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HomeMy WebLinkAboutNCGNE0748_COMPLETE FILE - HISTORICAL_20110616 STORMWATER DIVISION CODING SHEET NCG PERMITS PERMIT NO. DOC TYPE Ik HISTORICAL FILE ❑ MONITORING REPORTS DOC DATE ❑ YYYYMMDD ALjTD_1l;WA W fRi NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Dee Freeman Governor Director Secretary 16 June 2011 Mr, Eric Harrison, Director of Operations Ornamental Products PO Box 4068 Archdale, NC 27263 Subject: No-Exposure Certification NCGNE0748 Ornamental Products 3804 Comanche Road, Archdale, NC 27263 Randolph County Dear Mr, Harrison: The Division reviewed and approved your request for a No-Exposure Certification for Exclusion from NPDES Stormwater Permitting on February 9, 2011. Based,on your submittal and signed certification of no exposure at the above referenced facility, the Division granted your conditional exclusion from permitting as provided for under 40 CFR 126.22(g), which is incorporated by reference in North Carolina regulations. It is important to note the following items pursuant to the No-Exposure Certification approval: 1) The uncovered dumpster at the rear of the facility contains scrap wood and some metal banding. Pursuant to the information you provided during the site inspection, this dumpster is emptied once or twice per week. Provided that this dumpster is emptied on that schedule (once or twice per week), and does not contain any other products such as paint or stain containers, chemical containers, or other prod uctslcontainers that could contaminate stormwater, then this would not violate the terms of the No-Exposure Certification. 2) The minor amount of saw dust on the ground at the rear of the facility is frequently removed. The remaining amount does not pose a threat to stormwater contamination provided that this good housekeeping practice is maintained on a frequent basis. There exists a vegetated filter strip between this area and the stormwater outfall that prevents any of this material from leaving the site. It is also important to maintain this vegetated filter strip. 3) Scrap metal drums can be stored outside provided that the lids are secured to prevent the collection of rainwater and also to eliminate any possibility of discharge from them. 4) Brand new (never used) wood pallets can be stored outside. Pallets that have been used in any manner must be stored inside or under roof. Your conditional exclusion from permitting does not affect your facility's legal requirements to obtain environmental permits that may be required under other federal, state, or local regulations or ordinances. Division of Water Quality-Surface Water Protection Section 1�7One 1 Winston-Salem Regional Office 1�OY th Carolina Ph e:336-771 Street,Winston-Salem,North Carolina S7107 ���tr�� r`� Phone:336-771-500171 FAX:336-771�63D 1 Customer Service:1-877$23�748 K L/i/ Internet:www.ncwaterquality.org An Equal opportunity 1 Affirmative Action Employer Mr. Eric Harrison NCGNE0748 16 June 2011 If you have any questions or need further information, please contact Corey Basinger at(336) 771-4963, or at corey.basinger@ncdenr.gov. Sincerely, W. Corey Basinger Regional Supervisor Surface Water Protection Section Winston-Salem Regional Office cc: WSRO files S ®®-'�GDA M�CDENR North Carolina Department of Environment and Natural Resources Division of Water quality Beverly Eaves Perdue Coleen H. Sullins Dee Freeman Governor Director Secretary 9 February 2011 Mr. Eric Harrison, Director of Operations Ornamental Products PO Box 4068 Archdale, NC 27263 Subject: No-Exposure Certification NCGNE0748 Ornamental Products 3804 Comanche Road, Archdale, NC 27263 Randolph County Dear Mr. Harrison: The Division has reviewed your submittal of the No-Exposure Certification for Exclusion from NPDES Stormwater Permitting form. Based on your submittal and signed certification of no exposure at the above referenced facility, the Division is granting your conditional exclusion from permitting as provided for under 40 CFR 126.22(g), which is incorporated by reference in North Carolina regulations. Please note that by our acceptance of your no-exposure certification, you are obligated to maintain no-exposure conditions at your facility. If conditions change such that your facility can no longer qualify for a no-exposure exclusion, you are obligated to immediately obtain NPDES permit coverage for your stormwater discharge. Otherwise, the discharge becomes subject to enforcement as an un-permitted discharge. You must self re-certify annually using the included form, or obtain NPDES permit coverage for any stormwater discharges from your facility. The annual self re-certification does not need to be submitted to DWO, unless requested. Your conditional exclusion from permitting does not affect your facility's legal requirements to obtain environmental permits that may be required under other federal, state, or local regulations or ordinances. If you have any questions or need further information, please contact Corey Basinger at(336) 771-4963, or at corey.basinger@ncdenr.gov. Sincerely, 02,11.1 c N for Coleen H. Sullins FFB 1 4 2011 cc: Winston-Salem Regional Office Otormwater_permitting Unit, No-Exposure Files WDEN Rds tRA Q—U7 Brar>tch Wetlands and Stormwater Branch One 1617 flail Service Center,Raleigh,North Carolina 27699-1617 NorthCarolina Location:512 Salisbury 5t.Raleigh,North Carolina 2fiO4 Naturall Phone:919-8-807 S -63001 FAX:919-807-6494 1 Customer Service:1-877-623-674$ i Internet:www.ncwaterquallty.org An Equal Opportunity 1 Affirmative Action Employer AV A ON NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Dee Freeman Governor Director Secretary 9 February 2011 Mr. Eric Harrison, Director of Operations Ornamental Products PO Box 4068 Archdale, NC 27263 Subject: No-Exposure Certification NCGNE0748 Ornamental Products 3804 Comanche Road, Archdale, NC 27263 Randolph County Dear Mr. Harrison: The Division has reviewed your submittal of the No-Exposure Certification for Exclusion from NPDES Stormwater Permitting form. Based on your submittal and signed certification of no exposure at the above referenced facility, the Division is granting your conditional exclusion from permitting as provided for under 40 CFR 126.22(g), which is incorporated by reference in North Carolina regulations. Please note that by our acceptance of your no-exposure certification, you are obligated to maintain no-exposure conditions at your facility. If conditions change such that your facility can no longer qualify for a no-exposure exclusion, you are obligated to immediately obtain NPDES permit coverage for your stormwater discharge. Otherwise, the discharge becomes subject to enforcement as an un-permitted discharge. You must self re-certify annually using the included form, or obtain NPDES permit coverage for any stormwater discharges from your facility. The annual self re-certification does not need to be submitted to DWQ, unless requested. Your conditional exclusion from permitting does not affect your facility's legal requirements to obtain environmental permits that may be required under other federal, state, or local regulations or ordinances. If you have any questions or need further information, please contact Corey Basinger at(336) 771-4963, or at corey.basinger@ncdenr.gov. Sincerely, for Coleen H. Sullins =MnstonSale Regional Office Stormwater Permitting Unit, No-Exposure Files Wetlands and Stormwater Branch One 1617 Maii Service Center,Raleigh,North Carolina 27699-1617 NorthCarolina Location:512-8 7 Salisbury St.Raleigh,North Carolina r S604 ;Vatmra rly Phone:919-807-63061 FAX:919-807�4941 Customer Service:1-877-623-6748 K ` Internet:www.ncwaterqualii .org An Equal Opportunity 1 Affirmative Action Employer i r i RECEIVED N.C.Dect.of EN? JAN 0 3 2011 FOR AGENCY USE ONLY `[ Date Received Division of Water Quality/SurfaceMa ter Protection Year I Moath Day 0 D 1 1 ����� National Pollutant Discharge Elimination System CenificateofCoverage NO EXPOSURE CERTtFICATTON for Exclusion N C N E fN>�Nrvr wr,Nti,.rs�.rr^a�:r� NCGNE0000 NO EXPOSURE CERTIFICATION Please check here if this is a renewal: © RENEWAL National Pollutant Discharge Elimination System application for exclusion from a Stormwater Permit based on NO EXPOSURE: Submission of this No Exposure Certification constitutes notification that your facility does not require a permit for Stormwater discharges associated with industrial activity in the State of North Carolina because it qualifies for a no exposure exclusion_'A condition of no exposure at an industrial facility means all industrial materials and activities are protected by a storm resistant shelter(with some exceptions) to prevent exposure to rain, snow, snowmelt, and/or runoff. For permitted facilities in North Carolina,;DWQ must approve your application for No Exposure Certification before this exclusion is effective. Until you are issued a No Exposure Certification and your,NPDES permit is rescinded, your facility must continue to abide by the terms and conditions of the current permit. Industrial materials or activities include, but are not limited to: material handling equipment or activities, industrial machinery, raw materials, intermediate products, by-products, final products, or waste products. Material handling activities include the storage, loading and unloading, transportation, or conveyance of any raw material, intermediate product, final product or waste product. A storm resistant shelter is not required for the following industrial materials and activities: drums, barrels, tanks, and similar containers that are tightly sealed, provided those containers are not deteriorated and do not leak. "Sealed"means banded or otherwise secured and with locked or non-operational taps or valves;adequately maintained vehicles used in material handling;and final products, other than products that would be mobilized in stormwater discharges(e.g., rock salt). A No Exposure Certification must be provided for each facility qualifying for the no exposure exclusion. In addition, the exclusion from NPDES permitting is available on a facility-wide basis only—not for individual outfalls. If any industrial activities or materials are, or will be, exposed to precipitation, the facility is not eligible for the no exposure exclusion. By signing and submitting this No Exposure Certification form, you certify that a condition of no exposure exists at this facility or site and are obligated to comply with the terms and conditions of 40 CFR 122.26(g). You are required to reapply for the No Exposure Exclusion once every rive (5) Ven L- For questions,please contact the DWQ Regional Office for your area. (See page 6) 1 V � (Please print or type) ed w iz 1) Mailing address of owner/operator (address to which all certification correspondence will be Name a S 3 Contact Street Address CityrC�ddet 3f State_ e, ZIP Code 72:j!20 27Z�j Telephone No. Fax: "3-3�o — 4131_1/26 K 3a i5 '331n - 3f �a Page 1 of 7 SWU-NE-021309 L2St revised 2/13/2009 w , NCGNE0000 No Exposure Certification 2) Location of facility producing discharge: Facility Name Facility Contact arr.sa Street Address City y{-rc-kA State A)O_ ZIP Code 'Z(S 3 County �n d 1 Telephone No. 336 r} (— q(20 Fax: 3.3�a- - 431 3) Physical location information: Please provide a narrative description of how to get to the facility(use stre t names, state road Ou tiers, ar cl distance and dire tion from a roadway inter action . j ;n 0. e (A copy of a map with the facility clearly or a d on it should be included with the certification applicatio 4) Is the facility located on Native American Lands? ❑ Yes B<O 5) Is this a Federal facility? ❑ Yes E-tq-o 6) Latitude 35,1*53,S" Longitude l i. ! 0 (deg., min., seconds) 7) This NPDES No Exposure Exclusion application applies to which of the following: ❑ New or Proposed Facility Date operation is to begin EMI xisting Date operation began U Renewal of existing No Exposure Certification Certification No.: NCGNE 8) Was this facility or site ever covered under an NPDES Stormwater Permit? ❑ Yes If yes, what is the NPDES Permit Number? j 9) Standard Industrial Classification: Provide the 4 digit Standard Industrial Classification Code (SIC Code) that describes the primary industrial activity at this facility SIC Code: 10) Provi e a brief description of the types of indu trial activi es and products pro uced t this facility: .1r1RG it o �� I Y: 11) Does,this facility have any Non-Discharge permits (ex: recycle permits)? *-o 0 Yes If,yes, list the permit numbers for all current Non-Discharge permits for this facility: r Page 2 of 7 SWU-NE-021309 Last revised 2/13/2009 t NCGNE0000 No Exposure Certification Exposure Checklists(12. - 14.) 12) Are any of the following materials or activities exposed to precipitation, now or in the foreseeable future? (Please check either "Yes" or "No.") If you answer "Yes" to any of these items,you are not eligible for the no exposure exclusion. / a. Using, storing, or cleaning industrial machinery or equipment, and areas where ❑ Yes B'No ❑ NIA residuals from using, storing or cleaning industrial machinery or equipment remain and are exposed to stormwater b. Materials or residuals on the ground or in stormwater inlets from spills/leaks ❑ Yes o ❑ NIA c. Materials or products from past industrial activity ❑ Yes R'fo ❑ NIA d. Material handling equipment (except adequately maintained vehicles) ❑ Yes R off❑ NIA o. Materials or products during loading/unloading or transporting activities ❑ Yes o ❑ N/A f. Materials or products stored outdoors (except final products intended for outside Cl Yes a o ❑ NIA use [e.g., new cars]where exposure to stormwater does not result in the discharge of pollutants) g. Materials contained in open, deteriorated or leaking storage drums, barrels, tanks, ❑ Yes 2- o ❑ N/A and similar containers h. Materials or products handled/stored on roads or railways owned or maintained by ❑ Yes o ❑ NIA the discharger i. Waste material (except waste in covered, non-leaking containers [e.g dumpsters]) ❑ Yes Pilo ❑ N/A j. Application or disposal of process wastewater(unless otherwise permitted) ❑ Yes o ❑ NIA k. Particulate matter or visible deposits of residuals from roof stacks and/or vents not ❑ Yes B`INo ❑ NIA otherwise regulated (i.e., under an air quality control permit) and evident in the stormwater outflow 1. Empty containers that previously contained materials that are not properly stored ❑ Yes 1No ❑ NIA (i.e., not closed and stored upside down to prevent precipitation accumulation) rn. For any exterior ASTs, as well as drums, barrels, tanks, and similar containers ❑ Yes NIA stored outside, has the facility had any releases in the past three (3) years? 13) Above Ground Storage Tanks (ASTs): If you answer "No"to any of the following items, you are not eligible for the no exposure exclusion. a.Are exterior AST§or piping free of rust, damaged or weathered coating, pits, or ❑ Yes ❑ No Eo /A deterioration, or evidence of leaks? b. Is secondary containment provided for all exterior ASTs? If so, is it free of any ❑ Yes ❑ No i? A cracks, holes, or evidence of leaks, and are drain valves maintained locked shut? Page 3 of 7 SWU-NE-021309 Last revised 2/1 312 0 0 9 NCGNEOOOO No Exposure Certification 14) Secondary Containment: If you answer "No" to any of the following items,you are not eligible for the no exposure exclusion. / a. Is secondary containment provided for single above ground storage containers ❑ Yes ❑ No tj-K/A (including drums, barrels, etc.)with a capacity of more than 660-gallons? b. Is secondary containment provided for above ground storage containers stored ❑ Yes ❑ No in close proximity to each other with a combined capacity of more than 1,320- gallons? �� c. Is secondary containment provided for Title III Section 313 Superfund ❑ Yes ❑ No eITA Amendments and Reauthorization Act (SARA) water priority chemicals*? d. Is secondary containment provided for hazardous substances'"designated in 40 ❑ Yes ❑ No "/A CFR §116? e. Are release valves on all secondary containment structures locked? ❑ Yes ❑ No /A 15) Hazardous Waste:. a. is this facility a Hazardous Waste Treatment, Storage, or Disposal Facility? ❑ Yes Imo ❑ NIA b. Is this facility a Small Quantity Generator (less than 1000 kg. of hazardous waste ❑ Yes o ❑ NIA generated per month) of hazardous waste? c. Is this facility a Large Quantity Generator (1000 kg. or more of hazardous waste ❑ Yes P-K-0 ❑ NIA generated per month) of hazardous waste? If you answered yes to questions b. or c., please provide the following information: Type(s) of waste: How is material stored: Where is material stored: How many disposal shipments per year: Name of transport/disposal vendor: Vendor address: Footnotes to Questions 14) c. & d. *Note that amounts below the 660-gallon (single) and 1,320-gallon (combined) bulk storage minimums require secondary containment. However, some exceptions may be made for de minimis amounts of certain substances, and/or other qualifiers, as described in the exemptions from reporting requirements of Title III SARA 313 in 40 CFR §372.38. .**Note that amounts below the 660-gallon (single) and 1,320-gallon (combired),bulk storage minimums require secondary containment. However, some exceptions may be made for amounts less than the Reportable Quantities of the hazardous substances listed in 40 CFR §117.3. _ _ Page 4 of 7 . _ _ , SWO-NE-021309 - Last revised 2/1 312 0 09 ` e NCGNEOOOO No Exposure Certification 16) other information: If you answer "Yes"to any of the following items, you might not be eligible for the no exposure exclusion. A more in-depth evaluation of the site circumstances may be required. a. Does your facility store used, recycled, or otherwise reclaimed pallets outside? ❑ Yes R o ❑ NIA b. Does your facility have coal piles on site? ❑ Yes ioldo�❑ NIA c, Does your facility store other fuel sources outside in piles, such as wood chips, Li �N Yes o ❑ N/A sawdust, etc.? d. Does your facility have air emissions associated with its industrial activity(e.g., B< I] No ❑ NIA degreasing operations, plati g, p intifng an met I finishing)? If-so, describe th / industrial activity: � y�E 1t ; e. If you answered yes to d;, are those emissions permitted by an Air Quality Permit? 21'es ❑ No ❑ NIA Please specify: _:it 0914S942 f. Please list any other environmental program permits (federal, state, etc.) not specified earlier in this application (such as Hazardous Waste Permits, etc.): Permit: Program: Permit: Program: Permit: Program: Permit: Program: Permit: Program: Permit: Program: Permit: Program: 5a ( 1 i 4- Lue � r &tn r,4 rv� �,, Page 5 of 7 SWU-NE-021309 Last revised 2/13/2009 NCGNE0000 No Exposure Certification 17) Certification: I certify under penalty of law that I have read and understand the eligibility requirements for claiming a condition of"no exposure"and obtaining an exclusion from NPDES stormwater permitting. I certify under penalty of law that there are no discharges of stormwater contaminated by exposure to industrial activities or materials from the industrial facility or site identified in this document (except as allowed under 40 GFR 1 22.26(g)(2)). I understand that I am obligated to submit a no exposure certification form once eve five 5 ears to the North Carolina Division of Water Quality and, if requested,to the operator of the local municipal separate storm sewer system (MS4) into which the facility discharges (where applicable). I understand that I must allow the North Carolina Division of Water Quality,or MS4 operator where the discharge is into the local MS4,to perform inspections to confirm the condition of no exposure and to make such inspection reports publicly available upon request. In the event that the site no longer qualifies for a No Exposure Exclusion, i understand that I must obtain coverage under an NPDES permit prior to any point source discharge of stormwater from the facility.Additionally, I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gathered and evaluated the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information,the information submitted is to the best-of my knowledge and belief true, accurate and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations. I certify that I am familiar with the information contained in this application and that to the best of my knowledge and belief such information is true,complete, and accurate. Printed Name of Person Signing: �f i �` t4ct f—f i �&-r-\ Title: I / b I (Signa ure of Applicant) (Date Signed) c �z0 Please note: This application for the No Exposure Exclusion is subject to approval by the NCDENR Regional Office prior to issuance. The Regional Office may inspect your facility for compliance with no exposure conditions prior to that approval. The Regional Office may also inspect your facility at any time in the future for compliance with the No Exposure Exclusion. North Carolina General Statute 143-215.6 B(i) provides that: Any person who knowingly makes any false statement,representation,or certification in any application,record,report,plan,or other document filed or required to be maintained under this Article or a rule implementing this Article;or who knowingly makes a false statement of a material fact in a rulemaking proceeding or contested case under this Article;or who falsifies,tampers with,or knowingly renders inaccurate any recording or monitoring device or method required to be operated or maintained under this Article or rules of the [Environmental Management]Commission implementing this Article shall be guilty of a Class 2 misdemeanor which may include a fine not to exceed ten thousand dollars($10,000). There is currently no fee for a No Exposure Exclusion. Page 6 of 7 SWU-NE-021309 Last revised 2/1 312 0 0 9 . NCGNE0000 No Exposure Certification Final Checklist This application should include'the following items: 0-f This completed application and all supporting documentation. Cif A map with the location of the facility clearly marked. El If this is a renewal, indicated current NCGNE number in Question 7. © If the site currently has an NPRES.Stormwater Permit, be sure to indicate the permit number in Question 8. Mail the entire package to: Stormwater Permitting Unit Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-1617 Note The submission of this document does not guarantee the issuance of a No Exposure Exclusion. For questions,please contact the DWO Regional Office for your area. dWQ Regional Office Contact Information: �....Asheville Office ...... (828) 296-4500 - l � Fayetteville Office ... (910) 433-3300 Mooresville Office ... (704) 663-1699 aY Raleigh Office ........ (919) 791-4200 Washington Office ... 252 946-6481 Wilmington Office O€fice ... (910) 796-7215 Winston-Salem ...... (336) 771-5000F ett�'lte >: . .. 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Sre t -..3 i /tts F• . t t5', .: �T ai '.: S v ,G i .4 ;r , r S?.t1}}1E�rtCd .fir,r'7 - �' : 5• S r §k, ���-� CJ'�" ..P c'�s ,•�- ;� a J Sts �k��,.. �"+ 4e �- � x;.,��5 Google Map;data 02009 Google http://maps.google.com/maps?f=q&source=s_q&hl=en&geoeode=&q=3804+comanche+... 12/30/2009 <=>rnamentalO mouldings www.cmamental.com Eric Harrison, VP,rVorth American Afa►tufacturing P.Q. Box 4068 3804 Comanche Road Archdale,NC 27263 Telephone Number 336-431-9120 x3015 Cell 336-210-2759 Fax Number 336-431-9104 E-mail. eharrison@ornamental.com ornamental.com December 20, 2010 Mr. Cory Larsen Environmental Engineer NCDENR—DWQ—Stormwater Permitting Unit 1617 Mail Service Center Raleigh,NC 27699-1 6 1 7 Cory, Thanks for the feedback on the requested information. I am requesting a receipt so that we don't encounter the same issue again. Will we receive any notification before an inspection is done and if any preparation is needed? I don't know if we have any issues or not but don't want to waste the NCDENR's time if there is any preparation needed. Thank you sincerely Eric Harrison O^ VP,North American Mfg. C� • O 219 6 Ornamental Mouldings LLC, P.O.Box 4068, 3804 Comanche Road,Archdale,NC 27263 Eric Harrison From: Larsen, Cory [cory.larsen@ncdenr.gov] Sent: Wednesday, December 15, 2010 8AS AM To: Eric Harrison Subject: RE: stormwater permit exemption You can just send what you have on hand with a cover letter stating your previous submission that cannot be located. That will be sufficient. From: Eric Harrison [mailto:eharrison@ornamental.com] Sent: Tuesday, December 14, 2010 4:29 PM To: Larsen, Cory Subject: RE: stormwater permit exemption Correct, Ornamental Products is one of cur facilities also. I'll be back at the facility where the No Exposure Certificctie:l app is filed in the morning and will send another copy... does it need to be an original with current dates on it(I mailed the original last year) or should I just submit the copy I have on file? Thanks for your help. Eric Harrison From: Larsen, Cory [mailto:cory.larsen@ncdenr.gov] Sent: Tuesday, December 14, 2010 3:53 PM To: Eric Harrison Subject: RE: stormwater permit exemption Eric, I believe you are describing a No Exposure Certification application and from our database, I cannot find a facility or permit associated with Ornamental Mouldings. I found an Ornamental Products in Hickory but nothing for the facility in Archdale. Where did you send the application originally? It may not have been routed to the central office but if you still have the paperwork and would like to reapply,you can send it to me and I will get the process started. Cory Larsen f 1 nvironmental_Engineer �NCDENR I DWQ I Stormwater Permitting Unit s 1617 Mail Service Center, Raleigh, NC 27699-1617 51 L'•IV. 5allsUu1� .]l, Glv.ly_, 11 1. L/VV f Phone: (919) 807-6365 Fax: (919) 807-6494 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: Eric Harrison [mailto:eharrison@ornamental.com] Sent: Tuesday, December 14, 2010 3:44 PM To: Larsen, Cory Subject: stormwater permit exemption Good afternoon Sir. I got your contact information from Jenny Graznak out of the Winston Salem office. We submitted a permit exemption for our Archdale facility (Ornamental Mouldings, LLC-3804 Comanche Rd,Archdale, NC 27263) in December, 2009. 1 did not request a receipt notice since it was not time sensitive. I have a friend that works in water quality in Winston and he told me about 6 months ago it probably is just delayed due to the load. That is no problem i