NCGNE0990_COMPLETE FILE - HISTORICAL_20140228

STORMWATER DIVISION CODING SHEET
NCG PERMITS
PERMIT NO. /VC&N � D /��jQ
DOC TYPE L7' HISTORICAL FILE
❑ MONITORING REPORTS
DOC DATE o 00H p aag
YYYYMMDD

Al
Awl
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Energy, Mineral, and Land Resources
Land Quality Section
Tracy E. Davis, PE, CPM Pat McCrory, Governor
Director John E. Skvarla, III, Secretary
February 28, 2014
Allen Vestal
Wright Global Graphic Solutions;
P.O. Box 1069
Thomasville, NC 27360
Subject: No Exposure Certification NCGNE0990
Rescission of Permit NCG170014
Wright of Thomasville
Randolph County
Dear Mr. Vestal:
The Division has reviewed your submittal of the application for No Exposure Certification requesting exclusion from
NPDES stormwater permitting at Wright of Thomasville. Based on your submittal of a signed certification of no exposure
and on inspection by Aana Taylor-Smith on January 31, 2014', the Division is granting conditional exclusion from
permitting as provided for under40 CFR 122.26(g), which is incorporated by reference in North Carolina regulations. We
are also hereby rescinding your current permit Certificate of Coverage, NCG170014.
Please note that by our acceptance of your No Exposure Certification, Wright of Thomasville is obligated to maintain no
exposure conditions at this facility. If conditions change such that the facility no longer qualifies for no exposure exclusion,
you are obligated to immediately obtain NPDES permit coverage for any stormwater discharge. Otherwise, the discharge
becomes subject to enforcement as unpermitted discharge.
Wright of Thomasville must recertify the no exposure status annually using the included form. Any "yes" answer would
require that you obtain NPDES permit coverage for stormwater discharge from the facility. The annual self-
recertification form does not need to be submitted to DEMLR, unless requested. Please note that this 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 Aana Taylor-Smith or me at(336) 771-5000.
Sincerely,
Matthew E. Gantt, PE
Regional Engineer
Land Quality Section
Enclosures:
1. Annual Self-Recertification Form
CC: Stormwater Permitting Unit—No Exposure Files
Central Files - DWR
VI SRO Files— Land Quality
Winston-Salem Regional Office
585 Waughtown Street, Winston-Salem, NC 27101 a Phone: [phone] FAX: [phone]

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1-OR AGENCY USEON LY
* Date Received
Division of Water Quality 1 Surface Water Protection Ye;,, I ,,,,,,,,, I D;,y
oa 107
NC®ENR National Pollutant Discharge Elimination System ceniricaleolc }crage
N �
c .: �.......Z, NO EXPOSURE CERTIFICATION for Exclusion RECEIVED
avNr.,,v�r.HEN.rtr-.n.x.s
NCGNE0000 N.C.[Dept,of ENR
FEE 9 3 90K
NO EXPOSURE CERTIFICATION
Winston-Salem
National Pollutant Discharge Elimination System application for exclusion from a Stormwater,EPerm&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, DWO 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 self re-certify your No Exposure Exclusion annually.
For questions,please contact the DWQ Regional Office for your area. (See page 6)
(Please print or type)
1) Mailing address of ownerloperator(address to which all certification correspondence will be mailed):
Name 1n/r ,'ahT GrJD A I C-rA h: c S61U-DoNS
Contact
Street Address _0. BOX
City r h qM AS 1/r /I 0­ State ZIP Coe +�
Telephone No. 3 G - Fax: `
Email C 0 A�
Page 1 of 7
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SWU-NE-12Aug2010
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NCGNE0000 No Exposure Certification
2) Location of facility producing discharge:
Facility Name —\t r; o h T Ong r WA(S
Facility Contact dAlle V_S T
Facility Street Address S ( 5 �
City State_,N(__ZIP Code
County
Telephone No. 2 3 G --L Fax: _33 L_ -
Email. C-0 Af
F. �
3) Physical location information:
Please provide a narrative description of how to get to the facility(use street names, state road numbers, and
distance and direction from a roadway intersection).
_roc k?.4 j'Nq uAt 1. T .
(A copy of a map with theqacility clearly located on it should be incluu d with the certification application.)
4) Is the facility located on Native AmericZN
ands? ❑ Yes R No
5) Is this a Federal facility? ❑ Yes
6) Latitude �o 1 3 Longitude 0.Oq/2-3.3 (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
YExisting Date operation began I q
© Renewal of existing No Exposure Certification Certification No.: NCGNE
8) Was this facility or site ever covered under an NPDES Stormwater Permit? VYes ❑ No
If yes, what is the NPDES Permit Number?_fi cs' 170'q
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:411
10) Pr vide a brief description of the types of industrial activities and roducts produced at this facility:
vide
0 � �InML icrn��'S1� �`n .
11) Does this facility have any Non-Discharge permits(ex: recycle permits)?
C�"N o
❑ Yes
If yes, list the permit numbers for all current Non-Discharge permits for this facility:
Page 2 of 7
SWU-NE-12Aug2010

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 V Na
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 ICJ No
c. Materials or products from past industrial activity ❑ Yes M No
d. Material handling equipment (except adequately maintained vehicles) ❑ Yes W//No
e. Materials or products during loading/unloading or transporting activities ❑ Yes Q No
f.-Materials or products stored outdoors (except final products intended for outside ❑ Yes t/No
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 ® Na
and similar containers
h. Materials or products handled/stored on roads or railways owned or maintained by ❑ Yes f(N0
the discharger
i. Waste material (except waste in covered, non-leaking containers [e.g., dumpsters]) ❑ Yes f/No
j. Application or disposal of process wastewater (unless otherwise permitted) ❑ Yes CQ Na
k_ Particulate matter or visible deposits of residuals from roof stacks and/or vents not ❑ Yes M/N0
otherwise regulated (i.e., under an air quality control permit) and evident in the
stormwater outflow /
I. Empty containers that previously contained materials that are not properly stored ❑ Yes R No
(i.e., not closed and stored upside down to prevent precipitation accumulation)
m. For any exterior ASTs, as well as drums, barrels, tanks, and similar containers ❑ Yes 0"No
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 ASTs and piping free of rust, damaged or weathered coating, pits, or ❑ Yes ❑ No Tr NIA
deterioration, or evidence of leaks? /
b. Is secondary containment provided for all exterior ASTs? If so, is it free of any Li Yes Li No NIA
cracks, holes, or evidence of leaks, and are drain valves maintained locked shut?
Page 3 of 7
5WU-NE-12Aug2010

NCGNE0000 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 all single above ground storage ❑ Yes ❑ No 4 N/A
containers (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/A
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 0 No t/NIA
Amendments and Reauthorization Act(SARA)water priority chemicals'?
d. Is secondary containment provided for hazardous substances— designated in 40 ❑ Yes ❑ No 9/N/A
CFR §116?
e. Are release valves on all secondary containment structures locked? ❑ Yes ❑ No I(N/A
15) Hazardous Waste-
a.
a. Is this facility a Hazardous Waste Treatment, Storage, or Disposal Facility? ❑ Yes [/No
b. Is this facility a Small Quantity Generator (less than 1000 kg. of hazardous waste 6d Yes ❑ No
generated per month) of hazardous waste?
c. Is this facility a Large Quantity Generator(1000 kg. or more of hazardous waste ❑ Yes t/No
generated per month) of hazardous waste?
If you answered yes to questions b. or c., please provide the following information:
Type(s) of waste: IN K
How is material stored: 1 Al
Where is material stored: / e
How many disposal shipments per year:
Name of transport 1 disposal vendor:
Vendor address: d Ll
A ec jA d I,-,_ AIL, _2y),UN
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 (combined) 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.
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NCGNE0000 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 reqZo
.
a. Does your facility store used, recycled, or otherwise reclaimed pallets outside? ❑ Yes
b" Does your facility have coal piles on site? ❑ Yes /NO
c. Does your facility store other fuel sources outside in piles, such as wood chips, ❑ Yes i1 No
sawdust, etc.?
d. Does your facility have air emissions associated with its industrial activity(e.g., ❑ Yes No
degreasing operations, plating, painting and metal finishing)? If so, describe the
industrial activity:
e" If you answered yes to d., are those emissions permitted by an Air{duality Permit? ❑ Yes ❑ No VN/A
Please specify:
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:
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NCGNE0000 No Exposure Certification
17) Certification:
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.
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 CFR 122.26(g)(2)).
I understand that I am obligated to annually self re-certifv No Exposure and, if requested, submit the re-certification to
DWQ or 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 Duality,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. r
Printed Name of Person Signing:�A l l e-N Ves—r.4f
Title:
^
(Signature of Applicant) (Date Signed)
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 Genera[ 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 tiled 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 of 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.
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S W U-N E-12Aug2010

NCGNE0000 No Exposure Certification
Final Checklist
This application should include the following items:
This completed application and all supporting documentation.
J/ A map with the location of the facility clearly marked.
® If the site currently has an NPDES 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 DWQ Regional Office for your area.
DWQ Regional Office Contact Information:
Win ala
Asheville Office ...... [phone]
Fayetteville Office ... [phone] °! ;
1699 Mooresville Office ... (704) 663
_.3.
Raleigh Office ........ [phone]PO
Washington Office ...[phone] 1 le!
Wilmington Office ... [phone]
Winston-Salem ...... [phone]
Central Office .........[phone]
!:Wil noton
J
Page 7 of 7
SWU-NE-12Aug2010

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MCDEN i V
North Carolina Department of Environment and Natural Resources
Division of Energy, Mineral, and Land Resources
Land Quality Section
Tracy E. Davis, PE, CPM Pat McCrory, Governor
Director John E, Skvarla, III, Secretary
31 January 2014.
Mr. Allen Vestal
Wright of Thomasville
P.O. Box 1069
Thomasville, NC 27361
Subject: Compliance Evaluation Inspection
NPDES General Stormwater Permit NCG170000
Certificate of Coverage NCG170014
Wright of Thomasville
Randolph County
Dear Mr.Vestal:
Aana Taylor-Smith of the Winston-Salem Regional Office of the NC Division of Energy, Mineral, and Land
Resources(DEMLR) conducted a compliance evaluation inspection at the subject facility on 31 January
2014.Your assistance and cooperation were greatly appreciated. An inspection checklist is attached for
your records and the inspection findings are summarized below.
This facility is located at 5115 Prospect Street in Thomasville, Randolph County, North Carolina.
Stormwater related to industrial activity is discharged from the site to an unnamed tributary to the
Hunts Fork, Class C waters in the Yadkin-Pee Dee River Basin.
Documentation & Monitoring Review
The facility's Stormwater Pollution Prevention Plan (SPPP)was found to be incomplete. However, as was
noted in the previous inspection conducted November 6, 2008,this facility qualifies for No Exposure
Certification (NEC).The facility submitted an application for NEC in 2007, but it was never acted upon in
Raleigh. That situation was also noted in the previous insp'ection..The facility has been advised to
reapply for NEC and has been determined to be in compliance, as they were never informed of the
status of their previous application. Please find a copy of the NEC application attached to this letter.
Additionally, Wright of Thomasville currently holds a NCG170000 Permit for Textile Mills. However,the
facility's primary industrial activity is printing.The correct NPDES General Stormwater Permit for this
facility would be the NCG050000 permit for Apparel, Printing, Leather, and Rubber if the industry should
need to reapply for a NPDES General Stormwater Permit in the future.
Qualitative monitoring has been completed as required. Records were complete and very thorough.
Analytical monitoring is not required because this facility does not perform on-site vehicle maintenance.
The facility has two Stormwater Discharge Outfalls (SDOs)that discharge stormwater related to
industrial activity, but mainly from roof drains and parking lot areas.
Winston-Salem Regional Office
585 Waughtown Street,Winston-Salem, NC 27101 . Phone: [phone] I FAX:[phone]

Wright of Thomasville a
01/31/2014
Page 2 of 2
! Site Review
The facility is clean and well maintained. Secondary containment is implemented as required. Both
outfalls were inspected and were found to be in good order. No evidence of erosion or instability at the
SDOs was observed.
We appreciate your efforts to comply with the stormwater permit and minimize exposure of industrial
activity to stormwater. No additional response to this letter is required. Should you have any questions
regarding the NCG170000 permit, No Exposure Certification, or this inspection, please do not hesitate to
1
contact Ms. Taylor-Smith or me at [phone].
Sincere)
� Y,
f
Matthew E. Gantt, PE
Regional Engineer
Land Quality Section
i
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Enclosures: BIMS Inspection Checklist
No Exposure Certification Application
cc: Central Files
WSRO/LQ

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` Compliance Inspection Report
Permit: NCG170014 Effective: 08/01/09 Expiration: 07/31/14 Owner: Wright Of Thomasville Inc
SOC: Effective: Expiration: Facility: Wright Of Thomasville Inc
County: Randolph 5115 Prospect St Extension
i
Region: Winston-Salem
Thomasville NC 27360
Contact Person: Allen Vestal Title: Phone: [phone]
3
Directions to Facility:
i
I System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
I
On-Site Representative(s):
Related Permits:
Inspection Date: 01131/2014 Entry Time: 09:30 AM Exit Time: 10:00 AM
Primary Inspector: Aana Taylor-Smith Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Textile Mill Products Stormwater Discharge COC
Facility Status: ® Compliant D Not Compliant
Question Areas:
®Storm Water
(See attachment summary)
Page: 1

}
Permit: NCG170014 Owner-Facility: Wright Of Thomasville Inc
i Inspection Date: 01/31/2014 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection summary:
It was determined during the inspection that the facility qualifies for a No Exposure Certification. A NEC application was
filed in 2007 and never acted on by Raleigh staff. This situation was noted in the last inspection report, conducted in 2008.
The facility has been advised to reapply for NEC and has been determined to be in compliance, as they were not
i
informed of the status of their previous application.
The facility does not have the correct permit, as their main industrial activity is commercial printing. No textile
9 manufacturing occurs at this facility. That being said, the facility qualifies for No Exposure Certification and will apply for
NEC.
1
€ Please refer to attached inspection letter.
II
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Permit: NCG170014 Owner-Facility: Wright Of Thomasville Inc
Inspection Date: 01/31/2014 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Stormwater Pollution Prevention Plan Yes No NA NE
Does the site have a Stormwater Pollution Prevention Plan? ® n n n
#Does the Plan include a General Location (LISGS)map? ® n n n
#Does the Plan include a "Narrative Description of Practices"? n n e n
#Does the Plan include a detailed site map including outfall locations and drainage areas? ■ n ❑ n
#Does the Plan include a list of significant spills occurring during the past 3 years? f=l n ® n
#Has the facility evaluated feasible alternatives to current practices? n n ® n
#Does the facility provide all necessary secondary containment? ❑ n ® n
#Does the Plan include a BMP summary? ■ n n 11
#Does the Plan include a Spill Prevention and Response Plan (SPRP)? Q Q ® n
#Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? n n ® n
#Does the facility provide and document Employee Training? n n ® n
#Does the Plan include a list of Responsible Party(s)? n n ® n
# Is the Plan reviewed and updated annually? 0 0 ❑ n
#Does the Plan include a Stormwater Facility Inspection Program? n n ® n
Has the Stormwater Pollution Prevention Plan been implemented? ® n n n
Comment: The SP3 was missing several elements, however it was determined during
the inspection that the facility qualifies for a No Exposure Certification. A NEC
application was filed in 2007 and never acted on by Raleigh staff. This situation was
noted in the last inspection report, conducted in 2008. The facility has been advised to
reapply for NEC and has been determined to be in compliance, as they were not
informed of the status of their previous application.
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? ® n n n
Comment: Qualitative monitoring has been performed as required at both outfalls and
thorough records were available for inspection.
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? n n
#Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? n ❑ ® n
Comment: No vehicle maintenance occurs on-site - analytical monitoring not required.
Permit and Outfalls Yes No NA NE
#Is a copy of the Permit and the Certificate of Coverage available at the site? ® ❑ n n
Page: 3

' Permit: NCG170014 Owner-Facility: Wright Of Thomasville Inc
Inspection Date: 01/31/2014 Inspection Type: Compliance Evaluation Reason for Visit: Routine
E
#Were all outfalls observed during the inspection? ® n 0 0
#If the facility has representative outfall status, is it properly documented by the Division?
I
#Has the facility evaluated all illicit(non stormwater)discharges? n n
i
Comment: The facility has two outfalls, both of which convey stormwater from the roof.
f The facility does not have the correct permit, as their main industrial activity is
commercial printing. No textile manufacturing occurs at this facility. That being said, the
t facility qualifies for No Exposure Certification and will apply for NEC.
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FNXFEB
SCEIVED '
'eot.ofENR
NCD NR 2 4 2009
North Carolina Department of Environment and Natural Resources Reg'onalSaloOff e
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
February 20, 2009
Mr. Allen Vestal
Wright of Thomasville
P.O. Box 1069
Thomasville, NC 27361
Subject: No-Exposure Certification NCGNE0470
Application Withdrawal
Wright of Thomasville
5115 Prospect Street, Thomasville, NC
Randolph County
Dear Mr. Vestal:
The Division has reviewed your submittal of the No Exposure Certification for Exclusion from NPDES
Stormwater Permitting form, which we received on October 10, 2007. Because of a long backlog, we were
unable to conclude this request before now and apologize for the delay.
We understand from the Winston-Salem Regional Office that your facility is no longer eligible for No-Exposure
Certification because of recent changes in storage practices. Therefore we will not process your application
any further. Please continue to operate under the General Permit NCG170000 (Certificate of Coverage No.
NCG 170014).
If you have any questions or need further information, please contact Bethany Georgoulias at(919)807-6372,
or through email at [e-mail].
Sincerely,
for Co een H. Sullins
cc: Winston-Salem Regional Office—Mike Mickey
Stormwater Permitting Unit Files/ NCG170014
Wetlands and Stormwater Branch e
1617 Mail Service Center,Raleigh,North Carolina 27699-1617
Location:512 N.Salisbury St.Raleigh,North Carolina 27604 One
Phone:[phone] a FAX:[phone]\Customer Service:1-877-623-6748 na
Internet:www.ncwaterquality.org NorthCaroli
l i
An Equal opportunity 1 Affirmative Action Employer

o�oF W William
F.Easley,Governor
William G. Ross Jr.,Secretary
North Carolina Department of Environment and Natural Resources
p Coleen H.Sullins,Director
Division of Water Quality
November 7, 2008
Mr. Allen Vestal
Wright of Thomasville
P.O. Box 1069
Thomasville, NC 27361
Subject: General Stormwater Permit Inspection
Wright of Thomasville
Certificate of Coverage # NCG170014
Randolph County
Dear Mr. Vestal:
On November 6, 2008, Mike Mickey of this office met with you in response to the "No
Exposure Certification" form (NOE) submitted to our Division for the Wright of Thomasville
facility .located on Prospect Street. To qualify for the NOE, all industrial materials and
operations would have to be.protected from exposure to stormwater. The exemption would
exclude Wright of Thomasville from having to hold the above certificate of coverage for a
stormwater discharge.
Observations at the facility revealed that the certification could be granted provided
that the few pallets stored outside of the building were moved inside. You indicated that they .
would be moved inside this week. Based on this information, we will recommend to our
central office in Raleigh that the NOE be granted. You will receive official notification by
separate letter.
During the site visit a General Stormwater Permit Inspection was also performed. This
inspection evaluated the five (5) areas as designated on the attached inspection form.
Observations from each area are addressed below:
1. Permit
Wright of Thomaville holds Certificate of Coverage # NCG170014 for the discharge of .
stormwater from the facility. The General Permit became effective August 1, 2004 and
expires July 31, 2009.
2. Records/Reports
Part II, Section A of the permit requires the development of a Stormwater Pollution
Prevention Plan (SPPP). To date, no plan has been developed. However, the previous
inspection letter dated 9/26/07 advised that this requirement would be waived once the NOE
is granted.
ooc Nz Carolina
�Nutura!!y
North Carolina Division of Water Quality 585 Waughtown Street Winston Salem,NC 27107 Phone[phone] Customer Service
Internet www.ncwaler uali .or FAX [phone] 1-877-623-6748
An Equal Opportunity/Affirmative Action Employer—50%Recycled110%Post Consumer Paper

Mr.Allen Vestal
Page#2
November 7, 24a7
3. Facility Site Review
Observations at the facility did not reveal any concerns, except for the pallet issue already
addressed. The site appeared clean and well managed.
4. Effluent/Receiving Waters
Stormwater runoff from the facility reaches Hunts Fork Creek, Class °C" waters in the Yadkin-
Pee Dee River Basin,
5. Monitoring Program
Part ll, Section B of the permit requires that semi-annual qualitative (visual) monitoring be
performed and documented once in the spring (April - June) and once in the fall (September
— November). A review of the facility files found that the only documented monitoring
occurred on 4/25/07. Again, the NOE will waive this requirement. The analytical monitoring
for on-site vehicle maintenance listed in Section C of the permit is not required since Wright
of Thomasville uses less than 55 gallons of new motor oil per month when averaged over the
calendar year.
Should you have any questions concerning this letter, please contact Mike Mickey or
me at [phone].
Sincerely,
Steve W. Tedder
Water Quality Regional Supervisor
cc: NPS Assistance and Compliance Oversight Unit
Central Files — SWP
WSRO

Permit: NCG170014 owner-Facility: Wight Of Thomasville Inc
Inspection pate: 1110612008 Inspection Type: Stormwater Reason for Visit: Routine
Stormwater Pollution Prevention Plan Yes No NA NE
Does the site have a Stormwater Pollution Prevention Plan? n M n n
#Does the Plan include a General Location(USGS) map? n ® n Cl
#Does the Plan include a"Narrative Description of Practices"? n ® n n
#Does the Plan include a detailed site map including outfall locations and drainage areas? n n n
#Does the Plan include a list of significant spills occurring during the past 3 years? Q ® n n
#Has the facility evaluated feasible alternatives to current practices? ❑ ® ❑ n
#Does the facility provide all necessary secondary containment? n ® n ❑
#Does the Plan include a BMP summary? n ® n n
#Does the Plan include a Spill Prevention and Response Plan(SPRP)? n ® n n
#Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? ❑ ® n Cl
#Does the facility provide and.document Employee Training? ❑ ® n n
# Does the Man include a list of Responsible Party(s)? n ® ❑ n
# Is the Plan reviewed and:updated annually? ❑ ® n
#Does the Plan include a Stormwater Facility Inspection Program? ❑ ® ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented? n S n n
Comment: No SPPP has been prepared. The previous inspection letter (dated
9/26/07) advised the facility to submit a NOE, which would waive the SPPP
requirement. The NOE form was submitted to Raleigh on 10/10/07, where it sat for over
a year. This inspection was conducted to confirm that the NOE could be issued.
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? ® n n n
Comment: Only one visual monitoring event has been conducted (4/25/07). In
regards to the analytical monitoring, the facility uses less than 55 gallons of new motor
oil per month so the on-site vehicle maintenance monitoring in Part II. Section (C) is not .
required.
Permit and Outfalls Yes No NA NE
#is a copy of the Permit and the Certificate of Coverage available at the site? ® n n n
#Were all outfalls observed during the inspection? ® n n n
# If the facility has representative outfall status, is it properly documented by the Division? n n M n
#Has the facility evaluated all illicit(non stormwater)discharges? ® n n n
Page: 3

Permit: NCG170014 Owner-Facility:Wright Of Thomasville Inc
Inspection Date: 11/06/2008 Inspection Type: Stormwater Reason for Visit:Routine
Comment: The only concern noted during the site visit involved the few pallets stored
outside against the building. A "no exposure exemption" cannot be granted if pallets
are stored outside. Allen Vestal said that they would be moved inside to remedy this
problem. All other areas met the exemption (the two dumpsters were covered as was
the 55 gallon drum storage area). The outside areas were neat and clean.
Page: 4

FOIE AGENCY USE ONLY
Division of Water Quality/ Surface Water Protection Datc 0.1h eJ
Q •d Y"ear Momh Dav
01 j to# I Io
�'®��� National Pollutant Discharge Elimination System eertscalen cavmage
NC 0 '7D
11p+t.+ anE --Df -EmO NO EXPOSURE CERTIFICATION for Exclusion
E-.+wa...--D N.Q -RESOD n Z,nJ CeV�St��.l
NCGNE4044
NO EXPOSURE CERTIFICATION
R
National Pollutant Discharge Elimination System application for exclusion from a Stormw r Per
based on NO EXPOSURE:
Y.
Submission of this No Exposure Certification constitutes notice that your facility does not re , erm
authorization for its stormwater discharges associated with industrial activity in the State of
Carolina because it qualifies fora no exposure exclusion. A condition of no exposure at an ind _-D ` \ .
facility means all industrial materials and activities are protected by a storm resistant shelter(wi e
exceptions) to prevent exposure to rain, snow,snowmelt,and/or runoff.
Industrial materials or activities include, but are not limited to:"material-handling equipment or-zcti ;
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 of40 CFR 1122.26(g).
You are required to reapply for the No Exposure Exclusion once every five (5)years.
For-questions,please contact the DWQ Regional Office for your area. (See page 5)
(Please-print or type)
1) Mailing address of owner/operator(address to which all certification correspondence will be mailed):
Name V i
Street Address
City State N.C. ZIP Code
Telephone No, Fax:
2) Location of facility producing discharge:
Facility Name _ 11r� DG _T o.PI A 5 41 e
Facility Contact Al I a Ly c5 % �d
Street Address C IT T
City - State /\L.C__. ZIP Code
County
Telephone iYlo. Fax:
Page 1 of 5
SWU-NE-060607 Last revised 06/06/07

NCGNE0000 No Exposure Certification
3) Physical location information:
Please provide a narrative description of how to get to the faciiit use street names, state road numbers, and
dis nce and dir ction from a roadway intersection). B e c
(A copy of a map with the facility clearly sated on it should be include vuith the certifi(gion application.)
4) Is the facility located on Native American Lands?❑ Yes l//No
5) Is this a Federal facility? ❑ Yes O/N0
6) Latitude J� Longitude (deg, ruin, sec)
7) This NPDES Permit Application applies to which of the following:
❑/New or Proposed Facility Date operation is to begin
Existing Hate operation began /
8) Was this facility or site ever covered under an NPDESStormwater Permit? ®Yes ElNo
If yes,what is the NPDES Permit Number? N tC C= 1 7 0 01 4
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) Provide a brief description of the types of,industrial activities and products produced at this facility:.
11) Does this facility have any Non-Discharge permits (ex: recycle.permits)?
1 No
❑ Yes
If yes,list the permit numbers for all current Non-Discharge permits for this facility:
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 If you answer"Yes"to any of these items, you are not
eligible for the no exposure exclusion.
- - - -- — a: Using, storng,-orcleaning-industri5l imachinery or equip'ment, and areas.where ❑ Yes Q No
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 l9'No
c. Materials or products from past industrial activity ❑ Yes_ l2/No
d. Material handling equipment(except adequately maintained vehicles) ❑ Yes lVNo
e. Materials or products during loading/unloading or transporting activities ❑ Yes CY/No
f. Materials or products stored outdoors (except final products intended for outside n Yes Q1 N0
use[e.g„ new cars]where exposure to stormwater does not result in the discharge
of pollutants) .
Page 2 of 5
SWU-NE-060607 Last revised 06/06/07

, r
'i
NCGNE0000 No Exposure Certification
g. Materials contained in open, deteriorated or leaking storage drums, barrels, tanks, ❑ Yes No
and similar containers /
h. Materials or products handled/stored on roads or railways owned or maintained by ❑ Yes ® N0
the discharger
i. Waste material (except waste in covered, non-leaking containers fe.g., dumpstersj) ❑ Yes 9'No
j. Application or disposal of process wastewater(unless otherwise permitted) 0 Yes 6l No
k. Particulate matter or visible deposits of residuals from roof stacks and/or vents not ❑ Yes JN 0
otherwise regulated(i.e., under an air quality control permit) and evident in the
stormwater outflow
I. Empty containers that previously contained materials that are not properly stored 0 Yes JNO
(i.e., not closed and stored upside down to prevent precipitation accumulation)
m. For any exterior ASTs, as well as drums, barrels, tanks, and similar containers ❑ Yes d No
stored outside, has the facility had any releases in the past three(3)years?
A� tk13) Above Ground Storage Tanks (ASTs): If you answer"No"to any of the following items, you are not
h► eligible for the no exposure exclusion.
a.Are exterior ASTs or piping free of rust, damaged or weathered coating, pits, or ❑ Yes ❑ No
deterioration, or evidence of leaks?
b. Is secondary containment provided for all exterior ASTs? If so,is it free of any ❑'Yes ❑ No
cracks, holes, or evidence of leaks, and are drain valves maintained locked shut?
,,,�1 NU) Secondary Containment: If you answer"No" to any of the following items, you are not eligible for the
1 no exposure exclusion.,
a. Is secondary containment provided for single above around storage containers © Yes ❑ No
(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. Are release valves on all secondary containment structures locked? ❑Yes ❑ No
Page 3 of 5
SWU-NE-060607 Last revised 06/06/07

NCGNE0000 No Exposure Certification
15) Hazardous Waste:
a. Is this facility a Hazardous Waste Treatment, Storage, or Disposal Facility? ❑ Yes IV No
b. Is this facility a Small Quantity Generator(less than 1000 kg. of hazardous waste iyes ❑ No
generated per month) of hazardous waste?
c. Is this facility a Large Quantity Generator(1000 kg. or more of hazardous waste ❑Yes 5 f/NO
generated per month) of hazardous waste?
If you answered yes to questions b. or c., please provide the following information:
Type(s)of waste: P OTT) De.0 tor Alit/ ;4Ti'[ AjApMAZ� 1JVd,^dce4rbaN5
How is material stored:
Where is material stored: C1_ Si ?� _
How many disposal shipments per year:
Name of transport/disposal.vendor: —
vendor address: 18 _D d M eN ,,N k a I _So d 0ul A Iv kJAI z Nf,
16) Certification:
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 CFR 122.26(g)(2)).
I understand that I am obligated to submit a no exposure certification form once every five(5)_years 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). t understand that 1 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. 1 '
Printed Name of Person Signing: _All e-N V_ t,�5 TA t _
Title:
- � - - - ,ram- -07
(Signature of Applicant) (Date Signed)
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.
Page 4 of 5
5WU-NE-060607 Last revised 06105/07

J
NCGNE0000 No Exposure Certification
North Carolina General Statute 143-215.6 B(l) 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 Articie;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(510,000),
There is currently no fee fora No Exposure Exclusion.
Final Checklist '
This"application should include the following items:
❑ This completed application and all supporting documentation.
❑ A map with the location of the facility clearly marked.
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 DWQ Regional Office for your area.
DWO—Rectional Office Contact Information:
Asheville Office ...... [phone] � `
Fayetteville Office ... [phone] f�+� •� ��1 r <' �,� ,�-��'..s�� Y „�, . �s_
Mooresville Office ... [phone]
Raleigh Office ........ [phone]
Washington Office ...[phone]
Wilmington Office ... (910).796-7215 �t ;� • - ,d'
Winston-Salem ...... [phone]
Central Office .........[phone]
n9tan
Page 5 of 5
SWU-NE-060607 Last revised 06/06/07

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http://\vww.mapquest.com/maps/print.adp?mapdata=UAmOU3b9NY 1 wDASvsNoZ%252f... 10/4/2007

r
W Ar, 9Q Michael F.Fasley,Governor
�0 G William G.Ross Jr.,Secretary
North Carolina Department of Environment and Natural Resources
0 Coleen H.Sullins,Director
Division of Water Quality
November 7, 2008
Mr. Allen Vestal
Wright of Thomasville
P.O. Box 1069
Thomasville, NC 27361
Subject: General Stormwater Permit Inspection
Wright of Thomasville
Certificate of Coverage # NCG170014
Randolph County
Dear Mr. Vestal:
On November 6, 2008, Mike Mickey of this office met with you in response to the "No
Exposure Certification" form (NOE) submitted to our Division.for the Wright of Thomasville
facility .located on Prospect Street. To qualify for the NOE, all industrial materials and
operations would have to be protected from exposure to stormwater. The exemption would
exclude Wright of Thomasville from having to hold the above certificate of coverage for a
stormwater discharge.
Observations at the facility revealed that the certification could be granted provided
that the few pallets stored outside of the building were moved inside. You indicated that they.
would be moved inside this week. Based on this information, we will recommend to our
central office in Raleigh that the NOE be granted. You will receive official notification by
separate letter.
During the site visit General Stormwater Permit Inspection was also performed. This
inspection evaluated the five (5) areas as designated on the attached inspection form.
Observations from each area are addressed below:
1. Permit
Wright of Thomaville holds Certificate of Coverage # NCG170014 for the discharge of
stormwater from the facility. The General Permit became effective August 1, 2004 and
expires .duly 31, 2009.
2. Records/Reports
Part 11, Section A of the permit requires the development of a Stormwater Pollution
Prevention Plan (SPPP). To date, no plan has been developed. However, the previous
inspection letter dated 9/26/07 advised that this requirement would be waived once the NOE
is granted.
NonhCarotina
�'�7CIt1l1'Qi!i!!f
North Carolina Division of Water Quality 585 Waughtown Street Winston Salem,NC 27107 Phone[phone] Customer Service
Internet www.ncwateLquality.orq FAX [phone] 1-877-623-6748
An Equal Opportunity/Affirmative Action Employer—50%Recycled110%Post Consumer Paper

Mr.Allen Vestal
Page#2
November 7,2007
3. Facility Site Review
Observations at the facility did not reveal, any concerns, except for the pallet issue already
addressed. The site appeared clean and well managed.
4. Effluent/Receiving Waters
Stormwater runoff from the facility reaches Hunts Fork Creek, Class "C" waters in the Yadkin-
Pee Dee River Basin.
5. Monitoring Program
Part 11, Section B of the permit requires that semi-annual qualitative (visual) monitoring be
performed and documented once in the spring (April - June) and once in the fall (September
— November). A review of- the facility files found that the only documented monitoring
occurred on 4/25/07. Again, the NOE will waive this requirement. The analytical monitoring
for on-site vehicle maintenance listed in Section C of the permit is not required since Wright
of Thomasville uses less than 55 gallons of new motor oil per month when averaged over the
calendar year.
Should you have any questions concerning this letter, please contact Mike Mickey or
me at [phone].
Sincerely,
Steve W. Tedder
Water Quality Regional Supervisor
cc: NPS Assistance and Compliance Oversight Unit
Central Files — SWP
WSRO

Re: [F�i-r?-'.1CGNE0470]
Subject: Re: [Fwd: NCGNE0470]
From: Bethany Georgoulias <[e-mail]>
Date: Wed, 18 Feb 2009 15:57.24 -0500
To: Sarah Young <Sarah,[e-mail]>
CC:[e-mail], Mike Mickey <[e-mail]>
Got it from the cabinet - I 'll take care of this one.
cheers,
bg
Sarah Young wrote:
Yes, I think that's the final result we want, but I think we should still send a
letter to that effect, so they know they need to continue to abide by their
permit. -sarah
Sarah M. Young
Wetlands and Stormwater Branch 1617 Mail Service Center
Raleigh, NC 27699-1617
Phone: (919) 807--6303
Fax: (919) 807-6494
Email : sarah.yo6ng@ncmail .net
Web site: htzp://h2o.enr.state.nc.us/ws/home.htm
**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. **
Bethany Georgoulias wrote:
Sarah,
I just called Jenny back on this today (at least I'm pretty sure it's the same
one - sounds like it) . I missed her but was going to talk more. However, if
they're under a stormwater permit that's still in place, it might be easier
just to withdraw the No Exposure request and stick with the way things are.
If no one' s picked this one up, I can put it in my queue to handle.
-Bg
Sarah Young wrote:
Please read email below. They first responded and told us to issue this one
and then sent this email today. 1 put it in the file, so please put
specific language in the letter to this effect. Thanks, Sarah
------------------------------------------------------------------------
Subject:
NCGNE0470
From:
Mike Mickey <[e-mail]>
Date:
Wed, 18 Feb 2009 15: 02:30 --0500
To:
Sarah Young <Sarah.Youn @ncmail.net>
To:
Sarah Young <[e-mail]>
CC:
Jenny Graznak <Jenn [e-mail]>
loft 2/19/2009 10:00AM

Re: [Fwd;-VCG;NE04?0]
Sarah - Wright of 'Thomasville has a no exposure request that BIMS says is
"in review" . WSRO previously recommended approval of the NOE since Wright
moved their pallets inside. However, Wright called today and said the
pallets need to go back outside. Can we stop the NOE and let them remain
under their existing stormwater permit? I know you said you were getting
ready to send the letters out soon. het me know what ye think. Thanks,
Mike.
Mike Mickey
NC DENR Winston-Salem Regional Office
Division of Water Quality, Water Quality Section
565 Waughtown Street
Winston-Salem, NC 27107
Main Office: (336) 771-5000
Voice: (336) 771-4962 FAX: (336) 771-4630
E-mail correspondence to and from this address may be subject to the North
Carolina Public Records Law and may be disclosed to third parties.
------------------------------------------------------------------------
denr.dwq.strmperm mailing list
[e-mail] .net
Bethany Georgoulias
Environmental Engineer
NCDENR } . DWQ I Stormwater Permitting Unit 1617 Mail Service Center, Raleigh, NC
27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: (919) 807-6372
Fax: (919) 607-6494
Website: http://h2o.enr.srate.nc.us/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.
2 of 2 2/19/2009 10:00 AM