DEQp00022698

� 1 �
.•r.ar,rr•��
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, P.E. Dee Freeman
Governor Director Secretary
February 6, 2012
'
Mr. Michael E. Johnson FEB 2 8 2012
Environmental Manager CENTRAL FILES
E.I. DuPont de Nemours & Company DWQ/BOG
22828 NC Highway 87 West
Fayetteville, North Carolina 28306-7332
Subject: Issuance of NPDES Permit
NC0003573
Fayetteville Works
Bladen County
Facility Class III
Dear Mr. Johnson:
Division personnel have reviewed and approved your application for renewal of the subject permit.
Accordingly, we are forwarding the attached NPDES discharge permit. This permit is issued pursuant to the
requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between North
Carolina and the U.S. Environmental Protection Agency dated October 15, 2007 (or as subsequently amended).
The Final Permit contains the following significant changes from the Draft Permit:
• Tertiary filters were removed from the description of the wastewater treatment facilities.
• Classification of the receiving stream was changes to Class C, WS -IV.
• Cooling tower blowdown was added to the description of waste streams.
• Chronic toxicity monitoring requirement was moved to the Outfall 002.
This Final Permit maintains the following changes contained in the Draft Permit:
One clarifier was added to the description of the treatment facility.
• The permit limits have recalculated based on the latest OCPSF production information in accordance with
the 40 CFR 414 Subpart D.
• The limits for Cr, Cu, CN, Pb, Ni, and Zn were added to the permit in accordance with the 40 CFR 414
Subpart D.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 One
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748 NorthCarolina
Internet: www.ncwaterquality.org ����y�� /��
An Equal Opportunity 1 Affirmative Action Employer

• The limit for Fluoride (F) was removed from the permit based on the statistical analysis of the effluent data
and the monitoring was reduced to quarterly. The instream monitoring for F was removed from the permit.
If any parts, measurement frequencies or sampling requirements contained in this permit are unacceptable
to you, you have the right to an adjudicatory hearing upon written request within thirty (30) days following receipt
of this letter. This request must be in the form of a written petition, conforming to Chapter 150B of the North
Carolina General Statutes, and filed with the Office of Administrative Hearings (6714 Mail Service Center, Raleigh,
North Carolina 27699-6714). Unless such demand is made, this decision shall be final and binding.
Please note that this permit is not transferable except after notice to the Division. The Division may
require modification or revocation and reissuance of the permit. This permit does not affect the legal requirements
to obtain other permits which may be required by the Division of Water Quality or permits required by the
Division of Land Resources, the Coastal Area Management Act or any other Federal or Local governmental permit
that may be required. If you have any questions concerning this permit, please contact Sergei Chernikov at
telephone number [phone].
Sincerely,
V Y"`
harles Wakild
cc: Central Files
NPDES Files
Fayetteville Regional Office / Surface Water Protection Section
EPA Region IV (e -copy)
Aquatic Toxicology Unit (e -copy)
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 One
Phone: [phone] FAX: [phone] \ Customer Service: 1.877-623-6748 NorthCarohna
Internet: www.ncwaterquality.org �aturalC�
An Equal Opportunity 1 Affirmative Action Employer

Permit NC0003573
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions 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,
E.I. DuPont de Nemours & Co.
is hereby authorized to discharge wastewater and stormwater from a facility located at
DuPont - Fayetteville Works
22828 NC Highway 87
Duart Township
Bladen County
to receiving waters designated as the Cape Fear River in the Cape Fear River Basin in accordance with
effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III, and IV
hereof.
The permit shall become effective March 1, 2012.
This permit and the authorization to discharge shall expire at midnight on October 31, 2016.
Signed this day February 6, 2012.
tTiarles Wakild P.E., Director
V Division of Water Quality
By Authority of the Environmental Management Commission

Permit NC0003573
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby
revoked, and as of this issuance, any previously issued permit bearing this number is no longer
effective. Therefore, the exclusive authority to operate and discharge from this facility arises under the
permit conditions, requirements, terms, and provisions included herein.
E.I. DuPont de Nemours & Co., Inc.
is hereby authorized to:
1. Continue to operate existing wastewater treatment facilities consisting of:
• equalization;
• neutralization;
• aerated pre -digester tank;
• nutrient feed system;
• aeration tank;
• three clarifiers;
• effluent flow measurement;
• DAF unit;
• rotary filter for sludge thickening;
• sludge pump;
• sludge filter press; and
• steam heated sludge dryers.
2. Discharge treated process wastewater from Butacite®, Nafion®, SentryGlas®, and PVF
(polyvinyl fluoride resin), process stormwater, sanitary wastewater, and co -neutralized
regenerate from said treated facilities through internal outfall 001;
3. Discharge stormwater, non -contact cooling water, boiler blowdown and condensate,
cooling tower blowdown, and treated wastewater effluent from 001, through outfall 002
at the location specified on the attached map into the Cape Fear River, a class C, WS -1V
water in the Cape Fear River Basin.

Permit NC0003573
A. (2) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - SUBPART I (CONTUNUED)
Beginning on the effective date of this permit and lasting through the expiration date, the Permittee shall comply
with the limitations and monitoring frequencies established below at outfall 001:
PARAMETER
EFFLUENT LIMITATIONS
MONITORING REQUIREMENTS
Monthly
Avera el
Daily
1Vlaidmum1
Measurement
Frequency
Sample
e
Sample
Location
Fluoranthene
0.188
28.2 ug/L
See Note 2
Grab
Effluent
Fluorene
0.166
0.444
See Note 2
Grab
Effluent
Hexachlorobenzene
0.113
0.5 gg/L
Annually3
Grab
Effluent
Hexachlorobutadiene
0.151
0.369
See Note 2
Grab
Effluent
Hexachloroethane
0.158
0.406
See Note 2
Grab
Effluent
Methyl Chloride
0.647
1.430
See Note 2
Grab
Effluent
Methylene Chloride
0.301
0.670
See Note 2
Grab
Effluent
Naphthalene
0.166
0.444
See Note 2
Grab
Effluent
Nitrobenzene
0.203
0.512
See Note 2
Grab
Effluent
2-Nitrophenol
0.309
0.519
See Note 2
Grab
Effluent
4-Nitrophenol
0.542
0.933
See Note 2
Grab
Effluent
Phenanthrene
0.166
0.444
See Note 2
Grab
Effluent
Phenol
0.113
0.196
See Note 2
Grab
Effluent
Pyrene
0.188
0.504
See Note 2
Grab
Effluent
Tetrachloroethylene
0.166
0.422
See Note 2
Grab
Effluent
Toluene
0.196
0.602
See Note 2
Grab
Effluent
1,2,4-Trichlorobenzene
0.512
1.054
See Note 2
Grab
Effluent
1,1,1 -Trichloroethane
0.158
0.406
See Note 2
Grab
Effluent
1,1,2 -Trichloroethane
0.158
0.406
See Note 2
Grab
Effluent
Trichloroethylene
0.158
0.406
See Note 2
Grab
Effluent
Vinyl Chloride
0.783
2.017
See Note 2
Grab
Effluent
Total Chromium
8.355
20.849
Annually
Grab
Effluent
Total Copper
10.914
25.441
Annually
Grab
Effluent
Total Cyanide
3.161
9.032
See Note 2
Grab
Effluent
Total Lead
2.409
5.194
See Note 2
Grab
Effluent
Total Nickel
12.720
29.957
Annually
Grab
Effluent
Total Zinc
7.903
j 19.645
Annually
Grab
Effluent
Notes:
1. All units are lbs/day unless otherwise noted.
2. Monitoring for the specified parameters has been waived based on a demonstration made by the Permittee in
accordance with 40 CFR 122.44(a)(2)(i). This waiver is good only for the term of the permit. Please note that
any exceedence of the effluent limitations found herein shall be considered a permit violation subject to
appropriate enforcement action.
3. The most sensitive analytical method available shall be employed for determining the presence of
hexachlorobenzene in the effluent.

Permit NC0003573
A. (3) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
Beginning on the effective date of this permit and lasting through the expiration date, the Permittee is authorized
to discharge from Outfall 002 (boiler blowdown, once -through cooling water, and treated wastewater from
outfall 001) Such discharges shall be limited and monitored by the Permittee as specified below:
PARAMETER
EFFLUENT LIMITATIONS
MONITORING REQUIREMENTS
Monthly Daily
Average Maximum
Measurement
Frequency
I Sample
e .
Sample
Location'
Flow (MGD)
Continuous
Recording
Effluent or
Influent
Temperature, °C
See Note 2
Daily3
Grab
Effluent,
Upstream,
Downstream
BODS, 20°C
Quarterly
Composite
Effluent
COD
Quarterly
Composite
Effluent
Fluoride (ug/L)
Quarterly
Grab
Effluent
Dissolved Oxygen
Weekly
Grab
Upstream,
Downstream
PFOA4
Monthly
Grab
_Effluent -
Total Phosphorus
Monthly
Composite
Effluent
Total Nitrogen
(NO2+NO3+TKN)
Monthly
Composite
Effluent
Conductivity
Weekly
Grab
Upstream,
Downstream
Chronic Toxicity
See Note 5
Quarterly
Composite
Effluent
pH
Between 6.0 and 9.0 Standard Units
3/Week
Grab
Effluent
Notes:
1. Upstream shall be at the Permittee's river pump station; downstream shall be at the boat ramp approximately
4500 feet downstream at Prospect Hall Landing.
As a participant in the Middle Cape Fear River Basin Association, the instream monitoring requirements as
stated above are waived. Should your membership in the agreement be terminated, you shall notify the
Division immediately and the instream monitoring requirements specified in your permit shall be reinstated.
2. The temperature of the effluent shall be such as not to cause an increase in the temperature of the receiving
stream of more than 2.8°C and in no case cause the ambient water temperature to exceed 32°C.
3. Daily shall be defined as every day except Saturdays, Sundays, and legal holidays. Instream temperature
sampling shall be conducted weekly.
4. PFOA (Perfluorooctanoic acid) - The Cape Fear River water intake may be sampled for PFOA on a monthly
basis and reported as an upstream parameter in DWQ Form - MR -3.
5. Chronic Toxicity (Ceriodaphnia) P/F Q 3.3% February, May, August, November; see condition A. (4) of this
permit. The compliance monitoring point for chronic toxicity shall be downstream of the confluence of outfall
001 and 002.
THERE SHALL BE NO DISCHARGE OF FLOATING SOLIDS OR VISIBLE FOAM IN OTHER THAN TRACE AMOUNTS.

Permit NC0003573
A. (1) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
Beginning on the effective date of this permit and lasting through the expiration date, the Permittee is authorized
to discharge from Outfall 001. Such discharges shall be limited and monitored by the Permittee as specified
below:
PARAMETER
EFFLUENT LIMITATIONS
MONITORING REQUIREMENTS
Monthly Daily
Average Maximum
Measurement
Frequency
Sample Sample
e Location
Flow (MGD)
2.0
Continuous
Recording
Effluent
BODS, 20° C
182.61bs/day
484.7 lbs/day
3/Week
Composite
Effluent
Total Suspended Solids
303.1 lbs/day
981.5 lbs/day
3/Week
Composite
Effluent
Temperature
Weekly
Grab
Effluent
Oil & Grease
Monthly
Grab
Effluent
pH
Between 6.0 and 9.0 Standard Units
3/Week
Grab
Effluent
40 CFR 414 Subpart I
See Condition A. (2)
THERE SHALL BE NO DISCHARGE OF FLOATING SOLIDS OR VISIBLE FOAM IN OTHER THAN TRACE AMOUNTS.

Permit NC0003573
A. (2) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - SUBPART I
Beginning on the effective date of this permit and lasting through the expiration date, the Permittee shall comply
with the limitations and monitoring frequencies established below at outfall 001:
PAPAlVIETER
EFFLUENT LIMITATIONS
MONITORING REQUIREMENTS
Monthly
Average'
Daily
Maximum'
Measurement
Frequency
Sample
e
Sample
Location
Acenaphthene
0.166
0.444
See Note 2
Grab
Effluent
Acenaphthylene
0.166
0.444
See Note 2
Grab
Effluent
Acrylonitrile
0.723
1.821
See Note 2
Grab
Effluent
Anthracene
0.166
12.8 ug/L
See Note 2
Grab
Effluent
Benzene
0.278
1.024
See Note 2
Grab
Effluent
Benzo(a)anthracene
0.166
0.444
See Note 2
Grab
Effluent
3,4-Benzofluoranthene
0.173
0.459
See Note 2
Grab
Effluent
Benzo(k)fluoranthene
0.166
0.444
See Note 2
Grab
Effluent
Benzo(a)pyrene
0.173
0.459
See Note 2
Grab
Effluent
Bis(2-ethylhexyl) phthalate
0.775
2.100
See Note 2
Grab
Effluent
Carbon Tetrachloride
0.135
0.286
See Note 2
Grab
Effluent
Chlorobenzene
0.113
0.211
See Note 2
Grab
Effluent
Chloroethane
0.783
2.017
See Note 2
Grab
Effluent
Chloroform
0.158
0.346
See Note 2
Grab
Effluent
2 -Chlorophenol
0.233
0.738
See Note 2
Grab
Effluent
Chrysene
0.166
0.444
See Note 2
Grab
Effluent
Di -n -butyl phthalate
0.203
0.429
See Note 2
Grab
Effluent
1,2 -Dichlorobenzene
0.580
1.227
See Note 2
Grab
Effluent
1,3 -Dichlorobenzene
0.233
0.331
See Note 2
Grab
Effluent
1,4 -Dichlorobenzene
0.113
0.211
See Note 2
Grab
Effluent
1,1-Dichloroethane
0.166
0.444
See Note 2
Grab
Effluent
1,2-Dichloroethane
0.512
1.588
See Note 2
Grab
Effluent
1,1-Dichloroethylene
0.120
0.188
See Note 2
Grab
Effluent
1,2-trans-Dichloroethylene
0.158
0.406
See Note 2
Grab
Effluent
214-Dichlorophenol
0.294
0.843
See Note 2
Grab
Effluent
1,2-Dichloropropane
1.152
1.731
See Note 2
Grab
Effluent
1,3-Dichloropropylene
0.218
0.331
See Note 2
Grab
Effluent
Diethyl phthalate
0.610
1.528
See Note 2
Grab
Effluent
2,4 -Dimethylphenol
0.135
0.271
See Note 2
Grab
Effluent
Dimethyl phthalate
0.143
0.354
See Note 2
Grab
Effluent
4,6-Dinitro-o-cresol
0.587
2.085
See Note 2
Grab
Effluent
2,4-Dinitrophenol
0.534
0.926
See Note 2
Grab
Effluent
2,4-Dinitrotoluene
0.851
2.145
See Note 2
Grab
Effluent
2,6-Dinitrotoluene
1.919
12.3 ug/L
See Note 2
Grab
Effluent
Ethylbenzene
0.241
0.813
See Note 2
Grab
Effluent

Permit NC0003573
A. (4) CHRONIC TOXICITY PERMIT LIMIT (QUARTERLY) — OUTFALL 002
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to
Ceriodaphnia dubia at an effluent concentration of 3.3%.
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 February, May, August, and November. 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 THP313 for the Chronic Value. Additionally, DWQ Form AT -3 (original) is to be sent to the
following address:
Attention: Environmental Sciences Section
North Carolina Division of Water Quality
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.
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.

Permit NC0003573
A. (5) RE -OPENER CONDITION
This permit shall be modified, or revoked and reissued to incorporate additional toxicity limitations and
monitoring requirements in the event toxicity testing or other studies conducted on the effluent or receiving
stream indicate that detrimental effects may be expected in the receiving stream as a result of this discharge.
A. (6) BIOCIDE CONDITION
The permittee shall not use any biocide except those approved in conjunction with the permit application. The
permittee shall notify the Director in writing not later than ninety (90) days prior to instituting use of any
additional biocide used in cooling systems which may be toxic to aquatic life other than those previously reported
to the Division of Water Quality. Such notification shall include completion of Biocide Worksheet Form 101 and a
map locating the discharge point and receiving stream.

NPDES Permit Standard Conditions
Page 1 of 18
PART II
STANDARD CONDITIONS FOR NPDES PERMITS
Section A. Definitions
2/Month
Samples are collected twice per month with at least ten calendar days between sampling events. These samples shall be
representative of the wastewater discharged during the sample period.
3/Week
Samples are collected three times per week on three separate calendar days. These samples shall be representative of
the wastewater discharged during the sample period.
Act or "the Act"
The Federal Water Pollution Control Act, also known as the Clean Water Act (CWA), as amended, 33 USC 1251, et.
seq.
Annual Average
The arithmetic mean of all "daily discharges" of a pollutant measured during the calendar year. In the case of fecal
coliform, the geometric mean of such discharges.
Arithmetic Mean
The summation of the individual values divided by the number of individual values.
Bypass
The known diversion of waste streams from any portion of a treatment facility including the collection system, which is
not a designed or established or operating mode for the facility.
Calendar Day
The period from midnight of one day until midnight of the next day. However, for purposes of this permit, any
consecutive 24-hour period that reasonably represents the calendar day may be used for sampling.
Calendar Week
The period from Sunday through the following Saturday.
Calendar Quarter
One of the following distinct periods: January through March, April through June, July through September, and
October through December.
Composite Sample
A sample collected over a 24-hour period by continuous sampling or combining grab samples of at least 100 ml, in
such a manner as to result in a total sample representative of the wastewater discharge during the sample period. The
Director may designate the most appropriate method (specific number and size of aliquots necessary, the time interval
between grab samples, etc.) on a case-by-case basis. Samples may be collected manually or automatically. Composite
samples may be obtained by the following methods:
(1) Continuous: a single, continuous sample collected over a 24-hour period proportional to the rate of flow.
(2) Constant time/variable volume: a series of grab samples collected at equal time intervals over a 24 hour period
of discharge and combined proportional to the rate of flow measured at the time of individual sample
collection, or
(3) Variable time/constant volume: a series of grab samples of equal volume collected over a 24 hour period with
the time intervals between samples determined by a preset number of gallons passing the sampling point. Flow
measurement between sample intervals shall be determined by use of a flow recorder and totalizer, and the
preset gallon interval between sample collection fixed at no greater than 1/24 of the expected total daily flow at
the treatment system, or
Version 11/09/2011

NPDES Permit Standard Conditions
Page 2 of 18
(4) Constant time/constant volume: a series of grab samples of equal volume collected over a 24-hour period at a
constant time interval. Use of this method requires prior approval by the Director. This method may only be
used in situations where effluent flow rates vary less than 15 percent. The following restrictions also apply:
➢ Influent and effluent grab samples shall be of equal size and of no less than 100 milliliters
➢ Influent samples shall not be collected more than once per hour.
➢ Permittees with wastewater treatment systems whose detention time < 24 hours shall collect effluent grab
samples at intervals of no greater than 20 minutes apart during any 24-hour period.
➢ Permittees with wastewater treatment systems whose detention time exceeds 24 hours shall collect effluent
grab samples at least every six hours; there must be a minimum of four samples during a 24-hour sampling
period.
Continuous flow measurement
Flow monitoring that occurs without interruption throughout the operating hours of the facility. Flow shall be .
monitored continually except for the infrequent times when there may be no flow or for infrequent maintenance
activities on the flow device.
Daily Discharge
The discharge of a pollutant measured during a calendar day or any 24-hour period that reasonably represents the
calendar day for purposes of sampling. For pollutants measured in units of mass, the "daily discharge" is calculated as
the total mass of the pollutant discharged over the day. For pollutants expressed in other units of measurement, the
"daily discharge" is calculated as the average measurement of the pollutant over the day. (40 CFR 122.2; see also
"Composite Sample," above.)
Daily Maximum
The highest "daily discharge" during the calendar month.
Daily Sampling
Parameters requiring daily sampling shall be sampled 5 out of every 7 days per week unless otherwise specified in the
permit. Sampling shall be conducted on weekdays except where holidays or other disruptions of normal operations
prevent weekday sampling. If sampling is required for all seven days of the week for any permit parameter(s), that
requirement will be so noted on the Effluent Limitations and Monitoring Page(s).
DWQ or "the Division"
The Division of Water Quality, Department of Environment and Natural Resources.
Effluent
Wastewater discharged following all treatment processes from a water pollution control facility or other point source
whether treated or untreated.
EMC
The North Carolina Environmental Management Commission
EPA
The United States Environmental Protection Agency
Facility Closure
Cessation of all activities that require coverage under this NPDES permit. Completion of facility closure will allow this
permit to be rescinded.
Geometric Mean
The Nth root of the product of the individual values where N = the number of individual values. For purposes of
calculating the geometric mean, values of "0" (or "< [detection level]") shall be considered = 1.
Grab Sample,
Individual samples of at least 100 mL collected over a. period of time not exceeding 15 minutes. Grab samples can be
collected manually. Grab samples must be representative of the discharge (or the receiving stream, for instream
samples).
Version 11/09/2011

NPDES Permit Standard Conditions
Page 3 of 18
Hazardous Substance
Any substance designated under 40 CFR Part 116 pursuant to Section 311 of the CWA.
Instantaneous flow measurement
The flow measured during the minimum time required for the flow measuring device or method to produce a result in
that instance. To the extent practical, instantaneous flow measurements coincide with the collection of any grab
samples required for the same sampling period so that together the samples and flow are representative of the discharge
during that sampling period.
Monthlyverage (concentration limit)
The arithmetic mean of all "daily discharges" of a pollutant measured during the calendar month. In the case of fecal
coliform or other bacterial parameters or indicators, the geometric mean of such discharges.
Permit Issuing Authority
The Director of the Division of Water Quality.
Quarterly Average (concentration limit)
The arithmetic mean of all samples taken over a calendar quarter.
Severe property damage
Substantial physical damage to property, damage to the treatment facilities which causes them to become inoperable, or
substantial and -permanent loss of natural resources which can reasonably be expected to occur in the absence of a
bypass. Severe property damage excludes economic loss caused by delays in production.
Toxic Pollutant:
Any pollutant listed as toxic under Section 307(a)(1) of the CWA.
Unset
An incident beyond the reasonable control of the Permittee causing unintentional and temporary noncompliance with
permit effluent limitations and/or monitoring requirements. An upset does not include noncompliance caused by
operational error, improperly designed treatment facilities, inadequate treatment facilities, lack of preventive
maintenance, or careless or improper operation.
Weekly verage (concentration limit)
The arithmetic mean of all "daily discharges" of a pollutant measured during the calendar week. In the case of fecal
coliform or other bacterial parameters or indicators, the geometric mean of such discharges.
Section B. General Conditions
Duty to Comply
The Permittee must comply with all conditions of this permit. Any permit noncompliance constitutes a violation of
the CWA and is grounds for enforcement action; for permit termination, revocation and reissuance, or
modification; or denial of a permit renewal application [40 CFR 122.41].
a. The Permittee shall comply with effluent standards or prohibitions established under section 307(a) of the
CWA for toxic pollutants and with standards for sewage sludge use or disposal established under section
405(d) of the CWA within the time provided in the regulations that establish these standards or prohibitions or
standards for sewage sludge use or disposal, even if the permit has not yet been modified to incorporate the
requirement.
b. The CWA provides that any person who violates section[s] 301, 302, 306, 307, 308, 318 or 405 of the Act, or
any permit condition or limitation implementing any such sections in a permit issued under section 402, or any
requirement imposed in a pretreatment program approved under sections 402(a)(3) or 402(b)(8) of the Act, is
subject to a civil penalty not to exceed $37,500 per day for each violation. [33 USC 1319(d) and 40 CFR
122.41(a)(2)]
c. The CWA provides that any person who negligently violates sections 301, 302, 306, 307, 308, 318, or 405 of
the Act, or any condition or limitation implementing any of such sections in a permit issued under section 402
of the Act, or any requirement imposed in a pretreatment program approved under section 402(a)(3) or
402(b)(8) of the Act, is subject to criminal penalties of $2,500 to $25,000 per day of violation, or
Version 11/09/2011

NPDES Permit Standard Conditions
Page 4 of 18
imprisonment of not more than 1 year, or both. In the case of a second or subsequent conviction for a negligent
violation, a person shall be subject to criminal penalties of not more than $50,000 per day of violation, or by
imprisonment of not more than 2 years, or both. [33 USC 1319(c)(1) and 40 CFR 122.41(a)(2)]
d. Any person who knowingly violates such sections, or such conditions or limitations is subject to criminal
penalties of $5,000 to $50,000 per day of violation, or imprisonment for not more than 3 years, or both. In the
case of a second or subsequent conviction for a knowing violation, a person shall be subject to criminal
penalties of not more than $100,000 per day of violation, or imprisonment of not more than 6 years, or both.
[33 USC 1319(c)(2) and 40 CFR 122.41(a)(2)]
e. Any person who knowingly violates section 301, 302, 303, 306, 307, 308, 318 or 405 of the Act, or any permit
condition or limitation implementing any of such sections in a permit issued under section 402 of the Act, and
who knows at that time that he thereby places another person in imminent danger of death or serious bodily
injury, shall, upon conviction, be subject to a fine of not more than $250,000 or imprisonment of not more than
15 years, or both. In the case of a second or subsequent conviction for a knowing endangerment violation, a
person shall be subject to a fine of not more than $500,000 or by imprisonment of not more than 30 years, or
both. An organization, as defined in section 309(c)(3)(B)(iii) of the CWA, shall, upon conviction of violating
the imminent danger provision, be subject to a fine of not more than $1,000,000 and can be fined up to
$2,000,000 for second or subsequent convictions. [40 CFR 122.41(a)(2)]
f. Under state law, a civil penalty of not more than $25,000 per violation may be assessed against any person
who violates or fails to act in accordance with the terms, conditions, or requirements of a permit. [North
Carolina General Statutes § 143-215.6A]
g. Any person may be assessed an administrative penalty by the Administrator for violating section 301, 302,
306, 307, 308, 318 or 405 of this Act, or any permit condition or limitation implementing any of such sections
in a permit issued under section 402 of this Act. Administrative penalties for Class I violations are not to
exceed $16,000 per violation, with the maximum amount of any Class I penalty assessed not to exceed
$37,500. Penalties for Class II violations are not to exceed $16,000 per day for each day during which the
violation continues, with the maximum amount of any Class II penalty not to exceed $177,500. [33 USC
1319(g)(2) and 40 CFR 122.41(a)(3)]
2. Dg1y to Mitigate
The Permittee shall take all reasonable steps to minimize or prevent any discharge or sludge use or disposal in
violation of this permit with a reasonable likelihood of adversely affecting human health or the environment [40
CFR 122.41(d)].
3. Civil and Criminal Liability
Except as provided in permit conditions on 'Bypassing" (Part R.C.4), "Upsets" (Part ILC.5) and "Power Failures"
(Part II.C.7), nothing in this permit shall be construed to relieve the Permittee from any responsibilities, liabilities,
or penalties for noncompliance pursuant to NCGS 143-215.3, 143-215.6 or Section 309 of the Federal Act, 33 USC
1319. Furthermore, the Permittee is responsible for consequential damages, such as fish kills, even though the
responsibility for effective compliance may be temporarily suspended.
4. Oil and Hazardous Substance Liability
Nothing in this permit shall be construed to preclude the institution of any legal action or relieve the Permittee
from any responsibilities, liabilities, or penalties to which the Permittee is or may be subject to under NCGS 143-
215.75 et seq. or Section 311 of the Federal Act, 33 USG 1321. Furthermore, the Permittee is responsible for
consequential damages, such as fish kills, even though the responsibility for effective compliance may be
temporarily suspended.
5. Properly Rights
The issuance of this permit does not convey any property rights in either real or personal property, or any exclusive
privileges, nor does it authorize any injury to private property or any invasion of personal rights, nor any
infringement of Federal, State or local laws or regulations [40 CFR 122.41(g)].
6. Onshore or Offshore Construction
This permit does not authorize or approve the construction of any onshore or offshore physical structures or
facilities or the undertaking of any work in any navigable waters.
Version 11/09/2011

NPDES Permit Standard Conditions
Page 5 of 18
7. Severability
The provisions of this permit are severable. If any provision of this permit, or the application of any provision of
this permit to any circumstances, is held invalid, the application of such provision to other circumstances, and the
remainder of this permit, shall not be affected thereby [NCGS 150B-23].
8. Duty to Provide Information
The Permittee shall furnish to the Permit Issuing Authority, within a reasonable time, any information which the
Permit Issuing Authority may request to determine whether cause exists for modifying, revoking and reissuing, or
terminating this permit or to determine compliance with this permit. The Permittee shall also furnish to the Permit
Issuing Authority upon request, copies of records required by this permit [40 CFR 122.41(h)].
9. D= to Reapply
If the Permittee wishes to continue an activity regulated by this permit after the expiration date of this permit, the
Permittee must apply for and obtain a new permit [40 CFR 122.41(b)].
10. Expiration of Permit
The Permittee is not authorized to discharge after the expiration date. In order to receive automatic authorization to
discharge beyond the expiration date, the Permittee shall submit such information, forms, and fees as are required
by the agency authorized to issue permits no later than 180 days prior to the expiration date unless permission for a
later date has been granted by the Director. (The Director shall not grant permission for applications to be
submitted later than the expiration date of the existing permit.) [40 CFR 122.21(d)] Any Permittee that has not
requested renewal at least 180 days prior to expiration, or any Permittee that does not have a permit after the
expiration and has not requested renewal at least 180 days prior to expiration, will subject the Permittee to
enforcement procedures as provided in NCGS 143-215.6 and 33 USC 1251 et. seq.
11. Signatory Requirements
All applications, reports, or information submitted to the Permit Issuing Authority shall be signed and certified [40
CFR 122.41(k)].
a. All permit applications shall be signed as follows:
(1) For a corporation: by a responsible corporate officer. For the purpose of this Section, a responsible
corporate officer means: (a) a president, secretary, treasurer or vice president of the corporation in charge
of a principal business function, or any other person who performs similar policy or decision making
functions for the corporation, or (b) the manager of one or more manufacturing, production, or operating
facilities, provided, the manager is authorized to make management decisions which govern the operation
of the regulated facility including having the explicit or implicit duty of making major capital investment
recommendations, and initiating and directing other comprehensive measures to assure long term
environmental compliance with environmental laws and regulations; the manager can ensure that the
necessary systems are established or actions taken to gather complete and accurate information for permit
application requirements; and where authority to sign documents has been assigned or delegated to the
manager in accordance with corporate procedures .
(2) For a partnership or sole proprietorship: by a general partner or the proprietor, respectively; or
(3) For a municipality, State, Federal, or other public agency: by either a principal executive officer or
ranking elected official [40 CFR 122.22].
b. All reports required by the permit and other information requested by the Permit Issuing Authority shall be
signed by a person described in paragraph a. above or by a duly authorized representative of that person. A
person is a duly authorized representative only if:
(1) The authorization is made in writing by a person described above;
(2) The authorization specified either an individual or a position having responsibility for the overall operation
of the regulated facility or activity, such as the position of plant manager, operator of a well or well field,
superintendent, a position of equivalent responsibility, or an individual or position having overall
responsibility for environmental matters for the company. (A duly authorized representative may thus be
either a named individual or any individual occupying a named position.); and
(3) The written authorization is submitted to the Permit Issuing Authority [40 CFR 122.22]
Version 11/09/2011

NPDES Permit Standard Conditions
Page 6 of 18
c. Changes to authorization: If an authorization under paragraph (b) of this section is no longer accurate because
a different individual or position has responsibility for the overall operation of the facility, a new authorization
satisfying the requirements of paragraph (b) of this section must be submitted to the Director prior to or
together with any reports, information, or applications to be signed by an authorized representative [40 CFR
122.22]
d. Certification. Any person signing a document under paragraphs a. or b. of this section shall make the following
certification [40 CFR 122.221. NO OTHER STATEMENTS OF CERTIFICATION WILL BE ACCEPTED:
7 cert, 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 fines and imprisonment for knowing violations. "
12. Permit Actions
This permit may be modified, revoked and reissued, or terminated for cause. The filing of a request by the
Permittee for a permit modification, revocation and reissuance, or termination, or a notification of planned changes
or anticipated noncompliance does not stay any permit condition [40 CFR 122.41(f)].
13. Permit Modification, Revocation and Reissuance, or Termination
The issuance of this permit does not prohibit the permit issuing authority from reopening and modifying the permit,
revoking and reissuing the permit, or terminating the permit as allowed by the laws, rules, and regulations
contained in Title 40, Code of Federal Regulations, Parts 122 and 123; Title 15A of the North Carolina
Administrative Code, Subchapter 02H .0100; and North Carolina General Statute 143.215.1 et. al.
14. Annual Administering and Compliance Monitoring Fee Requirements
The Permittee must pay the annual administering and compliance monitoring fee within thirty days after being
billed by the Division. Failure to pay the fee in a timely manner in accordance with 15A NCAC 02H .0105(b)(2)
may cause this Division to initiate action to revoke the permit.
Section C. Operation and Maintenance of Pollution Controls
Certified Operator
Owners of classified water pollution control systems must designate operators, certified by the Water Pollution
Control System Operators Certification Commission (WPCSOCC), of the appropriate type and grade for the
system, and, for each classification must [T15A NCAC 08G.0201]:
a. designate one Operator In Responsible Charge (ORC) who possesses a valid certificate of the type and grade at
least equivalent to the type and grade of the system;
b. designate one or more Back-up Operator(s) in Responsible Charge (Back-up ORCs) who possesses a valid
certificate of the type of the system and no more than one grade less than the grade of the system, with the
exception of no backup operator in responsible charge is required for systems whose minimum visitation
requirements are twice per year; and
c, submit a signed completed "Water Pollution Control System Operator Designation Form" to the Commission
(or to the local health department for owners of subsurface systems) countersigned by the designated certified
operators, designating the Operator in Responsible Charge (ORC) and the Back-up Operator in Responsible
Charge (Back-up ORC):
(1) 60 calendar days prior to wastewater or residuals being introduced into a new system; or
(2) within 120 calendar days following:
➢ receiving notification of a change in the classification of the system requiring the designation of a new
Operator in Responsible Charge (ORC) and Back-up Operator in Responsible Charge (Back-up ORC)
of the proper type and grade; or
➢ a vacancy in the position of Operator in Responsible Charge (ORC) or Back-up Operator in
Responsible Charge (Back-up ORC).
Version 1110912011

NPDES Permit Standard Conditions
Page 7 of 18
(3) within seven calendar days of vacancies in both ORC and Back-up ORC positions replacing or designating
at least one of the responsibilities.
The ORC of each Class I facility (or the Back-up ORC, when acting as surrogate for the ORC) must:
➢ Visit the facility as often as is necessary to insure proper operation of the treatment system; the treatment
facility must be visited at least weekly
➢ Comply with all other conditions of 15A NCAC 08G.0204.
The ORC of each Class II, III and IV facility (or the Back-up ORC, when acting as surrogate for the ORC) must:
➢ Visit the facility as often as is necessary to insure proper operation of the treatment system; the treatment
facility must be visited at least five days per week, excluding holidays
➢ Properly manage and document daily operation and maintenance of the facility
➢ Comply with all other conditions of 15A NCAC 08G.0204.
Proper Operation and Maintenance
The Permittee shall at all times properly operate and maintain all facilities and systems of treatment and control
(and related appurtenances) which are installed or used by the Permittee to achieve compliance with the conditions
of this permit. Proper operation and maintenance also includes adequate laboratory controls and appropriate quality
assurance procedures. This provision requires the Permittee to install and operate backup or auxiliary facilities only
when necessary to achieve compliance with the conditions of the permit [40 CFR 122.41(e)].
NOTE: Properly and officially designated operators are fully responsible for all proper operation and maintenance
of the facility, and all documentation required thereof, whether acting as a contract operator [subcontractor] or a
member of the Permittee's staff.
3. Need to Halt or Reduce not a Defense
It shall not be a defense for a Permittee in an enforcement action that it would have been necessary to halt or
reduce the permitted activity in order to maintain compliance with the condition of this permit [40 CFR 122.41(c)].
4. Bypassing of Treatment Facilities
a. Bypass not exceeding limitations [40 CFR 122.41(m)(2)]
The Permittee may allow any bypass to occur which does not cause effluent limitations to be exceeded, but
only if it also is for essential maintenance to assure efficient operation. These bypasses are not subject to the
provisions of Paragraphs b. and c. of this section.
b. Notice [40 CFR 122.41(m)(3)]
(1) Anticipated bypass. If the Permittee knows in advance of the need for a bypass, it shall submit prior notice,
if possible at least ten days before the date of the bypass; including an evaluation of the anticipated quality
and effect of the bypass.
(2) Unanticipated bypass. The Permittee shall submit notice of an unanticipated bypass as required in Part
II.E.6. (24-hour notice).
c. Prohibition of Bypass
(1) Bypass from, the treatment facility is prohibited and the Permit Issuing Authority may take enforcement
action against a Permittee for bypass, unless:
(A) Bypass was unavoidable to prevent loss of life, personal injury or severe property damage;
(B) There were no feasible alternatives to the bypass, such as the use of auxiliary treatment facilities,
retention of untreated wastes or maintenance during normal periods of equipment downtime. This
condition is not satisfied if adequate backup equipment should have been installed in the exercise of
reasonable engineering judgment to prevent a bypass which occurred during normal periods of
equipment downtime or preventive maintenance; and
(C) The Permittee submitted notices as required under Paragraph b. of this section.
(2) Bypass from the collection system is prohibited and the Permit Issuing Authority may take enforcement
action against a Permittee for a bypass as provided in any current or future system -wide collection system
permit associated with the treatment facility.
Version 11/09/2011

NPDES Permit Standard Conditions
Page 8 of 18
(3) The Permit Issuing Authority may approve an anticipated bypass, after considering its adverse effects, if
the Permit Issuing Authority determines that it will meet the three conditions listed above in Paragraph c.
(1) of this section.
5. Upsets
a. Effect of an upset [40 CFR 122.41(n)(2)]: An upset constitutes an affirmative defense to an action brought for
noncompliance with such technology based permit effluent limitations if the requirements of paragraph b. of
this condition are met. No determination made during administrative review of claims that noncompliance was
caused by upset, and before an action for noncompliance, is final administrative action subject to judicial
review.
b. Conditions necessary for a demonstration of upset: Any Permittee who wishes to establish the affirmative
defense of upset shall demonstrate, through properly signed, contemporaneous operating logs, or other relevant
evidence that:
(1) An upset occurred and that the Permittee can identify the cause(s) of the upset;
(2) The Permittee facility was at the time being properly operated; and
(3) The Permittee submitted notice of the upset as required in Part II.E.6.(b) of this permit.
(4) The Permittee complied with any remedial measures required under Part II.B.2. of this permit.
c. Burden of proof [40 CFR 122.41(n)(4)1: The Permittee seeking to establish the occurrence of an upset has
the burden of proof in any enforcement proceeding.
6. Removed Substances
Solids, sludges, filter backwash, or other pollutants removed in the course of treatment or control of wastewaters
shall be utilized/disposed of in accordance with NCGS 143-215.1 and in a manner such as to prevent any pollutant
from such materials from entering waters of the State or navigable waters of the United States except as permitted
by the Commission. The Permittee shall comply with all applicable state and Federal regulations governing the
disposal of sewage sludge, including 40 CFR 503, Standards for the Use and Disposal of Sewage Sludge; 40 CFR
Part 258, Criteria For Municipal Solid Waste Landfills; and 15A NCAC Subchapter 2T, Waste Not Discharged To
Surface Waters. The Permittee shall notify the Permit Issuing Authority of any significant change in its sludge use
or disposal practices.
7. Power Failures
The Permittee is responsible for maintaining adequate safeguards (as required by 15A NCAC 02H .0124) to
prevent the discharge of untreated or inadequately treated wastes during electrical power failures either by means
of alternate power sources, standby generators or retention of inadequately treated effluent.
Section D. Monitoring and Records
Representative Sampling
Samples collected and measurements taken, as required herein, shall be representative of the permitted discharge.
Samples collected at a frequency less than daily shall be taken on a day and time that is representative of the
discharge for the period the sample represents. All samples shall be taken at the monitoring points specified in this
permit and, unless otherwise specified, before the effluent joins or is diluted by any other wastestream, body of
water, or substance. Monitoring points shall not be changed without notification to and the approval of the Permit
Issuing Authority [40 CFR 122.41(j)].
2. Reporting
Monitoring results obtained during the previous month(s) shall be summarized for each month and reported on a
monthly Discharge Monitoring Report (DMR) Form (MR 1, 1. 1, 2, 3) or alternative forms approved by the
Director, postmarked no later than the last calendar day of the month following the completed reporting period.
The first DMR is due on the last day of the month following the issuance of the permit or in the case of a new
facility, on the last day of the month following the commencement of discharge. Duplicate signed copies of these,
and all other reports required herein, shall be submitted to the following address:
Version 11/09/2011

NPDES Permit Standard Conditions
Page 9of18
NC DENR / Division of Water Quality / Surface Water Protection Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
3. Flow Measurements
Appropriate flow measurement devices and methods consistent with accepted scientific practices shall be selected
and used to ensure the accuracy and reliability of measurements of the volume of monitored discharges. The
devices shall be installed, calibrated and maintained to ensure that the accuracy of the measurements is consistent
with the accepted capability of that type of device. Devices selected shall be capable of measuring flows with a
maximum deviation of less than 10% from the true discharge rates throughout the range of expected discharge
volumes. Flow measurement devices shall be accurately calibrated at a minimum of once per year and maintained
to ensure that the accuracy of the measurements is consistent with the accepted capability of that type of device.
The Director shall approve the flow measurement device and monitoring location prior to installation.
Once -through condenser cooling water flow monitored by pump logs, or pump hour meters as specified in Part I of
this permit. and based on the manufacturer's pump curves shall not be subject to this requirement.
4. Test Procedures
Laboratories used for sample analysis must be certified by the Division. Permittees should contact the Division's
Laboratory Certification Section (919 733-3908 or http://portal.ncdenr.org/web/wq/lab/cert) for information
regarding laboratory certifications.
Facilities whose personnel are conducting testing of field -certified parameters only must hold the appropriate field
parameter laboratory certifications.
Test procedures for the analysis of pollut4nts shall conform to the EMC regulations (published pursuant to NCGS
143-215.63 et. seq.), the Water and Air Quality Reporting Acts, and to regulations published pursuant to Section
304(g), 33 USC 1314, of the CWA (as amended), and 40 CFR 136; or in the case of sludge use or disposal,
approved under 40 CFR 136, unless otherwise specified in 40 CFR 503, unless other test procedures have been
specified in this permit [40 CFR 122.41].
To meet the intent of the monitoring required by this permit, all test procedures must produce minimum detection
and reporting levels that are below the permit discharge requirements and all data generated must be reported down
to the minimum detection or lower reporting level of the procedure: If no approved methods are determined
capable of achieving minimum detection and reporting levels below permit discharge requirements, then the most
sensitive (method with the lowest possible detection and reporting level) approved method must be used.
5. Penalties for Tampering
The CWA provides that any person who falsifies, tampers with, or knowingly renders inaccurate, any monitoring
device or method required to be maintained under this permit shall, upon conviction, be punished by a fine of not
more than $10,000 per violation, or by imprisonment for not more than two years per violation, or by both. If a
conviction of a person is for a violation committed after a first conviction of such person under this paragraph,
punishment is a fine of not more than $20,000 per day of violation, or by imprisonment of not more than 4 years,
or both [40 CFR 122.41 ].
6. Records Retention
Except for records of monitoring information required by this permit related to the Permittee's sewage sludge use
and disposal activities, which shall be retained for a period of at least five years (or longer as required by 40 CFR
503), the Permittee shall retain records of all monitoring information, including:
➢ all calibration and maintenance records
➢ all original strip chart recordings for continuous monitoring instrumentation
➢ copies of all reports required by this permit
➢ copies of all data used to complete the application for this permit
These records or copies shall be maintained for a period of at least 3 years from the date of the sample,
measurement, report or application. This period may be extended by request of the Director at any time [40 CFR
122.41].
Version 11/09/2011

NPDES Permit Standard Conditions
Page 10 of 18
Recording Results
For each measurement or sample taken pursuant to the requirements of this permit, the Permittee shall record the
following information [40 CFR 122.41]:
a. The date, exact place, and time of sampling or measurements;
b. The individual(s) who performed the sampling or measurements;
c. The date(s) analyses were performed;
d. The individual(s) who performed the analyses;
e. The analytical techniques or methods used; and
£ The results of such analyses.
Inspection and Ent1y
The Permittee shall allow the Director, or an authorized representative (including an authorized contractor acting as
a representative of the Director), upon the presentation of credentials and other documents as may be required by
law, to;
a. Enter, at reasonable times, upon the Permittee's premises where a regulated facility or activity is located or
conducted, or where records must be kept under the conditions of this permit;
b. Have access to and copy, at reasonable times, any records that must be kept under the conditions of this permit;
c. Inspect at reasonable times any facilities, equipment (including monitoring and control equipment), practices,
or operations regulated or required under this permit; and
d. Sample or monitor at reasonable times, for the purposes of assuring permit compliance or as otherwise
authorized by the CWA, any substances or parameters at any location [40 CFR 122.41(1)].
Section E Reporting Requirements
1. Change in Discharge
All discharges authorized herein shall be consistent with the terms and conditions of this permit. The discharge of
any pollutant identified in this permit more frequently than or at a level in excess of that authorized shall constitute
a violation of the permit.
2. Planned Changes
The Permittee shall give notice to the Director as soon as possible of any planned physical alterations or additions
to the permitted facility [40 CFR 122.41(1)]. Notice is required only when:
a. The alteration or addition to a permitted facility may meet one of the criteria for new sources at 40 CFR
122.29(b); or
b. The alteration or addition could significantly change the nature or increase the quantity, of pollutants
discharged. This notification applies to pollutants subject neither to effluent limitations in the permit, nor to
notification requirements under 40 CFR 122.42(a)(1); or
c. The alteration or addition results in a significant change in the Permittee's sludge use or disposal practices, and
such alteration, addition or change may justify the application of permit conditions that are different from or
absent in the existing permit, including notification of additional use or disposal sites not reported during the
permit application process or not reported pursuant to an approved land application plan.
Anticipated Noncom liance
The Permittee shall give advance notice to the Director of any planned changes to the permitted facility or other
activities that might result in noncompliance with the permit [40 CFR 122.41(1)(2)].
4. Transfers
This permit is not transferable to any person without prior written notice to and approval from the Director in
accordance with 40 CFR 122.61. The Director may condition approval in accordance with NCGS 143-215.1, in
particular NCGS 143-215. 1 (b)(4)b.2., and may require modification or revocation and reissuance of the permit, or
a minor modification, to identify the new permittee and incorporate such other requirements as may be necessary
under the CWA [40 CFR 122.41(1)(3), 122.61] or state statute.
Version 11/09/2011

NPDES Permit Standard Conditions
Page 11 of 18
5. Monitoring Reports
Monitoring results shall be reported at the intervals specified elsewhere in this permit [40 CFR 122.41(1)(4)].
a. Monitoring results must be reported on a Discharge Monitoring Report (DMR) (See Part II.D.2) or forms
provided by the Director for reporting results of monitoring of sludge use or disposal practices.
b. If the Permittee monitors any pollutant more frequently than required by this permit using test procedures
approved under 40 CFR Part 136 and at a sampling location specified in this permit or other appropriate
instrument governing the discharge, the results of such monitoring shall be included in the calculation and
reporting of the data submitted on the DMR.
6. Twenty-four Hour Reporting
a. The Permittee shall report to the Director or the appropriate Regional Office any noncompliance that
potentially threatens public health or the environment. Any information shall be provided orally within 24
hours from the time the Permittee became aware of the circumstances. A written submission shall also be
provided within 5 days of the time the Permittee becomes aware of the circumstances. The written submission
shall contain a description of the noncompliance, and its cause; the period of noncompliance, including exact
dates and times, and if the noncompliance has not been corrected, the anticipated time it is expected to
continue; and steps taken or planned to reduce, eliminate, and prevent reoccurrence of the noncompliance [40
CFR 122.41(1)(6)].
b. The Director may waive the written report on a case-by-case basis for reports under this section if the oral
report has been received within 24 hours.
c. Occurrences outside normal business hours may also be reported to the Division's Emergency Response
personnel at [phone], [phone] or [phone].
7. Other Noncompliance
The Permittee shall report all instances of noncompliance not reported under Part II.E.5 and 6. of this permit at the
time monitoring reports are submitted. The reports shall contain the information listed in Part II.E.6. of this permit
[40 CFR 122.41(1)(7)].
8. Other Information
Where the Permittee becomes aware that it failed to submit any relevant facts in a permit application, or submitted
incorrect information in a permit application or in any report to the Director, it shall promptly submit such facts or
information [40 CFR 122.41(1)(8)].
9. Noncompliance Notification
The Permittee shall report by telephone to either the central office or the appropriate regional office of the Division
as soon as possible, but in no case more than 24 hours or on the next working day following the occurrence or first
knowledge of the occurrence of any of the following:
a. Any occurrence at the water pollution control facility which results in the discharge of significant amounts of
wastes which are abnormal in quantity or characteristic, such as the dumping of the contents of a sludge
digester; the known passage of a slug of hazardous substance through the facility; or any other unusual
circumstances.
b. Any process unit failure, due to known or unknown reasons, that render the facility incapable of adequate
wastewater treatment such as mechanical or electrical failures of pumps, aerators, compressors, etc.
c. Any failure of a pumping station, sewer line, or treatment facility resulting in a by-pass without treatment of all
or any portion of the influent to such station or facility.
Persons reporting such occurrences by telephone shall also file a written report within 5 days following first
knowledge of the occurrence. Also see reporting requirements for municipalities in Part IV.C.2.c. of this permit.
10. Availability of Reports
Except for data determined to be confidential under NCGS 143-215.3 (a)(2) or Section 308 of the Federal Act, 33
USC 1318, all reports prepared in accordance with the terms shall be available for public inspection at the offices
of the Division. As required by the Act, effluent data shall not be considered confidential. Knowingly making any
false statement on any such report may result in the imposition of criminal penalties as provided for in NCGS 143-
215.1(b)(2) or in Section 309 of the Federal Act.
Version 11/09/2011

NPDES Permit Standard Conditions
Page 12 of 18
11. Penalties for Falsification of Reports
The CWA provides that any person who knowingly makes any false statement, representation, or certification in
any record or other document submitted or required to be maintained under this permit, including monitoring
reports or reports of compliance or noncompliance shall, upon conviction, be punished by a fine of not more than
$25,000 per violation, or by imprisonment for not more than two years per violation, or by both [40 CFR 122.41 ].
12. Annual Performance Reports
Permittees who own or operate facilities that collect or treat municipal or domestic waste shall provide an annual
report to the Permit Issuing Authority and to the users/customers served by the Permittee (NCGS 143-215.1C). The
report shall summarize the performance of the collection or treatment system, as well as the extent to which the
facility was compliant with applicable Federal or State laws, regulations and rules pertaining to water quality. The
report shall be provided no later than sixty days after the end of the calendar or fiscal year, depending upon which
annual period is used for evaluation.
The report shall be sent to:
NC DENR / Division of Water Quality / Surface Water Protection Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Version 11/09/2011

NPDES Permit Standard Conditions
Page 13 of 18
PART III
OTHER REQUIREMENTS
Section A. Construction
a. The Permittee shall not commence construction of wastewater treatment facilities, nor add to the plant's treatment
capacity, nor change the treatment process(es) utilized at the treatment plant unless (1) the Division has issued an
Authorization to Construct (AtC) permit or (2) the Permittee is exempted from such AtC permit requirements
under Item b. of this Section.
b. In accordance with NCGS 143-215.1(a5) [SL 2011-3941, no permit shall be required to enter into a contract for the
construction, installation, or alteration of any treatment work or disposal system or to construct, install, or alter any
treatment works or disposal system within the State when the system's or work's principle function is to conduct,
treat, equalize, neutralize, stabilize, recycle, or dispose of industrial waste or sewage from an industrial facility and
the discharge of the industrial waste or sewage is authorized under a permit issued for the discharge of the
industrial waste or sewage into the waters of the State. Notwithstanding the above, the permit issued for the
discharge may be modified if required by federal regulation.
c. Issuance of an AtC will not occur until Final Plans and Specifications for the proposed construction have been
submitted by the Permittee and approved by the Division.
Section B. Groundwater Monitoring
The Permittee shall, upon written notice from the Director, conduct groundwater monitoring as may be required to
determine the compliance of this NPDES permitted facility with the current groundwater standards.
Section C. Changes in Discharges of Toxic Substances
The Permittee shall notify the Permit Issuing Authority as soon as it knows or has reason to believe (40 CFR 122.42):
a. That any activity has occurred or will occur which would result in the discharge, on a routine or frequent basis, of
any toxic pollutant which is not limited in the permit, if that discharge will exceed the highest of the following
"notification levels";
(1) One hundred micrograms per liter (100 pg/L);
(2) Two hundred micrograms per liter (200 pg/L) for acrolein and acrylonitrile; five hundred micrograms per liter
(500 µg/L) for 2,4-dinitrophenol and for 2-methyl-4,6-dinitrophenol; and one milligram per liter (1 mg/L) for
antimony;
(3) Five times the maximum concentration value reported for that pollutant in the permit application.
b. That any activity has occurred or will occur which would result in any discharge, on a non -routine or infrequent
basis, of a toxic pollutant which is not limited in the permit, if that discharge will exceed the highest of the
following "notification levels";
(1) Five hundred micrograms per liter (500 µg/L);
(2) One milligram per liter (1 mg/L) for antimony;
(3) Ten times the maximum concentration value reported for that pollutant in the permit application.
Section D. Facility Closure Requirements
The Permittee must notify the Division at least 90 days prior to the closure of any wastewater treatment system covered
by this permit. The Division may require specific measures during deactivation of the system to prevent adverse
impacts to waters of the State. This permit cannot be rescinded while any activities requiring this permit continue at the
permitted facility.
Version 11/09/2011

NPDES Permit Standard Conditions
Page 14 of 18
PART IV
SPECIAL CONDITIONS FOR MUNICIPAL FACILITIES
Section A. Definitions
In addition to the definitions in Part II of this permit, the following definitions apply to municipal facilities:
Indirect Dischame or Industrial User
Any non-domestic source that discharges wastewater containing pollutants into a POTW regulated under section
307(b), (c) or (d) of the CWA. [40 CFR 403.3 (i) and 0) and 15A NCAC 02H .0903(b)(11)]
Interference
Inhibition or disruption of the POTW treatment processes; operations; or its sludge process, use, or disposal which
causes or contributes to a violation of any requirement of the Permittee's (or any satellite POTW's if different from the
Permittee) NPDES, collection system, or non -discharge permit or prevents sewage sludge use or disposal in
compliance with specified applicable State and Federal statutes, regulations, or permits. [15A NCAC 02H
.0903(b)(14)]
Pass Throujzh
A discharge which exits the POTW into waters of the State in quantities or concentrations which, alone or with
discharges from other sources, causes a violation, including an increase in the magnitude or duration of a violation, of
the Permittee's (or any satellite POTW's, if different from the Permittee) NPDES, collection system, or non -discharge
permit. [15A NCAC 02H .0903(b)(23)]
Publicly Owned Treatment Works (POTW)
A treatment works as defined by Section 212 of the CWA, which is owned by a State or local government organization.
This definition includes any devices and systems used in the storage, treatment, recycling and reclamation of municipal
sewage or industrial wastes of a liquid nature. It also includes the collection system, as defined in 15A NCAC 2T
.0402, only if it conveys wastewater to a POTW treatment plant. The term also means the local government
organization, or municipality, as defined in section 502(4) of the CWA, which has jurisdiction over indirect discharges
to and the discharges from such a treatment works. In this context, the organization may be the owner of the POTW
treatment plant or the owner of the collection system into which an indirect discharger discharges. This second type of
POTW may be referred to as a "satellite POTW organization." [15A NCAC 02H .0903(b)(26)]
"Significant Industrial User" or "SN"
An Industrial User that discharges wastewater into a publicly owned treatment works and that [15A NCAC 02H
.0903(b)(33)]:
1. Discharges an average of 25,000 gallons per day or more of process wastewater to the POTW (excluding sanitary,
noncontact cooling and boiler blowdown wastewaters); or
2. Contributes process wastewater which makes up five percent or more of the NPDES or non -discharge permitted
flow limit or organic capacity of the POTW treatment plant. hi this context, organic capacity refers to BOD, TSS
and ammonia; or
3. Is subject to categorical standards under 40 CFR Part 403.6 and 40 CFR Parts 405-471; or
4. Is designated as such by the Permittee on the basis that the Industrial User has a reasonable potential for adversely
affecting the POTW's operation or for violating any pretreatment standard or requirement, or the POTW's effluent
limitations and conditions in its NPDES or non -discharge permit, or to limit the POTW's sludge disposal options;
5. Subject to approval under 15A NCAC 02H .0907(b), the Permittee may determine that an Industrial User meeting
the criteria in paragraphs 1 or 2 of this definition above has no reasonable potential for adversely affecting the
POTW's operation or for violating any pretreatment standard or requirement, the POTW's effluent limitations and
conditions in its NPDES or non -discharge permit, or to limit the POTW's sludge disposal options, and thus is not a
Significant Industrial User (SN); or
6. Subject to approval under 15A NCAC 02H .0907(b), the Permittee may determine that an Industrial User meeting
the criteria in paragraph 3 of this definition above meets the requirements of 40 CFR Part 403.3(v)(2) and thus is a
non-significant categorical Industrial User.
Section B. Publicly Owned Treatment Works (POTWs)
Version 11/09/2011

NPDES Permit Standard Conditions
Page 15 of 18
All POTWs must provide adequate notice to the Director of the following [40 CFR 122.42(b)]:
1. Any new introduction of pollutants into the POTW from an indirect discharger, regardless of the means of
transport, which would be subject to section 301 or 306 of CWA if it were directly discharging those pollutants;
and
2. Any substantial change in the volume or character of pollutants being introduced by an indirect discharger as
influent to that POTW at the time of issuance of the permit.
3. For purposes of this paragraph, adequate notice shall include information on (1) the quality and quantity of effluent
introduced into the POTW, and (2) any anticipated impact that may result from the change of the quantity or
quality of effluent to be discharged from the POTW.
Section C. Municipal Control of Pollutants from Industrial Users.
Effluent limitations are listed in Part I of this permit. Other pollutants attributable to inputs from Industrial Users
discharging to the POTW may be present in the Permittee's discharge. At such time as sufficient information
becomes available to establish limitations for such pollutants, this permit may be revised to specify effluent
limitations for any or all of such other pollutants in accordance with best practicable technology or water quality
standards.
Prohibited Discharges
a. The Permittee shall develop and enforce their Pretreatment Program to implement the prohibition against the
introduction of pollutants or discharges into the waste treatment system or waste collection system which
cause or contribute to Pass Through or Interference as defined in 15A NCAC 02H .0900 and 40 CFR 403. [40
CFR 403.5(a)(1)]
b. The Permittee shall develop and enforce their Pretreatment Program to implement the prohibitions against the
introduction of the following wastes in the waste treatment or waste collection system [40 CFR 403.5(b)]:
(1) Pollutants which create a fire or explosion hazard in the POTW, including, but not limited to,
wastestreams with a closed cup flashpoint of less than 140 degrees Fahrenheit or 60 degrees Centigrade
using the test methods specified in 40 CFR 261.21;
(2) Pollutants which cause corrosive structural damage to the POTW, but in no case discharges with pH lower
than 5.0, unless the works is specifically designed to accommodate such discharges;
(3) Solid or viscous pollutants in amounts which cause obstruction to the flow in the POTW resulting in
Interference;
(4) Any pollutant, including oxygen demanding pollutants (BOD, etc.) released in a Discharge at a flow rate
and/or pollutant concentration which will cause Interference with the POTW;
(5) Heat in amounts which will inhibit biological activity in the POTW resulting in Interference, but in no
case heat in such quantities that the temperature at the POTW Treatment Plant exceeds 40°C (104°F)
unless the Division, upon request of the POTW, approves alternate temperature limits;
(6) Petroleum oil, non -biodegradable cutting oil, or products of mineral oil origin in amounts that will cause
Interference or Pass Through;
(7) Pollutants which result in the presence of toxic gases, vapors, or fumes within the POTW in a quantity that
may cause acute worker health and safety problems; or
(8) Any trucked or hauled pollutants, except at discharge points designated by the POTW.
c. The Permittee shall investigate the source of all discharges into the POTW, including slug loads and other
unusual discharges, which have the potential to adversely impact the Permittee's Pretreatment Program and/or
the operation of the POTW.
The Permittee shall report such discharges into the POTW to the Director or the appropriate Regional Office.
Any information shall be provided orally within 24 hours from the time the Permittee became aware of the
circumstances. A written submission shall also be provided within 5 days of the time the Permittee becomes
aware of the circumstances. The written submission shall contain a description of the discharge; the
investigation into possible sources; the period of the discharge, including exact dates and times; if the
discharge has not ceased, the anticipated time it is expected to continue; and steps taken or planned to reduce,
eliminate, and prevent reoccurrence of the noncompliance,
Version 1110912011

NPDES Permit Standard Conditions
Page 16 of 18
3. With regard to the effluent requirements listed in Part I of this permit, it may be necessary for the Permittee to
supplement the requirements of the Federal Pretreatment Standards (40 CFR, Part 403) to ensure compliance by
the Permittee with all applicable effluent limitations. Such actions by the Permittee may be necessary regarding
some or all of the industries discharging to the municipal system.
4. The Permittee shall require any Industrial User (1U) discharging to the POTW to meet Federal Pretreatment
Standards developed under Section 307(b) of the Act as amended (which includes categorical standards and
specific local limits, best management practices and narrative requirements). Prior to accepting wastewater from
any Significant Industrial User (SIU), the Permittee shall either develop and submit to the Division a new
Pretreatment Program or, as necessary, a modification of an existing Pretreatment Program, for approval as
required under section D below as well as 15A NCAC 02H .0907(a) and (b). [40 CFR 122.440)(2)]
5. This permit shall be modified, or alternatively, revoked and reissued, to incorporate or modify an approved POTW
Pretreatment Program or to include a compliance schedule for the development of a POTW Pretreatment Program
as required under Section 402 (b)(8) of the CWA and implementing regulations or by the requirements of the
approved State pretreatment program, as appropriate.
Section D. Pretreatment Programs
Under authority of sections 307 (b) and (c) and 402(b)(8) of the CWA and implementing regulations 40 CFR 403,
North Carolina General Statute 143-215.3(14) and implementing regulations 15A NCAC 02H.0900, and in accordance
with the approved pretreatment program, all provisions and regulations contained and referenced in the pretreatment
program submittal are an enforceable part of this permit. [40 CFR 122.440)(2)]
The Permittee shall operate its approved pretreatment program in accordance with Section 402(b)(8) of the CWA, 40
CFR 403, 15A NCAC 02H .0900, and the legal authorities, policies, procedures, and financial provisions contained in
its pretreatment program submission and Division approved modifications thereof. Such operation shall include but is
not limited to the implementation of the following conditions and requirements. Terms not defined in Part II or Part IV
of this permit are as defined in 15A NCAC 02H.0903 and 40 CFR 403.3.
1. Sewer Use Ordinance (SUO)
The Permittee shall maintain adequate legal authority to implement its approved pretreatment program. [15A
NCAC 02H .0903(b)(32), .0905 and .0906(b)(1); 40 CFR 403.8(f)(1) and 403.9(b)(1) and (2)]
2. Industrial Waste Survey (IWS)
The Permittee shall implement an IWS consisting of the survey of users of the POTW collection system or
treatment plant, as required by 40 CFR 403.8(f)(2)(i-iii) and 15A NCAC 02H.0905 [also 40 CFR 122.440)(1)],
including identification of all Industrial Users that may have an impact on the POTW and the character and amount
of pollutants contributed to the POTW by these Industrial Users and identification of those Industrial Users
meeting the definition of SIU. Where the Permittee accepts wastewater from one or more satellite POTWs, the
IWS for the Permittee shall address all satellite POTW services areas, unless the pretreatment program in those
satellite service areas is administered by a separate Permittee with an approved Pretreatment Program. The
Permittee shall submit a summary of its IWS activities to the Division at least once every five years, and as
required by the Division. The IWS submission shall include a summary of any investigations conducted under
paragraph C.2.c. of this Part. [15A NCAC 02H .0903 (b)(1 3),.0905 and .0906(b)(2); 40 CFR 403.8(f)(2) and 403.9]
3. Monitoring Plan
The Permittee shall implement a Division -approved Monitoring Plan for the collection of facility specific data to
be used in a wastewater treatment plant Headworks Analysis (HWA) for the development of specific pretreatment
local limits. Effluent data from the Plan shall be reported on the DMRs (as required by Parts II.D and II.E.5.). [15A
NCAC 02H .0903(b)(16), .0906(b)(3) and .0905]
4. Headworks Analysis (HWA) and Local Limits
The Permittee shall obtain Division approval of a HWA at least once every five years, and as required by the
Division. Within 180 days of the effective date of this permit (or any subsequent permit modification) the
Permittee shall submit to the Division a written technical evaluation of the need to revise local limits (i.e., an
updated HWA or documentation of why one is not needed) [40 CFR 122.44]. The Permittee shall develop, in
accordance with 40 CFR 403.5(c) and 15A NCAC 02H .0909, specific Local Limits to implement the prohibitions
listed in 40 CFR 403.5(a) and (b) and 15A NCAC 02H .0909. Pursuant to 40 CFR 403.5, local limits are
Version 11/09/2011

NPDES Permit Standard Conditions
Page 17 of 18
enforceable Pretreatment Standards as defined by 40 CFR 403.3(1). [15A NCAC 02H .0903(b)(10), .0905, and
.0906(b)(4)]
5. Industrial User Pretreatment Permits (IUP) & Allocation Tables
In accordance with NCGS 143-215.1, the Permittee shall issue to all Significant Industrial Users, permits for
operation of pretreatment equipment and discharge to the Permittee's collection system or treatment works. These
permits shall contain limitations, sampling protocols, reporting requirements, appropriate standard and special
conditions, and compliance schedules as necessary for the installation of treatment and control technologies to
assure that their wastewater discharge will meet all applicable pretreatment standards and requirements. The
Permittee shall maintain a current Allocation Table (AT) which summarizes the results of the HWA and the limits
from all NPs. Permitted NP loadings for each parameter cannot exceed the treatment capacity of the POTW as
determined by the HWA. [15A NCAC 02H .0906(b)(6), .0909, .0916, and .0917; 40 CFR 403.5, 403.8(f)(1)(iii);
NCGS 143-215.67(a)]
6. Authorization to Construct (AtC)
The Permittee shall ensure that an Authorization to Construct permit (AtC) is issued to all applicable Industrial
Users for the construction or modification of any pretreatment facility. Prior to the issuance of an AtC, the
proposed pretreatment facility and treatment process must be evaluated for its capacity to comply with all
Industrial User Pretreatment Permit (IUP) limitations. [15A NCAC 02H .0906(b)(7) and .0905; NCGS 143-
215.1(a)(8)]
7. POTW Inspection & Monitoring of their Ns
The Permittee shall conduct inspection, surveillance, and monitoring activities as described in its Division
approved pretreatment program in order to determine, independent of information supplied by hidustrial Users,
compliance with applicable pretreatment standards. [15A NCAC 02H .0908(e); 40 CFR 403.8(f)(2)(v)] The
Permittee must:
a. Inspect all Significant Industrial Users (SNs) at least once per calendar year;
b. Sample all Significant Industrial Users (SNs) at least once per calendar year for all SIU permit -limited
parameters including flow except as allowed under 15A NCAC .0908(e); and
c. At least once per year, document an evaluation of any non-significant categorical Industrial User for
compliance with the requirements in 40 CFR 403.3(v)(2), and either continue or revoke the designation as non-
significant.
8. N Self Monitoring and Reporting
The Permittee shall require all Industrial Users to comply with the applicable monitoring and reporting
requirements outlined in the Division -approved pretreatment program, the industry's pretreatment permit, or in 15A
NCAC 02H.0908. [15A NCAC 02H .0906(b)(5) and .0905; 40 CFR 403.8(f)(1)(v) and (2)(iii); 40 CFR
122.440)(2) and 40 CFR 403.12]
9. Enforcement Response Plan (ERP)
The Permittee shall enforce and obtain appropriate remedies for violations of all pretreatment standards
promulgated pursuant to section 307(b) and (c) of the CWA (40 CFR 405 et. seq.), prohibitive discharge standards
as set forth in 40 CFR 403.5 and 15A NCAC 02H .0909, specific local limitations, and other pretreatment
requirements. All remedies, enforcement actions and other, shall be consistent with the Enforcement Response
Plan (ERP) approved by the Division. [15A NCAC 02H .0903(b)(7), .0906(b)(8) and .0905; 40 CFR 403.8(f)(5)]
10. Pretreatment Annual Re orts� (PAR)
The Permittee shall report to the Division in accordance with 15A NCAC 02H.0908. In lieu of submitting annual
reports, Modified Pretreatment Programs developed under 15A NCAC 02H .0904 (b) may be required to submit a
partial annual report or to meet with Division personnel periodically to discuss enforcement of pretreatment
requirements and other pretreatment implementation issues.
For all other active pretreatment programs, the Permittee shall submit two copies of a Pretreatment Annual Report
(PAR) describing its pretreatment activities over the previous calendar year to the Division at the following
address:
Version 11/09/2011

NPDES Permit Standard Conditions
Page 18 of 18
NC DENR / Division of Water Quality / Surface Water Protection Section
Pretreatment, Emergency Response, and Collection Systems (PERCS) Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
These reports shall be submitted by March 1 of each year and shall contain the following:
a. Narrative
A narrative summary detailing actions taken, or proposed, by the Permittee to correct significant non-
compliance and to ensure compliance with pretreatment requirements;
b. Pretreatment Program Summa (PPS)
A pretreatment program summary (PPS) on forms or in a format provided by the Division;
c. Significant Non -Compliance Report (SNCR)
A list of Industrial Users (Ns) in significant noncompliance (SNC) with pretreatment requirements, and the
nature of the violations on forms or in a format provided by the Division;
d. Industrial Data Summary Forms (IDSF)
Monitoring data from samples collected by both the POTW and the Significant Industrial Users (SIUs). These
analytical results must be reported on Industrial Data Summary Forms (IDSF) or on other forms or in a format
provided by the Division;
e. Other Information
Copies of the POTW's allocation table, new or modified enforcement compliance schedules, public notice of
IUs in SNC, a summary of data or other information related to significant noncompliance determinations for
lUs that are not considered SIUs, and any other information, upon request, which in the opinion of the Director
is needed to determine compliance with the pretreatment implementation requirements of this permit;
11. Public Notice
The Permittee shall publish annually a list of Industrial Users (IUs) that were in significant noncompliance (SNC)
as defined in the Permittee's Division -approved Sewer Use Ordinance with applicable pretreatment requirements
and standards during the previous twelve month period. This list shall be published within four months of the
applicable twelve-month period. [15A NCAC 02H .0903(b)(34), .0908(b)(5) and .0905 and 40 CFR
403.8(f)(2)(viii)]
12. Record Keeping
The Permittee shall retain for a minimum of three years records of monitoring activities and results, along with
support information including general records, water quality records, and records of industrial impact on the
POTW and shall retain all other Pretreatment Program records as required by 15A NCAC 02H .0908(f). [15A
NCAC 02H .0908(f); 40 CFR 403.12(0)]
13. Pretreatment Program Resources
The Permittee shall maintain adequate funding and qualified personnel to accomplish the objectives of its approved
pretreatment program. and retain a written description of those current levels of inspection. [I 5A NCAC 02H
.0906(b)(9) and (10) and .0905; 40 CFR 403.8(f)(3), 403.9(b)(3)]
14. Modification to Pretreatment Pro rg ams
Modifications to the approved pretreatment program including but not limited to local limits modifications, POTW
monitoring of their Significant Industrial Users (SIUs), and Monitoring Plan modifications, shall be considered a
permit modification and shall be governed by 40 CFR 403.18, 15 NCAC 02H.01 14 and 15A NCAC 02H.0907.
Version 11/09/2011

Dr. Sergei Chernikov
NCDENR Division of Water Quality
Point Source Branch
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
SUBJECT: Comments on the Draft NPDES Permit
Permit NC0003573
DuPont Company — Fayetteville Works
Bladen County
Dear Dr. Chernikov:
DuPont Fluoroproducts
22828 NC Highway 87 W
Fayetteville, NC 2.8306-7332
September 19, 2011
FLN 0 c --,
SEP 21 2011
DENR- ATER QUALITY
The DuPont Company — Fayetteville Works ("DuPont") has received the subject draft NPDES
Permit, and respectively submits the following as comments to that permit:
1. Supplement to Permit Cover Sheet: In Item 1, the listing of existing wastewater treatment
facilities includes "tertiary filters"; however this site's wastewater treatment plant does not
have any tertiary filters. This bulleted item should therefore be eliminated.
2. Supplement to Permit Cover Sheet: In Item 2, the process area shown as Sentryglas® should
be SentryGlas®.
3. Supplement to Permit Cover Sheet: In Item 3, the Cape Fear River is shown as being a
Class C water, however the segment of the river receiving the DuPont effluent discharge is
now a Class WS -IV water.
4. Supplement to Permit Cover Sheet: On July 26, 2011, DuPont submitted to DWQ a letter
titled "NPDES Permit Renewal Application - Addendum 2" that included the Biocide/
Chemical Treatment Worksheet Form 101's for the five (5) chemicals that will be used with
a future cooling tower. Neither those biocide chemicals nor the cooling tower blowdown are
shown in the draft permit.
E.I. du Pont de Nemours and Company

Dr. Sergei Chernikov
NCDENR Division of Water Quality
September 19, 2011
Page 2 of 2
5. Section A(1) — Effluent Limitations and Monitoring Requirements: The Chronic Toxicity
parameter is listed as a requirement for Outfall 001, with Note 1 specifying that the
compliance monitoring point is actually at Outfall 002. This site's DWQ inspector in the
Fayetteville Regional Office mentioned during his last inspection that he would prefer if the
permit was modified and the chromic toxicity monitoring requirement be moved to the
Outfall 002 section so that the permit matches the site's practice.
6. Section A(3) — Effluent Limitations and Monitoring Requirements: Currently the flow of
Outfall 002 is measured as the daily quantity of water pumped from the Cape Fear River into
the DuPont facility, so the "Sample Location" should be "Influent". However, a project is
underway that will reroute the final Outfall 002 effluent from entering the river downstream
of Lock and Dam No. 3 to entering the river upstream of the lock and dam. As part of this
project, a flow rate monitoring station will be installed to measure the actual daily flow of
Outfall 002, at which time the "Sample Location" would be "Effluent". It may be
appropriate to include a description of the Outfall 002 flow as being the "Influent" prior to
the completion of the project, and "Effluent" after the project.
7. Section A(3) — Effluent Limitations and Monitoring Requirements: In Note 1, the second
sentence should read: "As a participate in the Middle Cape Fear River Basin Association...".
8. Section A(4) — Chronic Toxicity Permit Limit (Quarterly) — Outfall 001: See Comment 5
above. This site's DWQ inspector in the Fayetteville Regional Office would prefer if the
chromic toxicity monitoring requirement be specified for Outfall 002.
Should you have any questions regarding these comments, please call me at [phone].

4. 0
Chernikov, Sergei
From: [e-mail]
Sent: Monday, September 19, 2011 11:40 AM
To: Poupart, Jeff
Cc: Belnick, Tom; [e-mail]; Chernikov, Sergei; Mckay, James
Subject: No comments to three draft permits: NCG510000, NC0003573 and NC0032077
Dear Mr. Poupart:
In accordance with the EPA/NC Memorandum of Agreement, we have completed our review of three
draft National Pollutant Discharge Elimination System (NPDES) permits referenced above and
have no comments to the proposed conditions. The EPA requests that we be afforded an
additional review opportunity only if significant changes are Made to the draft permits prior
to issuance, or if significant objections to them are received. Otherwise, please send Region
4 one copy of each final permit when issued with its signed cover letter.
Official letters of n nt are being mailed to you today for each draft permit to
include: NCG510000, NC0003573 and NC0032077.
If you have any questions, please call me or respond by email.
Sincerely,
Pamala Myers
Environmental Engineer and Technical Advisor Pollution Control and Implementation Branch
Water Protection Division Municipal and Industrial NPDES Section U.S. EPA, Region 4 Atlanta,
GA 30303
404.562.9421
myers.pamala(@epa.gov
I

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
August 31, 2011
Mr. Michael E. Johnson
Environmental Manager
E.I. DuPont de Nemours & Company
22828 NC Highway 87 West
Fayetteville, North Carolina 28306-7332
Subject:
Dear Mt. Johnson:
Draft NPDES Permit
Permit NC0003573
Fayetteville Works
Bladen County
Facility Class III
Dee Freeman
Secretary
Enclosed with this letter is a copy of the draft permit for your facility. Please review the draft very
carefully to ensure thorough understanding of the conditions and requirements it contains.
The draft permit contains the following significant changes from your current permit:
• One clarifier was added to the description of the treatment facility.
• The permit limits have recalculated based on the latest OCPSF production information in accordance with
the 40 CFR 414 Subpart D.
• The limits for Cr, Cu, CN, Pb, Ni, and Zn were added to the permit in accordance with the 40 CFR 414
Subpart D.
• The limit for F was removed from the permit based on the statistical analysis of the effluent data and the
monitoring was reduced to quarterly. The instream monitoring for F was removed from the permit.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 one
Phone: [phone] \ FAX: [phone] Customer Service: 1-877-623-6748 NorthCarolina
Internet: www.ncwaterquality.org �lltll �'a��lf
An Equal Opportunity i Affirmative Action Employer L t

Please submit any comments to me no later than thirty days following your receipt of the draft. Comments
should be sent to the address listed at the bottom of this page. If no adverse comments are received from the
public or from you, this permit will likely be issued in late October, with an effective date of December 1, 2011.
If you have any questions about the NPDES permit process, please contact me at the following e-mail
address: sergei.chernikov(4 ncdenr.gov, or telephone number: 919-807-6393.
Sincerely,
4'?
Sergei Chernikov, Ph.D.
Environmental Engineer II
Complex NPDES Permitting Unit
cc: NPDES Files
Fayetteville Regional Office / Surface Water Protection Section (e -copy)
Aquatic Toxicology Unit (e -copy)
TACU (e -copy)
EPA Region IV (with application, fact sheet, and RPA)
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 One
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748 NorthCarohna
Internet: www.ncwaterquality.org �y1�p //g i
An Equal Opportunity i Affirmative Action Employer Natd a `�`J

Permit NC0003573
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
In compliance with the provisions 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,
E.I. DuPont de Nemours & Co.
is hereby authorized to discharge wastewater and stormwater from a facility located at
DuPont Fayetteville Works
22828 NC Highway 87
Duart Township
Bladen County
to receiving waters designated as the Cape Fear River in the Cape Fear River Basin in accordance with
effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III, and IV
hereof.
The permit shall become effective
This permit and the authorization to discharge shall expire at midnight on October 31, 2016.
Signed this day
Coleen H. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit NC0003573
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby
revoked, and as of this issuance, any previously issued permit bearing this number is no longer
effective. Therefore, the exclusive authority to operate and discharge from this facility arises under the
permit conditions, requirements, terms, and provisions included herein.
E.I. DuPont de Nemours & Co., Inc.
is hereby authorized to:
Continue to operate existing wastewater treatment facilities consisting of:
• equalization;
• neutralization;
• aerated pre -digester tank;
• nutrient feed system;
• aeration tank;
• three clarifiers;
• effluent flow measurement;
• tertiary filters
• DAF unit;
• rotary filter for sludge thickening;
• sludge pump;
• sludge filter press; and
• steam heated sludge dryers.
2. Discharge treated process wastewater from Butacite®, Nafion®, Sentryglas®, and PVF
(polyvinyl fluoride resin), process stormwater, sanitary wastewater, and co -neutralized
regenerate from said treated facilities through internal outfall 001;
3. Discharge stormwater, non -contact cooling water, boiler blowdown and condensate, and
treated wastewater effluent from 001, through outfall 002 at the location specified on
the attached map into the Cape Fear River, a class C water in the Cape Fear River
Basin.

X
Pont Fayetteville Works - NC0003573 I Facility
quad Name: Duart I I Existing 11 11 Location Aod*
0

Permit NC0003573
A.' 1) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
Beginning on the effective date of this permit and lasting through the expiration date, the Permittee is authorized
to discharge from Outfall 001. Such discharges shall be limited and monitored by the Permittee as specified
below:
PARAMETER
EFFLUENT LIMITATIONS
MONITORING REQUIREMENTS
Monthly Daily
Average Maximum
Measurement Sample Sample
Frequency Type Location,
Flow (MGD)
2.0
Continuous
Recording
Effluent
BODS, 20° C
182.6 lbs/day 484.71bs/day
3/Week
Composite
Effluent
Total Suspended Solids
303.1 lbs/day 981.51bs/day
3/Week
Composite
Effluent
Temperature
Weekly
Grab
Effluent
Oil & Grease
Monthly
Grab
Effluent
Chronic Toxicity
See Note 1
Quarterly
Composite
See Note 1
pH
Between 6.0 and 9.0 Standard Units
3/Week .
Grab
Effluent
40 CFR 414 Subpart I
See Condition A. (2)
Notes:
1. Chronic Toxicity (Ceriodaphnia) P/F @ 3.3% February, May, August, November; see condition A. (4) of this
permit. The compliance monitoring point for chronic toxicity shall be downstream of the confluence of outfall
001 and 002.
i
THERE SHALL BE NO DISCHARGE OF FLOATING SOLIDS OR VISIBLE FOAM IN OTHER THAN TRACE AMOUNTS.

Permit NC0003573
A. (2) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - SUBPART I
Beginning on the effective date of this permit and lasting through the expiration date, the Permittee shall comply
with the limitations and monitoring frequencies established below at outfall 001:
PARAMETER
EFFLUENT LIMITATIONS -
MONITORING REQUIREMENTS
Monthly
Average'
Daily
Maximum'
Measurement
Frequency
Sample
e
Sample
Location `
Acenaphthene
0.166
0.444
See Note 2
Grab
Effluent
Acenaphthylene
0.166
0.444
See Note 2
Grab
Effluent
Acrylonitrile
0.723
1.821
See Note 2
Grab
Effluent
Anthracene
0.166
12.8 ug/L
See Note 2
Grab
Effluent
Benzene
0.278
1.024
See Note 2
Grab
Effluent
Benzo(a)anthracene
0.166
0.444
See Note 2
Grab
Effluent
3,4-Benzofluoranthene
0.173
0.459
See Note 2
Grab
Effluent
Benzo(k)fluoranthene
0.166
0.444
See Note 2
Grab
Effluent
Benzo(a)pyrene
0.173
0.459
See Note 2
Grab
Effluent
Bis(2-ethy1hexyl) phthalate
0.775
2.100
See Note 2
Grab
Effluent
Carbon Tetrachloride
0.135
0.286
See Note 2
Grab
Effluent
Chlorobenzene
0.113
0.211
See Note 2
Grab
Effluent
Chloroethane
0.783
2.017
See Note 2
Grab
Effluent
Chloroform
0.158
0.346
See Note 2
Grab
Effluent
2 -Chlorophenol
0.233
0.738
See Note 2
Grab
Effluent
Chrysene
0.166
0.444
See Note 2
Grab
Effluent
Di -n -butyl phthalate
0.203
0.429
See Note 2
Grab
Effluent
1,2 -Dichlorobenzene
0.580
1.227
See Note 2
Grab
Effluent
1,3 -Dichlorobenzene
0.233
0.331
See Note 2
Grab
Effluent
1,4 -Dichlorobenzene
0.113
0.211
See Note 2
Grab
Effluent
1,1-Dichloroethane
0.166
0.444
See Note 2
Grab
Effluent
1,2-Dichloroethane
0.512
1.588
See Note 2
Grab
Effluent
1,1.-Dichloroethylene
0.120
0.188
See Note 2
Grab
Effluent
1,2-trans-Dichloroethylene
0.158
0.406
See Note 2
Grab
Effluent
2,4-Dichlorophenol
0.294
0.843
See Note 2
Grab
Effluent
1,2-Dichloropropane
1.152
1.731
See Note 2
Grab
Effluent
1,3-Dichloropropylene
0.218.
0.331
See Note 2
Grab
Effluent
Diethyl phthalate
0.610
1.528
See Note 2
Grab
Effluent
2,4 -Dimethylphenol
0.135
0.271
See Note 2
Grab
Effluent
Dimethyl phthalate
0.143
0.354
See Note 2
Grab
Effluent
4,6-Dinitro-o-cresol
0.587
2.085
See Note 2
Grab
Effluent
2,4-Dinitrophenol
0.534
0.926
See Note 2
Grab
Effluent
2,4-Dinitrotoluene
0.851
2.145
See Note 2
Grab
Effluent
2,6-Dinitrotoluene
1.919
12.3 ug/L
See Note 2
Grab
Effluent
Ethylbenzene
0.241
0.813
See Note 2
Grab
Effluent

Permit NC0003573
A. (Z) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - SUBPART I (CONTUNUED)
Beginning on the effective date of this permit and lasting through the expiration date, the Permittee shall comply
with the limitations and monitoring frequencies established below at outfall 001:
PARAMETER
EFFLUENT LIMITATIONS `'
- MONITORING REQUIREMENTS
Monthly
Average'
Daily
Maximum'
Measurement
Frequency
Sample
e
Sample
Location -
Fluoranthene
0.188
28.2 ug/L
See Note 2
Grab
Effluent
Fluorene
0.166
0.444
See Note 2
Grab
Effluent
Hexachlorobenzene
0.113
0.5 µg/L
AnnualV
Grab
Effluent
Hexachlorobutadiene
0.151
0.369
See Note 2
Grab
Effluent
Hexachloroethane
0.158
0.406
See Note 2
Grab
Effluent
Methyl Chloride
0.647
1.430
See Note 2
Grab
Effluent
Methylene Chloride
0.301
0.670
See Note 2
Grab
Effluent
Naphthalene
0.166
0.444
See Note 2
Grab
Effluent
Nitrobenzene
0.203
0.512
See Note 2
Grab
Effluent
2-Nitrophenol
0.309
0.519
See Note 2
Grab
Effluent
4-Nitrophenol
0.542
0.933
See Note 2
Grab
Effluent
Phenanthrene
0.166
0.444
See Note 2
Grab
Effluent
Phenol
0.113
0.196
See Note 2
Grab
Effluent
Pytene
0.188
0.504
See Note 2
Grab
Effluent
Tetrachloroethylene
0.166
0.422
See Note 2
Grab
Effluent
Toluene
0.196
0.602
See Note 2
Grab
Effluent
1,2,4-Trichlorobenzene
0.512
1.054
See Note 2
Grab
Effluent
1,1,1 -Trichloroethane
0.158
0.406
See Note 2
Grab
Effluent
1,1,2 -Trichloroethane
0.158
0.406
See Note 2
Grab
Effluent
Trichloroethylene
0.158
0.406
See Note 2
Grab
Effluent
Vinyl Chloride
0.783
2.017
See Note 2
Grab
Effluent
Total Chromium
8.355
20.849
Annually
Grab
Effluent
Total Copper
10.914
25.441
Annually
Grab
Effluent
Total Cyanide
3.161
9.032
See Note 2
Grab
Effluent
Total Lead
2.409
5.194
See Note 2
Grab
Effluent
Total Nickel
12.720
29.957
Annually
Grab
Effluent
Total Zinc
7.903
19.645
Annually
Grab
Effluent
Notes:
1. All units are lbs/day unless otherwise noted.
2. Monitoring for the specified parameters has been waived based on a demonstration made by the Permittee in
accordance with 40 CFR 122.44(a)(2)(i). This waiver is good only for the term of the permit. Please note that
any exceedence of the effluent limitations found herein shall be considered a permit violation subject to
appropriate enforcement action.
3. The most sensitive analytical method available shall be employed for determining the presence of
hexachlorobenzene in the effluent.

Permit NC0003573
A. (3) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
Beginning on the effective date of this permit and lasting through the expiration date, the Permittee is authorized
to discharge from Outfall 002 (boiler blowdown, once -through cooling water, and treated wastewater from
outfall 00 1) Such discharges shall be limited and monitored by the Permittee as specified below:
PARAMETER .
EFFLUENT LIMITATIONS
MONITORING REQUIREMENTS
Monthly Daily
Average Maximum
Measurement
Frequency
Sample
e
Sample
Location'
Flow (MGD)
Continuous
Recording
Effluent
Temperature, °C
See Note 2
Daily3
Grab
Effluent,
Upstream,
Downstream
BODS, 20°C
Quarterly
Composite
Effluent
COD
Quarterly
Composite
Effluent
Fluoride (ug/L)
Quarterly
Grab
Effluent
Dissolved Oxygen
Weekly
Grab
Upstream,
Downstream
PFOA4
Monthly
Grab
Effluent
Total Phosphorus
Monthly
Composite
Effluent
Total Nitrogen
(NO2+NO3+TKN)
Monthly
Composite
Effluent
Conductivity
Weekly
Grab
Upstream,
Downstream
pH
Between 6.0 and 9.0 Standard Units
3/Week
Grab
Effluent Li
Notes:
1. Upstream shall be at the Permittee's river pump station; downstream shall be at the boat ramp approximately
4500 feet downstream at Prospect Hall Landing.
As a participant in the Cape Fear River Basin Association, the instream monitoring requirements as stated
above are waived. Should your membership in the agreement be terminated, you shall notify the Division
immediately and the instream monitoring requirements specified in your permit shall be reinstated.
2. The temperature of the effluent shall be such as not to cause an increase in the temperature of the receiving
stream of more than 2.8°C and in no case cause the ambient water temperature to exceed 32°C.
3. Daily shall be defined as every day except Saturdays, Sundays, and legal holidays. Instream temperature
sampling shall be conducted weekly.
4. PFOA (Perfluorooctanoic acid) - The Cape Fear River water intake may be sampled for PFOA on a monthly
basis and reported as an upstream parameter in DWQ Form — MR -3.
THERE SHALL BE NO DISCHARGE OF FLOATING SOLIDS OR VISIBLE FOAM IN OTHER THAN TRACE AMOUNTS.

- . 01 P
Permit NC0003573
A. (4) CHRONIC TOXICITY PERMIT LIMIT (QUARTERLY) — OUTFALL 001
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to
Ceriodaphnia dubia at an effluent concentration of 3.3%.
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 February, May, August, and November. 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 THP313 for the Chronic Value. Additionally, DWQ Form AT -3 (original) is to be sent to the
following address:
Attention: Environmental Sciences Section
North Carolina Division of Water Quality
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.
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.

Permit NCO003573
A. (5) RE -OPENER CONDITION
This permit shall be modified, or revoked and reissued to incorporate additional toxicity limitations and
monitoring requirements in the event toxicity testing or other studies conducted on the effluent or receiving
stream indicate that detrimental effects may be expected in the receiving stream as a result of this discharge.
A. (6) BIOCIDE CONDITION
The permittee shall not use any biocide except those approved in conjunction with the permit application. The
permittee shall notify the Director in writing not later than ninety (90) days prior to instituting use of any
additional biocide used in cooling systems which may be toxic to aquatic life other than those previously reported
to the Division of Water Quality. Such notification shall include completion of Biocide Worksheet Form 101 and a
map locating the discharge point and receiving stream.

a
a
a
n
n
a
I
I
I
a
a
a
ol
a
a
a
I
�
I I I I I�
I I I I I
aaa a"a"aaa
I I I I I
aaa a"a
I I I I I
I I I I I
I I I I I
I I I I I
I I I I I
a"a"a"a"a"
a
a�°aa"a
N N ry N I
I I I I I
S
N N N N N
I I I I I
ig
N N N N I
I I I I I
N N N N N I
I I I I I
o
N N N N N
I I I I I
N N N N N
I I I I I
N N N N
I I I I I
N N N N
a�nda
N N N N
a"a"aa as
N N N N
I I a" I I
N N N N
HI'
P5
t
L
L
NN
E
E
E
E
E
E
E
E
E
EE
0
E
E
0
0
c
0
c
0
U
0
c
0
c
0
c
0
U
0
c
c
0
c
c
z
+
zz
S
z
+
z
+
z
z
z
+
z
+
z
z
+
.�
0 0
O
U
u
O
O
G
Q
a
9 a
+ v
e U
U
5 u+
uci
?
+
a
L
^
^
A
L '
"p'rn
a
N O l
r,h
`� x�
L '
"Ch
"ati
°
>
¢N
a
s
d
rp.ti
r
>
°arn
v
V dti
F
V dti
a
V am
S
W C
W C
V1 W G
W G
W e
W E
W
W
O
W
W` C
W C
Y
O
O
p 0 d.
y
N a Q
V O. N
O a
O a
N O K Q
�
00 W'
O PC
00 PL O
C a
OC PL
b
U 'm
�_ Z
C .�-. O
� �
�✓ � �
� z
� G
� d
� b
� oma-.
r
c_
GNx ^
x N
fru a
a�x
vra rn
in v
NQi V
mci
3ha2
r..-
�osoo
§z.o
go gzo
go F' -o
uc 5 o
ep F'_'o
po 6^0
uZuar
�zupn
QzL,
�'zupr
�zua.r
Z Wn
,y
W2U Wr
�,zUar
WZuar
Wzua.r
"�wzupr

( a
ot
NORTH CAROLINA C8 WORKING GROUP
Ire -
2009 CHAPEL HILL ROAD, DURHAM, NC 27707
May 5, 20061,'.
Alan Klimek, Director DW. O WAS
Division of Water Quality a�
North Carolina Department of Environment and Natural Resources
1617 Mail Service Center
Raleigh, North Carolina 27699Water Quality Division
RE: Request to Investigate DuPont's Fayetteville Plant for Deliberate Unauthorized Discharges
APFO Plant Wastewater
Dear Mr. Klimek,
Please consider this letter as enforcement sensitive and direct it to the appropriate persons within
your Division. This request concerns DuPont's Fayetteville facility, the only location in the
United States where APFO (also known as C8) is produced. As you may know, C8
contamination of groundwater and surface water at the Fayetteville Works was discovered several
months after production of this controversial chemical began. Since that time, C8 contamination
has been found in new areas of the plant and in off-site locations. The source(s) of this
contaminationhas yet to be identified by DuPont or DENR.
Although DuPont has represented that all APFO Plant wastewater was transported out of the
complex for off-site treatment and disposal, records to support this claim are not available to the
public. If unauthorized wastewater discharges did occur, it could explain the presence of C8
contamination in surface water discharges and monitoring wells located near the Wastewater
Treatment Plant. It could also explain the presence of C8 in the Nafion area and in groundwater
at the APFO plant.
Background
On May 3, 2001 DuPont -Fayetteville submitted a renewal application for its NPDES discharge
permit. The new permit was to authorize wastewater discharges from the new APFO Plant in
addition to existing permitted discharges from other plants in the complex. It was anticipated that
up to 48,000 gallons of APFO Plant wastewater would need to be discharged each day.(1)
DuPont wanted to be able to choose between two discharge options for the APFO Plant .
wastewater. One option was to send it through the Wastewater Treatment Plant where it would
then be discharged with wastewater from other plants through a "woodlined ditch" leading to the
Cape Fear River. The other option was to bypass the Wastewater Treatment Plant, and the send
the APFO Plant wastewater to the Cape Fear River through the woodlined ditch.(2)
On January 9, 2004 DuPont was sent the NPDES permit authorizing discharges from the APFO
Plant.(3) The permit was to be effective as of February 1, 2004 and did not require the
wastewater to be monitored for C8. It allowed DuPont the option of bypassing the Wastewater
b`�

Treatment Plant when it chose to do so. Even though DuPont was granted the permit it had been
requesting since May of 2001, the company promptly notified DENR that it no longer wanted
authority to discharge APFO Plant wastewater. The DENR changed the permit accordingly on
February 3, 2004 and references to Outfall 007 and APFO Plant discharges were removed.
DuPont began operating its APFO Plant in late 2002, well before it received the permit.
authorizing APFO plant discharges. Discharges occurring before the effective date of the permit
would have been a clear violation of the Clean Water Act, as would have been discharges .
occurring after the permit was changed on February 3, 2004. DuPont claims that it has never
discharged wastewater from the APFO Plant. According to DuPont, all C8 wastewater has been
trucked to its facility in Deepwater, New Jersey, to a hazardous waste incinerator in El Dorado,
Arkansas, or to other locations.
For some reason DuPont chose the more expensive option of trucking its wastewater off-site and
out-of-state, over the less expensive option of discharging it to the Cape Fear River.(4) We
believe that it is possible that DuPont discharged APFO Plant wastewater when it first began C8
production and stopped doing so when it discovered or suspected C8 was escaping into
groundwater or surface water. DuPont claims its first sampling of groundwater for C8 took place
in January 2003.
DuPont had a possible economic incentive to begin discharging before receiving authorization to
do so. It was unlikely that APFO Plant discharges, mingled with discharges from other
manufacturing plants, would be noticed by the Division in the absence of speck sampling and
analysis, DuPont may also have assumed, and correctly so, that DENR would be issuing the
NPDES permit authorizing the discharges anyway.
The following indicates that deliberate unauthorized discharges may have occurred:
• When DuPont first applied for permission to discharge from the APFO Plant, the company
wanted to be able to by-pass the Wastewater Treatment Plant because fluoride and fluorocarbons
in the wastewaterwould cause settleability problems in the clarifiers. However, DuPont was also
concerned that APFO Plant wastewater that did not go through the Wastewater Treatment Plant
(WWTP) might exceed permit limitations for BOD. Accordingly, DuPont proposed to bypass the
WWTP unless BOD approached the permitted limits.
• In November of 2002, DuPont exceeded its permitted monthly discharge limits for BOD. This
was the first such exceedance in the site's thirty year history.(5) The exceedance resulted in a
slime appearing in the clarifiers.(6) When DuPont applied for their NPDES permit, the company
indicated that a yet to be identified Biocide would be used in the APFO Plant's scrubber.(7)
DuPont blamed the BOD exceedance of November 2002 on a new plasticiser that had been used
in the Butacite Plant without incident most of the year.
• Although DuPont would later inform the DENR that the APFO Plant did not begin operating
until November 23, 2002, a news article in the Fayetteville Observer, which included interviews
with the plant manager, states that the plant began producing C8 in October 2002.(8) The news
reporter could have been mistaken about the October startup date, but comments in a DENR
regional report also reflect a siartup date of October of 2002.
• The same DENR inspection report that identified the APFO Plant startup date of October 2002
also stated that the plant only operated for a couple of months before shutting down until June of

2003. If these dates are correct, this shut down would have occurred around January of 2003, the
same time DuPont claims to have first discovered C8 in groundwater and surface water
discharges. Perhaps this discovery prompted DuPont to stop unauthorized discharges and begin
trucking the wastewater off-site for disposal. DENR files contained records reflecting such
wastewater shipments in 2003, but not for 2002 when the APFO Plant first started operating.(9)
• DuPont claims that the C8 in groundwater at the Nafion Plant does not come from the APFO
Plant, but instead comes from the Nafion manufacturing process where it is created as a "by-
product." DuPont also claims this by-product leaked to the groundwater from an "underground
concrete waste storage vault, or sump" beneath the Nafion Plant. This area is referred to as
SWMU 6 (Common Sump). DuPont claims the sump was closed in 2000 after plant workers
found groundwater leaking through a in the crack in the floor.(10) This leak would have occurred
before the APFO Plant began operating. DuPont also reported a crack in the concrete wall near
the top of the "Waste Fluorocarbon System's secondary containment sump" on December 11,
2002. The APFO Plant was operating at this time. DuPont asked that its hazardous waste permit
be modified to allow this "existing secondary containment system" to be repaired and lined.(11)
• It is also possible that the C8 found in groundwater beneath the Nafion Plant came from
unauthorized APFO Plant wastewater discharges that were routed to the Nafion Plant. DuPont's
NPDES permit application proposed two locations for a new internal Outfall 007 to monitor
APFO Plant discharges. One was at the APFO Plant and the other was at the Nafion Plant.(12)
• It is not clear if APFO Plant discharges were intended to enter the "Common Sump" prior to
discharge through Outfall 007. Even if APFO Plant wastewater did not enter the common sump,
the wastewater could still cause or contribute to the C8 contamination in the Nafion area. In 2004
the DENR noted, "the distribution of different constituents and variations in their concentrations
implies there may be more than one release originating at SWMU 6 (Common Sump)." The
agency wanted DuPont to consider the possibility of point sources of contamination "other than
the common sump at SWMU 6."(13)
Specific Areas and Events in Need of investigation
• Pathways for Deliberate Wastewater Discharges
According to DuPont, there is a "drainage system" in the C8 plant that is "designed to catch and
guide any spilled material into a collection and treatment system.(14)" This collection and
drainage and collection system should be sampled for the presence of C8. Although DuPont
claims never to have discharged wastewater from the APFO Plant, it was apparently designed and
built on the assumption that discharges could occur.
The APFO Plant's drainage or conveyance system should be sampled at the point beginning at
the APFO plant where DuPont initially proposed Outfall 007, and points leading to the Nafion
Plant where DuPont also proposed to locate Outfall 007.
DuPont employees, who would have knowledge of APFO Plant discharges, should be
interviewed to determine if APFO Plant wastewater discharges occurred. The interviews should
be conducted off-site and in the absence of DuPont management.
• Records of Wastewater Shipment and Disposal

The DENR should locate, review, and make public company records that verify the proper
shipping, treatment, and disposal of C8 contaminated wastes. DuPont has indicated APFO Plant
wastewater was trucked off-site. DuPont reported the shipment of hazardous wastes from the
APFO Plant for year 2003 including 754,158 lb of "sulfuric acid from C8 process WFN-221,"
14,718 lb of "APFO heels from dilution tank/sump WFN-155A," and 6,894 lb of "APFO heels
from dilution tank WFN-155." These wastes were reported in the 2003 Biennial Report
submitted to EPA.
Even if reporting is required for odd years only, DuPont is required to keep records of waste
shipments for EPA to review. Records of waste haulers and the facilities where the waste was
shipped (NJD0002385730 and ARD069748192) should be checked to determine if wastes
generated in 2002 were received. EPA can also review production records to determine if the
amounts of wastes shipped correspond to the amounts produced.
We understand that documents related to enforcement investigations may not be available
to the public until the enforcement process is complete. However, we would like to know this
investigation is actually being conducted and we would like to see any evidence that wastewater
was, in fact, shipped off-site for 2002 and 2003. If the agency does not intend to investigate this
matter, we will ask others to do so.
Your attention to this matter is appreciated. Please direct your communications to the NC C8
Working Group at the address on the letterhead.
Yours y,
;f
Hope Taylor -Guevara, /
Exec. Director, Clean Water for North Carolina
[phone] or [e-mail]
c ove
Southeastern Representative, WATERKEEPERO Alliance
(252) 63 6-923 8 or [e-mail]
References:
(1) Renewal Application for NPDES Permit NC0003573, May 3, 2001.
(2) DuPont's Schematic Water Flow Process Uses, revised 4/01. Page 2 of 2 indicates that
wastewater water from the APFO plant and the Nafton Processes could be routed through the
Wastewater Treatment Plant or directly to the Cape Fear River.
(3) NPDES Permit NC0003537. NPDES Renewal Application approved by DENR and Permit
NC0003573 effective 2-1-04 attached. Indicates discharge of treated wastewater from APFO and
other facilities through internal Outfall 001 and APFO low -biodegradable wastewater through

Outfall 007. Internal Outfalls 001, 006, and 007 are discharged through Outfall 002 at Cape Fear
River. Outfall 007 (APFO low -biodegradable process wastewater) limitations were: flow .048
MGD monthly average; BODS 20 degrees C, 18 lb. a day monthly average, 48 lb. day daily
maximum; TSS 22.8 lb./day monthly average, 73.3 lb./day daily maximum; pH between 6-9
standard units.
(4) On 2/3/04 DENR sent a corrected permit reflecting changes requested by DuPont, including
references to Outfall 007 where C-8 plant discharges had previously been authorized.
(5) The 1/17/03 letter from DuPont to DENR blamed the exceedance on the use of a new
plasticizer in the Butacite Plant. According to DuPont, the plasticizer was used without issue for
most of 2002.
(6) 2/5/03, Letter from DENR to DuPont Fayetteville Works with December 5, 2002 internal
DENR email communication. According to an 3/21/03 EPA inspection report, DuPont blamed the
BOD exceedance of November 2002 on a new product (3GO Plasticide) that was discharged to
the wastewater treatment plant.
(7) 5-3-01, DuPont Renewal Application for NPDES Permit NC0003537, Potential Facility
Changes.
(8) "DuPont officials say chemical process is safe," March 3, 2003, Fayetteville Observer
(9) DuPont's 2003 Hazardous Waste Report, Forms GM, identify quantities of hazardous waste
related to the C-8 manufacturing process and the ultimate location and disposition of those
wastes.
(10) 5/26/05, "DuPont monitors chemical pollution." Fayetteville Observer
(11) 12-11-02, Letter from DuPont's Fayetteville Plant Environmental Manager to DENR
Division of Waste Management, Hazardous Waste Section
(12) It is not clear why DuPont wanted to route the APFO Plant Wastewater to the Nafion Plant
area located several hundred yards to the south east. This was not the most direct route of
discharge to the Cape Fear River or the Wastewater Treatment Plant. Although DuPont proposed
that Nafion and APFO plant discharges have the same effluent limitations and monitoring
requirements, each had a separate internal Outfall to be monitored.
(13) 6/25/04, Hazardous Waste Section's Comments on Phase I Supplemental RCRA Facility
Investigation Report (5/27/04)
(14) 3/3/03, "DuPont officials say chemical process is safe," Fayetteville Observer

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
March 22, 2011
Michael E. Johnson
Environmental Manager
Dupont — Fayetteville Works
22828 NC Hwy 87 West
Fayetteville, NC 28306-7332
Subject: BIOMONITORING INSPECTION
DuPont — Fayetteville Works
NPDES Permit No. NC0003573
Bladen County
Dear Mr. Johnson,
Dee Freeman
Secretary
Enclosed you will find a copy of the Compliance Biomonitoring Inspection report for
the inspection that Danny Strickland (DWQ-Fayetteville Regional Office) and I conducted
on February 15 and 17, 2011. The inspection included the same objectives as that of a
routine Compliance Evaluation Inspection plus a sampling inspection that included an
Aquatic Toxicity (AT) test that evaluated the biological effect of the facility's discharge on
test organisms. As part of the inspection a tour of the Wastewater Treatment Plant was
conducted. All requirements, observations, and a suggestion are in the Part D Summary of
Findings/Comments section of this inspection report. On February 15 and February 17,
Whole Effluent Toxicity samples were collected from DuPont's Outfall 002 24-hour
composite sample for use in a chronic Ceriodaphnia dubia pass/fail toxicity test. These
aquatic toxicity samples were divided by the "true split" sample splitting method and were
sent to two Whole Effluent Toxicity testing laboratories. One split sample was sent to your
commercial laboratory (Meritech), and the other split sample was sent to the Division of
Water Quality Aquatic Toxicity Laboratory, (located on Reedy Creek Road in Raleigh).
The results of both laboratories were in agreement: the Whole Effluent Toxicity (at a dilution
of. 3.3%) resulted in a "PASS". Test results for these samples indicated that the effluent
would not be predicted to have water quality impacts on receiving water. The same effluent
24-hour composite sample that was collected by DuPont at the Outfall 002 on February 15
was also analyzed for the following parameters (which are currently in your NPDES Permit):
Biochemical Oxygen Demand (BOD), Ammonia Nitrogen, Total Phosphorus, and Total
Nitrogen (NO2 + NO3 + TKN). These chemistry analyses were sent to the Division of
Water Quality Chemistry Laboratory (located on Reedy Creek Road in Raleigh), and the
results of these parameters were as follows: Biochemical Oxygen Demand = <2 mg/L, NH3
as N = 0.02 mg/L, Total Kjeldahl N = 0.62 mg/L, NO2 + NO3 = 0.92 mg/L, and Phosphorus
= 0.67 mg/L.
225 Green St., Suite 714, Fayetteville, NC 28301-5043
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748 �TDie _
Internet: www.ncwaterquality.org 1 V ofthCarolina
An Equal Opportunity \ Affirmative Action Employer Na" " tZ`l"alll

Mr. Johnson
March 22, 2011
Page 2
As according to the enclosed March 4, 2011 email from Jamie Lewis (ORC), the
corrective actions to the following opportunities for improvement that were noticed during
the inspection have already been implemented:
1) The 002 flow meter (influent river water) was calibrated at a frequency of
approximately once every three years. The requirement is once per year.
2) The operator worksheet did not indicate the Outfall identity as 001 for flow meter
totalizer readings; but, the worksheet did indicate that it was the flow readings at
the "Flume". It was understood as being the designated 001 Outfall point.
3) At 6 AM, the Outfall 001 totalizer flow meter readings were recorded on the
operator worksheet (the written integrator number). The 24-hour composite
sample was routinely taken off at 8 AM. It would be best to performed both at the
same time so that the 24-hour composite sample would accurately represent the
exact same 24-hour flow period.
4) The MGD flow readings that were used for the pounds per day calculations were
usually taken from the operator worksheets that he wrote as the integrator number
at 6 AM.while he was at the Outfall 001 site location. But occasionally, the MGD
totalizer flow was also taken from a different electronic flow meter reading
location for use in the pounds calculation on the DMR, which may also have been
at a time other than 6 AM, and may not have been the same number that was
recorded at 6 AM.
During the week of this inspection, the facility was found to be in compliance with
permit NC0003573. In the future, please indicate on the DMRs that the Influent flow meter
was used to estimate the flow at Outfall 002, instead of an Effluent flow measuring device as
was previously noted. You are commended your continued success with the wastewater
treatment plant. I appreciate the time and professional courtesy that was extended by your
staff during the inspection. Jamie Lewis's cooperation and attitude for improvement was
greatly appreciated. If you have any questions about this report, please contact me at (410)
433-3312.
Si
Dale Lopez
Environmental
Enclosures: EPA Water Compliance Inspection Report and Facility Site Review (checklist)
Regional Field Inspectors Check List for Field Parameters
Water Balance (Revised 12/07/06) flow diagram
cc: Jamie Lewis, ORC
FRO Files (Mark Brantley)
Danny Strickland, DWQ-FRO

United States Environmental Protection Agency
Form Approved.
EPA Washington, D.C. 20460
OMB No. 2040-0057
Water Compliance Inspection Report
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 I NI 2 151 31 NC0003573 ( 11 121 11/02/15 117 181 BI 191 s1 201 1
Remarks
2111111111111111111111 11111111 11111111 1111 11111116
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA -------------Reserved-------- -
671 4.0 169 70131 711 1 721 N I 73L_U ' 74 751 I I 1 I I I 180
u_1
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time/Date
Permit Effective Date
POTW name and NPDES permit Number)
Dupont Fayetteville Works
09:00 AM 11/02/15
07/07/01
Exit Time/Date
Permit Expiration Date
22828 NC Highway 87 West
Fayetteville NC 283067332
02:00 PM 11/02/15
11/10/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Jamie Ray Lewis/ORC/910-678-1143/
Name, Address of Responsible Official/Title/Phone and Fax Number
Michael Johnson,2262B NC Highway 67 West Fayetteville NC Contacted
283067332//910-678-1155/ No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Flow Measurement Operations & Maintenance Records/Reports
Self -Monitoring Program Sludge Handling Disposal Facility Site Review Effluent/Receiving Waters
Laboratory
Section D: Summary of Finding/Comments Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and n e(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Dale Lopez FRO WQ//910-433-3300 Ext.712/ 9A 0//
Signature ofkAanagement Q A eviewer Agency/Office/Phone and Fax Numbers
/Dae
--&& I 3a
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page # 1

NPDES yr/mo/day Inspection Type (cont.) 1
3I NC0003573 I11 12I 11/02/15 '17 1801
UJ
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Enclosed you will find a copy of the Compliance Biomonitoring Inspection report for the inspection that
Danny Strickland (DWQ-Fayetteville Regional Office) and I conducted on February 15 and 17, 2011. The
inspection included the same objectives as that of a routine Compliance Evaluation Inspection plus a
sampling inspection that included an Aquatic Toxicity (AT) test that evaluated the biological effect of the
facility's discharge on test organisms. As part of the inspection a tour of the Wastewater Treatment Plant
was conducted. All observations and recommendations are in the Part D Summary of Findings/Comments
section of this inspection report. On February 15 and February 17, Whole Effluent Toxicity samples were
collected from DuPont's Outfall 002 24-hour composite sample compositer for use in a chronic
Ceriodaphnia dubia pass/fail toxicity test. These aquatic toxicity samples were divided by the "true split"
sample splitting method and were sent to two Whole Effluent Toxicity testing laboratories. One split sample
to your commercial laboratory (Meritech) and the other split sample was sent to the Division of Water
Quality Aquatic Toxicity Laboratory, (located on Reedy Creek Road in Raleigh). The results of both
laboratories were in agreement: the Whole Effluent Toxicity (at a dilution of 3.3%) resulted in a "PASS".
Test results for these samples indicated that the effluent would not be predicted to have water quality
impacts on receiving water. The same effluent 24-hour composite sample that was collected by DuPont at
the Outfall 002 on February 15 was also analyzed for the following parameters (which are currently in your
NPDES Permit): Biochemical Oxygen Demand (BOD), Ammonia Nitrogen, Total Phosphorus, and Total
Nitrogen (NO2 + NO3 + TKN). These chemistry analyses were sent to the Division of Water Quality
Chemistry Laboratory (located on Reedy Creek Road in Raleigh), and the results of these parameters were
as follows: Biochemical Oxygen Demand = <2 mg/L, NH3 as N = 0.02 mg/L, Total Kjeldahl N = 0.62 mg/L,
NO2 + NO3 = 0.92 mg/L, and Phosphorus = 0.67 mg/L.
The following items were addressed and the corrective actions have already been implemented. For the
corrective actions, please see the enclosed March 4, 2011 email from Jamie Lewis, ORC. During the
inspection, I noted the following: 1)The 002 flow meter (influent river water) was calibrated at a frequency of
approximately once every three years.2)The operator worksheet did not indicate the Outfall identity as 001
for flow meter totalizer readings; but, the worksheet did indicate that it was the flow readings at the "Flume"
(and therefore, that it was the 001 Outfall).3)At 6 AM, the Outfall 001 totalizer flow meter readings were
recorded on the operator worksheet (the written integrator number). The 24-hour composite sample was
routinely taken off at 8 AM. Both should be performed at the same time so that the 24-hour sample would
accurately represent the exact 24-hour flow period. 4)The MGD flow readings that were used for the pounds
per day calculations were usually taken from the operator worksheets that were read at 6 AM at the Outfall
001 site location. But occasionally, the MGD totalizer flow was taken from an electronic flow meter reading
at a time other than 6 AM, thus possibly causing disagreement between the two 24-hour flow meter
readings that may have been recorded for same 24-hour period by two different individuals. It would be
better that the two 24-hour flow meter readings agreed exactly when calculating pounds per day for the
DMRs.
Requirements: 1) Already implemented (see #1 above),2)Already implemented (see #2 above), 3)Already
implemented (see #3 above), 4)Already implemented (see #4 above), 5)Beginning with the most recent
DMR to be submitted, please note on the Outfall 002 DMR that the Influent flow meter was the measuring
device for Outfall 002 (please see the Flow column on the DMRs).Suggestion: 1)During the inspection, rust
was noticed on the catwalk of one of the clarifiers. It is suggested that painting the catwalk may be helpful
in preventing repairs due to corrosion in the future. During the week of this inspection, the facility was
found to be in compliance with permit NC0003573. You are commended for the continued success of the
wastewater treatment plant. I appreciate the time and professional courtesy that was extended by your staff
during the inspection; Jamie Lewis's cooperation was greatly appreciated. If you have any questions about
this report, please contact me at [phone].
A Brief Description of DuPont — Fayetteville Works WWTP: The Polyvinyl Fluoride (PVF) facility began
Page # 2

Permit: NC0003573 Owner - Facility: Dupont Fayetteville Works
Inspection Date: 02/15/2011 Inspection Type: Bioassay Compliance
production in October 2007, and an expansion of that product started up in June 2010. SentryGlas® (SG),
located on the North side of plant, Butacite® (West side), Nafion® (East side) merged influent process and
domestic flows (from the Sanitary Sewage Lift Station at Third Street and C Street) in the Collection Sump
from two lines. The PPA Process (processing aid for Teflon®) wastewater was shipped out, except for the
sanitary sewer. The influent had between 500 to 700 mg/L of BOD (90% of the BOD & COD came from the
Butacite® Plant) and between 1000 to 2,000 mg/L of COD. Flow could be diverted (by automatic
switch -over) to a 175,000 -gallon capacity Retention Tank (that handled spills and chemical slugs), and later
sent back to the Collection Sump through a two-inch line. Normally, the flow was pumped to an 850,000
gallon capacity Equalization Basin (EQ), which had three aerators (40 HP each) and two mixers (20 HP
each). In the EQ basin, there was re -circulation through a Muffin Monster; the flow then went back to the
EQ basin. The Collection Sump and the Equalization Basin were considered as the Primary Treatment
Units. The Pre -Digester Tank, Aeration Tank (20 feet deep, with 3 feet of freeboard), and the two Clarifier
Tanks were considered as the Secondary Treatment Units. Flow was then pumped to an aerated
Pre -Digester Tank, with a 50 horsepower (HP) aerator and a 15 HP blower. Adsorption of the
hydrocarbons onto the bacteria occurred in the Pre -Digester Tank. Flow was then pumped to an Aeration
Tank (where Absorption occurred), diffused air by two blowers (each rated at 4,000 cubic feet per minute
(CFM), one blower rated at 1,200 CFM, and two BioMixers). Ammonium hydroxide (28% concentration)
was used as a nitrogen nutrient source, and phosphoric acid was used for the phosphate nutrient source.
Both were continuously added to the Aeration Tank. In addition, when the production plant was down and
the biomass food source was low. sodium acetate or Mt. Olive pickle brine was added to the Aeration Tank
as a carbon source to keep the biomass in good condition. Folic acid was continuously added as a
micronutrient. Flow traveled to the two circular Clarifier Tanks. #1 Clarifier Tank was 45 -feet in diameter and
10 -feet deep. #2 Clarifier Tank was 55 -feet in diameter and 10 -feet deep. An Authorization to Construct (A
to C) is presently in the process for a #3 Clarifier Tank. For process control, the sludge blanket has a target
range of between zero to 5 feet was maintained in each Clarifier Tank. The Return Activated Sludge (RAS)
was pumped from the two circular Clarifier Tanks to the Aeration Tank. Scum that was collected from the
Clarifier Tanks was pumped to the Equalization Basin. Effluent from the Clarifier Tanks flowed to a 6 -inch
Parshall Flume. The Outfall 001 composite sampler was located at the Parshall Flume. Outfall 001 effluent
had treated wastewaters from the Sanitary Wastewater, Demineralizer Regeneration Wastewater, Process
Wastewater from the Butacite Plant Area, Process Wastewater from Nafion Area, and process wastewater
from Sentry Glass Plus. Flow from Outfall 001 traveled into a board lined ditch, which contained the boiler
blow -down from Dupont oil -fired boilers, boiler blow -down, the once -through cooling water, and filter
backwash that was discharged to the Nafion® ditch, which then flowed to a wood- lined ditch. Approximately
50 to 100 feet downstream of where Outfall 001 flow commingled with flow that was in the Board Lined
Ditch; the flow then passed under a board deck that supported the Outfall 002 compositor. For compliance
monitoring of samples for chronic toxicity and according to the NPDES permit, the samples were taken
downstream of the confluence of outfall 001 and 002. An A to C is in the process for the relocation of Outfall
002 to the Cape Fear River at a location upstream of Lock and Dam No. 3. Waste Activated Sludge (WAS)
flowed from the underflow of the two Clarifier Tanks and traveled to the Dissolved Air Floatation (DAF)
Tank. The solids were pumped to a Holding Tank, then to a Feed Tank (with coagulant). The flow was
thickened (with polymer addition) in the Pre -Thickener Tank (Steam addition). Solids were dewatered in the
Screw Press (with Steam addition); and, the Total Solids analysis at this point ranged from 9% to 18%. A
conveyor transferred the solids to a Hold -Up Tank, where it was mixed with lime. Solids traveled along
another conveyor, then through an air and steam dryer (the air going to an Odor Scrubber and vented to the
atmosphere). The dried solids were transferred onto another conveyor, to a Sludge Waste Container, and
finally to the Sampson County (Roseboro) Landfill (Waste Industries, Inc.), a commercial Subtitle D landfill.
The final day filter sludge Total Solids analysis ranged from 35 to 60%.
SUMMARY OF INDUSTRIES: Nafion@ Manufacturing: Nafion® Membrane is a plastic film used in the
chloroalkali industry and in electro chemical fuel cells. Nafion® Resins are ultimately extruded into a
Page # 3

Permit: NC0003573
Inspection Date: 02/15/2011
Owner - Facility: Dupont Fayetteville Works
Inspection Type: Bioassay Compliance
finished film. The FLPR Vinyl Ether and HFPO monomers are shipped to other DuPont locations to produce
various fluorochemical products such as DuPont Teflon®. Wastewater from this facility is discharged to the
WWTP.
(Teflon® is no longer at this site.)
Butacite& Manufacturing: Produces Butacite® Interlayer plastic sheeting used in safety glass. Polyvinyl
butyral (PVB) resin is shipped off-site as a transfer to other DuPont locations for final processing. The
wastewater from this manufacturing facility is treated in the site's biological WWTP.
SentryGlas& Manufacturing: This is an ionoplast interlayer laminate used for production of laminated
automotive safety glass and architectural safety glass. This manufacturing process started in June 2005.
No process wastewaters flow to the WWTP. Non -contact cooling water is discharged the wood lined ditch
and ultimately to the Outfall 002.
Polymer Processing Aid (PPA) Manufacturing: Fluorocarbon compounds are produced and shipped to
other DuPont facilities where they are used as processing aids in the production of fluoropolymers and
fluorinated telomers. The wastewaters that are generated in this process are collected and shipped off-site
for disposal.
Polyvinyl Fluoride resins (PVF) Manufacturing: This facility produced PVF and began production in October
2007 with an expansion that started up in June 2010. PVF is used in DuPont Tedlar& fluoropolymer film
manufactured at other DuPont facilities. Tedlar& is used in the photovoltaic industry (in photovoltaic cells)
and the aircraft industry for interior cabin surfaces, as well as other uses. The wastewater generated at this
site was treated at the on-site wastewater treatment plant. Wastewater from the PVF process contained
un -reacted vinyl fluoride, with little or no BOD value. The expected concentration of vinyl fluoride at Outfall
0002 was 0.0035 mg/L. Non -contact cooling water, condensate, and storm water was discharged to Outfall
002.
Additional notes from the DuPont site visit on 02-15-2011: All units were up. DuPont has been hauling
sludge at a rate of one truckload per day because the sludge heat dryer, located in the filter press building,
has been down for approximately six weeks. Plans were to start back next week. There were two manholes
that were approximately Y2 mile upstream of the influent collection sump. The manholes had pH adjustment
with 20% sodium hydroxide (caustic soda) with a pH meter and automatic pressure header to adjust to 9.5
pH units. The Butacite plant added phosphoric acid to the WWTP influent wastewater. The WWTP also had
the ability to add phosphoric acid if needed. In the aeration tank 28% aqueous ammonium hydroxide was
added. Folic acid was continuous added to the Return Activated Sludge (RAS) that was going back into the
aeration basin. There were three blowers in the aeration basin: one 1500 cfm, and two 4,000 cfm. There
were two aerators in the EQ Basin. The new Clarifier (#3) may go into service at the end of March 2011.
Plans were to put a new Clarifier (#3) on line, take #1 & #2 clarifiers off-line for repair. #1 & #2 will be kept
operational, but not in service. Neither chlorine nor any other disinfectant was added; this WWTP was not
required to test for fecal coliform because this industry was less than 2% domestic and fecal coliform would
probably not survive in such a harsh chemical environment. The 001 Parshall Flume was calibrated on
August 16, 2010 and more recently February 1, 2011 by Richard Brown with ISI Instrumentation Services,
Inc, no adjustment was needed for either calibration. The 002 flow measuring device was a Rosemont 1151
DP (Differential Pressure) Flowmeter (venturi type) located at the DuPont facility's Cape Fear water intake
(a 42 -inch pipe). Possible sources of flow error when using influent flow values for the estimated effluent
flow from the facility to the River: effect of evaporation loss within the entire DuPont facility, effect of
infiltration, use of purchased potable water that flowed thru the WWTP, and the influence of the storm water
volume from a rain event. The 002 flow meter totalizer readings were recorded on the operator's worksheet.
Although the A to C has been approved (ATC #003573A02), the clearing and construction projects have not
Page # 4

Permit: NC0003573
Inspection Date: 02/15/2011
Owner - Facility: Dupont Fayetteville Works
Inspection Type: Bioassay Compliance
begun yet. According to Mike Johnson, plans are to also have an effluent flow meter with the relocation of
Outfall 002.
Page # 5

Permit: NC0003573 Owner - Facility: Dupont Fayetteville Works
Inspection Date: 02/15/2011 Inspection Type: Bioassay Compliance
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? ■ Q n n
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge ■ n n n
Judge, and other that are applicable?
Comment:
(If the present permit expires in 6 months or less). Has the permittee submitted a new application?
■
n
n
n
Is the facility as described in the permit?
■
n
n
n
# Are there any special conditions for the permit?
0000
n
n
Q
Is access to the plant site restricted to the general public?
■
n
n
n
Is the inspector granted access to all areas for inspection?
■
n
n
n
Comment:
Record Keeping
Yes
No
NA
NE
Are records kept and maintained as required by the permit?
■
n
n
Q
Is all required information readily available, complete and current?
■
n
n
n
Are all records maintained for 3 years (lab. reg. required 5 years)?
■
n
n
n
Are analytical results consistent with data reported on DMRs?
■
n
n
n
Is the chain -of -custody complete?
■
n
Cl
Cl
Dates, times and location of sampling
■
Name of individual performing the sampling
■
Results of analysis and calibration
■
Dates of analysis
■
Name of person performing analyses
■
Transported CDCs
■
Are DMRs complete: do they include all permit parameters?
■
000
Has the facility submitted its annual compliance report to users and DWQ?
■
000
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift?
■
Cl
n
n
Is the ORC visitation log available and current?
■
n
n
n
Is the ORC certified at grade equal to or higher than the facility classification?
■
n
n
n
Is the backup operator certified at one grade less or greater than the facility classification?
■
n
n
n
Is a copy of the current NPDES permit available on site?
■
n
n
n
Page # 6

Permit: NC0003573 Owner - Facility: Dupont Fayetteville Works
n n ■ n
Comment:
NA
Inspection Date: 02/15/2011 Inspection Type: Bioassay Compliance
Yes No NA NE
# Is flow meter used for reporting?
■ n n n
Record Keeping Yes
No
NA
NE
Facility has copy of previous year's Annual Report on file for review? n
n
■
n
Comment:
n
Starting with the most recent DMR, please indicate that the Influent flow measuring
n
Effluent Pipe Yes
No
NA
NE
Is right of way to the outfall properly maintained? ■
n
n
n
Are the receiving water free of foam other than trace amounts and other debris? ■
n
n
n
If effluent (diffuser pipes are required) are they operating properly?
n n ■ n
Comment:
NA
Flow Measurement - Influent
Yes No NA NE
# Is flow meter used for reporting?
■ n n n
Is flow meter calibrated annually?
n ■ n n
Is the flow meter operational?
■ n n n
(If units are separated) Does the chart recorder match the flow meter?
n n n ■
Comment: The influent flow reading at the intake from the Cape Fear River (for the
Is the flow meter operational?
whole production plant) was used for the 002 Effluent flow reading on the DMR.
n
Starting with the most recent DMR, please indicate that the Influent flow measuring
n
device was used for estimating the Outfall 002 flow. This flow meter was calibrated on
■
a frequency of approximately once every three years. Immediately after this inspection,
n
DuPont implemented an Influent flow meter calibration schedule of once per year.
Comment: The Outfall 001 was correctly reported as an Effluent Flow measuring
Flow Measurement - Effluent
Yes
No
NA
NE
# Is flowmeter used for reporting?
■
n
n
Cl
Is flow meter calibrated annually?
■
n
n
n
Is the flow meter operational?
■
n
n
n
(If units are separated) Does the chart recorder match the flow meter?
■
n
n
n
Comment: The Outfall 001 was correctly reported as an Effluent Flow measuring
■
n
n
n
device in the column on the DMR for Flow (code 50050).
■
n
n
n
Solids Handling Equipment
Yes
No
NA
NE
Is the equipment operational?
■
n
n
n
Is the chemical feed equipment operational?
■
n
n
n
Is storage adequate?
■
n
n
n
Is the site free of high level of solids in filtrate from filter presses or vacuum filters?
■
n
n
n
Is the site free of sludge buildup on belts and/or rollers of filter press?
■
n
n
n
Is the site free of excessive moisture in belt filter press sludge cake?
■
n
n
n
Page # 7

Permit: NC0003573 Owner - Facility: Dupont Fayetteville Works
Inspection Date: 02/15/2011 Inspection Type: Bioassay Compliance
Solids Handling Equipment Yes No NA NE
The facility has an approved sludge management plan? ■ ❑ ❑ ❑
Comment: DuPont has been hauling sludge at a rate of one truckload per day
because the sludge heat dryer, located in the filter press building, has been down for
approximately six weeks. Plans were to start back next week.
Equalization Basins
Yes
No
NA
NE
Is the basin aerated?
■
❑
❑
❑
Is the basin free of bypass lines or structures to the natural environment?
■
❑
❑
❑
Is the basin free of excessive grease?
■
fl
❑
0
Are all pumps present?
■
❑
❑
n
Are all pumps operable?
■
❑
n
❑
Are float controls operable?
■
❑
0
❑
Are audible and visual alarms operable?
■
Cl
fl
0
# Is basin size/volume adequate?
■
❑
❑
❑
Comment:
Secondary Clarifier
Yes
No
NA
NE
Is the clarifier free of black and odorous wastewater?
■
❑
❑
❑
Is the site free of excessive buildup of solids in center well of circular clarifier?
■
❑
❑
❑
Are weirs level?
■
❑
❑
❑
Is the site free of weir blockage?
■
❑
❑
❑
Is the site free of evidence of short-circuiting?
■
❑
❑
❑
Is scum removal adequate?
■
❑
❑
❑
Is the site free of excessive floating sludge?
■
❑
❑
❑
Is the drive unit operational?
■
❑
❑
❑
Is the return rate acceptable (low turbulence)?
■
❑
❑
❑
Is the overflow clear of excessive solids/pin floc?
■
❑
❑
❑
Is the sludge blanket level acceptable? (Approximately % of the sidewall depth)
■
❑
❑
❑
Comment: During the inspection, rust was noticed on the catwalk of one of the
clarifiers. It is suggested that painting the catwalk may be helpful in preventing repairs
due to corrosion in the future. The new Clarifier (#3) may go into service at the end of
March 2011. Plans were to put the new Clarifier (#3) in service, and take #1 & #2
clarifiers off-line for repair. It is planned that #1 & #2 will be kept operational, but not in
service.
Page # 8

Permit: NC0003573
Inspection Date: 02/15/2011
Aeration Basins
S
Owner - Facility: Dupont Fayetteville Works
Inspection Type: Bioassay Compliance
Mode of operation
Type of aeration system
Is the basin free of dead spots?
Are surface aerators and mixers operational?
Are the diffusers operational?
Is the foam the proper color for the treatment process?
Does the foam cover less than 25% of the basin's surface?
Is the DO level acceptable?
Is the DO level acceptable?(1.0 to 3.0 mg/1)
Comment:
Laboratory
Are field parameters performed by certified personnel or laboratory?
Are all other parameters(excluding field parameters) performed by a certified lab?
# Is the facility using a contract lab?
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)?
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees?
Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees?
Comment:
Effluent Sampling
Is composite sampling flow proportional?
Is sample collected below all treatment units?
Is proper volume collected?
Is the tubing clean?
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type representative)?
Comment:
Yes No NA NE
Ext. Air
Diffused
■ n n n
■ n n n
■non
■ n n n
■nnn
■ n n n
■nnn
Yes No NA NE
■nnn
■nnn
■nnn
■nnn
nn■n
nn■o
Page # 9

Regional Field Inspectors Check List for Field Parameters
Name of site to be Inspected: DuPont Date: 02-1 -2011
Field certification # (if applicable): 5105 Inspector: Da e
�ogpk:
NPDES #: NC 0003573 Region: FRO
1. Circle the parameter or parameters performed at this site.
Residual Chlorine, Settleable Solids, �H, DO, Conductivity, em erature
11. Instrumentation:
A. Does the facility have the equipment necessary to analyze field parameters as circled above?
1. A pH meter IFisher Accumet 50 pH Mete es No
2. A Residual Chlorine meter Yes No
3. DO meter
Yes
No
4. A Cone for settleable solids
Yes
No
5. A thermometer or meter that measures temperature.
es
No
6. Conductivity meter
Yes
No
Ill. Calibration/Analysis:
1. Is the pH meter calibrated with 2 buffers and
checked with a third buffer each day of use? yis No
2. For Total Residual Chlorine, is a check standard
analyzed each day of use? Yes No
3. Is the air calibration of the DO meter performed
each day of use? Yes No
4. For Settleable Solids, is 1 liter of sample
settled for 1 hour? Yes No
5. Is the temperature measuring device calibrated
annually against a certified thermometer? es No
Oanuary 2010
6. For Conductivity, is a calibration standard
analyzed each day of use? Yes No

IV. Documentation:
1. Is the date and time that the sample was collected documented?
es
No
2. Is the sample site documented?
es
No
3. Is the sample collector documented?
Y es
No
4. Is the analysis date and time documented?
es
No
5. Did the analyst sign the documentation?
es
No
6. Is record of calibration documented?
es
No
7. For Settleable Solids, is sample volume and
1 hour time settling time documented?
Yes
No
8. For Temperature, is the annual calibration of
the measuring device documented?
es
No
Janua 2010
Comments:
pH 4 Buffer expiration date was 07/31/2013
pH 7 Buffer expiration date was 09/30/2013
pH 10 Buffer expiration date was 07/31/2013
Please submit a copy of this completed form to the Laboratory Certification Program.
DWQ Lab Certification
Chemistry Lab
Courier # 52-01-01
FIELD INSPECTOR CHECKLIST REV. 04/23/2002

J�
Lopez, Dale
From: Jamie R Lewis [Jamie. R. [e-mail]]
Sent: Friday, March 04, 2011 12:48 PM
To: Lopez, Dale
Subject: Re: FW: DuPont CEI and WET sampling (BIO inspection) on February 8th and 10th
Attachments: Brief Description of DuPont.doc
Hey Dale,
I just wanted to give you an update on the items we found during our audit.
1 - We have updated our calibration on our 002 flow meter to a 1 year calibration.
2 - Changed wording on our daily report to say "001 integrator reading @ 0800"
3 - Updated our integrator reading from 0600 to 0800 to match our sample removal.
4 - Changed our electronic shift notes format to match our written integrator number.
Thanks,
Jamie
"Lopez, Dale" <dale.lopez(a)ncdenr.gov> To Jamie R Lewis/AE/DuPont@DuPont
cc "Lopez, Dale" <dale.lopez oQncdenr.gov>, Danny Strickland
01/05/2011 12:18 PM <Dannv.Strickland(a)ncmail.net>
Subject FW: DuPont CEI and WET sampling (BIO inspection) on February 8th and 10th
Hi Jamie,
As per your request yesterday, the inspection will be during the week of February 14th instead of February 7th. Danny
Strickland and I will arrive at the truck entrance gate at 9:00 AM on February 15th and on February 17th at 9 AM for the split
procedure with you (Meritech). if there is enough sample after you take your chemistries, I would like to collect some of the 24-
hour composite for BOD, COD, T -Phos, and T -Nitrogen (for an additional amount of <2 liters).
Thanks,
Dale
From: Lopez, Dale
Sent: Thursday, December 30, 2010 11:28 AM
To: jam ie. r.lewis(a)usa.dupont.com
Cc: Lopez, Dale; Danny Strickland
Subject: DuPont CEI and WET sampling (BIO inspection) on February 8th and 10th
Hi Jamie,
As per our phone conversation this morning, Danny Strickland and I will be visiting your W WTP for a routine BIO inspection
(CEI & WET Sampling) on Tuesday, February 81h , (arriving at the truck entrance gate at 9:00 AM) and on Thursday, February 101h
,(9:00 AM at the gate). I understood that you would start your 1"t WET sample at 9 AM on Monday February 7th , and that I would
be permitted to obtain a "split" sample; the same start time with your 2nd sample. In order to perform the "True Split Procedure", I
will need to be present at the time that each of the 24-hour composites is poured into the WET cubitainers (on Tuesday and
Thursday), that I estimate will be 9:30 AM on both days. Thank you for collecting enough volume of sample from your 24-hour
composite equipment for me to split samples.

QRON -N
momoD
DUPONT COMPANY - FAYETTEVILLE WORKS
RENEWAL APPLICATION
FOR
NPDES PERMIT NC0003573
2@19on4
MAY 0 2 2011
SUBMITTED APRIL 29, 2011

Please,print or type in the unshaded areas only FApproved. OMB No. 2040-0086. Approval ices 5-31-92
/fill-in nr-,q.ara snar-rl fnr alit- tvn- in 12 rhararters/inch)_ or pp pp expires
FORM
U.S. ENVIRONMENTAL PROTECTION AGENCY
I. EPA I.D. NUMBER
GENERAL INFORMATION
TiA D
F
Consolidated Permits
Program
110000559609
1
2 13 14 15
GENERAL
Read the "General Instructions" before starting)
LABEL ITEMS
GENERAL INSTRUCTIONS
If a preprinted label has been provided,
affix it in the designated space. Review the
information carefully; if any of it is
I. EPA I.D. NUMBER
110000559609
incorrect, cross through it and enter the
correct data in the appropriate fill-in area
III. FACILITY NAME
DUPONT COMPANY — FAYETTEVILLE WORKS
below. Also, if any of the preprinted data is
absent (the area to the left of the label
space Fists the information that should
a)'pear) please provide it in the proper fill -
in areas) below. If the label is com lete
Mems
V. FACILITY
22828 NC HIGHWAY 87 W
MAILING LIST
FAYETTEVILLE NC 28306-7332
�
and correct you need not complete
I, III, V, and VI (except VI -B which must be
completed regardless). Complete all items
if no label has beenroved. Refer to the
instructions for detained item descriptions
VI. FACILITY
22828 NC HIGHWAY 87 W
L
LOCATION
DUART TOWNSHIP, BLADEN COUNTY, NC
and for the legal authorization under which
this data is collected.
11;.POLLU�AN7 GHAR3ACTERISTICS
INSTRUCTIONS: Complete A
through J to determine whether you need to submit any permit application forms
to the EPA. If you answer "yes" to any
questions, you must submit this
form and the supplemental from listed in the parenthesis following the question.
Mark "X" in the box in the third column if
the supplemental form is attached.
If you answer "no" to each question, you need not submit any of these forms.
You may answer "no" if your activity is
excluded from permit requirements;
see Section C of the instructions. See also, Section D of the instructions
for definitions of bold-faced terms.
MARK "X" ISPECIFIC
MARK "X
SPECIFIC QUESTIONS
QUESTIONS
YES
NO
FORM
YES
NO
FORM
ATTACHED
ATTACHED
A. Is this facility a publicly owned treatment works
which results in a discharge to waters of the
❑
®
❑
B.
Does or will this facility (either existing or
proposed) include a concentrated animal
❑
®
❑
U.S.? (FORM 2A)
feeding operation or aquatic animal
production facility which results in a discharge
to waters of the U.S.? (FORM 26)
16
17
18
19
20
21
C. Is this facility which currently results in
®
EJ®
D.
Is this proposal facility (other than those described
❑
®
❑
discharges to waters of the U.S. other than
in A or B above) which will result in a discharge
22
23
24
25
26
27
those described in A or B above? FORM 2C
to waters of the U.S.? FORM 2D
E. Does or will this facility treat, store, or ispose of
hazardous wastes? (FORM 3)
®
❑
❑
F.
Do you or will you inject at this facility industrial or
municipal effluent below the lowermost stratum
❑
®
❑
containing, within one quarter mile of the well
bore, underground sources of drinking water?
(FORM 4)
28
29
30
31
32
1 33
G. Do you or will you inject at this facility any
H.
Do you or will you inject at this facility fluids or
produced water other fluids which are brought to
the surface in connection with conventional oil or
❑
®
❑
special processes such as mining of sulfer by the
Frasch process, solution mining of minerals, in
❑
®
❑
natural gas production, inject fluids used for
situ combustion of fossil fuel, or recovery of
enhanced recovery of oil or natural gas, or inject
geothermal energy? (FORM 4)
fluids for storage of liquid hydrocarbons?
35
36
37
38
39
FORM L34
1
I. Is this facility a proposed stationary source
J.
Is this facility a proposed stationary source
which is one of the 28 industrial categories listed
®
❑
❑
which is NOT one of the 28 industrial categories
instructions ❑
®
❑
in the instructions and which will potentially emit
listed in the and which will potentially
100 tons per year of any air pollutant regulated
emit 250 tons per year of any air pollutant
under the Clean Air Act and may affect or be
regulated under the Clean Air Act and may affect
41
44 45
located in an attainment area? RM 5 40
FO
42
or be located in an attainment are? FORM 5 43
NAME OF ILITY
111. FAC
SKIP DUPONT COMPANY —FAYETTEVILLE
WORKS
15 16-29 30
69
IV. FACILITY CONTACT
A. NAME & TITLE last, first, & title
B. PHONE area code & no.
2 JOHNSON, MICHAEL, ENVIRONMENTAL MANAGER
910 678 1155
15 16
45 46 48 49 51 52 55
V. FACILITY MAILING ADDRESS
A. STREET OR P.O. BOX
3 22828 NC HIGHWAY 87 W
15 1 16
45
B. CITY OR TOWN C. STATE D. ZIP CODE
C-1—
FAYETTEVILLE
P1
NC 28306-7332
1640 41
42 47 51
V1. FACILITY LOCATION`
A. STREET, ROUTE NO. OR OTHER SPECIFIC IDENTIFIER
s 22828 NC HIGHWAY 87 W
INTCQUALITY
BuOSOURC
15 16
45
B. COUNTY NAME
BLADEN
46 70
C. CITY OR TOWN
D. STATE
E. ZIP CODE
F. COUNTY CODE
s DUART TOWNSHIP
NC
28306
37017
15 16 40 1
41 42
47 51
52 54
EPA FORM 3510-1 (8-90) CONTINUED ON REVERSE

CONTINUED FROM THE FRONT
Vit. SIC CODES (4-d1g#,, in order pf priority)
A. FIRST B. SECOND
2869
INDUSTRIAL ORGANIC
CHEMICALS
7 2821
PLASTIC MATERIALS AND RESINS
c
15
16 17
15 16 19
C. THIRD D. FOURTH
c 3081 UNSUPPORTED PLASTICS FILM 7 (specify)
15 16 17 AND SHEET 15 ,6 19
VIII: OPERATOR INEORMN17ION
A. NAME B. Is the name listed in Item
c 1—
1. DU PONT DE NEMOURS & COMPANY, INC. VIII -A also the owner?
® YES EJ NO
8
18
19 55
C. STATUS OF OPERATOR Enter the appropriate letter into the answer box; if "Other,"specify.)D.
PHONE area code & no.
F = FEDERAL M = PUBLIC (other than federal or state)
P
302
1000S
A
=STATE O = OTHER (specify)
NIAP
L774
56
16 18
21
1 22 25
= PRIVATE
15
E. STREET OR PO BOX
1007 MARKET STREET
26 55
F. CITY OR TOWN G. STATE H. ZIP CODE IX INDIAN„LAND i`
cWILMINGTON DE 19898 Is the facility located on Indian lands?
B ❑ ®
YES NO
15 16 40 42 4 47 51
X, EXISTING; ENVIRONMENTAL: PERMITS
A. NPDES (Discharges to Surface Water D. PSD Air Emissions from Proposed Sources
g N I NC0003573 g P 8 NC TITLE V PERMIT 03735
15 1 16 1 17 18 30 15 1 16 17 1 18 30
B. UIC (Underground Injection of Fluids E. OTHER (specify)
(Specify)
N/A s T 8
N/A
9 U
15 16 17
18 30 15 16 17
1 18 30
C. RCRA Hazardous Wastes E. OTHER (specify) (Specify)
cT NCD047368642 c T 8 NIA
15 16 17 18 30 1 15 1 16 1 17 18 30
XL�MAP :;
Attach to this application a topographic map of the area extending to at least one mile beyond property boundaries. The map must
show the outline of the facility, the location of each of its existing and proposed intake and discharge structures, each of its
hazardous waste treatment, storage, or disposal facilities, and each well where it injects fluids underground. Include all springs,
rivers and other surface water bodies in the map area. See instructions for precise requirements.
XII. NATURP OF,BUSINESS (provide -a brief description
CHEMICAL MANUFACTURER PRODUCING THE FOLLOWING PRODUCTS:
• DUPONTTm BUTACITEO POLYVINYL BUTYRAL (PVB) THERMOPLASTIC SHEETING
• DUPONTTMSENTRYGLASOTONOPLASTINTERLAYER
• DUPONTTm NAFIONO MEMBRANE AND DISPERSION
• FLUORINATED MONOMERS AND VINYL ETHERS
• POLYVINYL FLUORIDE (PVF) RESIN
• FLUOROPOLYMER PROCESSING AIDS
XIII. CERTIFICATION (see instructions)
I certify under penalty of law that I have personally examined and am familiar with the information submitted in this application and
all attachments and that, based on my inquiry of those persons immediately responsible for obtaining the information contained in
the application, ! believe that the information is true, accurate and complete. ! am aware that there are significant penalties for
submittingfalse information, includingthe ossibllit of fine and im risonment.
A. NAME &OFFICIAL TITLE (type or print) B IGNATU A
C. DATE SIGNED
ELLIS H. MCGAUGHY, PLANT MANAGER K7
COMMENTS FOR OFFICIAL USE ONLY
ECc
15
16 55
EPA FORM 3510-1 (8-90)

Y
O
w
J
J_
w
I-
H
w
a
LL
U)
w
H
U
w
Q
2
U
0
z
a
w
Y
a
z
U.
O
U)
O
a
U
O
J

EPA I.D. NUMBER (copyfrom Item 1 of Form 1) Form Approved.
Please print or type in the unshaded areas only. 110000559609 OMB No'
oApproval.exxpiresoires086.
3-31-98.
FOFORMU.S. ENVIRONMENTAL PROTECTION AGENCY
2APPLIC EPA FOR PERMIT TO DISCHARGE WASTEWATER
EXISTING MANUFACTURING,vCOMMERCIAL, MINING AND SILVICULTURE OPERATIONS
NPDES Consolidated Permits Program
I. OUTFALL LOCATION
For each outfall, list the latitude and longitude of its location to the nearest 15 seconds and the name of the receiving water.
A. OUTFALL NUMBER
(list)
B. LATITUDE C. LONGITUDE
D. RECEIVING WATER (name)
1. DEG.
2. MIN.
3. SEC. 1. DEG.
2. MIN.
3. SEC.
001
34.00
50.00
22.94 -78.00
50.00
11.66
CAPE FEAR RIVER
002 (CURRENT)
34.00
50.00
19.64 -78.00
50.00
11.52
CAPE FEAR RIVER
002 (FUTURE)
34.00
50.00
17.72 -78.00
49.00
47.40
CAPE FEAR RIVER
II. FLOWS, SOURCES OF POLLUTION, AND TREATMENT TECHNOLOGIES
A. Attach a line drawing showing the water flow through the facility. Indicate sources of intake water, operations contributing wastewater to the effluent, and treatment units
labeled to correspond to the more detailed descriptions in Item B. Construct a water balance on the line drawing by showing average flows between intakes, operations,
treatment units, and outfalls. If a water balance cannot be determined (e.g., for certain mining activities), provide a pictorial description of the nature and amount of any
sources of water and any collection or treatment measures.
B. For each outfall, provide a description of: (1) All operations contributing wastewater to the effluent, including process wastewater, sanitary wastewater, cooling water,
and storm water runoff; (2) The average flow contributed by each operation; and (3) The treatment received by the wastewater. Continue on additional sheets if
necessary.
1. OUT-
2. OPERATION(S) CONTRIBUTING FLOW 3. TREATMENT
FALL
NO. (list)
b. AVERAGE FLOW b. LIST CODES FROM
a. OPERATION (list) (include units) a. DESCRIPTION TABLE 2C-1
002
OUTFALL 001 908,000 GAL/DAY DISCHARGE TO SURFACE WATER (CAPE FEAR RIVER) 4-A
NON -CONTACT RAW RIVER WATER
17,249,000 GAL/DAY
NON -CONTACT FILTERED WATER
2,521,500 GAL/DAY
STORMWATER
186,000 GAL/DAY
TOTAL EFFLUENT THROUGH OUTFALL 002 20,864,500 GAL/DAY BIOLOGICAL WASTEWATER TREATMENT PLANT
1-O
- INFLUENT SUMP
1-0
- EQUALIZATION WITH MIXING AND AERATION
1-0 3-E
- EMERGENCY RETENTION TANK
1-0
0013-E
BUTACITE(r) MANUFACTURING AREA 682,500 GAL/DAY - PRE -DIGESTER TANK
NAFION(r) MANUFACTURING AREA - ACTIVATED SLUDGE TANK
90,000 GAL/DAY 3-A
SENTRYGLAS(r) MANUFACTURING AREA 0 GAL/DAY - CLARIFICATION (3 CLARIFIERS IN PARALLEL)
1-U
PVF -1 MANUFACTURING AREA
65,000 GAL/DAY
001
PVF -2 MANUFACTURING AREA 65,000 GAL/DAY
NEUTRALIZED REGENERATE BIOLOGICAL SOLIDS SEPARATION
75,000 GAL/DAY 1-U
SANITARY SEWER
8,000 GAL/DAY
CONTACT STORMWATER
46,500 GAL/DAY
001
TOTAL INFLUENT TO WWTP 1,032,000 GAL/DAY
OFFICIAL USE ONLY (effluent guidelines sub -categories)
EPA Form 3510-2C (8-90) PAGE 1 of 4 CONTINUE ON REVERSE

r`r)KITINI ipn PPOK/1 TNF FRr1NT
C. Except for storm runoff, leaks, or spills, are any of the discharges described in Items II -A or B intermittent or seasonal?
❑ YES (complete thefollowing table) 0 NO (go to Section III)
3. FREQUENCY
4. FLOW
1. OUTFALL
NUMBER (list)
2. OPERATION(s)
CONTRIBUTING FLOW
(list)
a. DAYS PER
WEEK
(speck
ve
arage)
b. MONTHS
PER YEAR
(sP-ify erage)
a. FLOW RATE (in mgd)
B. TOTAL VOLUME
(sped with units)
C. DURATION
(in days)
1. LONGTERM
AVERAGE
2. MAXIMUM
DAILY
1. LONGTERM
AVERAGE
2. MAXIMUM
DAILY
III. PRODUCTION
A. Does an effluent guideline limitation promulgated by EPA under Section 304 of the Clean Water Act apply to your facility?
W1 YES (complete Item III -B) ❑ NO (go to Section IP)
B. Are the limitations in the applicable effluent guideline expressed in terms of production (or other measure of operation)?
❑ YES (complete Item III -C) W] NO (go to Section IT7
C. If you answered "yes" to Item III -B, list the quantity which represents an actual measurement of your level of production, expressed in the terms and units used in the
applicable effluent guideline, and indicate the affected outfalls.
1. AVERAGE DAILY PRODUCTION
2. AFFECTED OUTFALLS
(list outfall numbers)
a. QUANTITY PER DAY
b. UNITS OF MEASURE
c. OPERATION, PRODUCT, MATERIAL, ETC.
(spec)
IV. IMPROVEMENTS
A. Are you now required by any Federal, State or local authority to meet any implementation schedule for the construction, upgrading or operations of wastewater
treatment equipment or practices or any other environmental programs which may affect the discharges described in this application? This includes, but is not limited to,
permit conditions, administrative or enforcement orders, enforcement compliance schedule letters, stipulations, court orders, and grant or loan conditions.
❑ YES (complete thefollowing table) NO (go to Item IV -B)
1. IDENTIFICATION OF CONDITION,
AGREEMENT, ETC.
2. AFFECTED OUTFALLS
3. BRIEF DESCRIPTION OF PROJECT
4. FINAL COMPLIANCE DATE
a. NO.
b. SOURCE OF DISCHARGE
a. REQUIRED
b. PROJECTED
B. OPTIONAL: You may attach additional sheets describing any additional water pollution control programs (or other environmental projects which may affect your
discharges) you now have underway or which you plan. Indicate whether each program is now underway or planned, and indicate your actual or planned schedules for
construction.
® MARK "X" IF DESCRIPTION OF ADDITIONAL CONTROL PROGRAMS IS ATTACHED
EPA Form 3510-2C (8-90) PAGE 2 of 4 CONTINUE ON PAGE 3

t
EPA I.D. NUMBER (copyfrom Item 1 of Form 1)
CONTINUED FROM PAGE 2 1 110000559609
EPA Form 3510-2C (8-90) PAGE 3 of 4 CONTINUE ON REVERSE
V. INTAKE AND EFFLUENT CHARACTERISTICS
A, B, & C: See instructions before proceeding —Complete one set of tables for each outfall —Annotate the outfall number in the space provided.
NOTE: Tables V-A, V -B, and V -C are included on separate sheets numbered V-1 through V-9.
D. Use the space below to list any of the pollutants listed in Table 2c-3 of the instructions, which you know or have reason to believe is discharged or may be discharged
from any outfall. For every pollutant you list, briefly describe the reasons you believe it to be present and report any analytical data in your possession.
1. POLLUTANT
2. SOURCE
1. POLLUTANT
2. SOURCE
NONE OF THE POLLUTANTS LISTED
IN TABLE 2C-3 ARE BELIEVED TO
BE PRESENT IN THE WASTEWATER
DISCHARGE FROM THE SITE.
VI. POTENTIAL DISCHARGES NOT COVERED
BY ANALYSIS
or a component of a substance which you
currently use or manufacture as an intermediate
or final product or byproduct?
Is any pollutant listed in Item V -C a substance
W1 YES (list all such pollutants
below ) ❑
NO (go to Item VbB)
APPLICABLE GUIDELINES REQUIRE TESTING OF ALL ITEM V -C COMPOUNDS IDENTIFYING ANY POTENTIAL DISCHARGES.
EPA Form 3510-2C (8-90) PAGE 3 of 4 CONTINUE ON REVERSE

CONTINUED FROM THE FRONT
EPA Form 3510-2C (8-90) PAGE 4 of 4
VII. BIOLOGICAL TOXICITY TESTING DATA
Do you have any knowledge or reason to believe that any biological test for acute or chronic toxicity has been made on any of your discharges or on a receiving water in
relation to your discharge within the last 3 years?
© YES (idents the test(s) and describe their purposes below) ❑ NO (go to Section VIII
THE NORTH CAROLINA "CERIODAPHNIA DUBIA" CHRONIC PASS/FAIL REPRODUCTION AND MORTALITY TEST HAS BEEN PERFORMED
EACH QUARTER IN ACCORDANCE WITH THE NPDES PERMIT REQUIREMENTS. NO TOXICITY TEST FAILURES OCCURRED DURING THE
LAST THREE YEARS OF TESTING THE FINAL DISCHARGE. NCDENR DIVISION OF WATER QUALITY HAS COPIES OF THE TEST
RESULTS THAT WERE SUBMITTED WITH THE DISCHARGE MONITORING REPORTS DURING THE PERIOD FROM 2008 TO 2010.
VIII. CONTRACT ANALYSIS INFORMATION
Were any of the analyses reported in Item V performed by a contract laboratory or consulting firm?
® YES (list the name, address, and telephone number of, and pollutants analyzed by, ❑ NO (go to Section IX)
each such laboratory or firm below)
A. NAME
B.ADDRESS
C. TELEPHONE
D. POLLUTANTS ANALYZED
(area code & no.)
(list)
TBL
2401 WEST STH STREET
910-738-6190
BOD5, TSS, OIL & GREASELUMBERTON,
NC 28358-6261
PRIORITY POLLUTANTS., CO;,D
FLUORIDE, TOTAL PHOSPHORUS,
TOTAL NITROGEN
TEST AMERICA
4955 YARROW STREET
303-736-0100
PFOA
ARVADA, CO 80002
MERITECH INC.
642 TAMCO ROAD
336-342-4748
CHRONIC TOXICITY
REIDSVILLE, NC 27320-8690
IX. 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.
A. NAME & OFFICIAL TITLE (type orprint)
B. PHONE NO. (area code & no.)
ELLIS H. MCGAUGHY PLANT AGER
[phone]
C. SIG TURE
D. DATE SIGNED
%
`
%
2�Z�/
EPA Form 3510-2C (8-90) PAGE 4 of 4

c
O
E
O
L
0
co
a)
O
0
T:
O
N N
�a
E m
= a)
O)
J •.�-
Z a)
OC
U O
of O
Q "0
❑ @
W "vO
❑ c
2CO
U CO
z
W a)
2 E
H @
Z y
w t
}
@
H 3 V)
NZ
O zO
Z.ocU
U)
N d'
W @ In
U) az
J c W
IL o to
w
m
w
w
w
Cr
z
O
w
z
f
Z
O
U
Cl
m
W
U
N
0
LO
Cl)
E
U-
CL a
w
Ow
r�
OW
z
a
z
zZQ
zZi
z
Q
��
QE
Ul
Wo
tUvZq
Oo
Z
Mn
T�
ZQ
Z
lQ❑Ol.
pp
W
Z
WFQ
IvQ-
vWQ
E=
Qa
z
h�
>'Q
?U@
Z
WNZ
zzO
Y=TO
W
O
_jOfE
z
z
z
zoz
z
z
w
LU
w
w
w
w
@TJ
z
c0'
@
O
o
Q'
Q'
Q
U)
<
i o
¢
W
a
FC
z
z
a
Q
cn
@r42
a
a
Iq
Iq
FEm
N
fn Q
��
0
O 3 E~
Z,
z
a
❑
w °-6
wo
as
a
s
a
M
wo
a
a
a
a
y'� o
O~
a
o
0
aL
vca
y.
Z
\
A
Ur
z
Q
a o c
U 2
@
5
z
x
to
(D LL 0
@~
u
L)
~
@
C N
w U
@
N@
0
O U
J
w
U U
}
Ln
Ln
w
L`
H
M
d 0.
U
Z
�-I
rl
rl
rl
rl
O
z a
�O
Ol
r -I
ri
�O
Ql
r -i
Q
ri
�-1
N
rl
C�
�'
> "O
O 0
z
Q
V Z
T tL, co
I11
Q
LO
@ N
N
0
U
C
u C)
O
J
co
a)
o
m
m
U la
°c
U
W
a
0@ N
U
N
0 0
'
Q
>
N
@
wQ
-S
Q
^.
z
°
.0m m
O
¢ Q
l9
N
Ln
E @ _
F-
^�
CO
Q
Z
kD
Ln
h
O=p O
Z
v W
U
O
N
U
0
Z
OU
c
C7
z
Xm0
a)
ci
W
Cl)
°
OJ
`r
N
i
t O
@
F
y
N
z
O
a) ?
Z
W
J
Q
C
°
U
W
W
W
•-O.0
❑
Q
g
N
U
N
U) fl. C
LL
Q ti
Z
>
>
>
o
w
O o
n
j
CL to
ri
o °
z
LL
U
j
Ln
rl
a)
0)D.Fj
Cl)
o
O
EY
N w
W
Q
Q
00
a) O EO
U
1
~
O
N
>
rz
Q
v
W
L? N
~
❑ -o
co
M
N
c 0@
Z
O0.Q
O
O
Cl) O_
Cl) O
b
Z
O
dl
LO
W
N= U
O) N
"O
Q
U
ri
Z'
0 `•�
a
M
O
N
N
N
O
Q >
�v
��
Ln
�N
>
@ (a T
W
0
U1
!O
a)
0
'Z
v
Ol
dl
D
0
L =
`o
J
Q
Q
Ln
a'
Z
a'
Z
r-
W
w o
Z
0
�r
E
'
N
O
ri
N
O T
L)
J
>
J
>
J
>
Z
^2
3- L)
Y j N
J
C @
_ 52 N
Q
❑
Z
0 @
O
wrn
W
L-
W
Ln
r
g
0�
O, ° CL
C�
O
H
0
O
J
Q
N@
0
�_
N
U y
>
�•
N
v
ri
d'
W
O
Xao
Q
�L..
7 O
x
vZ
O
O
O
w
N
H
F- @
U
J
O
O >, O
at N O
Q
W
U
O
rl
N
M
m
p
cq
rl
o
cL) 0 .c
`O_
o
z
w 15
_O
N
M
@ c
U
U w
~
oo
Ln
o
m
°mx
w
U)
2
Q
_�
v W
m
ro
o
H
o
O
O
�Ln
0
@ Q c
N
>w
4)
U
()
W
0
W
0
W
0
T@
c V Q
x
Y
-L m
W Q
@
Z
O
J
J
J
Z
E m
m
j
>
>
>
0_�g
o
jW
X
X
XXX
LL O.
a)
°'.�_.
N
�J W
W
Z
D
�
c
rn
U
°
x �'
W-
O
` Uz C
:3
Q O
J
U�
O Q
@
0�
_
'2 V 6
Q N
F
O
.@.
w >
J
E'Q
t"OE
c@iU
"O
rn
O
=
U
@
c
O
m
-
m
F O.o
Cl Z
rn
v�
�-
-
U
m
a�q'
Z
Q Q
d
d
fl. i
m
J Z
16
?
°
Lb E
L E
U E
i -Q
Q
�
F c
F E
`.3
x
n
IL
2 Loo'
cc)
Ua
°
U
m
W
Li m
Q
a)
o
Q
z�
w
m
w
w
w
Cr
z
O
w
z
f
Z
O
U
Cl
m
W
U
N
0
LO
Cl)
E
U-
CL a
w

/
}
§
§
§
\
LL
§
§
§
§
§
§
§
§
/
{/
k
§
§
/
§
§
§
§
§
E
\\)
�\\_\4
4
4
4
4
4
4
4
<
—z
2
2
a
a
a
2
2
2
a
)
8
\
3
3
S
S
)
S))
j
(
\
§(
k
2
2
2\
2
k
2
)§
2
\\
e
m
a
o
0
0
o
a
o
o
a
a
0
0
o
e
e
o
a
o
c
eZ
§
¥
§
j
\\
<a
ly
(»
�§
_§
0
\
j
\
2§
m
CO
%
§/
¢
LL
LL
E
e
§
.
/
�§
0
#
_§
2
z
a
0
j
/
%
\
®
/
%
%
0
)
§
/
\
%
3
e
§
/
J
g
\
/
z
\
/
=
G
2
/
/
\
/
_§Ln
�{
\
}
G
/
/
G
/
/
0
/
E
ziU
x
x
x
x
x
x
x
x
x
x
x
}
( $
mS
§}
x
x
x
x
x
x
ƒ
Co a -
22k\
#�
(
\
( \
}ƒ\*
\\\/
/
/)�\
\
20
\)\\\
\7)
IL t3
z
)
\�
\7/\(\\�§\
�\
�\
\\
�\
/7\�7\�7§
£\)\\
w
W-
as
=s&
.
E
«
e/
&e
was=�
KJ=
a
ae�
at
et
�t
wt�etseb;eb
k»
xet
/
}
§
§
§
\

❑
L
g
Z
Z
Z
Z
Z
Z
Z
Z
Z
Z
%
Z
Z
Z
Z
M
<0 N 7 Q YO YO .a
4
F('i
di
di
<
�i
Zi
Or
Zi
4r
Z4
Zi
Z<
@ @ G @
¢
w
C @
Eyo�yEO
Z0WW
p N@
L6
0
z IL
QO
K
c L n °�
w^
F
�Z
FC
Q
Q
Z
Q
Z
Q
Z
Q
Z
FC
Z
Z
Q
Z
Q
Z
Z
i E o@
Xw?o3 hyo
@>
a
cwi
Z
Z
Z
Z
z
Z
Y 3 O= w y N
O
1 15
u1 @ p0 N E W
E
U
3 T>> n
w7 w N O^
w
y T w T
N
Q
(Yl
W
W
W
P9
a1
W
Pel
PQ
m
PO
a
m
a
FA
a
m
a
PQ
a
L
a
a
a
a
a
a
a
a
a
a
a
oN"
Na�OEa
C N a'� 7 w
F
Z
E �.n@o-o
�
ZZ
oyN�a�o
T p) •U)
�o
a
\
a
\
a
\
a
\
a
\
a
\
a
\
a
\
a
\
a
\
a
\
a
\
a
\
a
\
a
\
H p E
E
z
O
U
L7
i7
c7
i7
L7
L7
L7
L7
C7
C7
L7
C7
C7
L7
o m N
@
p` T O
Lco
_LU
@ - U
�O
a T@ GL T
O(Lll
U O c O
J.
0_ '
ZZ
D Q
- N
(0U
N
N
O N L @ U
U C@ O @
LEoygO-
C7
Q
N
U U I L O d
@ O
Q O
E@ c L N v@
W
O
-
N 0F
n
C7
ga
p. oa _L
U O
�
ZJ
O y COi
c a@
�>
-Z
N d
C L @
U
0O
y Er
U
C Tp O
@ N
N
J
(n
N@ c C Q m
W
Q
Q
c T N O y p r
Nw- o.OEy
J}
LLL
Q�
N
N d O O @
N.N N
w❑
b
co ..,,
Z
U c dCS
vi
O
o N O N p yxx
"wU
W
O c U U
Q
H
E @z
8,6
W
:2
_ m O c Z
.0
O
U
.@. w y Y N N 1W
O
h
L�
Ln
N
N
N
ri
L-
u)
h
h
O
@@> m e °)
❑
MIn
M
O
H
N
O
m
M
H
M
M
M
fh
z
G L E E-
J
Q
O
O
O
O
O
O
O
O
O
O
Ln
O
m T o 08 N 0
>
O
O
O
O
O
O
O
O
O
O
O
V
U)
3° 3wY pv
V
V
v
V
V
V
V
V
V
J
D
U m'Y E Tn
❑
O
W
E 0 7 7 w
H
W
Ln
H
N
L�
l�
M
O
N
Ln
N
Ln
N
m
L'
O- U T- T b
❑
O
O
O
O
O
O
O
O
H
O
O
O
r
O
O
W
N
Q
O
O
O
O
O
mX
Xv_
U
O
O
O
OO
O
O
O
O
O
O
O
O
O
O
O
Q `p
V
V
V
V
V
V
V
V
V
In
w
U Q N O@
y
@
O
O
❑
N =
@ Uol
O C
N CN@
11
> Z
N O Q
'oO>bw
O W U
J
WQ
+L+NL
D A N c @@ y
m p
m
(Q
J
O
of
OLS E
c
?<
Z
oomo00
aWW
=
"O T U w @ O@@
@
LU a•
J
E o E cY ��
.�
N
ma
Q
❑
@ F-
TX y U 0@@
E @ Y N O
F
L L N
d
Z
/ \
I ♦
I \
I \
/ \
/ \
I \
I \
I \
I
I \
/ \
/ \
' `
I �
@= o p 3 �v
N
LLIw
Q
U U .O U>�
Z w
z
F
O
FO
M
O
O
N
N
O
W
N
d cO
T @@ N O' V
= nv an` @
Q m
F a
Q
}
U
r
E
E
r
�q
F
.@.
°
F-
Z'^cN'c
O
-
Ern
3q
F-
E N
O
NU,
��
N
'00
❑ ❑
J Z � 'Q
I
V%
E O
ci^
'C N
!�
_
'� 01
EO
na0
O
r^
r
N
, (O
N O.
N a0
> N
c6
CLO
@
T
c
N
cco
U1
U
J Q Z
t0
N a0
M
.�
I-
m
Y N
Zo
1�
Ov
Uo
L
~�
No
U?
L
Q_
X
F-
ro
d Q
tQ-
Qo
V
Qo
-T
mo
V
Uo
,
Uv
N
Uo
d'
M
M
d'
� f0
� V
V
O
o c
ti O X
Q.
L
r O
W
V
�v
V
�v
N
d'
�v
M
V
�v
V
O
u7 F-
V
t0 ^
V
fir,
n
V
`Lv
eD
7
O v
O O
F
d'
r v
N O
r i'-
P2
d' O
r f'-'
N O
r
❑
N 0❑

W
Q
0.
Z
O
W
Z
Z
LL U)
w
J
di
4z
4z
4zz
4z
4zz
4zz
1
4z
�i
Iz
�zz
i
1
z
4zz
1
Z4
ZQ
z
z
z
z
z
z
z
%
z
z
Z
Q
a
o
U
iy
¢�i
m
Qi
z
z
FI'i
z
Qi
z
di
Z
Qi
z
z
z
z
z
z
z
z
z
I
z
Z4
z
Y�w
z
z
z
z
W
H
z
ow
O
L6
U
09
cd
W �
z
z
FCFC
z
z
z
z
FC
z
z
FC
z
FC
z
FC
z
z
FC
z
z
z
z
FC
z
z
FC
z
U
z
O
U
Q
W
W
W
W
W
fY1
PO
W
P 1
0.l
W
W
PO
0.l
fA
W
W
pq
0.l
U
a
z
m
zz
wo
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
z�
X
°�
Cd
c�
x
�
x
X
x
LLU)
Ow
U)
}
°zQ
ri
ri
ri
ri
ri
ri
r-1
rl
ri
ri
H
H
r -I
r -I
14
r -I
r -I
H
.z
Q
U)
.II
z
WCD
O
f -
Z
J
Q Q
vW
�>
U
U
Q
U
W
U
Q
D
LL
W
W
p p
o
C'i
cam') Gf
O
v
x�
Q
—Z
U
z0
�
U
w
r
r
r -I
ri
ri
ri
r -I
r
r
r
ri
r
r-1
ri
r-1
r -I
H
O
'A
r
W
J
Q
M
O
C
%
O
O
O
O
M
O
O
O
O
O
O
O
O
O
O
O
-k
O
O
O
O
OV
O
Ov
O
o
O
o
o
O
V
O
OV
}
J
N,
v
V
V
V
V
v
V
V
V
V
V
V
V
v
0
z
O
F-
0
1O
H
H
ri
ri
In
NO
Lf)
r -i
In
ri
H
ri
ri
r -I
0
r -I
Ln
NO
Ln
o
o
O
o
0
O
0
o
0
0
0
0
O
0
O
o
0
O
0
o
0
O
0
o
0
0
0
0
0
0
0
0
�U
o
o
-N
o
O
o
0
0
0
0
0
0
0
0
0
0
0
0
0
gz
v
v
v
v
v
v
v
v
v
v
v
v
v
v
v
v
v
v
o
C6
of
>z
U
U)
J m
W <
Z
iC
o
O
Y
z
>w
0.
��w
O
wua
U
w
N
J
°PWU0XXXXX
XXXX
XX
X
XXXXX
x
W
I
Z
Z w
W
U
F-
U
N
c
N
N
N
N
i
N
C
O
O M
O N
OO
O�
ON
Obi
r
O
O
c
N
m
M
M
N
Fm. a
J Z
C
N �..�
y
c
N
C
,r0
.S •--•
p
O
N
='�
`p
O^
, C
l6
O L
L
O
O L
O W
O
O C
l0
O L
O l0
L
O N
L c
U M
O
L O
U r
O O
L C i
U l0
D C
70 0 D
0()S
L
U
C
O
L
W
V
y C
N
V
y C
CS
z Q
LL
U
O OD
UN
O r
Z'C;
O
G N
.0
U
W aD
O
In
i
_00
N
_O EaD
O M
L W
U C
O
LM
E N^
U d'
L
_ v
r
N
N N
N (O
M C
T V
L
N N
N N
UQ
O_ U
Q`,
U O
Qr
U
Qr
N C;
O]�'
N '� a0
CCI ygN
ON
m
.0
O U M
U 10N
L
U�
L O
U E V
L O
UO
N '� r
U co
(O
Or-
�N
OIC
m
'co
N
{ @
j.
d
>. I�
O.N
W
O
O
1 U
U
O
O
>
> V
>
co
i N
O
�
O N
i
>
TO'
> L
O
1.
> O LO
N
>>
M
T
7
m L
10
(O L
> O>
W O d'
O O
> O
O
> _
L
1
CD
N—
MC
V FS
m
(OHS
F,
cob Z,.
0)
r 0)
r�
rdC
r'OC
.- N
r N
r N
er- Q.
r O.-
r
NCO
NU
W
Q
0.
Z
O
W
Z
Z

w
U)
w
w
z
O
W
0
Z_
I -
Z
O
U
LL N
Ow
°4
z
z
z
z
z
z
z
z
z
z
z
z
z
z
z
z
z
z
z
z
z
zQ
-6Z
o
o
wFC
N
FC
FC
FC
FC
FC
FC
Z
FC
Z
FC
Z
FC
Z
FC
Z
FC
Z
FC
Z
FC
Z
FC
Z
FC
Z
Z
Z
w
J
N
Z
Z
Z
Z
Z
Z
Z
Z
Z
w Q
F
z
Q
0
to
U
OJ
(6
.-.
W
zyyyy4
�y
�y
y�
4y
Fd
y�
H4
yy
��H
4H
Qi
^H
H4
Qi
H4
f4
yy4
F
Q"
U
Z
U
U
CO
¢
PQ
PQ
PQ
PQ
M
m
of
m
m
PQ
PQ
m
m
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
C
a
z
D
z
v
Uo
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
ZF
6i
Ow
cn
ri
ri
ri
r -I
rl
ri
ri
ri
ri
rf
ri
r -I
r -I
ri
ri
ri
ri
ri
rl
ri
ZJ
Z
U Q
U
Q
�
Q �
v
O
Z
O
?
UJ N
I -
z
J
OJ
U
>
U
O
U
W
rn
Q
w
j
g
LL
}
¢
N
LL
w
p a
vi
m Q
O
v2
X2
4
U
Q
O
U
w
to
O
J
Q
O
O
O
O
O
O
�
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
V
}
J
`✓
V
V
V
V
V
V
V
V
V
V
V
V
V
V
V
V
V
0
Z
O
{-
Ln
H
ri
to
ri
ri
ri
ri
Lo
ri
riH
Hr
-I
ri
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
F-
O
O
O
O
O
O
O
O
O
O
X
Q
`"Z
W
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O0
V
O
V
Z
�9
V
V
V
V
V
V
V
V
V
O
s
U
SE
U
> z
UW
Ci
m
W<
0
z
x
O
0
oI
Y
>w
d
<
��w
O
O
ma
°
CL
g
N
LU
J
O
X
XX
X
XXX
X
X
XXXXXXXXXxX
K
I
ZO
I
O_
F-
Z
cr-u
d
o
o
o
_
o
N
ED
ON
tdLNn
LVO
O}i
W
R
Q
OL
W
E
I(VNQ`O
Q
LL
C'LLL
M
>
H
N N
rC
0,0
C=
o
O
U
d
oo
W
up
vJ
I�
L
YW
NZ
Nn
LLcL
cUOapLnOer
O U
')
�
Op
O
'�NF
F -
O
OO
VQ
V
7p¢
U
>>;
O
O
C
} L
> 6 L6
� N
(V
11
r
Cbo
N
N U
M dN r
_ O S
N
N
N NM
7
r
Q
7
omp
I
OU
---
w
U)
w
w
z
O
W
0
Z_
I -
Z
O
U

h
z
O
Of
LL
w
2
H
O
w
IL
w
D
Z
P
Z
O
U
w
a
z
O
W
D
z
z
z
O
U
0
C6
U
N
O_
LO
n
E
O
1
L
W Cl)
Ow
z
z
z
Z
Z
z
z
Z
Z
Z
Z
Z
z
z
z
z
z
z
z
z
z
z°a
�z
o
o
wZ
U
Z
Z
Z
Z
Z
Z
Z
Z
Z
Z
Z
Z
Z
z
z
z
z
z
z
z
w
J
N
W*—
H
z
U' w
o
ui
C7
OLU
@a
-W
zzzz
FC
FC
FC
zz
FC
z
z
FC
z
z
FC
z
FC
z
FC
z
FC
zz
Z
ZZ
Z4
4z
U
z
O
U
cn
U)
m
m
m
as
m
w
as
m
as
as
as
as
ao
m
m
as
m
m
as
z
n
z z
v
w
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
F -
Cd
,cn
Ow
U)
Q >-
z Z Q
Z
Q
N
Q Q
N
� Q
W :ti
z
0
F v
W
F
Z9^H
OJ
�z
>
U
U
o
U
F
W
O
LL
i¢ ti
N
..,
❑ .a
W
O
z
M
M o
0
v
%�
�2
4
U
O
-Q
U
w
co ri
H
H
h
Hri
H
H
1
r
r-
L�
to
t
ri
r -I
H
r-4
1-1
H
rI
J
O
O
O
O
O
O
O
O
O
O
O
O
ri
O
O
O
O
O
O
O
O
>
�
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
}
J
N
V
V
V
V
V
V
V
V
V
V
V
V
O
V
y
V
V
V
V
V
V
z
Q
O
r -I
ri
ri
0
ri
r -I
rl
ri
rl
N
r -IO
H
`-I
H
r-1
Hr
-1
Hp
2
^H
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
N
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
v
a
vV
O
O
O
O
O
O
O
O
O
O
O
p
O
O
O
O
O
O
O.
z
V
V
V
v
V
V
V
V
V
O
V
V
V
V
V
V
V
O
m
U
ON
w
❑
Z
oJ1
O
ED
SC
❑ F
O
U
Y
of
>w
.6!!! U
¢
wof
D
ma
N
¢
Xxxx
xx
xx
x
x
x
x
xx
x
xx
xxx
wa
m
FW
Q w ,�?
m
(~J
N
�'
N
C
N
O
.-. N
o C
•C.20
O
�-..-
s?• .zg
O.
C�
W
N
v
O Op
O
L
,.p
❑ Q
.tO.
L
a
L
a_
N
O
C
.Qr
.Q.M
N N
c
.S
�OJ
.y^..0
c
UL
U
p�
4V N
m
O
E
Nm
m�
O
O C
C
O
N
L N
�v
U
_ v
Jz❑'��(0
J Q Z?
C^
N
C�
r
wN
"O
N
OC^OO
N N
Nv
NC
mLN
0"00
N U
Ny W
N�
N .L+ V
.ry...
p0
N42
LIQ
N
Qw
W M
m
w d
LC
N
U Nn
.CLMy
N
Uo.^
Z'W
CG
N N
1]
❑m
N N
❑v
pj N
C1
O :n
CL Q`
m
Nm
U N
QM
0)
U p�
Q
c
Q p'
C�
N I�
m oD
C UM
N {n
mt1O
c
N N
m
V C
C (�
c C
N O
m
c Com'
N O
m
m �
�{•
d',
m W v
^
C0 0"
s.
m �' 00
'V' >.11�
C
0
m N
N ..'C+ aD
7 �'�
t
U O
UM
❑ O
C
N
C
N
ed
ON
D6
'd,
'd,
Lo m Q�
(mO LL
m�N
W 0_
0
mLLLN
`N�
m m�.r..
m U W
m :i
md.O
mQ.
C�
m d0
W N
W QLo
0Nd
N9
w
a
z
O
W
D
z
z
z
O
U
0
C6
U
N
O_
LO
n
E
O
1
L

w
U)
w
w
w
w
z
O
w
Z_
H
Z
O
U
0
rn
00
U
N
_O
M
O
LL
wW
LL Cn
ow
°�]
z
z
z
z
z
z
z
z
z
z
z
z
z
z
z
z
z
z
z
z
z
z¢
�Z
a
a
Q
o
U)
FC
FC
FC
FC
FC
FC
FC
Z
z
FC
z
FC
Z
FC
z
FC
Z
FC
Z
FC
z
F
Z
FC
Z
4z
Z
4z
Z
Z4
z
W
w
JC
N
z
z
Z
z
z
z
z
Z
w Q
H
Z
C7 W
z
ui
OC7
w
C6Q�W
^F-
4z
z
9z
z
4z
z
4z
z
'
z
4z
z
9z
z
FC
z
FC
Z
4z
z
Z4
z
FC
z
9z
z
4z
z
4z
z
Z4
z
z
z
z
z
U
Z
O
U
U7
Q
W
PO
W
P9
W
W
W
W
W
fA
al
PO
PQ
CA
rQ
Cl
Pa
W
Cl
f-0
CQ
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
F
z
z z
v
w
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
LL U)
OW
U)
ri
H
`-I
ri
rl
r�
Hr
-I
r -I
rl
r -I
rl
ri
rI
ri
ri
ri
r-4
r -I
ri
ri
Z>1
a
oZ
a
as
'Q
W Q
Z
0
Fh
W
OJ
i
U
O
U
H
W
N
w
Q
IJLLL
D
W
p
M
MO
Q
U
ZO
�
U
w
W
rl
ri
H
rl
h
L-
J
Q
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
j
N
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
}
J
v
V
V
v
v
V
v
v
v
V
v
v
V
v
V
v
v
v
v
V
0
Z
O
F-
ri
rl
ri
O
rl
O
ri
O
ri
O
r -I
O
ri
O
ri
ri
O
to
O
ri
ri
rl
D^
m
O
O
O
O
o
0
o
O
O
O
O
O
O
O
0
O
O
O
`z
W
s
O
o
o
o
O
O
o
o
o
O
v
O
v
o
v
o
v
Ov
O
v
o
V
O
v
C)
o
v
V
v
v
v
v
O
�
U
wz
Z
Ww
Uwmn.
0
m<
0O
X
o t-
U
w 2
a W W
QJ
R
ma
D
W
N
w
Op
Z
co
`J�/
X
X
X
X
`J�/
\J(/
`J�,
`J�/
I \
`J(,
/ `
`J�/
/ `
X
I \
\J�,
/ \
X
/ \
\J�,
/ \
`J�/
/ \
X
/ \
\J�,
/ \
X
/ \
`J�,
I \
X
/
w O
pap
/ \
/ \
/ \
/ \
/ \
/ \
/ \
/ `
�K
I
F-
Q (�
O
F
1
O
V
-
V
N
(O
N
_ V
IV
N
O
_ W
O r
C N
N
N
�
O 7
r
M
O W
O
O N
O r
C
N
N
C
O
N
N
N
C
"O
m .-;
O
U
O
UO
O W
U�
(O
1E,"'
i0 4
C
O N
C(O
.L'�
U
N Q N
L y
Ll W
.t-.
O
O W
U�
O I�
U�
O C
N
U'0
O N
Lei
d
Oa
O
O
N
w
N
C
)_
N
O N
0.9
J Z
a Z
LL
CJS
O N
�,W
L
N r
w
N M
E r
p] W
Z i
CJS
C] O
Oa-
`�
Z d
O `�
N .-.
N
lC`0
O O
O
R v
X
N
X O
t6 "0
X
U n
N (v
C
N In
L
L
O
+-� L
— N
I�
O O
Q. in SN
Cn
rG
V a)
O
co C
M :O
ro
O
O
()
_ O
C] @
V
N C
(O
N C
_ O
C)
C
` N
3 �'
LL V
O 1
LL
N
S N
N
Z a
N V
= 0 7
= C
C d)
M C'
N
N
Z N
Z�
Z M1
Q V'
Z o (p
C
m C
m�
06:5 M
D]L+
m J
m j
p]'=
M- O C
MCC
Mb
m C
Ed
CD Ur
M
CD
(0:5
CD N'6Mi
M��
'D
coC
m
mom'
mvN
m�
mD, N
7
U
N d
N.00
ND.
N 0_�
N f1
N
N
C,
M L -UO
M�
M
M.O
M L
UC
c0]�
V
Z
w
U)
w
w
w
w
z
O
w
Z_
H
Z
O
U
0
rn
00
U
N
_O
M
O
LL
wW

O
00
U
N
0
M
O
LL
CL
W
LL U)
Ow
z
z
z
z
z
z
z
z
z
z
z
z
z
z
z
z
z
z
Z
z
ZQ
a
�Z
a
�
o
oW
Z
Z
Z
Z
Z
Z
Z
Z
Z
Z
Z
Z
Z
Z
Z
Z
Z
Z
Z
Z
W
J
N
w Q
F<-
H
(D w
o
L6
c�
ow
FC
FC
FC
FC
FC
FC
FC
rC
rG
rG
rG
FC
FC
FC
FC
CdQ
�Z
z
z
z
z
z
z
z
z
z
z
z
z
z
z
z
z
z
z
z
z
U
O
UZ
U)
Q
PO
W
W
W
W
0.l
0.l
W
Cq
W
fA
W
W
P7
PA
P 1
W
W
W
W
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
U
F
z
z
4
w0
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
(n
°F-
co
LL U)
Ow
U)
O J
ri
ri
ri
ri
ri
ri
ri
rl
ri
ri
ri
r -I
r -I
ri
rl
ri
—1
r -I
r-1
ri
ZQ
v Z
Q
N
Q
Q �
N
O
Z
W 1
O
H
(D W
z
J
OJ
�. Z
>
U
U
Z
0
W
co
w
j
Q
LL
Q
<
LL
W
❑ p
M
MO
F
Fjn
Q
U
.O
O
U
w
cn
L�
ri
ri
h
d�
V�
J
Q
O
O
O
O
I
W
1
W
I
W
I
W
I
W
O
1
W
I
W
I
W
I
W
I
W
I
W
I
W
I
W
I
W
1
W
N
O
O
O
O
[M
ct+
d'
'T
d'
O
cr
cM
d'
V
d'
dl
}
J
V
VV
V
V
V
V
V
V
V
V
V
V
V
V
V
V
V
V
V
Z
O
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
ra
O
Hri
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
v
—W
s
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
a
Z
o
V
O
V
O
V
V
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
v
V
V
V
V
V
V
V
V
V
V
V
V
V
V
V
U
Z
wZ
aww=O
5U
MCL
mQ
m
iC
O
U
O
Y
j w
-1
K
oww
ma
w
w
N
Q
XXX
XXX
X❑XXX`J�/X\J�/XXXXXX
,
\
/ \
/
\
/ `
XX
XX
W Ci
W
Co
/ `
I \
/ ♦
/ \
/ \
/ \
/ `
/ \
/ \
/ `
/
♦
I
/ \
I
I `
I
N�
I
Z
p
Z
O
!
m
Q W
M
t3
F-
Q
E
s
t
m
~
F"
W
❑
c
w
w
o
w
v
I
J Z O
LL
O >.
C
C
F m
N
? C
LL
CN
U
U
U�
U
m
❑
�M
❑
Cm
❑
❑'
-p
cc
r
n
y
O
C
C q
J QZ
p
N
Z Cl.
N W
d0
n.0
N N
pW
U)
�O
=c0
m W
=I�
1 W
2
mW
S°P
mi W
O�
Z
�O�
��
W
t4
N�
❑I�
W
6Q
W
O.N
C Q
W �
C
W O
C "O M
WLR
NCD
x4
i
n• Qh
ZLO
cs
dM
m
LL
O
m`
r
0'
2
�_
U
Q�
23 W
C 6
T
rq�
V
Uri
d' N
Gln
"t
V)
o�
47
�{
wM
m
N
vv
N N
Ov
I
U
U
(7
oco
7 to
min
V
V ....
and
cl' U ....
dM
av
N
av
M
a�
v �-'
av
�n
d�
co
a�
r
d�
o� .J
a�
rn
c2�
��
U)
v�-i
caov
O
00
U
N
0
M
O
LL
CL
W

W
w
Q
CL
2
w
LL
cl
W
D
z
z
O
U
0
U
0
E
lL
a
w
LLU)
Ow
d 1
z
z
z
z
z
z
z
z
z
za
c
aZ
a
w
co
CD
z
z
z
z
z
z
z
z
z
o
o
W
J
N
W a
H
z
z
C7w
tri
�LD
0 c4
�
(6Q
F-
W
z
z
z
z
z
z
z
z
z
U
Z
O
U
a
Pq
m
W
P9
m
PQ
PQ
W
W
a
a
a
a
a
a
a
a
s
F
F-
2-1
z
U0
a
a
a
a
a
a
a
a
a
z�
U- C/)
Ow
U)
O J
H
ri
r -I
r -I
rl
1-1
H
H
z Q
z
a
N
2
> �Q
a O
N
Z
O
of Es
W
W
ZJ
OLu
-Z
>
U
U
Q
U
W
O
N
H
w
j
Q�
LLL
}a ti
N
v
W
W
ri
M
O
o
-Z
w
o
.0
U
W
Co
cr
d�
d�
di
I
Q
co
<
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
>
}
NO
V
O
O
O
O
O
O
O
J
V
V
V
V
V
V
V
V
z
O
_O
~
Lf)
OO
In
Ln
u,
In
In
In
Ln
Ln
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
Y
�z
O
a
(wj
OV
O
O
O
O
O
O
O
O
ZO
V
V
V
V
V
V
V
V
@
U
O H
w
>w
�wI
J m
W
ca Q
d
X
S
e
e
off
Y
<
W
>w
aww
v
ma
U
N
w
U
w
mw=zo'
F
a
W
XxXXXXXXX
F°
,
I
z
F
O
QWN
`O
N
7
N
m
OCo
c0
C
Q Q9
IILL..LLLL
U
y
-It
04 --
LO
rN- -
� N
r2 In
� (O
N
O N
L
O_'�
JQ= O
z?
W
U)
M
N N j
mN
L)
mm
U I
[O�
U N
m�
U
mrn
U N
CON
U W
m�
U
fON
O M
O NVQ
EL
g=�
4
W co
o m
Q- 0
0
o
a m
v'
O r
F-r
a:o
aM
a�
a�
N
a�
aN
N
a�
N
aN
N`-'
ao
N00,
C7
��-W z-.�
N.r..
0
U
0
E
lL
a
w

c
O
0
N
r
m
O
E
In
r
N N
N
E mp_
7 �
O)
J'.c-.,
Z a)
OE
Qo
U
of O
Q a
0 m
wN
C c
2 • �'
m
z E
O —O
W N
2 �
ID
t- m
Zy
W
}a. m
(n
Z
O ZO
z�O
N �
af
w `� ai
U) o. Z
w0W
J c W
CL o cn
a
rn
U
N
O
LO
M
0
LL
IL
W
LLU)�
a)
LL
OW
ow
°zQ
z
z
z
z
z
z
z
z
-0 Q
°z¢
z
z
z
z
z
�.
�Q
E�
aQ
^
O o
y
Q
Z
co
9z
T
O
W
(7
Q
U)
9z
9z
W
Zi
Zi
Zi
Zi
3 cV
R'
N
Zi
Zi
Zi
F¢..
?
16
W
¢
¢w
v
o
W¢
E
>>
O
v"
�->
Ur W
�i
�i
o. v
Z
27)
w J
z
O
Z
ZQ
O
z
Z
Z
Lfi
Om
Z
Z
Z
¢
�z
Z
Z
Z
Zi
Z
o o
�
"0
z
z
W
W
W
W
m T
J
z
z
c 0
m
O
O
Q
>
Q
>
Q
>
co
0 3
Q
PO
W
W
W
Wm
42
1-1
a
a
a
a
a
z
z
E a
a
F
z^
U
v=
po
=
aQ
D
z
wo
a
a
s
o=U
ci
Z
Lp
U)
~
ao
b c
\
£
£
�cu
�
£
£
to
(D LL y
m~
U
m
C N
v
y0
a)
>>m
W w
Ow
0cn
kD
m ao
O�
rt
ri
t
Ln
0
CO)
z J
rN-1
�
.-�
ri
p
m
r
O 0
Z
p
Z
rl
.�-�
s
T.. m
a
Q
U
z
O O
i
:3
L!1
C
! o
0--
�
J
Q
Q
U)
L\
d
O' C`
2
>
g
M
CO
W
Q
O
LO
U m
'
N
O
m m
m
Q
N
V
N
O N
w
> O
Q
O
O
>
_
L y
Q
U
Uca ^
04.2 a)
Q
H
m
Q�
rr
r
w
Em_
w
a
O
N
a)
_
0 0
°oyo
ZO
v W
wh
�¢
i
c L
OZ
m
a)
U
z
o
Ln
j� aNi m
v
O
Z
U
N
V
O
N
_ m
Y a)
`m °
U
m
z
O
a)
Z
W
J
m
CIL
U
V
W
w
W
-2
U L
O*
N
N
N
U
Z
>
>
>
C
LL
Wco
Q ti
w
o
CL w
M
W A
2
O
CO) am.
E o.
O
ro
.«�
(j w
LLw
LL
JW
N
Q
ri
O a'
d
N O E
ry w
W
�z
'a) TU
....
^�
c
N
}
N
V
r-
x
Q
.o
O aj C ai
z
W
d'
W
Q ti
61
M
N
m
z
O
L
N
L
O
O
M
a
M Q
O
Z
d�
O
7
O) N
U
N
O
ri
M
y:O
10--i
N
vLU
O Z
L ,.m--. L
J
Q
O O
L)
V
l0
W
O
W
O
W
O
O E ._
Q
>
Zi
Zi
d�
M
l0
W
•�
N
z
J
J
J
Z
3— U
N
Cm
W
U)
T N O-
O
>
U u)
V
r -i
V
OD
7- O
�z
Ln
N
LP
co
(~!J
J
O. N p
2
w
O
L11
m
p
z
O
co
Ln
0)) m
m
O
W
F -ti
O
kD
r -I
M
m a c
a) x m
U
Fs-
`)
Q
zN
w
LnOV
r
Ola
N N
x
a W
_
U w
2
Z
V
LD
N
W
O
W
O
W
O
T
c= O
Y
U)
w m
ai
O
>
>
>
Z_
Em
w
W
�-co
Q
0)
o
L
m
YO
'w
XXXXX
J
W d
N
L
>
N
m w W
LL w
H
>°
m
v
X> w°
w a
w :3ZQ
E
m
U
d
m
r
z
0
E
m
z
o
F
vpQ
00
om
m
Q
m
`m ��
�'v
Q
y
N
V`�
(n h
OO
r
o
j0z
O�
ai
0
°
Z
Q
d
O
N
N^
(D
F-
z
om
Lm
2r
mN
3
E
E £
F
�¢Q
Em
`oma
o
ov
a
m m
U m
2o
f°- o
a
,�
�.s
a¢
°
ca
��
0
LL
LL�
z�
> n
ni O
s O
ci �'
'o co
ai
m
r
._
d
ns
a
ci
v
ai
• :°
a
rn
U
N
O
LO
M
0
LL
IL
W

F -
z
w
LL
2
O
Of
LL
O
w
D
z_
f-•
z
O
U
m
w
w
H
w
cD
a
z
0
w
D
Z
z
Z
0
U
O
W
U
N
O
LO
Cl)
0
LLIL
w
LL U)
Ow
z
z
z
z
z
z
z
z
z¢
cs
flQ
o
U)
U)
2.
z
z
z
z
z
z
z
z
z
w
w
2=
N
w
v
F
>
Z
V w
0
L6
0
z
z
z
z
z
z
z
z
z
Cd
Z
w
U
z
O
U
Q
W
P�1
PA
W
Pa
W
W
al
ai
F
Wz
00
a
a
a
a
a
a
a
a
a
z�
X
m
2:
LLU)
Ow
U)
zJ
M
m
o
0
o
O
li
O
O
H
H
O
o
O
H
o
i
o
0
-a a
w
J
(NA
O
d
N
¢
tl
z
O
H
0
r
0
Z
o
J
O
ti
U
U
N
0)
LnQ
O
N
LL
}
N
w
(M
O ti
b
Z
O
O
X
�Z
Q
w
Z
M
rl
p
O
w
J
U
Q
0
N
N
O
p\
N
N
Lr)
In
V
N
l0
co
Ul
W
}
cu
J
Q
z
�
O
rG
F
l0
M
co
OD
0-1
M
O
^ Z
0
LU
U
M
V
rl
rl
ri
M
N
0
Z
O
U
O l
X
�wm
u
x
u
x
u
x
x
u
x
u
x
u
x
u
x
u
x
u
x
u
u
x
J m
mQ
,`
Y
�
N
x
X
X
X
I \
X
X
X
`J�,
X
/
N
w K
I \
/ \
/ \
/ \
/ \
/ \
m a.
z
¢
O
m
(O
N
r
G
En
$
p
O
FZo
E
N
Nv
mMvN
( 6m
Q0
@
G
(n
d
N m'o
co
mN
Co
J0 ?
CL
OQ
�,-ffi
O
OU
aOU)
W�
V
0.4
QJ
M
G_m
YEO
G
o
U)°U)
m
Uv
v
�ov
�ovz
o
—o
_
E °
c
dl -C
aC
vC
C
�C
1-C
AHC
>HC
3C
XrC
w
cD
a
z
0
w
D
Z
z
Z
0
U
O
W
U
N
O
LO
Cl)
0
LLIL
w

af N
W O
m
O
Z
J
LL
H
O
U
o:
O
11W
O
W
Q
a
w
LL
L O O
LL N
O V)
>o
ZQ
z
Z
Z
Z
Z
Z
Z
Z
Z
�
Z
Z
Z
Z
Z
000lZ)'3�
La �.- O
-a.:.a'romcc
o
U)
m 'c o
Z4
I
FC
FC
FC
FC
FC
4z
4z
FC
�
Z<
Z4
o c° O= N a@i
m T
w
N
7�
z
Z
Z
Z
z
Z
Z
Z
�,
7
Z
p T— _
Nm
�@ymm
m
Y
Q
OE J
Wa
�.
O
c m
E`pE0
ZOw
�>
O W N N O 7 U
L6
O
30 c L N N
J W
^ h-
-cz)
di
Z
Z
Z9
Z4
�i
�/
i
4z
Z4
4z
Z9
Z9
Zi
4z
Z4
Z9
� 2. ?0:
@>
Z
Z
Z
Z
Z
Z
Z
Z
Z
Z
Z
Y 3 U C m n y
O
a E @
U
m E
3 T j 7 Q
p 7= n O^
y O w N T
y T c
U)
PQ
PQ
m
m
CQ
(Yi
m
m
Gp
GQ
m
in
PQ
m
(Yi
O_ 7.@-�N�m..
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
cn
cn
.n
y QcO So)
EO N fl_ 7
F
Z
wZ
am+
7
oc°=ate=
O
v
U O
a
a0
a
a
a
a
a
a
a
a
a
a
a0
T 2.0 � - �
y w m m w
ZO ~~
\
C7
\
i7
\
i7
\
C7
\
L7
\
L7
\
i7
\
C7
\
C7
\
Z7
\
C7
\
L7
\
i7
\
i7
\
C7
7
C
@
L m T T 0
LL N
OU)
i U
O @ — U
In 'D T@ °c :c
>,
o o t 3
U w
O}
r1
H
H
H
H
H
,1
H
'A
� -i
'A
rt
r -I
r -I
-i
N 7 in o',2 2
Z Q
2:t<
Q
--mp--ScL
O N L U a @ U
M
U CO @
d 3
N
3
y
<
0
O D U m y N
Q
v
EmN Edo
y
�o
Z
O
C.L-.N
W `•ti
"EEm`co oa�o
~
D
Q~
2'
pa U ` C 00
c
ZJ
OQ
w
a @
L N O.
o�XNra—
J >
U
Z
m, 7 o m w
E.c rn
ci
O
U
O
N p O O
W
C y Tcr L y
N
�
O
co
N m L C a 0)
w R
W
Q
Q
p N «a 4i O
O>
C T N 7 p
J}
LL
N
U N O. p p i
❑ .p
O_
N O N Cy@
U C d
c*
M¢
Q
N L> m
M O N O N Svw
�od
z
N C D U O
@ d c Z
O
w
m 47 j@ O) N
J
CO
N
O
M
wN
O
HM
O
k.0
co
rl
O
O
M
O
M
N
O
M
O
N E E M
y r
Q
Q
`"�
ri
rl
M
y@ 7?
N
O
O
O
O
O
O
O
O
O
O
O
O
O
O
N
V
v
v
v
v
v
v
v
v
v
v
v
v
v
F
J
IDU
T
Q
Z
O
N Y c E
❑
U
EE O 7 7 L
F
N
Ln
rl
N
Ln
k
M
N
O
Ln
Ln
N
Ln
N
to
-;;p
Of
CL
aw >@
O¢
^w
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
m
@ @ N U
y
-Z
W
O
p J— x
z
O
V
O
V
O
V
O
V
O
V
O
O
V
O
O
VV
O
O
V
O
V
O
O
V
U
•L-. @
U Q a
O
V
V
(q
W
p d p@
O N
p U
@
U
❑
D
4 0 cc w
O C
O= N L y +@-
w Z
y m m a�
O.y
•L• NL MO
awW
co
Wm
>
7 C @ d y
m Q
fn
J
N
@mac°C'f E
X
O
0
y o
E y 0.)
w
W Z
Z
x
p m 3 0 C
oww
d
v7a0"�°cmamiQ
Y
an WW
C p c@� ��
.�
Q
w
Tx r U @ m
T0y
m fla C
O
y
m EPEE._
z0.
w
mwyw��°y °
~w
w
FOf
2
a
m c c d c a c
'oo a m w6 �. O
❑
T U U p N d7 a
Z W
Q
F�
p
F
H
M
0
p
W
N
y0
@
0_ (O
wwwm CO O_a fl._Q N
�""'❑� Q
U
C
~
E
E
3Q�
��
~
O
~a^-
~
I-.
jq
t
j N
F...
Or
G
O
N N�
U
J Z�
JaZ ?[O
00
CN
Na0
2iz
�M
EO
v
Od'
N W
O_
QO
'ON
�(O
�1�
'O
p
i'NC�
E N
mao
N i
>
m V
U
m
T�
C
m
L
Ccp
m m�
I--�:
~
d U`^
Q
Qo
Qo
ca
Uo
Uv
Uo
�a
�m
Zo
UC
Un6
I-...
No
Ute,
Z
m a c
Q
a=
U
W
v
v
v
v
v
v
v
v
v
v
M
v
M
v
t
v
�m
gv
v
�m
gv
d'
�m
.
2m
ro
ri o
IL
�C
NC
MC
vC
m -
co
FZC
WC
rnC
�F°
�C
�H
MC
�F-
mF
❑
N v❑
W
M
LU
LU
w
w
Z
O
w
Z_
I --
Z
O
U
0
rn
co
N
O
N
E
LLL
IL
W

N
J
W
n
a
z
O
w
M
z_
F.
z
O
U
s
CP
U
N
O_
LO
m
O
LL
a
W
LL (/)
W
d J�i
�i
Z
Z
�i
Z
Z
�i
Z
Z
Z
Z
Z
Z
�i
Z
Z
Z
�i
di
Za
Z
Z
Z
Z
Z
Z
�Z
a
o
w
Z
Z
Z
Z
Z
Z
Z
Z
z
Z
Z
Z
Z
Z
Z
Z�7.�
Z
Z
W
J
N
w
F
Z
OW
O
ui
(7
O
Z
-
Z<
z
Z4
z
FC
z
�z
z
z
FC
z
FC
z
z
FC
z
FC
z
FC
z
FC
z
FC
z
FC
z
C
Fz
4z
z
FzC
FzC
asQ
w
U
z
O
U
U)
CO
a
a1
W
W
m
Pa
P9
PO
m
PU
m
W
P9
W
fA
PO
m
PQ
W
Cq
U
F -
a
z
D
zz
�o
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
zF
cn
°F-
ca
LL (1)
Ow
rn
ri
'-I
ri
ri
r -I
Hri
ri
H1-1
1-1
r -I
ri
H
ri
rl
r -I
r -I
ZJ
a
O z
oU)
co
Q
a ti
a
z
O
F�
W
t
ZJ
z
OJ
U
U
O
U
W
u1
Q
w
J
LL
}
N
W
❑ o
M
M
O
F-
O
W
zoO
a
U
W
U)
M
ri
rl
w
rl
l0
ri
kD
ri
ko
M
O
M
O
M
Ln
N0
M
ri
w
ri
l0
r -I
w
rq
IO
ri
l0
r -I
l0
.-I
l0
In
J
U
Q
O
O
,k
O
O
O
M
M
O
O
O
O
O
O
O
O
ri
N
M
V
O
O
*
O
O
O
O
O
M
V
ri
O
O
O
O
O
O
O
O
O
O
V
}
J
V
V
V
V
V
V
V
V
V
V
V
V
V
V
V
Oz
O
H
O
H
r -I
ri
ri
Ln
Ln
Ln
Hri
ri
H
O
Hr
-I
Ln
NO
^�
Ln
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
vV
O
O
O
O
O
O
O
OV
O
O
O
O
O
O
O
O
O
O
O
O
z
V
V
V
V
V
V
V
O
O
V
V
V
V
V
V
V
V
V
O
❑ l
w z
W
U w
U
Co
mQ
Z
;<
❑ F -O
Y
of
> w
�Ww
a
O
Q
g
wMU
M EL
w
N
zw
J
cd P s
g
x
X
X
FW
o
/ `
I \
/ \
/ \
I `
/ \
/ \
I �
/ \
/ `
/ \
/ \
I `
/ `
/ `
W
,
F- w
w,v
O_
~
N
a)
O
N
a)
C
E
0
O
00
O N
O
O�
O l0
O
O
m
C
N
T
Cl)
M
r
FZ CO
Q ^a
qU
LL
N
C
C
O
N
E
C V
C
.00
C
°O O
L
L
N
O O
O"
w
O
O
O C
O L
O N
O r
.0 V
U M
O(p
2 O
U I�
L M
U l0
O1�
L CD
U ap
t
U
C
D
CO
T 4
W
.4
J Z D
J Z a
LL
O W
O r
Z`pj
0
N .-.
i L
U
W
O
ON
O `O
-2L�
Q r
OD
O N
E W
O
OM
L OD
U C�
O
Lch
L �.
U E�
L a)
U O�
r v
N`-'
v
r•
(] v
N 0
m
M ��L,
w r
a) m
v
N a)
Oa
(n ;^
U
UN
U O
U
CN
N (.j
N C aD
>,
t0
N U M
U
L W
U
_O
Z O V
U
L O
U
(V ' 1�
U (O
❑ O F-
❑
r 0
C
a)
r C
C
r- 0
C
0
>' 1�
W V
a
Q�
0] V
0]
N
D] N
In
cc N
t O
W
O
rC 4
O N
O
T O
L
t0
1
E N
O O>
0
> L6
f0
} L
a1
} L
>.
- L
0.
% O
d N
% O V
O
� O
E
O
} L
C)
N
M
V C
7 r
i a,
DF-
��
i
O��
i ,,
T�
O N-
r 0
N v
c-.0
M!�
c-'0
atezt
N
V)
c- N
O
r N
w -
��
W
O
Nm
NU
N
J
W
n
a
z
O
w
M
z_
F.
z
O
U
s
CP
U
N
O_
LO
m
O
LL
a
W

W
a
W
W
a
z
0
LU
n
Z
z
0
O
D)
0`0
U
N
O_
Cl)
LL
IL
w
LL U)
W
ci
Q
�
Z
Z Q
Z
Z
Z
Z
Z
z
Z
Z
Z
Z
Z
Z
Z
Z
Z
Z
Z
Z
Z
Z
a Z
Q
c
z
o
w
<
FC
FC
FC
Z<
Z
4Z
Z
FC
Z
FC
Z
FC
z
z
z
4
z
Z
FC
Z
%
FC
Z
Z
Z
W
J
Z
z
Z
Z
Z
z
Z
z
a
W Q
F
Z
U W
O
ui
C7
O g�
(6Q
Z
F
C
Z
F
ZF
F
F
ZZ
F
Z
Z
Z
z
z
Z44
zz
4
ZZ
FC
4
Z
Z
4
Z
U
Z
O
U
N
Q
PO
W
P7
0.l
a1
fA
W
W
W
W
P9
W
PO
fA
fA
W
W
PO
W
P9
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
U
a
z
z z
W
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
z�
�
c�
°�
Z
Z
Z
XZ
Z
X
Z
x
Z
Z
Z
Z
LL
OW
O J
rl
rl
rl
rl
rl
rl
H
ri
rl
rl
ri
rl
rl
rl
rl
rl
rl
rl
rl
rl
zQ
-6 Z
Q
co
Q
'a
Q ti
N
v
�
a a
�
Z
Fa
N
z D
Z
�F
J
OJ
Z
U
ti
ZO
U
W
co
Q
7
�}
_
N
LL
w
❑
M
roi
O
Fj0
Q
U
.a
O
U
W
U
M
rl
ri
M
rl
rD
rl
rl
M
ri
ri
rl
r -,r
-,r
-,r1
r -I
H
ri
ri
O
l0
l0
O
w
l0
w
w
O
l0
kD
w
1.0
w
110
w
k0
l0
w
Q
<
M
OO
M
O
O
O
O
M
O
N
O
O
O
O
O
O
O
O
O
O
O
V
O
V
O
V
O
V
O
V
O
V
O
V
O
V
O
V
O
V
O
V
>.
J
V
v
V
V
V
V
V
V
V
v
Z
O
1-
Lf)
rl
rl
In
rl
H
H
HLn
rl
rl
rl
rl
rl
rl
H
H
rl
rl1-4
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
%-F
O
O
O
O
O
O
O
O
O
O
X
-ZO
O
O
O
O
O
O
O
O
O
O
V
O
V
O
V
O
V
O
V
O
V
O
V
O
V
O
V
O
V
O
V
Z�O
O
�
�
>w
O W
C/)O
m
W
Z
x
O
0
of
Y
> W
d
Q
w
O
O
Co
U
CL2
'N
J
Ouj
C6 H
X
XXX
X
X`�J�/,XXX
XXXXX`J�/XXXXX
/
I \
I ♦
/ \
/ `
/ \
/ \
/ \
/ \
/
Q
a
I
I `
/ \
I \
/ \
/ \
/ \
I \
/ \
I \
/ \
I
\
I
O
I
I
I
I
I
O
Z W N
N O)
N
C
.V O
t In
O`
L
M
1�
O N
LO
Q m .p
~Q2 tl
U
C O
N�
.L.
N(D
LN
C
N
C N
i>
t(1
HN
O
F�
O
y0�
O O
O N
t
U
tL
O
O W
L�
_L
(O
N�
(()
W
N
s
D
L
Ll
O
�N
O cp
L�
.0 lfJ
F O
J Z 71
JQZ
LL
yC
N' 0
27-
I>
H N�
c:v
Nv
L...
V.L.+
?,�
LL
!]r'
<]�
❑
❑v
O
On
L�
r W
NN
O W
O to
N 01
�LtO
d O
F=
O W
-w
N PO
-o
r
`"'
��
(J C
F N
0) V'
HErn
Cd'
>
U�
r
Vv
o
V
0
(O
0
V 'o
Z�
n
N
ZN
o
V
0
o
drn
No
LL Q`
U
NL7L
03 M
N�
((o U�
C
r zE
C
a.0;5
o)-5
'2'9
O 0(
r
O
�In
U
C*, lC)
a(O
N C
QL
N C
QL
V y
Q 6
N C
Q.0
I6
Qs
O'
Q�
IL N
Q
d C
Q.00
W
O�
C
aL
U'
N U
N I-- A
N N
N�
N D
N N
N 0)
N U)
M i
M C
C.7
N O.
M d
7 U
(O d
(O
Imo ...
W U
W
a
W
W
a
z
0
LU
n
Z
z
0
O
D)
0`0
U
N
O_
Cl)
LL
IL
w

rn
C6
U
N
O
Cl)
E
LL
0.
W
LL U)
OW
O
�-�
Z
Z
Z
Z
r/
%+
Zi
i
Z Q
Z
Z
Z
Zi
Za
Z+
Z+
Zi
Z
%+
Z+
Zi
Z
-i
o Q
0
w
z
Za
Zi
z
<z
Z
Z
z
Z
Z
z
Z
`Zi
Z+
WQ,
j
N
Zi
Z
Z
Z
Z
Z
Zi
LUz
r>
Z
OW
Z Q
"
z
H
H
H
f-1
H
N Q
W
U
H
H
H
N
H
H
H
H
H
f-1
H
H
H
F
z
O
U
U)
m
m
m
ao
w
as
m
w
ao
as
cn
w
w
a�
m
as
as
w
m
U
a
z
z
q
LUo
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
LL U)
o
U)
°z�
H
H
H
li
�
-A
H
H
�
�
ri
rl
H
Q
�Z
Q
U)
a
�
Q �
N
v
b
>>
z
F
F
U
^�Z
O
�Z
><
U
U
0
U
W
U
Q
W
O
M
M b
O_
Q
�Q
vz
x�h
Q
U
O
a
U
W
U
H
r1
r1
rl
rl
H
r-1
rl
rl
r -I
ri
r -I
HkD
J
Q
O
O
O
O
O
O
O
O
N
O
O
O
O
O
O.
O
Q
N
O
O
O
O
O
O
O
O
O
O
V
O
V
O
V
O
O
V
O
O
O
O
O
O
O
}
J
V
V
V
V
V
V
V
V
V
V
V
V
V
V
V
V
Z
O
F-
O
o
O
o
r -I
C)
O
ri
r -I
O
r -I
O
ri
O
ri
O
r -I
O
ri
rl
r -I
Ol
M
rl
O
H1
O
-i
O
ri
O
H
O
rl
O
rl
O
^Z
0
0
0
O
o
O
o
0
0
O
O
O
0
O
0
0
0
0
o
O
O
vW
o
O
O
0
0
0
o
O
o
0
0
0
o0
o
O
O
o
0
0
g
v
Z
v
v
v
v
v
v
v
v
v
v
v
o
V
v
v
v
v
v
v
v
o
U
�
o
W z
Z
U J m
O
m Q
X
of
Iii
O
U
Y
>W
�Ww
-J
Lu m
ma
cv
w
w
z
���
mXXXX
�/
�/
XX
�/
X
�/
X
X
X
X
X
X
/
XX
X
�/
XX
�/
�/
XXX
�/
~�
1
W ti
Q
N
O
O
N
OD
N
.-. N�.
C
n
C 00
L
Q
W
N
O
O O
O
~ b
U
L
L
L
N
C
.Q.
C*,
.�. Ci
N N
.� O)
v C
�"� L
Ll
O a0
GV N
O
E N
N
0] ao
O
p N
O >.
p C
C
N
p
N
L �O
U to
'C
Y V'
JZ� b
J Q z Q
LL
O
Q)
O W
L°(�
'O
N_
O C
N N M
O
N
N �N
m y
O`-'
N d
OE W
N
�N^.N...m
t0 r
N.L..
v qN
N O
.^..-C�
N L
�LM
m W
O
�.-.
L N.--.
U
LL�
N
i W
N
O (7
N N
M N
CL z
!n
d
C',
N t0
U O)
r N
Cr
NIS
N �tC!
O C
m
��
N N
OJ
N c O
m
m ��
m W v
m �''
ma W
d' a�
C
m
N..L., OD
d'>.�
UO
S O
r
Q`
U
Q M
Cl)0�
Q ro'
Q O'
CO OD
m L t0
p
M
ID
p
k
m
O N
m
r
m
m
L
m
L
(r
C O
m
OD
L
N
ONE
N
m
C7
m
N N
M .'-_.
V
m Q
(mO d
CO
CO
n.
CO LL N
N
N��
U W
y
d O
p_
C v
0_C
<s
E
rn
C6
U
N
O
Cl)
E
LL
0.
W

w
U)
w
w
w
z
O
w
D
_z
z
Z
O
U
O
W
U
N
O_
M
LL
d
W
LL U)
O W
z
z
z
z
z
z
z
z
z
z
z
z
z
z
z
z
z
z
z
z¢
ri Z
a
a
o
U
'Z
rC
a
a'
'
az
<Z
a
4z
a`
a'
4z
Z
z
Z
lz<
Z
Z
a'
Zi
lz<
Z
a
Zi
Z
9
Z
Z
°R
W
w9z
J
N
Z
Z
Z
Z
Zi
Z
Z
Z9
Z
Q
LU
F
Z
o W
O
L6O
O
g^
4Q
�Q
W
Z
FC
91:4FC
Z
Z
Z
Z
FC
Z
FC
Z
Z
Z
FC
Z
FC
Z
Z
FC
Z
FC
Z
FC
Z
FC
Z
FC
Z
FC
Z
FC
Z
U
Z
O
U
V)
CO
as
w
w
ao
m
as
m
w
w
m
as
an
m
ao
as
m
m
m
m
as
o0
cf)
a
z
z
a
w
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
LL
o
U)
zQ
-6Z
a
�
Q �
N
Z
Z
H
0ZhJv}JiQ-0]o�
ZOU
U
O
W�U�NNznQ
ui
LL
LL
wai
mc
O
o-ZwOU
W
v)
',DrDi
r�1
�rDl
r -I
rl
.-I
r�l
rl
rl
ri
H
rl
rl
lrO�D
r -I
OM
)r -i1
rrV
ll
Q
O
O
O
O
O
Oi
M
O
O
O
O
O
O
O
V
Ori
Orl
O
V
O
V
O
V
OO
V
0
V
V
Orril
O
V
VO
V
V
V
VVV
V
V
V
V
V
ZO
O
;2:
0
L(
�a�0Za
p
p
O
O
O
O
O
O
O
O
O
0
OOO
�Z
W
O
O
O
O
O
V
OOO
O
V
O
V
O
V
O
V
O
V
O
V
O
V
V
V
V
v
VZ
@OU
�
Hn
w
'i >W
W
O
¢0
>w
wU)
a
=W
W
D
W
N
W
XXXXX
XXXXX
XX
XXXX
X
X
WdmXxX
~
O
2-
2.+
(O
7
N
O V
N
ON
ado
�. O O
C
V'
p N
0
^
N
N
C
C
N
H m'a
D� ^2 tl
.C(O
UO
.CT
U
V
j.s
>'
.L..
Jd'
m W
C
Cm
O
Ur
pr
`�
t�N
O_Ri
_LF,
�`�
C
N
C
d
:E
U
.C�
U�
.00 N
U'O
On
L
U
T
Oa
C
O
O
L
N
C
E
O N
N C
O '�
'�
J Z
J Q Z ?�
LL
....
C
O N
M C
L
U) .O+
N M
.U.
Z �N,
O r
7
D
t0
Z d
0 U) .-.
N C
O O
7
O .-.
7 1�
N —Z
x
N C
t0
X N
N
t0 .m,
X C
N
N (n0
N �''
N
C rU W
O_.-+
N r
d^
O M
... M
Z L
N O
f0
Z_ t`
Q 7
d U) 4_1
C
r 0
Cl)
l6
0
_
O cr-
.
_ O
O O
N C
N
N C
O
0�
r
�'
U-
LL fM
r
2 D
2�
O?
2 d n
O V
= C
M
d)
N
Z O
N
Z to
Z In
r
Z o (D
I r C)
m
coN N
m L
_
m L M
O L
m O
002
pmj L
N
p -j, N
m N
N
M�
N
M N
mm
V
m O L
(O L
maw O
06
N�
C6
O) p)
m
O�
m 0�
m a N
V
I
N S)
S)
N 4.
cO46-Z.
ND.
N
N
N a
ML Z
M
M 9
M U
M N
M -.��
M�..�
M
V
7 N
Z
w
U)
w
w
w
z
O
w
D
_z
z
Z
O
U
O
W
U
N
O_
M
LL
d
W

O
OD
U
N
0
LO
Cl)
E
LLL
n
W
LL U)
OW
�
�-i
%a
z
z
Zi
Z+
�/-�
Zi
%i
Zi
7-i
Z
Z
Z
Z
Zi
Z<
Z
6
Z
Q
o
U
Zi
Z
Z
Z
z%a
Zi
Z
%+%+
Zi
%i
W
N
Zi
WQ
F-
Z
U' WO
C7
ui
O W
Ld>
^�
W
FC
Z
Z
FC
FC
z
Z
FC
Z
FC
Z
FCFC
Z
Z
Z
Z
Z
FC
Z
Z
z
FC
Z
4z
Z
FC
Z
I
Z
Z FC
U
Z
O
U
O
Q
W
W
W
W
0.1
W
W
0.l
W
P9
CO
W
W
fA
W
W
P9
0.l
W
W
F -
z
::)
z Z
a
w
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
Z
°F-
Cd
LL. U)
0
Jr-1
.-I
ri
rl
ri
r -I
r -I
rl
ri
r-1
ri
rl
rl
r -I
r -I
rl
r -I
�-I
rl
�-I
Z Q
o Z
Q
w y
N
Q Q
N
Z
O
?
W
� v
H
W
Z J
vZ
OJ
i
U
U
O
U
W
N
w
j
Q
J
W
}
N
WW
�
0 Q
M
MO
O
2
2—
—Z
w
4
O
-Q
U
WU
c -I
l0
ri
l0
M
O
M
O
M
O
M
O
M
O
M
M
O
M
O
M
O
M
O
M
O
M
O
M
O
M
O
M
O
M
O
J
U
Q
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
}
N
OO
V
O
O
V
O
O
O
O
O
O
V
O
O
O
O
O
O
O
O
O
O
J
V
V
V
V
V
V
V
V
V
V
V
V
V
V
V
V
V
❑
O
Lf)
Ln
Ln
Ln
Ln
n
N
Ln
Ln
Ln
Ln
Ln
Ln
Ln
L(
Ln
Ova
F
H
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
iz
O
O
O
O
O
OOO
O
O
O
OOO
V
OO
V
VO
O
O
O
O
O
O
O
O
O
O
O
OZ
O
V
V
V
V
V
V
V
V
V
V
V
V
V
V
V
�
U
"
Z
W
Z
W
ti W N
O
J m
W¢
W
�
5f
O
U
0 F
Y
>w
dww
CO
ma
F
❑
N
(90
�~O
XXX
`J�,
`J�,
,
`J�,
`J�,
`J�,
`J�,
`X,
/ \
\J�,
`J(,
/ \
`J�/
/ \
`J�,
/ \
`J�,
/ \
`J(/
/ \
`J�,
I \
`J�,
`J(,
/ \
`J�/
/ \
`J�,
/
W
Q
/ \
/ `
/ `
I `
/ \
/ \
/ \
/ \
I `
/ \
F LY
�
Z
O
Z
O
Z
c
c
W, m
F-
c
D❑ D O
J Z 2 CS
J Z
W
O
"' �+
C
C
d O
~ N{
C
W
C N
U (O
U 1�
U
'O
O
D
Q
O
O
L'] ^
C
"O ^
O
C r
'OO
c r
N aO
0
V r
C
'O
C V
"O N M
(YU6
RD
Q
O
d co
VJ
Z N
Z L O
L
Q.
>.O
4. O
N d N
p aD
O
O
m W
2
m W
2
m
LM
t V'
M
W
W
tl')
W
V
N r
t`
W
tl N
W
U'•.N
C p
W .�.
C a0
W O
C -p
W t
a0
2 V
U
_
U
d M
m O(O
O
V Ln
mN
CCO O ON
U
Q
a0
23
d O)
¢1
lLM
r
�.�
U L
W r
V N
a0
d' In
dNdN00
V LO
a�
N�M=�
M
C,4
�N
a- V
7
a-.
i:i
N.M..
M �.
V �"
O�
r.�_.
W
O.r..
r Ln
O
OD
U
N
0
LO
Cl)
E
LLL
n
W

x
W N
m o
O
7
z
0
CP
o�
U
N
O
E
LL
a
W
LL Ln
OW
OJ
Z
z
z
z
Z
Z
Z
z
z
Z<
cs
Z
Q
o
1�1o
CDU
z
z
z
z
z
z
z
z
z
W
W
2of �
W a
z
U' W
O
L6
0
0
cd
z
z
z
z
z
z
z
z
z
z
U
Z
O
U
0
CQ
a
on
a
a
a
a
a
a
F
a
z
z z
VO
a
a
a
a
a
a
l
a
Fl
zF
ovF-
Lo
LL U)
o
Ln
z¢
-6Z
a
a�
N
z
W
O
W
aa
z
Z
O>
U
Cl
O
U
W
U)
Q
7
>
Q
IJLL
L
W
0 a
M
MQ
O
D w
ZZ
%5
w
Z
O
�
U
w
N
rO
M
O
Cl)
O
M
O
c+)
O
M
O
M
O
M
O
(Y)
O
J
Q
O
OO
O
O
O
O
O
O
}
J
N
V
V
V
V
V
V
V
V
V
!]
D
~
0
O
to
Ln
Ln
Ln
Ln
N
Ln
Ln
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
y
_�
�z
O
O
O
O
O
O
O
O
O
O
a
W
U
z
OV
O
V
O
V
O
V
O
V
O
V
O
V
O
V
O
V
O
C6
U
wz
w
'swI
CO
ma
m
a
X
e
Y
wz
>w
u
aLLW
m ate.
w
LV
U_
w
m om-
W
u
u
u
u
u
u
u
u
wU
d
~w
I
z
H
O
QW tiU
O
O
U
N
N p
V
T r^. to
N N
N
N 9
T
aD
N�
e-
O
N
CO
C
ID
J Z
J Z ?�
a O
IIILLL
LL
y6 M
N N N
mN
U
m�
U O
m�
U N
m�
U
mM
U N
mN
U° P
U V
N
O M
d��
x s d
p)
'L o
a�
wo
a'IT
a^
aN
a
r C)
U
n oo
n
s
n
d�
i�
aN
CL
a:N_
Lig
CD
� W z.
W
�2r
NZ:
NZ
N
N
N
N
0
CP
o�
U
N
O
E
LL
a
W

H
Z
O
of
LL
w
F-
2
w
LL
w
n
Z
F-'
z
O
U
>
w
na
z
O
w
D
Z_
z
Z
O
U
s
s
U
N
_O
N
Cl)
ff
LL
CL
w
LL CO
Ow
CO
J
4z
'%i
'7-i
Z<
Zi
z
Z
%
Z+
%
Zi
Z
Z
Zi
Zi
z
Z
7-a
Zi
Zi
Z
z
Z
Q
cc
o
w
Z
'z
z
z
z
z
z
�7-�
z
z
z
z
z
z
z
z
z
z
z
z
W
�=
N
Z9
� J
W Q
H
Z
(9 w
O
ui
O
O
W
v
FC
FC
FC
FC
FC
FC
FC
FC
FC
FC
FC
FZC
FC
Z
FC
4z
I
Q
w
U
Z
Z
Z
Z
Z
Z
Z
Z
Z
Z
Z
Z
Z
Z
Z
Z
Z
Z
Z
Z
O
U
U)
Q
W
W
W
0.l
CQ
P9
f-0
P9
pq
W
P7
W
W
W
P7
P9
0.l
W
P7
W
W
U
a
z
D
zz
v
wO
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
i7
i7
0
0
0
0
0
0
0
0
0
0
0
0
0
0
O
0
0
0
°Z7
C �
LL co
Ow
co
ZJ
ri
ri
H
H
rl
H
H
H
Hri
.-I
ri
ri
ri
ri
ri
rl
ri
ri
ri
Q
-6 Z
Q
U)
U
Q �
z
O
w
(7 W
ag
z J
^�
OJ
Z
LU
>
U
U
O
U
H
w
O
U)
>
0
�
}
Q ti
N
LL
❑ p
W
M
M
O
�
� cs
F
X
Q
z
w
O
�
U
w
co
r-
r-
r♦
ri
Hri
H
Hr"
ro
r
r-
MO
H
m0
ri
ri
ri
11
rl
H
r-
co
O
O
O
O
O
O
O
M
O
O
O
O
O
O
O
O
O
>
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
}
J
V
V
V
V
V
V
V
V
V
V
V
V
V
V
V
V
V
V
V
V
V
z
O
g
F
o
H
ri
ri
ri
ri
ri
ri
Ln
Ln
Ln
HLn
H
ra
14
H
ri
Ln
ul
N
7
^�-
Ln
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
0
xx�_
vw
O
0
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
Z
V
V
V
V
V
V
V
V
V
V
V
V
V
V
V
V
V
V
V
C6
O
wz
w
oWm
CO
co
Z
X
0
O
Y
>w
a
Q
�Jw
O
w
ma
U
w
N
Lucy
Z
J
m s�
Og
X
u
u
u
u
u
u
u
u
x
u
u
u
u
u
u
XX
HW
>
m
a)
C
L
O.ON
O?
O�
L W
OC6
C
W
P4.
0�0
Z
-j Z
❑QU
O
NN
a5
O
O
O
OEob
wJ
LCN
Ow
N co
"t
v.Oo
>.L..
v.LMZ❑dQ
Un
Or
L
)
O LO
NL
Uc7L
CDM
U '6
S2
❑ OO
Q
C
N N
M
N N
N NU
�„�p._.
W
E V
l
O
% O
CO
V
Ln
co
0
r--
O
co .0
W
NT
�N
—'Or�
—
rN
O
W,
F
W O
Os
m
OmNi�
N
U
>
w
na
z
O
w
D
Z_
z
Z
O
U
s
s
U
N
_O
N
Cl)
ff
LL
CL
w

�,
O
CPW
U
N
O
M
LL
D_
W
LL U)
Ow
O�;
z
z
z
z
z
z
z
z
z
z
z
z
z
z
z
z
z
z
z
z
z
Z¢
Z
Q
0
o
wm
4z
4z
Z4
Z4
<z
9z
z
�/-�
FC
�/-�
FC
I
<z
I
FC
4z
FC
Z
Z9
FC
W
S J
N
Z
Z
Z
z
Z
Z
Z
Z
Z
Z
Z
Z
Z
Z4
Z
Z
z
Z
W Q
F
Z
o W
O
z Q
F
Lri
Ow
r�a
�w
'Zi
Zi
Z
Zi
Z
Zi
a
7-+
a
a
Zi
a
Z
a
Z
a
Z
Z
Z
a
z
a
Z
a
Zi
�+
Zi
'Zi
N Q
U
r7 -i
z
Z
O
U
U)
Q
PQ
m
PO
W
PO
W
P7
M
W
W
PO
Pa
W
m
m
W
P7
PQ
m
m
m
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
s
a
a
a
s
a
�
a
z
z
v
�O
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
z �
W cn
Ow
U)
Q J
ri
ri
r -I
ri
ri
rl
r1
ri
r -I
ri
r-1
ri
ri
r -i
r -I
ri
ri
r1
ri
ri
zQ
�z
a
co
Q �
Q
L2
Z
Z =
:;:,I-
-Z
LLI
JO 1
U
ti
ZO
U
w
W
N
vi
M
O_
Q
�QK
2-
�Z
W
O
U
w
to
M
r -I
`�
r-1
rl
ri
r -i
M
M
M
M
ri
r -I
rl
H
r -I
li
r -I
Ln
O
U
O
�ko
l0
l0
l0
l0
O
O
O
LO
N
O
l0
w
�
�
�
l4
l0
Q
O
O
O
O
O
M
M
ri
M
O
O
O
O
O
O
O
}N
M
V
O
V
O
O
O
O
O
O
O
M
V
ri
O
O
O
O
O
O
O
O
O
O
V
J
V
V
V
V
V
V
V
V
V
V
V
V
VV
V
Z
0
F-
O
rl
H
ri
ri
r -I
LO
LO
to
mLn
r -I
Hr
-I
H
Hr
O
-1
r-,
LnN
O
^F
W
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
�Z
O
O
O
U
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
Z
V
V
V
V
V
V
V
V
V
V
V
V
V
V
V
V
V
'6
O
mF
w
>
U W
U)
m
¢
0
m
Z
X
0H
O
Y
>w
0
a
W
o
w
mG-
U
w
N
J
Z LY
m U)
Q
J
XXX
X
X
X
X
`x,
X
\X,
X
XXXX
`�J�/'X
U
F W
>
�
I
z
Z w
N
C
N
01
p
O .-.
O N
O :;
l0
60
O
>=
N
O)
M
M
F m,a
0
U
C
w
0)
O
N
E
V
C
C
'O O
L
N
O O
O '"'
O
O C
O7
O N
L
t�
U M
L D
U
LM
U In
L00
U
t
Y
C
O
OD
V
I'L
W
d'
J Z
J Q Z
L.L
LL
N^
O M
C^
O
C
0)
..0 L^
U r
O
C
O p
.fl
O
O
O +'�.+ ^
N r-
O
O
O
W
L W
O
O 1.
O .L.
L OL
O
L N
U)
ti
G O
C] v
O6
I�
p t
C] N (O
'p
>.7
Tv
.L+
i ....
O N
CA
U N
Z' M
C N
0) M
W
N
O N_
N
p
L
L E ao
M
L O
U C N
L M
U E 7
U E W
5 O`
.ti...
r
_ 0)
(V
N
r N
r
[V 0)
C
M C
O
L
01 0)
0) N
IL Q
U O
Q r
U
Q r
m�
C 00
mI-
r0
mN
U M
U �6N
O
U�
O
U Ev
UO
cli
TO'
U co
O
CJ O 1-L
EN
O f�
� C
r
C
� co
r U
U
O
O
m y
O>
O N
>O L r•
>
N 210
w�
L
L
t
- O
co O
6 O
6,b
> L
CJ
N
M
V E
OF
f��
au ��
d
r N-
r .O
r`O
N—
N
r 0)
r d
r 0.S
r
Nm
N U
O
CPW
U
N
O
M
LL
D_
W