Loading...
HomeMy WebLinkAbout20091308 Ver 1_401 Application_20091209Progress Energy 1n Mr. Scott Jones U.S. Army Corps of Engineers Asheville Regulatory Field Office Chief US Army Corps of Engineers 151 Patton Avenue, Room 208 Asheville, North Carolina 28801-5006 Dear Mr. Jones and Ms. Karoly: op, ,Fhk ? v M?s`?arFR `??09 ry 09-1308 Ms. Cyndi Karoly N.C. Division of Water Quality 401 Oversight/ Express Unit 1650 Mail Service Center Raleigh, NC 27699-1650 1'A I SUBJECT: Progress Energy 404 Dredge and Fill Permit Application to Repair Walters Hydroelectric Project Intake Structure Please find enclosed a Section 404 permit application to permit localized dredging activities at the intake structure of the Walters Hydroelectric Plant. Progress Energy is requesting a 404 permit to repair a breeched area at the intake structure of the Walters Hydroelectric Plant. The power plant is currently off-line due to the breech and will not resume generation operations until the repairs have been made. Accumulated woody debris, manmade trash, and sediment need to be removed to access the area immediately in front of the intake structure and to permit safe, timely, and effective repair of the breech. Progress Energy requests 404 permit authorization to begin dredging in front of the intake structure to remove sufficient quantities of debris and sediment for the repair work and to allow the power plant to resume power generation operations. The power plant is currently off- line due to the intake breech. We thank you for your support of our efforts regarding this matter. If you have any questions concerning the permit application, please contact Mr. Shannon Langley (919-546-2439) or Mr. John Crutchfield (919-546-2019). Sincerely yours, Cecil T. Gurganus Manager, Hydro Operations Enclosure Progress Energy Carolinas, Inc. Tillery Hydro Plant 179 Tillery Dam Aoad Mount Gilead, NC 27306 c w/enclosure: Mr. Dave McHenry-N.C. Wildlife Resources Commission Mr. Steve Cahoon Mr. John Crutchfield Mr. Shannon Langley Mr. Max Gardner c w/o enclosures: Ms. Brenda Brickhouse Mr. Fred Holt Mr. Alan Madewell 2 g_ 1 3 Q 8 0F wA7-f o? O `C Office Use Only: Corps action ID no. DWQ project no. Form Version 1.3 Dec 10 2008 Pre-Construction Notification PC Form A. Applicant Information 1. Processing kip 1a. Type(s) of approval sought from the Corps: ®Section 404 Permit ®Section 10 Permit 1 b. Specify Nationwide Permit (NWP) number: Nationwide 3 or General Permit (GP) number: 1c. Has the NWP or GP number been verified by the Corps? ® Yes ? No 1 d. Type(s) of approval sought from the DWQ (check all that apply): N 401 Water Quality Certification - Regular ? Non-404 Jurisdictional General Permit ? 401 Water Quality Certification - Express ? Riparian Buffer Authorization 1 e. Is this notification solely for the record because written approval is not required? For the record only for DWQ 401 Certification: ? Yes ® No For the record only for Corps Permit: ? Yes ® No 1f. Is payment into a mitigation bank or in-lieu fee program proposed for mitigation of impacts? If so, attach the acceptance letter from mitigation bank or in-lieu fee program. ? Yes ® No 1 g. is the project located in any of NC's twenty coastal counties. If yes, answer 1 h below. ? Yes ® No 1 h. Is the project located within a NC DCM Area of Environmental Concern (AEC)? ? Yes ® No 2. Project Information 2a. Name of project: Sediment and debris removal at Progress Energy's Walters Hydroelectric Plant to access and repair failed intake bottom seal 2b. County: Haywood 2c. Nearest municipality / town: Waterville 2d. Subdivision name: N/A 2e. NCDOT only, T.I.P. or state project no: N/A 3. Owner Information 3a. Name(s) on Recorded Deed: Great Mountain Power Co. to Carolina Power & Light Co. 3b. Deed Book and Page No. Book 72 page 377 3c. Responsible Party (for LLC if applicable): Carolina Power and Light Company d/b/a/ Progress Energy Carolinas, Inc. 3d. Street address: 410 South Wilmington Street 3e. City, state, zip: Raleigh, NC 27601 3f. Telephone no.: 3g. Fax no.: 3h. Email address: Page 1 of 11 PCN Form - Version 1.3 December 10, 2008 Version 4. Applicant Information (if different from owner) 4a. Applicant is: ? Agent ® Other, specify: Plant Manager 4b. Name: Cecil T. Gurganus, Plant Manager 4c. Business name (if applicable): Carolina Power & Light Company d/b/a/ Progress Energy Carolinas, Inc. 4d. Street address: 179 Tillery Dam Road 4e. City, state, zip: Mt. Gilead, NC 27306 4f. Telephone no.: 910-439-5211 4g. Fax no.: 910-439-5359 4h. Email address: cecil.gurganus@pgnmail.com 5. Agent/Consultant Information (if applicable) 5a. Name: 5b. Business name (if applicable): 5c. Street address: 5d. City, state, zip: 5e. Telephone no. 5f. Fax no.: 5g. Email address: Page 2 of 11 PCN Form - Version 1.3 December 10, 2008 Version B. Project Information and Prior Project History 1. Property Identification 1a. Property identification no. (tax PIN or parcel ID): 7793-82-1780 1 b. Site coordinates (in decimal degrees): Latitude: 35.69481 Longitude: - 83.05046 (DD.DDDDDD) (-DD.DDDDDD) 1c. Property size: 249 acres 2. Surface Waters 2a. Name of nearest body of water (stream, river, etc.) to proposed project: Pigeon River/ Waterville Lake 2b. Water Quality Classification of nearest receiving water: Class "C" waters 2c. River basin: French Broad 3. Project Description 3a. Describe the existing conditions on the site and the general land use in the vicinity of the project at the time of this application: The site is used for hydroelectric generation. 3b. List the total estimated acreage of all existing wetlands on the property: 3c. List the total estimated linear feet of all existing streams (intermittent and perennial) on the property: 3d. Explain the purpose of the proposed project: A failed intake bottom seal has been found at the Walters Hydroelectric Plant intake structure. The power plant is shut down to prevent further entrainment of debris into the generating turbines. Accumulated woody debris, manmade trash, and sediment need to be removed to be able to access areas needing further evaluation and repair. Progress Energy requests authorization to begin immediately dredging the area in front of the power plant intake structure to remove sufficient quantities of intermixed debris and sediment to access and repair the failed seal to allow the power plant to resume operations We need to conduct the proposed project to ensure safe, timely and effective repair of the intake breech and return the power generation service to customers in our western region service area.. 3e. Describe the overall project in detail, including the type of equipment to be used: Progress Energy intends to remove the accumulated material from the area, using a clamshell. The material will be placed in lined containers to prevent decanting of sediment and water and then disposed of in a landfill in accordance with applicable waste disposal requirements. 4. Jurisdictional Determinations 4a. Have jurisdictional wetland or stream determinations by the Corps or State been requested or obtained for this property / project (including all prior phases) in the past? ? Yes ®No ? Unknown Comments: 4b. If the Corps made the jurisdictional determination, what type f ? Preliminary ? Final o determination was made? 4c. If yes, who delineated the jurisdictional areas? Agency/Consultant Company: Name (if known): Other: 4d. If yes, list the dates of the Corps jurisdictional determinations or State determinations and attach documentation. 5. Project History 5a. Have permits or certifications been requested or obtained for this project (including all prior phases) in the past? ® Yes ? No ? Unknown 5b. If yes, explain in detail according to "help file" instructions. Page 3 of 11 PCN Form - Version 1.3 December 10, 2008 Version 6. Future Project Plans 6a. Is this a phased project? ? Yes ® No 6b. If yes, explain. Page 4 of 11 PCN Form -Version 1.3 December 10, 2008 Version C. Proposed Impacts Inventory 1. Impacts Summary 1 a. Which sections were completed below for your project (check all that apply): ? Wetlands ? Streams - tributaries ? Buffers ® Open Waters ? Pond Construction 2. Wetland Impacts If there are wetland impacts proposed on the site, then complete this question for each wetland area impacted. 2a. 2b. 2c. 2d. 2e. 2f. Wetland impact Type of jurisdiction number - Type of impact Type of wetland Forested (Corps - 404, 10 Area of impact Permanent (P) or (if known) DWQ - non-404, other) (acres) Temporary T W1 ? PEI T ? Yes ? Corps ? No ? DWQ W2 ? P ? T ? Yes ? Corps ? No ? DWQ W3 ? P ? T ? Yes ? Corps ? No ? DWQ W4 ? P ? T ? Yes ? Corps ? No ? DWQ W5 ? P ? T ? Yes ? Corps ? No ? DWQ W6 ? P ? T ? Yes ? Corps ? No ? DWQ 2g. Total wetland impacts 2h. Comments: 3. Stream Impacts If there are perennial or intermittent stream impacts (including temporary impacts) proposed on the site, then complete this question for all stream sites impacted. 3a. 3b. 3c. 3d. 3e. 3f. 3g. Stream impact Type of impact Stream name Perennial Type of jurisdiction Average Impact number - PER or (Corps - 404, 10 stream length Permanent (P) or intermittent DWQ - non-404, width (linear Temporary (T) (INT)? other) (feet) feet) S1 ? P ®T Dredging Pigeon River ® PER ? INT M Corps ® DWQ 'See comments S2 ? P ? T ? PER ? Corps ? INT ? DWQ S3 ? P ? T ? PER ? Corps ? INT ? DWQ S4 ? P ? T ? PER ? Corps ? INT ? DWQ S5 ? P ? T ? PER ? Corps ? INT ? DWQ S6 ? P ? T ? PER ? Corps ? INT ? DWQ 3h. Total stream and tributary impacts 3i. Comments: Item 3g. Sediment, intermixed with rocks, woody debris, and manmade debris, will be removed to access the repair area is approximately 45 feet along length of intake structure, 10 feet away from structure and 4 feet in depth (-67 cubic yards of sediment intermixed with debris). There is an additional 6 feet of woody debris, plastics, and other manmade debris on top of the accumulated sediment and debris mixture in this area that will be removed. as well. Page 5 of 11 PCN Form - Version 1.3 December 10, 2008 Version 4. Open Water Impacts If there are proposed impacts to lakes, ponds, estuaries, tributaries, sounds, the Atlantic Ocean, or any other open water of the U.S. then individually list all open water impacts below. 4a. 4b. 4c. 4d. rArea Open water Name of waterbody impact number - (if applicable) Type of impact Waterbody type of impact (acres) Permanent (P) or 01 ?P?T 02 ?P?T 03 ?P?T 04 ?P?T 4f. Total open water impacts 4g. Comments: 5. Pond or Lake Construction If and or lake construction prop 0 5a. 5b. Pond ID number Proposed use or purpose of pond then complete the chart below. 5c. Wetland Impacts (acres) 5d. 5e. Stream Impacts (feet) Upland Flooded I Filled I Excavated I Flooded I Filled I Excavated I Flooded P1 P2 5f. Total 5g. Comments: 5h. Is a dam high hazard permit required? ? Yes ? No if yes, permit ID no: 5i. Expected pond surface area (acres): 5j. Size of pond watershed (acres): 5k. Method of construction: 6. Buffer Impacts (for DWQ) If project will impact a protected riparian buffer, then complete the chart below. If yes, then individually list all buffer impacts below. If an impacts require mitigation, then you MUST fill out Section D of this form. 6a. Project is in which protected basin? 6b. 6c. 6d. Buffer impact number - Reason Permanent (P) or for Temporarv (T) impact 61 ?P?T B2 ?P?T B3 ?P?T 6i. Comments: ? Neuse ? Tar-Pamlico ? Other: ? Catawba ? Randleman 6e. 6f. 6g. Buffer Stream name mitigation required? ? Yes ? No ? Yes ? No ? Yes ? No 6h. Total buffer impacts Zone 1 impact Zone 2 impact (square feet) (square feet) Page 6 of 11 PCN Form - Version 1.3 December 10, 2008 Version D. Impact Justification and Mitigation 1. Avoidance and Minimization 1a. Specifically describe measures taken to avoid or minimize the proposed impacts in designing project. This activity is necessary to permit timely repair of a failed intake bottom seal at the Walters Hydroelectric Plant and to get the hydroelectric plant back into electric generation service. 1b. Specifically describe measures taken to avoid or minimize the proposed impacts through construction techniques. Accumulated debris and sediment will be placed into lined cont ainers and transported to a landfill for disposal in accordance with applicable waste disposal requirements. 2. Compensatory Mitigation for Impacts to Waters of the U.S. or Waters of the State 2a. Does the project require Compensatory Mitigation for impacts to Waters of the U.S. or Waters of the State? ? Yes ® No 2b. If yes, mitigation is required by (check all that apply): ? DWQ ? Corps 2c. If yes, which mitigation option will be used for this project? ? Mitigation bank El Payment to in-lieu fee program ? Permittee Responsible Mitigation 3. Complete if Using a Mitigation Bank 3a. Name of Mitigation Bank: 3b. Credits Purchased (attach receipt and letter) Type Quantity 3c. Comments: 4. Complete if Making a Payment to In-lieu Fee Program 4a. Approval letter from in-lieu fee program is attached. ? Yes 4b. Stream mitigation requested: linear feet 4c. If using stream mitigation, stream temperature: ? warm ? cool ?cold 4d. Buffer mitigation requested (DWQ only): square feet 4e. Riparian wetland mitigation requested: acres 4f. Non-riparian wetland mitigation requested: acres 4g. Coastal (tidal) wetland mitigation requested: acres 4h. Comments: 5. Complete if Using a Permittee Responsible Mitigation Plan 5a. If using a permittee responsible mitigation plan, provide a description of the proposed mitigation plan. Page 7 of 11 PCN Form - Version 1.3 December 10, 2008 Version 6. Buffer Mitigation (State Regulated Riparian Buffer Rules) - required by DWQ 6a. Will the project result in an impact within a protected riparian buffer that requires buffer mitigation? ? Yes ® No 6b. If yes, then identify the square feet of impact to each zone of the riparian buffer that requires mitigation. Calculate the amount of mitigation required. Zone 6c. Reason for impact 6d. Total impact (square feet) Multiplier 6e. Required mitigation (square feet) Zone 1 3 (2 for Catawba) Zone 2 1.5 6f. Total buffer mitigation required: 6g. If buffer mitigation is required, discuss what type of mitigation is proposed (e.g., payment to private mitigation bank, permittee responsible riparian buffer restoration, payment into an approved in-lieu fee fund). 6h. Comments: Page 8 of 11 PCN Form - Version 1.3 December 10, 2008 Version E. Stormwater Management and Diffuse Flow Plan (required by DWQ) 1. Diffuse Flow Plan 1a. Does the project include or is it adjacent to protected riparian buffers identified ? Yes ® No within one of the NC Riparian Buffer Protection Rules? 1 b. If yes, then is a diffuse flow plan included? If no, explain why. ? Yes ? No Comments: 2. Stormwater Management Plan 2a. What is the overall percent imperviousness of this project? 0% 2b. Does this project require a Stormwater Management Plan? ? Yes ® No 2c. If this project DOES NOT require a Stormwater Management Plan, explain why: Project consists of dredging deposited material to access and repair a failed intake structure bottom seal. Removed materials will be taken to landfill for disposal as appropriate. 2d. If this project DOES require a Stormwater Management Plan, then provide a brief, narrative description of the plan: ? Certified Local Government 2e. Who will be responsible for the review of the Stormwater Management Plan? ? DWQ Stormwater Program ? DWQ 401 Unit 3. Certified Local Government Stormwater Review 3a. In which local government's jurisdiction is this project? N/A ? Phase II 3b. Which of the following locally-implemented stormwater management programs ? NSW ? USMP apply (check all that apply): ? Water Supply Watershed ? Other: 3c. Has the approved Stormwater Management Plan with proof of approval been ? Yes ? No attached? 4. DWQ Stormwater Program Review ? Coastal counties 4a. Which of the following state-implemented stormwater management programs apply ? HQW ? ORW (check all that apply): ? Session Law 2006-246 ? Other: 4b. Has the approved Stormwater Management Plan with proof of approval been attached? ? Yes ? No 5. DWQ 401 Unit Stormwater Review 5a. Does the Stormwater Management Plan meet the appropriate requirements? ? Yes ? No 5b. Have all of the 401 Unit submittal requirements been met? ? Yes ? No Page 9 of 11 PCN Form - Version 1.3 December 10, 2008 Version F. Supplementary Information 1. Environmental Documentation (DWQ Requirement) 1a. Does the project involve an expenditure of public (federal/state/local) funds or the ? Yes ® No use of public (federal/state) land? 1 b. If you answered "yes" to the above, does the project require preparation of an environmental document pursuant to the requirements of the National or State ? Yes ? No (North Carolina) Environmental Policy Act (NEPA/SEPA)? 1c. If you answered "yes" to the above, has the document review been finalized by the State Clearing House? (If so, attach a copy of the NEPA or SEPA final approval letter.) ? Yes ? No Comments: 2. Violations (DWQ Requirement) 2a. Is the site in violation of DWQ Wetland Rules (15A NCAC 2H .0500), Isolated Wetland Rules (15A NCAC 2H .1300), DWQ Surface Water or Wetland Standards, ? Yes ® No or Riparian Buffer Rules (15A NCAC 2B .0200)? 2b. Is this an after-the-fact permit application? ? Yes ® No 2c. If you answered "yes" to one or both of the above questions, provide an explanation of the violation(s): 3. Cumulative Impacts (DWQ Requirement) 3a. Will this project (based on past and reasonably anticipated future impacts) result in ? Yes ® No additional development, which could impact nearby downstream water quality? 3b. If you answered "yes" to the above, submit a qualitative or quantitative cumulative impact analysis in accordance with the most recent DWQ policy. If you answered "no," provide a short narrative description. 4. Sewage Disposal (DWQ Requirement) 4a. Clearly detail the ultimate treatment methods and disposition (non-discharge or discharge) of wastewater generated from the proposed project, or available capacity of the subject facility. N/A Page 10 of 11 PCN Form - Version 1.3 December 10, 2008 Version 5. Endangered Species and Designated Critical Habitat (Corps Requirement) 5a. Will this project occur in or near an area with federally protected species or ? Yes ® No habitat? 5b. Have you checked with the USFWS concerning Endangered Species Act ? Yes ® No impacts? 5c. If yes, indicate the USFWS Field Office you have contacted. El Raleigh ? Asheville 5d. What data sources did you use to determine whether your site would impact Endangered Species or Designated Critical Habitat? http://www.saw.usace.army.mil/WETLANDS/esa 6. Essential Fish Habitat (Corps Requirement) 6a. Will this project occur in or near an area designated as essential fish habitat? ? Yes ® No 6b. What data sources did you use to determine whether your site would impact Essential Fish Habitat? http://ocean.floridamarine.org/efh-coral/ims/viewer.htm 7. Historic or Prehistoric Cultural Resources (Corps Requirement) 7a. Will this project occur in or near an area that the state, federal or tribal governments have designated as having historic or cultural preservation ? Yes ? No status (e.g., National Historic Trust designation or properties significant in North Carolina history and archaeology)? 7b. What data sources did you use to determine whether your site would impact historic or archeological resources? 8. Flood Zone Designation (Corps Requirement) 8a. Will this project occur in a FEMA-designated 100-year floodplain? ? Yes ? No 8b. If yes, explain how project meets FEMA requirements: 8c. What source(s) did you use to make the floodplain determination? Cecil T. Gurganus r December 9, 2009 X-2- <A Applicant/Agent's Printed Name Applicant/Agent's SignatAX ' Date (Agent s signature is valid only if an authorization etter from the applicant is provided. Page 11 of 11 PCN Form - Version 1.3 December 10, 2008 Version 83° 04' 00.00" V? 083° 03' VV 00.00" W 083° 02'00.00" f L 00 > ' l 4) I/ Z C) ?. ? .. ?,.?t7 r ` v 1 \ ELEV 2 xMlle 102 I 7r 14? ??? ` Ui' \ _; , ? r \ ?i y 1 ?fi'\ r,,1)??r z ?`? ? \ ? ? I 1 ko' ? ? , „// L' ?? I ? ? ?? /??J " ? '??;' /? err- /? ?•. \? ._ ?? y ?I NI,) t• / / j ?1? Y ? Y r ° c C> 1 ` j 911 I'T ? 01?" 4 I v , lv?_ I - 11, 11 -1 V_ C) WC S, C) ? /-> I ?. l l ( \I A r 11 ? 1 C /?? ?? 1 JJ )C 771 / o 83° 04' b0.00" Val 83° 03' 0.00" vit I 83° 02' 0.00" Z 0 0 O NV to M O z 0 0 0 M O Z 0 O O Q O M O r'-rinhf /(:1 9M5 RAanfnrh 1- N-.eunumrvu&t NNIRN [MOLINA IIAWooo ((/ Yxry+ ' _ >SNWI tE SEIZES fT(I.d.GNAMIICI Iu NE 117 apyF`>-Y, r y? 2 ?..?+? . ,¢d Y I ?E..? ^l IV u t i ? ,? 1 1':. ? 7 ? sd t x ?, r irV' t>? r" i'i't. ?Y,? ?d^?.os x• i ,? 1 I 4'v ? ?? 1 J ?? '°. , 4 1 g. 1 tt H .. rU- ? __ .rN? ? ? ? ?{? , 1 r .• 4 u ?' , ?'? '.h -y- <,.d ..-? j ? •,. siE{a`. r a 1 d .. ? S d i T 79i 1 t414Mry»' \ Nf' Area to be dredged' Y r # ; ` in front of intake .7r- x a«+l. J 4L Y w., M • 1 f ? l ' i b 1 i y. PEW Q?' } +?t, ter, ) 1 + '1} it , 7k { I )jjS -. ° .,.,r `•,. 1 'i?"L . l t 2 . ? t4 ..??,... '4p C „a ? 2 ?' {7*-`??,? 411 dG ? 1 ? ? ??• ?YO i /'f."^ -....?Y,? t d..? ? y y?.r } .,... .., Ei`?,+' f'? :'t ? *.^. ? . "..Qw VI lu, t ii ? t{ 4e, _ '1 ,n??a _ ? ? ? ' la?;, _ i C i.;` i a.alrN W LL. (.Ii.I 51Nn (+dnak.l S.wy + W'a1A...N1.w.rtlNl..w.. v+•, hn..., 6C Al_I.NOOp ` > ? •_ +i ?i'"F? -._ :??????'??- ACME Mapper 2.0 - 10.7 kin NE of Cocke County TN Page 1 of 1 htfr?•//monthr amm? nnm/ Walters Plant Debris and Sediment Removal Activity The Walters Plant is currently off-line and not generating due to a breech at the intake structure. We need to make the necessary repairs to bring the plant back on-line and provide power to our customers in our western region area. We cannot make safe, timely or effective repairs until we remove the debris and sediment in front to the intake screens to access and repair the breeched area. The area to be dredged is a localized area in front of the intake screens. The area of sediment disturbance is small (approximately 45 ft in length, 10 feet in width, and 4 ft in depth) and the intake is located on the Cataloochee Creek arm of the lake which drains pristine mountain waters. The area to be disturbed was previously dredged in 1980 when the major maintenance repairs were performed at the intake area, and we will be limiting our debris and sediment removal activities to the 1980 dredge footprint. A diver visual survey of the intake was conducted in 2001 and found no significant accumulation of debris or sediment in the proposed dredge footprint area immediately in front of the intake. A follow-up SONAR mapping survey of this same area in 2007 also showed very little sediment or debris accumulation at the intake. Therefore, the majority of the debris and sediment accumulation has occurred since 2007. Blue Ridge performed plant modifications to reduce dioxin inputs into the lake in 1989 and the accumulated sediment in the intake area dates to the period (1990 to present date) of reduced dioxin inputs with sediment loading into the lake. Of the debris and sediment to be removed, approximately 70% represents woody debris, plastics and manmade debris and 30% represents sediment. There is debris intermixed with the sediment. The debris and sediment will have to be removed together with a clamshell due to the debris being intermixed with the, sediment. The material will be placed in lined containers on a barge to prevent sediment and water from decanting and running off into the lake. The barge will be placed close to the dredging activity to minimize swing of the clamshell over open water and sediments/debris/water being unnecessarily dispersed into open water areas. The lined containers will be hauled to an approved landfill and sediment will not be placed on the lake shoreline where it would be exposed to erosion and runoff. The power plant will not resume operations until the dredging activity is conducted, screens are removed and replaced, and the breech area repaired. This entire process will take several weeks for the activities to occur before power plant is placed into service so there will be no suspended sediment entrainment downstream. We are limiting the area to be disturbed to the immediate area along the intake structure and not the entire length of the intake structure (approximately 54 feet in length). The lake level will be maintained at normal operating levels during the repair activities so sediments will not be exposed or disturbed throughout the lake. M a) L49 L ca r V IIl,. IlI? j! a ^^`` W ff ? r C ' ^ V/ . L /? eA L {\ ; As <C ^ -13 SIAN" M I j r^ 12A * ,. t a g V/ U) ? M-ft. P i V q. ? ? ? 4 a u t ^ E ? L l: I ? r9 t W u , CD ' O (D' O -h (D c n C (D Cl) cc ov (D (D n r O n N o' 'O O tC? CA tG?t CD CD n D CD N C CL (D (D v DO N N n 77 a Q N C O O U >O O -O U C N cu N 70 O Co O ?f :3ft LM C? I a . C? C O 4- j cu U O J L U N N ML W C O vJ L U D L- 4-1 vJ cu C 4- O \) VJ