HomeMy WebLinkAbout20060447 Ver 3_Approval Letter_20200615DocuSign Envelope ID: 1B025184-D4C6-4DB8-8115-6B906DCFBE38
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
Olde Towne WEH, LP
Attn: Mr. Eric Rifkin
56 Hunter Street
Apex NC 27502
NORTH CAROLINA
Environmental Quality
June 15, 2020
DWR # 20060447 v3
Wake County
Subject: Approval of Individual 401 Water Quality Certification with Additional Conditions
Olde Town Master Plan Community
USACE Action ID. No. SAW-2006-20287
Dear Mr. Rifkin:
Attached hereto is a copy of Certification No. WQC004230 issued to Mr. Eric Rifkin and Olde Towne
WEH, LP, dated June 15, 2020. Please note that you should get any other federal, state or local permits
before proceeding with the subject project, including those required by (but not limited to) Sediment
and Erosion Control, Non -Discharge, and Water Supply Watershed regulations.
This approval and its conditions are final and binding unless contested. This Certification can be
contested as provided in Articles 3 and 4 of General Statute 150B by filing a written petition for an
administrative hearing to the Office of Administrative Hearings (hereby known as OAH) within sixty (60)
calendar days.
A petition form may be obtained from the OAH at http://www.ncoah.com/ or by calling the OAH Clerk's
Office at (919) 431-3000 for information. A petition is considered filed when the original and one (1)
copy along with any applicable OAH filing fee is received in the OAH during normal office hours (Monday
through Friday between 8:00am and 5:00pm, excluding official state holidays).
The petition may be faxed to the OAH at (919) 431-3100, provided the original and one copy of the
petition along with any applicable OAH filing fee is received by the OAH within five (5) business days
following the faxed transmission.
D E Q�� North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1617 Mail Service Center I Raleigh, North Carolina 27699-1617
m )ry rN cxl4o:. i
o.�ro�em or E�.w�����a�:r� /� 919.707.9000
DocuSign Envelope ID: 1B025184-D4C6-4DB8-8115-6B906DCFBE38
Mailing address for the OAH:
If sending via US Postal Service:
Office of Administrative Hearings
6714 Mail Service Center
Raleigh, NC 27699-6714
Olde Towne WEH, LP
DWR Project #20060047 v3
Individual Certification # WQC004230
Page 2 of 10
If sending via delivery service (UPS, FedEx, etc):
Office of Administrative Hearings
1711 New Hope Church Road
Raleigh, NC 27609-6285
One (1) copy of the petition must also be served to DEQ:
William F. Lane, General Counsel
Department of Environmental Quality
1601 Mail Service Center
Raleigh, NC 27699-1601
Unless such a petition is filed, this Certification shall be final and binding.
This Certification completes the review of the Division under section 401 of the Clean Water Act and 15A
NCAC 02H .0500. Contact Sue Homewood at 336-776-9693 or sue.homewood@ncdenr.gov if you have
any questions or concerns.
Sincerely,
DocuSigned by:
949D91BA53EF4E0...
Paul Wojoski, Supervisor
401 & Buffer Permitting Branch
cc: Jennifer Burdette, McAdams Company (via email)
James Lastinger, USACE Raleigh Regulatory Field Office (via email)
Gabriela Garrison, NCWRC (via email)
Todd Bowers, EPA, (via email)
DWR RRO 401 file
DWR 401 & Buffer Permitting Branch Laserfiche file
Filename: 20060447v3OldeTowneMasterPlanCommunity(Wake)_401_IC_NRB.docx
DocuSign Envelope ID: 1B025184-D4C6-4DB8-8115-6B906DCFBE38
Olde Towne WEH, LP
DWR Project #20060047 v3
Individual Certification # WQC004230
Page 3 of 10
NORTH CAROLINA 401 WATER QUALITY CERTIFICATION
CERTIFICATION #WQC004230 is issued in conformity with the requirements of Section 401, Public Laws
92-500 and 95-217 of the United States and subject to North Carolina's Regulations in 15 NCAC 02H .0500
and 15A NCAC 026 .0200, to Mr. Eric Rifkin and Olde Towne WEH, LP, who have authorization for the
impacts listed below, as described within your application received by the N.C. Division of Water
Resources (Division) on February 5, 2020 and subsequent information on February 27, 2020 and May 18,
2020, and by Public Notice issued by the U. S. Army Corps of Engineers and received by the Division on
February 25, 2020.
The State of North Carolina certifies that this activity will not violate the applicable portions of Sections
301, 302, 303, 306, 307 of the Public Laws 92-500 and PL 95-217 if conducted in accordance with the
application, the supporting documentation, and conditions hereinafter set forth.
This approval requires you to follow the conditions listed in the Certification below.
Conditions of Certification:
1. The following impacts are hereby approved. No other impacts are approved, including incidental
impacts. [15A NCAC 02H .0506(b) and (c)] and 15A NCAC 02B .0233(8)]
Type of Impact
Amount Approved (units)
Amount Approved (units)
Permanent
Temporary
Stream
Impact Area A* - road
120 (linear feet) — culvert
5 (linear feet)
crossing
32 (linear feet) - riprap
Impact Area B* — road
150 (linear feet) — culvert
5 (linear feet)
crossing
43 (linear feet) - riprap
Impact Area D — road
13 (linear feet) — culvert
2 (linear feet)
crossing
16 (linear feet) — riprap
26 (linear feet) - fill
Impact Area E — road
112 (linear feet) —culvert
5 (linear feet)
crossing
22 (linear feet) — riprap
Impact Area H* — road
48 (linear feet) — culvert
0 (linear feet)
widening
Impact Area I* — road
351 (linear feet) — stream
0 (linear feet)
widening
relocation
404/401 Wetlands
Impact Area B - road
0.298 (acres)
0.003 (acres)
crossing
Impact Area E - road
0.041 (acres)
0.0 (acres)
crossing
Impact Area H — road
0.213 (acres)
0.0 (acres)
widening
Impact Area I — road
0.116 (acres)
0.152 (acres)
widening
DocuSign Envelope ID: 1B025184-D4C6-4DB8-8115-6B906DCFBE38
Olde Towne WEH, LP
DWR Project #20060047 v3
Individual Certification # WQC004230
Page 4 of 10
Buffers —Zone 1
Impact Area A*— road
11,316 (square feet)
0 (square feet)
crossing
Impact Area B*— road
10,845 (square feet)
0 (square feet)
crossing
Impact Area D*— road
3,441 (square feet)
0 (square feet)
crossing
Impact Area E— road
8,405 (square feet)
0 (square feet)
crossing
Impact Area H— road
2,701 (square feet)
0 (square feet)
crossing
Impact Area I— road
521 (square feet)
0 (square feet)
non -perpendicular
impact
Impact Area I— SCM
528 (square feet)
0 (square feet)
outlet
Impact Area J— SCM
900 (square feet)
0 (square feet)
outlet
Impact Area K— SCM
491 (square feet)
0 (square feet)
outlet
Buffers — Zone 2
Impact Area A*— road
7,133 (square feet)
0 (square feet)
crossing
Impact Area B*— road
6,335 (square feet)
0 (square feet)
crossing
Impact Area D*— road
3,991 (square feet)
0 (square feet)
crossing
Impact Area E— road
5,638 (square feet)
0 (square feet)
crossing
Impact Area H— road
2,104 (square feet)
0 (square feet)
crossing
Impact Area I— road
6,533 (square feet)
0 (square feet)
non -perpendicular
impact
Impact Area I— SCM
298 (square feet)
0 (square feet)
outlet
Impact Area J— SCM
551 (square feet)
0 (square feet)
outlet
Impact Area K— SCM
528 (square feet)
0 (square feet)
outlet
*indicates impacts requiring mitigation
2. Mitigation must be provided for the proposed impacts as specified in the table below. You have
proposed a phased mitigation plan as indicated in the table below. The Division has received
documentation that mitigation had been previously satisfied for 300 feet of stream and 0.4752 acres
DocuSign Envelope ID: 1B025184-D4C6-4DB8-8115-6B906DCFBE38
Olde Towne WEH, LP
DWR Project #20060047 v3
Individual Certification # WQC004230
Page 5 of 10
of wetlands. The Division has received an acceptance letters from the mitigation banks listed below
to meet the remainder of the mitigation requirement. Until the Mitigation Banks receive and clears
your payment for each phase of the proposed project, and proof of payment has been provided to
this Office, no impacts specified within that phase in this Authorization Certificate shall occur. [15A
NCAC 02H .0506 (b)(6)]:
Compensatory Mitigation Required
River and Sub -basin Number
Stream
Phase 1: 271.5 (linear feet)
Neuse 03020201
Phase 2: 270 (linear feet)
Wetland
Phase 1: 0.329 (acres)
Neuse 03020201
Phase 2: 0.339 (acres)
Buffers
Phase 1: 11,363 (square feet)
Neuse 03020201
Phase 2: 101,001 (square feet)
Bank Sponsor
Bank Name
Wildlands Holdings III, LLC
Falling Creek Stream and Wetland
Mitigation Bank
Wildlands Holdings II, LLC
Neuse 01 Nutrient Offset & Buffer
Umbrella Bank - Buck Swamp Parcel
Wildlands Holdings II, LLC
Neuse 01 Nutrient Offset & Buffer
Umbrella Bank - Caraway Parcel
Wildlands Holdings II, LLC
Old Savannah Nutrient Offset & Buffer
Mitigation Bank
Wildlands Holdings III, LLC
Thoroughfare Swamp Nutrient Offset &
Buffer Mitigation Bank
Wildlands Holdings III, LLC
Grantham Branch Nutrient Offset &
Buffer Mitigation Bank
3. This approval is for the purpose and design described in your application and as described in the Public
Notice. The plans and specifications for this project are incorporated by reference and are an
enforceable part of the Certification. When final construction plans are developed for Phase 2 they
shall be submitted to the Division for review to determine if modification to this 401 Water Quality
Certification is required. If a modification is required, an application shall be submitted to the Division
with the appropriate fee. Final designs shall reflect all appropriate avoidance, minimization, and
mitigation for impacts to wetlands, streams, and other surface waters, and buffers. No construction
activities that impact any wetlands or streams within Phase 2 shall begin until after the Permittee
applies for, and receives, either a notification from the Division that a modification to the 401 is not
required, or a modified 401 Water Quality Certification from the Division. [15A NCAC 02H .0501 and
.0502]
4. Any final construction plans for this project must include or reference the application and plans
approved by the Division under this authorization letter and certification. The applicant will also be
required to evaluate all acquired permits to assure that they are consistent and all relative impacts
are accounted for and shown on the construction plans. [15A NCAC 02H .0502 (b) and 15A NCAC
DocuSign Envelope ID: 1B025184-D4C6-4DB8-8115-6B906DCFBE38
Olde Towne WEH, LP
DWR Project #20060047 v3
Individual Certification # WQC004230
Page 6 of 10
02H .0506 (4)]
5. Any additional impacts to streams and/or wetlands as a result of future roads, buildings, driveways,
utility lines or other development related activities within this planned community will require a
modification of this 401 Water Quality Certification approval. [15A NCAC 02H .0506(4) and 15A
NCAC 02H .0501 and .0502]
6. You are required to secure an approved Stormwater Management Plan (SMP) for each phase of this
project from City of Raleigh before any impacts authorized within each phase of the project in this
certification occur. After it is approved, the SMP may not be modified without prior written
authorization from City of Raleigh. [15A NCAC 02H .0506(b)(5)]
7. The proposed onsite stream relocation at Impact Area H shall be constructed in accordance with the
design submitted to the Division on May 18, 2020. [15A NCAC 02H .0506 (b)(6)]
The designer or their designee shall supervise relocated channel construction activities.
b. The stream relocation shall be constructed in a dry work area and shall be completed and
stabilized prior to diverting water into the new channel.
c. The permittee shall ensure that mature trees within the buffer areas will be protected as much
as feasible during the construction of this project. [15A NCAC 02H .0506(b)(2)]
Native vegetation shall be used throughout this project. All tree and shrub plantings within the
proposed planting buffer on both sides of the stream shall be protected from mowing or clearing.
As -Built plans for the completed stream relocation shall be submitted to Division within 60 days
of the completion of the construction of the relocation.
Monitoring of the relocated channel, and success criteria determination, shall be in accordance
with the Relocation Monitoring Plan submitted to the Division on May 18, 2020.
8. No waste, spoil, solids, or fill of any kind shall occur in wetlands or waters beyond the footprint of the
impacts (including temporary impacts) as authorized under this Certification. [15A NCAC 02H .0501
and .0502]
No removal of vegetation or other impacts of any kind shall occur to state regulated riparian buffers
beyond the footprint of impacts approved in a Buffer Authorization or Variance or as listed as an
exempt activity in the applicable riparian buffer rules. [15A NCAC 02B .0200]
9. All wetlands, streams, surface waters, and riparian buffers located within 50 feet of the construction
area on the project site shall be clearly marked (example- orange fabric fencing) prior to any land
disturbing activities and must be maintained on the property until the project phase is completed.
[15A NCAC 02H .0506 (b)(2) and (c)(2) and 15A NCAC 02H .0507 (c)]
10. All construction activities shall be performed and maintained in full compliance with G.S. Chapter
113A Article 4 (Sediment and Pollution Control Act of 1973).
11. Sediment and erosion control measures shall not be placed in wetlands or waters except within the
footprint of temporary or permanent impacts authorized under this Certification. [15A NCAC 02H
0501 and .0502]
DocuSign Envelope ID: 1B025184-D4C6-4DB8-8115-6B906DCFBE38
Olde Towne WEH, LP
DWR Project #20060047 v3
Individual Certification # WQC004230
Page 7 of 10
12. Erosion control matting that incorporates plastic mesh and/or plastic twine shall not be used along
streambanks or within wetlands. [15A NCAC 02B .02011
13. An NPDES Construction Stormwater Permit (NCG010000) is required for construction projects that
disturb one (1) or more acres of land. The NCG010000 Permit allows stormwater to be discharged
during land disturbing construction activities as stipulated in the conditions of the permit. If the
project is covered by this permit, full compliance with permit conditions including the erosion &
sedimentation control plan, inspections and maintenance, self -monitoring, record keeping and
reporting requirements is required. [15A NCAC 02H .0506(b)(5) and (c)(5)]
The North Carolina Department of Transportation (NCDOT) shall be required to be in full compliance
with the conditions related to construction activities within the most recent version of their individual
NPDES (NCS000250) stormwater permit. [15A NCAC 02H .0506(b)(5) and (c)(5)]
14. All work in or adjacent to streams shall be conducted so that the flowing stream does not come in
contact with the disturbed area. Approved best management practices from the most current version
of the NC Sediment and Erosion Control Manual, or the NC DOT Construction and Maintenance
Activities Manual, such as sandbags, rock berms, cofferdams, and other diversion structures shall be
used to minimize excavation in flowing water. [15A NCAC 02H .0506(b)(3) and (c)(3)]
15. Culverts shall be designed and installed in such a manner that the original stream profiles are not
altered and allow for aquatic life movement during low flows. The dimension, pattern, and profile of
the stream above and below a pipe or culvert shall not be modified by widening the stream channel or
by reducing the depth of the stream in connection with the construction activity. The width, height,
and gradient of a proposed culvert shall be such as to pass the average historical low flow and spring
flow without adversely altering flow velocity. [15A NCAC 02H .0506(b)(2) and (c)(2)].
Placement of culverts and other structures in streams shall be below the elevation of the streambed
by one foot for all culverts with a diameter greater than 48 inches, and 20% of the culvert diameter
for culverts having a diameter less than or equal to 48 inches, to allow low flow passage of water and
aquatic life.
If multiple pipes or barrels are required, they shall be designed to mimic the existing stream cross
section as closely as possible including pipes or barrels at flood plain elevation and/or sills where
appropriate. Widening the stream channel shall be avoided.
If bedrock is discovered during construction, then DWR shall be notified by phone or email within 24
hours of discovery.
Installation of culverts in wetlands shall ensure continuity of water movement and be designed to
adequately accommodate high water or flood conditions. When roadways, causeways, or other fill
projects are constructed across FEMA-designated floodways or wetlands, openings such as culverts
or bridges shall be provided to maintain the natural hydrology of the system as well as prevent
constriction of the floodway that may result in destabilization of streams or wetlands.
The establishment of native woody vegetation and other soft stream bank stabilization techniques
shall be used where practicable instead of riprap or other bank hardening methods.
DocuSign Envelope ID: 1B025184-D4C6-4DB8-8115-6B906DCFBE38
Olde Towne WEH, LP
DWR Project #20060047 v3
Individual Certification # WQC004230
Page 8 of 10
16. Application of fertilizer to establish planted/seeded vegetation within disturbed riparian areas and/or
wetlands shall be conducted at agronomic rates and shall comply with all other Federal, State and
Local regulations. Fertilizer application shall be accomplished in a manner that minimizes the risk of
contact between the fertilizer and surface waters. [15A NCAC 02B .0200 and 15A NCAC 02B .0231]
17. If concrete is used during construction, then all necessary measures shall be taken to prevent direct
contact between uncured or curing concrete and waters of the state. Water that inadvertently
contacts uncured concrete shall not be discharged to waters of the state. [15A NCAC 02B .0200]
18. No temporary impacts are allowed beyond those included in this Certification. All temporary fill and
culverts shall be removed and the impacted area shall be returned to natural conditions within 60
calendar days after the temporary impact is no longer necessary. The impacted areas shall be
restored to original grade, including each stream's original cross sectional dimensions, planform
pattern, and longitudinal bed profile. All temporarily impacted sites shall be restored and stabilized
with native vegetation. [15A NCAC 02H .0506(b)(2) and (c)(2)]
19. All proposed and approved temporary pipes/culverts/riprap pads etc. in streams shall be installed as
outlined in the most recent edition of the North Carolina Sediment and Erosion Control Planning and
Design Manual or the North Carolina Surface Mining Manual or the North Carolina Department of
Transportation Best Management Practices for Construction and Maintenance Activities so as not to
restrict stream flow or cause dis-equilibrium during use of this Certification. [15A NCAC 02H
.0506(b)(2) and (c)(2)]
20. Any riprap required for proper culvert placement, stream stabilization, or restoration of temporarily
disturbed areas shall be restricted to the area directly impacted by the approved construction activity.
All riprap shall be buried and/or "keyed in" such that the original stream elevation and streambank
contours are restored and maintained. Placement of riprap or other approved materials shall not
result in de -stabilization of the stream bed or banks upstream or downstream of the area. [15A NCAC
02H .0506(b)(2)]
21. Any riprap used for stream stabilization shall be of a size and density to prevent movement by stream
flows and shall consist of clean rock or masonry material free of debris or toxic pollutants. Riprap shall
not be installed in the streambed except in specific areas required for velocity control and to ensure
structural integrity of bank stabilization measures. [15A NCAC 02H .0506(b)(2)]
22. Deed notifications or similar mechanisms shall be placed on all lots with retained jurisdictional
wetlands, waters, and state regulated riparian buffers within the project boundaries in order to assure
compliance with NC Wetland Rules (15A NCAC 02H .0500), NC Isolated Wetland Rules (15A NCAC 02H
.1300), and/or State Regulated Riparian Buffer Rules (15A NCAC 02B .0200). These mechanisms shall
be put in place at the time of recording of the property or individual parcels, whichever is appropriate.
[15A NCAC 02H .0501 and .0502]
23. This Certification does not relieve the applicant of the responsibility to obtain all other required
Federal, State, or Local approvals before proceeding with the project, including those required by, but
not limited to Sediment and Erosion Control, Non -Discharge, Water Supply Watershed, and Trout
Buffer regulations.
DocuSign Envelope ID: 1B025184-D4C6-4DB8-8115-6B906DCFBE38
Olde Towne WEH, LP
DWR Project #20060047 v3
Individual Certification # WQC004230
Page 9 of 10
24. All mechanized equipment operated near surface waters shall be inspected and maintained regularly
to prevent contamination of surface waters from fuels, lubricants, hydraulic fluids, or other toxic
materials. Construction shall be staged in order to minimize the exposure of equipment to surface
waters to the maximum extent practicable. Fueling, lubrication and general equipment maintenance
shall not take place within 50 feet of a waterbody or wetlands to prevent contamination by fuels and
oils. [15A NCAC 02H .0506(b)(3) and (c)(3) and 15A NCAC 02B .0211 (12)]
25. Heavy equipment working in wetlands shall be placed on mats or other measures shall be taken to
minimize soil disturbance. [15A NCAC 02H .0506(b)(3) and (c)(3)]
26. In accordance with 143-215.85(b), the Permittee shall report to the Raleigh Regional Office at 919-
791-4200 (after hours and on weekends call 800-858-0368) any petroleum spill of 25 gallons or more;
any spill regardless of amount that causes a sheen on surface waters; any petroleum spill regardless
of amount occurring within 100 feet of surface waters; and any petroleum spill less than 25 gallons
that cannot be cleaned up within 24 hours.
27. Mr. Eric Rifkin and Olde Towne WEH, LP shall conduct construction activities in a manner consistent
with State water quality standards (including any requirements resulting from compliance with section
303(d) of the Clean Water Act) and any other appropriate requirements of State and Federal law.
[15A NCAC 02B .0200] If the Division determines that such standards or laws are not being met
(including the failure to sustain a designated or achieved use) or that State or federal law is being
violated, or that further conditions are necessary to assure compliance, the Division may reevaluate
and modify this Certification. Before modifying the Certification, the Division shall notify Mr. Eric
Rifkin and Olde Towne WEH, LP and the U.S. Army Corps of Engineers, provide public notice in
accordance with 15A NCAC 02H .0503 and provide opportunity for public hearing in accordance with
15A NCAC 02H .0504. Any new or revised conditions shall be provided to Mr. Eric Rifkin and Olde
Towne WEH, LP in writing, shall be provided to the U.S. Army Corps of Engineers for reference in any
Permit issued pursuant to Section 404 of the Clean Water Act, and shall also become conditions of the
404 Permit for the project.
28. Upon completion of all permitted impacts included within the approval and any subsequent
modifications, the applicant shall be required to return a certificate of completion (available on the
DWR website https://edocs.deg.nc.gov/Forms/Certificate-of-Completion). [15A NCAC 02H .0502(f)]
29. If the property or project is sold or transferred, the new Permittee shall be given a copy of this
Certification (and written authorization if applicable) and is responsible for complying with all
conditions. [15A NCAC 02H .0501 and .0502]
30. This Certification neither grants nor affirms any property right, license, or privilege in any waters, or
any right of use in any waters. This Certification does not authorize any person to interfere with the
riparian rights, littoral rights, or water use rights of any other person and this Certification does not
create any prescriptive right or any right of priority regarding any usage of water. This Certification
shall not be interposed as a defense in any action respecting the determination of riparian or littoral
rights or other rights to water use. No consumptive user is deemed by virtue of this Certification to
possess any prescriptive or other right of priority with respect to any other consumptive user
regardless of the quantity of the withdrawal or the date on which the withdrawal was initiated or
expanded.
DocuSign Envelope ID: 1B025184-D4C6-4DB8-8115-6B906DCFBE38
Olde Towne WEH, LP
DWR Project #20060047 v3
Individual Certification # WQC004230
Page 10 of 10
31. This Certification grants permission to the director, an authorized representative of the Director, or
DEQ staff, upon the presentation of proper credentials, to enter the property during normal business
hours. [15A NCAC 02H .0502(e)]
32. Non-compliance with or violation of the conditions herein set forth by a specific project may result in
revocation of this General Certification for the project and may also result in criminal and/or civil
penalties.
33. The permittee shall report to the Raleigh Regional Office at 919-791-4200 any noncompliance with
this Certification, any violation of stream or wetland standards [15A NCAC 02B .0200] including but
not limited to sediment impacts, and any violation of state regulated riparian buffer rules [15A NCAC
02B .0200]. Information shall be provided orally within 24 hours (or the next business day if a
weekend or holiday) from the time the applicant became aware of the circumstances. A written
submission shall also be provided within 5 business days of the time the applicant becomes aware of
the circumstances. The written submission shall contain a description of the noncompliance, and its
causes; the period of noncompliance, including exact dates and times, if the noncompliance has not
been corrected, the anticipated time compliance is expected to continue; and steps taken or planned
to reduce, eliminate, and prevent reoccurrence of the noncompliance. The Division may waive the
written submission requirement on a case -by -case basis.
This approval to proceed with your proposed impacts or to conduct impacts to waters as depicted in
your application shall expire upon expiration of the 404 Permit. The conditions in effect on the date of
issuance shall remain in effect for the life of the project, regardless of the expiration date of this
Certification. [15A NCAC 02H .0507(d)(2) and 15A NCAC 02H .0506]
This the 15th day of June 2020
DocuSoignn�e/d by:
�C�LLG 10
949D91BA53EF4E0...
Paul Wojoski, Supervisor
401 & Buffer Permitting Branch
SLH
WQC004230