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HomeMy WebLinkAboutWQ0011825_Final Permit_20140911Akp '-w ,d MCDENR North Carolina Department of Environment and Natural Resources Pat McCrory Governor September 11, 2014 Maricoma Steele -Rowland AMAC Property's, Inc. 2919 Fayetteville Street Durham, North Carolina 27707 Dear Ms. Steele -Rowland: John E. Skvarla, III Secretary Subject: Permit No. WQ0011825 AMAC Property's Inc. (Lot 413) Single -Family Residence Wastewater Irrigation System Chatham County In accordance with your permit application renewal and major modification request received May 2, 2014, and subsequent additional information received August 15, 2014, we are forwarding herewith Permit No. WQ0011825 dated September 11, 2014, to AMAC Property's, Inc for the continued operation of the subject single-family residence wastewater treatment and irrigation facilities. Please note that this renewed permit shall become effective on December 1, 2014 (i.e. the day after the expiration date of the existing permit), which differs from the date of this letter. The modification to this permit includes changing the previously permitted sand filter treatment system, tablet chlorinator and spray irrigation system to an Advantex treatment system, ultraviolet disinfection with drip irrigation as the disposal method. This permit shall be effective from the date of issuance until November 30, 2019, and shall be subject to the conditions and limitations as specified therein. An extension shall be requested at least six months prior to the expiration of this permit. Upon receipt of the request, the Commission will review the adequacy of the facility described therein and, if warranted, will extend the permit for such period of time and under such conditions and limitations as it may deem appropriate. Please note that Condition I.3 references the requirement that the Permittee shall submit subdivided lot plats and property ownership documentation to the Division. In the event the permitted facility changes ownership or the Permittee changes their name, a formal permit modification request shall be submitted to the Division as outlined in Condition VI. 5. Please pay particular attention to the operation and maintenance requirements listed in Section III. Failure to establish an adequate system for collecting and maintaining the required operational information shall result in future compliance problems. Also note that Condition VI.6. requires the Permittee to retain a set of Division approved plans and specifications for the life of the facilities permitted herein. If any parts, requirements or limitations contained in this permit are unacceptable, the Permittee has the right to request an adjudicatory hearing upon written request within 30 days following receipt of this permit. This request shall be in the form of a written petition, conforming to Chapter 15OB of the 1636 Mail Service Center, Raleigh, North Carolina 27699-1636 Phone: 919-807-64641 Internet: http://portal.ncdenr.om/web/wq An Equal Opportunity 1 Affirmative Action Employer— Made in part with recycled paper Ms. Steele -Rowland September 11, 2014 Page 2'of 2 North Carolina General Statutes, and filed with the Office of Administrative Hearings at 6714 Mail Service Center, Raleigh, NC 27699-6714. Unless such demands are made, this permit shall be final and binding. One set of approved plans and specifications is being forwarded to you. If you need additional information concerning this matter, please contact Alice M. Wessner at (919) 807-6425 or alice.wessner@ncdenr.gov. Sincerely, hom s A. Reeder, Director Division of Water Resources cc: Chatham County Health Department (Electronic Copy) Raleigh Regional Office, Water Quality Regional Operations Section Kevin D. Davison, PE - Agri -Waste Technologies (Electronic Copy) Beth Buffington, Public Water Supply Section — Protection and Enforcement Branch (Electronic Copy) Central Files Digital Permit Archive (Electronic Copy) 11 In accordance with the provisions of Article 21 of Chapter 143, General Statutes of North Carolina as amended, and other applicable Laws, Rules and Regulations AMAC Property's, Inc. Chatham County construction and operation of a 480 gallon per day (GPD) single-family residence wastewater treatment and irrigation facility consisting of- a 1,250 gallon baffled septic tank; an AX20-RT Advantex treatment system consisting of a 800 gallon recirculation tank, an ultraviolet (LTV) disinfection system; a 3,500 gallon storage/pump tank; a 0.39 acre drip irrigation area consisting of a mixed hardwood cover crop with four disposal zones with a total of approximately 8,491 linear feet (LF) of dripper line; and all associated piping, valve, controls and appurtenances to serve AMAC Property's, Inc. (Hickory Trace Lane Lot 4B Parcel #72136), with no discharge of wastes to surface waters, pursuant to the application received July 11, 2014, and subsequent additional information received by the Division of Water Resources of August 15, 2014 and in conformity with the project plans, specifications, and other supporting data subsequently fled and approved by the Department of Environment and Natural Resources and considered a part of this permit. This permit shall be effective from the date of issuance until July 31, 2019, and shall be subject to the following specified conditions and limitations: 1. In accordance with 15A NCAC 02T .0 116, upon completion of construction and prior to operation of this permitted facility, a certification (attached) shall be submitted from a licensed North Carolina Professional Engineer certifying that the permitted facility has been installed in accordance with this permit, Division approved plans and specifications, and other supporting documentation, including the location of all monitoring wells as applicable. If this project is to be completed in phases and partially certified, the Permittee shall retain the responsibility to track further construction ap rp oved under the same permit, and shall provide a final certificate of completion once the entire project has been completed. Mail the Certification to the Division of Water Resources, Water Quality Permitting Section, 1636 Mail Service Center, Raleigh, NC 27699-1636. WQ0011825 Version 3.0 Shell Version 140707 Page 1 of 7 2. The Raleigh Regional Office, telephone number (919) 791-4200, shall be notified at least 48 hours in advance (excluding weekends and holidays) of operation of the installed facilities such that an in- place inspection can be made. Notification to the regional supervisor shall be made from 8:00 a.m. until 5:00 p.m. on Monday through Friday, excluding State Holidays. 3. By November 1, 2014, the Permittee shall submit subdivided lot plats as well as property ownership documentation to the Division. 4. No later than six months prior to the expiration of this permit, the Permittee shall request renewal of this .permit on official Division forms. Upon receipt of the request, the Division will review the adequacy of the facilities described therein, and if warranted, will renew the permit for such period of time and under such conditions and limitations as it may deem appropriate. Please note Rule 15A NCAC 02T .0105(d) requires an updated site map to be submitted with the permit renewal application. 5. In accordance with 15A NCAC 02T .0607, if a public or community sewage system is or becomes available, the subject single-family residence wastewater treatment and irrigation facilities shall be closed and all wastewater shall be discharged into the public or community sewage system within 180 days of its availability. Prior to the initiation of these connection activities, appropriate Division approval shall be received. 1. The subject non -discharge facilities shall be effectively maintained and operated at all times so there is no discharge to surface waters, nor any contravention of groundwater or surface water standards. In the event the facilities fail to perform satisfactorily, including the creation of nuisance conditions due to improper operation and maintenance, or failure of the irrigation areas to adequately assimilate the effluent, the Permittee shall take immediate corrective actions including Division required actions, such as the construction of additional or replacement wastewater treatment or disposal facilities. 2. This permit shall not relieve the Permittee of their responsibility for damages to groundwater or surface water resulting from the operation of this facility. 3. Application rates, whether hydraulic, nutrient or other pollutant, shall not exceed those specified in the following table: TABLE 1— APPLICATION LIMITATIONS Field Parameter Hourly Rate Yearly Max Units 1 01284 — Non -Discharge Application Rate 0.25 19.50 inches 4. The subject facility has been approved to land apply wastewater effluent on the following fields: TABLE 2 — IRRIGATION AREA INFORMATION Field Owner County Latitude Longitude Net Dominant Acreage Soil Series 1 AMAC Property's Inc. Chatham 35°50'52" 78°57'40" 0.39 Creedmoor Total 0.39 5. The Operation and Maintenance Agreement (attached) between the Permittee and the Division of Water Resources is incorporated herein by reference and shall be a condition of this permit. Noncompliance with the terms of the Operation and Maintenance Agreement shall subject the Permittee to all sanctions provided by North Carolina General Statutes § 143-215.6A to § 143-215.6C for violation of or failure to act in accordance with the terms and conditions of this permit. WQ001.1825 Version 3.0 Shell Version. 11.40707 Page 2 of 7 6. The irrigation system shall be connected to a rain or moisture sensor, which shall indicate when effluent application is not appropriate in accordance with Conditions IIIA. and I11.5. of this permit. 7. In accordance with 15A NCAC 02L .0107(i), the compliance boundary is established at the property boundar-y-Any exceedance—of—standards—at—the—com. pl-iance—bmundar-y—shal-l—require—action—ire accordance with 15A NCAC 02L .0106. 8. In accordance with 15A NCAC 02L .0108, the review boundary is established midway between the compliance boundary and the effluent disposal area. Any exceedance of groundwater standards at the review boundary shall require action in accordance with 15A NCAC 02L.0106. 9. The Permittee shall apply for a permit modification to establish a new compliance boundary prior to any sale or transfer of property affecting a compliance boundary. 10. The facilities permitted herein shall be constructed according to the following setbacks: a. The setbacks for irrigation sites permitted under 15A NCAC 02T .0600 shall be as follows (all distances in feet): i. Any habitable residence or place of public assembly under separate ownership: 100 ii. Any habitable residence or place of public assembly owned by the Permittee: 15 iii. Any private or public water supply source: 100 iv. Surface waters: 100 v. Groundwater lowering ditches: 100 vi. Surface water diversions: 25 vii. Any well with exception of monitoring wells: 100 viii. Any property line: 50* ix. Top of slope of embankments or cuts of two feet or more in vertical height: 15 x. Any water line from a disposal system: 10 xi. Subsurface groundwater lowering drainage systems: 100 xii. Any swimming pool: 100 xiii. Public right of way: 50 xiv. Nitrification field: 20 xv. Any building foundation or basement: 15 *a setback agreement is in place to waive the setback to property lines as required by 15A NCAC 02T .0606(a). b. The setbacks for storage and treatment units permitted under 15A NCAC 02T .0600 shall be as follows (all distances in feet): i. Any habitable residence or place of public assembly under separate ownership: 100 ii. Any private or public water supply source: 100 iii. Surface waters: 50 iv. Any well with exception of monitoring wells: 100 v. Any property line: 50 M. OPERATION AND MAINTENANCE REQUIREMENTS 1. The facilities shall be properly maintained and operated at all times. The facilities shall be effectively maintained and operated as a non -discharge system to prevent the discharge of any wastewater resulting from the operation of this facility. The Permittee shall maintain an Operation and Maintenance Plan pursuant to 15A NCAC 02T .0604(f). WQ0011825 Version 3.0 Shell Version 140707 Page 3 of 7 2. The installation of the Advantex AX20 recirculating filter units shall comply with the manufacturer's specifications. The Engineer's Certification shall serve as evidence that these specifications have been met. Upon the Water Pollution Control System Operators Certification Commission's (WPCSOCC) classification of the subject non -discharge facilities, in accordance with 15A NCAC 08G .0200 the Permittee shall designate and employ a certified operator in responsible charge (ORC) and one or more certified operator(s) as back-up ORC(s). The ORC or their back-up shall visit the facilities in accordance with 15A NCAC 08G .0200, and shall comply with all other conditions specified in the previously cited rules. 4. A suitable year round vegetative cover shall be maintained at all times, such that crop health is optimized, allows for even distribution of effluent and allows inspection of the irrigation system. 5. Adequate measures shall be taken to prevent effluent ponding in or runoff from the irrigation sites listed in Table 2 of Condition 111.4. 6. Irrigation shall not be performed during inclement weather or when the ground is in a condition that will cause ponding or runoff. 7. Only effluent from AMAC Property's, Inc. (Hickory Trace Lane Lot 4B Parcel #72136), shall be irrigated on the sites listed in Table 2 of Condition 11.4. 8. No automobiles or machinery shall be allowed on the irrigation sites except during equipment installation or while maintenance is being performed. 9. Public access to the irrigation sites and wastewater treatment facilities shall be prohibited. Fencing shall be provided to prevent access to the irrigation site (minimum 2 -strand wire) and treatment units shall be secured with locks on all tank accesses and control panels. 10. The residuals generated from the wastewater treatment facilities shall be disposed or utilized in accordance with 15A NCAC 02T .1100. 11. Diversion or bypassing of untreated or partially treated wastewater from the treatment facilities is prohibited. 12. Pump/dosing tanks shall have audible and visual alarms external to any structure. 13. Any excavation into bedrock shall be lined with a 10 millimeter (mm) synthetic liner. 14. A water -tight seal on all treatment/storage units or minimum of two feet protection from the 100 -year flood plain elevation shall be provided. 15. The Permittee is responsible for the operation and maintenance of the entire treatment and disposal system including, but not limited to, the following items: a. The septic tank shall be checked annually and pumped out as needed. The septic tank effluent filter shall be checked and cleaned at the same frequency as the septic tank. b. The ultraviolet disinfection unit shall be checked weekly. The lamps) and quartz sleeve(s) shall be cleaned or replaced as needed to ensure proper disinfection. c. The storage, pump, and alarm systems shall be inspected monthly. The scum layer shall be removed at the same interval as the septic tank is cleaned out. d. The system shall be inspected monthly'to make certain of the proper operation of the drip lines, that the system is free of leaks, that the vegetative growth allows a proper drip pattern, that the soil is assimilating the disposed treated wastewater with no surface runoff, and that no objectionable odors are being generated. WQ0011825 Version 3.0 Shell Version 140707 Page 4 of 7 A, 1. Any Division required monitoring (including groundwater, plant tissue, soil and surface water analyses) necessary to ensure groundwater and surface water protection shall be established, and an acceptable samplingreporting schedule shall be followed. 2. Noncompliance Notification: The Permittee shall report by telephone to the Raleigh Regional Office, telephone number (919) 791- 4200, 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 process unit failure (e.g., mechanical, electrical, etc.), due to known or unknown reasons, rendering the facility incapable of adequate wastewater treatment. b. Any facility failure resulting in a by-pass directly to receiving surface waters. c. Any time self-monitoring indicates the facility has gone out of compliance with its permit limitations. d. Ponding in or runoff from the irrigation sites. Any emergency requiring immediate reporting (e.g., discharges to surface waters, imminent failure of a storage structure, etc.) outside normal business hours shall be reported to the Division's Emergency Response personnel at telephone number (800) 662-7956, (800) 858-0368, or (919) 733-3300. Persons reporting such occurrences by telephone shall also file a written report in letter form within five days following first knowledge of the occurrence. This report shall outline the actions taken or proposed to be taken to ensure the problem does not recur. 1. The Permittee shall provide adequate inspection and maintenance to ensure proper operation of the wastewater treatment and irrigation facilities. 2. The Permittee or their designee shall inspect the wastewater treatment and irrigation facilities to prevent malfunctions, facility deterioration and operator errors resulting in discharges, which may cause the release of wastes to the environment, a threat to human health or a public nuisance. The Permittee shall maintain an inspection log that includes, at a minimum, the date and time of inspection, observations made, and any maintenance, repairs, or corrective actions taken. The Permittee shall maintain this inspection log for a period of five years from the date of the inspection, and this log shall be made available to the Division upon request. 3. Any duly authorized Division representative may, upon presentation of credentials, enter and inspect any property, premises or place on or related to the wastewater treatment and irrigation facilities permitted herein at any reasonable time for the purpose of determining compliance with this permit; may inspect or copy any records required to be maintained under the terms and conditions of this permit, and may collect groundwater, surface water or leachate samples. 1. Failure to comply with the conditions and limitations contained herein may subject the Permittee to an enforcement action by the Division in accordance with North Carolina General Statutes 143- 215.6A to 143-215.6C. WQ0011825 Version 3.0 Shell Version 140707 Page 5 of 7 2. This permit shall become voidable if the permitted facilities are not constructed in accordance with the conditions of this permit, the Division approved plans and specifications, and other supporting documentation. 3. This permit is effective only with respect to the nature and volume of wastes described in the permit application, Division approved plans and specifications, and other supporting documentation. No variances to applicable rules governing the construction or operation of the permitted facilities are granted, unless specifically requested and approved in this permit pursuant to 15A NCAC 02T .0105(n). 4. The issuance of this permit does not exempt the Permittee from complying with any and all statutes, rules, regulations, or ordinances, which may be imposed by other jurisdictional government agencies (e.g., local, state, and federal). Of particular concern to the Division are applicable river buffer rules in 15A NCAC 02B .0200; erosion and sedimentation control requirements in 15A NCAC Chapter 4 and under the Division's General Permit NCGO10000; any requirements pertaining to wetlands under 15A NCAC 02B .0200 and 02H .0500; and documentation of compliance with Article 21 Part 6 of Chapter 143 of the General Statutes. 5. In the event the permitted facilities change ownership or the Permittee changes their name, a formal permit modification request shall be submitted to the Division. This request shall be made on official Division forms, and shall include appropriate property ownership documentation and other supporting documentation as necessary. The Permittee of record shall remain fully responsible for maintaining and operating the facilities permitted herein until a permit is issued to the new owner. 6. The Permittee shall retain a set of Division approved plans and specifications for the life of the facilities permitted herein. 7. The Permittee shall maintain this permit until all permitted facilities herein are properly closed or permitted under another permit issued by the appropriate permitting authority pursuant to 15A NCAC 02T.01050). This permit is subject to revocation or unilateral modification upon 60 days notice from the Division Director, in whole or part for the requirements listed in 15A NCAC 02T.01 10. 9. Unless the Division Director grants a variance, expansion of the permitted facilities contained herein shall not be granted if the Permittee exemplifies any of the criteria in 15A NCAC 02T .0120(b). 10. The Permittee shall pay the annual fee within 30 days after being billed by the Division. Failure to pay the annual fee accordingly shall be cause for the Division to revoke this permit pursuant to 15A NCAC 02T .0105(e)(3). Permit issued this the I Ph day of September 2014 NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION omas 4fReeder, Director ivision of Water Resources By Authority of the Environmental Management Commission Permit Number WQ0011825 WQ0011825 Version 3.0 Shell Version 140707 Page 6 of 7 Permit No. WQ0011825 Single Family Residence Wastewater Irrigation AMAC Property's, Inc. September 11, 2014 AMAC Property's, Inc. (Hickory Trace Lane Lot 4B Parcel #72136) Chatham County F,,N(=TNF.F- ATIOIY ❑ Partial ❑ Final In accordance with 15A NCAC 02T .0 116, I, , as a duly registered Professional Engineer in the State of North Carolina, having the Permittee's authorization to ❑ periodically ❑ weekly ❑ fully observe the construction of the permitted facility, hereby state to the best of my abilities that due care and diligence was used in the observation of the construction, such that the facility was built within substantial compliance and intent of this permit, the Division approved plans and specifications, and other supporting documentation. •0 Any variation to this permit, the Division approved plans and specifications, and other supporting documentation has been documented in the attached as -built drawings, and shall serve as the Permittee's minor modification request to amend the permit accordingly. Provide a brief narrative description of any variations: Professional Engineer's Name Engineering Firm Mailing Address City State Zip Telephone E-mail NC PE Seal, Signature & Date 110 all) 'alkyl 01 V C1312F.1101 OKI Ely I a) IN V.111 RIM -41.1 as F.11 N W] MR1 04121 W X111 1; 109 010J R 9110AI IMMA 011 =011125 1, on , . By U.S. Postal Service: 1636 MAIL SERVICE CENTER By Courier/Special Delivery: 512 N. SALISBURY ST. RALEIGH, NORTH CAROLINA 27699-1636 RALEIGH, NORTH CAROLINA 27604 WQ0011825 Version 3.0 Shell Version 140707 Page 7 of 7 SOF wATFh'Q State of North Carolina \p L ;[Department of Environment and Natural Resources ; r Division of Water Quality ai U-1 15A ICAC 02T.0600 — SINGLE-FAMILY RESIDENCE WASTEWATER IRRIGATION SYSTEMS FORM: SFRWWIS O&M 06-11 Permit No. V40DI I Ba County: Chatham Property owner(s) as appearing on the recorded deed: AMAC PropertV's Inc. c/o Maricorna Steele Mailing address: 2919 Fayetteville Street, Durhain, NC, 27707 Facility address: Hickory Trace Lane Lot #413, Durham, NC, 27713 Irrigation Method: ❑ SPRAY ® DRIP I / We agree to operate and maintain the single-family residence wastewater treatment and irrigation system as follows: 1. The Permittee is responsible for the operation and maintenance of the entire wastewater treatment and irrigation system including, but not limited to, the following items: a. The septic tank shall be checked annually and pumped out as needed. b. The septic tank effluent filter shall be checked and cleaned annually. c. Accessible sand filter surfaces shall be raked and leveled every six months and any vegetative growth shall be removed manually. d. ❑ The tablet chlorinator shall be checked weekly. Wastewater grade tablets (calcium hypochlorite) shall be added as needed to provide proper chlorination (pool chlorine tablets shall not be used), OR The ultraviolet disinfection unit shall be checked weekly. The lamps) and quartz sleeve(s) shall be cleaned or replaced as needed to ensure proper disinfection. e. All pump and alarm systems shall be inspected monthly. f. The irrigation system shall be inspected monthly to ensure that the system is free of leaks, that all irrigation equipment is operating as designed, that vegetative growth does not interfere with the system inspection or operation, that the soil is assimilating the disposed treated wastewater with no visible runoff or ponding, and that no objectionable odors are being generated. 2. Failure to pay the annual fee shall be cause for the Division to revoke the permit pursuant to 15A NCAC 02T .0105(e)(3). 3. The Permittee's failure to properly operate this system is subject to a penalty up to $25,000 per day. 4. Failure to meet the permit conditions or violation of the State's surface water or groundwater regulations may void the permit. All owners appearing on the legally recorded property deed shall sign this Operation & Maintenance Agreement I / We understand the ab ve requir ents and agree to these terms as part of e issued permit. Owner Signature: '��` Date: Owner Signature: Date: FORM: SFRWWIS O&M 06-11 Page I of 1 State of North Carolina Department of Environment and Natural Resources Division of Water Resources (THIS FORM MA Y BE PHOTOCOPIED FOR USE AS AN ORIGINAL) The Division of Fater Resources will not consider this form complete unless all instructions are followed. Failure to follow instructions or to submit all required items will lead to additional processing and review time. For more information or.for arz electronic version of this, forms, visit our web site at: http: //portal. iicdenr. or g/web/wq/apsllau/applications. INSTRUCTIONS TO THE APPLICANT: ✓ Do not submit this form for review without a corresponding Non -Discharge Pennitting Unit application form. ✓ Any changes to this form will result in the application package being returned. ✓ Any other setbacks required by 15A NCAC Subchapter 02T other than those referenced below, cannot be waived through execution of this form. ✓ A copy of the completed and appropriately executed fonn must be provided to the property owner. AGREEMENT TO WAIVE SETBACKS AS REQUIRED BY 15A NCAC 02T .0506(a), .0506(b), .0606(a), .0706(a) and .1006(x) The undersigned property owner(s) hereby permits: Applicant's name: 'MAC ProperVs Inc. Complete mailing address. of applicant: 2919 Fayetteville Street City: Durham Telephone number:9( 19) 491-4766 State: NG Hereinafter referred to as the Permittee, to (check all that apply): ® Non -Discharge disposal of wastewater effluent within ❑ Non -Discharge disposal of wastewater effluent within ❑ Construct treatment and storage units within ❑ Construct treatment and storage units within 15 Zip 27707 Facsimile number: (� feet of the property line, feet of the identified residence, feet of the property line, feet of the identified residence. FORM: NDWSW 11-13 Page 1 of 2 The waived setbacks apply as shown on the attached snap and located at the following: L-ocation- ddress-of-property: Hickory Trace Lane Lot #4B City: Durham State: NC Zip: 27713 ❑ I certify that I ain a deeded property owner of above -referenced property and am authorized to make decisions regarding this property on behalf of other deeded property owners. Furthermore, I certify that I have read and understand this Agreement and do hereby grant permission to the Pennittee to dispose of wastewater effluent or construct wastewater treatment units as, specified herein. I further agree that upon the Division of Water Resources's issuance of a permit for the subject non-dischargesystem, I will record this waiver form with the appropriate Register of Deeds and provide the Permittee and Division of Water Resources with documentation of such. Property ow err(ns) name(s): AMAC Property's Inc. Signature /e A -0-,l (Z49M� .t . /f lt./ f/l"Y°J` 4"' t t -'1r-- Date: Signature: Date: NORTH CAROLINA, / UGC') C� COUNTY 1, �-►�a. �: ( �`�`/ , a Notary Public for y Vl kel-" County, North Carolina, c® do hereby certify that 5 G. "' c�`f'e�Ie� personally appeared before me this day and acknowledged the due execution of the foregoing instrument. Witness my hand and official seal this the day of SEAL ------ a 'T L c ___..-�__ E NOTARY PUBi-IC ilVAKE COUNTY, NO My Commission Epiro.s 7-19-2094 Signature of Notaiy Public My commission expires ;Z-l4-Zo1+ FORM: NDWSW 11-13 Page 2 of 2