NC0028941_Wasteload Allocation_19930512

NPDES DOCUMENT $CANNINO COVER SHEET
NC0028941
Pine Valley WWTP
NPDES Permit:
Document Type:
Permit Issuance
'.
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Speculative Limits
Complete File - Historical
Instream Assessment (67B)
Environmental Assessment (EA)
Permit
History
Document Date:
May 12, 1993
This; document iOs printed on reuise paper - ignore any
content on the resrernse ride

DIVISION OF ENVIRONMENTAL MANAGEMENT
May 12, 1993
MEMORANDUM
TO: Jule Shanklin
FROM: Susan A. WilsonpALt
THROUGH: Ruth Swanek
SUBJECT: Pine Valley Subdivision Draft Permit
Setman Branch, Yadkin River Basin (030706)
Rowan County
The Technical Support Branch (TSB) has received the letter addressed to Coleen Sullins
regarding Rachel Stogner's comments on the NPDES draft permit.
TSB has attached the USGS flow estimates that were used in devising the wasteload
allocation. As was TSB's policy at the time the WLA was performed, any USGS flow
later than 1985 was appropriate to use for renewal permits. The drainage area of 0.16
square miles is appropriate for the discharge point, which, by our records, is very near the
headwaters of Setman Branch. The 0.74 square mile drainage area which was used in the
1981 wasteload allocation was probably in error, as that drainage area corresponds to the
mouth of Setman Branch and not the discharge point, according to 1987 USGS
information.
The low flow study entitled "Procedures for Projecting Low Flow Statistics at an Ungaged
Site" is also attached. TSB suggests that the permittee first request updated flows for this
site before submitting plans to conduct a low flow study (as there is a remote possibility
that the flows have changed). The permittee should be informed that USGS will assess a
charge on this request.
Due to the Yadkin basinwide plan, this permit is up for reissuance in July 1994. TSB
recommends, due to the short term nature of this permit, that the permittee be allowed to
postpone the engineering evaluation until the next permitting period. This will allow the
facility adequate time to request new flows from USGS and to conduct their own
streamflow study if necessary. The study should be completed during the summer and fall
of this year. The results of the study should be available to USGS and TSB 180 days prior
to the next permit renewal (similar to the timeline given for the engineering evaluation).
Should the study indicate zero 7Q10 and zero 30Q2 values, then upon permit renewal in
1994 the facility should receive the standard zero flow policy language requiring the
engineering evaluation.
TSB recommends that the facility receive the existing limits and a condition in the permit
requiring the streamflow study, in lieu of the engineering evaluation. The permittee should
be aware that this may incur extra cost, since the flows may still be zero. Should this
situation Qccur the permittee would still be required to conduct the engineering evaluation
within the next permit renewal period, beginning in July 1994.
cc: Rex Gleason (Mike Parker), MRO

State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27604
James B. Hunt, Jr., Governor Jonathan B. Howes, Secretary
MEMORANDUM
To: MRO-Mike Parker
TSB -Susan Wilson
From: Jule Shankli
Subject: NC0028941, Pine N alley Subdivision
Draft Permit
Date: 4/20/93
Encl.: 2/9/93 letter from Rachel Stogner to Coleen Sullins
Please provide your respective inputs relative to the enclosure at your earliest
convenience so that all available feedback can be factored into a response to Ms. Stogner.
thanks
Regional Offices
Asheville Fayetteville Mooresville Raleigh Washington Wilmington Winston-Salem
704/251-6208 919/486-1541 704/663-1699 919/571-4700 919/946-6481 919/395-3900 919/896-7007
Pollution Prevention Pays
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

0'2i411/93 12:17
FAX [phone] EWS, RAYCO INC.
P01
•
NC LicenaejRC1378
RAYCO UTILITIES, INC.
4220 Highway 29
Harrisburg, NC 28075
• [phone]
February 9, 1993
Ms. Coleen Sullins
NPDES Permits Group
Division of Environmental Management
NC Department of EHNR
P.O. Box 27686
Raleigh NC 27611-7687
Subject
SC License 5341
: Draft NPDES Permit No. NC0028941
Rayco Utilities, Inc.
Pine Valley Subdivision Wastewater Treatment Plant
Rowan County
Dear Ms. Sullins:
This letter is in reference to the subject draft permit you
have scheduled to issue on February 15, 1993. I am writing
to express concerns with the draft that I hope may be
resolved prior to issuance.
Specifically, I am concerned with the two (2) items as
follows:
1) The proposed expiration date of July 31, 1994.
2) Part III E. Zero Flow Condition
I understand the rationale which is prompting issuance of
permits for less than the five (5) years allowed, but I feel
that this is an unreasonably short duration (fourteen and a
half months) that presents an unnecessary burden to us. We
ask that you reconsider and extend the proposed expiration
date for a more appropriate duration.
We have a more significant concern with the zero flow
condition. This subject was first alluded to in a letter
dated ,,January 21, 1992 from Mr. Michael L. Parker of your
Mooresville Regional Office. Mr. Parker's letter indicated
that there was a revised waste load allocation that would
result in the inclusion of certain conditions among which
would be an engineering evaluation to demonstrate that there
are no practical alternatives to the discharge.
Post-Ir brand fax transmittal memo 7671 r pea `.
S...
NADIR\luliiii\P"&ci
clYt. -
D4M5d
F_kk
Ph
one
1' 04 - '12- GCOG
Fe" r 901-1a3 ft

02i11/93 12:18 FAX [phone] EWS, RAYCO INC. P02
Ms. Coleen Sullins
Page 2
February 9, 1993
This concerned us then as it concerns us now. As such we
submitted a letter to Mr. Parker dated March 9, 1992 in
which we expressed our concern and requested information to
help us understand the reasoning behind this and the
procedures we could use to properly demonstrate that this is
not a zero 7Q10 flow stream. We received a response to this
request by letter dated March 25, 1992, from D. Rex Gleason.
This letter provided copies of some of the information
needed to develop the effluent limits and indicated that we
would 1e sent a copy of the procedures for conducting stream
flow measurements. To date, we have not received this
information.
In the information received, we found it interesting that
the drainage area was listed as 0.74 square mile in 1981 but
0.16 square mile in 1987 and since. Also, it is not clear
whether the 7Q10 was fully reevaluated during this last
renewal or the data (including the questionable drainage
area) was simply reused. The accuracy of the stream flow
estimate is extremely important.
The proposed zero flow condition in the draft permit
presents a significant, unnecessary and costly demand to
conduct an engineering evaluation of the feasibility of
eliminating the discharge. This should not be necessary
since, as we expressed in our letter (copy attached), we do
not believe this a zero flow stream.
The methods used by USGS to "estimate" flow conditions in
the receiving streams are not exact but are merely based on
the best information and methods available. In this
instance, we believe the estimate is simply in error and
certainly should be reviewed more closely in lieu of
proceeding with an evaluation of eliminating the discharge.
We recognize that the limited resources of your office and
USGS do not allow you to conduct more extensive evaluation
of every site. We accept that we should share in this
effort. I believe it would be more reasonable to allow us
to review the information used to determine the flow
estimated and, if necessary, conduct actual stream flow
gauging following recognized and acceptable methods to more
accurately demonstrate the conditions of the receiving
stream

• 02/ell/93 12:19 FAX [phone] EWS, RAYCO INC. P03
Ms. Col'een Sullins
Page 3
February 9, 1993
I ask that you please review the matters discussed in our
letter 'to Mr. Parker and provide us with the procedures for
stream; gauging.
Further, I request that you delete the current zero flow
condition from the permit and replace it with a condition
that requires that we conduct stream flow gauging, following
appropriate procedures, to define stream flow conditions
prior t7 permit expiration.
This would allow us to resolve the question of receiving
stream flow rather than accepting the estimated" flow and
moving into a costly and difficult evaluation of eliminating
the discharge. It is simply more prudent to resolve the
issue of stream flow first before proceeding unnecessarily
on a course that could ultimately cause great financial
distress to our utility and to the service public.
I appreciate your attention to our concerns and hope that
you understand that we want to work with you in resolving
these matters in a mutually beneficial way. I hope that you
will call me if you have any questions or if we can be of
any assistance.
Thank you for the opportunity to input to the permitting
process.
Sincerely,
14511
Rschel S. 6Stogner
President
RSS/le1

NPDES WASTE LOAD ALLOCATION
PERMIT NO.: NC0028941
PERMITTEE NAME:
FACILITY NAME:
Rayco Utilities, Inc.
Pine Vally Subdivision Wastewater Treatment
Facility Status: Existing
Permit Status: Renewal
Major Minor �l
Pipe No.: 001
Design Capacity: 0.025 MGD
Domestic (% of Flow): 100 %
Industrial (% of Flow):
Comments:
STREAM INDEX: 12-108-21-4-1
RECEIVING STREAM: Setman Branch
Class: C
Sub -Basin: 03-07-06
Reference USGS Quad: E16NE, Rowan Mills (please attach)
County: Rowan
Regional Office: Mooresville Regional Office
Previous Exp. Date: 5/31/92 Treatment Plant Class:
Classification changes within three miles:
> 3 mi.
Requested by:
Prepared by:
Reviewed by:
3 3 ts6,0)
Jule Shanklin
Bo -Di -
wq/Ft,
II
PLO IE
Date: 11/19/91
s&t56D
Date: e/5/9
Date:
1
Modeler
Date Rec.
#
SAW
/2 /91
' 3
Drainage Area (mi2 ) p, I C
Avg. Streamflow (cfs): U • 2-
7Q10 (cfs) 0 Winter 7Q10 (cfs) O 30Q2 (cfs) 0
Toxicity Limits: IWC
Instream Monitoring:
Parameters D. 0.
Upstream
Downstream i
% Acute/Chronic
FEE -AG coLi 1-6m'. CnnJDu&flytTl
Location per t.ERST IDo / UF5114.6.411k
Location At LFASr 3o0' DowiosTg_ektin
Effluent
Characteristics
Summer
Winter
BOD5 (mg/1)
10
I0
NH3-N (mg/1)
4
4
D.O. (mg/1)
(0
6
TSS (mg/1)
30
30
F. Col. (/100 ml)
Zoo
Zoo
pH (SU)
6 _ 1
14 The facility discharges into a stream with 7Q10/30Q2= cfs. Removal of
tdischarge is recommended if a more environmentally sound alternative is
available at an economically reasonable cost. An engineering report
evaluating alternatives to discharge is due 180 days prior to permit expiration
along with the permit renewal application. As part of the report, the cost of
constructing a treatment plant at the discharge point to meet limits of 5 mg/1
BOD5, 1 mg/1 NH3, 6 mg/1 DO, and 17pg/1 chlorine should also be included
E ; if there are no feasible alternatives to a surface discharge. Upon review of the
is results of the engineering report, the Division retains the right to reopen and
L modify this NPDES permit to require removal of the discharge or to revise
the permit limitations within a specified time schedule.

State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27604
James G. Martin, Governor
William W. Cobey, Jr., Secretary
George T. Everett, Ph.D.
Director
DIVISION OF ENVIRONMENTAL MANAGEMENT
March 25, 1992
Mrs. Rachel S. Stogner, President
Rayco Utilities, Inc
4200 Highway 29
Harrisburg, North Carolina 28075
Dear Mrs. Stogner:
REGEiVED
MAR 2 7 1992
TECHNICAL SUPPORT BRANCH
Subject: Revised Wasteload
Allocation
Pine Valley Subdivision
NPDES Permit No. NC0028941
Rowan County
This Office is in receipt of your letter dated March 9, 1992
concerning changes/revisions in the Wasteload Allocation (WLA) for
the subject facility. In your letter you indicated concern that the
existing limitations have been made substantially more stringent
since the Permit was last issued. You also indicated that the
changes/revisions may have been developed from information
regarding the receiving stream which is in error, consequently
effluent limitations beyond the capability of the existing
treatment facilities are being imposed. In addition, several items
of information were requested which dealt with the WLA process.
Please find enclosed a copy of the map used to identify the
subject facility's discharge location for the purposes of
promulgating the WLA (item No. 1 of your letter). Also please find
a copy of past WLAs (item No. 2 of your letter). As for the other
information you requested (items No. 3, 4 and 5 of your letter),
this informs ion can be obtained through our Technical Support
Branch, and y copy of this letter we are asking them to provide
you with the information.
REGIONAL OFFICES
Asheville Fayetteville Mooresville Raleigh Washington Wilmington Winston-Salem
704/251-6208 919/486-1541 704/663-1699 919/733-2314 919/946-6481 919/395-3900 919/896-7007
Pollution Prevention Pays
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

Mrs. Rachel Otogner
March 25, 1992
Page Two
If you have any questions regarding this matter, please
contact Mr. Michael L. Parker or me at [phone].
Enclos es
cc:- revor
MLP
lements
Sincerely,
D. Rex Gleason, P.E.
Water Quality Regional Supervisor

RAYCO UTILITIES, INC.
4200 Highway 29
Harrisburg, NC 28075
[phone]
fit, a Mrr. or NATO'
RESOURCES AND
M 'Z
�1TC License {TY DEYELOP
;AR 1 0 1992-
March 9, 1991
$ Vrr% Of imMOKMUITAL Watts .tg
ittORESIIUI aE WWtL orI
Mr. Michael L. Parker
Environmental Engineer II
Division of Environmental Management
NC Depart of EH and NR
PO Box 950
Mooresville, NC 28115
Subject: Revised Wasteload Allocation
Pine Valley Subdivision
NPDES Permit No. NC0028941
Rowan County
Dear Mr. Parker:
SC License 5341
This 4tter is in response to your letter dated January 21,
1992 w ich advised of your intent to incorporate certain
change0 and additional requirements in the forthcoming
renewed permit.
These matters are obviously of great concern and at this
point,;we do not fully understand the need for such drastic
changes. It appears that the basic concern is the estimated
flow in the receiving stream.
We have operated this facility for over five (5) years and
have never experienced a zero flow condition. We recognize
that the stream is relatively small but the stream is spring
fed and maintains a continuous base flow. This obversation
is supported by the fact that we have faithfully reported
upstream and downstream concentrations (as required by the
permits) and that, not only was there flow, but there were
no contraventions of water quality standards. It should be
obvious that not only is there flow in the stream but it is
sufficient to assimilate the wastes concentrations currently
being discharged.
It is our understanding that this is the intent of the
effluent limitations to protect the water quality of the
receiving stream. Considering this, we can see no
justification for tightening the existing limits.

Mr. Michael L. Parker
Page 2
March 9; 1992
In our opinion, the proposed changes are unnecessary and may
be proposed based on information that is in error. The
proposed effluent limits are well beyond the intended
capability of this facility and there is no practical
alternates to eliminate this discharge.
Due to the seriousness of these proposed changes and the
impact they would have, we ask that you reconsider and not
revise the existing limits or conditions. We hope that you
will agree that such changes are not needed.
However if you still intend to change the effluent limits,
we ask for your cooperation the exchanging information that
will h 1p us understand the reasons why and will help us
plan subsequent action. Specifically we ask that you
provide copies of the following information.
1. A copy of the USGS Map indicating the locating of the
discharge for which you based the waste load
allocation.
2. A copy of the original wasteload allocation which
in Ludes the 7Q10 and 30Q2 flow estimates and drainage
ba in for the original NPDES permit and subsequent
reissuances and renewals of the permit for this
facility.
3. A copy of the "...(zero flow policy)" which explains
the procedures being followed in changing these limits.
4. A Copy of the procedures to be followed in conducting a
site specific monitoring of stream flow to verify the
correct 7Q10 and 30Q2 of the receiving stream.
Please include directions on the appropriate procedures
to be followed in requesting to conduct such stream
monitoring per Division of Environmental Management
approval.
5. A
fo
opy of the flow estimate provided by USGS as a basis
this waste load allocations.
Again, we hope that you will reconsider and continue our
permit under the existing limits especially since these
limits !lave shown to protect the receiving steam.

Mr. Michael L. Parker
Page 3
March 9, 1992
Regardless, we appreciate your assistance in this regard and
will look forward to your reply. If you have any questions
or if we can be of assistance, please call.
Sincerely,
Rachel S. Stogner
President
RSS/bh

•
Facility Name:
NPDES No.:
Type of Waste:
Facility Status:
Permit Status:
Receiving Stream:
Stream Classification:
Subbasin:
County:
Regional Office:
Requestor:
Date of Request:
Topo Quad:
FACT SHEET FOR WAS I ELOAD ALLOCATION
Pine Valley Subd.
NC0028941
Domestic - 100%
Existing
Renewal
Setman Branch
C
030706
Rowan z
MR0714J,r
J. Shanklin
11/20/90
E16NE
Request # 6613
P. C. DEPT. OF NATURAL
RESOURCES AND
COMMUNITY DEVELOPNIEN'Jil
J nN 1 61992
DIVISI::N OF 'FVIVEMTAt MANAGEMEllt
MOBRESIILLE REGIONAL OFFICE
Stream Characteristic:
USGS #
Date:
Drainage Area (mi2):
Summer 7Q10 (cfs):
Winter 7Q10 (cfs):
Average Flow (cfs):
30Q2 (cfs):
IWC (%):
0212078402
1987
0.16
0.0
0.0
0.2
0.0
100.0
Wasteload Allocation Summary
(approach taken, correspondence with region, EPA, etc.)
Facility discharges to stream with 7Q10/30Q2 = O. Removal of discharge is recommended in
three years or new limits (page 2) will apply at that time. Facility must submit an engineering
report within 12 months of the effective date of this permit showing no alternative to surface water
discharge.
The facility has had 1 fecal coli violation in the past year. Instream data shows up and downstream
flow, but the facility did not indicate where the up and downstream flows were taken. Instream
DO's during the winter months are not much greater than those in summer (could be suspect).
Special Schedule Requirements and additional comments from Reviewers:
Clu o ktI6,1t NIA g a Rat-, ttE t
v,,ti- p-wok 2
Recommended by:
Reviewed by
Instream Assessment: t xfQ4A CLLk' --n
'Phal
Regional Supervisor: (/)(
Permits & Engineering:
Date: %Z72.,l
Date: 1 a /SO 4 /
Date: 1peiq
Date: / (f .v
FEB
�ra�N -ro k att. SuPPoivT 6\1 i•
f,(,;- t - OK'd MIS wait M.p• (Af2,0). 7ntip em- NEw FLAW L4NyuA;E

3
Existing Limits:
Wasteflow (MGD):
BOD5 (mg/1):
NH3N
DO (mg/1):
TSS (mg/1):
Fecal Col. (/100 ml):
pH (SU):
Recommen ed Limits:
Wasteflow (MGD):
BOD5 (mg(I):
NH3N (mg/1):
DO (mg/1):
TSS (mg/1):
Fecal Col. (/100 ml):
pH (SU):
Residual Chlorine (µg/1):
Oil & Grease (mg/1):
TP (mg/1):
TN (mg/1):
PARAMETERS
Monthly Average
Summer Winter WQ or EL
0.025 0.025
10 10
4 4
6 6
30 30
1000 1000
6-9 6-9
For three years:
Monthly Average
Summer Winter
0.025 0.025
10 10
4 4
6 6
30 30
200 200
6-9 6-9
(.Io
A ter three ye
nthly Ave
WQ or EL
WQ
WQ
WQ
ge
Su .► I er inter WQ or EL
0.02 1.025
5.0 10.0 WQ
1.0 1.8 WQ
6.0 6.0 WQ
30.0 30.0 WQ
20'd.0 00.0 WQ
I-9.0 :0-9.0 WQ
7.0 1 .0 WQ
Limits Changes Due To: Parameter(s) Affected
New procedures (zero flow policy) BOD5, NH3-N
_X_ Parameter(s) are water quality limited. For some parameters, the available load capacity of
the immediate receiving water will be consumed. This may affect future water quality based
effluent limitations for additional dischargers within this portion of the watershed.
OR
No parameters are water quality limited, but this discharge may affect future allocations.

• 4
INSTREAM MONITORING REQUIREMENTS
Upstream Location: at least 100 ft upstream
Downstream Location: at least 300 ft downstream
Parameters DO, Fecal coli, temperature, conductivity
Special inseam monitoring locations or monitoring frequencies:
MISCELLANEOUS INFORMATION & SPECIAL CONDITIONS
Adequacy of Existing Treatment
Has the facility demonstrated tie ability to meet the proposed new limits with existing treatment
facilities? Yes No ✓
1
If o, which parameters cannot be met? BoD/ A) #3 / Tau
W uld a "phasing in" of the new limits be appropriate? Yes _Z No
If yes, please provide a schedule (and basis for that schedule) with the regional
office recommendations:
t XatiA4
u
;477e,a-toea.r.,,,,....97:7)•=4LO /5- Its=4>fiLae
If no, why not?
Special Instructions or Conditions
Wasteload sent to EPA? (Major) _N (Y or N)
(If yes, then attach schematic, toxics spreadsheet, copy of model, or, if not modeled, then old
assumptions that were made, and description of how it fits into basinwide plan)
Additional
Information attached? _N (Y or N) If yes, explain with attachments.

/JCS gy¢
p co Ci7/G/7/E5 %/vc.
TMde^l SR. ,
c
9 A = 0.0zS t CrD CO?, Do/I.:CSTiC
1 �A�`Cv LCTr{,�, Prnl6 OLLEY SL %p.
q = o. 0�5 is+cp
v2/Z 078402!a
VA-a(b0,z
t 4 0.0
7Q(Qw=0.0
Ng3 _ N /4-
0 6 fr
TS53a/30
r uir- .Cor_r = 1ob1000
pFl - -9
1�ISC1lA4L W[ r Mc P4�7.
I
/Jo ,5rAFF
1 r'G[AL Cop/ ✓l oil-R!/a
iAJ f PAST Nt✓ -
JGS;CcAM 4 AowiU5T2 4M M0N17a211/c
TA(4 Dot ; 147 (Alp1C/Tl%. Of_ o� . VowN.`5"-?/ Ell.,Ait /IA.o/Ur702//U Z LoC47/o/JS
-F /ink Sce P_Ecr D,o, Na • 1nIG 5_ Ak Luc,( /4/ kit /t/:ElL)

STREAM DATA
INSTREAM SELF -MONITORING DATA
MONTHLY AVERAGES
(J-14 z s ( 47-6
Discharger: PINS uty S4617,
Permit No. .(90 Z094 j
Receiving Stream:
Upstream Location:
DATE
Dec-91
No -91
Oct-91
Sep-91
Aug-91
JuI-.9i
Jun-91
May-91
Apr-91
Mar-91
Feb-91
Jan-91
Dec-90
Nov-90
Oct-90
Sep-90
Aug-90
JuI-90
Jun-90
May-90
Apr-90
Mar-90
Feb-90
Jan-90
Dec-89
Nov-89
Oct-89
Sep-8
Aug-8
Jul-8
Jun-8
May-8
Apr-8
Mar-8
Feb-8
Jan-8
TEMP
D.O.
COLD
Sub -basin:
Downstream Location: 2
FECAL COLI.
9
9
9
9
9
9
9
9
14.1-66
1.0071)
117 (0)
io(20
6(781)
77,1(vac)
i (?A)
flig)C7f?
9,%,
Cr5( o)
/ of ,,o)
f3, 50,9
to6T,
.Z?(zig)
±7(se)
0'40.°r,
(4*,,(6o)
6,i(C86)
4-3(IID)
4r (17o)
r9- (zo)
,24
If7, 605
'78'7%,2
)¢(i5)
'7.o( .0)
to
o(to)
'2-3(7z)J,q/0
z.F3(4o)
P1 io)
?, 5(6,6)
(4(zo )
�� j
%C1
p
Q J,O ('/ 0)
1 k7,
290Cz.
9 7(t90
ri(.Z lz)
g.9(8,cb�
•
D.O.
COLD
FECAL CO
13(14O
'I,7i' 4,)
141(►7o
Z y3)
g.0(g.0Y
1270
4BC / /0
2((z-t
79(74)
le. (b►o
2S(z8
,,4(O,0)
toi S�;A,,•
.5z 6g0
7-7 C >
R, il1. `i
ZO813
3(24)
6.:1 (4,/
,
77zoo
37.((t
?.5 (7,4,)
1 - "
Zh tic
l ¢ OS
'7,0(6,
6o(cza
r4 (zo ,i
Io (1)
7.4(7,4
Gs %
? 4.(to)
-7•6. 07,2;
17 (30
(7
R.O(`�'.0)
14'd2o
So(2
r4 (11)
6r7(SrG�
ILs(io
Page 1