The URL can be used to link to this page

Home My WebLink AboutNC0067342_NOV-2018-PC-0233_20180712DocuSign Envelope ID: 77C14687-3F24-4700-9FOF-7338BOCE6239 WateYResou Ces ENWROMMEMTAL QUALITY Certified Mail # 7017 2620 0000 9759 4698 Return Receipt Requested July 12, 2018 James Rice Eaven Brice Partnership 329 Emma Rd Asheville, NC 28806 SUBJECT: NOTICE OF VIOLATION Tracking Number: NOV-2018-PC-0233 Permit No. NCO067342 North View Mobile Home Park WWTP Buncombe County Dear Permittee: ROY COOPER GoTerna, NIICHAEL S_ REGAN S�cra�� LLVDA CT -TT -PEPPER IFJiPi' m DfFBCia- The North Carolina Division of Water Resources conducted inspections of the North View Mobile Home Park on June 1, 2018 and June 20, 2018. These inspections were conducted to verify that the facility is operating in compliance with the conditions and limitations specified in NPDES WW Permit No. NC0067342. A summary of the findings and comments noted during these inspections are provided in the enclosed copies of the inspection reports. The inspections were conducted by Division of Water Resources staff from the Asheville Regional Office. The following violations were noted during the inspection: Inspection Area Description of Violation Record Keeping Jim Queen's, designated ORC, Certification has been revoked. An ORC Designation form for the new ORC/BORC has not been submitted. Mr. Queen is listed as ORC in DWR database. Process Control Logs are not submitted as required by Permit. Disinfection -Tablet New Cl contact basin blanket level: 4'/7' Old Cl contact basin blanket level: 3'/7' State of North Carolina I Environmental Quality I Water Resources 2090 U.S. 70 Highway, Swannanoa, NC 28778 828-296-4500 DocuSign Envelope ID: 77C14687-3F24-4700-9FOF-7338BOCE6239 Inspection Area Description of Violation Secondary Clarifier Old clarifier blanket level: 378' Circular clarifier blanket level: 879' Effluent Sampling Sampling shall take place below de -chlorination. Flow Measurement - Effluent Chart recorder is not working. Remedial actions should have already been taken to correct these problems and prevent further occurrences in the future. The Division of Water Resources may pursue enforcement action for these and any additional violations of State law. To prevent further action, please respond in writing to this office within 30 days upon your receipt of this Notice of Violation regarding your plans or measures to be taken to address the indicated violations. If you should have any questions, please do not hesitate to contact Linda Wiggs with the Water Quality Regional Operations Section in the Asheville Regional Office at 828-296-4500. Sincerely, DocuSigned by: p7E617A38285848C... G. Landon Davidson, P.G., Regional Supervisor Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ ATTACHMENTS — June 1, 2018 Inspection Report, June 20, 2018 Inspection Report Ec: Asheville Regional Office Server Laserfiche State of North Carolina I Environmental Quality I Water Resources 2090 U.S. 70 Highway, Swannanoa, NC 28778 828-296-4500 DocuSign Envelope ID: 77C14687-3F24-4700-9FOF-7338BOCE6239 United States Environmental Protection Agency Form Approved. EPA Washington, D.C. 20460 OMB No. 2040-0057 Water Compliance Inspection Report 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 IN 1 2 15 I 3 I NCO067342 111 12 I 18/06/20 I17 18 Lam] 19 LG] 201 I 211111 1 1 1 1 1 111 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 111 1 1 1 1 1 166 Inspection Work Days Facility Self -Monitoring Evaluation Rating 131 QA ----------------------Reserved------------------- 67 70 I I 71 I I 72 I r l 73 I I 174 751 1 1 1 1 1 1 180 u ty I I i 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 oermit Number) 11:30AM 18/06/20 18/04/01 North View Mobile Home Park 329 Emma Rd Exit Time/Date Permit Expiration Date Asheville INC 28806 12:30PM 18/06/20 23/03/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Name, Address of Responsible Official/Title/Phone and Fax Number Contacted James Rice,329 Emma Rd Asheville INC 28806//828-253-0164/8282537803 Yes Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Flow Measurement Operations & Maintenance 0 Self -Monitoring Program 0 Facility Site Review 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 Date DS DocuSigned by: Linda S Wiggs �'�:J W\28-296-4500 Ext.4653/ Timothy H Heim R .//828-296-4665/ 7/12/2018 E 17A38285848C Signatur ( 1 WgWRVAkY A Reviewer Agency/Office/Phone and Fax Numbers Date \[r7'�,— � 7/12/2018 7E617A38285848C... EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# DocuSign Envelope ID: 77C14687-3F24-4700-9FOF-7338BOCE6239 NPDES yr/mo/day Inspection Type NC0067342 111 121 18/06/20 1 17 18 g Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) The Inspectors, Linda Wiggs and Tim Heim with DWR met with Joe David Hall to split effluent samples from the facility sampler. DWR sample results: Fecal Coliform — 1 CFU/100ml TSS — 11 mg/I BOD — 6.7 mg/I NH3 — 0.07 mg/I Page# DocuSign Envelope ID: 77C14687-3F24-4700-9FOF-7338BOCE6239 Permit: NCO067342 Owner - Facility: North View Mobile Home Park Inspection Date: 06/20/2018 Inspection Type: Compliance Sampling Operations & Maintenance Yes No NA NE Is the plant generally clean with acceptable housekeeping? ❑ 0 ❑ ❑ Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable ❑ ❑ ❑ Solids, pH, DO, Sludge Judge, and other that are applicable? Comment: Solids remain high throughout the plant. Refer to June 1, 2018 inspection report. Effluent Pipe Yes No NA NE Is right of way to the outfall properly maintained? 0 ❑ ❑ ❑ Are the receiving water free of foam other than trace amounts and other debris? 0 ❑ ❑ ❑ If effluent (diffuser pipes are required) are they operating properly? ❑ ❑ 0 ❑ Comment: Flow Measurement - Effluent Yes No NA NE # Is flow meter used for reporting? 0 ❑ ❑ ❑ Is flow meter calibrated annually? 0 ❑ ❑ ❑ Is the flow meter operational? 0 ❑ ❑ ❑ (If units are separated) Does the chart recorder match the flow meter? ❑ 0 ❑ ❑ Comment: Chart recorder not working. Aeration Basins Yes No NA NE Mode of operation Type of aeration system Is the basin free of dead spots? 0 ❑ ❑ ❑ Are surface aerators and mixers operational? ❑ ❑ 0 ❑ Are the diffusers operational? 0 ❑ ❑ ❑ Is the foam the proper color for the treatment process? 0 ❑ ❑ ❑ Does the foam cover less than 25% of the basin's surface? 0 ❑ ❑ ❑ Is the DO level acceptable? 0 ❑ ❑ ❑ Is the DO level acceptable?(1.0 to 3.0 mg/1) 0 ❑ ❑ ❑ Comment: Inspectors DO readings: Air OFF: Old Aeration Basin — 0.2 mq/1 Air OFF: New Aeration Basin — 0.2 mg/I Air ON: Old Aeration Basin — 0.66-1.28 mq/1 Air ON: New Aeration Basin — 0.88-1.3 mg/I Facility DO reading: 0.3 mg/I Page# 3 DocuSign Envelope ID: 77C14687-3F24-4700-9FOF-7338BOCE6239 Permit: NCO067342 Owner - Facility: Inspection Date: 06/20/2018 Inspection Type: North View Mobile Home Park Compliance Sampling Are tablet chlorinators operational? E ❑ Secondary Clarifier Yes No NA NE Is the clarifier free of black and odorous wastewater? 0 ❑ ❑ ❑ Is the site free of excessive buildup of solids in center well of circular clarifier? ❑ 0 ❑ ❑ Are weirs level? ❑ 0 ❑ ❑ Is the site free of weir blockage? ❑ 0 ❑ ❑ Is the site free of evidence of short-circuiting? ❑ 0 ❑ ❑ Is scum removal adequate? 0 ❑ ❑ ❑ Is the site free of excessive floating sludge? ❑ 0 ❑ ❑ Is the drive unit operational? ❑ 0 ❑ ❑ Is the return rate acceptable (low turbulence)? ❑ ❑ ❑ 0 Is the overflow clear of excessive solids/pin floc? ❑ 0 ❑ ❑ Is the sludge blanket level acceptable? (Approximately'/4 of the sidewall depth) ❑ 0 ❑ ❑ Comment: Circular clarifier had same issues as 6/1/2018 inspection. Refer to June 1, 2018 in report. Disinfection -Tablet Yes No NA NE Are tablet chlorinators operational? E ❑ ❑ ❑ Are the tablets the proper size and type? 0 ❑ ❑ ❑ Number of tubes in use? 4 ❑ ❑ ❑ Is the level of chlorine residual acceptable? ❑ ❑ ❑ 0 Is the contact chamber free of growth, or sludge buildup? ❑ 0 ❑ ❑ Is there chlorine residual prior to de -chlorination? ❑ ❑ ❑ 0 Comment: Solids remain in the contact chamber. Effluent Sampling Yes No NA NE Is composite sampling flow proportional? 0 ❑ ❑ ❑ Is sample collected below all treatment units? ❑ 0 ❑ ❑ Is proper volume collected? 0 ❑ ❑ ❑ Is the tubing clean? 0 ❑ ❑ ❑ # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees 0 ❑ ❑ ❑ Celsius)? Is the facility sampling performed as required by the permit (frequency, sampling type ❑ 0 ❑ ❑ representative)? Comment: Sampling point had not been moved below de -chlorination. DMR data indicates 2X weekly sampling did not occur the first two weeks in April. Refer to summary for CSI results. Page# 4 DocuSign Envelope ID: 77C14687-3F24-4700-9FOF-7338BOCE6239 Permit: NC0067342 Inspection Date: 06/20/2018 Owner - Facility: North View Mobile Home Park Inspection Type: Compliance Sampling Page# DocuSign Envelope ID: 77C14687-3F24-4700-9FOF-7338BOCE6239 United States Environmental Protection Agency Form Approved. EPA Washington, D.C. 20460 OMB No. 2040-0057 Water Compliance Inspection Report 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 IN 1 2 15 I 3 I NCO067342 111 12 I 18/06/01 I17 18 I S J 19 LG] 201 I 211111 1 1 1 1 1 111 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 111 1 1 1 1 1 166 Inspection Work Days Facility Self -Monitoring Evaluation Rating 131 QA ----------------------Reserved------------------- 67 70 I I 71 I I 72 I r l 73 I I 174 751 1 1 1 1 1 1 180 u ty I I i 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 oermit Number) 10:OOAM 18/06/01 18/04/01 North View Mobile Home Park 329 Emma Rd Exit Time/Date Permit Expiration Date Asheville INC 28806 11:45AM 18/06/01 23/03/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Name, Address of Responsible Official/Title/Phone and Fax Number Contacted James Rice,329 Emma Rd Asheville INC 28806//828-253-0164/8282537803 Yes Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit 0 Flow Measurement Operations & Maintenance Records/Reports Self -Monitoring Program 0 Facility Site Review Compliance Schedules 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 Date DS Linda S Wiggs �� ARO WQ//828-296-4500 Ext.4653/ G. Landon Davidson (�Docusigned by: ARO WQ//828-296-4500/ i- 7/12/2018 7E617A38285848C... F1> 'wpyle N: A Reviewer Agency/Office/Phone and Fax Numbers Date Signat1717A38285848C ��7/12/2018 ... EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# DocuSign Envelope ID: 77C14687-3F24-4700-9FOF-7338BOCE6239 NPDES yr/mo/day Inspection Type (Cont.) NC0067342 111 121 18/06/01 1 17 18 ICI Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Linda Wiggs and Landon Davidson with DWR met onsite with Joe David Hall (BORC) and James Rice (Owner). Process Control Logs: A letter dated March 13, 2018 was sent to Mr. Rice notifying him that DWR had not received Process Control Logs since June 23, 2017. Tap Moratorium: The Moratorium remains in effect. Vacated trailers cannot be reoccupied. ORC: An ORC designation form for the new ORC has not been submitted. Mr. Queen is still listed as ORC in DWR database. Sampling: Sampling location is to be relocated to post treatment; after de -chlorination. The second weekly sampling event should begin on Thursdays. Solids: Inspectors discussed with Mr. Hall and Mr. Rice the removal of solids from clarifiers and contact chambers to allow for a "reset" to gage if the plant is continuing to lose solids or surge that is not showing up in sampling. Solids removal is to be documented on Process Control Logs as well as blanket depth measurements from these components. DWR Process Controls conducted during the inspection: Settleability (30 minute): Old aeration basin — 95% New aeration basin — 95% Sludge Judge: blanket'/water depth' Circular clarifier — 879' Package plant clarifier — 3'/8' (very dark, almost black) New chlorine contact basin — 4'/7' Package plant chlorine contact basin — 3'/7' MLSS: New ASB — 4230 mg/I Old ASB — 4480 mg/I Page# 2 DocuSign Envelope ID: 77C14687-3F24-4700-9FOF-7338BOCE6239 Permit: NCO067342 Owner - Facility: North View Mobile Home Park Inspection Date: 06/01/2018 Inspection Type: Compliance Evaluation Compliance Schedules Yes No NA NE Is there a compliance schedule for this facility? 0 ❑ ❑ ❑ Is the facility compliant with the permit and conditions for the review period? ❑ 0 ❑ ❑ Comment: Process Control loa shall be received by the 10th. ADril's PC loa was received 6/12/2018 May's was received 6/22/2018. BORC is doing PC logs. Tap Moratorium remains in effect. Vacated trailers cannot be reoccupied. Operations & Maintenance Yes No NA NE Is the plant generally clean with acceptable housekeeping? ❑ 0 ❑ ❑ Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable ❑ ❑ ❑ Solids, pH, DO, Sludge Judge, and other that are applicable? Comment: Process Controls are beina Derformed by BORC: thev indicate the olant continues to have operational issues, excessive solids, as were observed during the inspection. DWR PC results: New ASB 30 -minute settle ability: 95% Old ASB 30 -minute settle ability: 95% Old clarifier blanket level: 3'/8' (blanket depth/total depth) New CI contact basin blanket level: 4'/7' (before solids removal pumping) and 35/7' after pumping Old CI contact section blanket level: 377' Circular clarifier blanket level: 8'/9' See summary. Permit Yes No NA NE (If the present permit expires in 6 months or less). Has the permittee submitted a new ❑ ❑ 0 ❑ application? ❑ 0 ❑ ❑ Is the facility as described in the permit? 0 ❑ ❑ ❑ # Are there any special conditions for the permit? 0 ❑ ❑ ❑ Is access to the plant site restricted to the general public? 0 ❑ ❑ ❑ Is the inspector granted access to all areas for inspection? 0 ❑ ❑ ❑ Comment: Refer to Permit for Special Conditions. Engineered as -built plans of the facility are to be submitted by September 30, 2018. Record Keeping Yes No NA NE Are records kept and maintained as required by the permit? ❑ 0 ❑ ❑ Is all required information readily available, complete and current? ❑ 0 ❑ ❑ Are all records maintained for 3 years (lab. reg. required 5 years)? ❑ ❑ ❑ 0 Are analytical results consistent with data reported on DMRs? ❑ ❑ ❑ 0 Is the chain -of -custody complete? ❑ ❑ ❑ 0 Dates, times and location of sampling ❑ Page# 3 DocuSign Envelope ID: 77C14687-3F24-4700-9FOF-7338BOCE6239 Permit: NCO067342 Inspection Date: 06/01/2018 Record Keeping Name of individual performing the sampling Results of analysis and calibration Dates of analysis Name of person performing analyses Transported CDCs Are DMRs complete: do they include all permit parameters? Owner - Facility: North View Mobile Home Park Inspection Type: Compliance Evaluation Has the facility submitted its annual compliance report to users and DWQ? (If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift? Is the ORC visitation log available and current? Is the ORC certified at grade equal to or higher than the facility classification? Is the backup operator certified at one grade less or greater than the facility classification? Is a copy of the current NPDES permit available on site? Facility has copy of previous year's Annual Report on file for review? Yes No NA NE Comment: Jim Queen, designated ORC, Certification has been revoked. Inspectors were told that the BORC (Joe David Hall) is to become the ORC, however at the time of the inspection the contract between Environmental Inc. and the owner (Mr. Rice) was still in the works. An ORC designation form for the new ORC has not been submitted. Mr. Queen is still listed as ORC in DWR database. ARO is to receive Process Control logs by the 10th. Bar Screens Type of bar screen a.Manual b.Mechanical Are the bars adequately screening debris? Is the screen free of excessive debris? Is disposal of screening in compliance? Is the unit in good condition? Comment: Equalization Basins Is the basin aerated? Is the basin free of bypass lines or structures to the natural environment? Yes No NA NE 0 EJ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ Page# 4 DocuSign Envelope ID: 77C14687-3F24-4700-9FOF-7338BOCE6239 Permit: NCO067342 Inspection Date: 06/01/2018 Owner - Facility: North View Mobile Home Park Inspection Type: Compliance Evaluation Mode of operation ❑ ❑ Equalization Basins Yes No NA NE Is the basin free of excessive grease? 0 ❑ ❑ ❑ Are all pumps present? ❑ ❑ ❑ 0 Are all pumps operable? ❑ ❑ ❑ 0 Are float controls operable? ❑ ❑ ❑ 0 Are audible and visual alarms operable? ❑ ❑ ❑ 0 # Is basin size/volume adequate? 0 ❑ ❑ ❑ Comment: EQ is not being used as EQ. Not all flow is going to EQ from influent. Aeration Basins Yes No NA NE Mode of operation ❑ ❑ ■ ❑ Type of aeration system ❑ ■ ❑ ❑ Is the basin free of dead spots? 0 ❑ ❑ ❑ Are surface aerators and mixers operational? ❑ ❑ 0 ❑ Are the diffusers operational? 0 ❑ ❑ ❑ Is the foam the proper color for the treatment process? 0 ❑ ❑ ❑ Does the foam cover less than 25% of the basin's surface? 0 ❑ ❑ ❑ Is the DO level acceptable? ❑ 0 ❑ ❑ Is the DO level acceptable?(1.0 to 3.0 mg/1) ❑ 0 ❑ ❑ Comment: D.O. reading from the ORC's equipment indicated the old aeration basin's D.O. was 6.0 mq/I. Secondary Clarifier Is the clarifier free of black and odorous wastewater? Is the site free of excessive buildup of solids in center well of circular clarifier? Are weirs level? Is the site free of weir blockage? Is the site free of evidence of short-circuiting? Is scum removal adequate? Is the site free of excessive floating sludge? Is the drive unit operational? Is the return rate acceptable (low turbulence)? Is the overflow clear of excessive solids/pin floc? Is the sludge blanket level acceptable? (Approximately 1/4 of the sidewall depth) Yes No NA NE ■ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ Page# 5 DocuSign Envelope ID: 77C14687-3F24-4700-9FOF-7338BOCE6239 Permit: NCO067342 Inspection Date: 06/01/2018 Secondary Clarifier Owner - Facility: North View Mobile Home Park Inspection Type: Compliance Evaluation Comment: Old clarifier/polishing clarifier: 378' (blanket or solids/total depth) Circular clarifier: 879' Issues with circular clarifier remain. Disinfection -Tablet Are tablet chlorinators operational? Are the tablets the proper size and type? Number of tubes in use? Is the level of chlorine residual acceptable? Is the contact chamber free of growth, or sludge buildup? Is there chlorine residual prior to de -chlorination? Yes No NA NE Yes No NA NE ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ 4 ❑ ❑ ❑ ■ ❑ ■ 1:11:1 ❑ ❑ ❑ ■ Comment: New CI contact basin: 477' (before solids removal pumping) and 3.577' after pumping Old CI contact basin: 377' De -chlorination Yes No NA NE Type of system ? Tablet ❑ ❑ Is the feed ratio proportional to chlorine amount (1 to 1)? ❑ ❑ 0 ❑ Is storage appropriate for cylinders? ❑ ❑ 0 ❑ # Is de -chlorination substance stored away from chlorine containers? ❑ ❑ 0 ❑ Comment: Are the tablets the proper size and type? 0 ❑ ❑ ❑ Are tablet de -chlorinators operational? 0 ❑ ❑ ❑ Number of tubes in use? 4 Comment: Effluent Pipe Yes No NA NE Is right of way to the outfall properly maintained? 0 ❑ ❑ ❑ Are the receiving water free of foam other than trace amounts and other debris? 0 ❑ ❑ ❑ If effluent (diffuser pipes are required) are they operating properly? ❑ ❑ 0 ❑ Comment: Flow Measurement - Effluent Yes No NA NE # Is flow meter used for reporting? 0 ❑ ❑ ❑ Is flow meter calibrated annually? 0 ❑ ❑ ❑ Page# 6 DocuSign Envelope ID: 77C14687-3F24-4700-9FOF-7338BOCE6239 Permit: NCO067342 Owner - Facility: North View Mobile Home Park Inspection Date: 06/01/2018 Inspection Type: Compliance Evaluation Flow Measurement - Effluent Yes No NA NE Is the flow meter operational? 0 ❑ ❑ ❑ (If units are separated) Does the chart recorder match the flow meter? ❑ 0 ❑ ❑ Comment: Chart recorder not working. Effluent Sampling Yes No NA NE Is composite sampling flow proportional? 0 ❑ ❑ ❑ Is sample collected below all treatment units? ❑ 0 ❑ ❑ Is proper volume collected? 0 ❑ ❑ ❑ Is the tubing clean? 0 ❑ ❑ ❑ # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees 0 ❑ ❑ ❑ Celsius)? Is the facility sampling performed as required by the permit (frequency, sampling type ❑ 0 ❑ ❑ representative)? Comment: Sample aliquot volume = 130 ml Samplinq is to take place below de -chlorination. Upstream / Downstream Sampling Yes No NA NE Is the facility sampling performed as required by the permit (frequency, sampling type, and ❑ ❑ ❑ sampling location)? Comment: Page# 7