HomeMy WebLinkAboutNC0086681_Draft Permit_20240402ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Ms. Erin Burke, County Manager
Camden County
103 Water Plant Road
Camden, NC 27921
Dear Permittee:
STATE
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NORTH CAROLINA
Environmental Quality
April 2, 2024
Subject: Draft NPDES Permit NCO086681
South Camden Water and Sewer District —
Reverse Osmosis WTP
Not Classified - Physical Chemical WPCS
Camden County
The Division has reviewed your request to renew the subject permit. Enclosed with this letter is a copy
of the draft permit for your facility. Please review this draft carefully to ensure your thorough
understanding of the information, conditions, and requirements it contains.
The draft permit includes the following significant changes from the existing permit:
➢ Updated the maximum, monthly average wastewater discharge on the Supplement to Permit
Cover Sheet
➢ Added the chemical additives list at the water treatment plant to the Supplement to Permit Cover
Sheet
➢ Changed the measurement frequency for pH from monthly to 2 times per month in accordance
with the current Water Treatment Plan strategy.
➢ Duration of Discharge was added to the table in Part I. A. (I.).
➢ Updated eDMR parameter codes on the effluent table in Section A. (1.).
➢ Updated footnotes and added footnote 2 to the effluent table in Section A. (L).
➢ Added Total Copper and Total Zinc monthly monitoring and limits to the table in Part I. A. (1)
based on a reasonable potential to exceed water quality standards.
➢ Total Copper and Total Zinc monitoring and limits were added with a compliance schedule
shown in Part 1. A. (2).
➢ In the case of `non -detect' values, permittees (or their laboratories) are expected to report daily
values to the Practical Quantitation Level (PQL) for each parameter (or "<[PQL]" for values less
than the PQL).
➢ Please note that the practical quantitation limit (PQL) for Total Copper is 2 µg/L and the PQL for
Total Zinc is 10 µg/L (per the Inorganic Chemistry Branch of the Division of Water Resources
Water Sciences Section), and monitoring data should be reportable down to these levels. Limits
for water treatment plants are determined by evaluating DMR data submitted to the Division,
along with a dilution factor (if applicable) and the maximum monthly average flow reported in
the previous 3 years at the time the review is completed.
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1617 Mail Service Center I Raleigh, North Carolina 27699-1617
919.707.9000
oeorenwn a [�.a..n.mn o..xn�
Page 2 of 2
NPDES Permit NCO086681
➢ Based on the results of the reasonable potential analysis, monitoring for Nickel was removed
from the table in Part I. A. (1).
➢ Updated Whole Effluent Toxicity testing language in Part I. A. (3).
➢ Updated eDMR language for electronic data submission in Part I. A. (6).
➢ Updated the map.
Please note that the Pasquotank River is listed as an impaired waterbody on the North Carolina 303(d)
Impaired Waters List. Addressing impaired waters is a high priority with the Division, and instream
data will continue to be evaluated. If there is noncompliance with permitted effluent limits and stream
impairment can be attributed to your facility, then mitigative measures may be required.
The NPDES standard conditions (Parts II, III, and IV) that are a part of the permit are not included in
this draft document (cover, map, and Part I). The conditions are the same as in your current permit
except that agency and division names have been updated. The latest version is available at
httns://bit.lv/3k5NFaL and can be viewed online or downloaded as a PDF file.
With this notification, the Division will solicit public comment on this draft permit by publishing a
notice in newspapers having circulation in the general Camden County area, per EPA requirements.
Please provide your comments, if any, to me at the e-mail address below no later than 30 days
after receiving this draft permit.
Following the 30-day public comment period, the Division will review all pertinent comments and take
appropriate action prior to issuing a final permit.
If you have questions concerning the draft, please contact me at caroline.robinson(a-deq.nc.gov.
Sincerely,
Environmental Specialist II
NPDES Compliance and Expedited Permitting
cc: NPDES Files
Washington Regional Office
Aquatic Toxicology Unit
Operator Certification Program
NPDES Permit NCO086681
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WATER RESOURCES
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
(NPDES)
In compliance with the provisions of North Carolina General Statute 143-215.1, other lawful standards
and regulations promulgated and adopted by the North Carolina Environmental Management
Commission, and the Federal Water Pollution Control Act, as amended,
Camden County
is hereby authorized to discharge wastewater from a facility located at the
;i
South Camden Water and Sewer District, WTP
103 Water Plant Drive
Camden
Camden County
to receiving waters designated as the Pasquotank River in the Pasquotank River Basin in accordance
with effluent limitations, monitoring requirements, and other applicable conditions set forth in Parts I,
II, III and IV hereof.
This permit shall become effective
This permit and authorization to discharge shall expire at midnight on April 30, 2029.
If the permittee intends to continue to discharge at the facility beyond the term of this permit, a renewal
application must be submitted no later than November 1, 2028 (180 days before the expiration of this
permit).
Signed this day
John E. Hennessy, Section Chief Regional Operations
Division of Water Resources
By Authority of the Environmental Management Commission
Page 1 of 9
NPDES Permit NCO086681
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby
revoked. As of this permit issuance, any previously issued permit bearing this number is no longer
effective. Therefore, the exclusive authority to operate and discharge from this facility arises under the
permit conditions, requirements, terms, and provisions included herein.
Camden County
is hereby authorized to:
1. Continue to operate a wastewater treatment system applying Reverse Osmosis I Nanofiltration
technology, in support of potable -water production from groundwater sources with a design potable
flow rate of 1.44 MGD and a maximum, monthly average wastewater discharge of approximately
0.302 MGD. Water and wastewater treatment includes the following Vmponents:
• Influent pump [currently 700 gpm] '
• Two (2) each pre -filters [52 cartridges; microns]
• Duel (2) RO Units [eight (8) modules w/6 bundles each]
• 2" a pass RO unit [eight (8) modules w/6 bundles each]
• Concentrated to outfall
Potable Water:
• Forced draft aerator [introduction of CaCl, NaOH, Phosphate; chlorine (NaOCI)]
• Detention tank [9,000 gallon]
• Pumps to elevated tank
• Gravity -feed to distribution system
Chemical Additives
• Noveon Aquafeed 1025 Antiscalent (proprietary formulation)
These facilities are located at the South Camden Water and Sewer District WTP, 103 Water Plant
Drive in Camden, Camden County; and
2. Discharge from said treatment works at the location specified on the attached map via Outfall 001
[extended offshore approximately 800 feet and fitted with a discharge diffuser], into the Pasquotank
River [Stream Segment: 30-3-(12)], a waterbody currently classified SB within subbasin 03-01-50
[HUC: 030102050708] of the Pasquotank River Basin.
Page 2 of 9
NPDES Permit NCO086681
PART I
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
[15A NCAC 02B 0400 et seq. and 0213.0500 et seq.]
Not Classified - Physical Chemical WPCS [15A NCAC 08G. 0306]
During the period beginning on the effective date of the permit and lasting until expiration,
the Permittee is authorized to discharge reverse osmosis (RO) reject water through a diffuser
via Outfall 001. Such discharges shall be limited, monitored, and reportedt,2 by the Permittee
as specified below:
EFFLUENT CHARACTERISTICS
Parameter Codes
LIMITS
MONITORING
REQUIREMENTS
Monthly
Average
Daily
Maximum
Measurement
Frequency
Sample
Type
Sample
Location3
Flow (MGD)
50050
Monitor & Report
Continuous
Recording
E
Duration of Discharge (Hours)
81381
Monitor & Report
Continuous
Recording
E
Total Residual Chlorine4 (µg/L)
50060
13 µg/L
2/Month
Grab
E
pH (standard units)
00400
Not < 6.8 or > 8.5
2/Month
Grab
E, U,
S1, S2 S4
Conductivity (µmhos/cm)
00094
Monitor & Report
Monthly
Grab
E, U,
S1, S2, S4
Salinity (ppth)
00480
Monitor & Report
Monthly
Grab
E, U,
S1, S2, S4
Ammonia Nitrogen (mg/L)
00610
Monitor & Report
Monthly
Grab
E
Total Dissolved Solids (mg/L)
70295
Monitor & Report
Monthly
Grab
E
Turbidity (NTU)
00070
Monitor & Report
Monthly
Grab
E
Total Coppers (µg/L)
01042
3.70 µg/L
5.80 µg/L
Monthly
Grab
E
Total Zincs (µg/L)
01092
85.6 µg/L
95.1 µg/L
Monthly
Grab
E
Total Nitrogen (mg/L)
C'0600
Monitor & Report
Quarterly
Grab
E
Total Phosphorus (mg/L)
C0665
Monitor & Report
Quarterly
Grab
E
WET Testing6
TGE3E
Pass/Fail
Quarterly
Grab
E
Footnotes:
1. The Permittee shall submit monthly Discharge Monitoring Reports (DMRs) electronically using DWR's
Electronic Discharge Monitoring Report [eDMR] Program, as detailed herein [see Section A. (6)].
2. All practical quantitation limits (PQL) must be sufficiently sensitive considering the respective water quality
standard for each parameter [see Part Il. Section D. (4)].
3. Sample Locations: E-Effluent, U-Upstream [background]; for other sampling locations [S1, S2, and S4, see
Section A. (5.). S1 [BIMS Outfall 001A], S2 [BIMS Outfall 00113], S4 [BIMS Outfall 0011)].
4. Total Residual Chlorine monitoring/limit required only if chlorine or chlorine derivatives are used. The Division
shall consider all effluent TRC values reported below 50 µg/L to be in compliance with the permit. However, the
Permittee shall continue to record and submit all values reported by a North Carolina certified laboratory (including
field certified), even if these values fall below 50 µg/L.
5. See Section A. (2) for a compliance schedule for Total Zinc and Total Copper limits.
6. Whole Effluent Toxicity (WET) testing, Acute 24-hour Pass/Fail (Mysidopsis bahia) at 90% in January,
April, July, and October [see Section A. (3.)].
Page 3 of 9
NPDES Permit NCO086681
Effluent samples shall accurately reflect the physical and chemical character of the discharge.
THERE SHALL BE NO DISCHARGE OF FLOATING SOLIDS OR VISIBLE FOAM IN OTHER THAN
TRACE AMOUNTS.
A. (2) SCHEDULE OF COMPLIANCE (OUTFALL 001)
[G.S. 143-215.1(b)]
1. Within one year from the effective date of the permit the Permittee shall submit to the Division of
Water Resources a Corrective Action Plan summarizing the actions or strategy to be taken to achieve
compliance with the Total Copper and Total Zinc limits at Outfall 001. Specific dates for completion
or implementation of each action shall be included.
2. Within two years from the effective date of the permit submit a report to the Division summarizing
actions taken in accordance with the Corrective Action Plan.
3. Within three years from the effective date of the permit submit a report to the Division summarizing
actions taken in accordance with the Corrective Action Plan.
4. Within four years from the effective date of the permit submit a report to the Division summarizing
actions taken in accordance with the Corrective Action Plan.
5. Achieve compliance with Total Copper and Total Zinc limits specified in Section A. (1) within five
years of the permit effective date.
Upon approval of the Corrective Action Plan by the Division, the report and actions become an
enforceable part of this permit. Any modifications to the schedule shall be requested to the Division at
least ninety (90) days before the deadline. Modifications to the schedule in excess of four months will
be subject to public notice.
The Corrective Action Plan and reports shall include the owner's name, NPDES permit number and
Permittee contact person, and shall be submitted to:
(1) NCDEQ / Division of Water Resources (2) NCDEQ / Division of Water Resources
NPDES Compliance and Expedited Permitting Washington Regional Office
1617 Mail Service Center 943 Washington Square Mall
Raleigh, NC 27699-1617 Washington, NC 27889
A. (3.) ACUTE TOXICITY PASS/FAIL MONITORING (QUARTERLY)
[15A NCAC 02B .0200] [15A NCAC 02B .0500]
The permittee shall conduct acute toxicity tests on a quarterly basis using protocols defined in the
North Carolina Procedure Document entitled "Pass/Fail Methodology For Determining Acute Toxicity
In A Single Effluent Concentration" (Revised -December 2010, or subsequent versions). The
monitoring shall be performed as a Mysid Shrimp (Mysidopsis bahia) 24-hour static test. The effluent
concentration at which there may be at no time significant acute mortality is 90% (defined as treatment
two in the procedure document). The tests will be performed during the months of January, April,
July, and October. These months signify the first month of each three-month toxicity testing quarter
assigned to the facility. Effluent sampling for this testing must be obtained during representative
effluent discharge and shall be performed at the NPDES permitted final effluent discharge below all
treatment processes.
Page 4 of 9
NPDES Permit NC0086681
Should any single quarterly monitoring indicate a failure to meet specified limits, then monthly
monitoring will begin immediately until such time that a single test is passed. Upon passing, this
monthly test requirement will revert to quarterly in the months specified above.
All toxicity testing results required as part of this permit condition will be entered electronically using
the Division's eDMR system for the month in which it was performed, using the parameter code
TGE3E. Additionally, DWR Form AT-2 (original) is to be sent to the following address:
North Carolina Division of Water Resources
Water Sciences Section/Aquatic Toxicology Branch
1621 Mail Service Center
Raleigh, NC 27699-1621
Or, results can be sent to the email, ATForms.ATB(a)deg.nc.gov.
Completed Aquatic Toxicity Test Forms shall be filed with the Water Sciences Section no later than 30
days after the end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements and all
concentration/response data, and be certified by laboratory supervisor and ORC or approved designate
signature.
Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is
employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is
required, the permittee will complete the information located at the top of the aquatic toxicity (AT) test
form indicating the facility name, permit number, pipe number, county, and the month/year of the
report with the notation of "No Flow" in the comment area of the form. The report shall be submitted to
the Water Sciences Section at the address cited above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required, then
monthly monitoring will begin immediately. Upon submission of a valid test, this monthly test
requirement will revert to quarterly in the months specified above.
Should any test data from either these monitoring requirements or tests performed by the North
Carolina Division of Water Resources indicate potential impacts to the receiving stream, this permit
may be re -opened and modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control
organism survival and appropriate environmental controls, shall constitute an invalid test and will
require immediate follow-up testing to be completed no later than the last day of the month following
the month of the initial monitoring.
USE OF A DIFFERENT TEST ORGANISM
The permittee may request the use of a different test organism upon documentation that the alternate test
organism would provide an equal or greater level of protection and is appropriate based on the
Page 5 of 9
NPDES Permit NCO086681
characteristics of the discharge and receiving stream. Such documentation would consist of one of the
following:
1. For saltwater classified streams, a fathead minnow may be assigned as the acute testing
species if the salinity of the receiving stream at the point of discharge is <5 ppt throughout
the tidally influenced cycle. This determination may be based on the best professional
judgment of DWR staff or data collection provided by the permittee and approved by
DWR staff. This evaluation should include vertical profiles of salinity/conductivity
measurements at both high tide and low tide over several 24-hr cycles.
2. Three (3) consecutive "side -by -side" tests with results indicating that the alternate test
organism is as or more sensitive to the facility's effluent. Each test series would consist
of two separate toxicity tests conducted on the same sample of effluent with the length
of exposure specified by the permit, the only difference between the tests being the
organism used.
3. An alternate plan developed by the permittee and approved by the Aquatic Toxicology
Unit that demonstrates an equal level of protection is offered by the test organism.
For items 2 and 3, it must also be demonstrated that viable and standardized culture techniques are
available for that organism and standardized testing methodologies have been developed and
validated. This demonstration should meet guidance provided by EPA in Section 6 of EPA-821-R-02-
012, "Short Term Methods for Estimating the Acute Toxicity of Effluents and Receiving Waters to
Freshwater Organisms, Fifth Edition 2002."
Requests to use a different test organism and supporting documentation should be sent to North
Carolina Division of Water Resources, Water Sciences Section (at theaddress listed above).
A. (4.) DISCHARGE SPECIAL CONDITION
[15A NC 02B .0500 et seq.]
Should this discharge cause scouring or visible turbulence within the Pasquotank River, the Division
may require the permittee to relocate this discharge.
A. (5.) INSTREAM MONITORING REQUIREMENTS FOR SALINITY
[15A NCAC 02B .0500 et seq.]
Salinity shall be monitored within the Pasquotank River (at the locations indicated) monthly
year-round. [Previous Outfalls S3 and S5 omitted as irrelevant, based on past data.]
Parameter
Sample Location
Frequency
Year -Round
Salinity
S 1 [B1MS Outfall 001 A]
Monthly
January through
(parts per thousand)
S2 [BIMS Outfall 001 B]
Monthly
December
S4 [BIMS Outfall 001 D]
Monthly
See attached Sample Location Map (not to scale); sampling points are described as:
Page 6 of 9
NPDES Permit NCO086681
S1— background samples (outside the influence of the discharge), taken at a convenient
location near the northern end of Machelhe Island Bridge on Hwy 158;
S2 - along the shoreline (at a convenient location) approximately 100 feet west of the outfall;
S4 - along the shoreline, (at a convenient location) approximately 100 feet east of the outfall.
A. (6.) ELECTRONIC REPORTING OF DISCHARGE MONITORING REPORTS
[G.S. 143-215.1(b)]
Federal regulations require electronic submittal of all discharge monitoring reports (DMRs) and
program reports. The final NPDES Electronic Reporting Rule was adopted and became effective on
December 21, 2015.
NOTE: This special condition supplements or supersedes the following sections within Part II of this
permit (Standard Conditions for NPDES Permits):
• Section B. (11.)
• Section D. (2.)
• Section D. (6.)
• Section E. (5.)
Signatory Requirements
Reporting
Records Retention
Monitoring Reports
1. Reportine Requirements [Supersedes Section D. (2.) and Section E. (5.) (a)]
The permittee shall report discharge monitoring data electronically using the NC DWR's Electronic
Discharge Monitoring Report (eDMR) internet application.
Monitoring results obtained during the previous month(s) shall be summarized for each month and
submitted electronically using eDMR. The eDMR system allows permitted facilities to enter
monitoring data and submit DMRs electronically using the internet. The eDMR system may be
accessed at: https://deg.nc.gov/about/divisions/water-resources/edmr.
If a permittee is unable to use the eDMR system due to a demonstrated hardship or due to the
facility being physically located in an area where less than 10 percent of the households have
broadband access, then a temporary waiver from the NPDES electronic reporting requirements may
be granted and discharge monitoring data may be submitted on paper DMR forms (MR 1, 1. 1, 2, 3)
or alternative forms approved by the Director. Duplicate signed copies shall be submitted to the
following address:
NC DEQ / Division of Water Resources / Water Quality
Permitting Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
See "How to Request a Waiver from Electronic Reporting" section below.
Monitoring results obtained during the previous month(s) shall be summarized for each month and
reported via the eDMR system no later than the last calendar day of the month following the
completed reporting period. Regardless of the submission method, the first DMR is due on the last
Page 7 of 9
NPDES Permit NC0086681
day of the month following the issuance of the permit or in the case of a new facility, on the last day
of the month following the commencement of discharge.
Starting on December 21, 2025, the permittee must electronically report the following compliance
monitoring data and reports, when applicable:
Sewer Overflow/Bypass Event Reports;
Pretreatment Program Annual Reports; and
Clean Water Act (CWA) Section 316 (b) Annual Reports.
The permittee may seek an electronic reporting waiver from the Division (see "How to Request a
Waiver from Electronic Reporting" section below).
2. Electronic Submissions
In accordance with 40 CFR 122.41(1)(9), the permittee must identify the initial recipient at the time
of each electronic submission. The permittee should use the EPA's website resources to identify
the initial recipient for the electronic submission.
Initial recipient of electronic NPDES information from NPDES-regulated facilities means the entity
(EPA or the state authorized by EPA to implement the NPDES program) that is the designated
entity for receiving electronic NPDES data [see 40 CFR 127.2 (b)].
EPA plans to establish a website that will also link to the appropriate electronic reporting tool for
each type of electronic submission and for each state. Instructions on how to access and use the
appropriate electronic reporting tool will be available as well. Information on EPA's NPDES
Electronic Reporting Rule is found at:
https://www.federalregister.gov/documents/2015/10/22/2015-24954/national-pol I utant-di scharge-
elimination-s stem-npdes-electronic-reporting-rule
Electronic submissions must start by the dates listed in the "Reporting Requirements" section
above.
3. How to Request a Waiver from Electronic Reporting
The permittee may seek a temporary electronic reporting waiver from the Division. To obtain an
electronic reporting waiver, a permittee must first submit an electronic reporting waiver request to
the Division. Requests for temporary electronic reporting waivers must be submitted in writing to
the Division for written approval at least sixty (60) days prior to the date the facility would be
required under this permit to begin submitting monitoring data and reports. The duration of a
temporary waiver shall not exceed 5 years and shall thereupon expire. At such time, monitoring
data and reports shall be submitted electronically to the Division unless the permittee re -applies for
and is granted a new temporary electronic reporting waiver by the Division. Approved electronic
reporting waivers are not transferrable. Only permittees with an approved reporting waiver request
may submit monitoring data and reports on paper to the Division for the period that the approved
reporting waiver request is effective.
Information on eDMR and the application for a temporary electronic reporting waiver are found on
the following web page:
Page 8 of 9
NPDES Permit NC0086681
hqp://deg.nc. gov/about/div isions/water-resources/edmr
4. Sianatory Requirements [Supplements Section B. (11.) (b) and Supersedes Section B. (11.) (d)l
All eDMRs submitted to the permit issuing authority shall be signed by a person described in Part
II, Section B. (11.) (a) or by a duly authorized representative of that person as described in Part II,
Section B. (11.) (b). A person, and not a position, must be delegated signatory authority for eDMR
reporting purposes.
For eDMR submissions, the person signing and submitting the DMR must obtain an eDMR user
account and login credentials to access the eDMR system. For more information on North
Carolina's eDMR system, registering for eDMR and obtaining an eDMR user account, please visit
the following web page:
hqp://deg.nc.gov/about/divisions/water-resources/edmr
Certification. Any person submitting an electronic DMR using the state's eDMR system shall
make the following certification [40 CFR 122.22]. NO OTHER STATEMENTS OF
CERTIFICATION WILL BE ACCEPTED:
7 certify, under penalty of law, that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is, to the best of my knowledge and belief, true, accurate,
and complete. I am aware that there are significant penalties for submitting false information,
including the possibility of fines and imprisonment for knowing violations. "
5. Records Retention [Supplements Section D. (6.)1
The permittee shall retain records of all Discharge Monitoring Reports, including eDMR
submissions. These records or copies shall be maintained for a period of at least 3 years from the
date of the report. This period may be extended by request of the Director at any time [40 CFR
122.41].
Page 9 of 9
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NC HWY 158
Instream Sample
Locations, S2 and S4
o rslop—dam , _
t -�_
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_
_ _
==° 1 ^
%NK CO
Upstream Sample
i
Location, S1
cll� Olt
1 R yPoint
4
Outfa11001
`F/ rr, (diffuser located 800 feet offshore)
Lat 36' 18' 03", Long 76 ° 10' 20"
144'
(discharge subject to ocean and wind tides)
i
L7/
NCO086681- South Camden W&SD RO/WTP
Camden County
Latitude: 361 18' 03" N Longitude: 761 10' 20" W
Stream Class: SB Receiving Stream: Pasquotank River
Sub -Basin: 03-01-50 HUC: 030102050708
Drainage Basin: Pasquotank Basin
State Grid/Quad: B 34 SW/Elizabeth City
5' sr 7t
Anson Pw"ht 3 r
t�
—_ CAMDEN CO
7ARQ_ OTAKK CO — — ___ _
grkkhouse
Facility
Location
Camden County
Map not to scale