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HomeMy WebLinkAboutWQCS00142_NOV2021PC0456_20210913ROY COOPER. Governor ELIZABETH S. BISER Secretary S. DANIEL SMITH Director Shane Fox, Town Manager Town of Blowing Rock 1036 Main Street Blowing Rock, NC 28605 NORTH CAROLINA Environmental Quality September 13, 2021 SUBJECT: NOTICE OF VIOLATION Tracking Number: NOV-2021-PC-0456 Permit No. WQCS00142 Blowing Rock Collection System Watauga County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Blowing Rock Collection System on August 10, 2021. This inspection was conducted to verify the facility is operating in compliance with the conditions and limitations specified in Collection System Permit No. WQCS00142. A summary of the findings and comments noted during the inspection are provided in the enclosed copy of the inspection report. This inspection was conducted by Division of Water Resources staff from the Winston-Salem Regional Office. The following violation(s) were noted during the inspection: Inspection Area Description of Violation Part I. Performance Standards Paragraph 6. Capital Improvement Plan Operators were only able provide a project list during the inspection. The latest CIP available on the town's website is dated 2006 and there have been no apparent updates. Part II. Operations & Maintenance Requirements Paragraph 8. Line Cleaning Town did not clean total required in 2020, due in part to COVID. Part III. Records Paragraph 1. Required records Sufficient records not available during inspection for: 1. Part I, Para 4 FOG Program; 2. Part II, Para 2 Review of records; 3. Part IV, Para 3 Annual Report; and, 4. Part V, Para 3, Annual General Observation NORTH D E Dopartmom of Envimnmomni au.i` North Carolina Department of Environmental Quality Division of Water Resources Winston-Salem Regional Office 1450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105 336.776.9800 You are hereby reminded that pursuant to NC General Statute 143-215.6A, a civil penalty of not more than twenty- five thousand dollars ($25,000) may be assessed against any person who violates or fails to act in accordance with the terms, conditions, or requirements of a permit issued pursuant to NC General Statute 143-215.1. If you wish to provide additional information regarding the noted violation(s), request technical assistance, or discuss overall compliance, please respond in writing within ten (10) business days after receipt of this notice. If the violations are of a continuing nature, not related to operation and/or maintenance problems, and you anticipate remedial construction activities, then you may wish to consider applying for a Special Order by Consent (SOC). If you have any questions or concerns, please do not hesitate to contact Ron Boone with the Water Quality Regional Operations Section in the Winston-Salem Regional Office at 336-776-9800. Attachments: Compliance Inspection Report cc: Laserfiche LD_E NORTH CAROLINA Department of Environmental quaky Sincerely, DocuSiiggned by:by� %A. l . c%A.aCf 145B49E225C94EA... Lon T. Snider, Regional Supervisor Water Quality Regional Operations Section Winston-Salem Regional Office Division of Water Resources, NCDEQ North Carolina Department of Environmental Quality j Division of Water Resources Winston-Salem Regional Office 1450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105 336.776.9800 Compliance Inspection Report Permit: WQCS00142 Effective: 10/01/16 SOC: Effective: County: Watauga Region: Winston-Salem Contact Person: Marshall James Townsend Directions to Facility: System Classifications: CS2, Primary ORC: Marshall James Townsend Secondary ORC(s): On -Site Representative(s): Related Permits: Expiration: 09/30/24 Expiration: Title: ORC Owner : Town of Blowing Rock Facility: Blowing Rock Collection System PO Box 47 Blowing Rock NC 286050047 Phone: 828-295-5226 Certification: 996495 Phone: 828-295-5226 NC0027286 Town of Blowing Rock - Blowing Rock WWTP Inspection Date: 08/10/2021 Entry Time 02:OOPM Primary Inspector: Ron Boone Secondary Inspector(s): Patricia Lowery Reason for Inspection: Routine Permit Inspection Type: Collection system management and operation Facility Status: ❑ Compliant Not Compliant Question Areas: ▪ Miscellaneous Questions II Capital Improvement Plan ▪ Inspections ▪ Lines (See attachment summary) ▪ General ▪ Map ▪ Spill Response Plan ▪ Manholes Exit Time: 04:OOPM Phone: 336-776-9690 Inspection Type: Collection System Inspect Non Sampling ▪ Sewer & FOG Ordinances ▪ Reporting Requirements ▪ Spills ▪ Pump Stations Page 1 of 10 Permit: WQCS00142 Owner - Facility:Town of Blowing Rock Inspection Date: 08/10/2021 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Inspection Summary: Ron Boone and Tricia Lowery of the NC Division of Water Resources, Winston-Salem Regional Office, conducted a compliance evaluation inspection of the Town of Blowing Rock's wastewater collection system on August 10, 2021. Matthew Blackburn, James Townsend, and Trathen Greene, operators of the collection system, were present for the inspection. Results of the inspection are summarized in the following paragraphs: PERMIT PART I, PERFORMANCE STANDARDS Part I, Paragraph 2, system effectively managed, maintained and operated at all times. Observations: The system is very well operated and maintained. This appears to minimize spills and malfunctions. No spills have been reported in 2021, no spills reported in 2020, four spills reported in 2019. Compliance Status: Compliant Part I, Paragraph 3, sewer use ordinance (SUO) Observations: Complete SUO is posted on website and is acceptable. Compliance Status: Compliant Part I, Paragraph 4, educational and enforceable fats, oils and grease (FOG) program. Observations: FOG blurbs in newsletters sent to customers twice yearly with billing statement. Grease traps inspected at least twice yearly. Strongly recommend town create grease trap inventory. Traps are inspected twice yearly and inspections are well documented. Strongly recommend town keep copies of newsletters with FOG info in them on file for three years as documentation of this activity as required in Part III, Paragraph 1. Compliance Status: Compliant Part I, Paragraph 5, Capital Improvement Plan (CIP) Observations: CIP is posted on town's website but is dated 2006 with no apparent updates. Operators provided updated project list from 2014, but not an entire CIP. Compliance Status: Noncompliant Part I, Paragraph 6 no overflow or bypass structures. Observations: None observed during inspection. Operators stated none exist. Compliance Status: Compliant Part I, Paragraph 7 pump station contingency plan (PSCP) Observations: PSCPs reviewed and found to meet requirements. Compliance Status: Compliant Part I, Paragraph 8 pump station (PS) signage. Observations: Pump stations visited during inspection were properly posted. Operators stated all others a similarly posted. Compliance Status: Compliant Part I, Paragraph 9 PS security. Observations: PSs visited during inspection were properly secured. Operators stated all others are similarly secured. Compliance Status: Compliant Part I, Paragraph 10 requires PSs not employing automatic polling feature to have both audible and visual high water alarms. Observations: PSs visited have both audible and visible alarms as well as telemetry. Alarms at Chestnut Ridge PS did not initially work properly but a loose wire was repaired and proper operation restored immediately. Operators stated all other PSs are similarly equipped. Compliance Status: Compliant Part I, Paragraph 11 requires all newly constructed, modified and rehabilitated PSs be equipped with corrosion -resistant Page 2 of 10 Permit: WQCS00142 Owner - Facility:Town of Blowing Rock Inspection Date: 08/10/2021 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine coatings or encasements on all equipment and components. Observations: No conditions noted during inspection demonstrating non-compliance with this condition. Compliance Status: Compliant PERMIT PART IIOPERATION AND MAINTENANCE REQUIREMENTS Part II, Paragraph 1 properly designated operators and system visitation. Observations: Mr. Townsend and Mr. Greene are properly designated. No conditions noted demonstrating non-compliance with this condition. Compliance Status: Compliant Part II, Paragraph 2 requires Permittee develop and adhere to schedule for reviewing all documentation. Observations: It is apparent that Mr. Blackburn, Mr. Townsend, and Mr. Greene, all review all records at some point in the process. Inspectors are confident that areas of concern are readily noted and addressed. However, the process is not recorded. Town is compliant with this condition but non -compliant with permit Part III, paragraph 1, as it relates to this permit condition. Strongly recommend ORC sign or initial and date all such documentation to indicate and document his review of it. Compliance Status: Compliant Part II, Paragraph 3 requires Permittee to develop and adhere to schedule for testing emergency/standby equipment. Observations: Operators stated PS generators are exercised under load monthly. One PS (Grandfather) does not have on site generator but its capacity is very small and portable pumps, generators, and tank trucks used as backup for this PS. Compliance Status: Compliant Part II, Paragraph 4 requires Permittee to develop and implement a routine pump station inspection and maintenance program. Observations: PS logs are sufficient to meet pump station inspection requirements. Compliance Status: Compliant Part II, Paragraph 5 requires one fully operational spare pump capable of pumping peak flow to be maintained on hand for all PSs not meeting reliability requirements. Observations: Operators stated there are no simplex PSs and all duplex or greater PSs meet the specified reliability requirements. Compliance Status: Compliant Part II, Paragraph 6 spare pump requirements for simplex pressure sewer PSs. Observations: According to operators there are no such PSs in the system. Compliance Status: Not applicable Part II, Paragraph 7 requires rights -of -way and/or easements be properly maintained. Observations: ROWs maintained as needed. None observed during inspection that were not properly maintained. Compliance Status: Compliant Part II, Paragraph 8 requires Permittee clean 10 percent of gravity system yearly. Observations: System contains 15.8 miles of gravity sewer. Annual requirement is 8,343 feet. The town cleaned about 7,707 feet in 2020, falling short of requirement by about 600 feet. Compliance Status: Noncompliant Part II, Paragraph 9 requires containment and proper disposal of SSO materials. Permittee must maintain Spill Response Action Plan. Observations: An acceptable plan was reviewed during inspection. Compliance Status: Compliant Page 3 of 10 Permit: WQCS00142 Owner - Facility:Town of Blowing Rock Inspection Date: 08/10/2021 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Part II, Paragraph 10 requires Permittee to conduct on -site evaluations for all SSOs within two hours of first knowledge. Observations: No conditions observed indicating noncompliance with this requirement. Compliance Status: Compliant Part II, Paragraph 11 requires Permittee to restore system operation, remove solids and paper, sanitize ground area and restore surroundings for all SSOs. Observations: No conditions observed indicating noncompliance with this requirement. Compliance Status: Compliant PERMIT PART III, RECORDS Part III, Paragraph 1 requires that records be maintained to document compliance for three years. Observations: Sufficient records not available during inspection for the following permit conditions: Part I, Paragraph(4) - FOG Program; Part I, Part II Pargraph(2) — Records Review; Part IV Pargraph(3)—Annual Report; and, Part V Pargraph(3) — Annual General Observation. Compliance Status: Noncompliant Part III, Paragraph 2 requires Permittee to maintain SSO and complaint records for a minimum of three years. Observations: SSO and complaint records available during inspection and considered compliant with this requirement. Please note that NC General Statute 143-215.1C requires press releases be kept for one year after issuance. Compliance Status: Compliant Part III, Paragraph 3 requires Permittee to maintain an up-to-date, accurate, comprehensive map of the system. Observations: System is fully mapped using computer software, including all required attributes, and information continues to be updated as needed. Compliance Status: Compliant Part III, Paragraph 4 requires Permittee to maintain records of all of the modifications and extensions to the system. System map should be updated within one year of construction completion of modifications/extensions. System description shall be updated with modification/extension information upon permit renewal. Observations: The operators fully acknowledged this requirement and no conditions demonstrating noncompliance were observed. Compliance Status: Compliant PERMIT PART IV, MONITORING AND REPORTING REQUIREMENTS Part IV, Paragraph 1 requires monitoring deemed necessary by Division shall be followed. Observations: No conditions demonstrating noncompliance with this condition were observed. Compliance Status: Compliant Part IV, Paragraph 2 requires Permittee verbally report to Division of Water Resources within 24 hours the occurrence or first knowledge of the occurrence reportable SSOs. Observations: No conditions were observed during inspection indicating noncompliance with this requirement. Compliance Status: Compliant Part IV, Paragraph 3 requires Permittee to meet annual reporting and notification requirements provided in North Carolina General Statute §143-215.1 C. Observations: Latest available annual report on website is dated 2016. No conditions noted indicating noncompliance with press release/public notice requirements. Compliance Status: Noncompliant PERMIT PART V, INSPECTIONS Page 4 of 10 Permit: WQCS00142 Owner - Facility:Town of Blowing Rock Inspection Date: 08/10/2021 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Part V, Paragraph 1 requires Permittee to inspect collection system regularly. Observations: Given the observations enumerated above and below this condition, the inspector believes the permittee is compliant with this condition. Compliance Status: Compliant Part V, Paragraph 2 requires PSs without Supervisory Control and Data Acquisition (SCADA) or telemetry systems be inspected everyday (i.e. 365 days per year). PSs so equipped shall be inspected once weekly. Observations: All five pump stations have telemetry and are inspected weekly. Compliance Status: Compliant Part V, Paragraph 3 requires a general observation of entire system be conducted each year. Observations: Operators are confident entire system is observed over course of each operational year and inspectors observed no conditions that lead them to believe otherwise. However, it is not recorded. The town is therefore considered compliant with this permit condition, but not compliant with permit condition Part III, paragraph 1, as it relates to this permit condition. Compliance Status: Compliant Part V, Paragraph 4 requires inspections of all high priority lines (HPL) be performed at least once per every six-month period of time. Observations: Records of required high priority line (HPL) inspections were reviewed and deemed compliant. Five is a relatively low number of HPLs in a town this size. Town should reevaluate entire system for existence of additional HPLs in accordance with definition of HPL found in permit condition Part V, Paragraph 4. Compliance Status: Compliant Page 5 of 10 Permit: WQCS00142 Owner - Facility:Town of Blowing Rock Inspection Date: 08/10/2021 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine General Is there a properly designated primary ORC and at least one back-up of proper grade? Are logs being reviewed by the system management or owner on a regular basis? # What is that frequency? # Are there any issues being addressed currently or any in the planning stages? Is there a specific pump failure plan available for all pump stations? Does plan indicate if pump parts/new pumps are in spare parts/equipment inventory? Are new/significantly upgraded pump stations equipped with anti -corrosion materials? Does the permittee have a copy of their permit? # Is permit expiring within the next 6 months? If Yes, has the Permittee applied for renewal? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ As generated • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ • ❑ Comment: Inspectors observed no conditions indicating documentation review is NOT being conducted, but the review is undocumented, as required in Part III Paragraph 1. Recommend ORC, BORC, or utilities superintendent sign or initial and date all generated documentation to indicate their review of it. Sewer and FOG Ordinances Is Sewer Use Ordinance (SUO) or other Legal Authority available? Does it appear that the Sewer Use Ordinance is enforced? Is there a Grease Control Program that legally requires grease control devices? What is the standard grease trap cleaning requirement in the FOG ordinance? Is Grease Control Program enforced via periodic inspections/records review? Is action taken against violators? # Have satellite systems adopted an equivalent or more stringent ordinance? Is grease/sewer education program documented with req'd customer distribution? # Are other types of education tools used like websites, booths, special meetings, etc? If Yes, what are they? (This can reduce mailing to annual.) Comment: The sewer use ordinance is posted on the town's website and is sufficient. Operators stated that they know all grease traps in the system and they are inspected a minimum of twice yearly. However, there is no grease trap list/inventory. An inventory should be created to keep track of all grease traps and provide a historical record for the city and new operators. Grease trap inspection records are sufficient. Operators stated FOG educational materials in the form of a newsletter blurb are distributed twice yearly along with mailed billing statements. The blurb was reviewed and also considered sufficient. The town should keep dated copies of all newsletters that include FOG educational material to document this activity in accordance with Permit Condition Part III, Paragraph 1. Capital Improvement Plan Has a Capital (CIP) or System Improvement Plan been developed and adopted? Is it designated for wastewater only or does it have a dedicated section? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Monthly Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ Page 6 of 10 Permit: WQCS00142 Owner - Facility:Town of Blowing Rock Inspection Date: 08/10/2021 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Does CIP cover three to five year period of earmarked improvements? Does CIP include description of project area? Does CIP include description of existing facilities? Does CIP include known deficiencies? Does CIP include forecasted future needs? • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Comment: The CIP is very outdated and needs to be reaccomplished and kept updated perpetually. The latest copy on the city's website is dated 2006. Map Is there a overall sewer system map? Does the map include: Pipe Type (GS/FM) Pipe sizes Pipe materials (PVC, DIP, etc) Pipe location Flow direction Approximate pipe age Pump station ID, location and capacity # Force main air release valve location & type # Location of satellite connections Is the map being updated for changes/additions within 1 year of activation? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Comment: Map is fully digitized using GIS software and most data points for the required attributes are known and saved in the system. Updates are made as needed to correct and/or add information. Reporting Requirements # Have there been any sewer spills in the past 3 years? If Yes, were they reported to the Division if meeting the reportable criteria? If applicable, is there documentation of press releases and public notices issued? Is an Annual Wastewater Performance Report being filed with the Division, if required? Is the report being made available to all its sewer customers? # How is it being made available? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Website Comment: The town has annual reports for the collection system on their website up through 2016. Reports for 2017-2020 are not available on the website. Inspections Are adequate maintenance records maintained? Are pump stations being inspected at the required frequency? # Is at least one complete functionality test conducted weekly per pump station? Is there a system or plan in place to observe the entire system annually? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Page 7 of 10 Permit: WQCS00142 Owner - Facility:Town of Blowing Rock Inspection Date: 08/10/2021 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Is the annual inspection documented? # Does the system have any high -priority lines/locations? Are inspections of HPL documented at least every 6 months? Are new lines being added to the HPL list when found or created? ❑ • ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Comment: Operators are confident the entire collection system is observed over the course of every operational year and inspectors observed no conditions during the inspection that led them to believe otherwise. However, it is not recorded. The town is considered compliant with this permit condition, but not compliant with permit condition Part III, paragraph 1, as it relates to this permit condition. Spill Response Action Plan Is a Spill Response Action Plan available? Is a Spill Response Action Plan available for all personnel? Does the plan include: 24-hour contact numbers Response time Equipment list and spare parts inventory Access to cleaning equipment Access to construction crews, contractors, and/or engineers Source of emergency funds Site sanitation and cleanup materials Post-overflow/spill assessment Does the Permittee appear to respond within 2 hours of first knowledge of a spill? Comment: None Spills Is system free of known points of bypass? If No, describe type of bypass and location Are all spills or sewer related issues/complaints documented? # Are there repeated overflows/problems (2 or more in 12 months) at same location? # If Yes, is there a corrective action plan? Comment: None Lines/Right-of-Ways/Aerial Lines Please list the Lines/Right of Ways/Aerial Lines Inspected: Wastewater plant aerial. Are right-of-ways/easements maintained for full width for access by staff/equipment? If No, give details on temporary access: Is maintenance documented? Are gravity sewer cleaning records available? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ • ❑ Yes No NA NE • ❑ ❑ ❑ II El El El Page 8 of 10 Permit: WQCS00142 Owner - Facility:Town of Blowing Rock Inspection Date: 08/10/2021 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Has at least 10% of lines older than 5 yrs been cleaned annually? Were all areas/lines inspected free of issues? • ❑ • ❑ ❑ ❑ ❑ ❑ Comment: System contains about 15.8 miles of gravity sewer. Annual cleaning requirement is about 8,343 feet. The town cleaned about 7,707 feet in 2020, falling short of the requirement by about 600 feet. According to operators, this is due, in part, to COVID19, as well as other challenges and complications. Documentation of line cleaning activities is considered compliant. Manholes Please list the Manholes Inspected: Are manholes accessible? # Are manhole covers/vents above grade? Are manholes free of visible signs of overflow? Are manholes free of sinkholes and depressions? Are manhole covers present? # Are manholes properly seated? # Are manholes in good condition? # Are inverts in good condition? Is flow unrestricted in manholes? Are manholes free of excessive amounts of grease? Are manholes free of excessive roots? Are manholes free of excessive sand? Are manhole vents screened? Are vents free of submergence? Are manholes free of bypass structures or pipes? Comment: Pump Stations Please list the Pump Stations Inspected: Chetola Resort and Chest Nut Ridge # Number of duplex or larger pump stations in system # Number of vacuum stations in system # Number of simplex pump stations in system # Number of simplex pump stations in system serving more than one building How many pump/vacuum stations have: # A two-way "auto polling" communication system (SCADA) installed? # A simple one-way telemetry/communication system (auto -dialer) installed? For pump stations inspected: Are they secure with restricted access? Were they free of by-pass structures/pipes? Yes No NA NE ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ MI Yes No NA NE 5 0 0 0 0 5 • ❑ ❑ ❑ Page 9 of 10 Permit: WQCS00142 Owner - Facility:Town of Blowing Rock Inspection Date: 08/10/2021 Inspection Type : Collection System Inspect Non Sampling Reason for Visit: Routine Were wet wells free of excessive grease/debris? # Do they all have telemetry installed? Is the communication system functional? Is a 24-hour notification sign posted ? Does the sign include: Owner Name? Pump station identifier? # Address? Instructions for notification? 24-hour emergency contact numbers? Are audio and visual alarms present? Are audio and visual alarms operable? # Is there a backup generator or bypass pump connected? If tested during inspection, did it function properly? Is the back-up system tested at least bi-annually under normal operating conditions? # Does it have a dedicated connection for a portable generator? # Is the owner relying on portable units in the event of a power outage? # If Yes, is there a distribution plan? If Yes, what resources (Units/Staff/Vehicles/etc) are included in Plan? # Does Permittee have the approved percentage of replacement simplex pumps? Is recordkeeping of pump station inspection and maintenance program adequate? Do pump station logs include at a minimum: Inside and outside cleaning and debris removal? Inspecting and exercising all valves? Inspecting and lubricating pumps and other equipment? Inspecting alarms, telemetry and auxiliary equipment? Comment: None • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ❑ • • ❑ ❑ ❑ ❑ ❑ ❑ • • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ • ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ • ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Page 10 of 10