HomeMy WebLinkAboutNC0067318_Permit Issuance_20121108 NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles Wakild,P.E. Dee Freeman
Governor Director Secretary
November 8, 2012
Mr. David Curtis
Macon County Schools
1202 Old Murphy Rd
Franklin, N.C. 28734
Subject: Issuance of NPDES Permit NC0067318
Nantahala School W WTP
Class WW-2
Macon County
Dear Mr. Curtis:
Division personnel have reviewed and approved your application for renewal of the subject permit.
Accordingly, we are forwarding the attached NPDES discharge 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 U.S. Environmental Protection Agency dated October 15, 2007 (or as subsequently
amended).
This final permit includes no major changes from the draft permit sent to you on July 5,
2012. With the issuance of this permit,you are hereby authorized to operate the subject facility
at a monthly average flow of up to 0.003 MGD.
If any parts, measurement frequencies or sampling requirements contained in this permit are
unacceptable to you,you have the right to an adjudicatory hearing upon written request within thirty (30)
days following receipt of this letter. This request must be in the form of a written petition, conforming to
Chapter 150B of the North Carolina General Statutes, and filed with the Office of Administrative Hearings
(6714 Mail Service Center,Raleigh, North Carolina 27699-6714). Unless such demand is made, this
decision shall be final and binding.
Please note that this permit is not transferable except after notice to the Division. The Division may
require modification or revocation and reissuance of the permit. 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, the 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 Charles Weaver at telephone number(919) 807-6391t
ZP 4E.
cc: Central Files
Asheville Regional Office/Surface Water Protection
,NPDES Unit
1617 Mail Service Center,Raleigh,North Carolina 27699-1617 One
512 North Salisbury Street,Raleigh,North Carolina 27604 O Carolina
Phone: 919 807-6300/FAX 919 807-6495/hftpl/podal.ncdenr.org/web/wq
An Equal Opportunity/Affirmative Action Employer—50'/o Recycled/101/o Post Consumer Paper atmally
Permit NCO067318 '
s
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
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,the
Macon County Board of Education
are hereby authorized to discharge wastewater from a facility located at the
Nantahala School WWTP
212 Windingstairs Road, south of Fairview
Macon County
to receiving waters designated as Partridge Creek in subbasin 04-04-03 of the Little Tennessee River Basin
in accordance with effluent limitations,monitoring requirements,and other conditions set forth in Parts I,
II, III and IV hereof.
This permit shall become effective December 1, 2012.
This permit and authorization to discharge shall expire at midnight on November 30, 2017.
Signed this day November 8, 2012
Ch akild,P.E.,Director
Di ' ion of Water Quality
By Authority of the Environmental Management Commission
Permit NCO067318
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby
revoked, and as of this 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.
The Macon County Board of Education is hereby authorized to:
1. Continue to operate an existing 0.003 MGD extended-aeration wastewater treatment
system that includes the following components:
■ 2000-gallon primary clarifier tank
■ 2000-gallon Aero-flo aerobic digestion system
■ 1000-gallon polishing tank
■ 580 ft2 recirculating sand filter
The facility is located at the Nantahala School WW'I'P, south of Fai=view off
Windingstairs Road in Macon County.
2. Discharge from said treatment works at the location specified on the attached map
into Partridge Creek, a class C-Trout stream in hydrologic unit 06010202 of the Little
Tennessee River Basin.
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Quad:Hewitt,N.C. N C 00 6 7 318 Facility
Stream Class:C-Trout Location
Subbasin:40403 NantahaLa School WWTP
Latitude:35°15'10"
Longitude:83°38'06"Receiving Stream:Partridge Creek North SCALE 1:24000
Permit NCO067318
A. (1) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS [0.003 MGD]
During the period beginning upon the effective date of the permit and lasting until expiration,the Permittee is
authorized to discharge from outfall 001. Such discharges shall be limited and monitored by the Permittee as
specified below:
PARAMETER LIMITS MONIMRING_�REQUIREMENTS
Monthly Daily Measurement Sample Type Sample Location
Avers a Maximum Fr uenc
Flow 0.003 MGD Weekly Instantaneous Influent or Effluent
50050
BOD,5-day(20°C) 30.0 mg/L 45.0 mg/L 21Month Grab Effluent
00310
Total Suspended Solids 30.0 mg/L 45.0 mg/L 2/Month Grab Effluent
00530
NH3 as N Monthly Grab Effluent
00610
Temperature(°C) Weekly Grab Effluent
00010
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Weaver, Charles
From: Cantwell, Janet
Sent: Monday, November 05, 2012 2:55 PM
To: Weaver, Charles
Cc: Cranford, Chuck
Subject: RE: Nantahala School: Macon Co. NCO067318
Hi Charles---Yes,that all sounds good to me with the "AtO" on the cover letter. That way there will be no mistake with
the flow,which only rarely do they exceed. Getting rid of the "special condition"will help also.
Sounds good to go!
Thanks---Janet
Janet Cantwell-Janet.Cantwell@ncdenr.¢ov
North Carolina Dept.of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality-Water Quality Section
2090 US Highway 70
Swannanoa, NC 28778-8211
Tel:828-296-4500
Fax:828-299-7043
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: Weaver, Charles
Sent: Monday, November 05, 2012 2:13 PM
To: Cantwell, Janet
Cc: Cranford, Chuck
Subject: RE: Nantahala School: Macon Co. NCO067318
Janet—This permit doesn't have Fecal limits [and thus a TRC limit/dechlor requirement] due to the dilution instream.
Disinfection has never been required.
They never got an AtC,and didn't need one. They can operate at 0.003 MGD with the existing system. The old special
condition should come out as the wording doesn't make sense.
The permittee probably went forward with operating at 0.003 MGD based upon Bob DeWeese's recommendations.
Should I just include an Authorization to Operate with the permit cover letter? Their flow data for the past 3 years
occasionally shows them violating 0.002 MGD but never approaching 0.003 MGD.
Let me know,and thanks for your help.
CHW
From: Cantwell, Janet
Sent: Thursday, September 13, 2012 1:04 PM
To: Weaver, Charles
Cc: Cranford, Chuck; Menzel,Jeff
Subject: Nantahala School: Macon Co. NCO067318
t
Permit Enforcement History Details by Owner
09/13/10
1
Owner:Benson Apartments
Facility: Benson Apartments
Permit:NCO066362
Region:Asheville County: Henderson
Penalty Remission Enf EMC EMC OAH Collection Has
Assessment penalty Enforcemen Request Enf Conf Remission Hearing Remission Remission Memo Sent Pmt Case
Case Number MR Approved Amount t Costs Damages Received Held Amount Held Amount Amount to AGO Total Paid Balance Due Plan Closed
LV-2009-0134 2-2009 05/01/09 $450 $65.00 06/11/09 $.00 $515.00 $.00 No 07/30/10
LV-2009-0398 7-2009 11/04/09 $200 $67.00 11/11/09 $.00 $267.00 $.00 No 07/30/10
LV-2010-0118 12-2009 05/05/10 $900 $67.00 $967.00 No
LV-2010-0137 1-2010 05/06/10 $850 $67.00 06/05/10 $917.00 No
LV-2010-0179 2-2010 06/16/10 $312.5 $67.00 07/13/10 $379.50 No
LV 2010-0207 3-2010 07/01/10 $437.5 $67.00 07/13/10 $504.50 No
LV-2010-0267 4-2010 08/17/10 $437.5 $67.00 $504.50 No
LV-2010-0310 5-2010 $1,000 $67.00 $1,067.00 No
Total Cases:8 Total Penalty Amount: $4,587.5 Total Enforcement Cost: $534.00 Sum of Total Paid: $782.00 Total Balance Due: $4,339.50
Sum of Total Case Penalties: $5,121.50 Total Penalties after remission(s): $5,121.50
Hi Charles: Attached are documents I found in our files but I could find no AtC. I also found nothing in the files to
indicate that Raleigh had changed the flow from 0.002 mgd to 0.003 mgd. Their last permit,issued 12/1/07,listed 0.002
mgd for the existing flow but:it stated:
"2. Upon receiving an Authorization to Operate from the Division of Water Quality, treat up to 0.003 MGD of
domestic wastewater."
What the school probably did was look at number two above and assume they could discharge up to 0.003 mgd since
their permit had been renewed.
The school also had the EAA and Treatment Capability reports from Bob DeWeese stating that"3000 epd was
sustainable" (see bottom of p. 9 of the attachment).
I remember this issue came up for the Cullasaja School WWTP also.
So, it's your call on the flow issue. It appears there was no AtC issued but Bob DeWeese's reports could have a bearing
on the outcome,I reckon.
I am curious why there are no fecal limits with TRC and dechlor requirements.
Other than all that mentioned above,the permit looks as it always has.
Thanks---Janet
Janet Cantwell-Janet.Cantwell@ncdenr.eov
North Carolina Dept.of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality-Water Quality Section
2090 US Highway 70
Swannanoa,NC 28778-8211
Tel:828-296-4500
Fax:828-299-7043
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.
2
Permit Enforcement History by Permit
Permit:NCO066362 Facility:Benson Apartments Owner:Nathan D Benson
Region:Asheville County:Henderson
Penalty Remission Enforcement Collection Has
Assessment Penalty Enforcement Request Conference EMC Memo Sent Paymeet
Case Number Approved Amount Costs Damages Received Held Hearing Held to AGO Total Pald Balance Due Plan Case Closed
LV-2009-0134 05/01/09 $450.00 $65.00 06/11/09 10/03/09 $516.00 .00 No 07/30/10
LV 2009-0398 11/04/09 $200.00 $67.00 11/11/09 01/20/10 $267.00 .00 No 07/30/10
LV 2010-01:18 05/05/10 $900.00 $67.00 05/12/10 07/12/10 05/12/11 967.00 No
LV 2010-0137 05/06/10 $850.00, $67.00 06/05/10 08/07/10 05/12/11 917.00 No
LV 2010-0179 06/16/10- $312.50. $67.00 07/13/10 04/19/11 379.50 No
LV 2010-0207 07/01/10 - $437.50 $67.00 07/13/10 04/19/10 504.50 No
LV 2010-0267 08/17/10 . $437.50 $67.00 09/20/10 04/17/11 504.50 No
LV 2010-0310 09/14/10 . $1,000.00 $67.00 09/23/10 04/19/11 1,067.00 No
LV 2010-0374 11/18/10 $1.275.00 $67.00 12/20/10 1,342.00 No
LV-2011-0008 01/12/11 $375.00 $67.00 02/12/11 442.00 No
LV-2011-0010 01/12/11 $200.00' $67.00 02/12/11 267.00 No
Total Cases: 11 $6,437.50 $735.00 _ 782.00 $6,390.60
Total Penalties: $7,172.50 Total Penalties after remisslon(s): $7,172.60
-
ASHEVIi i F
CITIZEN T M ES
VOICE OFTHE MOUNTAINS•CIT MV TIAfS.COm
AFFIDAVIT OF PUBLICATION
RCS Procpertles, Inc. requested renewal of BUNCOMBE COUNTY
�rlIt NC0p62961 for Shoppe5 of n c le
WWfP, Aveg Cgrity. This �e mIne P}ec fty
d scheehies eetea wastewt r to a Wa u
�a Piv r, watnupe River Gast. C ero ee Cou
vy v.N.ls reoouested renewal o VAN SS.
NCOp363B6 for to HIW a4seee am Sc�iool
ad This lter to f}anig tllzc ar es `prest
,, ivestewyter Into Thom son Branca es d NORTH CAROLINA
see River BaalI1. Macon Counnty BOE re0yestetl
renewal Of perhrlll NLOg67326/LuIAseo5c o
WWTP. Facl ty dscharges to t e Cu Uncle
River/Lllttle Tennessee gqllver Basle Fecal col
rRI a tl total resitluaI chlorine are water
quality iimmed. Macon Cpunty ac,j re uestetl Before the undersigned, a Notary Public of said County and
renew lof NC0067319/NantCun 0 hoe WW9TP.
Faclluty tllspna ge4 to Parthl Ype C agwu no State duly commissioned qualified and authorized by law
Tennessee River Basin. Currently no > >
paramete are water qualltY limited. TWA5A
lequeste�renew at. of permit tI00097602/Vlhit to administer oaths personally appeared Velene Fagan
er WWTP/J3ckson County Fac llty dlschar s a
to me T cicaseUr ee Riv r/Tittle Tenne see ttev who being first dui sworn deposes and says: that she is
er B 11 Current) gecal calif rm Is ware
quality mrtetl. 1. Pa'IcI NelneB requested a g Y r P Y
renews f permI NC 7/Sln n ater
pnmp4npp Resort WYRP api4Dn CpDu `Y the Legal Billing Clerk of The Asheville Citizen-Times,
Facility di chQar e¢s5p�.toC ro t Crlco L(oette
To "B8Itl R291au�1 1phmrlp airy watelr quality engaged in publication of a newspaper known as The
ruts
STATE PUBLIC NOTICE ICFOLINA Asheville Citizen-Times,published, issued, and entered as
OF NOWINENVIRONMENTAL MANAGEMENT first class mail in the City of Asheville,in said County and
COMMISSION PDES UNIT
1611 MAIL SERVICE CEN ER,RALEION,NC 21693-
617 State;that she Is authorized to make this affidavit and —— -
NOTIFICATION OF INTENT TO ISSUE A NPDES
WASTEWATER meetPERM p sworn statement; that the notice or other legal
The Noah Carolina En Ihpnmepta Management
ane ement
CDmm440n prapO4e4 t0 ssuea
�oIIw ale w dlc g� permit to the per advertisement,a true copy of which is attachedhereto,was
w itt comments reaprtll p the proposed perpublished in The Asheville Citizen-Times on the
W]t bComme cc¢FFFFnpts rnfll rd avvs
niter t e oubll5b tlete of t I n tice.The DInto
t�ppr opf)Ne pNc Rllv++�mna1�,toFQnDtn �� following date: September 16'h 2012. And that the said
6ee3ipnit¢ant degree of public lnierestoultl there s
Pleasa mDa11 co meros and/or Information re newspaper in which said notice,paper, document or legal
Inter sfetl PaRotiris aaY y'I It tM1e4UWQ at 512 N.
5aSf5gu Street,R aTgh.NG lD revI w advertisement was published was, at the time of each and
i format on an tI a Ptltl1t oriel IM 11 if It on
N�DES p r II a th s notice ay tie ou tl on
our w¢P641 e: my o /po al.in enr.o p waL/w every publication, a newspaper meeting all of the
/sw np�es/calen�x. or ay calling (9199
September162012 9647 requirements and qualifications of Section 1-597 of the
General Statues of North Carolina and was a qualified
newspaper within the meaning of Section 1-597 of the
General Statues of North Carolina.
A Signed this 17B',day of September,2012
�v_ \
(Signature of person making Ida '
Swom to and subs 'b d before me the 17th,day of
j1eplebar,
Libl,
My Co fission expires the 5`n day of October,2013aYe�,.A�'P,)®Yt` o�•,,,�tl
.XZ
(828)232-5830 1 (828)253-5092 FAX 64, 1`�'-� 6 AkY
14 0.HENRY"E. I P.O.BOX 2090 1 ASHEVILLE,NC 28802 1 (800)800-4204
c)GANNErr Pt, el 1C �Ue
FACT SHEET FOR EXPEDITED PERMIT RENEWALS
This form must be completed by Permit Writers for all expedited permits which do not require
full Fact Sheets. Expedited permits are generally simple 100%domestics (e.g., schools,mobile
home parks, etc)that can be administratively renewed with minor changes, but can include
facilities with more complex issues (Special Conditions, 303(d)listed water, toxicity testing,
instream monitoring, compliance concerns).
Basic Information for Expedited Permit Renewals
Permit Writer/Date Charles H. Weaver 9/11/2012
Permit Number NC0067318
Facility Name Nantahala School WWTP
Basin Name/Sub-basin number 04-04-03
Receiving Stream Partridge Creek
Stream Classification in Permit C-Trout
Does permit need Daily Max NH3 limits? N/A
Does permit need TRC limits/language? N/A
Does permit have toxicity testing? No
Does permit have Special Conditions? No
Does permit have instream monitoring? No
Is the stream impaired(on 303(d) list)? No
Any obvious compliance concerns? None
Any permit modifications since last permit? None. .
New expiration date 11/30/2017
Comments on Draft Permit?
Most Commonly Used Expedited Language:
• 303(d) lanauase for Draft/Final Cover Letters: "Please note that the receiving stream
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".
• _ NPDES APPLICATION FOR PERMIT RENEWAL - FORM A
For Publicly Owned Treatment Works (POTW) or other treatment systems treating
domestic wastes <0.1 MGD With no pretreatment program.
- Mail the complete application to:
N. C. Department of Environment and Natural Resources
Division of Water Quality / NPDES Unit
1617 Mail Service Center, Raleigh, NC 27699-1617 •
NPDES Permit 000067310
If you are completing this form in computer use the TAB key or the up -down arrows to move from one
field to the next. To check the boxes, click your mouse on top of the box. Otherwise,please print or type.
1. Contact Information:
Owner Name MACON COUNTY BOARD OF EDUCATION
Facility Name MACON COUNTY SCHOOLS
Mailing Address 1202 OLD MURPHY ROAD
City FRANKLIN
State / Zip Code NORTH CAROLINA 28734
Telephone Number (828)524-3314
Fax Number (828)524-5938
e-mail Address david.curtis@macon.kl2.nc.us
2. Location of facility producing discharge:
Check here if same address as above ❑
Street Address or State Road 213 WINDINGSTAIRS ROAD
City TOPTON
State / Zip Code NORTH CAROLINA 28781-9728
County MACON
3. Operator Information:
Name of the firm, public organization or other entity that operates the facility. (Note that this is not
referring to the Operator in Responsible Charge or ORQ
Name MACON COUNTY SCHOOLS
Mailing Address 1202 OLD MURPHY ROAD, PO BOX 1029
City FRANKLIN
State / Zip Code NORTH CAROLINA 28734 OR 28744
Telephone Number (828)524-4460 EXT 335
Fax Number (828)524-5938
F 4NT so
4. Population served: 120 c
` QUALITY
_ ,f BRAN - _
1 of 3 RCE CH Form A 1/06
NPDES APPLICATION FOR PERMIT RENEWAL - FORM A
For Publicly Owned Treatment Works(POTW)or other treatment systems treating
domestic wastes<0.1 MGD with no pretreatment program.
S. Do you receive industrial waste?
® No ❑ Yes(if you have an approved pre-treatment program,must complete Form 2A)
b. Type of collection system
® Separate (sanitary sewer only) ❑ Combined (storm sewer and sanitary sewer)
7. Outfall Information:
Number of separate discharge points 1
Outfall Ideatificatioa number(s) 001
Is the outfall equipped with.a diffuser? ❑ Yes ® No
S. Name of receiving stream(s) (Provide a map shounng the exact location of each outfall):
PARTRIDGE CREEK
9. Frequency.of Discharge: ❑ Contianvus ® Inter�mitteat
If intermittent:
Days per week discharge occurs: 5 Duration: N/A
10.Describe the treatment system
List all installed components, including capacities,provide design removal for BOD, TSS, nitrogen and
phosphorus. If the space provided is not sufficient; attach the description of the treatment system in a
separate sheet of paper.
A PRIMARY CLARIFIER TANK 21000 GAL
AERO-FLO AEROBIC DIGESTION 29000 GAL
SAND FILTER 580 SQ FT
POLISHING TANK 19000 GAL
11. Flow Information:
Treatment Plant Design flow 0.003 MGD
Annual Average daily flow .0010 MGD (for the previous 3 years)
Maximum daily flow .0023 MGD(for the previous 3 years)
12. Is this facility located on Indian country?
❑ Yes ® No
2 of 4 Form-A 1ro6
t
NPDE3 APPLICATION FOR PERMIT RENEWAL - FORM A
For Publicly Owned Treatment Works(POTW)or other treatment systems treating
domestic wastes< 0.1 MGD with no pretreatment program.
13. Effluent Data
Provide data forthe parameters listed.Fecal Coliform, Tempentture and pH shall be grab samples,for all other
parameters 24-hour composite sampling shall be used.Effluent testing data must be based on at least three
samples and must be no more than four and one half y
Units of Number of
Daily Monthly Measuremea
Parameter Maximum Average t Samples
Biochemical Oxygen Demand 45.0 MG/L 6.2 MG/L 72
(BODs)
Fecal Coliform N/A N/A N/A N/A
Total Suspended Solids 45.0 MG/L 8.7 MG/L
73
Temperature (Summer) N/A
16.2 o C 79 ,
Temperature (Winter) N/A
8.9 o C 79
P
H 9.0 7 UNITS 1158
14. List all permits, construction approvals and/or applications:
Type
Permit Number Type Permit Number
_ Hazardous Waste(RCRA) N/A NESHAPS (CAA) N/A
UIC(SDWA) NIA _
Ocean Dumping(MPRSA) N/A
NPDES NCO067318 Dredge or fill(Section 404 or CWA) N/A
PSD(CAA) N/A Special Order of Consent(SOC) N/A
Non-attainment program(CAA)N/A Other
15. APPLICANT CERTIFICATION
I certify that I am familiar with the information contained in the application and that to the
best of my knowledge and belief such information is true, complete, and accurate.
l
' ted name of Person Signing Title
Signature of Applicant ate
North Carolina General Statute 143-215.6 (b)(2) states: Any person who knowingly makes any false statement
application, record re o plan, or
representation, or certification in any p rt' p other document files or required to be
maintained under Article 21 or regulations of the Environmental Management Commission implementing that
Article, or who falsifies, tampers with, or knowly renders inaccurate any recording or monitoring device or
method required to be operated or maintained under Article 21 or regulations of the Environmental Management
Commission implementing that Article, shall be guilty of a misdemeanor punishable by a fine not to exceed
$25,000, or by imprisonment not to exceed six months, or by both. (18 U.S.C. Section 1001 provides a
Fom-A 1106
3of4
Macon. Coup Schools
1202 Old Murphy Road
-- ---j-= Franklin, NC 28734
February 13,2012
Subject: Receipt of permit renewal application
NPDES Permit NCO067318
Nantahala School Macon County
The following are dates and number of loads for the removal of solids(sludge)from our facility:
• February 9,2009 1 load
• June 17,2009 1 load
• August 20,2009 1 load
• October 13,2009 1 load
• November 24,2009 1 load
• January 20,2010 1 load
• April 5,2010 1 load
• August 19,2010 1 load
• December 4,2010 1 load
• April 6,2011 1 load
• April 19,2011 1 load
• August 1,2011 1 load
• October 14,2011 1 load
They are removed&disposed of by: B&B Concrete Products Inc
1687 Georgia Road
Franklin,NC 28734
(828)524-6483
If you need additional information concerning renewal,please contact me at(828)524-3314,
extension 342.
ly,
Davi Curtis
Director of Maintenance
DC/lh
Phone(828)5244414 FAX(828)369-7240•(828)524-5938
an equal opportunity/affirmative action employer