NC0088510_Regional Office Historical File Pre 2018

Allocco, Marcia
From: Dawn C. Reeves <[e-mail]>
Sent: Monday, July 21, 2014 4:32 PM
To: Allocco, Marcia
Subject: Re: NPDES Permit - Bank of America
Attachments: image001.jpg; image003jpg
Thank you so much for the clarification ! We do not have any discharge connected to the storm drains.
Dawn C. Reeves, PE, LEED AP
Environmental Compliance
Lincoln Harris, CSG
525 North Tryon Street
NC1-023-05-54
Charlotte, NC 28255
980-388-2607 Direct
980-406-0566 Mobile
980-386-2940 Fax
www.Linc©InHarris.com<http://ww.Linco!nHarris.com>
On Jul 21, 2014, at 4:01 PM, "Allocco, Marcia" <[e-mail]<mailto:[e-mail]»
wrote:
Ms. Reeves,
A search of our database notes that a permit application was submitted for 100 N. College Street (assigned NPDES
permit #NC0088510 during permit development) but the permit application was withdrawn by the applicant in
November 2007. The Division was told the discharge was being directed to the CMUD sewer collection system as noted
below.
There is no active NPDES permit for this facility to discharge treated groundwater from this system to surface waters
(through the City's storm drain system); any such discharges would be an illicit discharge and an enforceable violation
under N. C. G.S. 143-215.1 unless permit coverage is obtained.
Regards,
Marcia
mage003.jpg>
From: Dawn C. Reeves [mailto:[e-mail]
Sent: Monday, July 21, 2014 3:31 PM
To: Allocco, Marcia
Subject: NPDES Permit - Bank of America
Marcia,
I'm hoping that you can help me or point me in the right direction. We are working with CMUD in Charlotte to
determine if we can discontinue a GroundWater Pre-treatment System. Based on criteria stipulated by the city in 2007,
1

a City of Charlotte Wastewater Discharge Permit was not required. CMUD has asked that we confirm if a NPDES Permit
was issued by NCDENR. The facility is located at 100 North College Street and is a Bank of America facility managed by
Lincoln Harris. I searched the on-line database but did not see any matches. Would you be able to confirm if a NPDES
Permit was issued for this site.
THANKS - Dawn
Dawn C. Reeves PE, LEED AP
Environmental Compliance
<image001.jpg>
Lincoln Harris, CSG
525 North Tryon Street NC1-023-05-54
Charlotte, NC 28255
980-388-2607 Direct 980-406-0566 Mobile
980-386-2940 Fax
www.lincolnharris.com<http://www.lincolnharris.com/>
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2

To: NPDES Unit
Water Quality Section
Attention: Jackie Nowell
SOC PRIORITY PROJECT: No
Date: October 15, 2007
NPDES STAFF REPORT AND RECOMMENDATIONS
County: Mecklenburg
NPDES Permit No.: NC0088510
PART I - GENERAL INFORMATION
Facility and mailing address: Bank of America/Superblock
200 North College Street, Suite 124 A
Charlotte, NC 28202
Physical address: 100 Block North College Street
Charlotte, NC 28202
2. Date of investigation: October 11, 2007
3 Report prepared by: Michael L. Parker, Environmental Engineer II
4. Person contacted and telephone number: No one
5. Directions to site: The site is located at the 100 block of College Street in the City of
Charlotte.
6. Discharge point(s), List for all discharge points: -
Latitude: 35° 13' 35"
Longitude: 80° 50' 34"
Attach a USGS Map Extract and indicate treatment plant site and discharge point on map.
USGS Quad No.: G15NE
7. Site size and expansion area consistent with application: Yes.
8. Topography (relationship to flood plain included): The site is relatively flat and well
removed from any flood plain.
9. Location of nearest dwelling: Approx. 1000+ feet from the site.

Page Two
10. Receiving stream or affected surface waters: UT to Sugar Creek
a. Classification: C
b. River Basin and Subbasin No.: Catawba 030834
c. Describe receiving stream features and pertinent downstream uses: The receiving
stream is a headwaters channel that originates near the center of Charlotte. The
channel was dry at the time of the site investigation. The stream passes through a
heavily developed portion of Charlotte prior to its confluence with the main
segment of Sugar Creek. There may be other downstream dischargers on this
segment with similar de -watering facilities. The main segment of Sugar Creek is
listed as a 303(d) impaired stream.
PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS
a. Volume of wastewater: 0.030 MGD (Design Capacity)
b. What is the current permitted capacity: N/A (new facility)
c. Actual treatment capacity of current facility (current design capacity): There are
no existing treatment facilities
d, Date(s) and construction activities allowed by previous ATCs issued in the
previous two years: N/A
e. Description of existing or substantially constructed WWT facilities: There are no
existing WWT facilities.
g.
Description of proposed WWT facilities: The applicant has no submitted a
proposal for any proposed WWT facilities at this time.
Possible toxic impacts to surface waters: Toxic impacts are unknown at this time.
Toxicity monitoring is proposed in the draft peiinit.
h. Pretreatment Program (POTWs only): N/A
2. Residual handling and utilization/disposal scheme: Residuals generation is not expected
from this discharge.
Treatment plant classification: Unknown at this time pending the need to install
wastewater treatment.
4. SIC Code(s): 9999 Wastewater Code(s): 66 MTU Code(s): N/A
PART III - OTHER PERTINENT INFORMATION
Is this facility being constructed with Construction Grant Funds or are any public monies
involved (municipals only)? No public monies will be used in the construction of this

Page Three
2. Special monitoring or limitations (including toxicity) requests: The Central Office is
recommending the monitoring for carbon tetrachloride and chloroform. based on
analytical testing performed in February 2007. This Office concurs with this
recommendation.
Important SOC/JOC or Compliance Schedule dates: N/A
4. Alternative analysis evaluation
a. Spray Irrigation: There is insufficient area on the site to construct a spray
irrigation treatment system.
b. Connect to regional sewer system: The local POTW has refused the applicant's
request to discharge this waste stream into the sewer collection system.
c. Subsurface: There is insufficient area onsite to install a subsurface disposal
system.
d. Other disposal options: None that we are aware.
PART IV - EVALUATION AND RECOMMENDATIONS
The applicant has requested approval to discharge contaminated GW from a site near the
center of Charlotte to a UT to Sugar Creek in Mecklenburg County. The GW contamination
originates from past uses of the site, which included a dry cleaning facility and a gas station. The
primary contaminants are solvents and volatile organic compounds.
There appears to be no other alternative to a discharge to surface waters at this location.
The discharge will enter the City of Charlotte's storm water drainage system and travel for a
distance of several hundred feet prior to reaching the receiving stream. The applicant did not
propose treatment of the contaminated GW prior to discharge, however, limits contained in the
draft permit may necessitate the installation of some type treatment facilities in order to comply
with current WQ standards.
Pending a final technical review of this request by the NPDES Unit, it is recommended
that an NPDES Permit be issued.
Signature of Repo
Preparer
ater Qua1j J$giona1 Supervisor
hAdsr\dsr07\BOAsuperdsr
ate

1 UJJiLU11%." t_l •-.,)1 .)}JJ 1Y1U
0 0.3 0.6 0.9 1.2 1.5 km
0 0.1 0.2 0.3 0.4 0.5 mi
UTM 17 514427E 3897945N (NAD27)
Charlotte, USGS Charlotte East (NC) Quadrangle
Projection is UTM Zone 17 NAD83 Datum
"bia OF INEKRA [SuIPE51,0CIC_
N1=-7.128
G=0.0'32

Michael F Easley, Governor
William G. Ross Jr„ Secretary
North Carolina Department of Environment and Natural Resources
Coleen H. Sullins, Director
Division of Water Quality
October 10, 2007
Mr. John Cassisi, P.E.
Bank of America
200 North College Street, Suite 124A
Charlotte, North Carolina 28214
Subject: NPDES Draft Permit
NPDES Permit NC0088510
Bank of America/SuperBlock
Mecklenburg County
Dear Mr. Cassisi:
The Division of Water Quality (DWQ) has received your application and has drafted a
NPDES permit for the above referenced facility. The draft permit authorizes Bank of America to
discharge treated groundwater from the SuperBlock to the UT Little Sugar Creek, a class C water
in the Catawba River Basin. The draft permit includes discharge limitations /or monitoring for
flow, total suspended solids ), benzene, phenol, toluene, carbon tetrachloride, chronic toxicity
and several other parameters.
Prior to discharge. Bank of America SuperBlock must obtain an authorization to construct
permit from DWQ's Construction Grants and Loans section.
At this time, the Division is submitting a notice to the newspapers of general circulation in
Mecklenburg County, inviting comments from you or your representative, the public and other
agencies on the draft permit. The notice should be published on or about October 17, 2007.
Following a 30-day comment period, we will review all pertinent comments received and take
appropriate action on the permit issuance.
Please provide written comments on the draft permit no later than November 10, 2007.
If you have any questions, please contact me at [phone], extension 512.
Attachments
cc: Mooresville Regional Office/Surface Water Protection Section
Aquatic Toxicology Unit
NPDES File
NC DENR MR0
DWQ-Surface Water Protection
one
othCaro1ina
urally
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone] Customer Service
Internet: www.ncwaterquality.org Location: 512 N. Salisbury St Raleigh, NC 27604 Fax [phone]
An Equal Opportunity/AffirmaNe Action Employer — 50% Recycled/10% Post Consumer Paper

Permit NC0088510
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
DRAFT PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
(NPDES)
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards
and regulations promulgated and adopted by the North Carolina Environmental Management
Commission, and the Federal Water Pollution Control Act, as amended,
Bank Of America
is hereby authorized to discharge remediated groundwater from outfalls located at the
SuperBlock
100 Block of North College Street
Charlotte
Mecklenburg County
to receiving waters designated as an unnamed tributary to Little Sugar Creek in the Catawba River Basin
in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts
I, II, III and IV hereof.
This permit shall become effective xxxxxxxxxxxxx.
This permit and authorization to discharge shall expire at midnight on June 30, 2010.
Signed this day XXxxXxXXxxXxxX.
Coleen H. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit NC0088510
SUPPLEMENT TO PERMIT COVER SHEET
Bank of America
is hereby authorized to:
After receiving an Authorization to Construct permit for a groundwater treatment facility not to
exceed 0.030 MGD, construct and operate the SuperBlock, located in the 100 Block of North
College Street, Charlotte, Mecklenburg County, and
2. Discharge groundwater from said treatment facility through Outfall 001 at a specified location on the
attached map into an unnamed tributary to Little Sugar Creek, a Class C waterbody located within
the Catawba River Basin.

--Dischars a Point
Quad: Charlotte East, N.C.
Latitude: 35°13'34"
Longitude: 80°50'28"
Stream Class: C
Subbasin: 030834
Receiving Stream: UT Little Sugar Creek
NC©©8851©
Bank of
America/SuperBlock
SCALE 1:24000

Permit NC0088510
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - DRAFT
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is
authorized to discharge remediated/treated groundwater from outfall ON. Such discharges shall be limited
and monitored by the Permittee as specified below:
EFFLUENT
CHARACTERISTICS
Flowl
Total Suspended Solids
Phenol
Benzene
Toluene
Ethyl benzene
Total Xylenes
Naphthalene
Methyl Tertiary -Butyl Ether
(MTBE)
Total Lead2
1,2 Dichloroethane3
Carbon tetrachloride
Chloroform
Chronic Toxicity4
Monthly
Average
0.030 MGD
TS
Daily
Maximum
30.0 mg/L
1.6 p.g/L
MONITORING REQUI
Measurement
Frequency
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Quarterly
Sample
Type
MENTS
Sample
Location
Meter Effluent
Grab Effluent
Grab Effluent
Grab Effluent
Grab Effluent
Grab Effluent
Grab Effluent
Grab Effluent
Grab Effluent
Grab Effluent
Grab Effluent
Grab Effluent
Grab Effluent
Grab Effluent
Footnotes:
1. Flow may be monitored by a flow meter on the effluent side of the system.
2. Monitoring for Total Lead may be discontinued for the remainder of the permit term, if lead is not
detected above the practical quantitation level (10 µg/L) for the first eight sampling events.
3. Monitoring for 1,2-Dichloroethane may be discontinued for the remainder of the permit term, if
1,2-Diehloroethaneis not detected above the practical quantitation level (0.25 p.g/L) for the first
eight sampling events.
4. Chronic Toxicity (Fathead Minnow, 24-hour), Annual [see Special Condition A.(2.)].
There shall be no discharge of floating solids or foam visible in other than trace amounts.

Permit NC0088510
EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
SPECIAL CONDITIONS
A. (2) CHRONIC TOXICITY PERMIT LIMIT (QRTRLY)
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to
Ceriodaphnia dubia at an effluent concentration of 90%.
The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined in the "North
Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised February 1998, or subsequent versions or
"North Carolina Phase Q Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or
subsequent versions. The tests will be performed during the months of January, April, July and October.
Effluent sampling for this testing shall be performed at the NPDES permitted final effluent discharge below all
treatment processes.
If the test procedure performed as the first test of any single quarter results in a failure or ChV below the
permit limit, then multiple -concentration testing shall be performed at a minimum, in each of the two
following months as described in "North Carolina Phase II Chronic Whole Effluent Toxicity Test
Procedure" (Revised -February 1998) or subsequent versions.
The chronic value for multiple concentration tests will be determined using the geometric mean of the highest
concentration having no detectable impairment of reproduction or survival and the lowest concentration that does
have a detectable impairment of reproduction or survival. The definition of "detectable impairment," collection
methods, exposure regimes, and further statistical methods are specified in the "North Carolina Phase II Chronic
Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge
Monitoring Form (MR-1) for the months in which tests were performed, using the parameter code TGP3B for the
pass/fail results and THP3B for the Chronic Value. Additionally, DWQ Form AT-3 (original) is to be sent to the
following address:
Attention: North Carolina Division of Water Quali
Environmental Sciences Section
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Section no later than 30
days after the end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements and all
concentration/response data, and be certified by laboratory supervisor and ORC or approved designate
signature. Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is
employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required,
the permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating the
facility name, permit number, pipe number, county, and the month/year of the report with the notation of "No
Flow" in the comment area of the form. The report shall be submitted to the Environmental Sciences Section at
the address cited above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required, monitoring will be
required during the following month.

Permit NC0088510
Should any test data from this monitoring requirement or tests performed by the North Carolina Division of
Water Quality indicate potential impacts to the receiving stream, this permit may be re -opened and modified to
include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism
survival, minimum control organism reproduction, and appropriate environmental controls, shall constitute an
invalid test and will require immediate follow-up testing to be completed no later than the last day of the month
following the month of the initial monitoring.

Appli
DENR/DWQ
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES No. NC0088510
t/Facili
Applicant Address:
Facility Address:
Permitted Flow
Type of Waste:
Name:
Facility/Permit Status:
Facility Classification
County:
Receiving Stream:
Stream Classification:
303(d) Listed?:
Subbasin:
Drainage Area (mi2):
Summer 7Q 10 (cfs)
Winter 7910 (cfs):
Average Flow (cfs):
IWC (%):
Primary SIC Code:
Facility Information
Bank of America/SuperBlock
200 North College Street, Suite 124A Charlotte, NC 28202
100 Block of North College Street Charlotte, NC 28202
0.030 MGD
Groundwater Remediation
New
Mecklenburg
Miscellaneous
Little Sugar
Creek
Regional Office:
Mooresville
C
Yes
030834
NA
NA
NA
NA
100
USGS Topo Quad:
Permit Writer:
Date:
F15SE
Jackie Nowell
09/24/2007
SUMMARY OF FACILITY INFORMATION AND WASTELOAD ALLOCATION
Bank of America is applying for a NPDES permit for a groundwater remediation project. A
construction site will be dewatered. Historically several businesses have been on the site over
the many years and include a parking lot, a wax manufacturing facility, a gasoline station, a
dry cleaning facility, an auto supply facility, a cotton warehouse, and a printing and newspaper
facility. Preliminary results of the groundwater sampling indicate that volatile organic
compounds have exceeded groundwater standards. There is the possibility that soil and
groundwater contamination exists from prior developments on the site.
Water collected from the site would discharge to a stoi ui drain which discharges to Little Sugar
Creek.
RECEIVING STREAM INFORMATION:
Little Sugar Creek is listed on North Carolina's 2006 303(d) impaired streams list for fecal
coliform.
Estimations for QA, summer and winter 7Q10 flows are zero for Little Sugar Creek.
EAA GUIDANCE:
Groundwater Remediation System Discharges. You will need to evaluate whether WWTP
connection, land application, and infiltration galleries are viable disposal alternatives. While
land application might be a feasible alternative in rural areas, it would not be a feasible
alternative in downtown Charlotte, where there is no land available for wastewater
application. In this instance, you may simply state that land application is infeasible based
on land constraints within the city. You will also need to evaluate connection to an existing
WWTP (in accordance with Alternative A), since there are some municipalities that have
accepted this wastestream in the past. If the municipality will not accept the wastestream,
the connection alternative is also considered technologically infeasible.
Bank of America/SuperBlock included letter from Charlotte Mecklenburg Utilities that stated it
would not accept the remediated groundwater from this project.

INSTREAM MONITORING:
This is a new facility with no historical instream monitoring data.
TOXICITY TEST RESULTS:
N/A - Will recommend chronic quarterly toxicity test per guidance for GW remediation projects.
PRIORITY POLLUTANT ANALYSIS RESULTS:
Results of sample taken 2/2007:
• 2-butanone (MEK) - 6.7 ug/1 ---No NC Standard; No Federal Criteria
• carbon tetrachloride - 3.6 ug/1 --- Human health standard of 1.6 ug/l. With no dilution
instream, this sample would violate the WQ standard.
chloroform - 3.6 ug/1 --- No NC Standard: Federal Criteria for Human Health (Organism
Only) = 470 ug/1
• di-n-butylphthalate - 13 ug/1 --- No NC Standard (this is considered a laboratory
contaminant)
• Oil and Grease - <5 ug/1
• pH - 6.73 SU
• PCBs (polychlorinated biphenyls) - All <1.0 ug/1
• Barium - 31 ug/1 ---- No NC Standard for Class C waters
• Arsenic - <5 ug/1
• Cadmium - <1 ug/1
• Chromium - <5 ug/1
• Lead - <5 ug/1
• Mercury - <0.2 ug/1
• Selenium - <10 ug/1
• Silver - <5 ug/1
•
COMPLIANCE REVIEW:
NA
REASONABLE POTENTIAL ANALYSIS
Did not run RPA. Per BPJ, UT Little Sugar Creek has an estimated streamflow of 0 cfs. There
was only one data point for most parameters. Only carbon tetrachloride had a hit above the
standard. Recommended a limit for that parameter based on that one value.
Recommended monitoring for chloroform based on one hit.
PROPOSED CHANGES:
NA
PROPOSED SCHEDULE FOR PERMIT ISSUANCE:
Draft Permit to Public Notice: 10/10/2007
Permit Scheduled to Issue: 12/10/2007
Projected Effective Date of Permit: 01/01/2008
STATE CONTACT:
If you have any questions on any of the above information or on the attached permit, please
contact Jackie Nowell at [phone] ext. 512.
NAME: DATE:

REGIONAL OFFICE COMMENT:
NAME: DATE:
NPDES SUPERVISOR COMMENT:
NAME: DATE:

LETTER OF TRANSMITTAL
Ms. Susan Wilson
NCDENR/DWQ/NPDES Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
REFERENCE: NPDES Permit Application
100 Block of North College Street
Charlotte, North Carolina
March 16, 2007
ECS Project No, 08-4158D
ECS is enclosing the following item(s):
1 Copy(ies) of Report/Forms: Transmitted Via:
NPDES Permit Application Letter Fed Ex
NPDES Permit Application — Short Form - GW X Regular Mail
Site Location Map
Groundwater Analytical Data Table
MESSAGE:
Ms. Wilson,
ECS is enclosing the NPDES permit application prepared on behalf of Bank of America c/o Centex
Construction, for the construction site located at the 100 Block of North College Street. Attached
with this transmittal is a reply from the Charlotte Mecklenburg Utility Department (CMUD) denying
a request to grant a temporary discharge permit for treated groundwater to the City of Charlotte
wastewater collection system. Please note that the USGS streamflow data is not available at this
time. Once we have received this information we will forward it to your attention.
If you have any questions, please give us a call at [phone].
Thank you.
Sincerely,
urnar G. Bindiganavile, E.
Project Manager
S. Lair, P.G.
pal Geologist
ECS CAROLINAS, LLP
8702-A Red Oak Boulevard, Charlotte, North Carolina 28217
Phone: [phone] FAX: [phone]

ECS CAROLINAS, LLP
Geotechnical • Cons
truc,tion
Ms. Susan Wilson
NCDENR/DWQ/NPDES Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Reference: NPDES Permit Application
100 Block of North College Street
Charlotte, North Carolina
Dear Ms. Wilson:
ECS Carolinas, LLP
a NPDES permit be
the above referenced
Background Info
arerral • Environmental
March 16, 2007
ECS Project 08-4158D
(ECS) on behalf of Bank of America c/o Centex Construction, is requesting
issued for groundwater generated during dewatering activities proposed at
construction site.
io
The subject site is currently undergoing redevelopment (former parking lot)and
100 block of North College Street within the downtown business district of
Carolina. A dewatering system has been installed for is located in the
determine groundwater quality. Preliminary results of the construction purposes and was sampled to
Charlotte, North
groundwater volatile organic compounds (VOCs) exceed the North Carolina Department sampling Natural
Re ources
(NCDENR) 2L groundwater standard, rural Resources
Previous environmental and engineering investigations have been conducted
review of the previously conducted Phase I Environmental Site Assessment report
N©•08-3522A dated April 7, 2006) indicates that the site has ©n the site. A
The site was historically developed with a parking lot (1986 top (ECS p '
been developed since at leas 1885
a
facility (1960 to 1986), a gasoline station (1955-196©),a dry cleaning facility (1951-1955),manufa
automobile supplies facility (1929-1951), a cotton warehouse 1900-1ag
newspaper facility (1885-1900). Although there is no documentationy an
or
removal of petroleum USTs associated with the2regarding pthe printing
eand
other contaminants associated with former dry-cleaners gasoline
te pate tior the use of solvents d
groundwater contamination to exist from prior developments on the potential exists for soil and
The water collected from the site would discharge to the storm drain located
the intersection of North College Street and East Trade Street. Figure 2 shows
discharge location. The storm drains discharges to ©n the east corner of
roximate
estimated to be one to two years to complete. g the Little Sugar Creek. The project is
8702 Red Oak Boulevard,
Suite A, Charl atte, North Carolina 28217 .
704-55-515 Fax: 904-5-7t7
imited.com

NPDES Permit Application
100 North College Street
Charlotte, North Carolina
ECS Project 08-4158D
March 16, 2007
Engineering Alternative Analysis
Evaluation of potential restrictions to a wastewater discharge to surface waters
Streamflow data at the proposed discharge location is not available at this time. It will be
submitted as soon as it becomes available.
Little Sugar Creek is a Class C waterway. Therefore, there are no restrictions on watershed
development or types of discharges.
A review of the Catawba River Basinwide Water Quality Plan dated September 2004 and
prepared by Mr. Dave Toms with the NC Department of Environment & Natural Resources,
Division of Water Quality — Planning does not list NPDES permitting strategies that limit
wastewater discharges to particular streams within the basin.
Little Sugar Creek is on the 303(d) list as an impaired waterway. There is a Total Maximum
Daily Load (TMDL) for fecal coliform of 9.4x1012 cfu/100 ml. Based on the project description
and site contaminants, it is not anticipated that fecal coliform will be discharged into the storm
sewer.
Endangered species are not present in the proposed discharge location. Estimated treatment
design flow is 0.03 MGD.
Non -Municipal Flow Projections
Until operations commence, a reasonable flow projection cannot be determined.
Evaluation of technologically feasible alternatives
Alternative A. Connection to an Existing Wastewater Treatment System
Charlotte -Mecklenburg Utilities is responsible for the sanitary sewer system for the subject site.
They do not accept groundwater, stormwater, or other discharges to the sanitary sewer. A letter
from Charlotte -Mecklenburg Utility Department (CMUD) denying a request for temporary
discharge permit of treated groundwater to the City of Charlotte sanitary sewer system is
attached.
Alternative B. Land Application
Land application would not be a feasible alternative in downtown Charlotte based on land
constraints within the city.
Alternative C. Infiltration Galleries
This alternative cannot be properly evaluated until there is a clear definition of the contaminant
level and flow projections. Once dewatering begins, this alternative will be evaluated.

NPDES Permit Application
100 North College Street
Charlotte, North Carolina
ECS Project 08-4158D
March 16, 2007
Alternative D. In -Situ Groundwater Remediation Wells
In -situ groundwater remediation wells would not be a feasible alternative for this site because the
site is being dewatered; a remediation system is not being constructed.
Alternative E. Closed -Loop Groundwater Remediation Wells
Closed -loop groundwater remediation wells would not be a feasible alternative for this site
because the site is being dewatered; a remediation system is not being constructed,
Alternative F. Direct Discharge to Surface Waters
Direct discharge to the surface water is feasible for this site. Storm drains are located in the
vicinity of the site. The discharge to the storm drain will not create a hazardous condition. Other
considerations have been met as described previously.
Alternative F, direct discharge to surface waters is the most viable option at this time.
If you have any questions or comments, please do not hesitate to contact ECS at [phone].
Sincerely,
ECS-CAROLINAS, LLP
Kumar G. Bindiganavile, E.I.
Project Manager
Attachments:
1. USGS Topographic Map.
2. Site Map and Dewatering Well Locations.
3. Analytical results on sample of dewatering system water taken during
the pumping test.
4. Letter from the Charlotte -Mecklenburg Utility Department (CMUD).
CC: Mr. Scott Jones, Centex Construction
P.G.
pal Geologist

NPDES PERMIT APPLICATION - SHORT FORM C - GW
For discharges associated with groundwater treatment facilities.
Mail the complete application to:
N. C. Department of Environment and Natural Resources
Division of Water Quality / NPDES Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
NPDES Permit Number
NCO° IN.5 /
If you are completing this form in computer use the TAB key or the up - down arrows to move from one
field to the next. To check the boxes, click your mouse on top of the box Otherwise, please print or type.
1. Contact Information:
Owner Name
Facility Name
Mailing Address
City
State / Zip Code
Telephone Number
Fax Number
e-mail Address
Bank of America - Mr. John Cassisi - Authorized Agent.
SuperBlock
200 North College Street, Suite 124A
Charlotte
North Carolina 28202
[phone]
[phone]
[e-mail]
2. Location of facility producing discharge:
Check here if same as above 0
Street Address or State Road
100 Block of North College Street
City Charlotte
State / Zip Code
County
NC, 28202
Mecklenburg County
3. Operator Information:
Name of the firm, consultant or other entity that operates the facility. (Note that this is not referring to the
Operator in Responsible Charge or ORC)
Name
Mailing Address
City
State / Zip Code
Telephone Number
Fax Number
4. Ownership Status:
Federal El
ECS Carolinas, LLP - Attention:Kumar G. Bindiganavile, E.I.
8702 Red Oak Boulevard, Suite A
Charlotte
NC 28217
[phone]
[phone]
State El
Private Public 0
Page 1 of 3
C-GW 03/05

NPDES PERMIT APPLICATION - SHORT FORM C GW
For discharges associated with groundwater treatment facilities.
5. Products recovered:
Gasoline El Diesel fuel E]
Compounds
Solvents Ei
Other Volatile Organic
6. Number of separate discharge points: 1
Outfall Identification number(s) NA
7. Frequency of discharge: ContinuousIntermittent 0
If intermittent:
Days per week discharge occurs: Seven days a week Duration: 1-2
Years
8. Treatment System Design flow 0.03 MGD
9. Name of receiving stream(s) (Provide a map showing the exact location of each outfall, including
latitude and longitude):
Little Sugar Creek
10. Please list all additives to the treatment system, including chemicals or nutrients, that have
the potential to be discharged.
N/A
11. Is this facility located on Indian country? (check one)
Yes Ej No El
12. Additional Information
All applicants (including renewals):
A USGS topographical map (or copy of the relevant portion) which shows all outfalls
A summary of the most recent analytical results (effluent data, if available) containing the
maximum values for each chemical detected
NEW Applicants only:
Engineering Alternative Analysis
Description of remediation treatment system components, capacities, and removal efficiency
for detected compounds.
If the treatment system will discharge to a storm sewer, written approval from the
municipality responsible for the sewer.
A list of any chemicals found in detectable amounts at the site, with the maximum observed
concentration reported for each chemical (the most recent sample must be collected less
than one year prior to the date of this application)
For petroleum -contaminated sites - Analyses for Volatile Organic Compounds (VOC) should
be performed. Analyses for any fuel additives likely to be present at the site and for phenol
and lead should also be performed.
For sites contaminated with solvents or other contaminants - EPA Method 624/625
analysis should be performed.
Page 2 of 3
C-GW 03/05

NPDES PERMIT APPLICATION - SHORT FORM C - GW
For discharges associated with groundwater treatment facilities.
13. Applicant Certification
I certify that I am familiar with the information contained in the application and that to the
best of my knowledge and belief such information is true, complete, and accurate.
Jotin CksS (S; P.
Printed name of Person Signing
3
Sign re of Applicant Date
Pros (TX 1- T
No i( Carolina General Statute 143-215.6 (b)(2) provides that: Any person who knowingly makes any false
statement representation, or certification in any application, record, report, plan, or other document files or
required to be maintained under Article 21 or regulations of the Environmental Management Commission
implementing that Article, or who falsifies, tampers with, or knowingly renders inaccurate any recording or
monitoring device or method required to be operated or maintained under Article 21 or regulations of the
Environmental Management Commission implementing that Article, shall be guilty of a misdemeanor punishable
by a fine not to exceed $25,000, or by imprisonment not to exceed six months, or by both. (18 U.S.C. Section
1001 provides a punishment by a fine of not more than $25,000 or imprisonment not more than 5 years, or both,
for a similar offense.)
Page 3 of 3
C-GW 03/05

SOURCE:
United States Geological Survey 7.5- Minute
Series Topographic Quadrangle Maps
Charlotte East dated 1967
revised 1988
Scale: 1"=2,000'
FIGURE 1
USGS Topographic Map
SuperBlock
100 N. College Street
Charlotte, North Carolina
ECS PROJECT NO. 08-4158D

Location for dewatering discharge location sewer
outfall
SOURCE:
Mecklenburg County Property Ownership Land
Records Information System (POLARIS)
http: //maps2, co.mecklenburg. nc. us/website/realest
ate/viewer.htm
Scale: As Shown
ing Wells and Piping
FIGURE 2
Site Map and Dewatering Well location
SuperBlock
North College Street & East Trade Street
Charlotte, North Carolina l�
I
ECS Project No. 08-4158©

LABORATORY DATA SHEETS

rua—aaa—arbtl T-051 P102/002 F-442
r
CHARLOTTEsM
March 16, 2007
Mr. John S. Lair
ECS Carolinas, LLP,.
8702 Red ©aklvd
Suite A
Charlotte, NC 28217
SUBJECT: WO N. College Street Development, Charlotte NC
t)ez:'r . r. Lair
s requestedvby ECS Carolinas, LLP, the Charlotte Mecklenburg Utility Department -System Protection Section is
.denying a request for a special "Ground Water Discharge Permit to the City of Charlotte Wastewater Collection
System". ` As stipulated in the City of Charlotte Sewer Use Ordinance in Section 23-79, ground water, and
surface. rater run off are prohibited general standards.
As a result, ECS Carolinas LLP will have to find other engineered means of disposal for the ground water at the
100 N. College Street location. Examples of other engineered means are pump and hauled methods of
treatment, or an application for a North Carolina NPDES, which would enable the 100 N. College Street location
the akfiity to discharge to the surface waters of Charlotte.
Tha :MU.: -SPS appreciate the notification received from ECS Carolinas regarding the ground water discharge
may :ers. For further discussion or if you have any questions please call Michael R. Korzelius (Mike) at 704-391-
:31 66, Thank you for your cooperation.
mince
Mictawr P„ Ka
Erwironrr ntaI,Managernent Division
Charlotte Mecklenburg Utility Department
ivision 5100 Brookshire Blvd. Charlotte, NC 28216 Phone: [phone] Fax: [phone]
Charlotte -Mecklenburg Utilities

Table 1
Summary of Groundwater Analytical Results
Superblock Site
100 North College Street
Charlotte, North Carolina
ECS Job No: 08-4158C
Sample ID:
Sample Date:
Units:
Parameter (Method)
VOCs (8260)
2-butanone (MEK)
carbon tetrachloride
chloroform
SVOCs (8270)
di-n-butylphthalate
Oil & Grease (166444)
pH(150.1)
PCBs (8082)
Metals (6010/7470)
arsenic
barium
cadmium
chromium
lead
mercury
selenium
silver
WS-1
02/14/2007
µg/1
6.7
3.6
3.6
13
<5.0
6.73
All <1.0
<5.0
31
<1.0
<5.0
<5.0
<0.20
<10
<5
Notes:
VOCs = volatile organic compounds
SVOCs = semi -volatile organic compounds
PCBs = polychlorinated biphenyls
NS = no standard
Only those compounds detected above laboratory method detection
Values in bold print exceed 21, groundwater standard
File: I:\IENV1PR©JECTS14000-4999141.58C - SuperBlock Groundwater Activities\table.xls
Date: 02/21/2007
NCAC 2L
Groundwater
Standards
4,200
0.269
70
700
NS
6.5 - 8.5
NS
50
2,000
1.75
50
15
1.05
50
17.5
•

Michael F. Easley, Governor
William G. Ross
North Carolina Denar xtent ol'Environment and Na
Coleen H. Sullins, Di
Division of Water Quality
October 10, 2007
Mr. John Cassisi, P.E.
Bank of America
200 North College Street, Suite 124A
Charlotte, North Carolina 28214
Subject: NPDES Draft Permit
NPDES Permit NC0088510
Bank of America/SuperBlock
Mecklenburg County
Dear Mr. Cassi
The Division of Water Quality (DWQ) has received your application and has drafted a
NPDES permit for the above referenced facility. The draft permit authorizes Bank of America to
discharge treated groundwater from the SuperBlock to the UT Little Sugar Creek, a class C water
in the Catawba River Basin. The draft permit includes discharge limitations /or monitoring for
flow, total suspended solids (TSS), benzene, phenol, toluene, carbon tetrachloride, chronic toxicity
and several other parameters.
Prior to discharge, Bank of America SuperBlock must obtain an authorization to construct
permit from DWQ's Construction Grants and Loans section.
At this time, the Division is submitting a notice to the newspapers of general circulation in
Mecklenburg County, inviting comments from you or your representative, the public and other
agencies on the draft permit. The notice should be, published on or about October 17, 2007.
Following a 30-day comment period, we will review all pertinent comments received and take
appropriate action on the permit issuance.
Please provide written comments on the draft permit no later than November 10, 2007.
If you have any questions, please contact me at [phone], extension 512.
Attachments
cc:
Aquatic Toxicology Unit
NPDES File
Surface Water Protection Section
OCT 1 1 2007
NC DENR MRQ
DWQ-Surface Water
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone] Customer Service
Internet: www.ncwaterquality.org Location: 512 N. Salisbury St. Raleigh, NC 27604 Fax [phone]
An Equal Opportunity/Affirmative Action Employer — 50% Recycled/10% Post Consumer Paper

Permit NC0088519
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
DRAFT PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
(NPDES)
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards
and regulations promulgated and adopted by the North Carolina Environmental Management
Commission, and the Federal Water Pollution Control Act, as amended,
Bank Of America
is hereby authorized to discharge remediated groundwater from outfalls located at the
SuperBlock
100 Block of North College Street
Charlotte
Mecklenburg County
to receiving waters designated as an unnamed tributary to Little Sugar Creek in the Catawba River Basin
in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts
I, II, 111 and IV hereof.
This permit shall become effective xxxxxxxxxxxxx.
This permit and authorization to discharge shall expire at midnight on June 30, 2010.
Signed this day xXXxxxxxxxxxxx.
Coleen H. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit NC0088510
SUPPLEMENT TO PERMIT COVER SHEET
Bank of America
is hereby authorized to:
After receiving an Authorization to Construct permit for a groundwater treatment facility not to
exceed 0.030 MGD, construct and operate the SuperBlock, located in the 100 Block of North
College Street, Charlotte, Mecklenburg County, and
2. Discharge groundwater from said treatment facility through Outfall 001 at a specified location on the
attached map into an unnamed tributary to Little Sugar Creek, a Class C waterbody located within
the Catawba River Basin.

Quad: Charlotte East, N.C.
Latitude: 35'13'34"
Longitude: 80'50'28"
Stream Class: C
Subbasin: 030834
Receiving Stream: UT Little Sugar Creek
NC0088510
Bank of
America/SuperBlock
SCALE 1:24000

Permit NC0088510
A. (1.) EFFLUENT LIMITATIONS AND M©NIT©RING REQUIREMENTS - DRAFT
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is
authorized to discharge remediated/treated groundwater from outfall 00L Such discharges shall be limited
and monitored by the Permittee as specified below:
Flow
0.030 MGD
MONITORING RE#
Monthly
Meter
NTS
Effluent
Total Suspended Solids
Phenol
Benzene
Toluene
Ethyl benzene
Total Xylenes
Naphthalene
Methyl Tertiary -Butyl Ether
(MTBE)
Total Lead2
30.© mg/L
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
1,2 Dichloroethane
Carbon tetrachloride
1.6 µg/L
Monthly
Monthly
Grab
Grab
Effluent
Effluent
Chloroform
Chronic Toxicity4
Monthly
Quarterly
Grab
Grab
Effluent
Effluent
Footnotes:
1. Flow may be monitored by a flow meter on the effluent side of the system.
2. Monitoring for Total Lead may be discontinued for the remainder of the permit term, if lead is not
detected above the practical quantitation level (1©µg/L) for the first eight sampling events.
Monitoring for 1,2-Dichloroethane may be discontinued for the remainder of the permit term, if
1,2-Dichloroethaneis not detected above the practical quantitation level (0.25 µg/L) for the first
eight sampling events.
4. Chronic Toxicity (Fathead Minnow, 24-hour), Annual [see Special Condition A.(2.)].
There shall be no discharge of floating solids or foam visible in other than trace amounts.

Permit NC0088510
EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
SPECIAL CONDITIONS
A. (2) CHRONIC TOXICITY PERMIT LIMIT (QRTRLY)
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to
Ceriodaphnia dubia at an effluent concentration of 90%.
The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined in the "North.
Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised February 1998, or subsequent versions or
"North. Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or
subsequent versions. The tests will be performed during the months of January, April, July and October.
Effluent sampling for this testing shall be performed at the NPDES permitted final effluent discharge below all
treatment processes.
If the test procedure performed as the first test of any single quarter results in a failure or ChV below the
permit limit, then multiple -concentration testing shall be performed at a minimum, in each of the two
following months as described in "North Carolina Phase II Chronic Whole Effluent Toxicity Test
Procedure" (Revised -February 1998) or subsequent versions.
The chronic value for multiple concentration tests will be determined using the geometric mean of the highest
concentration having no detectable impairment of reproduction or survival and the lowest concentration that does
have a detectable impairment of reproduction or survival. The definition of "detectable impairment," collection
methods, exposure regimes, and further statistical methods are specified in the "North Carolina Phase II Chronic
Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge
Monitoring Form (MR-1) for the months in which tests were performed, using the parameter code TGP3B for the
pass/fail results and THP3B for the Chronic Value. Additionally, DWQ Form AT-3 (original) is to be sent to the
following address:
Attention: North Carolina Division of Water Quail
Environmental Sciences Section
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Section no later than 30
days after the end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements and all
concentration/response data, and be certified by laboratory supervisor and ORC or approved designate
signature. Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is
employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required,
the permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating the
facility name, permit number, pipe number, county, and the month/year of the report with the notation of `No
Flow" in the comment area of the form. The report shall be submitted to the Environmental Sciences Section at
the address cited above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required, monitoring will be
required during the following month.

Permit NC0088510
Should any test data from this monitoring requirement or tests performed by the North Carolina Division of
Water Quality indicate potential impacts to the receiving stream, this permit may be re -opened and modified to
include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism
survival, minimum control organism reproduction, and appropriate environmental controls, shall constitute an
invalid test and will require immediate follow-up testing to be completed no later than the last day of the month
following the month of the initial monitoring.

Aplicari
Applic
Faci
DENR/DWQ
FACT SHEET FOR NPDES PERMIT DE
NPDES No. NC0088510
a %l iy N rn :
Addre
Address:
Permitted Flow
1#acili
as
/Permit
aility lasi
County:
tus:
ation
Fa+c'
Bank of
a
on
SuperBlock
PENT
200 North College Street, Suite 124A Charlotte, NC 28202
100 Block of North College Street Charlotte, NC 28202
0.030 MGD
Groundwater Remediation
New
Mecklenburg
Mscel]
sous
Receiving Stream:
Stream Clasification:
3Q3(d)
d
Subbasirr:
Drainage
rea'(mi2):
Summer 7Q10 (cfs)
Winter 7910
Average
c;
ow (cfs):
I C (. o):
SIC Code:
le Sugar
ek
Yes
030834
NA
NA
NA
NA
100
e:
USGS Tc po Quad:
Date:
Mooresville
F15SE
Jackie Nowell
09/24/2007
SUMMARY OF FACILITY INFORMATION AND WASTELOAD ALLOCATION
Bank of America is applying for a NPDES permit for a groundwater remediation project. A
construction site will be dewatered. Historically several businesses have been on the site over
the many years and include a parking lot, a wax manufacturing facility, a gasoline station, a
dry cleaning facility, an auto supply facility, a cotton warehouse, and a printing and newspaper
facility. Preliminary results of the groundwater sampling indicate that volatile organic
compounds have exceeded groundwater standards. There is the possibility that soil and
groundwater contamination exists from prior developments on the site.
Water collected from the site would discharge to a storm drain which discharges to Little Sugar
Creek.
RECEIVING STREAM INFORMATION:
Little Sugar Creek is listed on North Carolina's 2006 303(d) impaired streams list for fecal
coliform.
Estimations for QA, summer and winter 7Q10 flows are zero for Little Sugar Creek.
EAA GUIDANCE:
Groundwater Remediation System: Discharges. You will need to evaluate whether WWTP
connection, land application, and infiltration galleries are viable disposal alternatives. While
land application might be a feasible alternative in rural areas, it would not be a feasible
alternative in downtown Charlotte, where there is no land available for wastewater
application. In this instance, you may simply state that land application is infeasible based
on land constraints within the city. You will also need to evaluate connection to an existing
WWTP (in accordance with Alternative A), since there are some municipalities that have
accepted this wastestream in the past. If the municipality will not accept the wastestream,
the connection alternative is also considered technologically infeasible.
Bank of America/SuperBlock included letter from Charlotte Mecklenburg Utilities that stated it
would not accept the remediated groundwater from this project.
Bark o'..''mff;calti„perBkx

INSTREAM MONITORING:
This is a new facility with no historical instream monitoring data.
TOXICITY TEST RESULTS:
N/A - Will recommend chronic quarterly toxicity test per guidance for GW remediation projects.
PRIORITY POLLUTANT ANALYSIS RESULTS:
_Results of sample taken 2/2007:
• 2-butanone (MEK) - 6.7 ug/1 ---No NC Standard; No Federal Criteria
• carbon tetrachloride - 3.6 ug/1 --- Human health standard of 1.6 ug/1. With no dilution
instream, this sample would violate the WQ standard.
• chloroform - 3.6 ug/1 --- No NC Standard: Federal Criteria for Human Health (Organism
Only) = 470 ug/1
■ di-n-butylphthalate - 13 ug/1--- No NC Standard (this is considered a laboratory
contaminant)
• Oil and Grease - < 5 ug/1
• pH - 6.73 SU
• PCBs (polychlorinated biphenyls) - All <1.0 ug/1
• Barium - 31 ug/1 ---- No NC Standard for Class C waters
• Arsenic - <5 ug/1
• Cadmium - <1 ug/1
• Chromium - <5 ug/1
• Lead - <5 ug/1
• Mercury - <0.2 ug/1
• Selenium - <10 ug/1
• Silver - <5 ug/1
•
COMPLIANCE REVIE
NA
REASONABLE POTENTIAL ANALYSIS
Did not run RPA. Per BPJ, UT Little Sugar Creek has an estimated streamflow of 0 cfs. There
was only one data point for most parameters. Only carbon tetrachloride had a hit above the
standard. Recommended a limit for that parameter based on that one value.
Recommended monitoring for chloroform based on one hit.
PROPOSED CHANGES:
NA
PROPOSED SCHEDULE FOR PERMIT
Draft Permit to Public Notice:
Permit Scheduled to Issue:
Projected Effective Date of Permit:
SUANCE:
10/10/2007
12/10/2007
01/01/2008
STATE CONTACT:
If you have any questions on any of the above information or on the attached pe
contact Jkie Nowell at [phone] ext. 512.
DATE:
t, please

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