Loading...
HomeMy WebLinkAboutNC0002828_Ownership Change Request 2007_20100524Michael F. Easley, Governor William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources Alan W. Klimek, P.E., Director Division of Water Quality November 9, 2007 WAYNE A DECAMP WEK INDUSTRIES 1001 N E MARKET STREET REIDSVILLE NC 27320 Subject: Permit No. N0002828 (Change of Name/Ownership Request) Incomplete Application for Request AMER KART CORPORATION Rockingham County Dear Mr. DeCamp: The Division of Water Quality, NPDES Unit received your request for change of name and/or ownership application on November 5, 2007. Because it is incomplete, we are returning your application request for the process of the name and/or ownership change. 1. Please Provide Legal Documentation of the transfer of ownership or company name change (Such as contract, deed, article of incorporation, approved Board minutes, etc.) for ownership changes. 2. Please submit completed name/ownership change request forms (enclosed) To ensure the maximum efficiency in processing permit requests, the Division asks your assistance in providing the information needed. Processing can take as long as 60 - 90 days after receipt of a completed request. If you have any questions, please contact Laurie Singleton at 919-733-5083, extension 350, or via e-mail at laurie.singleton@ncmail.net. If unavailable, you may leave a message, and someone will respond promptly. PLEASE REFER TO THE ABOVE REQUEST PERMIT NUMBER WHEN MAKING INQUIRIES ON THIS PROJECT. Sincerely, Laurie Singleton Cc: CENTRAL FILES Raleigh Regional Office/Surface Water Protection NPDES Unit Permit NC0002828 One Pretreatment, Emergency Response and Collection Systems Unit Internet http://h2o.enr.nc.state.us/ndpu NorthCarolina 1617 Mail Service Center, Raleigh, NC 27699-1617 An Equal Opportunity Action Employer Natimally Telephone (919) 733-5083 Fax (919) 733-0059 50% recycled/10% post -consumer paper Re: Page 2 WWTP Permit NC0002828 October 5, 2009 Please forward a copy of the approval to this request to my attention so I can put it in our WWTP permit file. Mr. Ron Ulery, Regional Manager for WEK Industries will have all records pertaining to our WWTP permit and will keep you notified if/when the WWTP is restarted. His address is: WEK Industries 1085 W. Jefferson St. Jefferson, OH 44047 Thank you for your support and assistance over the last several years; it has been a pleasure to work with you. Please don't hesitate to call if you have any questions. Sincerely, Wayne DeCamp Plant Manager CC: Mr. Ron Ulery Regional Manager Mr. Doug Christoff EHS Manager Myers Industries 1100 Northeast Market Street Reidsville, North Carolina 27320 Industries,Inc. A Myers Mdusle^res C-?7p-y October 5, 2009 Mr. Ron Boone NCDENR 585 Waughtown St. Winston-Salem, NC 27107 Re: WWTP # NC0002828 Request to place permit on Inactive Status Dear Mr. Boone: The WEK facility at 1001 NE Market Street in Reidsville will be permanently ceasing manufacturing operations in the next several months; we expect to be completely shut down by the end of December 2009. The facility will still be maintained for storage of equipment for the balance of 2010. However, there will be very limited activity. We plan on shutting down all sanitary sewer systems in the building and this in turn will eliminate any flow in to the WWTP. This activity will not allow the WWTP to stay alive and function properly, once the facility is shut down we will have the holding tanks pumped out and no flow will be permitted to go to the waste water treatment facility. We would like to put the facility on "Inactive Status" at that time and do wish to keep the permit #NC0002828 in place but on this inactive status. We will locate a Porta John on the facility for any limited personnel use while working at the facility. We will notify Meritech Inc. that we will not need to provide any certified laboratory test until such time that the facility might need to be reactivated. 1100 Northeast Market Street Reidsville, North Carolina 27320 Wek Industries, Reidsville Plant Attn: Mr. Wayne Decamp, Plant Manager Request to Inactivate NPDES Permit NCO027987 8 October 2009 Page 2 of 2 a. Turning off the water supply to all sanitary facilities that discharge to the plant; b. Evacuating all components of all wastewater and solids currently in the plant and disposing of them properly by applying for and acquiring a pump and haul permit from the Division; C. Preventing, by whatever means practical, the inflow and/or infiltration of precipitation, into the plant during the period of inactivity; d. Completely isolating the plant by closing all valves that are installed on and between the influent and effluent extremities of the plant; e. Verifying that all DMRs will be completed and submitted on time as usual through the discharge termination date, and; f. Verifying that Wek will continue to employ a ORC and BORC through the discharge termination date. 5. To formally request this waiver, please submit a written request no later than 30 days prior to the projected discharge termination date to the Division's central office in Raleigh at the following address: NC Department of Environment and Natural Resources Division of Water Quality, NPDES West Unit Attn- Charles Weaver 1617 Mail Service Center Raleigh, NC 27699-1617 Central office personnel will then forward the request to us and we will then schedule a site visit with you as required. You may use the time between now and then to prepare the manufacturing facility and WWTP to meet all the above conditions as well as to prepare the pump and haul permit application. 6. If you have any questions or need any assistance, please do not hesitate to contact me or Ron Boone at 336-771-5000. Sincerely, Steve W. Tedder Water Quality Regional Supervisor Winston-Salem Region Division of Water Quality CC: WSRO/SWP Central Files NPDES West Unit /� NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Dee Freeman Governor Director Secretary 8 October 2009 Wek Industries, Reidsville Plant Attn: Mr. Wayne DeCamp, Plant Manager 1001 Northeast Market Street Reidsville, NC 27320 SUBJECT: Request to Inactivate NPDES Permit Wek Industries Wastewater Treatment Plant Permit: NC0002828 Rockingham County Dear Mr. DeCamp: DENR - WATER QUALITY POINT SOURCE BRANCH We received your request dated 5 October 2009 to inactivate NPDES permit NC0002828. However, after further consideration, we have concluded that inactivating the permit would not be the best course of action under these circumstances. 2. If Wek wishes to keep the permit for possible future reactivation of the wastewater treatment plant (WWTP) and discharge, it would be more appropriate to consider temporarily waiving the permit requirements to submit monthly discharge monitoring reports (DMR) and employ and assign an operator in responsible charge (ORC) and backup ORC (BORC) for the WWTP. Doing so would keep the permit active, yet temporarily relieve Wek of the DMR and ORC requirements for as long as they can maintain compliance with the waiver. Also, during the waiver period, Wek would still be required to pay the annual permit fees. Once Wek becomes aware of the need to reactivate the WWTP and discharge, they would only need to notify us far enough in advance to allow us to perform a pre- operational site inspection, allow Wek to fully address and fix any identified issues and/or problems, allow Wek to identify and reassign the new ORC and BORC, and then allow us to rescind the waiver and grant permission to begin discharging again. 3. Please note that during the waiver period, discharge from the WWTP would be strictly prohibited, including the discharge of any accumulated stormwater. Once a waiver is approved and issued, if the plant fills to capacity and threatens to discharge and Wek wishes to continue to maintain the waiver under non -discharge status, then Wek would have to request and acquire a pump and haul permit from the Division to allow them to pump and haul the accumulated stormwater/wastewater/solids for proper disposal. Discharge of any kind during the waiver period would immediately render the waiver null and void and automatically reinstitute all conditions of the discharge permit, possibly resulting in severe permit violations. Furthermore, during the waiver period, all other conditions of the NPDES permit would remain in full force and effect. 4. Obviously, a waiver cannot be issued until it is verified that the WWTP is not discharging and that conditions are most favorable to completely cease all flow to the plant to prepare it for the extended period of inactivity. This includes but is not limited to the following: North Carolina Division of Water Quality, Winston-Salem Regional Office Location: 585 Waughtown St. Winston-Salem, North Carolina 27107 One Phone: 336-771-50001 FAX: 336-771-46301 Customer Service: 1-877-623-6748 NorthCarolina Intemet: www.ncwaterqualo.org Naturally An Equal Opportunity 1 Affirmative Action Employer Mr. Boone, I, unfortunately, have been designated as the Wek Industries contact for the former Wek South facility. I am seeking information from corporate as to the owners of the building. I suspect that this problem originated before the involvement of Myers' Industries, but cannot be sure, at this time. I drove over to the pond in question today, but was unable to investigate due to the presence of a rather large German Shepherd, accompanied by a female Pit Bull. There were cars in the drive and I blew the horn but got no response. Would it be possible for you to provide my contact info to the homeowners so we can agree on a time? I am happy to, and have been directed to, investigate but not at the risk of a dog attack Thanks, Lee Blackburn Plant Manager WhiteRidge Plastics Iblackburn@wek-whiteridge.com office: 336-342-1200 cell: 336-520-3605 SAFETY PAYS ALWAYS From: Boone, Ron [mailto:ron.boone@ncdenr.gov] Sent: Tuesday, April 13, 2010 10:23 AM To: Lee Blackburn Subject: RE: Whiteridge Plastics Mr. Blackburn, I apologize for bothering you again but I needed to ask you for a point of contact for Wek Industries, or whatever entity it is that Whiteridge leases the old Wek facility from. I need to speak with them about the plastic beads I mentioned to you last week. Do you feel the release of the plastic beads is a result of any Whiteridge activities, or do you think it occurred prior to your use of the facility? Ron Boone NC DENR Winston-Salem Regional Office Division of Water Quality, Surface Water Protection 585 Waughtown Street Winston-Salem, NC 27107 Voice: (336) 771-5000 FAX: (336) 771-4630 E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Lee Blackburn [mailto:lblackbum@wek-whiteridge.com] Sent: Tuesday, April 13, 2010 10:04 AM To: Boone, Ron Subject: Whiteridge Plastics Mr. Boone, I wanted to contact you by a mail so that you would have my contact info. We have started our clean up efforts. We have hired (2) two employees whose only duties are site clean up. We have provided vacuums and are vacuuming, containing, and disposing of the debris. Furthermore, we are developing programs to both contain pellets inside the building and to store and recycle waste. We are also looking for ways to screen/filter any water entering the spillway from the property. We will continue our efforts, both individually and with the assistance of Fehr -Graham. As you have much more expertise concerning these issues, I welcome any suggestions. 5 Best Regards, Ron Boone NC DENR Winston-Salem Regional Office Division of Water Quality, Surface Water Protection 585 Waughtown Street Winston-Salem, NC 27107 Voice: (336) 771-5000 FAX: (336) 771-4630 E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Lee Blackburn[mailto:lblackburn@wek-whiteridge.com] Sent: Wednesday, April 14, 2010 8:15 AM To: Boone, Ron Subject: RE: Whiteridge Plastics Thank you. I would be happy for you to provide my info to the homeowner. Lee Blackburn Plant Manager WhiteRidge Plastics lblackburn@wek-whiteridge.com office: 336-342-1200 cell: 336-520-3605 SAFETY PAYS ALWAYS From: Boone, Ron [mailto:ron.boone@ncdenr.gov] Sent: Wednesday, April 14, 2010 8:00 AM To: Lee Blackbum Subject: RE: Whiteridge Plastics Mr. Blackburn, I will try to contact the complainant today and ask if it's ok to give you his contact info, or just give him your info. Ron Boone NC DENR Winston-Salem Regional Office Division of Water Quality, Surface Water Protection 585 Waughtown Street Winston-Salem, NC 27107 Voice: (336) 771-5000 FAX: (336) 771-4630 E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Lee Blackburn[mailto:lblackbum0wek-whiteridge.com] Sent: Tuesday, April 13, 2010 4:02 PM To: Boone, Ron Subject: RE: Whiteridge Plastics 4 Winston-Salem, NC 27107 Voice: (336) 771-5000 FAX: (336) 771-4630 E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Lee Blackburn [mailto:lbladcbum@wek-whiteridge.com] Sent: Wednesday, April 14, 2010 9:44 AM To: Boone, Ron Cc: Dan Stoehr Subject: RE: Whiteridge Plastics Mr. Boone, I will contact Mr. Frasier today to arrange a meeting. 1 have been designated as the site contact for Wek issues, so the contact info below is valid. We appreciate your reticence to issue violations and will continue to work to ensure that these issues are addressed and proper controls put into place. Sincerely, Lee Blackburn Plant Manager WhiteRidge Plastics lblackbum@wek-whiteridge.com office: 336-342-1200 cell: 336-520-3605 SAFETY PAYS ALWAYS From: Boone, Ron [mailto:ron.boone@ncdenr.gov] Sent Wednesday, April 14, 2010 8:58 AM To: Lee Blackburn Subject: RE: Whiteridge Plastics Mr. Blackburn I spoke with the complainant this morning and he gave me approval to give you his contact info. His name is Hugh Frasier and his numbers are 336-613-0187 (mobile) and 434-799-4505 (work). Please give him a call and arrange a meeting. He said you'd have more success contacting him on his mobile. Please keep me updated on what happens with this. It sounds like this latest release of the plastics beads may have resulted from the recent torrential rains in Reidsville. These particular beads are white/clear in color and about 1/16 to 1/8 of an inch in diameter. The release of the beads, just like the release of the Styrofoam at the other facility, into the stream/pond/lake (waters of the state), is a water quality standard violation. However, I'd like to handle this without having to issue any notices of violation or anything; doing so just complicates matters and causes a lot more work for all involved. Please work with Mr. Frasier and Wek to stop any further release of the plastic beads and clean up those that have been released. Also, please provide me with your Wek contact information as there further issues concerning the site that I need to work out with them. Feel free to call if you have any questions or concerns. Winston-Salem Regional Office 585 Waughtown Street Winston-Salem, NC 27107 Let me know if you have any questions. Regards, Ron Boone NC DENR Winston-Salem Regional Office Division of Water Quality, Surface Water Protection 585 Waughtown Street Winston-Salem, NC 27107 Voice: (336) 771-5000 FAX: (336) 771-4630 E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Lee Blackburn[malito:lbladitm@wek-whteridge.com] Sent: Tuesday, April 27, 2010 9:42 AM To: Boone, Ron Subject: RE: Whiteridge Plastics Mr. Boone, I have yet to hear from the homeowner regarding the pellets on the banks of his pond. We are continuing our clean up at WhiteRidge and have submitted the Notice of Intent to apply for a stormwater permit. I also have the permit for the wastewater plant at Wek South and am ready to proceed with the application to close the plant. Can you provide a contact to walk me through the process? Thanks, Lee Blackburn Plant Manager WhiteRidge Plastics lblackburn@wek-whiteridge.com office: 336-342-1200 cell: 336-520-3605 SAFETY PAYS ALWAYS From: Boone, Ron [mailto:ron.boone@ncdenr.gov] Sent: Wednesday, April 14, 201010:06 AM To: Lee Blackburn Subject: RE: Whiteridge Plastics Mr. Blackburn, this may sound like a crazy question, but how are your people over at the Wek facility relieving themselves? Ron Boone NC DENR Winston-Salem Regional Office Division of Water Quality, Surface Water Protection 585 Waughtown Street 2 Weaver, Charles From: Boone, Ron Sent: Wednesday, April 28, 2010 12:29 PM To: Tedder, Steve; Weaver, Charles; Scardina, Maureen Subject: FW: Whiteridge Plastics Really sorry guys, but this email refers to Wek in Reidsville, NPDES permit #NC0002828. Ron Boone NC DENR Winston-Salem Regional Office Division of Water Quality, Surface Water Protection 585 Waughtown Street Winston-Salem, NC 27107 Voice: (336) 771-5000 FAX: (336) 771-4630 E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Boone Ron Sent: Wednesday, April 28, 2010 12:22 PM To: 'Lee Blad(burn' Cc: Weaver, Charles; Tedder, Steve Subject RE: Whiteridge Plastics Lee, As far as the pellets go, if you can't reach the homeowner, then don't worry about it right now. I will let you know if I receive further complaints from them. What you must do though is prevent any further discharge of the pellets because they could potentially cause problems in the stream, for which things could quickly become quite uncomfortable for the responsible party. FYI, when I went to the plant, the first place I went was to the silos in the back because I remembered when I inspected there long ago with Mr. Decamp, there was a considerable amount of pellets on the ground around the silos. However, during this visit, most of the pellets I saw (the same shape and color of which I found in the pond), were inside the building. I didn't find any pellets that shape and color around the silos. So, how are they getting from inside the facility into the pond? As far as the WWTP, I'll be your POC, but you'll need to send a letter to our Central Office in Raleigh requesting that the permit be inactivated because the manufacturing plant and it's WWTP have been shut down and are no longer in operation and the WWTP has ceased discharge, as I verified during my visit to the facility on 04/15/2010. Please send the letter to them at the following address: Division of Water Quality Surface Water Protection Section — NPDES 1617 Mail Service Center Raleigh, NC 27699-1617 I've copied them on this email so they know what's going on. Please also CC me at the following address: Division of Water Quality %ITERm PI.ASTics 661&" CUSTOM MOLDING AEG&ft%MN rEoe May 7, 2010 Division of Water Quality Surface Water Protection Section-NPDES 1617 Mail Service Center Raleigh, NC 27699-1617 Re: WWTP # NC0002828 Request to place permit on Inactive Status To Whom It May Concern: I have the unenviable task of watching over the former Wek South facility located at 1001 N.E. Market St, Reidsville, NC 27320. The facility the above referenced permit refers to was closed effective 31 December, 2009. While there is still limited activity at the site, mainly storage, the flow of water was less than required to keep the WWTP functioning properly. Holding tanks have been pumped out. Water service has been shut off at the site and Porta Johns provided for employees that are, occasionally, on site. I am requesting that the facility be placed on inactive status, however, I would prefer that the permit remained in place, in the event reactivation was ever necessary. Meritech, Inc. stopped their certified testing service in December. Please send the request approval to me at the address listed below for retention in our files. Franklin L. Blackburn WhiteRidge Plastics 109 Sands Rd. Reidsville, NC 27320 1 am enclosing a copy, for your use, of the original request sent by Mr. Wayne DeCamp, Plant Manager, requesting inactive status in October, 2009. If there are any questions that I can answer please feel free to contact me at 336-342-1200 or lblackbumkwek-whiteridge.com. Sincerely, Franklin L. Blackburn Plant Manager WhiteRidge Plastics. e``; yeti Ff 1oI I MAY 112010 DENIR 1W L-.-.;. . A�r,Y POINT SOURCE aRANC4 Greenville Utilities Commission A to C No. 023931 A02 Issued July 2, 2008 Engineer's Certification 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 modifications and improvements to the GUC WWTP, located on Aqua Lane in Pitt County for the Greenville Utilities Commission, hereby state that, to the best of my abilities, due care and diligence was used in the observation of the following construction: Replacement of the existing WWTP electrical power distribution system equipment and power conductors, transformers, switchboards and motor control centers (MCC), addition of three standby 800 kW generators and one 150 kW mobile generator, a new Generator Power Building, additions to the existing Blower Building and South Electrical Building, and replacement of the WWTP SCADA system and remote pump station communication system for 32 pump stations, and in conformity with the project plan, specifications, and other supporting data subsequently filed and approved by the Department of Environment and Natural Resources. I certify that the construction of the above referenced project was observed to be built within substantial compliance and intent of the approved plans and specifications. Signature: Registration No. , Date ,Send to: Construction Grants & Loans DENR/DWQ 1633 Mail Service Center Raleigh, NC 27699-1633 ; J - Weaver, Charles From: Boone, Ron Sent: Wednesday, May 12, 2010 9:21 AM To: Weaver, Charles Subject: WEK NCO002828 Hi, the WEK facility covered by the subject permit has shut down and I have verified there is no longer a discharge there and the WWTP is shut down. You should have received a letter dated 05/07/2010 from Franklin Blackburn at Whiteridge Plastics (owner owns both companies) about this. Have you received the letter? The owner's wish to keep the permit, but inactivate it. Please let me know. Am I asking the right person? Ron Ron Boone NC DENR Winston-Salem Regional Office Division of Water Quality, Surface Water Protection 585 Waughtown Street Winston-Salem, NC 27107 Voice: (336) 771-5000 FAX: (336) 771-4630 E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties. + � 0 NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Dee Freeman Governor Director Secretary May 12, 2010 Mr. Franklin L. Blackburn WhiteRidge Plastics 109 Sands Rd Reidsville, N.C. 27320 Subject: Waiver of Monthly Reporting Requirement WEK South Plant NPDES Permit NC0002828 Rockingham County Dear Mr. Blackburn: The Division has reviewed your letter of May 7, 2010, which states the subject facility is not producing any wastewater discharge; the treatment system has been inactive since 31 December 2009. After considering the recommendations of the staff in the Winston-Salem Regional Office, I have agreed to waive the requirement to submit monthly DMRs for the subject facility, effective May 1, 2010 The DMRs up through (and including) April 2010 should be submitted as usual. Be advised that if and when any wastewater discharge resumes, the discharge must be monitored as per the terms of the NPDES permit and other applicable rules or statutes. Please keep the Winston-Salem Regional Office apprised of any pertinent developments that arise regarding this facility, especially if the discharge is re -activated. While requirements for operator visitation, monitoring and reporting are being waived, your company is still required to pay the Annual Administering and Compliance Monitoring Fee that is associated with this and all NPDES permits. If you have any questions, or if you wish to request rescission of this permit, contact Charles H. Weaver, Jr. at 919 807-6391. Sincerely, f Coleen H. Sullins cc: Central Files • Winston-Salem Regional Office / Ron Boone NPDES Files 1617 Mail Service Center, Winston-Salem, North Carolina 27699-1617 One 512 North Salisbury Street, Winston-Salem, North Carolina 27604 NorthCarolina Phone: 919 807-6300 /FAX 919 807-6495 / Internet: www.ncwaterquality.org Natutuffil NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Dee Freeman Governor Director Secretary 24 May 2010 Whiteridge Plastics, LLC Attn: Mr. Lee Blackburn P.O. Box 2900 Reidsville, NC 27320-2900 Subject: WEK Facility, Reidsville, NC Plant NPDES Permit #NC0002828 Suspension of Discharge Monitoring Report Requirements Rockingham County Dear Mr. Blackburn: The Division received correspondence from you dated May 7, 2010, requesting suspension of the discharge monitoring report (DMR) requirements contained in the NPDES discharge permit NC0002828, for the Wek Reidsville wastewater treatment plant (WWTP), due to the manufacturing plant and WWTP being shut down and inactivated effective December 31, 2009. Your letter also requested that the permit be placed in inactive status until such time that the manufacturing facility and WWTP reopen. 2. The Division's Central Office replied to your request with correspondence dated May 12, 2010, which granted your requests, with the provision that we continue to receive monthly DMRs through April, 2010. We then received an email reply from you informing us that because the manufacturing plant and WWTP were actually shutdown effective December 31, 2009, there was no further discharge from the WWTP and therefore no data to report on DMRs past that date. 3. In light of the above circumstances, you, as the representative for the Wek facility, are no longer required to submit the monthly DMRs for the Wek facility through April, 2010. The Division has received DMRs up to, and including December, 2009, and that is all that is currently required. You are reminded however that you must request that the permit be reactivated prior to the WWTP restarting and discharging. Failure to do so would result in a violation of "Discharge Without a Valid Permit". 4. Thank you for your attention to this matter contact me or Ron Boone at 336-771-5000. Cc: WSRO/SWP NPDES West Unit Central Files North Carolina Division of Water Quality, Winston-Salem Regional Office Location: 585 Waughtown St. Winston-Salem, North Carolina 27107 Phone: 336-771-50001 FAX: 336-771A6301 Customer Service: 1-877-623-6748 Internet: www.ncwaterquality.org If you have any questions or concerns, please do not hesitate to Sincerely, N teve W. Tedder Water Quality Regional Supervisor Winston-Salem Region Division of Water Quality NonrthCarolina Naturally An Equal Opportunity 1 Affirmative Action Employer