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HomeMy WebLinkAboutNC0083313_Permit Modification_20170111Water Resources ENVIRONMENTAL QUALITY Ms. Valerie L. Smith Brookside Village Homeowners Association, Inc. C/O Two Trails LLC. 538 N. Main Street Hendersonville, North Carolina 28792 Dear Ms. Smith: ROY COOPER Governor S. JAY ZIMMERMAN Director January 11, 2017 Subject: Minor modification ofNPDES Permit NCO083313 Brookside Village W WTP Henderson County The Division has received and approved your request to transfer ownership of the subject permit. As a result, the Division hereby reissues NC0083313. This permit is issued pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between North Carolina and the U.S. Environmental Protection Agency dated October 15, 2007 (or as subsequently amended). Insert the attached page into your permit and discard the old page. This modified permit includes the following changes from your current permit: ➢ Change of ownership from Brookside Camp Village to Brookside Village Homeowners Association, Inc. ➢ Section A.(3) has been updated to require electronic submission of effluent data. Federal regulations require electronic submittal of all discharge monitoring reports (DMRs). If any parts, measurement frequencies or sampling requirements contained in this modification are unacceptable to you, you have the right to an adjudicatory hearing upon written request within thirty (30) days following receipt of this letter. This request must be in the form of a written petition, conforming to Chapter 150B of the North Carolina General Statutes, and filed with the Office of Administrative Hearings (6714 Mail Service Center, Raleigh, North Carolina 27699-6714). Unless such demand is made, this decision shall be final and binding. This permit is not transferable except after notice to the Division. The Division may require modification or revocation and reissuance of the permit This permit does not affect the legal requirements to obtain other permits which may be required by any other Federal, State, or Local governmental regulation. If you have any questions concerning this matter, please contact Brianna Young at (919) 807-6388 or via e-mail [brianna.young@ncdenr.gov]. cc: Central Files Asheville Regional Office NPDES File cere S. Jay Zimmerman, P. . Director, Division of Water Resources state of North Camlira I Envi onrnental Quality I Water Resources 1611 Mail service Cher I Raleigh, North Ca lim 27699-1611 919 707 9000 Permit NCO083313 STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY DIVISION OF WATER RESOURCES PERMIT TO DISCHARGE WASTEWATER UNDER THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, the Brookside Village Homeowners Association, Inc. is hereby authorized to discharge wastewater from a facility located at the Brookside Village Condos WWTP 59 Brookside Drive, Hendersonville Henderson County to receiving waters designated as Featherstone Creek in the French Broad River Basin in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III and IV hereof. This permit shall become effective January 11, 2017. This permit and authorization to discharge shall expire at midnight on November 30, 2020. signed this day January 11, 2017. ai aavvrva, AV AVaVaa Va ♦♦ K..Va X-0-K VVO - By Authority of the Environmental Management Commission Page 1 of 7 Permit NCO083313 SUPPLEMENT TO PERMIT COVER SHEET As of this permit issuance, any previously issued permit bearing this number is no longer effective. All previous NPDES Permits issued to this facility, whether for operation or discharge, are hereby revoked. Therefore, the exclusive authority to operate and discharge from this facility arises under the permit conditions, requirements, terms, and provisions included herein. Brookside Village Homeowners Association, Inc. is hereby authorized to: 1. continue to operate an existing 0.005 MGD extended -aeration type wastewater treatment system with the following components: ♦ equalization basin ♦ aeration basin ♦ clarifier ♦ tertiary filter ♦ chlorination ♦ dechlorination ♦ effluent pump station ♦ sludge holding facilities these facilities located at the Brookside Village Condos, 59 Brookside Drive in Hendersonville, Henderson County, and 2. discharge from said treatment works via Outfall 001, a location specified on the attached map, into Featherstone Creek [stream segment 6-55-12], a waterbody currently classified C within subbasin 04-03-02 [HUC: 06010105] of the French Broad River Basin. Page 2 of 7 Permit NCO083313 PART I A. (L) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS [NCAC 02B.0400 et seq., 02B.0500 et seq.] During the period beginning on the effective date of this permit, the Permittee is authorized to discharge from Outfall 001. Such discharges shall be limited, monitored and reported 1 by the Permittee as specified below: En►s° ti--� Moanv� . , t (J.t'JiL0N S . � I, adrrleeroeS,_ vn ,x ;J, Dy.4f ,�� su ene� ie r r.� F= fix •w,tih,.A A�►e iyy ,, e Flow 50050 0.005 MGD Weekly Instantaneous went or Effluent Total Residual Chlorine ('IRC) 3 50060 28 µg/L 2/ Week Grab Effluent Dissolved Oxygen 00300 Weekly Grab U & D Temperature (°C) 00010 Weekly Grab U & D BOD, 5-day (20°C) C0310 10.0 mg/L 15.0 mg/L Weekly Grab Effluent BOD, 5-day (20°C) C0310 20.0 mg/L 30.0 mg/L Weekly Grab Effluent Total Suspended Solids C0530 30.0 mg/L 45.0 mg/L Weekly Grab Effluent Temperature (°C) 00010 Weekly Grab Effluent Dissolved Oxygen 00300 Daily Ave. not < 6.0 mg/L Weekly Grab Effluent pH 00400 Not < 6.0 or > 9.0 s.u. Weekly Grab Effluent Ammonia Nitrogen (NH3 as N) C0610 2.0 mg/L 10.0 mg/L 2/ Month Grab Effluent (Apr 1— Oct 31) Ammonia Nitrogen (NH3 as N) C0610 4.0 mg/L 20.0 mg/L 2/ Month Grab Effluent (Nov 1— Mar 31) Fecal Coliform (geometric mean) 31616 200 / 100 Lm1400100 ml 2/ Month Grab Effluent Footnotes: 1. The Permittee shall submit discharge Monitoring Reports electronically using DWR's eDMR submittal system [See Section A. (2)]. 2. Upstream (U) = at least 100 feet from discharge point, Downstream (D) = at Howard Gap Road. 3. The Division shall consider compliant all effluent TRC values reported below 50 µg/L. However, the Permittee shall continue to record and submit all values reported by a North Carolina -certified test method (including field certified), even if these values fall below 50 µg/L. Condition: The Permittee shall discharge no floating solids or foam. Page 3 of 7 Permit NC008331 A. (2.) ELECTRONIC REPORTING - DISCHARGE MONITORING REPORTS [G.S. 143-215.1(b)] Federal regulations require electronic submittal of all discharge monitoring reports (DMRs) and program reports. The final NPDES Electronic Reporting Rule was adopted and became effective on December 21, 2015. NOTE: This special condition supplements or supersedes the following sections within Part II of this permit (Standard Conditions for NPDES Permits): • Section B. (11.) • Section D. (2.) • Section D. (6.) • Section E. (5.) Signatory Requirements Reporting Records Retention Monitoring Reports 1. Repordna Requirements [Supersedes Section D. (2.) and 'Section E. (5.) Ua 1 The permittee shall report discharge monitoring data electronically using the NC DWR's Electronic Discharge Monitoring Report (eDMR) internet application. Monitoring results obtained during the previous month(s) shall be summarized for each month and submitted electronically using eDMR. The eDMR system allows permitted facilities to enter monitoring data and submit DMRs electronically using the internet. Until such time that the state's eDMR application is compliant with EPA's Cross -Media Electronic Reporting Regulation (CROMERR), permittees will be required to submit all discharge monitoring data to the state electronically using eDMR and will be required to complete the eDMR submission by printing, signing, and submitting one signed original and a copy of the computer printed eDMR to the following address: NC DENR / Division of Water Resources / Water Quality Permitting Section ATTENTION: Central Files 1617 Mail Service Center Raleigh, North Carolina 27699-1617 If a permittee is unable to use the eDMR system due to a demonstrated hardship or due to the facility being physically located in an area where less than 10 percent of the households have broadband access, then a temporary waiver from the NPDES electronic reporting requirements may be granted and discharge monitoring data may be submitted on paper DMR forms (MR 1, 1. 1, 2, 3) or alternative forms approved by the Director. Duplicate signed copies shall be submitted to the mailing address above. See "How to Request a Waiver from Electronic Reporting" section below. Page 4 of 7 Permit NCO083313 Regardless of the submission method, the first DMR is due on the last day of the month following the issuance of the permit or in the case of a new facility, on the last day of the month following the commencement of discharge. Starting on December 21, 2020, the permittee must electronically report the following compliance monitoring data and reports, when applicable: • Sewer OverflowBypass Event Reports; • Pretreatment Program Annual Reports; and • Clean Water Act (CWA) Section 316(b) Annual Reports. The permittee may seek an electronic reporting waiver from the Division (see "How to Request a Waiver from Electronic Reporting" section below). 2. How to Request a Waiver from Electronic Reporting The permittee may seek a temporary electronic reporting waiver from the Division. To obtain an electronic reporting waiver, a permittee must first submit an electronic reporting waiver request to the Division. Requests for temporary electronic reporting waivers must be submitted in writing to the Division for written approval at least sixty (60) days prior to the date the facility would be required under this permit to begin submitting monitoring data and reports. The duration of a temporary waiver shall not exceed 5 years and shall thereupon expire. At such time, monitoring data and reports shall be submitted electronically to the Division unless the permittee re -applies for and is granted a new temporary electronic reporting waiver by the Division. Approved electronic reporting waivers are not transferrable. Only permittees with an approved reporting waiver request may submit monitoring data and reports on paper to the Division for the period that the approved reporting waiver request is effective. Information on eDMR and the application for a temporary electronic reporting waiver are found on the following web page: h=://i)ortal.ncdenr.org/web/Wg/admin/boo/ipu/edmr 3. Sianatory Requirements [Supplements Section B. (11.) (b) and Supersedes Section B. (11.) Ml All eDMRs submitted to the permit issuing authority shall be signed by a person described in Part II, Section B. (I 1.)(a) or by a duly authorized representative of that person as described in Part II, Section B. (I 1.)(b). A person, and not a position, must be delegated signatory authority for eDMR reporting purposes. For eDMR submissions, the person signing *and submitting the DMR must obtain an eDMR user account and login credentials to access the eDMR system. For more information on North Carolina's eDMR system, registering for eDMR and obtaining an eDMR user account, please visit the following web page: http://portal.ncdenr.or web/wg/admin/bog/ipu/edmr Page 5 of 7 r Permit NC0083313 Certification. Any person submitting an electronic DMR using the state's eDMR system shall make the following certification [40 CFR 122.22] . NO OTHER STATEMENTS OF CERTIFICATION WILL BE ACCEPTED: "I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations." 4. Records Retention [Supplements Section D. (631 The permittee shall retain records of all Discharge Monitoring Reports, including eDMR submissions. These records or copies shall be maintained for a period of at least 3 years from the date of the report. This period may be extended by request of the Director at any time [40 CFR 122.41]. Page 6 of 7 Permit NCO083313 1 Featherstone Cr. � • flows SW) 3!, t - p t _ F sample Point Outfall001 • •. (Flows SW) FB 141 /• jo Mud Creek M d •• Interstate HWy e (flows NW) I_76 •r: `'n;. � �L`r�\ , ram.. - Brookside Village Homeowners Association, Inc. Brookside Village Condos WWTP Latt_Mde: 3r22'3VN State Grdd1Ouad: F9Nw/FrW-dWd Lonelbde: 82.28'01" W PermiBed Flom 0.005 MOD Beceivfn<Stmam: Featherstone Reek Stream Segment: 6.55-12 Stream Mars: C Sah-Basta: 04-03-02 Brabane Basln: French Broad Rnn RUC: 06010103 Facility Location am to Scak North NPDES Permit NC0083313 Henderson County Page 7 of 7 NC-DENR Division of Water Resources Water Quality Permitting Section 1617 Mail Service Center Raleigh, NC 27699-1617 December 12, 2016 )kECEI'VEDiNCDEQjD DEC 19 2016 Water Quality Permitting Section Re: Permit # NC0083313 Brookside Village Association/Brookside Village Homeowners Association, Inc., Hendersonville, NC Attached is an NCDENR permit name/ownership change request. The permit holder's name is being changed because we have filed an application for incorporation with the Secretary of State's office. The facility has always been at 59 Brookside Drive, Hendersonville, NC 28792, but on all the paperwork we've found it is shown as 630 Brookside Camp Road which is a half mile west of the actual location. A copy of the county tax map is attached confirming the physical location of the property at the corner of Brookside Drive and Brookside Camp Road. The new "legally responsible person" shown is the current treasurer of the HOA Board of Directors who is acting for the corporation. This position could be filled by a new person every year. Rather than constantly changing information on our permit, we want all mail sent in care of our property manager whose address is shown in section III. She is also shown as the facility contact person because she will always have the current information for who is actually handling the wwtp issues for the HOA. Our mailing address has not been correct for some time so we have not received the bill for our 2016 permit renewal, nor have we received notice of a violation which regional office personnel told us was pending. We would appreciate your having the bill and any recent notices re -sent to us at our correct address as soon as possible. Please call me at 828-606-7158 if there are any questions. (/Aze-j f �;,l "-"- 7 / )`/I Valerie L. Smith Treasurer, Brookside Village Homeowners Association, Inc. c/o Two Trails, LLC, 538 N. Main St., Hendersonville, NC 28792 cc: NCDENR Regional Office, 2090 US 70, Swannanoa, NC 28778, Attn: Janet Cantwell Encl: NCDENR Permit Name/Ownership Change Request Declaration of Condominium, first page, Howard and Gwendolyn Pendleton to Brookside Village Deed to Howard and Gwendolyn Pendleton Property Summary, Henderson County Real Property Data Henderson County GIS Property Tax Map showing Brookside Village property CERTIFIED MAIL, RETURN RECEIPT REQUESTED Pat McCrory Governor -t to NCDENR North Carolina Department of Environment and Natural Resources Division of Water Resources WATER QUALITY PERMITTING SECTION Donald R. van der VaartRprmtmv PERMIT NAME/OWNERSHIP CHANGE REQUEST This form is for ownership changes or name changes of NPDES wastewater permits. • "Permittee" references the existing permit holder • "Applicant" references the entitv annlvinn rrr ri,P L NPDES Permit No. (for which the change is requested): N C Q Q$ 3 3 1 3 or Certificate of Coverage #: N C G 5 IL Existing Permittee Information: a. Permit issued to (company name): Brookside Village Association b. Person legally responsible for permit: Audrey Ku kendall First MI Last Property Manager RECEIVEDINCDEQIDUVR Title Asheville Phoenix Prop., 55 Sweeten Creek Rd #101 DEC 19 2016 Permit Holder Mailing Address Asheville NC 28803- Water Quality Permitting Section City State Zip (828)277-8685 ( ) Phone Fax c. Facility name: Brookside Village Association d. Facility's physical address: 59 Brookside Drive Address Hendersonville NC 28792- City State Zip e. Facility contact person: Audrey Kuykendall (828) 277-8685 First / MI / Last Phone III. Applicant information: a. Request for change is a result of ❑ Change in ownership of the facility ® Name change of the facility or owner Ijother Please eviain: new property mgt company for condo assoc and corn t al ad B C. ec ph sic dress Permit issued to (company name): Brookside Village Homeowners Association, Inc Person legally responsible for permit: Valerie L Smith First MI Last Treasurer Title c/o Two Trails LLC, 538 N. Main Street Permit Holder Mailing Address Hendersonville NC 28792 City State Zip (828) 696-2173 kbrannonAtwotrailsllc com Phone E-mail Address Page I of Revised 7/01/10/4 d. Facility name: Brookside Villa a Homeowners Association, Inc. e. Facility's physical address: 59 Brookside Drive Address Hendersonville NC 28792_ f. Facility contact person: City State ZipKristi B Brannon First MI Last Pro a - - er Title (828) 696-2173 kbrannon(a twotrailsllc com Phone E-mail Address IV. Will the permitted facility continue to conduct the same commercial/industrial activities conducted prior to this ownership or name change? ® Yes ❑ No (please explain) If applicable, the applicant shall submit a major permit modification request to DWR. A major modification shall be defined as one that increases the volume, increases the pollutant load, results in a significant relocation of the discharge point, or results in a change in the characteristics of the waste generated. V. Required Items: THIS APPLICATION WILL BE RETURNED UNPROCESSED IF ITEMS ARE INCOMPLETE OR MISSING: I. This completed application is required for both name change and/or ownership change requests. 2. Legal documentation of the transfer of ownership (such as relevant pages of a contract deed, or a bill of sale) is re wired for an ownership change request. Articles of incorporation are not sufficient for an ownership change. Applicable regulations: 40 CFR 122.4I, 40 CFR 122.61 and 15A NCAC 02H .0114 ........................................................................................... 0......................... The certifications below must be completed and signed by both the permit holder prior to the change (Permittee), and the new applicant in the case of an ownership change request. For a name change request, the signed Applicant's Certification is sufficient. PERMITTEE CERTIFICATION (Permit holder prior to ownership change): I, Valerie L. Smith, attest that this application for a namelownership change has been reviewed and is accurate and complete to the best of my knowledge. I understand that if all required parts of this application are not completed and that if all required supporting information is not included, this application package will be returned as incomplete. Signature APPLICANT CERTIFICATION 12/9/2016 Date I, Valerie L. Smith, attest that this application for a name,/ownership change has been reviewed and is accurate and complete to the best of my knowledge. I understand that if all required parts of this application are not completed and that if all required supporting information is not included, this application package will be returned as incomplete. Signature 12/9/2016 Date PLEASE SEND THE COMPLETE APPLICATION PACKAGE TO: Division of Water Resources Water Quality Permitting Section 1617 Mail Service Center Raleigh, North Carolina 27699-1617 NPDES PERMIT NAME/OWNERSHIP CHANGE REQUEST Page 2 of 2 Revised 710112014 I r o. flLi y,,, nK�d bf kore motbl= Cet ana �'�� WITNP.55 mY bnnti���n.�nl f/�. G: nl i i ., ❑. 7n i Tli C9il UL L'r A., AU4aT.k. vk -- - -_ - [srar,t �P.YUk I1L \llL1t.`1Q� br I�1 f_n Votaiv: 2uTll M nla Cnon+� n tz`�Q �1n ti ��� 1 aSi� .ry=k rffe, OItA RRATN, e auc wn fnf tLo/ t0iagalog inn0,it m .rx n s WW1 _ Y, .r - NENJkRSUN LG G'JLY - THIS u "L'ARRITOY of CO:r'CDlli i�r001 �'Ex �r Ut d thi6 1 u9 d�y� o JRf ,{U guo6, -'1972, by'. HO-J L, PMLEIJ',�' -3Rr end wit u, . _N7O YJ T SEND L:iUN, Jr the County of H�j%eaon',` State pf -Nurkh Caroline hbfe n fte. c^11od ."Grant aru°, U I T N E S $E T H i and, WHEREAS, Said Gruatore own certain roal property hereinafter doscribed; " - WHEREAS, Said Grantors are in -the processor, improving said property by constructing thereon a 19—unit multi—fdnilly. olsuctura known a BR GCK<_ICE VILLAGE, which structure isbeing built principally of frame, brick end masonry and cansists,pF 4 buildings-twostories in height, all of -which is more particularly shown, on drawings hersto attached as Exhibit A; and, - WHEREAS,,Said `Grantors hereby ostabllsh_by this "Declaration a plan for' the Individual ownership of the real propert 'estatea consisting or spec" contained 'in each Or t yidmnof the area Fre apartment par Lmant unite in weed multieof, sa.tenmhture and thn co-ewnet sh' • rp by the individual real P and separate owners thereof, es tenants - ve erred t-.heral the remaining real preparty which es,herelnaFier, defined and reFerr ed to heroin as the "common areas and-facilitles,u NCdl,. THEREFORE,' Said Grantors, being the fee simple ownors of all that real estate located in Hoopers Creek Township, Henderson CpUnty 'North -Carolina, as described in deed from Robert H. Wynn and wife, Ora Wynn, doted December 13, . 1971 and recorded in Dead Rook. 492 at* Page 23G , Henderson -County Reg- istry, to which rarerehco'is heieby`m`ade for'.gre.certaihty of description, hereby"make the following declaration as to the divisions, covenants, restric tions, limitations, conditions and rises to which the "ahoUs-described real _ property and improvements thereon, consisting of a 19—Unit multi —family struc- ture and appurtenances,: may be put, hereby specifying that said declaration shall constitute covenants to run with the land andshallbe binding on; said Grantors,.their-hairs and assigns, and on all subsequent owners of all or any Part of , said-real'.property and improvements, together with their grantees, - successors, hairs, executors, administrators, :devisees or assignai A. Said Grantors, in aeder'to ustablieh a plan of condominium ownership ..For the. abo0e—described property. and. improvements, hereby covenant. and. agree ' - that they .hereby divide said. 'real property..into the Fdllowing separate free- hold esteteei.. ,.. 1. Nineteen (19) oaparately designated and legally. described Freehold estates consisting or the spaceorerase,; being the area.or space. contained in the, perimeter wells or each - ofthe ninatwen'-('19) apartment Units in said multi -family structures construptad on said property, said spacos being - defined, endreferredto herein, as "apartment.spaces." " 2. .one (1)-_freehold estate;cmuioting, of the remaining portion of the .real. proper ty is. described and referred to.herein'es ihu,"common hroas, and Facilitius." which dafinition"includes r.hs multi —family structures and the property upon which It is located, end specifically includea,. but is net limited - tu,the land, }roof,, main -Walls- 'slabs, elevators,elevator snaf.ts,-stslrcasee, lobbies; hails,parking spaces, etorage souceo, community end commereiel' facilities, recraution room, laundry room, carporte, treed, pavement, porches,' Property Summary - Henderson County Real Property Data Home Henderson County Real Property Data Property Summary Data last updated on: 10/18/2010 Ownership current as of: 1/1/2010 Parcel Number 9928453 PIN tr9661613503 Location Address Property Description 59 BROOKSIDE Lot * BROOKSIDE VILLAGE DR COMMON AREA Pale 1 of 2 S Go Map Tax Bill Property Search Go Property Owner: BROOKSIDE VILLAGE HOMEOWNERS ASSOC Owner's Mailing Address RESEARCH ADDRESS FLETCHER NC 28732 Property Location Address 59 BROOKSIDE DR dministrative Data Transfer Information Property Value Old Map# 9661.04 Deed Date 01/01/1990 Total Appraised VCS 952 Deed Book 000499 Land Value $64,500 City Deed Page 0025* Total Appraised Fire District MOUNTAIN HOME Revenue Stamps 0.00 Building Value Township MOUTAIN HOME Package Sale Date FIRE Package Sale Price Total Appraised PROPERTY Land Sale Date Value $64,500 Land Class OWNER'S Land Sale Price ASSOCIATION Spec Improvement Summary Elderly Exclusion District 1 Other Exemptions $64,500 Spec Total Units 0 District 2 Heated Area 0 Use History Value Deferred Parcel Historic Value Deferred Number 1 Total Deferred Value History Parcel Number 2 Total Assessed Value Acreage 2.15 Permit Date Permit # G 1'r)5 .^s 13Us-�1c�S�eZ 4V http://taxinfo.hendersoncountync.org/PropertySearch/propertysummary.aspx?R-ID=992... 10/ 18/2010 b?/amio GaMaps 4.0 f 1 Parcels • Sig 11e gig • Sea aes n * Address '• Ga'oa` Sit Enter A�dr�ss 1 col d� : 16 Q - 102 53 P� 0 65 69 (/ •SD •e 61 g� � B7 • 69 , 71 MOM) SA gas 102 •s 75 • i 168 74 1Qi •105 116 •1a6 167 S <L 117 124 20 u o ' 114 +11g •126 B9UK51-DE V11LLa6E NCn�FCw���S }SS�Ei�InC�,IwG 5ci 4'bUKSIbc v� NeN�RsPn1VlLL , � 4pm 9i0 % 1a42 173 T hW'./a"mdera*Ud000uut "aPe4rhnMNama=aIx20la,waa eri&g l,,, r 4"