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HomeMy WebLinkAboutNC0004979_Portable Cooling Tower Request_20010410PDuke Power. A Duke Energy Company April 10, 2001 17=Mr._Mike_Myers_ North Carolina Department Environment and Natural Resources NPDES Unit 1618 Mail Service Center Raleigh, NC 27699-1618 SUBJECT: Portable Cooling Tower Request Plant Allen NPDES Permit # NC0004979 Buck Steam Station NPDES Permit # NC0004774 Marshall Steam Station NPDES Permit # NCO004987 Record Number: NC -005157 Certified: 7000 1670 0003 3252 8387 Dear Mr. Myers: Duke Power Group Environment, Health & Safety MG03A5 13339 Hagers Ferry Road Huntersville, NC 28078-7929 Duke Power requests the approval of a pilot study using portable cooling towers to provide additional cooling to the once -through, non -contact cooling water (CCW) at three of our stations. The three stations are Plant Allen, Buck Steam Station and Marshall Steam Station. The cooling towers will be used during the months of June, July, August and September. The cooling towers for Plant Allen may be rotated to Marshall Steam Station, with Plant Allen using the towers during June, July and August. If the towers are moved to Marshall Steam Station, this move would occur at the end of August and be used there for September each year. Duke Power requests the pilot study to begin on June 1, 2001 and last through October 31, 2002. When the portable cooling towers are in full operation, a portion (<15%) of the CCW water will be removed from the discharge pipe and cooled before it reaches the compliance monitoring point. There are currently no plans to use chemicals or have a blowdown discharge. It is also requested to move the thermal compliance point for Plant Allen 75 yards down stream in the discharge canal to account for the return line. John Mease and Ty Ziegler of Duke Power met with Mike Parker of NCDENR, Mooresville Regional Office, on April 9, 2001 to discuss the proposed Pilot Study. Mr. Parker was unaware of any potential water compliance issues or adverse environmental impacts associated with this project. A vendor brochure with additional information on the portable cooling towers was left with Mr. Parker, see attached. U ON �� C:1m N w U RrLn �N UCl- x f - Q W O oa Duke Power requests the approval of a pilot study using portable cooling towers to provide additional cooling to the once -through, non -contact cooling water (CCW) at three of our stations. The three stations are Plant Allen, Buck Steam Station and Marshall Steam Station. The cooling towers will be used during the months of June, July, August and September. The cooling towers for Plant Allen may be rotated to Marshall Steam Station, with Plant Allen using the towers during June, July and August. If the towers are moved to Marshall Steam Station, this move would occur at the end of August and be used there for September each year. Duke Power requests the pilot study to begin on June 1, 2001 and last through October 31, 2002. When the portable cooling towers are in full operation, a portion (<15%) of the CCW water will be removed from the discharge pipe and cooled before it reaches the compliance monitoring point. There are currently no plans to use chemicals or have a blowdown discharge. It is also requested to move the thermal compliance point for Plant Allen 75 yards down stream in the discharge canal to account for the return line. John Mease and Ty Ziegler of Duke Power met with Mike Parker of NCDENR, Mooresville Regional Office, on April 9, 2001 to discuss the proposed Pilot Study. Mr. Parker was unaware of any potential water compliance issues or adverse environmental impacts associated with this project. A vendor brochure with additional information on the portable cooling towers was left with Mr. Parker, see attached. ..,.- t L ; ,_ s Near term -forecast predictions indicate a continuation of abnormally dry conditions with below normal rainfall. Duke Power requests approval of this Pilot Study by April 24, 2001, to assure adequate electrical supply, while maintaining thermal limits, and protecting the environment. If you need further clarification on this request, please contact John Mease at (704) 875- 5347. Thank you in advance for your prompt consideration. Sincerely, Michael A. Ruhe, Manager Water Compliance cc: Mike Parker — NCDENR, Mooresville Regional Office -P-V 1-11, S- 47, (SD2)(?, 'il" jq L �A� L � Z 7f' p 9 f?�Al �*- �7k Duke dkr Power. A Duke Energy Company Decembe 000 Mr. David Goodr' ina Departmentof Environment, Health, and Natural Resources Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Subject: Plant Allen Steam Station NPDES Permit# NC0004979 Ash Basin Capacity Verification Certified 7099 3400 0001 7791 9822 Dear Mr. Goodrich: Duke Power Group Environment, Health & Safety MG03A5 13339 Hagers Ferry Road Huntersville, NC 28078-7929 0 EC 2 8 2000 DEHR - WATER QUALITY POINT SOURCE BRANCH While it is not required by our current NPDES permit we have undertaken to certify that adequate volume exists in the ash basin to contain all solids expected to be deposited as well as adequate volume for containment of rainfall runoff. Please find attached the ash basin capacity calculations for the Duke Power facility located in Gaston County. The attached calculations indicate that the ash basin is projected to have sufficient detention volume through the year 2006. Current calculations indicate a need for 2,382.2 Acre -ft of volume through 2006 and an available volume of 2,794 Acre -ft. ' The calculations are based on; 1. the most recent physical survey of the ash basin which was performed on January 8,1997; 2. monthly coal consumption data for estimated ash production from August, 1997 through November, 2000; 3. ENPRO base fuel consumption forecast (dated June, 1997) for ash production projections from December, 2000, through December, 2006; and 4. an in-place density of 55 pounds of ash per cubic foot. Please contact Robert Caccia at (704) 875-5268 if you have any questions. Respectfu I ly su bm itted, 4 (Z1VLe_1_ Michael A. Ruhe Manager, Water Compliance RWC/GDB cc: w/attachment- ash basin calculation sheets Mr. Richard Bridgeman NCDENR - Mooresville Regional Office Don Scruggs Plant Allen Steam Station r Duke Power Company Allen Steam Station -Ash Basin Forecasting 2000 Wet Weather Detention Volume Calculation Determination of Wet Weather Detention Volume: Wet Weather Detention Volume is the sum of the runoff accumulated in the ash basin which results from a 10 -yr 24 -hr storm (assuming 100% runoff) plus the maximum 24 -hr dry weather waste stream which discharges to the Ash Basin (refer to NPDES Permit NC0004979) I. Estimate Runoff to the Ash Basin from a 10 -yr 24 -hr storm: 1. Natural Drainage Area of Ash Basin = Station Yard Drainage Area Pumped to Ash Basin = Total = 2. Precipitation from 10 -yr 24 -hr storm = 3: Total Stormwater Runoff to Ash Basin = (Assuming 100% runoff) Il. Estimated Maximum 24 -hr Dry Weather Waste Stream Discharging to Ash Basin: 1. Maximum recorded Ash Basin Discharge = 2. Increase maximum daily disharge by 10% for conservatism and convert units to acre-feet = III. Wet Weather Detention Volume: Sum of Parts I. and II. = IV. Estimated quantity of solids (ash) to be discharged to the Ash Basin through 2006. (Refer to Coal Consumption Data and ENPRO EN9706F1 Output - Base Fuel Consumption Forecast.) Note: NPDES Permit expiration date is 8/31/2001. 288.0 Acres 40.0 Acres 328.0 Acres 5.0 Inches 136.67 Acre-feet 21,000,000 Gallons/day 70.89 Acre-feet 207.55 Acre-feet Time Period Actual or Estimated Coal Consumption (1000's tons) % Ash Estimated Ash Production (1000's tons) Estimated Ash Production (Ac - it) * 1997 2389 10.34% 246.97 206.17 1998 1579 10.16% 160.38 133.88 1999 2056 10.48% 215.52 179.91 1/1/2000 -11 /30/2000 2009 10.87% 218.34 182.27 1211/2000 -12/31/2000 195 10.87% 21.20 17.69 2001 2718 9.00% 244.58 204.17 2002 2878 9.00% 258.98 216.19 2003 3238 9.00% 291.38 243.24 2004 3391 9.80% 332.34 277.44 2005 2943 9.80% 288.37 240.73 2006 3336 9.80% 326.95 272.94 Total 26730.69 2605.00 2174.63 * Calculation assumes an in-place ash density of 55 lbs. per cubic foot. ** Assumes 25% of yearly projection is consumed in January and February. AS Wet Weather Det Vol Calc.xls 1 12/20/00 Duke Power Company r Allen Steam Station -Ash Basin Forecasting 2000 Wet Weather Detention Volume Calculation V. Estimated Total Storage Volume Required for through 2006: Wet Weather Detention Volume = 207.6 Acre-feet Estimated Solids to Ash Basin = 2174.6 Acre-feet Total = 2382.2 Acre-feet Vl. Results: Available Storage based on most recent basin survey dated 1/8/97 = 2794 Acre-feet Required Storage Volume: Through 12/31/2006 = 2382.2 Acre-feet Based on these calculations, there is sufficient capacity in the ash basin to provide the retention volume specified in the permit through the year 2006. AS Wet Weather Det Vol Calc.xls 2 12/20/00 State of North Carolina Department of Environment and Natural Resources Division of Water Quality James B. Hunt, Jr., Governor Bill Holman, Secretary Kerr T. Stevens, Director Ms. Angela M. Grooms Manager, Water Protection Duke Power Group Environment, Health Q Safety 13339 Hagers Ferry Road Huntersville, North Carolina 28078-7929 Dear Ms. Grooms: FWA IT1 • Rs� NCDENR NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES November 19, 1999 Subject: Acid Drip System Allen Steam Station NC PDES�-PeTmit Number NC0004979� Gaston County The Division has reviewed the information submitted by John Mease of Duke Power regarding the acid drip system installation at Allen Steam Station and has come to the conclusion that no Authorization to Construct is necessary for this project. Furthermore, installation of a similar system for dosing caustic is approved provided Duke documents the unit's installation and maintains records regarding dosing and pH. Please note that this letter does not serve as blanket approval for similar installations at other Duke facilities. The Division should be contacted prior to installing similar systems elsewhere. If you have any questions or comments regarding this matter, please do not hesitate to contact Mark McIntire at telephone number (919) 733-5083, extension 553. Sincerely err T. Stevens Cc: Central Files -NPDES-Permit+ile-1 Mooresville Regional Office, Water Quality 1617 MAIL SERVICE CENTER, RALEIGH, NORTH CAROLINA 27699-1617 - TELEPHONE 919-733-5083/FAX 919-733-0719 AN EQUAL OPPORTUNITY AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/ 10% POST -CONSUMER PAPER State of North Carolina Department of Environment and Natural Resources Division of Water Quality Y . James B. Hunt, Jr., Governor ; -Wayne McDevitt, Secretary A. Preston Howard, Jr., P.E., Director October 12, 1998 Ms. Angela Grooms Manager, Water Protection Duke Power 13339 Hagers Ferry Road Huntersville, North Carolina 28078-7929 N-CDENR Subject: Sump Overflows Duke Power Company NC Fossil Plants Dear Ms. Grooms: The Division has reviewed the information submitted by Duke Power regarding sump overflows at Allen. Buck,_ Dan River, Marshall, and Riverbend Steam Stations and accepts the characterization conducted at Buck as adequate for the remaining four facilities due to the similarity of the sump water. It is the Division's recommendation that the-NPDES permits for the above mentioned facilities be modified to accommodate these sump overflows. The Division would treat these overflows as an additional permitted outfall with monitoring require ments'indicative of those at the ash basin effluent. Additionally, the Division -would ask that Duke Power, wherever possible, minimize these overflows either through collection or diversion to the -ash basin. As this request would involve the installation of an additional permitted outfall into the NPDES permit, it would be considered a major modification and be. subject to all appropriate timelines and Statutory requirements. Should you have any questions or comments regarding this speculative limits request, please do not hesitate to contact Mark McIntire at (919) 733-5083, extension 553. Sincerely, David A. Goodrich Supervisor, NPDES Unit cc: Central Files (with attachments) Mooresville Regional Office, Water Quality Section Winston-Salem Regional Office, Water Quality Section DF:S1ilnit?Fil //( _�� nts1 NC0004961, NC0004987, NC0003468, 04909C," NC0004774 P.O. Box 29535, Raleigh, North Carolina 27626-0535 - . Telephone (919) 733-5083 FAX (919) 733-0719 An Equal Opportunity Affirmative Action Employer 50% recycled / 10% post -consumer paper NCDENR/DIVISION OF WATER QUALITY Water lQuality Section/NPDES Unit October 9, 1998 MEMORANDUM To: Dave Goodrich From: Mark McIntire A44 -`A, Subject: Sump Overflows Duke Power Fossil Plan I have been in discussions for quite some time w`th John Mease and Angela Grooms of Duke Power Company regarding sump overflow issues. NPDES permits for Alle , Buck, Dan River, Marshall, and Riverbend steam stations do not currently accommodate these overflows. Our di cussions have been aimed at finding a practical, protective way of handling these situations. Earlier in the year, I instructed Duke Power to grab a series of eight samples from the sump at Buck Steam Station over a two week period (these sumps are those that deliver wastewater to the ash basins). Duke collected the samples and subsequently forwarded the results, attached to our office on March 27, 1998. The data is indicative of an ash basin discharge with the exception of relatively hi h solids and iron. Incidents of high iron and TSS were likely due to heavy rains agitating sediment prior to raw water intake. These sump overflows occur in small volumes and on rare occasions. In light of the very high stream flows associated. with the streams into which Duke discharges, the mpact from these sump overflows is very likely minimal to zero. As such, I recommend permitting these sump overflo s as a serial numbered outfall with appropriate monitoring installed typical of that required at ash basin discharges. F rthermore, as these sump overflows are relatively consistent from facility to facility, I do not think it's necessary to r quire characterization of the other four facilities. Attached is a letter to Duke Power to that affect. As this propo ition would involve the permitting of -an additional outfall, we would likely need to proceed with the major modification route. In addition to monitoring for these overflows, I propose that we require Duke Power to make every reasonable ttempt to minimize the occurrence of these overflows. We should also require Duke to make every reasonable atte t to redirect these overflows to the respective ash basins. �n 1 Mark, Per our phone call,- attached is a list of waste streams at our NC Fossil sites that have sumps with overflow pipes going to surface waters. Also included is a copy of the letter (March 27,1998) with the results from the sump characterization study done at our Buck Steam Station. Please review this information and let us know what the permitting requirements would entail. Thanks for your help with this matter. . John Mease Sunhp Waste Streams Allen Steam Station Powerhouse Sump Wast6 Streams: (Overflows to River) • Unit # 5 Boiler Rbom sump: Floor wash water (O&G) Boiler seal wa er • Unit #3, #4, #5 I.Tduced Draft Motor Bearing Cooling Water • Unit #3, #4, #5 lir Preheater wash water (iron) - • Unit #3, #41 #5 hecker Plate wash/stormwaterash O • Unit #3, #4, #5 F�yash separator Tank overflow (ash) • Surface drains north of Powerhouse • 100,000 gallon Fuel Oil Storage Tank containment drain • Groundwater remediation oil/water separator discharge Yard Drainage Sump Waste Streams: (Overflows to CY Sump) • Water Treatment ystem Clarifier de+dge Pressure filt r backwash Activated ca bon filter backwash Reverse Osmosis blowdown Reverse OsrI osis Prefilter backwash Demineral¢ r/regeneration discharge (neutral) • Boiler Blowdown (hydrazine) • Laboratory wastes • Closed Cooling W ter leakage(biocides) • Turbine NDE Testig discharge (corrosion inhibitor) • Heat Exchanger cl aning discharge • Unit #1, #2 Induce Draft Fan Motor Bearing Cooling Water • Unit #1, #2, #3, #4 oiler Room Sumps Floor wash Water Boiler Seal Water • Unit #1, #2 Air Pre eater Wash Water (iron) • Chemical make-up anks and drum rinseate (hydrazine) • Misc. Janitorial pro 'esses 9 Misc. stormwater d ,ains Coal Yard Sump Waste Streams: (Overflows to River), • Coal Pile Run-off • Misc. Coal handling Sump Pump Discharges • Sanitary (septic tank effluent) • Possible overflow from Yard Drainage Sump • Misc. stormwater drains • Buck Steam Station Yard Sump: (Overflows to the Yadkin River): • Water Treatment System Clarifier desludge Gravity filters backwash Activated carbon filters backwash Demineralizer/regeneration discharge (neutral) • Waterwall blowdown • Continuous boiler blowdown • Superheater drain lines • Yard drains (stormwater) • Coal pile runoff • Sanitary waste • Floor drains • Sulfuric acid • Sodium Hydroxide • Water treatment chemicals • Hydrazine . • Oil • Corrosion Inhibitions - - • Laboratory Waste • Oil/water separator discharge • Microbiocides • Industrial cleaning products Dan River -3W Yard Sump: (Overflows tb the Dan River) • Yard drains (stor • Coal pile runoff • Miscellaneous p2 and light mainten • Small amounts of maintenance Marshall 101 rking lot oil & gasoline (only leaks or spills ance activities) flyash from precipitator hopper Sump 2: (Overflow to Lako Norman) • Water Treatment System Clarifier des udge Gravity filter backwash Activated cap bon filters backwash Demineraliz r/regeneration discharge • Closed system dr inage, cleanings, testing • Boiler seal water • Miscellaneous sys em leakage's • Moisture separato s on air compressor precipitators • Floor wash water • Pyrite (ash) remov I system overflow • Low volume waste ater • Chemical makeup anks and drum rinsate • Boiler blowdown • Yard stormwater d ins Sump 1: (Overflow to Lake Norman) • Coal pile runoff • Yard stormwater dr ins Turbine room sump overflow Riverbend 4�6 Yard Sump: (Overflow to Catawba River) • Water Treatment System Clarifier desludge Gravity filters backwash Activated carbon filters backwash Demineralizer/regeneration discharge (neutral) • Boiler Cleaning • Water treatment chemicals • Continuous boiler blowdown • Superheater drain lines • Yard drains (stormwater) • Coal pile runoff • Sanitary waste • Floor drains • Sulfuric acid • Sodium Hydroxide • Hydrazine • Oil & gasoline (only from leaks or spills) • Corrosion Inhibitions • Laboratory Waste • Oil/water separator discharge • Microbiocides • Industrial cleaning products • Groundwater sump • ID fans cooling water • Chemical makeup tank drain lines 1. Hydrazine 2. Ammonium Hydroxide 3. NaOH - 4. Aluminum Sulfate • Preheater bearing cooling water - _eDike Power March 27, 1998 Mr. Mark McIntire NPDES Unit North Carolina Department of Division of Water Quality P. O. Box 29535 Raleigh, NC 27626-0535 Subject: ment and Natural Resources Buck Steam Station Rowan County NPDES # NC00047 4 Record #: BU -0048E3 Certified Mail: P 318 140 645 Dear Mr. McIntire: Attached -are the -sample results system at. Buck Steam Station. l possible permitting of the sump's 1998. As required, the sump was sample( Tuesday, Wednesday and Thursda parameters. When the samples we normal plant waste streams. The to operations with units on and off line with heavy rains conditions (coal pil Should you need additional 5347. Sincerely, Angela -M. Grooms Manager, Water Protection jrm . - Duke Power Getup EmdrVnment,-Heald, 6-Sa en 13339 H-9— Ferry Road Hunter-ille, NC 28078-7929 acterizing the sump used in the waste treatment characterization was -needed in regards to the rflow pipe, see attached letter dated March 4, eight times during a two week period on Monday, at approximately two o'clock for -the requested collected the sump was operating, receiving the sampling events included normal plant order dry weather and the units on and off line run oft]. on, please contact John Mease at (704) 875 - cc: John Lesley, Mooresville Regional Office NCDENR Sump Results Samples Collected 3/2-5/98 and 319-12/98 Sampling Date 02 -Mar -98 03 -Mar -98 04 -Mar -98 05 -Mar -98 09 -Mar -98 10 -Mar -98 11 -Mar -98 12 -Mar -98 , TSS mg/L 22.0 64.0 34.0 34.0 100.0 190.0 168.0 127.0 O&G mg/L <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 BOD mg/L 0.8 0.8 <2.0 <2:0 4.2 3.1 2.9 <2.0 Ammonia mg-N/L 0.21 0.10 0.08 0.08 0.27 0.22 0.16 0.06 Total Arsenic ug/L <2.0 <2.0 <2.0 <2.0 <2.0 4.4 3.6 2.4 Total Copper Mg/l.mg/L 0.038 0.041 0.061 0.008 0.035 0.023 0.026 0.027 Total Iron 1.613 1.826 1.583 1.251 5.564 10.84 6.718 4.698 Total Total Total Sampling Date Nitrogen mg -NIL Phosphorus mg-P/L Selenium ug/L pH (S.U.) Temperature ,F Weather Unit Status 02 -Mar -98 03 -Mar -98 04 -Mar -98 05 -Mar -98 09 -Mar -98 10 -Mar -98 11 -Mar -98 12 -Mar -98 0.89 1..12 0.96 0.85 0.97 0.69 0.96 1.25. 0.097 0.123 0.100 0.296 0.140 0.210 0.270 0.170 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 <2,0 7.35 8.16 7.44 7.49 6.1 6.83 6.97 7.28 58.6 60.3 56.8 56.3 57.2 61.2 55.9. 54.3 No Rain Off No Rain Unit 5 On No Rain Unit 5 On No Rain Unit 5 On Heavy Rain Off No Rain Units 586 On No Rain Units 5&6 On No Rairi Units 5&6 On PhDake rPower_ AD.&E—rC—q-i March 4, 1998 Mr. John Lesley Department of Environment Water Quality Section Mooresville Regional Office 919 North Main Street Mooresville, NC 28115 Subject: Buck Steam Sta Rowan County NPDES # NCOD Record #: BU-Oi Certified Mail: P Dear Mr. Lesley: Natural Resources 4774 9 635 422 Duke Power 13339 Hagecs Ferry Road Huncusville. NC 28078-7929 As per a phone conversation b' tween yourself and John Mease (Duke Power), John Mease talked to Mr. Mark McIntire (NCDENR, NPDES Unit) regarding the possible permitting of the sump overflow pipe at Duke Power's Buck Steam Station. Mr. McIntire determined the following information would be required before a decision could be made regardi g possible permitting and permit- limits on the overflow pipe: • Eight discrete samples to be Monday, Tuesday, Wednesd • Sample for the following par. • Total Suspend( • Oil and Grease • Biochemical O) • Ammonia • Total Copper • Total Iron • Total Arsenic. • Total Selenium • Total Phosphor • Total Nitrogen- • pH • Temperature collected in the sump over a two week period on ay and Thursday ,meters:: , d Solids Demand. - • Possible sampling at other Duke Power locations that have similar_ sump design will be considered depending on the sample results. The analytical results will be summarized and sent to Mr. McIntire. Upon the State's review of the results a decision regarding permitting and possible permit limits will be issued by Mr. McIntire. Mr. Mease will copy the Mooresville office on all correspondences. Should you have questions regarding this matter, please contact John Mease at (704) 875-5347. Sincerely, Angela M. Grooms Manager, Water Protection 1r cc: D. T. Shuping - Buck Steam Station Mr. Mark McIntire - NCDENR State of North Carolina Department of Environment, Health and Natural Resources Division of Water Quality James B. Hunt, Jr., Governor Jonathan B. Howes, Secretary A. Preston Howard, Jr., P.E.,. Director July 7, 1997 Mr. David F. Mitchell, Technical System Manager Duke Power Company Electric System Support Water Protection 13339 Hagers Ferry Road Huntersville, North Carolina 28078-7929 Dear Mr. Mitchell: ALT.WYVA IT 4 I DEHNF1 Subject: Flow Measuring Changes - Duke Power NPDES Permits The Division acknowledges receipt of your correspondance dated June 12, 1997 regarding flow, measurement at Plant Allen, Belews Creek, Buck, Cliffside, Dan River, Marshall and Riverbend steam stations. With this letter, the Division approves the proposed changes to the flow measurement equipment, at the above referenced facilities. It is the Division's understanding that the proposed changes are being made in order to improve flow measuring accuracy and to implement a consistent approach system -wide. Should you have any questions concerning this matter, please do not hesitate to contact Mark McIntire at (919) 733-5083, extension 553. Sincerely, Lnt( __ l, David A. Goodrich NPDES Group Supervisor cc: Central Files Asheville Regional Office / Water Quality Mooresville Regional Office / Water Quality Winston-Salem Regional Office / Water Quality Permits and Engineering Unit / NPDES Permit Files NC0004979, NC0004774, NC0005088, NC0003468, NC0004987, NC0004961, NCO024406 P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone 919-733-5083 FAX 919-733-0719 An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper