Document VJ70zQQoxN2Vxmov8wEer8Bzj
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 2, ECAD-WCB
21st Floor, 290 Broadway, NY, NY 10007
COMPLIANCE EVALUATION INSPECTION REPORT
Program: Industrial Compliance Evaluation
Inspection Type: Compliance Evaluation
Inspection
Inspection
Permittee Name: Burlington Beef
NPDES/ICIS No.: NJ0099198 (Ground Water)
and NJG197670 (Terminated SW Permit)
Inspection Entry Date: February 19, 2025
Inspection Exit Date: February 19, 2025
Inspection Entry Time: 11:00 AM
Inspection Exit Time: 1:30 PM
Facility Inspected:
Lat, Long: 39.620338, -75.199911
Burlington Beef
NAICS / SIC Code: 2011 (Meat Packing Plants)
30 Burlington Road
Monroeville, NJ, 08343
EPA Representative(s):
Daniel Asselin, Environmental Engineer, EPA Region 2, ECAD-WCB, (212) 637-4262,
Asselin.daniel@epa.gov
State Representative(s):
Tiffany Malcolm, NJDEP, tiffany.malcolm@dep.nj.gov
Steve Mathis, NJDEP, steve.mathis@dep.nj.gov
On-Site Facility Representative(s):
Adam Kohn, General Manager, adam@burlingtonbeef.com
Cynthia "Cindy" Kohn, Owner & Vice President, cindy@burlingtonbeef.com
Thomas "Tommy" Patten, Office Manager, tom@burlingtonbeef.com
Responsible Official(s):
Henry Kohn, Owner & President, henry@burlingtonbeef.com
Cynthia "Cindy" Kohn, Owner & Vice President, cindy@burlingtonbeef.com
Thomas "Tommy" Patten, Office Manager, tom@burlingtonbeef.com
Name and Signature of Inspector
DANIEL
Digitally signed by DANIEL ASSELIN
ASSELIN
Date: 2025.03.11 11:38:12 -04'00'
Agency/Office/Phone Number
Date a date
Daniel Asselin, Environmental Engineer
ECAD-WCB (212) 637-4262
Name and Signature of Management QA Reviewer Agency/Office/Phone Number Date
MURRAY
LANTNER
Digitally signed by MURRAY LANTNER
a date
Date: 2025.03.11 13:26:25 -04'00'
Murray Lantner, P.E., Acting Section Supervisor
ECAD-WCB (212) 637-3976
I. INTRODUCTION
On February 19, 2025, representatives of the United States Environmental Protection Agency ("EPA") Region 2 and the New Jersery Department of Environmental Protection ("NJDEP") Southern Bureau conducted a Compliance Evaluation Inspection ("CEI" or "Inspection") at Burlington Beef, located at 30 Burlington Road, Monroeville, New Jersey (the "Site" or "Facility"). The facility maintains coverage under the New Jersey Pollutant Discharge Elimination System ("NJPDES") Discharge to Ground Water Permit NJ0099198 ("Permit"), which became effective on March 1, 2015, expired on February 29, 2020, but has been administratively extended. Discharges of wastewater from Burlington Beef are only authorized to discharge to the Site's spray field (and underlying groundwater), provided the discharge is contained within the spray field for irrigation purposes. The NJPDES Ground Water Discharge Permit does not authorize discharges to Waters of the U.S.
Upon arrival, EPA inspector Daniel Asselin and NJDEP inspectors Tiffany Malcolm and Steve Mathis, presented their credentials to Mrs. Cynthia "Cindy" Kohn, Owner and Vice President, Mr. Thomas "Tommy" Patten, Office Manager, and Mr. Adam Kohn, General Manager. Weather conditions at the time of the inspection were cloudy and approximately 28F with no precipitation. A brief opening conference was held to discuss the scope of the inspection with the Site representatives and afterwards, EPA conducted the Site inspection with the Site representatives.
The Site representatives stated that the Site receives cows, pigs, goats and lambs from the tristate area. The animals are slaughtered and bled within 24 hours of arrival. Animals are then put in the freezer overnight and deboned and cut the following day. Facility representatives stated that the Site has five (5) United States Department of Agriculture ("USDA") employees onsite (approximately 2-3 of which are inspectors) who oversee the process. The Site representatives stated they receive, on average, between 75 and 90 animals/day. The Site representative stated that the unused parts (blood, guts, etc) are put in a truck and shipped to Darling Ingredients, and they fill approximately 1-2 trucks/day. Untreated wastewater from the process is discharged to the spray field and sampled quarterly. The Site representative stated that they discharge approximately 1,000 gallons of wastewater in 20 minutes to the spray field. Multiple cows and goats, which were said to be the owners' pets are feeding and living on the spray fields.
II. FINDINGS
EPA began the inspection on the northern portion of the spray field. EPA observed mild puddling in the spray field (as shown in photograph P2190006). The Site representatives stated that there are four (4) lines of sprinklers in the spray field (with line 1 being the northernmost line and line 4 being the southernmost line), prior to discharging process wastewater to the spray field they said that they inspect the spray field for signs of puddling and if present, they discharge to a different line of sprinklers. EPA observed groundwater monitoring well 1 north of the spray field (as shown in photograph P2190009). EPA noted that PVC pipe was missing a cap and the well cover was not locked. Following the inspection, the Site representatives provided EPA with photographs of the PVC pipe capped and the covered locked. The Site representative stated that groundwater monitoring well 1 ("MW-1") was located upgradient, north of the spray field, groundwater monitoring well 2 ("MW-2") was located within the spray field, and groundwater monitoring well 3 ("MW-3") was located downgradient, south of the spray field, with each being a separate well not connected in any way.
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EPA also observed the western stormwater retention basin (as shown in photograph P2190008). The Site representative stated that there are two (2) retention basins onsite, one in the west and one in the east. All stormwater from the parking lots and roof gutters are channeled to one of the two retention ponds.
The inspection continued to the western edge of the spray field, along Burlington Road. EPA observed mild puddling and erosion along the western portion of the spray field (as shown in photographs P2190010 and P2190011, respectively). EPA observed an unauthorized discharge leaving the southwestern corner of the spray field. Photograph P2190034 shows the unauthorized discharge along Burlington Road, south of the Site. EPA observed MW-3, south of the spray field (as shown in photograph P2190012). The PVC pipe within MW-3 was uncapped and the well cover was unlocked, similar to MW-1.
The inspection continued to the southeastern portion of the Site. Prior to reaching the southern edge of the spray field, EPA observed a flow from the direction of the Site (as shown in photographs P2190014, P2190015, P2190020, and P2190021). The flow appeared to be red in nature, as shown in photographs P2190016, P2190017, P2190018, P2190022, P2190023, and P2190024. Additionally, EPA observed multiple signs of erosion on the southern portion of the Site (as shown in photographs P2190019 and P2190025). EPA was able to track the unauthorized discharge back to the southeastern corner of the Site's spray field. EPA observed multiple signs of frozen puddling within the spray field in the southeastern corner (as shown in photographs P2190013, P2190026, P2190027, P2190029, and P2190030). Additionally, EPA observed signs of erosion within the spray field (as shown in photographs P2190028 and P2190031) and just outside the southeastern portion of the spray field (as shown in photographs P2190032 and P2190033). EPA noted a distinct foul odor while in this portion of the Site. Additionally, EPA noted that the perimeter of the spray field was not bermed and only contained a metal fence. EPA was able to track the unauthorized discharge to an unnamed tributary of Muddy Run, which is a tributary of Maurice River, which flows to the Delaware Bay, a water of the US.
At the time of the inspection, the Site representatives discussed the possibility of regrading the spray field to increase the elevation of the edges (specifically the southeastern portion), installing a berm around the perimeter of the spray field, creating a path surrounding the spray field to allow for easy access to MW-3 and to observe all portions of the spray field, and dividing the spray field in sections to allow vegetation growth in one section at a time.
EPA continued the inspection to the eastern portion of the Site. While walking over, EPA observed a container full of animal bones and parts to the west of the main building (as shown in photograph P2190036). EPA observed evidence of forklift maintenance and dry absorbent placed on the ground in the eastern portion of the Site (as shown in photographs P2190037 and P2190044). The Site representative stated this was from a hydraulic leak in the forklift and that the floor drain is connected to an underground storage tank. EPA observed the eastern stormwater retention basin (as shown in photographs P2190041 and P2190042). EPA observed mild liter and debris within the eastern stormwater basin.
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III. RECORDS REVIEWED
Following the inspection, the Site provided EPA with electronic copies of the following documents: 1) Spray Field Operations and Maintenance Manual ("O&M" Manual); and 2) Photographs of groundwater monitoring wells 1, 2 and 3 with caps on the PVC pipes and locked caps.
IV. POTENTIAL NONCOMPLIANCE ITEMS
A. Unauthorized Discharge
a. Section 301(a) of the Clean Water Act ("CWA"), 33 U.S.C. 1311(a), makes it unlawful for any person to discharge any pollutant from a point source to waters of the United States, except, among other things, with the authorization of, and in compliance with, a National Pollutant Discharge Elimination System ("NPDES") permit issued pursuant to Section 402 of the CWA, 33 U.S.C. 1342.
b. As discussed in the attached Notice of Violation ("NOV") which was sent by NJDEP to Burlington Beef dated March 27, 2024, (Attachment 2), there were unpermitted discharges found on the property.
c. As shown in the photographs provided to EPA by the Cumberland Salem Soil Conservation District ("SCD"), (Attachment 3), the red discharge can be seen downstream, in an unnamed tributary of Muddy Run, adjacent to the Burlington Beef property. This attachment includes photographs displaying a red discharge entering a stream south of the Site. These photographs were taken on March 12, 2024 and February 3, 2025.
d. During EPA's inspection on February 19, 2025, EPA observed multiple instances of unauthorized discharge leaving the southern portion of the spray field. As described previously in this report, the Facility discharges its process wastewater to the spray field. EPA observed an unauthorized discharge on the southwestern portion of the spray field, along Burlington Road (as shown in photograph P2190034). Additionally, EPA observed an unauthorized discharge leaving the southeastern portion of the spray field as well (as shown in photographs P2190014-P2190033), entering an unnamed tributary of Muddy Run (which is a tributary of Delaware Bay and the Atlantic Ocean, both considered Waters of the U.S.). EPA noted the discharge appeared to be red in nature. EPA observed erosion within the spray field, as shown in photographs P2190028 and P2190031.
e. Following the inspection, EPA reviewed past aerial images of the Site online at CONNECTExplorer EagleView, (Attachment 4). The aerial images show a potential discharge leaving the southeastern portion of the Site's spray field as far back as May 13, 2007.
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f. The Facility does not have a NPDES or NJPDES Permit that authorizes the discharge of its process wastewater to Waters of the U.S./Navigable Waters as required by Section 301 of the Clean Water Act.
B. Potential Noncompliance Items - Discharge to Ground Water Permit (NJ0099198) a. Part III of the Permit addresses the Limits and Monitoring Requirements for groundwater monitoring well 1 ("MW-1"), groundwater monitoring well 2 ("MW-2") and groundwater monitoring well 3 ("MW-3") in Table III - A - 1. Following the inspection, EPA reviewed the Site's Waste Characterization Reports ("WCRs") for the period of March 2022 through February 2025, permit exceedances are displayed below in Table 1.
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Table 1: NJPDES Permit Exceedances submitted in Burlington Beef's WCRs for the period of March 2022 through February 2025.
Postmarked Outfall Date
Parameter Description
Statistical Base Type
WCR Value Unit
Limit Value
WCR Value
4/11/2022 MW-1 Solids, Total Dissolved (TDS)
Grab
mg/l
4/11/2022 MW-2 Solids, Total Dissolved (TDS)
Grab
mg/l
4/11/2022 MW-3 Nitrogen, Ammonia Total (N)
Grab
mg/l
4/11/2022 MW-3 Sodium, Total (Na)
Grab
mg/l
4/11/2022 MW-3 Chloride (Cl)
Grab
mg/l
7/19/2022 MW-2 Solids, Total Dissolved (TDS)
Grab
mg/l
7/19/2022 MW-2 Sodium, Total (Na)
Grab
mg/l
10/11/2022 MW-2 Sodium, Total (Na)
Grab
mg/l
10/11/2022 MW-2 Chloride (Cl)
Grab
mg/l
1/9/2023 MW-2 Solids, Total Dissolved (TDS)
Grab
mg/l
1/9/2023 MW-2 Sodium, Total (Na)
Grab
mg/l
1/9/2023 MW-3 Sodium, Total (Na)
Grab
mg/l
4/20/2023 MW-2 Sodium, Total (Na)
Grab
mg/l
7/20/2023 MW-2 Nitrogen, Ammonia Total (N)
Grab
mg/l
7/20/2023 MW-2 Sodium, Total (Na)
Grab
mg/l
10/23/2023 MW-2 Solids, Total Dissolved (TDS)
Grab
mg/l
10/23/2023 MW-2 Sodium, Total (Na)
Grab
mg/l
10/23/2023 MW-2 Chloride (Cl)
Grab
mg/l
10/23/2023 MW-3 Sodium, Total (Na)
Grab
mg/l
1/22/2024 MW-2 Solids, Total Dissolved (TDS)
Grab
mg/l
1/22/2024 MW-2 Sodium, Total (Na)
Grab
mg/l
1/22/2024 MW-2 Chloride (Cl)
Grab
mg/l
1/22/2024 MW-3 Sodium, Total (Na)
Grab
mg/l
4/22/2024 MW-2 Sodium, Total (Na)
Grab
mg/l
4/22/2024 MW-2 Chloride (Cl)
Grab
mg/l
7/22/2024 MW-2 Solids, Total Dissolved (TDS)
Grab
mg/l
7/22/2024 MW-2 Sodium, Total (Na)
Grab
mg/l
7/22/2024 MW-2 Chloride (Cl)
Grab
mg/l
10/24/2024 MW-1 Solids, Total Dissolved (TDS)
Grab
mg/l
10/24/2024 MW-2 Solids, Total Dissolved (TDS)
Grab
mg/l
10/24/2024 MW-2 Sodium, Total (Na)
Grab
mg/l
10/24/2024 MW-2 Chloride (Cl)
Grab
mg/l
1/23/2025 MW-2 Solids, Total Dissolved (TDS)
Grab
mg/l
1/23/2025 MW-3 Sodium, Total (Na)
Grab
mg/l
500
904
500
900
3
3.1
50
390
250
624
500
652
50
220
50
198
250
308
500
716
50
64.6
50
89.2
50
69.5
3
10
50
72.2
500 1212
50
410
250
599
50
76.2
500
984
50
329
250
362
50
79
50
369
250
430
500
712
50
197
250
275
500 1056
500 1052
50
349
250
400
500 1292
50
67.4
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b. Part III of the Permit addresses the Limits and Monitoring Requirements for the Site's discharge well ("G01G") in Table III - B - 1. Discharge well, G01G, stores the wastewater prior to being discharged to the spray field. Following the inspection, EPA reviewed the Site's Discharge Monitoring Reports ("DMRs") for the period of March 2022 through February 2025, permit exceedances are displayed below in Table 2.
Table 2: NJPDES Permit Exceedances submitted in Burlington Beef's DMRs for process wastewater during the period of March 2022 through February 2025.
Postmarked Outfall Parameter Description Statistical
Date
Base Type
DMR Value Unit
Limit Value
WCR Value
9/22/2023 G01G pH Minimum
Grab
SU
5
2.83
c. Part IV.B.1.c of the Permit states that "DMRs shall be postmarked no later than the 25th day of the month following the completed monitoring period." EPA reviewed the Site's DMRs for the period of March 2022 through February 2025. Table 3 below, displays the DMRs postmarked after the specified timeframe required by the permit.
Table 3: Late DMR submissions for the period of March 2022 through February 2025.
Monitoring Period
Postmarked Date
Days Late
March 2023 - May 2023
6/28/2023
3
March 2024 - May 2024
7/1/2024
6
June 2024 - August 2024 9/26/2024
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d. Part IV.D.2.f of the Permit lists the minimum provisions required to be included in the Site's O&M Manual. At the time of the inspection, the Site's O&M Manual did not include the following provisions, as required by the Permit: i. A list of all pollutants generated and/or discharged to all units regulated by this permit. ii. Assessment of emergency situations which affect the discharge activities as outlines in N.J.A.C. 7:14A-6.12(d)3. Emergency procedures in the O&M Manual shall not create an unpermitted discharge or contravene any rules or regulations. If the discharge flows to the regulated unites without the aids of pumps, the emergency plan only needs to address equipment and emergency procedures. iii. Procedures for correcting emergency situations. iv. Procedures for notifying the appropriate agencies.
e. Part IV.E.2.a.i of the Permit states that the Facility's O&M Manual should contain a schedule of physical inspections of entire visible spray field on a weekly basis during the periods of active discharge. During the inspection the
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permittee should look for areas of buildup of solids, ponding or channeling, and excessive or lack of vegetative growth. Part II of the Site's O&M Manual contains the stated requirements, however, at the time of the inspection, it was apparent to EPA that weekly visual inspections were not being taken place as multiple areas of ponding and erosion within the spray area were observed (as shown in photographs P2190013, P2190027, P2190028, P2190029, P2190030, and P2190031) and the entire spray field to be barren (as shown in photograph P2190006).
f. Part IV.E.2.a.ii of the Permit states that the Facility's O&M Manual should contain a "schedule of tilling, growth and harvesting of vegetation to ensure appropriate cover of the spray field." At the time of the inspection, EPA observed the spray field completely barren (as shown in photograph P2190006).
g. Part IV.E.2.c.i of the Permit states that "during the first year of the permit, the permittee is to determine the critical [wind] velocity limit above which spraying should not occur." At the time of the inspection, EPA did not observe a critical wind velocity limit within the Site's Soil Temperature and Wind Velocity logbook.
h. Part IV.E.2.c.ii of the Permit states that when using the manual soil temperature probe, "a minimum of three locations, within the spray field at least 500 feet apart, shall be tested. Spraying shall not commence when the soil temperature is below 40 degrees Fahrenheit."
i. According to the Site's Soil Temperature and Wind Velocity logbook, only one (1) soil temperature is collected and the required three (3) minimum soil temperatures were not being collected.
ii. Following the inspection, EPA reviewed the Site's Soil Temperature and Wind Velocity logbook entries from June 14, 2024 through February 18, 2025. During this period, EPA noted three (3) instances when the Site discharged to the spray field when the ground temperature was below 40F. Table 4 below shows the Soil Temperature and Wind Velocity data for the three (3) days.
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Table 4: Discharge to Ground Water Permit violations from the Site's Soil
Temperature and Wind Velocity Logbook
Anemometer Anemometer
Air
Ground
Date Wind Velocity Wind Velocity Temperature Temperature Discharge?
Min. [mph]
Max. [mph]
[F]
[F]
20 min
2/6/2025
1
3
38
35 spray
20 min
2/7/2025
1
5
38
36 spray
20 min
2/14/2025
1
3
36
38 spray
i. Part IV.E.2.d of the Permit states that the permittee must maintain records of wind speed and temperature measurements and "these records must include information regarding the date, time, and location of the measurements." EPA noted that the Site's Soil Temperature and Wind Velocity logbook did not record the time or location the sample was taken.
j. Part IV.E.2.f of the Permit states that "the discharge to the permitted spray fields shall not exceed the boundaries as indicated on the site plans submitted to the Department." At the time of the inspection, EPA observed multiple areas where the Site's wastewater discharge was exceeding the spray field's boundary (as shown in Attachment 1) and the wastewater was flowing off-site.
V. AREAS OF CONCERN
1. The Site representatives stated that the Facility is a slaughterhouse, where cows, pigs, goats and lambs are brough in for slaughter for meat to be sold. Therefore, the Site is classified under the Standard Industrial Classification ("SIC") Code 2011 (Meat Packing Plants). At the time of the inspection, the Site did not have coverage under the Basic Industrial Stormwater Permit ("5G2") for Stormwater Discharges associated with Industrial Activity (NJ0088315). Industrial activity under SIC Code 2011 is a regulated SIC code, and therefore the Site may be required to be permitted under the 5G2 per Section 402(p) of the CWA and 40 CFR 122.26(b)(14). Please work with NJDEP to discuss whether or not a 5G2 Permit is required for the Facility.
2. At the time of the inspection, EPA observed absorbent spread across the eastern portion of the Site and under a forklift (as shown in photographs P2190044 and P2190037). The Site representative stated that the forklift had a hydraulic leak which was fixed. The hydraulic fluid and absorbent outside the garage have potential to enter the eastern retention pond. Please ensure that all vehicle maintenance is conducted inside and contained, and that the absorbent is cleaned up and properly disposed.
VI. CLOSING At the conclusion of the inspection, EPA held a closing conference with the Site representatives and discussed the preliminary findings and follow-up.
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ATTACHMENTS Attachment 1 - Photographs Attachment 2 - NJDEP Notice of Violation ("NOV") for unpermitted discharge dated March 27, 2024 Attachment 3 - SCD Photographs from March 12, 2024 and February 3, 2025 Attachment 4 - Aerial Images of the Site Attachment 5 - Spray Field Operations and Maintenance Manual ("O&M" Manual)
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Att. 1, Unedited Photos Burlington Beef, Monroeville, NJ, February 19, 2025
Taken by, Daniel Asselin USEPA Region 2, ECAD-WCB OM Systems TG-7 Digital Camera
P2190001 - Soil Temperature & Wind Velocity Logbook
P2190002 - Soil Temperature & Wind Velocity Logbook
P2190003 - Soil Temperature & Wind Velocity Logbook
P2190004 - Soil Temperature & Wind Velocity Logbook
P2190005 - Burlington Beef main building.
P2190006 - Northern portion of the spray field.
P2190007 - Owner's pets in the spray field.
P2190008 - Retention pond on the western portion of the Site.
P2190009 - Monitoring Well 1, located north of the spray field.
P2190010 - Western edge of the spray field, along Burlington Road.
P2190011 - Mild erosion along the southwestern corner of the spray field.
P2190012 - Monitoring Well 3, located south of the spray field.
P2190013 - Frozen puddles in the southeastern corner of the spray field.
P2190014 - Frozen, unauthorized discharge leaving the southeastern portion of the spray field.
P2190015 - Unauthorized discharge leaving the southeastern portion of the spray field.
P2190016 - Red, unauthorized discharge leaving the southeastern portion of the spray field.
P2190017 - Red, unauthorized discharge leaving the southeastern portion of the spray field.
P2190018 - Red, unauthorized discharge leaving the southeastern portion of the spray field.
P2190019 - Erosion in the southeastern portion of the Site.
P2190020 - Frozen, unauthorized discharge leaving the southeastern portion of the spray field.
P2190021 - Frozen, unauthorized discharge leaving the southeastern portion of the spray field.
P2190022 - Red, unauthorized discharge leaving the southeastern portion of the spray field.
P2190023 - Red, unauthorized discharge leaving the southeastern portion of the spray field.
P2190024 - Red, unauthorized discharge leaving the southeastern portion of the spray field.
P2190025 - Erosion in the southeastern P2190026 - Frozen, red, puddles in the
portion of the Site.
southeastern portion of the spray field.
P2190027 - Frozen, red, puddles in the southeastern portion of the spray field.
P2190028 - Frozen, red, puddles in the southeastern portion of the spray field.
P2190029 - Frozen, red, puddles in the southeastern portion of the spray field.
P2190030 - Frozen, red, puddles in the southeastern portion of the spray field.
P2190031 - Frozen, red, puddles in the southeastern portion of the spray field.
P2190032 - Red, unauthorized discharge leaving the southeastern portion of the spray field.
P2190033 - Red, unauthorized discharge leaving the southeastern portion of the spray field.
P2190034 - Unauthorized discharge leaving the southwestern portion of the spray field, along Burlington Road.
P2190035 - Container full of bones on the western portion of the Site.
P2190036 - Container full of bones on the western portion of the Site.
P2190037 - Forklift maintenance and quick dry on the ground in the eastern portion of the Site.
P2190038 - Outside the maintenance area on the eastern portion of the Site.
P2190039 - Underground storage tank in the eastern portion of the Site.
P2190040 - Septic tank cover.
P2190041 - Retention pond on the eastern portion of the Site.
P2190042 - Retention pond on the eastern portion of the Site.
P2190043 - Burlington Beef.
P2190044 - Quick dry over hydraulic fluid leak.
ATTACHMENT 2
Att. 3, Unedited Photos Burlington Beef, Monroeville, NJ,
Taken by the Cumberland Salem Soil Conservation District March 12, 2024
DSC02096
DSC02099
Burlington Beef, Monroeville, NJ, Taken by the Cumberland Salem Soil Conservation District February 3, 2025
DSC03167
DSC03169
Att. 4, Aerial Imagery Burlington Beef, Monroeville, NJ,
Taken from CONNECTExplorer EagleView
December 7, 2019
April 13, 2018
December 19, 2016
May 13, 2007
ATTACHMENT 5
