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HomeMy WebLinkAboutNC0078492_Complete File - Historical_20171231State of North Carolina. Department of Environment, Health, and Vatural Resources Mooresville Regional Office James G. Martin, Governor William 'JZ Cobey, r., Secretary Albert F. Hilton, Regional Manager DIVISION OF ENVIRONM ;NTAL MANAGEMENT July 23, 1991 Mr. Richard L. Wagoner 931 Hearthstone Road Stone Mountain, Georgia 30083 Subject: Investigation. Chemstreams, Inc. Gribble Road Union County, NC Dear Mr. Wagoner: This is in response to your letter dated July 15, 1991 to Mr. Tony Parker with this Office. You indicated in your letter that Mr. Parker observed a discharge or saw evidence that chemicals were still flowing onto your property which originated at Chemstreams. Mr. Parker has stated that he has never observed any direct discharge from Chemstreams' property onto your property. Please note the attached reports documenting Mr. Parker's involvement to date. Mr. Parker did indicate, however, that a chemical substance was seeping out of the ground and appeared to be originating on your property. According to Mr. Parker, this seepage was not a result of a surface discharge. It would appear that the seepage may be contaminated groundwater. It is suggested that you contact the Groundwater Section for any advise or assistance concerning the seepage problem. Mr. Parker did, however, collect a soil sample from this area and water samples from the lagoon on your property. These results will be forwarded to all interested parties when they are received. Again, I wish to reiterate the fact that Mr. Parker's investigation on February 15 and July 11, 1991 indicated no off -site discharges. Please be advised that the Water Quality Section cannot address possible groundwater problems or concerns, only surface spillages or runoff. 919 North Main Street McxorrsvlNe, NC. 28115 • Telephone 7CW-663-1699 • FAX 704-663-6040 An Equal opportunity Affirmative Action Employer Sincerely, D. Rex Gleason, P. E. Water Quality Regional Supervisor Parker or me at .char- L. Wagoner Page Two July 23, 1991 In regards to spillages on site at Ch stre s Parker indicates that only minor problems exist and that previous spillages had been cleaned up d resolved. He also indicated that other actions were taken by Ch stre- s to regent any runoff oft -site, The attached reports should be self exP self-explanatory; however, should you have any questions, please contact _a 4/6-1. Attachments TRP:se State O North Carolina Department of :nviro, ent, Health, and Natural Resources s��tn��re ilk i s^.on a Otticr. Albcrt F. Hultnn, keg anal lv'laria ,'er DIVISION OF ENVIRONMENTAL MANAGEMENT February 28, 1991 Mr. Will Oliver Chemstreams, Inc. Post Office Box 1565 Matthews, North Carolina 28106 Subject: Chemstreams Response to Notice of Violation Chemstreams, Inc. Union County, NC Dear Mr. Oliver: This Office concurs with the proposed modifications and remediation plans for the subject facility outlined in your recent correspondence dated February 20, 1991. However, other concerns not addressed were areas where spills have occurred on site (i.e.-contaminated soils cleanup and analysis of spilled. material noted in the investigation on February 15, 1991). Another concern is the possibility of groundwater contamination on -site and off -site from the spills and runoff. The water table and bedrock in this area are suspected to be very shallow. It is, therefore, suggested that you contact the Groundwater Section of this Office for guidance and advise for defining the vertical and horizontal extent of any possible contamination. As noted in the previous Notice of Violation dated February 6, 1991, Chemstreams, Inc. must restore all areas adversely affected by previous discharges and spills an -site and off -site. Failure to comply with these requirements may result in this Office recommending enforcement action. If Chemstreams, Inc. does not have the expertise necessary for proper site evaluation and complete cleanup then the Company should consult with an engineering firm specializing in these areas. pageo February 2 1991 : Should you have urth r cluesquestions, or i you need to meet staff of this Office, please contact Mr. Tony Parker or me. Sincerely, D * Rex Gleason, Water Quality Regional Superir Union County Health Department Ms. Barbara Christian (Groundwater Section) Solid Waste Management (HazardousWaste on) TRP:se : James L. ill A _`, of NorthCarolina ent, Heald, and Natural. Resources ooresville Regional C)trice 1bernt DIVISION OF ENVIRONMENTAL, February 21, 1991 Mr. Steve Owens 3709 Gribble Road Indian Trail, North Carolina 28079 Dear Mr. Owens: F lilt��n Regional Manager ANAGEMENT Subject: Complaint Investigation Chemstreams, Inc. Union. County, NC Attached please find a copy of the Report of Investigation prepared by Mr. Tony R. Parker with this Office, regarding the complaint filed by you on February 13, 1991. The Report should be self-explanatory; however, should there be any questions or if you should need assistance from this Office in the future, please do not hesitate to contact Mr. Parker or me. Attachment TRP;se Sincerely, D. Rex Gleason, P. E. Water Quality Regional Supervisor 919 North Kean S et. Mooresville, N.C. 2311'5 • k prone 704 663-1699 * FAX 704 CO 6(Y4( -1n [qua) Opportunity .Ali.irn,a1 ve Aetuon Employer NRTr' CAROLINA DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES DIVISION OF ENVIRONMENTAL MANAGES EN'T WATER QUALITY SECTION POST OFFICE BOX 950 MOORESVILLE, NORTH CAROLINA 2 11 REPORT OF: Complaint Investigation PLACE VISITED: Roiling Truck Leasing and Chemstreams, Inc. DATE: February 15, 1991. ADDRESS: Gribble Road, Indian `frail, Union County, NC RIVER BASIN: Catawba BY WHOM: Tony R. Parker and Kent Smith TIME SPENT: 2 Hours PERSONS CONTACTED: Complainant -Steve Owens (Rollins Truck Leasing) ; Jerome DuBow and Hardy Griffin (Chemstreams, Inc.) REASON FOR VISIT: Mooresville Regional Office received complaint concerning chemicals or oil in a ditch below Chemstreams, Inc. located at Indian Trail in Union County, North Carolina COPIES TO: Solid Waste Management Division (Hazardous Waste Section) Groundwater Section (MRO) Union County Health Department Ron Phelps (MRO) Kent Smith (MRO) REPORT: A site visit was made by Tony Parker (writer) and Kent Smith on Friday, February 1.5, 1991. The investigators arrived at Rollins Truck Leasing and met with Mr. Steve Owens (Service Manager, complainant). Mr. Owens stated there appeared to be oil entering a ditch located on their property. He also stated a chemical substance was bubbling up from the ground also on their property. Mr. Rollins then led. the investigators to the rear of their property where a. visual inspection revealed that an oily substance was evident in a. ditch, also a chemical, substance appeared to be bubbling up from the ground in several areas. The area is located downgradient approximately 0.2 mile from Chemstreams. There is a vacant lot between Chemstreams and Rollins Truck Leasing. The investigators then departed. and proceeded to Chemstreams, Inc. and met with Mr. Jerome DuBow and Mr-. Hardy Griffin, General Manager. Mr. DuBow stated that Ron Phelps, Division of Environmental Management/Mooresville Regional Office had been working with them concerning the problem. The .investigators were not aware that Ron Phelps had already investigated the Company prior to this visit. After speaking with Mr. DuBow, the investigators requested to inspect the grounds. Mr. Griffin then agreed to accompany the investigators on a tour of the facility and grounds. During the investigation, it was noted that Chemstreams had numerous unlabeled barrels. stored on site. Many barrels were open with no lids and some were observed to have overflowed. Further investigation revealed an oily residue which had spilled onto the ground and appeared to be from a truck tanker. An additional oil or chemical spill was observed near the northern property boundary. The spills noted appeared to be confined to Chemstreams' property. According. to other workers on site, the spills had just been discovered. The investigators then advised Mr. Griffin. that the spills would need. to be cleaned up immediately. Mr. Griffin said he would. comply and ordered employees to begin cleaning up the spills. The investigators then departed. Upon returning to the Mooresville Regional Office, it was learned that a Notice of Violation. dated February 6, 1991 had. already been mailed regarding the above noted deficiencies. Company officials have advised they are preparing a response to that notice along with the most recent spillages noted during this investigation. By copy of this Report of Investigation, it is suggested that. the Solid Waste Management Division (Hazardous Waste Section) further investigate this facility to determine if any hazardous waste violations have occurred. Another area of concern not previously addressed is groundwater. The water table in this area appears to be very shallow and borders the Charlotte Belt and Carolina Slate. Belt units. The investigators suspect that groundwater may have been impacted due to the past spills and discharges; therefore, by copy of this report, it is suggested that the Groundwater Section, Mooresville Regional office, investigate to determine if groundwaters at and adjacent to this area have been impacted by the discharges and spills from Chemstreams, Inc. Jarnes C L 11"''illian7 r� CERTIFIED MAIL RETURN .RECEIPT REtUESTED Zc NU, , DIVISION OF ENVIRONMENTAL MANAGEMENT February 6, 1991 Mr. Jerome Dubow Chemstreams, Inc. Post Office Box 1565 Matthews, North Carolina 28106 Dear Mr. Dubow: Alix r . F~{jItt Subject: Notice of Violation Wastewater Discharge Chemstreams, Inc. Union County, N.C. This Office concurs with the modifications proposed for the subject facility outlined in your recent correspondence dated January 16, 1991. It is recommended that the work on these improvements begin as soon as possible. The results from the sampling at Chemstreams conducted by Mr. Phelps on January 4, 1991 have been received by this Office. The results from the diked area indicated a concentration of 39,000 mg/1 ethylene glycol. Analysis of the runoff onto the adjacent property indicated a concentration of 91,000 mg/1 ethylene glycol. To comply with North Carolina General Statute 143--215.84, it will be necessary to immediately cease all unpermitted discharges and undertake to restore all areas adversely affected by previous discharges. Failure to comply with these requirements may result in this Office recommending enforcement action in this matter. It is requested that a written response be submitted to this Office by February 28, 1991 outlining what measures are proposed for restoring the affected areas and preventing further discharges. W 7114-(OW Emph iv6rr Mr. Jerome Dubow Page Two February 6, 1991 If you have any questions regarding this matter, please do not hesitate to contact Mr. D. RexGleason, Water Quality Regional Supervisor, Mr. Ron Phelps or me at this Office. Sincerely, TwA Brenda J. Smith Regional Supervisor cc: Mr. Will Oliver ROP.se 0 Box ,I 65 �v1��11i PE3 Mr. Mike Shalati Union County Public WoY1 S P. G. Box 987 Monroe, NC 28111-0987 Re: Water c:1ischug at 1 IJ 1 i r i l:bJ lati: EAMS, SNC, NJC 28106 /041 82 :January 16 wek I talk and Mr. Ron Environment, Health and atResources uoucern of the rain water and process water from. the site. therefore it is important that I proceed in the proper txvolved. Therefore, :1 an outlining the results of my - Mr F'he l ps . 6727 ,.. the E)epar tment ref: e hat rdl.inc arrd disposal s a ser f ou s matter and ection to satisfy all coon versat i - with you and 1. No process water run off will be accepted. from leaking retaining walls. All fugitive piping plugged immediately. l r.rdes All storage drums on the rear of the property near the rai'1rjc ad tracks will be relocated to a central area where they wi11 be monit:ared for potential leaks. These drtrins are presently in gocxd condition . The ,present ©rage area ho lds water so sustained dry weather is necessary }efore I -locate these drtmrs . 3. The areas where hoses are rou containment. 4. Rain water will be al lowed to f items are in place. 5. Prxess water will lahoratory. The analysis approval, measured quantities w A per gallon fee will be ,paid. the facility to the sewer mai analysis and metering tai re nely handled wi11 be curbed for spill ral urse after the anal °zed by an EPA -ded to you for approval ill betrucked to the county for The ultimate objective will be to r. This system will also require 6. The quantity of water wi1l depend upon rain, but w. approximately 10,000 gallons per week. The contaminants trace amounts of glycols and other low` bl.ec_ular ight oxygenates such as ketones, alcohols and esters. 7e -oved Upon 15a l . e-1.rr prior 1 routinely be ill. n ar-ma 1 l y be cc:'t 7. You will provide acceptable analysis guide 1 i es for the plant to. use asa target. This will include acceptaEle levels of H.0.D., C.O.D. solids, and contained organics. forward to your response and to working with your group. Sincerely, Ron Phelps `orunental Management tment of Environment, Health and Natural Resources P. O. Box 950 Mooresville, NC 28115 Jerome DuBow Robert G. Sch Robert Farmer CT,vNIY IN AR?) F rQ1LE QR{S 5 121 131 14'i 1. 1.51 16 17 18 19 20 A .€ 1 t�r 1 SezehriM.eir, rs B DMI'Re+it T5 f.ced. 51T ded 5 44U..._ Valor .,l.xutgwct .. tS (�?,. PH 5 3 445 Aitt Te Ipertrrr, r /10044 110 m1 4002,2444) N.C. DEPT. OF NATURAL RESOURCES & COMMUNITY DEVELOPMENT DIVISION OF ENVIRONMENTAL MANAGEMENT WATER QUALITY FIELD -LAB FORM (OMI) SAMPLE TYPE ME4 'N'(5 S T i TION _.,,,J.Q 1AT PSTT R^iMARK5 3cf ..... irnc Begin C}ra€e End 40 100gym, 'hi )2217 co,r, 32r09 322i3 1 SP'Llf CC)MPL.IAN4C s nt N 625 1 a7yr *NCI .. p Nv I f d cas P 70507 P C7iasc8vcd vs P 6f5 Ac Sidvr"r 1027 . e.... ea a Cpnd Crs, S,t> �.y )T;a ;Cd'- �.ed orn10"27 fl .mr ar+.lnc+ss=To4a0 34"}t') ttdfr 1C0... 5 Pr 14 €037 S rise 745 S 14•Cnc 'dipatw 554 Orr W! 523 f1r e ad Peri A,l Frye 572 Clr#' cs. P'eei Flvre 825447 r LAH NUMHIR t, 0AUF R1CI DA1A ENTRY eIepe A Ft From Sus ' uta rrr rher Ccirepewe i,N1 lie€ tEr 7 0,51 5E Srrnewt) tOP;� CuPusr4u,lts 1147 c G (N7X 571 3rwLarb su caa*ecrR F� Actd ,PTPT9pTablel 4Y")42 4 d7 I es a.,.Atrea �r es'ity S�we ru€TSeer;ty 15er�r LAB NO. W44 REPORTED BY (1,40 CHECKED BY REVIEWED BY SUPERVISOR SAMPLE TYPE. OTHER STORET NO. COMPOUND DATE SEMIYOLATILI ORGANIC REPORT ANALYSIS RESULTS ENTERED BY CHECKED BY ANALYSIS BY GC/FID DIRECT AQUEOUS INJECTION INDICATES THE PRESENCE OF ETHYLENE GLYCOL, CONCENTRATION MG/L EH.TYLENE GLYCOL 39000 ROD?Ah. Tube Fe, P31615. ;Tw Fx e Total ' 1:40 ?�..,. ,,..._._.,..m.w. VOIpr to SOS. ,.u....�.....,.,_„ Residoe'S peaded 52,0 ..............._.....,...__ `—w.._....,...''_/1 +s - _.. TD4 .,.4sue_. fi 3435 Alkali�v'ly, to pH e J 4,5 kN 4 5, 410 01 A N C. DEPT OF NATURAL RESOURCES & CQMMUNITY DEVELOPMENT DIVISION OF ENVIRONMENTAL MANAGEMENT WATER QUALITY FIELD -LAB FORM (QM1) SAMPLl` TYH IAME8IENTT EjE EEtC'EN';:..r SPLIT STATION LOCATION w CTI T6 522'I7 _. 00 Care 32309 Ph ES yriMt 32 2 I 3 de P.80 'Phenols,_�w� fade 745 esnd. 95 _-_-�— uMlrasr'c znnss Dry WI 573 n�tsss Poi A lr L A'5 NUMf!if R 00008 DA.T8 R[C;IEVE.0 Re L1AIA ENIRY ay AN(;f DATE E"A4't Vole Iype A H I K Ist �s N, J S a IN0 ,e0YN0J us N 630 IPQ4 ns P i ,?507 .... 71900 nes'ium 927 II055w Ch C> GNXX sr°i &r,�s' / dti��rrf'esl ExEsa+°K n Ar.rd Tx;e�6t trnr l'r5 .Sewn Acid Henbic,ci Sc n Poraeas%res )0 * 4i13 94 i<`44 43? Ei2424) 0 R S©'tO Bi ¢t SoS 0ity ACloud Cover :� YW� d C3irexgiao10 g ;� S9uer iar877sL_ SPVdye. gFMIVf TII�F Rt3 NT, PFPORT �R�Y LAB NO. REPORTED BY CHECKED BY REVIEWED BY SUPERVISOR SAMPLE TYPE: OTHER DATE ANAL? SIS RESULTS ENTERED BY CHECKED BY t STORET h4O. COMPOUND CONCENTRAT ANALYSIS BY GC/FID DIRECT AQUEOUS INJECTION INDICATES THE PRES€NCE OF ETHYLENE GLYCOL. EHTYLENE GLYCOL CHEMS REAMS, INC, P., 0 Box 1565 - Matthews,. NO 28106 - (704. 821-6727. iv* (AL NA I URAL P:RRRR LA' , January 16, 1991 Mr. Mike Shalati Union County Pub 1 i c Works P. O. Box 987 Monroe, NC 28111-0987 Re: Water discharge from the Cbetnstreams facility at 3501 Gribble Road Dear Mr. Shalati: Last week I talked to you and Mr. Ron Phelps of the Department of Environment, Health and Natural Resources concerning the handling and disposal of the rain water and process water from the site. This is a serious matter and therefore it is important. that I proceed in the proper direction to satisfy all involved. Therefore, I am outlining the results ofmy conversation with. you and Mr. Phelps, 1. No process water run off will be accepted. This includes discharge from leaking retaining walls. All fugitive, piping will be removed and plugged immediately. 2. All storagedrums on the rear of the property near the railroad tracks will be relocated to a central area where they will be monitored for potential leaks. These drums are presently in good condition. The present storage area holds water 80 sustained dry weather is necessary T3-6-to-re --c-T:an-relocate these drums. 3. The areas where hoses are routinely handled will be curbed for spill containment. 4. Rain water will beallowed to follow its natural course after the above items are in place. 5. Process water will be retained andanalyzed. by an EPA approved laboratory. The analysis will be forwarded to you for approval. Upon approval, measured quantities will be trucked to the county for disposal. A per gallon fee will be paid. The ultimate objective will be to tie-in the facility to the, sewer main. This system will also iequre prior analysis, and metering. 6. The quantity of water will depend upon rain, but will routinely be approximately 10,000 gallons per week. The contaminants will normally be trace amounts of glycols and other low'molecular weight. oxygenates such as ketones, alcohols and esters. You will provide a ceptablean is guide the pl t t as a target. This will include acceptablelevels . m. ., a soli and contained organics. look for adt?your response and tc Sincerely, eaz� 1 al a c3 Natlae O. Box s G. Farm 2 4 5 6 9 17 A Oth Shipped by= Bus,( pttECTORCSYe�, .. BOD 'RANGE R®sidue75 nded ; 300 Yalatite 535 fiFed : ic#1r t 4436 Acrdtwta ii83 4 AI alir,ity m sty 8, 415 t—Y trt pHs 5 41 7 SEED: Air_T mperatU+e 70 Dead oa e erity 14s G GNXX Na<kel1067 An tlriit©ku 1092 nkks ;r"^'Gt n Extracttkb Gtsrt -Ad Exittt ict lies _ ,N,EPT, OF NATURAL RESOURCES & COM DEVELOPMENT DIVISION OF ENVIRONMENTAL MANAGEMENT WATER QUALITY FIELD -LAB FORM (DM1) AMMSIENI ._. REM6ARKS- yY/mmrdd,K A ssen Cfil a:.#rl� 322:17 SAMPLE TYPE GENCY '2209 e 71':80 Ta1a1 AS 38260 4Mh o /c L;COMPIIANCE DA°ft, REPORTED: — Catcium 916 11— t ..rTtwtim 3027' 7 Cha •rttuett. ,, tn1 1034 JeYair9+0 �•✓1 tht zrr 1132 / GA'Ci:'k7e51" ptds',5 014.5 4(Q0 h -?74 ';'32: 4 - 4 "t 'd,243 $a11trity Algae^F,10otkng Mats i*tac6pklwrtian In/Ocryt. ilktueEC wer, Wlirri I ver0y, CHECKED' ADDEO INJECTIONNDICAT THE PE EtF tHYNE GLYCOL lalrrr: F Trri 3k5 4 pH 4.:5,436. 16 A1rd , 10 pH 8-3 435_ _ 1 Al4ttlinitg ti TnH 3 435 8 Ili 19 20 iSiardl, tlH4,54111 C. DEPT. OF NATURAL RESOURCES VELOPMENT VISION OF NVIRONN ENTAL MANA WATER DUALITY FIELD -LAB FORM I M SAMP&E TYPE Ah*IEN1 STA a 209 Chl i . Peri Fivr. 8254 / 400 l I T OCt ITV DMA i ! ' Pl9ANCE DATE,,E�ar.; aa,M g C GNXX Nikkei 10 n iuCt±-f 14, 4Purr, nbles....__ pH4.5 Aeidity 4,5 PH 8,3. E TES « < E ERED CEKD BY DUPE " Ir SA Pi TYPE: TE CHECKED COEFITT11 ANAL 1S /F1D DIRECT. UE0 ETC ITE E PRE E ETHYLENE Gin EITEE State i= "Jt. r-th :rr:lia��r [ epartrnent of Erivironrr er t, Health, and Natural Resources !Mooresville Regional C.)1=tice Albert F. Hilton, E eicr DIVISION OF ENVIRONMENTAL MANAGEMENT January 11, 1991 Mr. Jerome Dubow Chemstrearns, Inc. Post Office Box 1565 Matthews, North Carolina 28106 Subject: Wastewater Discharge Chemstreams, Inc. Union County, NC Dear Mr. Dubow: Mr. Ron Phelps of this Office visited the subject facility on January 4, 1991 in response to a complaint. A survey of the premises was conducted which revealed contaminated runoff water leaving the property. This contaminated runoff must be contained, treated and properly disposed of. As previously discussed, it is recommended that you contact. Mr. Mike Shalati, Union County Public Works regarding the pretreatment of this wastewater for disposal into the sanitary sewer system. Mr. Shalati can be reached at 704/283-3819. Continuing to discharge this contaminated wastewater is a violation of North Carolina General Statute 143-215.1 and would subject you to a civil penalty of up to $10,000 per day. It is requested that a plan addressing the containment, treatment and disposal of your wastewater be submitted to this Office by February 4, 1991. If you need assistance with this matter, please do not hesitate to contact Mr. Phelps or me. RGP:se Mike Shalati Will Oliver Sincerely,. D. Rex Gleason, P. E. Water Quality Regional Supervisor tr �r, Maxare ville„ NC, 2411 • -Telephone 704-6f73-l699 • FAX 7(4-6(3-6040 CHEMS R -AMS, INC. Box '1 565 - Mal -hews, NC 28106 - (.704 82 °f -6727 July 30, 1990 George T. Eve State of Nort Health Division of 1 512 North Sa: Raleigh, NC Dear Dr. Eve As advised in your �CLLeL Permit No. NC0078492. for NPDES It is our intention to discharge our effluent water into the municipal sewer, as soon as this option becomes available. Please don't hesitate to contact me if there are any questions. Sincerely yours, C STR�S, INC. Robes_ Goozner, Ph.D Technical V.P. RG:pg cc: J. Dubow R. Schory State of North Carolina Department of Environment, Health, and Natural Resources Division of Environmental Management 512 North Salisbury Street • Raleigh, North Carolina 27611 James G. Martini, Governor William W. Coney, Jr., Secreta= ;August 10, 1990 Dr. Robert Goozner Chemstreams, Inc. P© Box 1565 Matthews, NC 28106 George T. Ev Subject: NPDES Permit Application NPDES Permit No. NC0078492 Chemstreams, Inc. Union County Dear Dr. Goozner: tt, Ph.D. Director In accordance with your request received August 7, 1990, the Division of Environmental Management (DEM) is returning your NPDES Permit application. A copy of your application has been submitted to our Central Files for future reference. Should you desire to reactivate your permit request, please advise the Division of Environmental Management in writing and resubmit the complete application with the appropriate application processing fees. Please note that construction or operation of wastewater discharge facilities without a permit may be considered a violation of the Division of Environmental Management regulation 15 NCAC 2H .0101 and the North Carolina General Statutes (GS 143-215.1). If you have any questions, please contact Mr. Dale Gvercash at (919) 733-5083. 'ec nical Support Branch Mr. Jim Patrick, EPA Central Files PoliW on Prevenuien Pays P.Q. Box 27687, Raleigh, North. Carolina 7611-7687 Telephone 919-7-'7t115 An Equal Opportunity Affirmative Action Employer