Dichloroethylene (0.7)
Pyridine (5.0)
2,4-Dinitrotoluene (0.13)
Selenium (1.0)
Endrin (0.02)
Silver (5.0)
Hexachlorobenzene (0.13)
Tetrachloroethylene (0.7)
Heptachlor (and its hydroxide) (0.008) Toxaphene (0.5)
Hexachloro-1,3-butadiene (0.5)
Trichloroethylene (0.5)
Hexachloroethane (3.0)
2,4,5 -Trichlorophenol (400.0)
Lead (5.0)
2,4,6 -Trichlorophenol (2.0)
Lindane (0.4)
2,4,5 -TP (Silvex) (1.0)
Mercury (0.2)
Vinyl chloride (0.2)
Methoxychlor (10.0)
Methyl ethyl ketone (200.0)
3. A representative analysis shall be conducted on residuals generated by the approved residuals
source -generating facility listed in Condition I. 5. quarterly (i.e., four times per year) by the
Permittee, and the results of all analytical determinations shall be maintained on file by the
Permittee for a minimum of five years. The analysis shall include but is not necessarily
limited to the following parameters:
Arsenic Nickel
Chromium Percent Total Solids.
4. Laboratory analyses as required by Condition III. 1., Condition 111. 2., Condition Ill. 3. shall
be performed/gathered on the residuals as they are to be disposed of in the surface disposal
unit. Furthermore, analytical determinations made pursuant to the monitoring and reporting
requirements of this permit shall be made by a laboratory certified by the Division for the
required parameter(s) under 15A NCAC 2H.0800 or 15A NCAC 2H. 1100.
5. Proper records shall be maintained by the Permittee tracking all disposal activities associated
with the surface disposal unit. All records shall be kept by the Permittee for a minimum
period of five years from the date of disposal. These records shall include, but shall not
necessarily be limited to, the following information:
a. Date and freeboard level measurements in the surface disposal unit;
b. Source and date of residuals disposed of in or removed from the surface disposal unit;
c. Volume of residuals disposed of in or removed from the surface disposal unit in gallons
per year, dry tons per year, or kilograms per year;
d. Cumulative volume of residuals disposed of in or removed from the surface disposal unit
in gallons or cubic yards (i.e., excluding freeboard);
e. Remaining volume in the surface disposal unit in gallons or cubic yards (i.e., excluding
freeboard); and
f. An estimate of the remaining useful disposal life for the surface disposal unit in years
(i.e., excluding freeboard).
0

6. Three copies of all required monitoring and reporting requirements as specified in Condition
III. 1., Condition III. 2., Condition III. 3., Condition UL 4., and Condition III. 5. shall be
submitted annually on or before March 1st of the year following the disposal event to the
following address:
NCDENR-DWQ
Information Processing Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
7. Noncompliance Notification:
The Permittee shall report by telephone to the Aquifer Protection Section of the Division's
Raleigh Regional Office, telephone number [phone], 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 with surface disposal activities that results in the disposal of significant
amounts of wastes that are abnormal in quantity or characteristic.
b. Any failure of the surface disposal activities resulting in a release of material to receiving
waters.
Any time that self-monitoring information indicates that the surface disposal unit has
gone out of compliance with the conditions and limitations of this permit or the
parameters on which the system was designed.
d. Any process unit failure, due to known or unknown reasons, that renders the surface
disposal unit incapable of adequate residual treatment.
Any significant spillage or discharge (i.e., greater than incidental) from a vehicle or
piping system transporting residuals to the surface disposal unit.
Occurrences outside of normal business hours (i.e., from. 8:00 a.m. until 5:00 p.m. on
Mondays through Fridays, except State Holidays) may also be reported to the Division's
Emergency Response personnel at one of the following telephone numbers [phone],
[phone], or [phone].
Persons reporting such occurrences by telephone shall also file a written report in letterform
within five 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
Applicable Boundaries:
a. The COMPLIANCE BOUNDARY for the surface disposal unit is specified by
regulations in 15A NCAC 2L (i.e., Groundwater Classifications and Standards). The
Compliance Boundary for surface disposal units individually permitted after December
31, 1983, shall be established at either (1) 250 feet from the unit or (2) 50 feet within the
property boundary, whichever is closest to the unit. An exceedance of Groundwater
Quality Standards at or beyond the Compliance Boundary is subject to immediate
remediation action according to 15A NCAC 2L .0106 (d)(2).
7

b. The REVIEW BOUNDARY shall be established around the surface disposal unit
midway between the Compliance Boundary and the perimeter of the surface disposal
unit. Any exceedance of Groundwater Quality Standards at the Review Boundary shall
require action in accordance with 15A NCAC 2L .0146 (d)(1).
2. Other Requirements:
a. Any additional groundwater quality monitoring, as deemed necessary by the Division,
shall be provided.
V. INSPECTIONS
The Permittee or his designee shall inspect the residuals conveyance facilities and/or surface
disposal unit 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 five years from the date of the inspection and shall be made available to the
Division or other permitting authority, upon request.
Note that special attention shall be paid by the Permittee to inspection of the above -ground
six-inch PVC pipeline used for distributing the residuals within the surface disposal unit. The
pipeline shall be repaired or replaced immediately at any time that such inspection shows that
the pipeline material has deteriorated such that a leak/rupture has occurred or is imminent.
2. 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 residuals conveyance facilities and/or surface disposal unit at any reasonable time for the
purpose of determining compliance with this permit; inspect or copy any records that must be
kept under the terms and conditions of this permit; and obtain samples of groundwater,
surface water, or leachate.
VI. GENERAL CONDITIONS
A set of all plans and specifications approved by the Division as well as any as -built plans for
the residuals conveyance facilities and surface disposal unit shall be retained by the Permittee
for the life of the facilities/unit.
2. This permit shall become voidable unless the disposal activities are carried out in accordance
with the conditions of this permit, the supporting materials, and in the manner approved by
this Division.
3. This permit shall be effective only with respect to the nature and volume of wastes described
in the application and other supporting data.

4. This permit shall not be automatically transferable. In the event that there is a desire for the
residuals conveyance facilities and surface disposal unit to change ownership or a name
change of the Permittee, a formal permit request shall be submitted to the Division
accompanied by documentation from the parties involved and other supporting materials as
may be appropriate. The approval of this request shall be considered on its merits and may or
may not be approved.
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 Statutes § 143-215.6A through § 143-215.6C.
6. The annual administering and compliance fee shall be paid by the Permittee within 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 15 NCAC 2H .0205 (c)(4).
7. The issuance of this permit does not preclude the Permittee from complying with any and all
statutes, rules, regulations, or ordinances which may be imposed by other government
agencies (i.e., 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 NCG010000,
and any requirements pertaining to wetlands under 15A NCAC 2B .0200 and 15A NCAC 2H
.0500.
8. The Permittee, at least six months prior to the expiration of this permit, shall request its
extension. Upon receipt of the request, the Division shall review the adequacy of the
residuals conveyance facilities and surface disposal unit described therein and, if warranted,
shall extend the permit for such period of time and under such conditions and limitations as it
may deem appropriate.
9. This permit may be modified, or revoked and/or reissued to incorporate any conditions,
limitations, and monitoring requirements the Division deems necessary in order to protect the
environment and public health adequately.
10. The Division shall be notified in writing at least 180 calendar days prior to closing of the
surface disposal unit. A formal closure plan and a post -closure management care program for
the surface disposal unit shall be submitted at that time. This information shall be specific to
the surface disposal unit as well as relate to the Permittee's future plans for the land. A
schedule for implementing both the closure plan and the post -closure management care
program shall be provided as well. The Division will accept a submittal that has been
prepared in accordance with the document entitled "Process Design Manual: Surface
Disposal of Sewage Sludge and Domestic Septage (EPA/625/R-95/002)," published by the
United States Environmental Protection Agency's Office of Research and Development.
Submit two copies of all information to the NCDENR-DWQ, Aquifer Protection Section,
Land Application Unit, c/o LAU Residuals Program Coordinator, 1636 Mail Service Center,
Raleigh, NC 27699-1636.

Permit issued this the eighteenth day of November, 2005.
NORTZCARO A ENVIYONMENTAL MANAGEMENT COMMISSION
for Alan W. Klimek, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission
Permit Number WQ0008431
10

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FIGURE 2