NCG030432_COMPLETE FILE - HISTORICAL_20110719

- - STORMWATER- DIVISION CODING SHEET
RESCISSIONS .
PERMIT NO..
DOC TYPE
O(COMPLETE FILE- HISTORICAL
DATE OF
.RESCISSION
❑ 010 d�
YYYYMMDD

4
_..�.
NC®EHR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue
Governor
Pat Eisenmenger.
Nestaway, LLC - Nestaway, LLC
214 Armory Dr
Clinton, NC 28328
Dear Permttee:
Coleen H. Sullins
Director
July 19, 2011
Dee Freeman
Secretary
DENR-FRO
JUL 2 I all
Subject: Rescission ofNPDES Stormwater Permit
Certificate of Coverage Number NCG030432
Nestaway, LLC - Nestaway, LLC
Sampson County
DWQ
On 6/20/201 1, the Division of Water Quality received your request to rescind your coverage under
Certificate of Coverage Number NCG030432. In accordance with your request, Certificate of Coverage
Number NCG030432 is rescinded effective immediately.
Operating a treatment facility, discharging wastewater or discharging specific types of stormwater to
waters of the State without valid coverage under an NPDES permit will subject the responsible party to a
civil penalty of up to $25,000 per day. It is the intention of DWQ that enforcement proceedings will
occur for persons that have voluntarily relinquished permit coverage when, in fact, continuing permit
coverage was necessary. If, in retrospect, you feel the site still requires permit coverage, you should
notify this office immediately. Furthermore, if in the future you wish to again discharge to the State's
surface waters, you must first apply for and receive a new NPDES permit.
If the facility is in the process of being sold, you will be performing a public service if you would inform
the new or prospective owners of their potential need for NPDES permit coverage.
If you have questions about this matter, please contact Brian Lowther at [phone], or the Water
Quality staff in our Fayetteville Regional Office at NPDES SW.
Sincerely,
J /
for C/oleen H. Sullins, Director
cc: Fayetteville Regional Office
Stormwater Permitting Unit
DWQ Central Files - w/attachments
Fran McPherson, DWQ Budget Office - please waive applicable fees
Wetlands and Stormwater Branch
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet: www.ncwaterquality.org
An Equal Opportunity 1 Affirmative Action Employer
NorthCarolina
Natumlly

Lawyer, Mike
From:
Lawyer, Mike
Sent:
Tuesday, June 28, 2011 12:23 PM
To:
Lowther, Brian
Cc:
Henson, Belinda
Subject:
RE: storm water termination request
Brian,
Conducted site visit at the Nestaway facility in Sampson County yesterday (NCG030432). I met with Mr. Roe and the
plant manager Mr. Pope. They have indeed shut down operations. Building has basically been gutted with almost all
equipment removed. Safety Kleen was there conducting some final removal of chemicals. There are still some items
outside of the plant awaiting pick up such as used pallets, scrap material, waste, etc. They said that would be finalized
within the next week or two, but otherwise I have no objections to rescission of their permit coverage.
Thanks,
Mike
Michael Lawyer, CPSWQ
Environmental Specialist
NCDENR-Division of Water Quality
Surface Water Protection Section
Fayetteville Regional Office
Direct: [phone]
Main: [phone]
Fax: [phone]
e-mail: [e-mail]
*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: Lowther, Brian
Sent: Monday, June 20, 2011 3:06 PM
To: Lawyer, Mike
Cc: Henson, Belinda
Subject: RE: storm water termination request
Mike,
Let me know if you think this permit can be rescinded and I'll process it with our next group. Thanks.
Brian
Brian C. Lowther
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604

Phone: [phone];68
Email: lirian.lo%%ther(u�ncdenr.Lov
Website: httti:Hportal.ticdenr.org/web/wq/ws/su
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: Henson, Belinda
Sent: Monday, June 20, 2011 11:42 AM
To: Lowther, Brian
Cc: Dave Roe; Lawyer, Mike
Subject: FW: storm water termination request
Brian,
Mr. Roe contacted me this morning asking the status of the rescission of their SW permit. Did you receive the attached
letter? Thank you for your assistance with this.
Belinda
From: Dave Roe [mailto:droe(alintrstar.netl
Sent: Monday, June 20, 2011 10:43 AM
To: Henson, Belinda
Cc: 'Rab Pope (Clinton)'
Subject: storm water termination request
Belinda,
Attached is the letter we sent June 3 to request termination of our storm water permit for Nestaway in Clinton NC.
I apologize for having your last name incorrect on the letter.
We appreciate your help in finding the status of our termination request.
Either myself or Rab Pope can be contacted at the below phone number or by email.
My extension is 228 and Rab's is 223.
Thanks,
David Roe
VP Plant Operations, Clinton
Nestaway
214 Armory Rd
Clinton, NC 28328
910-592-9244 xt 228
[e-mail]

®WQ
Van
214ARMORYROAD • CLINTON,NORTHCAROLWA 28328
PHONE [phone] • FAX[phone]
May 26, 2009
Mr. Michael Lawyer
Environmental Specialist
North Carolina Department of Environment and Natural Resources
225 Green Street, Suite 714
Fayetteville, NC 28301
Mr. Lawyer,
In reference to your review of our Stormwater prevention practices and observations reported
in your letter dated May 1, 2009, we have are in the process of making the following changes to
our Stormwater Pollution Prevention Plan;
1. Sampling requirements have been revised to semi-annual analytical testing. Tests will
be completed two times per year. Second test for 2009 is planned for September or
October 2009.
2. We have started the review and update of the Storm Water Pollution Prevention Plan
that includes item #1. It is anticipated that the update to the plan will be completed in
June, 2009.
3. Contact information for key managers
• Rab Pope
Plant Manager
910-592-9244 xt 223
Address above
• David Roe
VP Plant Operations
910-592-9244 xt 224
Address above.
We would appreciate your confirmation that our above plan satisfies the response and action
plan required per your letter.
Sincerely,
"Al-j
David Roe
VP Plant Operation, Clinton

NCDENR
North Carolina Department of Environment and
Division of Water Quality
Beverly Eaves Perdue Colleen H. Sullins
Governor Director
May I, 2009
Nestaway, LLC
Attn: David L. 12oe, VP -Quality, Finishing, Sourcing
214 Armory Road
Clinton, NC 28328
Subject: COMPLIANCE EVALUATION INSPECTION
Nestaway, LLC
NPDES Stormvyater General Permit-NCG030432
Sampson County
Dear Mr. Roe:
Natural Resources
Dee Freeman
Secretary
On April 28, 2009, 1, Michael Lawyer from the Fayetteville Regional Office of the Division of
Water Quality, conducted a site inspection for the Nestaway, LLC facility located at 214 Armory Road
in Clinton, Sampson County, North Carolina. A copy of the Compliance Inspection Report is enclosed
for your review. Along with yourself, Mr. Rab Pope, Plant Managcr, was also present during the
inspection and both his and your time and assistance is greatly appreciated. Stormwater from the facility
drains to an unnamed tributary to AVillianis Old Mill Branch, a Class C;Sw water located in the Cape
Fear River Basin. The site visit and file review revealed that the subject facility is covered by NPDBS
Stormwater General Permit-NCG030432.
Accordingly, the following observations were noted during the Division of Water Quality
inspection:
1) Stormwater Pollution Prevention Plan (SPPP)
A Stormwater Pollution Prevention Plan (SPPP) has been developed, recorded, and properly
in lemented.
Yes ■ No ❑
2) Qualitative Monitoring
Qualitative monitoring has been conducted and recorded in accordance with permit requirements.
Yes ■ No ❑
3) Analytical Monitoring
Analvtical monitoring has been conducted and recorded in accordance with permit requirements.
Yes.■ No ❑
Location. 225 Green Street. Suite 714, Fayetteville. North Carolina 28301
Phone: [phone] FAX [phone] Cuslomer Service: 1-877-623-6748
InlcmeC w .ncwaterouahly.orq
An Equal Opporionry 1 AllianaCrve Action Employer
One
NortliCarolina
�'xatlll-all

Other Observations:
In reviewing the facility's StonuwaterPollution Prevention Plan, it was not apparent that au annual
review/update is being conducted as required by the general permit. Analytical Monitoring was not
conducted semi-annually in 2008, however the increased frequency from annual to semi-annual was
instituted with the recent permit renewal in November 2007. Please refer to the enclosed Compliance
Inspection Report for additional comments and observations made during the inspection.
Requested Response:
You are asked to please respond to this office, in writing, by June 1, 2009. Your response should
include a Plan of Action to address the aforementioned observations.
Please be advised that violations of the NPDES General Permit are subject to a civil
penalty assessment of up to $25,000 per day for each violation. If you or your staff has any questions,
comments, or needs assistance with understanding any aspect of your permit, please do not hesitate to
.contact me at [phone].
Sincerel%
Michael Lawyer
Environmental Specialist
Enclosure
cc: Rab Pope, Plant Manager (same address)
FRO -Surface Water Protection
NPS-Assistance & Compliance Oversight Unit

Permit: NCG030432
SOC:
County: Sampson
Region: Fayetteville
Compliance Inspection Report
Effective: 11/01/07 Expiration: 10/31/12 Owner: Nestaway, LLC
Effective: Expiration: Facility: Nestaway, Li
214 Armory Rd
Contact Person: Rap Pope Title: Plant Manager
Directions to Facility:
System Classifications:
Primary ORC: Certification:
Secondary ORC(s):
On -Site Representative(s):
On -site representative Rab Pope
On -site representative David L Roe
Related Permits:
Clinton NC 28328
Phone: [phone]
Phone:
Phone: [phone]
Phone: [phone] ext 228
Inspection Date: 04/2812009 Entry Time: 02:35 P Exit Time: 04:00 PM
Primary Inspector: Mike Lawyer Phone: [phone]
,....r.., i ,..i..�. Ext.-?A
Belinda S Henson Phone: [phone] Exy.72�
.?32G
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Metal Fabrication Stormwater Discharge COC
Facility Status: IN Compliant 0 Not Compliant
Question Areas
® Storm Water
(See attachment summary)
Page: 1

Permit: NCG030432 Owner - Facility: Nestaway, LLC
Inspection Date: 04/28/2009 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Inspection conducted to ensure compliance with the conditions of the NCG030000 general stormwater permit. Met with
Mr. Rab Pope, Plant Manager, and Mr. David Roe, Vice President of Quality, Finishing, Sourcing. Mr. Pope provided
facility's Stormwater Pollution Prevention Plan (SPPP) for review, which contained all permit -required components with
the exception of documentation of an annual review/update. Records of Qualitative and Analytical Monitoring were also
available, however records indicated that only one sampling event occurred in 2008 although the monitoring frequency
was increased to semi-annual with the recent permit renewal in November 2007. The current monitoring schedule and
new Tiered response approaches were relayed to Mr. Pope and Mr. Roe. After the documents review, a tour of the
grounds of the facility was conducted with Mr. Pope where observations were made of storage practices,
loading/unloading areas and outfall location.
Page 2

Permit: NCG030432 Owner -Facility: Nestaway, LLC
Inspection Date: 04/28/2009 .Inspection Type: Compliance Evaluation
Stormwater Pollution Prevention Plan
Does the site have a Stormwater Pollution Prevention Plan?
# Does the Plan include a General Location (USGS) map?
# Does the Plan include a "Narrative Description of Practices'?
# Does the Plan include a detailed site map including outfall locations and drainage areas?
# Does the Plan include a list of significant spills occurring during the past 3 years?
# Has the facility evaluated feasible alternatives to current practices?
# Does the facility provide all necessary secondary containment?
# Does the Plan include a BMP summary?
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
# Does the facility provide and document Employee Training?
# Does the Plan include a list of Responsible Pady(s)?
# Is the Plan reviewed and updated annually? .
# Does the Plan include a Stormwater Facility Inspection Program?
Has the Stormwater Pollution Prevention Plan been implemented?
Comment: Facility's SPPP developed in 1993, but there is no documentation
regarding an annual review/update.
Qualitative Monitoring
Has the facility conducted its Qualitative Monitoring semi-annually?
Reason for Visit: Routine
Comment:
Analytical Monitoring
Has the facility conducted its Analytical monitoring?
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
Comment: Renewal of general permit in November 2007 changed frequency
requirement from annual to semi-annual, however facility personnel were unaware of
this change and records indicate only one sampling event in 2008.
Permit and Outfalls
# Is a copy of the Permit and the Certificate of Coverage available at the site?
# Were all outfalls observed during the inspection?
# If the facility has representative outfall status, is it properly documented by the Division?
# Has the facility evaluated all illicit (non stormwater) discharges?
Yes No NA NE
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Yes No NA NE
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Yes No NA NE
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Page: 3

Permit: NCG030432 Owner - Facility: Nestaway, LLC
Inspection Date: 04/28/2009 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Comment: Facility has one outfall.
Page:4

Mr. Pat Eisenmenger
Nestaway, LLC
214 Armory Drive
Clinton, NC 28328
Michael 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
RECEIVED
May 27, 2005
MAY' 31 mffi
DENR-FAYETULLE REGIONAL OFRCE
Subject: NPDES General Permit NCG030000
Certificate of Coverage NCG030432
Nestaway, LLC
Formerly Nestaway, Div. Of Axia
Sampson County
Dear Mr. Eisenmenger:
Division personnel have reviewed and approved your request to transfer coverage under the General Permit,
receive'd on May 25, 2005.
. s
Please ftnd;enclosed the revised Certificate of Coverage. The terms and conditions contained in the General
Permit remain unchanged and in full effect. This revised Certificate of Coverage is issued under the requirements of
North Carolina General Statutes 143-215.1 and the Memorandum of Agreement between North Carolina and the U.S.
+, .Environmental Protection Agency.
If you have any questions, please contact the Stocmwater Permitting Unit at [phone], extension 502.
Sincerely,
ORIGINAL SIGNED BY
BRADLEY BENNETr
cc: DWQ Central Files
-Fayetteville Regional Office, Water Quality Section
Siorrnwater Permitting Unit
Alan+WrKlimek P.-E.
North Carolina Division of Water
Internet: h2o.enr.state.nc.us
An Equal Opportunity/Affirmative Action
17Mail Service Center
2-N;"Salisbury St.
—500h'Regcledl10%Po
Raleigh, NC 27699-1617
Raleigh, NC 27604
Paper
Phone [phone] Customer Service
FAX [phone]

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG030000
CERTIFICATE OF COVERAGE No. NCG030432
STORMWATER DISCHARGES
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision 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,
NESTAWAY, LLC
is hereby authorized to discharge stormwater from a facility located at
NESTAWAY, LLC
214 ARMORY DRIVE
CLINTON
SAMPSON COUNTY
to receiving waters designated as a UT to Williams Old Mill Branch, a class C SW stream, in the Cape Fear River
Basin in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts 1,
II, III, IV, V, and VI of General Permit No. NCG030000 as attached.
This certificate of coverage shall become effective May 27, 2005.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day May 27, 2005. ORIGINAL SIGNED BY'
BRADLEY BENNETT
Alan W. Klimek, Diiec[oi-
Division of Water Quality
By Authority of the Environmental Management Commission

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NEIL E NORD
NESTAWAY DA CLINTON NC PLANT
9501 GRANGER ROAD
CLEVELAND, OH 44125
Dear Perm ittee:
Michael 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
r r — ,—A 1
August 23, 2002
AUG 2 9 2002
Subject: NPDES Stormwater Permit Renewal
NESTAWAY DA CLINTON NC PLANT
COC Number NCG030432
Sampson County
In response to your renewal application for continued coverage under general permit NCG030000, the Division of
Water Quality (DWQ) is forwarding herewith the reissued stormwater general permit. This permit is reissued
pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement
between the state of North Carolina and the U.S. Environmental Protection Agency, dated December 6, 1983.
'The following information is included with your permit package:
* A new Certificate of Coverage
A copy of General Stormwater Permit NCG030000
* A copy of the Analytical Monitoring Form (DMR)
* A copy of a Technical Bulletin for the general permit
Your coverage under this general permit is not transferable except after notice to DWQ. The Division may require
modification or revocation and reissuance of the Certificate of Coverage. This permit does not affect the legal
requirements to obtain other permits which may be required by DENR or relieve the permittee from responsibility
for compliance with any other applicable federal, state, or local law, rule, standard, ordinance, order, judgment, or
decree.
If you have any questions regarding this permit package please contact Bill Mills of the Central Office Stormwater
and General Permits Unit at [phone], ext. 548
Sincerely.
Bradley Bennett, Supervisor
Stormwater and General Permits Unit
cc: Central Files
Stormwater & General Permits Unit Files
Fayetteville Regional Office
TOM
NCDENR
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone] Customer Service
1- 800-623-7748

r
-i
O
WARREN E PARK
NESTAWAY DA CLINTON NC PLANT
9501 GRANGER RD
CLEVELAND, 014 44125
Dear Per nittee:
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Gregory J. Thorpe, Ph.D
-- - - Acting Director
F'`'-- !-(_;-1. t DivisionHof Water Quality
December 27, 2001
Subject: NPDES Stormwater Permit Renewal
NESTAWAY DA CLINTON NC PLANT
COC Number NCG030432
Sampson County
Your facility is currently covered for Stormwater discharge under General Permit NCG030000. This permit expires
on August 31, 2002. The Division staff is currently in the process of rewriting this permit and is scheduled to have
the permit reissued by late summer of 2002. Once the permit is reissued, your facility would be eligible for
continued coverage under the reissued permit.
In order to assure your continued coverage under the general permit, you must apply to the Division of Water
Quality (DWQ) for renewal ol'your permit coverage. To make this renewal process easier, we are informing you in
advance that your permit will he expiring. Enclosed you will find a General Permit Coverage Renewal
Application Form. The application must be completed and returned by March 4, 2002 in order to assure continued
coverage under the general permit.
Failure to request renewal within this time period may result in a civil assessment of al (east $250.00. Larger
penalties may he assessed depending on the delinquency of the request. Discharge of Stormwater from your facility
without coverage under a valid stormwater NPDES permit would constitute a violation of NCGS 143-215.1 and
could result in assessments of civil penalties of up to $10,000 per day.
Please note that recent federal legislation has extended the "no exposure exclusion" to all operators of industrial
facilities in any of the I I categories of "storm water discharges associated with industrial activity," (except
construction activities). If you feel your facility can certify a condition of "no exposure", i.e. the facilty industrial
materials and operations are not exposed to stormwater, you can apply for the no exposure exclusion. For additional
information contact the Central Off ice Stormwater Staff member listed below or check the Stormwater & General
Permits Unit Web Site at http://h2o.enr.state.nc.us/su/stormwater.litml
If the subject stormwater discharge to waters of the state has been terminated, please complete the enclosed
Rescission Request Form. Mailing instructions are listed on the bottom of the form. You will be notified when the
rescission process has been completed.
If you have any questions regarding the permit renewal procedures please contact Ricky Revels of the Fayetteville
Regional Office at 910-486-1541 or Bill Mills of the Central Office Stormwater Unit at [phone], ex(. 548
Sincerely,
Bradley Bennett, Supervisor
Stormwater and General Permits Unit
cc: Central Files
Fayetteville Regional Office
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone]
eM&
NCDENR
Customer Service
1- 800-623-7748

W
State of North Carolina
Department of Environment,
-Health and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary .
A. Preston Howard, Jr., P.E., Director
Mr. Warren E. Park
Nestaway, Division of Axia
9501 Granger Road
Cleveland, Ohio 44125
Dear Mr. Park:
Q
E:)FEE HNR
March 13, 1998 MAR 2 7 1998
FAYET%EVILLE
REG. CFFICE
Subject: General Permit No. NCG030000
Nestaway, Division of Axia
COC NCG030432
Sampson County
In accordance with your application for discharge permit received on January 27, 1998, we are
forwarding herewith the subject certificate of coverage to discharge under the subject state - NPDES general
permit. This permit is issued pursuant to the requirements of North Carolina General Statute 143-215 .1 and the
Memorandum of Agreement between North Carolina and the US Environmental Protection agency dated
December 6, 1983.
If any parts, measurement frequencies or sampling requirements contained in this permit are
unacceptable to you, you have the right to request an individual permit by submitting an individual permit
application. Unless such demand is made, this certificate of coverage shall be final and binding.
Please take notice that this certificate of coverage is not transferable except after notice to the Division
of Water Quality. The Division of Water Quality may require modification or revocation and reissuance of the
certificate of coverage.
This permit does not affect the legal requirements to obtain other permits which may be required by the
Division of Water Quality or permits required by the Division of Land Resources, Coastal Area Management
Act or any other Federal or Local governmental permit that may be required.
If you have any questions concerning this permit, please contact Darren England at telephone number 919/733-
5083 ext. 545.
Sincerely,
ORIGINAL SIGNED BY
BRADLEY BENNETT
A. Preston Howard, Jr., P. E.
cc: Fayetteville Regional Office
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG030000
CERTIFICATE OF COVERAGE No. NCG030432
STORMWATER DISCHARGES
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision 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,
Nestaway, Division of Axia
is hereby authorized to discharge stormwater from a facility located at
Nestaway, Division of Axia
214 Armory Road
Clinton
Sampson County
to receiving waters designated as an unnamed tributary of Williams Old Mill Branch in the Cape Fear River Basin
in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III
and IV of General Permit No. NCG030000 as attached.
This certificate of coverage shall become effective March 13, 1998.
This Certificate of Coverage shall remain in effect for the duration of the General Permit -
Signed this day March 13, 1998.
ORIGINAL SIGNED BY
BRADLEY SENNETT
A. Preston Howard, Jr., P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

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