HomeMy WebLinkAboutNCS000429_SPPP Ferg 2021 Complete_20220330PURPOSE
This Storm Water Pollution Prevention Plan (SPPP) is prepared in accordance with National Pollutant
Discharge Elimination System (NPDES) Permit No. NCS 00429, Part II, Section G (a) (b) & (c).
The purpose of this plan is to identify potential pollutant sources in contact with storm water, identify
spill prevention and response procedures, and implement Stormwater Control Measures (SCMs) to
eliminate non -permitted, non -storm water discharges.
The City of Gastonia is committed to the prevention of pollutant discharges to the surface waters of
Gaston County and the environment, and maintains the highest standards of Stormwater
pollution prevention through regular review, updating, and implementation of this Stormwater
Pollution Prevention Plan for the City of Gastonia Ferguson landscape and maintenance
facility.
Authorized Facility Representative:
Title:
Signature:
Date:
STORMWATER
POLLUTION PREVENTION
PLAN (SPPP)
Great Place. Great .People. Great Promise.
Developed for
CITY OF GASTONIA
Ferguson Parks and Recreation
Landscape and Maintenance Facility
GASTONIA, NORTH CAROLINA
Prepared in Accordance with
NPDES Permit No.
NCS 000429
August 2021
TABLE OF CONTENTS
1.0
INTRODUCTION...................................................................................................................1
2.0
SITE PLAN..............................................................................................................................1
2.1
SITE LOCATION.................................................................................................................. 1
2.2
SITE MAP...............................................................................................................................2
3.0
STORMWATER MANAGEMENT PLAN.......................................................................... 4
3.1
STORAGE PRACTICES.......................................................................................................4
3.2
WASTE DISPOSAL............................................................................................................... 4
3.3
SIGNIFICANT SPILLS AND LEAKS................................................................................. 4
3.4
NON-STORMWATER CERTIFICATION......................................................................... 4
3.5
EXPOSED SIGNIFICANT MATERIALS........................................................................... 4
3.6
EVALUATION OF STORMWATER CONTROL MEASURES (SCMs)........................4
4.0
SPILL PREVENTION AND RESPONSE PLAN(SPRP)..................................................5
5.0
PREVENTATIVE MAINTENANCE AND GOOD HOUSEKEEPING PLAN ............... 6
6.0
EMPLOYEE TRAINING...................................................................................................... 7
7.0
PLAN REVIEW AND AMENDMENT................................................................................ 8
APPENDICES
Appendix
A ................. Pollution Prevention Team Member Roster
B ................. Exposed Significant Materials
C ................. Reportable Spill Information Form
D ................. List of Significant Spills and Leaks
E ................. Employee Training Documentation Form
F ..................Non-Stormwater Discharge Assessment
And Certification
G ................. (1) Stormwater Discharge Outfall Qualitative Monitoring Report
(2) Equipment / Material/Area Inspection Form
(3) Accumulated Stormwater Release Log
H ................ Clean Up Contractors
J ................. SCM Evaluation and Implementation Form
1.0 INTRODUCTION
The City of Gastonia Ferguson landscape and maintenance facility is the headquarters from which the City
Staff group mows the grass at City -owned parks, cemeteries and other properties; takes care of trees, shrubs and
flowers at City -owned buildings, greenways and other facilities; picks up trash on City -owned properties and rights
of way; maintains ballfields; and provides free guidance for residents who have questions about trees or other
plants on their private property. This division does the landscaping and grounds keeping for 50 different areas,
including the five interchanges along I-85 in Gastonia.
2.0 SITE PLAN
2.1 SITE LOCATION
The City of Gastonia Ferguson landscape and maintenance Facility is owned and operated by the City
of Gastonia. The 80-acre facility (primarily a softball complex) is located at 1401 Golf Course Dr. in
Gastonia, North Carolina. There are City of Gastonia employees working at the facility during the
operating hours of 7:00 AM to 3:30 PM. All Stormwater runoff discharges to a municipal separate 3m
sewer system (MS4) and eventually discharges to a tributary to the headwaters of Catawba Creek, n
the Catawba River Basin. It is labeled Figure 1.
Figurel.
2.2 SITE MAP
The facility layout and surface drainage diagram (Figure 2.) demonstrates the drainage pattern of
Stormwater leaving the site.
The GPS coordinates for the outfalls are listed below.
SDO#001:35 ° 14'25 "N - 81 ° 10'47.9" W
SDO#002:35°14"26.9" N-81°10'49.7"
SDO#003:35°14'28" N- 81°10'50.9" W
FIGURE 2A.
A larger version of the site map is located in the back of the book labeled FIGURE 2A.
FIGURE 2B.
A larger version of the site map is located in the back of the book labeled FIGURE 2B.
3.0 STORMWATER MANAGEMENT PLAN
3.1 STORAGE PRACTICES
All equipment and vehicles are stored under cover, some being outdoors, some indoors. The
vehicle and equipment maintenance building is used to store barrels of used oil and other
automotive fluids.There are also three sheds with concrete flooring that are used to house heavy
equipment, maintenance equipment, salt, and soil.
3.2 WASTE DISPOSAL
There are several dumpsters located on -site, maintenance crews utilize these dumpsters to throw
away trash from various parks around the city. Once a week a maintenance crew focuses on cleaning
the surrounding park and area within the facility, this includes picking up any ground trash within
the area and replacing all trash bags in cans around the facility and park.
3.3 SIGNIFICANT SPILLS AND LEAKS
Material spills and leaks together are a potentially significant source of Stormwater pollution. If a
spill occurs, please refer to Section 4.0 Spill Prevention and Response Plan (SPRP) for response
procedures. A Reportable Spill Information Form (See Appendix C) must be completed and the
proper authorities notified for all spills of reportable quantities (greater than 25 gallons, hazardous
material spills or any amount that reaches surface waters). A historical record of spills should be
documented in the Significant Spills and Leaks Form (See Appendix D).
According to information from Mr. White, there have been no significant spills or leaks in excess of
reportable quantities in the past years.
3.4 NON-STORMWATER CERTIFICATION
Each Stormwater conveyance structure (drains, pipes, outfalls, ditches, etc.) must be evaluated for
the presence of non-Stormwater discharges. The non-Stormwater certification form (See Appendix
F) requires that facility personnel evaluate their facility's potential for non-Stormwater discharges.
The form should be completed subsequent to the evaluation of all Stormwater conveyance structures.
3.5 EXPOSED SIGNIFICANT MATERIALS
A description of significant material(s) that were exposed to Stormwater during the past three (3)
years and are currently exposed is included in Appendix B.
3.6 EVALUATION OF STORMWATER CONTROL MEASURES (SCMs)
Identify and evaluate the SCM(s) that are being implemented (See Appendix J) in the following
areas of the facility: loading and unloading, vehicle maintenance/washing, indoor/outdoor storage,
fueling, and waste disposal areas.
4.0 SPILL PREVENTION AND RESPONSE PLAN (SPRP)
Spill Response Team
Team Objectives: The goal of the Spill Response Team (See Appendix A) is to ensure that all
practical measures are taken to prevent spillage and in the event a spill occurs the "Team" will be
responsible for responding in accordance with the Spill Prevention Response Plan (SPRP).
The team will be responsible for general implementation of the Stormwater Pollution Prevention
Plan, and specifically responsible for the following tasks:
❖ Inspecting and maintaining existing Stormwater controls (including documentation
ofall inspections) and containment structures for potential pollution sources;
❖ Cleaning of all minor spills immediately and hiring an environmental cleanup company
to assist with major spills or spills involving hazardous material;
❖ Notifying the proper authorities when spills occur (see spill notification contacts...
Page 6);
❖ Maintaining spill response and safety equipment in areas where spills are likely to
occur;
❖ Maintaining records of all inspections, spills and cleanup activities for a minimum of
five (5) years;
❖ Revising the Plan when needed (documenting all significant spills, updating contact
names, etc.).
Shill Notification Contacts
Minor Spills (<25 gallons or any amount that reaches surface water or the stormwater
collection system)
❖ Contact Team Leader Tripp White at (704) 866 6840
❖ Notify the City of Gastonia Stormwater Division (COGSTD) from 8:00 - 5:00 at
(704) 869-1013, after hours contact on -call phone number at (704) 866-6843, if the spill
reaches surface waters or the storm water collection system;
❖ Notify North Carolina Department of Environment and Natural Resources (NCDENR)
Mooresville Regional Office at (704) 663-1699 within 24 hours if any spillage reaches
surface waters.
Major Spills (>25 gallons or any amount of Hazardous Material)
❖ Call 911 immediately if you don't have control over the spill or if there is a hazardous
material spill;
❖ Contact Team Leader Tripp White at (704) 866 6840
❖ Notify (COGSTD from 8:00-5:00 at (704) 869-1013, after hours contact on -call phone
number at (704) 866-6843, if the spill reaches surface waters or the storm water collection
system;
❖ Hire environmental clean-up contractor (if necessary) (See Appendix H);
❖ Notify NCDENR Mooresville Regional Office at (704) 663-1699 and The National
Response Center at 1-800-424-8802 within 24 hours;
❖ Complete and submit Reportable Spill Information Form (See Appendix Q.
5.0 PREVENTATIVE MAINTENANCE AND GOOD HOUSEKEEPING PLAN
The Stormwater Administrator will oversee all activities associated with preventative maintenance
and good housekeeping at the facility. The facility and the grounds should be maintained in a clean
and orderly fashion. This should include but is not limited to:
❖ Semi-annual inspection of equipment, material storage areas, and control devices for
condition and signs of pollution (See Appendix G);
❖ Maintain good housekeeping practices in all outside storage areas;
❖ Maintain adequate spill cleanup equipment such as: absorbent materials, drip pans, rags,
brooms, wet/dry vacuums, and disposal containers. These materials should be located in
the indoor/outdoor material storage areas and in the fuel storage area where it can be easily
accessed by the staff in the event of a spill.
❖ Stormwater that accumulates in the curbed area around the gasoline tanks must be
inspected for obvious signs of pollution prior to being released to the storm drain system.
An accumulated storm water inspection log has been provided as Appendix G. This log
will serve as inspection documentation and should be completed prior to opening the
manual release valve on the storm drain pipe.
❖ Safety equipment should be made available to staff, including: personal protective
equipment, fire extinguisher, and material safety data sheets (MSDS);
❖ Inspections of Stormwater Discharge Outfalls (SDO) will be conducted annually.
Documentation of SDO inspection will be documented using a Stormwater Discharge
Outfall Qualitative Monitoring Report, (See Appendix G). All documentation of
inspections shall be inserted into the SPPP and kept on file at the facility for a minimum
of five (5) years.
6.0 EMPLOYEE TRAINING
Employees at all levels shall be trained in the goals and components of the Plan. New employees
shall be trained within 90 days of their start date. Refresher training sessions should be scheduled
whenever changes are made to the plan and annually at the very minimum. The Public Works
Director or his/her designee shall provide employee training. Employee training including refresher
training must be documented (See Appendix E) and inserted into the SPPP. Documentation shall
include: employee signature, date, time, name of trainer, and type of training. All documentation
shall be maintained on file at the facility for a minimum of five (5) years.
7.0 PLAN REVIEW AND AMENDMENT
City of Gastonia Ferguson Facility
Stormwater Pollution Prevention Plan
The plan should be reviewed and/or amended if the facility introduces any change(s) that have a significant
effect on the potential for the discharge of pollutants to surface waters including but not limited to: changes
due to construction activity, changes in operation and maintenance, and changes in personnel. The Public
Works Director will have the responsibility for revising the plan so that it reflects current conditions at the
facility. The review and/or amendment of the plan will take place annually, at a minimum and all revisions
must be documented in the table below.
REPLACE/REVISE/UPDATE PAGE(S)-EXPLANATIONS
APPENDIX A: POLLUTION PREVENTION TEAM MEMBER ROSTER
City of Gastonia Ferguson Facility
Gastonia, North Carolina
Team Leader: Tripp White Title: Assistant Recreation Director
Office Phone: 7048666840
Responsibilities:
Members:
(1) Jerry Browning
Responsibilities:
Title: Maintenance Supervisor
Office Phone: 7042140721
(2) Chad
Responsibilities:
Title: Landscape Supervisor
Office Phone: 7042149119
(3) Greg Reynolds
Responsibilities:
Title: Downtown Maintenance Supervisor
Office Phone:
EXPOSED SIGNIFICANT MATERIALS
APPENDIX B:
City of Gastonia Ferguson Facility
Gastonia, North Carolina
Instructions: Describe the significant materials that were exposed to stormwater during the past three years and/or are currently exposed.
Exposed Material
Period of Exposure
Method of Storage
Material Management Practice
(e.g., pile, drum, tank)
(e.g. pile covered, drum sealed)
Material is stored under cover
None recommended
Existing measures are sufficient
Loading and Unloading Area
Performed under cover
None recommended
Existing measures are sufficient
Vehicle Maintenance Area
Covered area that drains to
None recommended
Existing measures are sufficient
Vehicle Washing Area and
oil/water separator and sanitary
Brine System
sewer system.
Material and pesticide
None recommended
Existing measures are sufficient
Indoor Material Storage Area
products are stored under
coverwith readily available
spill kit nearby
Storage area is covered with a
None recommended
Existing measures are sufficient
Outdoor Material Storage Area
structural canopy
Tanks are double -walled and
1. Inspect storm water
Implement Option 1
Fuel Storage Area
surrounded by a concrete
accumulated in diked area for
containment dike with a manually
indicators of pollution before
activated release valve
releasing water
Personnel ensure that no residual
1. Store materials under cover
A new building is being
Waste Disposal Area
liquid or solid materials remain on
constructed to store these
drums / totes / equipment prior to
materials.
storing in this area
APPENDIX C:
Reportable Spill Information Form
City of Gastonia Ferguson Facility
Instructions: A reportable spill is greater than 25 gallons or any amount that reaches surface water or
the storm water collection system. In the event that such a discharge occurs (refer to Page 6),
immediately contact 911 (City of Gastonia Fire Department) and notify NCDENR Mooresville
Regional Office and the National Response Center within 24 hours. Upon such an occurrence, this
form should be completed and forwarded to the proper authorities.
Spill Date and Time:
Type of Material Spilled:
Estimated Quantity Spilled:
Estimated Quantity Entering Surface Water:
Source of Spill:
Description of Affected Area:
Cause of Spill:
Corrective Action Taken:
Names of Parties/Agency Contacted:
APPENDIX D:
List of Significant Spills and Leaks
City of Gastonia Ferguson Facility
Instructions: Record below all significant spills and leaks that have occurred at the facility in the three years (3) prior to the effective date of the permit. If a spill or
leak should occur during the term of the storm water discharge permit; the pertinent information will be entered into this worksheet within 14 days. The individual
making the entry will date and initial the information.
Date
(mm/dd/yy)
Check One or Both
Location
Description
Response Procedures
Preventative
Measures
Taken
Completed
by:
(Initial/Date)
Spill
Leak
Type of
Material
Quantity
(Estimate)
Source
Reason
Cleanup Up Completed by:
Staff or Environmental Clean
Up Company
APPENDIX E:
Instructor:
Location:
Subject:
Employee SPPP Training Documentation Form
City of Gastonia Ferguson Facility
Date: Time:
Topics Covered:
Attendees:
Name:
Title:
Instructor Signature
Date
APPENDIX F:
NON -STORM WATER DISCHARGE ASSESMENT AND CERTIFICATION
City of Gastonia Ferguson Facility
Date of Evaluation
Stormwater
Conveyance Observed
During the Evaluation
Method Used to
Evaluate Discharge
Describe Result From
Evaluation of Non-
Stormwater Discharge
Identify Potential
Source(s)
Name of Person Who
Conducted the
Evaluation
Instructions
Discharges from all drains, pipes, outfalls, and other conveyances leading to the MS4 must be inspected and free of non-stormwater discharges. Non-stormwater certification should be
documented annually and should include the following information: description of the evaluation results, the method used, the date of evaluation, and on -site drainage points observed
during the evaluation.
APPENDIX G (2):
EQUIPMENT / MATERIAL / AREA INSPECTION
FORM
City of Gastonia Ferguson Facility
Date: Inspector:
Gastonia, North Carolina
Instructions: Two (2) times a year, the following areas should be inspected and documented on this form.
Exposed to
Signs of
Adequate
Equipment /
Stormwater
Condition
Pollution
Spill
Corrective Action Recommended
Material / Area
(Y/N)
(Good/Bad)
(No/Specify)
Controls
('/N)
Loading and
Unloading Area
Vehicle
Maintenance Area
Vehicle Washing
Areal Brine System
Indoor Material
Storage Area
Outdoor Material
Storage Area
Fuel Storage Tank
Area
Waste Receptacle
Area
APPENDIX G (3): ACCUMULATED STORMWATER RELEASE LOG
City of Gastonia Ferguson Facility
Gastonia, North Carolina
Instructions: Prior to opening the manual release valve on the storm drain pipe from the fuel tank storage area, the accumulated water must be inspected for
obvious pollution and documented on this form.
PARAMETER
Date:
Inspector's
Initials:
Color
(specify):
Odor (specify):
Clarity
(clear/cloudy)
Floating Solids
(Y/N)
Suspended
Solids (Y/N)
Foam
(Y/N)
Oil Sheen
(Y/N)
Other
Indicators
(specify)
APPENDIX H:
CLEAN UP CONTRACTORS
City of Gastonia Public Works Gastonia, North Carolina
Petroleum/Hazardous Material Spill Clean Up
• Carolina Environmental Response Team (can do lake cleanup) - 5648 Daphne Dr.,
Charlotte, NC 28269, Main: (877) 505-6799
• Contaminant Control Inc. - 281 Lane Parkway, Salisbury, NC 28146, 1-888-624-6555
(24 hours)
• Greenways Inc. of North Carolina - 31 Woodgate Ct, Durham, NC 27713, (919)
349-7665
• HAZ MAT Transportation and Disposal - 210 Dalton Ave., Charlotte, NC, 704-332-
5600
• HEPACO Inc. (can do lake cleanup) - 2711 Burch Dr., Charlotte, NC, 704-598-9782
• Safety HIeen Corp. -2320 Yadkin Ave., Charlotte, NC, 704-375-0098 (local number),
1-800-323-5040 (24 Hour)
• Spectrum -Nationwide Environmental Inc. - 117 Sylvania Ave., Charlotte, NC, 704-
334-2164
• FCC Environmental - 2115 Speedrail Ct., Concord, NC, 704-455-1333,
• Stanley Environmental Solutions, Inc. - 131 Mariposa Road, Stanley, NC 28164,
704-263-8186 (Office), 704-596-3353 (24 hour)
Sewer Spill Clean-up
• Bio-Nomic Services, Inc. - 530 Woodlawn Street Belmont, NC 28012., 704-529-0000
Toll Free: 1-800-782-6798
• Stanley Environmental Solutions, Inc. - 131 Mariposa Road, Stanley, NC 28164,
704-263-8186 (Office), 704-596-3353 (24 hour)
Bio-Hazard Cleanup
• Fagala Biohazard Specialists - 704-290-6095
• Bio Recovery Services - 1-888-611-3672.
STORMWATER CONTROL MEASURES (SCMs)
EVALUATION AND IMPLEMENTATION FORM
APPENDIX J:
City of Gastonia Ferguson Facility
Gastonia, North Carolina
Instructions: Evaluate and document the effectiveness of SCMs in the following areas of the facility: loading and unloading, vehicle
maintenance/washing, indoor/outdoor storage, fuel storage, and waste disposal areas. Implement any additional SCMs that are necessary to prevent
stormwater pollution.
FACILITY LOCATION
EXISTING SCM
NEW SCM OPTIONS
EVALUATION
Material is stored under cover
None recommended
Existing measures are sufficient
Loading and Unloading Area
Performed under cover
None recommended
Existing measures are sufficient
Vehicle Maintenance Area
Covered area that drains to oil/water
None recommended
Existing measures are sufficient
Vehicle Washing Area/ Brine
separator and sanitary sewer system
System
Material is stored under cover with
None recommended
Existing measures are sufficient
Indoor Material Storage Area
readily available spill kit nearby
Storage area is covered with a
None recommended
Existing measures are sufficient
structural canopy
Outdoor Material Storage Area
Tanks are double -walled and
1. Inspect storm water accumulated
Implement Option 1
surrounded by a concrete
in diked area for indicators of
Fuel Storage Area
containment dike with a manually
pollution before releasing water
activated release valve
Personnel ensure that no residual
1. Store materials under cover
A new building is being constructed
liquid or solid materials remain on
to store these materials.
Waste Disposal Area
drums /totes / equipment prior to
storing in this area
Environmental
Quality
Stormwater Discharge Outfall (SDO)
Qualitative Monitoring Report
For guidance on filling out this form, please visit https:Hdeq.nc.gov/about/divisions/energy-mineral-land-resources/
npdes-stormwater-gps
----------------
Permit No.: N/C/�G/ p /p /p /4 /2 /9 / �r Certificate of Coverage No.: N/GG/
Facility Name:
County:,r----------------------- ----------------------------------�
�tg� one o.
1---------------------------------------------------------------�
Inspector:
Date of Inspection:
Time of Inspection:
Total Event Precipitation (inches):
All permits require qualitative monitoring to be performed during a "measurable storm event."
A "measurable storm event' is a storm event that results in an actual discharge from the permitted site
outfall. The previous measurable storm event must have been at least 72 hours prior. The 72-hour storm
interval does not apply if the permittee is able to document that a shorter interval is representative for
local storm events during the sampling period, and the permittee obtains approval from the local DEMLR
Office.
By this signature, I certify that this report is accurate and complete to the best of my knowledge:
(Signature of Permittee or Designee)
1. Outfall Description:
Outfall No. Structure (pipe, ditch, etc.):
Receiving Stream:
Describe the industrial activities that occur within the outfall drainage area:
Page 1 of 2
SWU-242, Last modified 06/01/2018
2. Color: Describe the color of the discharge using basic colors (red, brown, blue, etc.) and tint
(light, medium, dark) as descriptors:
3. Odor: Describe any distinct odors that the discharge may have (i.e., smells strongly of oil, weak
chlorine odor, etc.):
4. Clarity: Choose the number which best describes the clarity of the discharge, where 1 is clear
and 5 is very cloudy:
1 2 3 4 5
5. Floating Solids: Choose the number which best describes the amount of floating solids in the
stormwater discharge, where 1 is no solids and 5 is the surface covered with floating solids:
1 2 3 4 5
6. Suspended Solids: Choose the number which best describes the amount of suspended solids in
the stormwater discharge, where 1 is no solids and 5 is extremely muddy:
1 2 3 4 5
7.
8.
9.
Is there any foam in the stormwater discharge? o Yes ® No.
Is there an oil sheen in the stormwater discharge? sqoYes G� No.
Is there evidence of erosion or deposition at the outfall? Q Yes Q� No.
10. Other Obvious indicators of Stormwater Pollution:
List and describe
Note: Low clarity, high solids, and/or the presence of foam, oil sheen, or erosion/deposition may be
indicative of pollutant exposure. These conditions warrant further investigation.
Page 2 of 2
SWU-242, Last modified 06/01/2018
J' r`Y. t`s - f $ 3• f .} St �. f tip} {" * I ■
`� PL :' � I, ' S }. �d'�,S � 4- ip 5 ��{` 55 1 ' •
A. � 1#> -. � 4 / y � t J Jy � Ll' f �•'.}� +SFr rs +Y r 1 �'. � i
vF• r .tnFF_ �� #�� �45. .ti' �,�+_�,J.y ¢r.rrr '' ' ��? Nyry
5F, x f - - - 'iik �'r•.+�? S'`.r 55 'r r * r _ir.Jf}f+x _ -lII�4il•`3Lillai •$ xiln �1':1 i '[• y
• ' r '� - -. 'ry r�Y.1 L 5e1 �_ Cti•d .. �F .It fff� T LLL{i LY 1V
d � � dr�c'�+• _ t . Fr 4 r�� v� . �r ram,,. '`� ' � 1)�ti I .Cl - [F�a _f �• f�.
�� ¢69 +gy,o''64� � � •¢t ft$ - �� +` •Irl,' J I rt _ � i •i - r .1`yv.. r`~ _ •r r��~4ti=5�_ '� - �, _
_ ,f,`� ,dy,�; '�. ! .rd. �, . �• �f{� L.. �y, •,'s'��'[' '� � rr 'c i-�'" '+ ~X ; + 'r-'.,i'�r�i� k' J
-
r*o- r
J.
v .Y .+'�5. •' _ ptiL
i 1 i •.1f¢ `. - z�rt�^SL]�f
V 4aT+A. F t... • J2 i ' .
44
16.
.f r1d 4 5 i�Li7�'JSAr+L7F.7.5}.p_a_it3 1 - - 5 -. - # rr f. I • i t
t I fr yyv} _vv.. 4 41 s 4 A
_ •l i'S 5 � Z i �y �vj rr r ��
5 55 55 • .y.. - �, ow i '; r i-7- y
'
,�.._ ., ••off �•� L r . 4; + ti ' ., ', r1 ' .y � r �;r• 6.7.1.
'•' 4 .
y 55irrr y Jti' i' }yy �15 dd �¢,
tl. 14 1
X/J*1
AL
29
4 _
INI
Lr
-
L'
+r L r r
t 5 •�& t � ,� .l� Ier�ux�sa Irk
k t {, • � �`�d�d
VAT N
x
d
4.
4.
'h
�h
4