NC0004308_SOC MEMO_20180829

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Interim Director
MEMORANDUM
To: Jeff Poupart
Through: John Hennessy
From: Derek Denard�V'
NORTH CAROLINA
Environmental Quality
August 29, 2018
Subject: SOC for Review & Approval to Be Sent to Public Notice
EMC SOC WQ S18-010
Badin Business Park LLC
Permit No. NC0004308
Stanly County
Please find the attached copy of the SOC for Badin Business Park LLC.
NPDES Permit NC0004308 issued September 29, 2017 has been adjudicated by the following
petitioners: Badin Business LLC and Concerned Citizens of West Badin Community. An order for
extension of stay was filed on June 1, 2018. For your reference, please see attached stay.
Badin Business Park LLC, referred to as `Kadin Park" has requested Special Order by Consent EMC
SOC WQ S18-010 for its Badin Business Park facility that (contaminated groundwater), stormwater,
and fire protection water to Little Mountain Creek in the Yadkin -Pee Dee River Basin under the
authority of NPDES Permit NC0004308, but is unable to consistently comply with effluent limits at
Outfall 005 for Total Fluoride and Total Cyanide. The proposed SOC will become effective
October 1, 2018.
Compliance with this order will require Badin Park to complete the design, prepare the specification
package, and complete the construction for the Badin Business Park piping system upgrade. Upon
completion of construction of the upgrade, Badin Park will be required to attain compliance with the
final effluent limitations in the NPDES Permit. Badin Park shall comply with NPDES permit limits with
the exception of the interim effluent limitations identified in the SOC. This SOC will expire on
February 28, 2019.
�DECr,")
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1617 Mail Service Center 1 Raleigh, North Carolina 27699-1617
919.707.9009

EMC SOC WQ S18-010
August 29, 2018
Page 2 of 4
The SOC will include the following financial assurance language as negotiated in paragraph 2 (e.):
If the stormwater piping system upgrades required by this Special Order have not been
completed by the date of the issuance of this Special Order, Badin Park shall, within thirty (30)
days of that issuance, secure and provide documentation to DWR of an irrevocable standby letter
of credit (Letter of Credit) to cover the cost of the uncompleted construction. The institution
issuing the Letter of Credit shall be an entity which has the authority to issue letters of credit and
whose letter of credit operations are regulated and examined by a Federal or State agency. The
Letter of Credit shall be issued in favor of the State of North Carolina. The financial assurance
provided by the Letter of Credit must be continuous in nature and must bind Badin Park as well
as its successors -in -interest. The amount of coverage of the Letter of Credit shall be at least
100% of the estimated cost of constructing the stormwater piping system upgrade required by
this Special Order, which is estimated at Seven Hundred and Fourteen Thousand Eight Hundred
and Sixty -Five Dollars ($714,865), or if Badin Park submits to DWR evidence that the
construction will be partially completed as of the time of issuance of the Letter of Credit and the
estimated costs of completing such work, DWR may, in its discretion, approve a lower amount
for the Letter of Credit based on that cost of completion, such approval not to be unreasonably
withheld; provided, that DWR may increase the amount of the Letter of Credit if it concludes
that additional work is required in order to achieve final compliance with effluent limits in the
Permit. The Letter of Credit shall be maintained during the term of this Special Order until it
expires or otherwise canceled.
Badin Park stipulates the following in their SOC application:
1. A Special Order by Consent ("Special Order") would address issues related to the NPDES
wastewater discharge permit renewal number NC0004308 (the "Permit") issued to Badin Park on
September 29, 2017 by the North Carolina Department of Environmental Quality, Division of
Water Resources (the "DWR").
2. The Permit authorizes the discharge of contaminated groundwater, stormwater, and fire
protection water from for Badin Park's facility located at NC Hwy. 740 & NCSR 1719, Stanly
County, NC ("Badin Business Park"). The Permit apples daily maximum total cyanide limits to
discharges form Outfalls 011, 018, and 022, and also applies both daily maximum and monthly
average total cyanide limits to discharges form Outfalls 005, 012, and 013 ("cyanide limits").
The Permit applies daily maximum total fluoride limits to discharges from Outfalls 011, 018 and
022, and also applies both daily maximum and monthly average total fluoride limits to
discharges from Outfalls 005 ("fluoride limits").
3. Compliance with the monthly average fluoride limit and the daily maximum and monthly
average cyanide limit at Outfall 005 in the permit will require the design and construction of a
stormwater piping system upgrade at the Badin Business Park.
4. Noncompliance with final effluent limitations in the Permit constitutes causing and contributing
to pollution of the waters of the State, and Badin Park is with the jurisdiction of the Commission
as set forth in G.S. Chapter 143, Article 21.
5. Badin Park has secured financing for planning, design, and construction of a stormwater piping
system upgrade which, once constructed and operated, is expected to be sufficient to achieve
compliance with the final effluent limitations in the Permit.

EMC SOC WQ S18-010
August 29, 2018
Page 3 of 4
The SOC, as drafted will require Badin Park to undertake the following activities in accordance with the
indicated time schedule:
Scheduled Activity
Due Date
Complete the design and prepare the specification package for
the Badin Business Park piping system upgrade.
May 31, 2018 (Met)
Complete the construction of the Badin Business Park piping
system upgrade.
November 30, 2018
Attain compliance with the final effluent limitations in the
Permit.
December 31, 2018
The SOC, as drafted, will maintain the following changes to conditions found in the existing permit
NC0004308 for Outfall 005:
Parameters
Units
Permit Limits
Interim Limits
Monthly
Avg.
Daily
Maximum
Monthly Avg.
Daily Maximum
Total Fluoride
mg/L
1.8 mg/L
24 mg/L
5.0 mg/L
(Permit Limit Applies)
Total Cyanide
j.tg/L
5.0 µg/1
46.6 µg/1
20.0 µg/L
(Permit Limit Applies)
Badin Park will agree under the SOC to pay, according to the following schedule, for failure to meet the
deadlines or failure to attain compliance with the effluent limitations/monitoring requirements:
Violation Description
Stipulated Penalty
Failure to meet a scheduled date
$1,000 per day
Failure to comply with a modified
effluent limit
$1,000 for exceeding monthly average
limit; $500 for exceeding daily maximum
limits
Monitoring frequency violations for
modified parameters
$100 per omitted value per parameter
Failure to Submit Status Reports
$1,000 for the first violation; penalty
doubles with each subsequent assessment
for late reports
Failure to achieve compliance with final
effluent limits
$5,000 (single penalty)

EMC SOC WQ S18-010
August 29, 2018
Page 4 of 4
Data Summary from November 2017 (permit effective date) through May 2018 (current DMR):
Parameter 00951 - Fluoride, Total (as F)
Outfall 'b05 Location Effluent
,Sample Composite
Month Day Year Value Modifier UoM
11 1 2017 2.9 mg/I
11 29 2017 3 mg/I
12 20 2017 3.1 mg/I
1 9 2018 2.5 mg/I
1 30 2018 2.2 mg/I
2 8 2018 2.1 mg/I
2 21 2018 2.2 mg/I
3 21 2018 2.2 mg/I
4 19 2018 0.28 mg/I
5 2 2018 2.2 mg/I
Average
2.268 mg/I
Parameter 00720 - Cyanide, Total (as Cn)
Outfall 1)05 !Location Effluent
Sample Grab
Month Day Year Value Modifier UoM
11 1 2017 8.3 ug/I
12 1 2017 8.3 ug/I
12 20 2017 5.8 ug/I
1 9 2018 5 LESSTHAN ug/I
1 30 2018 8.4 ug/I
2 8 2018 16 ug/I
2 21 2018 43 ug/I
3 21 2018 29 ug/I
4 19 2018 20 ug/I
5 2 2018 44 ug/I
Average
18.78 ug/I
The NC DOJ drafted the original SOC. The central office reviewed and revised the draft SOC. The NC
DOJ further mediated a final draft between petitioners, which includes the financial assurance language.
The attached SOC will be formally presented to the Badin Business Park LLC for its review, approval
and signature. Upon return of the signed amended SOC, it will be submitted for public notice. If no
significant public comment is received, the amended SOC will be sent directly to the Director's Office
for signature following the comment and review period, with no additional internal review.
If you have any questions or comments, please call me at 919-707-3618 or e-mail
[derek.denard@ncdenr. gov] .
ec: DWR/WQPS Teresa Rodriguez [[e-mail]]; John Hennessy [[e-mail]]
DWR/MRO Corey Basinger [[e-mail]]; Andrew Pitner [[e-mail]];
Roberto Scheller [[e-mail]]

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
COUNTY OF STANLY
IN THE MATTER OF
NORTH CAROLINA
NPDES PERMIT NC0004308
HELD BY
BADIN BUSINESS PARK LLC
SPECIAL ORDER BY CONSENT
EMC SOC WQ S18-010
Pursuant to provisions of North Carolina General Statutes (G.S.) 143-215.2 and 143-215.67, this
Special Order by Consent is entered into by Badin Business Park LLC, hereinafter referred to as
Badin Park, and the North Carolina Environmental Management Commission, an agency of the
State of North Carolina created by G.S. 143B-282, and hereinafter referred to as the
Commission. Badin Park and the Commission are referred to hereafter collectively as the
"Parties".
1. Badin Park and the Commission hereby stipulate the following:
a. Badin Park holds North Carolina NPDES permit number NC0004308 (the
"Permit") for the discharge of wastewater (contaminated groundwater),
stormwater, and fire protection water to an unnamed tributary to Little Mountain
Creek and Badin Lake (Yadkin River), Class WS-IV and WS-IV CA & B waters,
respectively, of the state in the Yadkin -Pee Dee River Basin, but is unable to
consistently comply with the final effluent limits for Total Fluoride and Total
Cyanide as set forth in the Permit for Outfall 005. This Special Order by Consent
("Special Order") addresses issues related to compliance with the Permit.
b. The Permit authorizes the discharge of contaminated groundwater, stormwater,
and fire protection water from for Badin Park's facility located at NC Hwy. 740 &
NCSR 1719, Stanly County, NC ("Badin Business Park").
c. The Permit applies daily maximum total cyanide limits to discharges from
Outfalls 011, 018 and 022, and also applies both daily maximum and monthly
average total cyanide limits to discharges from Outfall 005, 012, and 013
("cyanide limits").
d. The Permit applies daily maximum total fluoride limits to discharges from
Outfalls 011, 018 and 022, and also applies both daily maximum and monthly
average total fluoride limits to discharges from Outfall 005 ("fluoride limits").

Badin Business Park LLC
EMC SOC WQ S18-010
p. 2
e. Compliance with the monthly average fluoride limit and the daily maximum and
monthly average cyanide limits at Outfall 005 in the permit will require the design
and construction of a stormwater piping system upgrade at the Badin Business
Park, which can performed without further permitting in accordance with the
existing permit and this order.
f. Noncompliance with final effluent limitations constitutes causing and contributing
to pollution of the waters of this State named above, and Badin Park is within the
jurisdiction of the Commission as set forth in G.S. Chapter 143, Article 21.
g. Badin Park has secured financing for planning, design, and construction of a
stormwater piping system upgrade which, once constructed and operated, will be
sufficient to achieve compliance with the final effluent limitations in the Permit.
2. Badin Park, desiring to comply with the permit identified in paragraph 1(a) above, hereby
agrees to the do the following:
a. Undertake the following activities in accordance with the indicated time schedule:
Scheduled Activity
Due Date
Complete the design and prepare the specification package for
the Badin Business Park piping system upgrade.
May 31, 2018 (Met)
Complete the construction of the Badin Business Park piping
system upgrade.
November 30, 2018
Attain compliance with the final effluent limitations in the
Permit.
December 31, 2018
b. Badin Park will submit quarterly progress reports detailing the work and activities
undertaken and completed on the upgrades to the piping system. The reports are
to be submitted as follows: one copy must be mailed to the Mooresville Regional
Supervisor, Division of Water Resources / Water Quality Regional Operations
Section, 610 East Center Avenue, Suite 301, Mooresville, NC 28115, and one
copy must be mailed to the Water Quality Permitting Section / NPDES, 1617
Mail Service Center Raleigh, NC 27699-1617. The quarterly reports are due in
each respective office no later than the thirtieth (30th) day of January, April, July,
and October for the duration of this Order.
c. Badin Park will comply with all terms and conditions of the permit except those
effluent limits identified in paragraph 1(a) above. See Attachment A for all
current monitoring requirements and effluent limits for Outfall 005. Badin Park
may also be required to monitor for other parameters, as deemed necessary by the
Director, in future permits or administrative letters. During the time in which this
Special Order is effective, Badin Park shall comply with the interim effluent

Badin Business Park LLC
EMC SOC WQ S 18-010
P. 3
limits for total fluoride and total cyanide at Outfall 005 as listed in the table
below.
Under this Special Order, only the parameters listed below have been modified from
the most current NPDES Permit in effect for Outfall 005.
Parameters
Total Fluoride
Units
mg/L
Permit Limits
Interim Limits
Monthly
Avg.
1.8 mg/L
Daily
Maximum
24 mg/L
Monthly Avg.
5.0 mg/L
Daily Maximum
(Permit Limit Applies)
Total Cyanide
µg/L
5.0 µg/1
46.6 µg/1
20.0 µg/L
(Permit Limit Applies)
d. No later than fourteen (14) calendar days after any date identified for
accomplishment of any activity listed in paragraph 2(a) above, submit to the
Director of DWR written notice of compliance (including the date compliance
was achieved along with supporting documentation if applicable) or
noncompliance therewith. In the case of noncompliance, the notice shall include a
statement of the reason(s) for noncompliance, remedial action(s) taken, and a
statement identifying the extent to which subsequent dates or times for
accomplishment of listed activities may be affected.
e. If the stormwater piping system upgrades required by this Special Order have not
been completed by the date of the issuance of this Special Order, Badin Park
shall, within thirty (30) days of that issuance, secure and provide documentation
to DWR of an irrevocable standby letter of credit (Letter of Credit) to cover the
cost of the uncompleted construction. The institution issuing the Letter of Credit
shall be an entity which has the authority to issue letters of credit and whose letter
of credit operations are regulated and examined by a Federal or State agency. The
Letter of Credit shall be issued in favor of the State of North Carolina. The
financial assurance provided by the Letter of Credit must be continuous in nature
and must bind Badin Park as well as its successors -in -interest. The amount of
coverage of the Letter of Credit shall be at least 100% of the estimated cost of
constructing the stormwater piping system upgrade required by this Special
Order, which is estimated at Seven Hundred and Fourteen Thousand Eight
Hundred and Sixty -Five Dollars ($714,865), or if Badin Park submits to DWR
evidence that the construction will be partially completed as of the time of
issuance of the Letter of Credit and the estimated costs of completing such work,
DWR may, in its discretion, approve a lower amount for the Letter of Credit
based on that cost of completion, such approval not to be unreasonably withheld;
provided, that DWR may increase the amount of the Letter of Credit if it
concludes that additional work is required in order to achieve final compliance
with effluent limits in the Permit. The Letter of Credit shall be maintained during
the term of this Special Order until it expires or otherwise canceled.

Badin Business Park LLC
EMC SOC WQ S 18-O 10
p. 4
3. Badin Park agrees that unless excused under paragraph four (4), Badin Park will pay the
DWR, by check payable to the North Carolina Department of Environmental Quality,
stipulated penalties according to the following schedule for failure to meet the deadlines
set out in paragraphs 2(a), 2(b), and 2(d).
Violation Description
Stipulated Penalty
Failure to meet a scheduled date
$1,000 per day
Failure to comply with a modified
effluent limit
$1,000 for exceeding monthly average
limit; $500 for exceeding daily maximum
limits
Monitoring frequency violations for
modified parameters
$100 per omitted value per parameter
Failure to Submit Status Reports
$1,000 for the first violation; penalty
doubles with each subsequent assessment
for late reports
Failure to achieve compliance with final
effluent limits
$5,000 (single penalty)
4. Badin Park and the Commission agree that the stipulated penalties are not due if Badin
Park satisfies DWR that noncompliance was caused solely by:
a. An act of God;
b. An act of war;
c. An intentional act or omission of a third party, but this defense shall not be
available if the act or omission is that of an employee or agent of the defendant or
if the act or omission occurs in connection with a contractual relationship with the
permittee;
d. An extraordinary event beyond the permittee's control. Contractor delays or
failure to obtain funding will not be considered as events beyond the permittee's
control; or
e. Any combination of the above causes.
Failure within thirty (30) days of receipt of written demand by DWR to pay the penalties,
or challenge them by a contested case petition pursuant to G.S. 150B-23, will be grounds
for a collection action, which the Attorney General is hereby authorized to initiate. The
only issue in such an action will be whether the thirty (30) days has elapsed.

Badin Business Park LLC
EMC SOC WQ S 18-010
P. 5
5. Since this Special Order is by consent, the Parties acknowledge that review of the same is
not available to the Parties in the N.C. Office of Administrative Hearings. Furthermore,
neither party shall file a petition for judicial review concerning the terms of this Special
Order.
6. Noncompliance with the terms of this Special Order is subject to enforcement action in
addition to the above stipulated penalties, including, but not limited to injunctive relief
pursuant to G.S. 143-21.5.6C or termination of this Special Order by the Director of DWR
upon ten (10) days' notice to Badin Park. Noncompliance with the terms of this Special
Order will not be subject to civil penalties in addition to the above stipulated penalties.
7. This Special Order and any terms or conditions contained herein, hereby supersede any
and all previous Special Orders, Enforcement Compliance Schedule Letters, terms,
conditions, and limits contained therein issued in connection with NPDES permit number
NC0004308. In the event of an NPDES permit modification or renewal, any effluent limit
or monitoring requirements contained therein shall supersede those contained in
Attachment A of this Special Order, except as modified and contained in paragraph 2(c)
above.
8. This Special Order may be modified at DWR's discretion, provided DWR is satisfied that
Badin Park has made good faith efforts to secure funding, complete all construction, and
achieve compliance within the dates specified. In accordance with applicable law,
modification of this Special Order will go to public notice prior to becoming effective.
9. In addition to any other applicable requirement, each notice required to be submitted by
Badin Park under this Special Order shall be signed by a plant manager or a corporate
official responsible for environmental management and compliance, and shall include the
following certification:
I certify under penalty of law that this document and all attachments
were prepared under my direction or supervision in accordance with
a system designed to assure that qualified personnel properly gather
and evaluate the information submitted. Based on my inquiry of the
person or persons who manage the system, or those persons directly
responsible for gathering the information, the information submitted
is, to the best of my knowledge and belief, true, accurate, and
complete. I am aware that there are significant penalties for
submitting false information, including the possibility of fine and
imprisonment for knowing violations.
10. Failure to meet the scheduled date identified in paragraph 2(a) may terminate this Special
Order by Consent and require Badin Park to comply with the terms and conditions
contained in the permit identified in paragraph 1(a).

Badin Business Park LLC
EMC SOC WQ S 18-010
p. 6
11. Badin Park, upon signature of this Special Order by Consent, will be expected to comply
with all schedule dates, terms, and conditions of this document.
This Special Order by Consent shall expire February 28, 2019.
For Badin Business Park LLC:
Robyn L. Gross, Director Date
Asset Management Americas
For the North Carolina Environmental Management Commission.
Linda Culpepper, Interim Director Date
Division of Water Resources

Attachment A
EMC SOC WQ S18-010
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS —
OUTFALL 005 (INTERIM) [15A NCAC 02B .0400 et seq., 02B .0500 et seq.]
During the period beginning on the effective date of the Special Order and lasting until December 31, 2018, the
Permittee is authorized to discharge groundwater, stormwater, and fire protection water at Outfall 005. Such
discharges shall be limited and monitored' by the Permittee as specified below:
PARAMETER
[PARAMETER CODES]
EFFLUENT LIMITATIONS
MONITORING REQUIREMENTS
Monthly
Average
Weekly
Average
Daily
Maximum
Measurement
Frequency
Sample
Type
Sample
Location 2
Flow (mgd)
50050
Monthly
Instantaneous
E
Total Suspended Solids (mg/L)
C0530
Quarterly
Composite 3
E
pH (su)
00400
Shall remain within the range of 6.0
to 9.0 standard units at all times
Monthly
Grab
E
Total Aluminum (mg/L)
01105
Quarterly
Composite 3
E
Total Fluoride (mg/L) 4
00951
5.0 mg/I *
24 mg/1
Monthly
Composite 3
E
Total Cyanide (µg/L) 4
00720
20.0 µg/1 *
46.6 µg/1
Monthly
Grab
E
Total Residual Chlorine (µg/L) 4
50060
17 µg/1
Monthly
Grab
E
Acute Toxicity 5
TGP3B
Quarterly
Composite 3
E
* SOC Limits
Footnotes:
1. Submit Discharge Monitoring Reports electronically using NC DWR's eDMR application system. Please See
Special Condition C. (6).
2. Sample locations: E - Effluent.
3. The Permittee may use time -proportionate compositing or other sampling method provided that the alternate
method yields samples that are reasonably representative of the discharge during the monitoring period.
4. The permittee shall use sufficiently sensitive test procedures approved under 40 CFR part 136 for the analysis
of pollutants. A method is "sufficiently sensitive" when: (1) The method minimum level (ML) is at or below
the level of the effluent limit established in the permit for the measured pollutant or pollutant parameter; or
(2) the method has the lowest ML of the analytical methods approved under 40 CFR part 136 or required
under 40 CFR chapter I, subchapter N or 0 for the measured pollutant or pollutant parameter. The Permittee
shall report on its Discharge Monitoring Reports the actual laboratory results for each effluent sample tested.
5. Acute Toxicity P/F Quarterly; see Special Condition C. (1).

FILED
OFFICE OF ADMINISTRATIVE HEARINGS
06/01/2018 8:47 AM
STATE OF NORTH CAROLINA IN THE OFFICE OF
ADMINISTRATIVE HEARINGS
Concerned Citizens of West Badin Community, )
)
Petitioner, )
)
v. ) 17 EHR 07296
) County of Stanly
North Carolina Department of Environmental )
Quality, Division of Water Resources, )
)
Respondent. )
)
Badin Business Park LLC, )
)
Petitioner, )
)
v. ) 17 EHR 07316
) County of Wake
Division of Water Resources, North Carolina )
Department of Environmental Quality, )
)
Respondent. )
)
ORDER FOR EXTENSION OF STAY
Upon consideration of the Parties Joint Motion for Stay filed on May 30, 2018, and for
good cause shown, the undersigned hereby orders the following:
1. All proceedings shall be stayed until July 30, 2018;
2. During the extension of stay, Petitioner Badin Park will update the Court upon
filing their application for a Special Order by Consent. relating to the challenged
permit;

3. During the extension of stay, Respondent will update the Court on whether the
Special Order by Consent has been noticed for public comment,
4. Prior to July 30, 2018, the Parties will submit to the Court a report on the status of
discussions and the prospects of settlement and whether additional time will be
needed to complete the Special Order by Consent process; and
5. In the event that a settlement is not reached during this extension of stay, and all
parties do not agree to request an additional extension of the stay, the parties shall:
a. no later than three (3) days prior to the end of the stay, begin discussing
mutually acceptable dates following the expiration of the stay in which the
parties would complete noticed depositions and deliver remaining discovery
responses, and
b. within five (5) days following the expiration of the stay, submit to the court
a proposed scheduling order for filing dispositive motions and a hearing.
This the 1st day of June, 2018.
0„,,,/ i-tAitPk
David F Sutton
Administrative Law Judge

CERTIFICATE OF SERVICE
The undersigned certifies that, on the date shown below, the Office of Administrative
Hearings sent the foregoing document to the persons named below at the addresses shown below,
by electronic service as defined in 26 NCAC 03 .0501(4), or by placing a copy thereof, enclosed
in a wrapper addressed to the person to be served, into the custody of the North Carolina Mail
Service Center who subsequently will place the foregoing document into an official depository of
the United States Postal Service:
Mark E Anderson
McGuire Woods LLP
PO Box 27507
Raleigh, NC 27611
Attorney For Petitioner
Charles Dixon Case
McGuireWoods LLP
ccase(a.mcg uirewoods. com
Attorney For Petitioner
W. Dixon Snukals
McGuireWoods LLP
wsnukals(a mcguirewoods. com
Attorney For Petitioner
Chandra Terice Taylor
Southern Environmental Law Center
ctaylor(a�selcnc.org
Attorney For Petitioner
Mark E Anderson
McGuireWoods LLP
mandersonr mcguirewoods.com
Attorney For Petitioner
Asher Paris Spiller
North Carolina Department of Justice
aspillerAncdoj.gov
Attorney For Respondent
Amy L Bircher
North Carolina Department of Justice
Office of the Attorney General
abircherriPncdoixov
Attorney For Respondent

This the 1st day of June, 2018.
dt/frr
Jea,,,,tA)
Lisa J Garner
North Carolina Certified Paralegal
N. C. Office of Administrative Hearings
6714 Mail Service Center
Raleigh NC 27699-6700
Phone: [phone]