NC0036641_LV20150264_20151117

r
. i
1i
•
NorthCarolinaDepartment of Environmental Quality- {
Pat McCrory Donald R. van der Vaart .
Governor - Secretary 1
Certified Mail#7014 0510 0000 4466 8772 1
Return Receipt Requested
November 17,2015 1
•
F
Mr. David S. Wack , .I
A
Fletcher Academy Inc. i
P.O. Box 5335 4
Fletcher,North Carolina 28732
SUBJECT: Notice of Violation and Assessment of Civil Penalty
for Violations of North Carolina General Statute(G.S.) 143-215.1(a)(6)
and NPDES Permit No.NC0036641
Fletcher Academy Inc. - . 1
Fletcher Academy WWTP
Case No. LV-2015-0264 , .
Henderson County '
Dear Permittee: 1
This letter transmits a Notice of Violation and assessment of civil penalty in the amount of$1,159.26($1,000.00 civil penalty+ 1
$159.26 enforcement costs)against Fletcher Academy Inc: . V .
This assessment is based upon the following facts: a review has been conducted of the discharge monitoring report(DMR) 3
submitted by Fletcher Academy Inc.for the month of March 2015. This review has shown the subject facility to be in r
violation of the discharge limitations and/or monitoring requirements found in NPDES Permit No.NC0036641. The ,
violations,which occurred in March 2015, are summarized in-Attachment A to this letter.
Based upon the above facts,I conclude as a matter of law'that Fletcher Academy Inc.violated the terms,conditions or
requirements of NPDES Permit No.NC0036641 and G.S. 143-215.1(a)(6)-in the manner and extent shown in Attachment
A. In accordance with the maximums established by G.S. 143-215.6A(a)(2),a civil penalty may be assessed against any - ,
person who violates the terms, conditions or requirements of a permit required by G.S. 143-215.1(a).
g
Based upon the above findings of fact and conclusions of law, and in accordance with authority provided by the Secretary
of the Department of Environmental Quality and the Director of the Division of Water Resources,I,G. Landon Davidson,
Regional Supervisor,Asheville Regional Office hereby make the following civil penalty assessment against Fletcher
Academy Inc.:
1
2090 U.S.70 Highway,Swannanoa,NC 28778 I_
Phone:[phone]\Internet:www.ncdenr.gov<http://www.ncdenr.gov> 1
4.
An Equal Opportunity\Affirmative Action Employer-Made in part by recycled paper 6d
F

i
;
$1,000.00 1 of the 1 violations of 143-215.1(a)(6)and NPDES Permit No.NC0036641,by discharging waste
water into the waters of the State in violation of the Permit Monthly Average for N113-N-Conc.
I
i
$1,000.00 TOTAL CIVIL PENALTY -- - -
i
- $159.26 Enforcement Costs
$1,159.26 TOTAL AMOUNT DUE
3
Pursuant to G.S. 143-215.6A(c), in determining the amount of the penalty I have taken into account the Findings of Fact and
Conclusions of Law and the factors set forth at G.S. 143B-282.1(b),which are:
a
(1) The degree and extent of harm to the natural resources of the State,to the public health, or to private property ;
7
resulting from the violation;
(2) The duration and gravity of the violation; ,. 1
(3) The effect on ground or surface water quantity or quality or on air quality; `�
(4) The cost of rectifying the damage; __ - - _. 1
(5) The amount of money saved by noncompliance;
(6) Whether the violation was committed willfully or intentionally;
(7) Theprior record of the violator in complyingor failing to comply with programs over which the Environmental ;
g PY P 1
Management Commission has regulatory authority;-andy
(8) The cost to the State of the enforcement procedures. _
Within thirty(30)days of receipt of this notice,you must do one of the following: 1
•
(1) Submit payment of the penalty, OR . .
I
(2) Submit a written request for remission, OR i
(3) Submit a written request for an administrative hearing 1
Option 1: Submit payment of the penalty:
Payment should be made directly to the order of the Department of Environmental Quality(do not include waiver
form). Payment of the penalty will not foreclose further enforcement action for any continuing or new violation(s). ,
Please submit payment to the'attention of: •- .
NPDES Compliance/Enforcement Unit
Division of Water Resourcesti
1617 Mail Service Center
, Raleigh,North Carolina 27699-1617 0
• 5
1
1
1
a
3
1
i
S
7
s
1
1
1

Option 2: Submit a written request for remission or mitigation including a detailed justification for such 'i
r request: a'
Please be aware that a request for remission is limited to consideration of the five factors listed below as_they_may _
relate to the reasonableness of the amount of the civil penalty assessed. Requesting remission is not the proper-
procedure for contesting whether the violation(s)occurred orthe accuracy of any of the factual statements contained in 1
1
the civil penalty assessment document. Because a remission request forecloses the option of an administrative hearing,
such a request must be accompanied by a waiver of your right to an administrative hearing and a stipulation and
agreement that no factual or legal issues are in dispute. Please prepare a detailed statement that establishes why you a
believe•the civil penalty should be remitted,and submit it to the Division of Water Resources at the address listed below.
In determining whether a,remission request will be approved,the following factors shall be considered:
(1) whether one or more of the civil penalty assessment factors in NCGS 143B-282.1(b)was wrongfully 1
applied to the detriment of the petitioner; j
(2) whether the violator promptly abated continuing environmental damage resulting from the violation;
(3) whether the violation was inadvertent or a result of an.accident;- 1
(4) whether,the violator had been assessed civil penalties for any previous violations; or
(5) whether payment of the civil penalty will prevent payment for the remaining necessary remedial actions.
l
Please note that all evidence presented in support of your request for remission must be submitted in writing. The
Director of the Division of the Division of Water Resources will review your evidence and inform you of his decision in '?
the matter of your remission request. The response will provide details regarding the case status,directions for 40
payment,and provision for further appeal of the penalty to the Environmental Management Commission's Committee
on Civil Penalty Remissions(Committee). Please be advised that the Committee cannot consider information that was I
not part of the original remission request considered by the Director. Therefore, it is very important that you prepare a
complete and thorough statement in support of your request for remission.
In order to request remission,you must complete and submit the enclosed"Request for Remission of Civil Penalties,
Waiver of Right to an Administrative Hearing,and Stipulation of Facts"form within thirty(30)days of receipt of this r
notice. The Division of Water Resources also requests that you complete and submit the enclosed"Justification for t
Remission Request."
Both forms should be submitted to the following address: a
g
NPDES Compliance/Enforcement Unit i
Division of Water Resources
, 1617 Mail Service Center 1
Raleigh,North Carolina 27699-1617 ,
i
ii
1
r
,
qi
W
4
1
d
4
1
it
I

Option 3: File a petition for an administrative hearing with the Office of Administrative Hearings:
If you wish to contest any statement in the attached assessment document you must file a petition for an administrative
_hearing. You may obtain the petition form from the Office of Administrative Hearings: You must file the petition with
- -- --- --=
the Office of Administrative Hearings within thirty(30)days of receipt of this notice A petition is considered filed . -
when it is received in the Office of Administrative Hearings during normal office hours. The Office of Administrative
Hearings accepts filings Monday through Friday between the hours of 8:00 a.m. and 5:00 p.m., exceptforofficial state
holidays. The petition may be filed by facsimile(fax)or electronic mail by an attached file(with restrictions)-provided
the signed original; one(1)copy and a filing fee(if a filing feeis required by NCGS §150B-23.2)is received in the
Office of Administrative Hearings within seven(7)business days following the faxed or electronic transmission. You
should contact the Office of Administrative Hearings with all questions regarding the filing fee and/or the details of the
filing process. i
The mailing address and telephone and fax numbers for the Office of Administrative Hearings are as follows:
Office of Administrative Hearings
6714 Mail Service Center -
Raleigh,NC 27699-6714 6
Tel: [phone] -
Fax: [phone]
One(1)copy of the petition must also be served on DEQ as follows: •
Mr. Sam M.Hayes, General Counsel
Department of Environmental Quality
1601 Mail Service Center
Raleigh,North Carolina 27699-1601
Please indicate the case number(as found on page one of this letter)on the petition.
Failure to exercise one of the options above within thirty(30)days of receipt of this letter, as evidenced by,an internal
date/time received stamp(not a postmark),will result in this matter being referred to the Attorney General's Office for
collection of the penalty through a civil action. Please be advised that additional penalties may be assessed for violations 3
that occur after the review period of this assessment.
r4
3
3

If you have any questions,please contact Janet Cantwell with the Division of Water Resources staff of the Asheville '
: Regional Office at(828)296-4667 or via email at [e-mail]. '
Sincerely, - _ .. 1
t
. _ 1
i
t
G.Landon Davidson, Regional Supervisor . `
Water Quality Regional Operations Section .
_Asheville Regional Office i
Division of Water Resources,NCDEQ • I.
ATTACHMENTS .
i
Cc: WQS Asheville,Regional Office-Enforcement File (w/attachments)
NPDES Compliance/EnforcemenfUnit-Enforcement File . . (w/attachments)
Central Files,Water Quality Section (w/attachments) a
James&James Environmental/ORC -(w/attachments) .
i
n
9
,
• - i
1
, t
3
s
A
1
i
1
9
• Y
5
1
9
1
1
1
V
i
G•,\iR•WQ•iiendersomNastewaterMinors‘Ftetchei Academy 36e41'',L6-2015-0264 rtf
a
S
d
1

• 4
i
li
JUSTIFICATION FOR REMISSION REQUEST t 1
4
Case Number: LV-2015-0264 County: Henderson I
Assessed Party: Fletcher Academy'Inc. . 1
Permit No.: NC0036641 Amount Assessed: $1,159.26 - 5
I
1
4
Please use this form when requesting remission of this civil penalty. You must also complete the "Request For Remission,
Waiver of Right to an Administrative Hearing, and Stipulation of Facts"form to request remission of this civil penalty. 3
You should attach any documents that you believe support your request and are necessary for the Director to consider in i
evaluating your request for remission. Please be aware that a request for remission is limited to consideration of the five 3
factors listed below as they may relate to the reasonableness of the amount of the civil penalty assessed. Requesting a
remission is not the proper procedure for contesting whether the violation(s)occurred or the accuracy of any of the factual ti
statements contained in the civil penalty assessment document. Pursuant to N.C.G.S. § 143B-282.1(c),remission of a civil L
penalty may be granted only when one or more of the following five factors apply. Please check each factor that you1.
believe applies to your case and provide a detailed explanation, including copies of supporting documents,as to why the 1
factor applies(attach additional pages as needed). 1
a
r
(a) one or more of the civil penalty assessment factors in N.C.G.S. 143B-282.1(b)were wrongfully applied to the A
detriment of the petitioner(the assessment factors are listed in the civil penalty assessment document); ri
(b) the violator promptly abated continuing environmental damage resulting from the violation(i.e., explain the
steps that you took to correct the violation and prevent future occurrences);
(c) the violation was inadvertent or a result of an accident(i.e., explain why the violation was unavoidable or
something you could not prevent or prepare for);
(d) the violator had not been assessed civil penalties for any previous violations; -
1
(e) payment of the civil penalty will prevent payment for the remaining necessary remedial actions (i.e., explain 1
how payment of the civil penalty will prevent you from performing the activities necessary to achieve
compliance).
EXPLANATION: .
1
1
3
1.
3
1
I
i
i
a.
1
u
V

. •
STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY
COUNTY OF HENDERSON • -"
• I
IN THE MATTER OF ASSESSMENT ) WAIVER OF RIGHT TO AN
OF CIVIL PENALTIES AGAINST ) ADMINISTRATIVE HEARING AND
) STIPULATION OF FACTS •
FLETCHER ACADEMY INC. )
FLETCHER ACADEMY WWTP )
)
PERMIT NO.NC0036641 ) CASE NO. LV-2015-0264
Having been assessed civil penalties totaling$1,159.26 for violation(s)as set forth in the assessment document of the Division
of Water Resources dated November 17,2015,the undersigned, desiring to seek remission of the civil penalty, does hereby d
waive the right to an administrative hearing in the above-stated matter and does stipulate that the facts are as alleged in the
assessment document The undersigned further understands that all evidence presented in support of remission of this civil
penalty must be submitted to the Director of the Division of Water Resources within thirty(30)days of receipt of the notice -
of assessment. No new evidence in support of a remission request will be allowed after(30)days from the receipt of the
notice of assessment.
This the day of ,20
SIGNATURE -
ADDRESS
TELEPHONE
r '
i
4

ATTACHMENT A
Fletcher Academy Inc
CASE NUMBER LV-2015-0264
PERMIT: NC0036641 FACILITY: Fletcher Academy WWTP _ COUNTY: Henderson REGION: Asheville
Limit Violations
MONITORING OUTFALL/ VIOLATION UNIT OF CALCULATED %OVER
PENALTY REPORT PPI LOCATION PARAMETER DATE/ FREQUENCY MEASURE LIMIT VALUE LIMIT VIOLATION TYPE
$1,000.00 3-2015 001 Effluent NH3-N-Conc 3/31/15 2 X month mg/I 11 19.10 73.3 Monthly Average Exceeded
W .LL4L i+liy4JCwaY34"r1"±.JJ9i �0.uui:
L..n
� yt,.•m.i I .II iPl'I ,' I• �' I I h �l��"� wv��:�.rrsrl�v_rnR.�.`+.wr'�mi-rutWem�-,K,yy,.,�"..w.�i,,32m+luLWiW'�11�L::9AI1�1'ns�vsaacume,�^xdai.��Ir�r .y�+2.m:ua.�mivsJT wrsnai• J__,��.,....,n.u.,w...r......„a�,r-.�_...u�n.,.,.....�_.�...o..a.r...,.,�,,..-.,.�.,....�.�_..._....,_.�____________
i •• i�ff 'trt..”:w:r�4.�.ulsiurctc:ax.•t�u'sc:.r.-m..�n.,n,rr•,. _

DIVISION OF WATER RESOURCES-CIVIL,PENALTY ASSESSMENT (FILE)
Violator: Fletcher Academy Inc.
Facility Name: Fletcher Academy WWTP
Permit Number: NC0036641
County: Henderson
Case Number: LV-2015-0264
ASSESSMENT FACTORS
1) The degree and extent of harm to the natural resources of the State,to the public health,or to private
property resulting from the violation;
All effluent violations may be detrimental to the receiving stream but may not be immediately quantified.
2) The duration and gravity of the violation;
One Monthly Average Ammonia Nitrogen exceeded the permit limit by73.33%.
3) The effect on ground or surface water quantity or quality or on air quality;
All effluent violations may be detrimental to the receiving stream but may not be immediately quantified.
4) The cost of rectifying the damage;
The cost is unknown.
5) The amount of money saved by noncompliance; - !
The amount of money saved would include the cost of excess solids removal and additional
aeration. It would also include more operating and maintenance time on site and the cost of
additional chemical treatment.
6) Whether the violation was committed willfully or intentionally;
It does not appear to be either.
7) The prior record of the violator in complying or failing to comply with programs over which the
Environmental Management Commission has regulatory authority; and
There have been nine civil penalty enforcements in the twelve months prior to this violation.
8) The cost to the State of the enforcement procedures.
$159.26.
a
L( , t
Date G.Landon Davidson,Regional Supervisor
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources,NCDEQ
3
P

.. , , (rezteefiti)
I � I.1y. '
YPDES PERMIT NO. NC0036641 DISCHARC�Ja'1vV4. ,.-'''•' r 01 0 TB . MARCH YEAR 2015
FACILITY NAME FLETCHER ACADEMY,INC. - '`'• . -LASS. . ,II._ • ,COUNTY HENDERSON '
2,ERTIFIED LABORATORY(1) JAMES 3,►a0i,IES•E LV.'MGT.,IN \ Peyo,%- CERTIFICATION NO. 482 r�
list additional laboratories on the backside/page 2 of tlfis_fgj'.16) G,flate I - O MA2 015
OPERATOR IN RESPONSIBLE CHARGE(ORC) • • ETH itatfiCRUMMEL �C. GRADE 0 'CERTIFICATION NO. 9 41�
1y` `; 828-697-0063 .
PERSON(S)COLLECTING SAMPLES KE 2i;,ASON RUMMEL 2 2 ORC PHO
"HECK BOX IF ORC HAS CHANGED ` -1:4
_ fig\Mee
Eh • , SCHA$(i FROM SITE"
A00 o . ,
vlail ORIGINAL and ONE COPY to: 4\ .r R!„„it I ,:A' - ;
`f `4n7AIE ' "" I • " 4/20/2015 •
,TTN:CENTRAL FILES � ` .i ,f%•' iii
)IVISIONOFWATER QUALITY # , ' a 7:Js i•1(} -"1'4 ' DM, I,HAKIils) - DA11: I
617 MAIL SERVICE CENTER BY '1- .,1 CER /PBA •I. tEPORT I3 j
2ALEIGH,NC 27699-1617 _ AC `1 s • .,v: 1'L, "YO I, :-•• OF MY.KNOWLEDGE. • . - J j
w..47.:1:4;(-
.-. rr
• -50050 00010 00400 . 50060- 00311 .11 *•r 00530= •31616•- 00095- 38260 00300 -00600 00665 • - )
, F -
x E FLOW u� d w z z 'k. z
E�''>o .d. EFF ■
W do og ti INF ❑ ; • iliVLLc - Jui 151 lo a at: I
x NO i]HRS . .HRS I ® • f 3
1 0.00 _ :
2 `.1555 0.50 Y . ' "I 1 ' -I ! 1
3 1640 0.33 Y 0.052 _ i
4 1225 :1.83 Y 0.045 5.1 7.6 - . • ; .•1.-- 583 12.4 C,,P mTR AI Fit ES 1
5 1510 _ 0.62 Y 0.056 . <15 - - '' 0.1 DWR ION a
6 1350 0.83 Y 0.046 i
7 0.00 0.031 -
s 0.00 0.031 ' _ - I - I
9 1540 0.75 Y 0.031 <15 � 1
10 1350 0.75 Y 0.038
11 1515 0.75 Y• ' 0.049
12 1415 1.50• Y' -0.049 _ 8.3 7.6 <15 ' 33.0 C 16.4 43.0 ' <4 600.5 10.2
y
13 1515 - :0.75 . Y 0.049-. 1 5
;.,, a
14 H0.00 0:040 MAY y @
15 0.00 0.040 _ _ _ ® 7 air, _ ,,
16 1615 '0.67 Y •0.040 " <51 : -
17 1505 0.67 Y 0.048 ,
18 1435- .-0.58 • . Y • 0.049 • . .
19 1320 - 1.58
Y 0.048 10.4 7.7 <15 580 <0.1 9.6 _
20 1450 '0:67 "• Y'- -0.052 ` .... -
21 0.00 0.036
22 0.00 0.036 , _ '' -
23 1555 0.67 Y _ 0.036 <15 ' 11
1 I
•24 1450 0.92 Y. 0.047 I
25 1150 •0.92 '' Y 0.040 - 14.9 '7:3 `19.9 B 19.0• 21.7 <4 ",, 600 8.6
26 1540 0.50 Y 0.062 , <15 _
27 1250- -•0.67 Y _ 0.042 - , - t ' .... 1
28 0.00 0.039
29 0.00 0.039 - - • a
30 1605 0.58 Y 0.039 <15 _ -
31 1445 0.67 Y 0.044 20.2 A 21.8
AVERAGE 0.043 9.7 0.0 24.4 • 19.1 32.4 •4.0 590.9 0.1 10.2 ###I# NW "
MAXIMUM 0.062 14.9 7.7 -<15 33.0 21.8 43.0 <4.0 600.5 0.1 12.4 0.0 0.0
MINIMUM 0.031 5.1 7.3 <15 19.9 16.4 21.7 <4.0 580.0 <0.1 8.6 0.0 0.0 7 4
:::om.. /Grab G CONT G G' G C C C G G GGCC :
Monthly Limit 0.10 NL 6-9 28 30/45 11/35 90/135 200/400 NL NL NL NL NL 3 4
DwQ Form MR-1(11104) 1 ti
3
/ I JYF '
No4/�?zi� --4-✓moo ,syr , S >41/-Za(�- ozO e _
/ -71
/sib

i
a
A =
-:
i'`� - 4 31
Facilitytus:(f lease`check one of the following) ' . : i
monitoring data and-Sarnplind#equtncies meet permit requirements
_ (including weekly averages,if applic,) '_ _ 3 '1J
/ / Compliant ,
All mdnitoefng�,data and sampling frequencies do NO j meet permit requirements X
, -
s' -Noncompliant R ,
Thej�.
permittee shall report to the Director or the a ro'riate Re onal'Office"an'''n,
no 1
PP P !n . y t�ompPiarice:That potentially threatens public health or the
environment. Any information shall be provided orally within 24 hours f• rom the-time the'permiitee became aware of the circumstances. 'A written n
submission shall also be provided within 5 days of the time the permittee becomes- aware of the circumstances. r
If the facility is noncompliant,please attach a•list of corrective actions being taken and a,time-table•for improvements to be made as required by Part II.E.6 of s'
the NPDES permit.
"I certify,under penalty of law,that this,document and all attachments wereprepared under my'direction or supervision in accordance•with a system designed to assure r
that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who managed the system,'or those persons a
directly responsible for gathering the,information,the jnformtiowsgbmitted is,to the best of my knowledge and belief,true,accurate,and complete.•I am aware that there ' _ I
are significant penalties for submitting false information,including the possibility of fines and imprisonment for knowing violations." . a
. -. , A
1
FLETCHER ACADEMY 1
- Permittee (Please print or type) -, - - 5
.
`t ,, - •l ItLL-(t./Y1O C>:1/6t/C-: 4/20/2015 :.. . -L.
- Op.• inature o • ittee•* Date •• a
(Required submitted electronically)
PO BOX 5335,FLETCHER,NC 28732 - 828-697-0063 12-31-15
Permittee Address - Phone Number • . e-mail address . - Permit Expiranon Date
- . ,- •ADDITIONAL CERTIFIED LABORATORIES • " ,
Certified Laboratory(2) -RESEARCH&ANALYTICAL LABORATORES,INC Certification No. '. 34 • g
•-- - 8
Certified Laboratory(3) , Certification No. " -
Certified Laboratory(4) Certification No. E
Certified'Laboratory(5) Certification No.' . - - • " I
-
PARAMETER CODES - c
Parameter Code assistance may be obtained by calling the NPDES Unit at(919)807-6300.or by visiting http://portal.ncdenr.org/web /wq/swp/ps/npdes/appforms. , •
•
Use only units of measurement designated in the reporting facility's NPDES permit for-reporting data. -- - - ft i
* No Flow/Discharge From Site: Check this box•if no discharge occurs and,as a result,there are no data to.be - a
entered for all'of the parameters on the DMR for the entire monitoring period: • 4
** ORC On Site?: ORC must visit facility and document visitation of facility as required per 15A NCAC 8G.0204. '
***Signature Of Permittee: If signed by other than the-permittee,then the delegation ofthe-sign' -authority must be on - - -
file with the state per 15A NCAC 2B.0506(b)(2)(D).• ' ' • - - {, v
I•
•
' . . - • ' ' ' . - l•
•
a
3

I,
't
.
=/i ,.�; - JAMES-8z, JAMES-ENVIRONMENTAL MANAGEMENT, INC
I� t -4 ,� PO BOX 1354, MOUNTAIN HOME,NC 28758
r.41•44 Aiwa.�' ��f [phone] OFFICE
\,;moi • [phone] FAX
March 2015-DMR.
Client: Fletcher Academy
NPDES PERMIT NUMBER:NC0036641
Dear Client, `-_ -
We are pleased to notify you-that your facility operated most of the month within your National
Pollutant Discharge Elimination System(NPDES)permit.We did experience a result that was greater than a
the permit discharge limits. Your permit has both a monthly maximum and a daily maximum. Your
facility exceeded the permit discharge limits on the items listed below: -
Ammonia Nitrogen 19.1 mg/l monthly average
I
a
This gave a daily maximum violation on no days and did give one monthly violation. We I
determined that the cause of the violation was due to,the sudden temperature changes that occurred during
this month. We began adding Soda Ash to increase the pH and Alkalinity at the time the increase in
Ammonia Nitrogen was observed. -The Soda Ash is being added at the'Influent weir and in the final ! g
Effluent. The system is meeting with the Cane Creek Sewer District as well as evaluating installing aerated i
tankage to assist with the treatment. We are working with the Asheville Regional Office on available 1
options regarding this system. Fletcher Academy has sent response to the ARO regarding the options being
pursued under the observation of Will Buie,PE.
You may receive a monetary fine for this month. Thank you for your understanding in this 1
matter. , 1
Thank you for choosing James&James as your service company. 1
A
1 , -./
to James /
; ,
ii
- - i
1
•
•
a
I
ti
1