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Home My WebLink AboutNCG500633_Complete File_2012030556662-,- Bowden, Kevin From: Graznak, Jenny Sent: Tuesday, June 23, 2015 9:16 AM To: Bowden, Kevin Subject: RE: Craftique LLC Kevin, I talked to the ORC at the Mebane WWTP. He said that Craftique closed in 2012 and there has been no activity at the site in Mebane since. Please let me know if you need any other info about it. Thanks. /i Jenny Graznak NCDENR Division of Water Resources Winston-Salem Regional Office 450 W. Hanes Mill Road, Suite 300, Winston-Salem, NC 27105 Main Phone: (336) 776-9800 Direct Phone: (336) 776-9692 www.ncwater.ore /VO �C T vnyc .. Email correspondence to and from this address may be subject to the NC Records Law and may be disclosed to third parties. From: Bowden, Kevin Sent: Wednesday, June 17, 2015 2:05 PM To: Graznak, Jenny Subject: Craftique LLC Hi Jenny, We'll speak next week after you return to the office. This is not time sensitive. kevin Kevin Bowden Division of Water Resources 1617 Mail Service Center Raleigh, NC 27699-1617 (phone) 919.807.6397, (fax) 919.807.6494, (e-mail) Kevin.Bowden@ncdenr.gov E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties unless the content is exempt by statute or other regulation. 4 �I� NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Charles Wakild, P.E. Dee Freeman Governor Director Secretary March 5, 2012 Mr. Kirk Vickers, Maintenance Manager Craftique P.O. Box 428 Mebane, INC 27302 RECEIVED Subject: NOTICE OF VIOLATION MAR 13 2012 Craftique General Wastewater Permit Inspection CENTRAL FILES NPDES General Permit No. NCG500633 DWQ/BOG Alamance County Dear Mr. Vickers: On March 1, 2012, Jenny Graznak of this office met with you to perform a General Wastewater Permit Inspection at Craftique located at 1257 West Center Street in Mebane, North Carolina. This facility holds General Wastewater Permit No. NCG500633 under the National Pollutant Discharge Elimination System (NPDES) to discharge boiler blowdown and air compressor condensate. This type of inspection consists of two basic parts: a review of facility files and self - monitoring data, and an on -site inspection of the facility and its outfalls. This particular inspection evaluated four (4) areas and observations from each area are addressed below: 1. Permit The current permit became effective August 1, 2007 and will expire July 31, 2012. You will receive permit renewal information within the next several months. 2. Facility Site Review The facility has a boiler and an air compressor. The boiler has not been used since March of 2010 due to decreasing activity at the facility. The air compressor is tied to an oil/water separator. 3. Effluent/Receiving Waters Wastewater from the site discharges to an unnamed tributary to Haw Creek (Class C; NSW) in the Cape Fear River Basin. 4. Self -Monitoring Program It was determined during the inspection that the monitoring requirements for this permit have not been performed since 2008. You are required to sample on a semi-annual basis for the following parameters: Flow, Temperature, Oil & Grease, and pH. The failure to follow the monitoring requirements is a violation of the permit conditions, and therefore this inspection report is being sent as a NOTICE OF VIOLATION. We understand that business has significantly slowed down at Craftique and that the company is expected to shut down in the summer of 2012. However, as you are still manufacturing at the site and discharging air compressor condensate, you must perform the semi-annual monitoring requirements of the permit while you remain open. Otherwise, you could face enforcement action from our Division. Under state law, a daily civil penalty may be assessed against North Carolina Division of Water Quality, Winston-Salem Regional Office Location: 585 Waughtown St. Winston-Salem, North Carolina 27107 One Phone: 336-771-50001 FAX: 336-771-46301 Customer Service: 1-877-623-6748 North C arol i na Internet: www.ncwaterquality.org Naturally An Equal Opportunity 1 Affirmative Action Employer any person who violates or fails to act in accordance with the terms, conditions, or requirements of a permit. [Ref: NC General Statute 143-215.6A] If and when the facility does cease manufacturing at the site, you will need to rescind the permit. At that time, you should send a written request for permit rescission to the following address: Division of Water Quality Surface Water Protection Section — NPDES Compliance & Expedited Permitting Unit 1617 Mail Service Center Raleigh, NC 27699-1617 Please contact our office as soon as possible in order to discuss your options for handling this issue. Ms. Graznak has been trying to reach you by phone, but has been unsuccessful in reaching you as there is no voice mail or answering machine at the contact number. You can reach Ms. Graznak at (336) 771-4960 or me at (336) 771-4963. Sincerely, ev il tL4' av AL" W. Corey Basinger Regional Supervisor, Surface Water Protection Section cc: SWP — Central Files SWP — WSRO r United States Environmental Protection Agency Form Approved. EPA Washington, D.C. 20460 OMB No. 2040-0057 Approval expires 8-31-98 Section A: National Data System Coding (i.e., PCS) Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type 1 INI 2 1 51 31 NCG500633 111 121 12/03/01 117 18I � I 19I S I 20I I Remarks 211111111111111111IIIIIIIIIIII IIIIIII11111 IIIIIII6 Inspection Work Days Facility Self -Monitoring Evaluation Rating 81 QA ---------------------Reserved --- -------------- 67 I 169 70I 71 IU 721 NJ 73I I 174 751 I I I I I Li 80 t�l Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include Entry Time/Date Permit Effective Date POTW name and NPDES permit Number) Craftique, LLC 11:00 AM 12/03/01 07/08/01 Exit Time/Date Permit. Expiration Date 1257 W Center St Mebane NC 27302 12:30 PM 12/03/01 12/07/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Ot -er Facility Data Name, Address of Responsible Officialfritle/Phone and Fax Number Contacted Kirk Vickers,1257 W Center St Mebane NC 27302//919-563-1212/9195634082 Contato No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit 0 Self -Monitoring Program E Facility Site Review 0 Effluent/Receiving Waters Section D: Summary of Finding/Comments Attach additional sheets of narrative and checklists as necessary) (See attachment summary) Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Data Jennifer F Graznak WSRO WQ//336-771-5000/ Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date wAM4 Opt /-Id- N�Itt -4-D"M - lap-1 z,O" u %.L EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page # 1 Permit: NCG500633 Owner - Facility: Craftique, LLC Inspection Date: 03/01/2012 Inspection Type: Compliance Evaluation Permit (If the present permit expires in 6 months or less). Has the permittee submitted a new application? Is the facility as described in the permit? # Are there any special conditions for the permit? Is access to the plant site restricted to the general public? Is the inspector granted access to all areas for inspection? Comment: The current permit will expire July 31, 2012. Permit renewal information should be mailed within the next several months. Effluent Pipe Is right of way to the outfall properly maintained? Are the receiving water free of foam other than trace amounts and other debris? If effluent (diffuser pipes are required) are they operating properly? Comment: Wastewater from the site discharges to an unnamed tributary to Haw Creek (Class C; NSW) in the Cape Fear River Basin. Effluent Sampling Is composite sampling flow proportional? Is sample collected below all treatment units? Is proper volume collected? Is the tubing clean? # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)? Is the facility sampling performed as required by the permit (frequency, sampling type representative)? Comment: It was determined during the inspection that the monitoring requirements for this permit have not been performed since 2008. Yes No NA NE Cl ■ ❑ ❑ ■nnn n■00 ■nnn ■nnn Yes No NA NE nn■n n■nn n■nn nn■n n■nn n■nn Page # 3 NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Michael F. Easley, Governor William G. Ross, Jr., Secretary Coleen H. Sullins, Director July 30, 2007 Craig Shoemaker Craftique, LLC 1257 West Center Street Mebane, NC 27302 Subject: Renewal of coverage / General Permit NCG500000 Craftique, LLC Certificate of Coverage NCG500633 Alamance County Dear Permittee: In accordance with your renewal application [received on November 22, 20061, the Division is renewing Certificate of Coverage (CoC) NCG500633 to discharge under NCG500000. This CoC is issued pursuant to the requirements of North Carolina General Statue 143-215.1 and the Memorandum of Agreement between North Carolina and the US Environmental Protection agency dated May 9, 1994 [or as subsequently amended]. If any parts, measurement frequencies or sampling requirements contained in this General Permit are unacceptable to you, you have the right to request an individual permit by submitting an individual permit application. Unless such demand is made, the certificate of coverage shall be final and binding. Please take notice that this Certificate of Coverage is not transferable except after notice to the Division. The Division may require modification or revocation and reissuance of the certificate of coverage. Contact the Winston-Salem Regional Office prior to any sale or transfer of the permitted facility. Regional Office staff will assist you in documenting the transfer of this CoC. This permit does not affect the legal requirements to obtain other permits which may be required by the Division of Water Quality or permits required by the Division of Land Resources, Coastal Area Management Act or any other Federal or Local governmental permit that may be required. If you have any questions concerning the requirements of the General Permit, please contact Jim McKay [919 733-5083, extension 595 or j_ames.mckay ncmail.netl. Sincerely, for Coleen H. Sullins cc: Central Files Winston-Salem Regional Office / Surface Water Protection NPDES file 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 One 512 North Salisbury Street, Raleigh, North Carolina 27604 North Carolina Phone: 919 733-5083 / FAX 919 733-0719 / Internet: www.ncwaterquality.org Naturally An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10% Post Consumer Paper STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY GENERAL PERMIT NCG500000 CERTIFICATE OF COVERAGE NCG500633 TO DISCHARGE NON -CONTACT COOLING WATER, COOLING TOWER AND BOILER BLOWDOWN, CONDENSATE AND SIMILAR WASTEWATERS UNDER THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM 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, Craftique, LLC is hereby authorized to discharge Boiler Blowdown & Condensate from a facility located at Craftique, LLC 1257 West Center Street Mebane Alamance County to receiving waters designated as an unnamed tributary to the Haw River in subbasin 30602 of the Cape Fear River Basin in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III and IV hereof. This certificate of coverage shall become effective August 1, 2007. This Certificate of Coverage shall remain in effect for the duration of the General Permit. Signed this day July 30, 2007. for Coleen H. Sullins, Director Division of Water Quality By Authority of the Environmental Management Commission \NAT�c'Q �,3� Q Michael F. Easley, Governor State of North Carolina OG William G. Ross, Jr., Secretary > Department of Environment and Natural Resources O ~ Alan W. Klimek, P.E., Director Division of Water Quality November 22, 2006 Mr. Craig Shoemaker 1257 West Center Street Mebane, North Carolina Subject: General Permit No. NCG500000 Certificate of Coverage NCG500633 Craftique, LLC Alamance County Dear Mr. Shoemaker: In accordance with your application for discharge, the Division is forwarding herewith the subject Certificate of Coverage to discharge under the subject state-NPDES general permit. This permit is issued pursuant to the requirements of North Carolina General Statue 143-215 .1 and the Memorandum of Agreement between North Carolina and the US Environmental Protection agency dated May 9,1994 (or as subsequently amended). The following information is included with your permit package: • A copy of the Certificate of Coverage for your treatment facility ■ A copy of General Wastewater Discharge Permit NCG500000 • A copy of a Technical Bulletin for General Wastewater Discharge Permit NCG500000 If any parts, measurement frequencies or sampling requirements contained in this general permit are unacceptable to you, you have the right to request an individual permit by submitting an individual permit application. Unless such demand is made, the certificate of coverage shall be final and binding. Please take notice that this Certificate of Coverage is not transferable except after notice to the Division of Water Quality. The Division of Water Quality may require modification or revocation and reissuance of the certificate of coverage. This permit does not affect the legal requirements to obtain other permits which may be required by the Division of Water Quality or permits required by the Division of Land Resources, Coastal Area Management Act or any other Federal or Local governmental permit that may be required. If you have any questions concerning this permit, please contact Toya Fields at telephone number 919/733-5083, extension 551. Sincerely, -� „/Y_ / Alan W. Klimek, P.E. L cc: Central Files NPDES General Permit Files Winston Salem Regional Office, Surface Water Protection North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-1617 (919) 733-5083 FAX (919) 733-0719 On the Internet at http://h2o.enr.state.nc.us/ STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY CERTIFICATE OF COVERAGE NCG500633 GENERAL PERMIT NO. NCG500000 TO DISCHARGE NON -CONTACT COOLING WATER, COOLING TOWER AND BOILER BLOWDOWN, CONDENSATE AND SIMILAR WASTEWATERS UNDER THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM 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, Craftique, LLC is hereby authorized to discharge of boiler blowdown and condensate from a facility located at Craftique, LLC 1257 West Center Street Mebane Alamance County to receiving waters designated as an unnamed tributary to the Haw River in the Catawba River Basin in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, I1I and IV of General Permit NCG500000 as attached. This certificate of coverage shall become effective November 22, 2006. This Certificate of Coverage shall remain in effect for the duration of the General Permit. Signed this day November 22, 2006. 1 Alan W. Klimek, P.E., Director Division of Water Quality By Authority of the Environmental Management Commission Pi � • . sill � � �q ° Y*�, GT* h 650 + i + Discharge location o Q • r r • �� '�,, i WT •• r,��. rr 1. 414 r. 6 �` �� f y �+'♦ � � •"'ram r • +r ;, 'j i'' 00 Pee �l 'ter..,: • e � � / �•'�. �..r��/' � � � � � • J'�,.f �. r f` iM r '� r r • • s u1thLNW .�.. Craftique, LLC — NCG500633 USGS Quad Name: Mebane Lat.: 36°05'54" Receiving Stream: UT to Haw River Long.: 79°17'06" Stream Class: C NSW Subbasin: Cape Fear — 03 06 02 Facilityk { Location N Not to SCALE Craftique, NCG5OO633 Subject: Craftique NCG5OO633 From: Jenny Freeman <Jenny.Freeman@ncmail.net> Date: Fri, 17 Nov 2006 14:09:02 -0500 To: Toya Fields <Toya.Fields@ncmail.net> Hi Toya, Sorry for the delay is getting this information to you, but here it is. I visited with the folks at Craftique again today, in particular Kirk Vickers - Maintenance Manager. Their boiler blowdown discharges to a rip -rap lined ditch and then fizzles out before it gets even close to the pond in the back of the property. Stormwater and wastewater on the property ultimately drains to a Unnamed Tributary to Haw River (C; NSW). But truthfully, I don't think anything would ever reach that far. Everything looked a-ok during the site visit. Let me know if you need anything else from me. Thanks. Jenny Freeman NC DENR Winston-Salem Regional Office Division of Water Quality 585 Waughtown Street Winston-Salem, NC 27107 Voice: (336) 771-4960 FAX: (336) 771-4630 1 of 1 11/17/2006 2:32 PM Ak7T0_V*WA Division of Water Quality / Water Quality Section NCDENRNational Pollutant Discharge Elimination System NORTH C-LIN< DEPARTMENT OF ENVIRONMENT AND NAURAL RE60l1R- N C G 50 O O O U Date to NOTICE OF INTENT National Pollutant Discharge Elimination System application for coverage under General Permit NCG500000: Non -contact cooling water, cooling tower and boiler blowdown, condensate, exempt stormwater, cooling waters associated with hydroelectric operations and similar wastewaters (Please print or type) 1) Ownerloperator: Company Name: Contact Person: Street Address: City: Telephone No.: 2) Location of facility producing discharge: Facility Name: � WA FT1-Qv Contact Person: Street Address: City: County: Telephone No.: — 4—& State:_L'�[_S, ZIP Code: — / %' t c.--- Fax: 3) Permit Contact (complete this section if permit contact is different from facility contact) : Contact Person: Street Address: City: County: Telephone No.: 4) Physical location information: State: ZIP Code: Fax: A copy of an USGS quad map or county map with the facility clearly located on the map IS REQUIRED to be submitted with this application. Please provide a narrative description of how to get to the facility se street games, statg-,road numbers, and distance and direction from a roadway intersection): _ IV Q t" • ` f �� ' — 5) This NPDES permit application applies to which of the following: PK New or Proposed ❑ Modification Please describe the modification: ❑ Renewal Please specify existing permit number and original issue date: Page 1 of 4 SW U-212-080102 NCG500000 N.O.I. 6) Does this facility have any other NPDES permits, including stormwater general permits? R No ❑ Yes If yes, list the permit numbers for this facility: 7) What is the nature of the business applying for this ermit? -- h-1 f4- N U E%f'� c `�u�Z>r .per -=----` 4- _1- 8) Description of Discharge: a) Total number of discharge points that convey wastewater from the property, including ditches, pipes, 3) c) channels, etc.: ---------------------------------------- What type of wastewater is discharged and from which discharge points? ❑ Non -contact cooling water Discharge point(s) # 0a,Boiler Blowdown Discharge point(s) # ❑ Co-lin Tower Blowdown Discharge point(s) # : ------ g Condensate Discharge point(s) #-- ❑ Other Discharge point(s) #: _ — (Please describe "Other") : —_—_ Approximate volume of discharge for each discharge point (in GPD): #4 ------ 9) Please check the type of chemical added to the wastewater for treatment for each separate discharge point (if applicable, use separate sheet): ❑ Biocides Name: ______---_----___---__ Manuf.: ❑ Corrosion inhibitors Name: ---- --------------------- Manuf.: ❑ Chlorine Name: --- —------- ------------ Manuf.: ❑ Algaecide Name: ---- — ---------- —------ — Manuf.: ❑l Name: --------------------- -- Manuf.: /Other N'None If any box above, other than none, was checked, a completed Biocide 101 Form and manufacturers information, including MS/DS sheets on the additive IS REQUIRED to be submitted with the application for the Division's review. 10) Discharge Frequency: �� a) The discharge is: El Continuous El Intermittent 6d'Seasonal i) If the discharge is intermittent, describe when the discharge will occur : ii) If seasonal check the month(s) the discharge occurs: E-YJan. web. )2 ' ar. ❑ Apr. ❑ May ❑ Jun. ❑ Jul. ❑ Aug. ❑ Sept. E bct. ' Nov. 9-Dec. b) How many days per week is there a discharge? ---------- ---- — ----- —------- ____ 11) Receiving waters: a) What is the name of the body or bodies of water (creek, stream, river, lake, etc.) that the facility wastewater discharges end up in? If the site wastewater disch,�Kges to a separate st m s�ewer system 4S ,name the operator of the 4S e. City of Raleigh) lg �'1SG�i. �T Y ( ) P ( g Y 9 ): � — b) Stream Classification (WS-IV, NSW, etc.) : Page 2 of 4 SWU-212-080102 NCG500000 N.O.I. c) Is the discharge directly to the receiving water? ❑ Yes l/ No If no, a site map with the pathway to the potential receiving waters clearly marked IS REQUIRED to be submitted with the application. This includes tracing the pathway of the storm sewer to the discharge point, if the storm sewer is the only viable means of discharge. 12) Is there any type of treatment being provided,vi��to the wastewater before discharge (i.e., retention ponds, settling ponds, etc.)? I-]YestX0 If yes, please include design specifics (i.e., design volume, retention time, surface area, etc.) with submittal package. Existing treatment facilities should be described in detail. Design criteria and operational data (including calculations) should be provided to ensure that the facility could comply with the requirements of the General Permit. The treatment shall be sufficient to meet the limits set by the general permits. Note: Construction of any wastewater treatment facilities requires submission of three (3) sets of plans and specifications along with the application. Design of treatment facilities must comply with the requirements of 15A NCAC 2H .0138. If construction applies to this discharge, include the three sets of plans and specifications with this application. 13) Pollutants: Please list any known pollutants that are present ip the discharge, per each separate discharge point (if applicable, use separate sheet) : __-__--/Vo NE-------------------- 14) Alternatives to Direct Discharge: Address the feasibility of implementing each of the following non -discharge alternatives a) Connection to a Regional Sewer Collection System b) Subsurface disposal (including nitrification field, infiltration gallery, injection wells, etc.) c) Spray irrigation The alternatives to discharge analysis should include boring logs and/or other information indicating that a subsurface system is neither feasible nor practical as well as written confirmation indicating that connection to a POTW is not an option. It should also include a present value of costs analysis as outlined in the Division's "Guidance For the Evaluation of Wastewater Disposal Alternatives". 15) Additional Application Requirements: For new or proposed discharges, the following information MUST BE INCLUDED in triplicate with this application or it will be returned as incomplete. a) 7.5 minute series USGS topographic (quad) map (or a photocopied portion thereof) with discharge location clearly indicated. b) Site map. If the discharge is not directly to a stream, the pathway to the receiving stream must be clearly indicated. This includes tracing the pathway of a storm sewer to its discharge point. c) If this application is being submitted by a consulting engineer (or engineering firm), include documentation from the applicant showing that the engineer (Or firm) submitting the application has been designated an authorized Representative of the applicant. d) Final plans for the treatment system (if applicable). The plans must be signed and sealed by a North Carolina registered Professional Engineer and stamped -"Final Design -Not released for construction". Page 3 of 4 SWU-212-080102 NCG500000 N.O.I. e) Final specifications for all major treatment components (if applicable). The specifications must be signed and sealed by a North Carolina registered Professional Engineer and shall include a narrative description of the treatment system to be constructed. I certify that I am familiar with the information contained in this application and that to the best of my knowledge and belief such information is true, complete, and accurate. Printed Name of Person Signing: _ /f 14 Title:G1L_c�`'------ (Signature of Applicant) (Date Signed) North Carolina General Statute 143-215.6 b (i) provides that: Any person who knowingly makes any false statement, representation, or certification in any application, record, report, plan or other document filed or required to be maintained under Article 21 or regulations of the Environmental Management Commission implementing that Article, or who falsifies, tampers with or knowingly renders inaccurate any recording or monitoring device or method required to be operated or maintained under Article 21 or regulations of the Environmental Management Commission implementing that Article, shall be guilty of a misdemeanor punishable by a fine not to exceed $10,000, or by imprisonment not to exceed six months, or by both. (18 U.S.C. Section 1001 provides a punishment by a fine of not more than $10,000 or imprisonment not more than 5 years, or both, for a similar offense.) Notice of Intent must be accompanied by a check or money order for $80.00 made payable to: NCDENR Mail three (3) copies of the entire package to: Stormwater and General Permits Unit Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-1617 Final Checklist This application will be returned as incomplete unless all of the following items have been included: ❑ Check for $80 made payable to NCDENR ❑ 3 copies of county map or USGS quad sheet with location of facility clearly marked on map ❑ 3 copies of this completed application and all supporting documents ❑ 3 sets of plans and specifications signed and sealed by a North Carolina P.E. ❑ Alternatives analysis including present value of costs for all alternatives Note The submission of this document does not guarantee the issuance of an NPDES permit Page 4 of 4 SW U-212-080102 E t a.� 70) WEST CENTER ST ?/w 1 � 3 �Q B30 y IBCs 77 `O � h ST,PE�T / I ..t �/�.. �k .K�. -'�'. +:`q ? ,y..�ywi r �_ Y�•• k7.:, i jt � W' 1 y it - µs P� • is + ,�?r 1 _ Y - 62S 63 ? 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