Loading...
HomeMy WebLinkAboutWQ0032515_Final Permit_20071221WAr .�— December 21, 2007 Ms. Vicki Westbrook Deputy Director, Department of Water Management City, of Durham 101 City Hall Plaza Durham, North Carolina 27701 Dear Mr. Baker: Michael F. Easley, Governor William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources Coleen H. Sullins Director Division of Water Quality Subject: Permit No. WQ0032515 City of Durham North Durham Water Reclamation Facility Reclaimed Water Bulk Rill Operation Durham County In accordance with your permit application. received October 26, 2007, and additional information received December 14, 2007, we are forwarding herewith Permit Number WQ0021515, dated December 20, 2007, to City of Durham North Durham. Water Reclamation Facility for the construction and operation of the subject reclaimed water storage and bulk fill operation. The permit modification incorporated herein approves the operation of a bulk reclaimed water fill station with approved uses limited to: (1) Irrigation of public and private landscapes and turf; (2) Street sweeping (not street cleaning); (3) Sewer cleaning by City of Durham personnel or City authorized contractors; (4) Soil compaction and dust suppression; (5) Industrial purposes such as cooling tower make-up water, or concrete mixing; (6) Fire fighting and fire extinguishing; (7) Vehicle washing; and (8) Public and Commercial Pourer Washing Please note that the use of the reclaimed water for vehicle washing and pressure washing for commercial users is only acceptable provided that both the LTV disinfection and chlorination systems are operating properly to disinfect the reclaimed water. Educational material must be updated to cover requirements for these uses prior to the City allowing use of reclaimed water for these uses. Compliance and Review Boundaries for the reclaimed utilization areas have not been established pursuant to 15A NCAC 02T .0905. Any exceedance of groundwater standards shall require action in accordance with 15A NCAC 02L .0106. This permit shall be effective from the date of issuance until November 30, 2012, and shall be subject to the conditions and limitations as specified therein. Failure to establish an adequate system for collecting and maintaining the required operational information will result in future compliance problems. NorthCarolina ,Naturally Aquifer- Protection section 1636 Mail Service Center Raleigh, NC 27699-1636 Telephone : (919) 733-3221 intemet: www.ncwaterauality.om Location: 2728 Capital Boulevard Raleigh, NC 27604 Fax 1: (919) 715-0588 Fax 2: (919)715-6048 An Equal Opportunity/Affinnative Action Employer— 50% Reeycled/10% Post Consumer Paper Customer Service: (877) 623-6748 If any parts, requirements, or limitations contained in this permit are unacceptable, you have the right to request an adjudicatory hearing upon written request within thirty (30) days following receipt of this permit. 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, NC 27699-6714. Unless such demands are made this pexnxit shall be final and binding. If you need additional information concerning the modifications to this permit please contact Jon Risgaard at (919) 715-6167 orjon.risgaard@ncmail.net Sincerel Coleen H. Sullins cc: Durham County Health Department Raleigh, Regional Office, Aquifer Protection John Dodson, North Durham Water Reclamation Facility Technical Assistance and Certification Unit APS Central Files LAU Files NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES RALEIGH CONJUNCTIVE WASTEWATER TREATMENT AND RECLAIMED WATER UTILIZATION SYSTEM PERMIT In accordance with the provisions of Article 21 of Chapter 143, General Statutes of North Carolina as amended, and other applicable Laws, Rules, and Regulations PERMISSION IS HEREBY GRANTED TO City of Durham North Water Reclamation Facility Durham County FOR THE Construction and operation of a bulk reclaimed water fill station consisting of two (2) 5000 gallon reclaimed water storage tanks, turbidity meter, manual chlorine dosage, and associated piping and valves, with an estimated average flow of 5,000 gpd, and with approved uses limited to: (1) Irrigation of public and private landscapes and turf; (2) Street sweeping (not street cleaning); (3) Sewer cleaning by City of Durham personnel or City authorized contractors; (4) Soil compaction and dust suppression; (5) Industrial purposes such as cooling tower make-up water, or concrete mixing; (6) Fire fighting and fare extinguishing; (7) Vehicle washing; and (8) Public and Commercial Power Washing to serve North Durham Water Reclamation Facility with no discharge of wastes to the surface waters, pursuant to the application received October 26, 2007 and additional information received December 14 and 21, 2007, in conformity with the projcct plans, specifications, and other supporting data subsequently filed and approved by the Department of Environment and Natural Resources and considered a part of this permit. This permit shall be effective from the date of issuance until November 30, 2012, and shall be subject to the following conditions and limitations: WQ0032515 Version 1.0 Shell Version 070320 Page l of 11 I. SCHEDULES [please review the entire permit for reporting, monitoring, and other on -going activities] 1. Upon completion of construction and prior to operation of this permitted operation, a certification must be received from a professional engineer certifying that the permitted operation has been installed in accordance with this permit, the approved plans and specifications, and other supporting materials. If this project is to be completed in phases and partially certifiedyou shall retain the responsibility to track further construction approved under the same permit, and shall provide a final certificate of com letion once the entire project has been com leted. Mail the Certification to the Construction Grants and Loans Section, 1633 Mail Service Center, Raleigh, NC 27699-1633. 2. The Raleigh Regional Office, telephone number (919) 791-4200, shall be notified at least 48 hours in advance (excluding weekends and holidays) of initial operation of the installed facilities so that an in - place inspection can be made. Such notification to the Aquifer Protection Section regional supervisor shall be made during the normal office hours from 8:00 a.m. until 5:00 p.m. on Monday through Friday, excluding State Holidays. 3. No later than six months prior to the expiration of this permit, the Permittee shall request renewal of this permit on official Division. forms. Upon receipt of the request, the Division will review the adequacy of the facilities described therein., and if warranted, will extend the permit for such period of time and under such conditions and limitations as it may deem appropriate. Please note that Rule 15A NCAC 02T .0105(d) requires an updated site reap to be submitted with the permit renewal application. II. PERFORMANCE STANDARDS The reclaimed water utilization facilities shall be effectively maintained and operated at all times so that there is no discharge to the surface waters, nor any contamination of ground waters, which will render them unsatisfactory for normal use. In the event that the facilities fail to perform satisfactorily, including the creation of nuisance conditions or failure of the utilization area to adequately assimilate the wastewater, the Permittee shall tape immediate corrective actions including those actions that may be required by the Division of Water Quality (Division), such as the construction of additional or replacement wastewater treatment and disposal facilities. 2. The issuance of this permit shall not relieve the Permittee of the responsibility for damages to ground or surface waters resulting from the operation of this facility. 3. Operation of this reclaimed water storage and distribution system shall be contingent on approval of a modification request to this reclaimed water program permit and upon proper construction and operation of distribution, lines to be tied into either end of the distribution line approved in this permit. Future distribution line specifications must include quality assurance testing procedures and those procedures, upon approval, must be used prior to operation of this line. If potable water is used in the distribution system prior to reclaimed water becoming available, the Permittee shall develop specific cross connection control protocols to prevent cross connection when reclaimed water is subsequently used. When potable water is being used in the reclaimed water lines, the lines shall not be used for potable purposes. 4. Construction of the reclaimed water bulk distribution system shall be scheduled so as not to interrupt service by the existing wastewater system nor result in an overflow or bypass discharge of reclaimed water to the surface waters of the State. 5. Reclaimed water distributed through the bulls fill operations shall not exceed the effluent limitations specified in Attachment A. WQ0032515 Version 1.0 Shell Version 070320 Page 2 of 11 M. 6. Compliance and Review Boundaries for the reclaimed utilization areas have not been established pursuant to 15A NCAC 02T .0905. Any exceedance of groundwater standards shall require action in accordance with 15A NCAC 02L .0106. 7. The facilities permitted herein must be constructed according to the following setbacks: a. The setbacks for reclaimed utilization sites shall be as follows (all distances in feet): i. Surface waters not classified SA: 25 ii. Surface waters classified SA: 100 iii. Any well with exception to monitoring wells 100 b. The setbacks for treatment and storage units shall be as follows (all distances in feet): i. Any habitable residence or place of public assembly under separate ownership: 100 ii. Any private or public water supply source: 100 iii. Surface waters: 50 iv. Any well with exception of monitoring wells: 100 v. Any property line: 50 The following shall be requirements for the reclaimed water distribution, storage, and utilization facilities: a. All reclaimed water valves, storage facilities, and outlets shall be tagged or labeled to warn the public or employees that the water is not intended for drinking. Where appropriate, such warning shall inform the public or employees to avoid contact with the water. b. All reclaimed water piping, valves, outlets, and other appurtenances shall be color -coded, taped, or otherwise marked to identify the source of the water as being reclaimed water. i, All reclaimed water piping and appurtenances shall be either colored purple (i.e., Pantone 522) and embossed or integrally stamped or marked "CAUTION: RECLAIMED WATER — DO NOT DRINK" or be installed with a purple (i.e., Pantone 522) identification tape or polyethylene vinyl wrap. The warning shall be stamped on opposite sides of the pipe and repeated every three feet or less. ii, Identification tape shall be at least three inches wide and have white or black lettering on purple (i.e., Pantone 522) field stating "CAUTION: RECLAIMED WATER — DO NOT DRINK." Identification tape shall be installed on top of reclaimed water pipelines, fastened at least every 10 feet to each pipe length and run continuously the entire length of the pipe. c. All reclaimed water valves and outlets shall be of a type, or secured in a manner, that permits operation by authorized personnel only. 9. The Permittee shall maintain an active cross -connection control program that shall have the following minimum requirements: a. No direct cross -connections shall be allowed between the reclaimed water and potable water systems. b. A reduced pressure principle backflow preventer, an approved air gap separation, or other device approved by the Division of Environmental Health shall be installed at the potable water service connection to the use area where both reclaimed water and potable water are supplied to a reclaimed water use area. The installation of the reduced pressure principle backflow prevention device shall allow proper testing. WQ0032515 Version 1.0 Shell Version 070320 Page 3 of 11 c. An air gap separation, approved and regularly inspected by the Permittee shall be provided between the potable water and reclaimed water systems where potable water is used to supplement a reclaimed water system. III. OPERATION AND MAINTENANCE REQUIREMENTS The Permittee shall maintain an Operation and Maintenance Plan pursuant to 15A NCAC 02T .0913 including operational functions, maintenance schedules, safety measures, and a spill response plan. 2, Upon classification of the wastewater treatment and reclaimed utilization facilities by the Water Pollution Control System Operators Certification Commission. (WPCSOCC), the Permittee shall designate and employ a certified operator to be in responsible charge (ORC) and one or more certified operator(s) to be back-up ORC(s) of the facilities in accordance with 15A NCAC 08G ,0200. The ORC shall visit the facilities in accordance with 15A NCAC 08G .0200 or as specified in this permit and shall comply with all other conditions specified in these rules. 3. No type of wastewater other than that from the North Durham Water Reclamation Facility, Permit Number NCO023841, is approved for bulk distribution under the conditions of this permit. 4. Public access to the reclaimed water bulk distribution operation and utilization sites shall be controlled during active site use. Such controls may include the posting of signs indicating the use of reclaimed water and appropriate restrictions. 5. For use of the bulk fill operation the following requirements must be met: a. The Permittee shall develop and implement an operation and maintenance plan which includes but is not limited to the following i. Description of operation, I Description of anticipated maintenance, iii. Safety measures, including site restrictions, iv. Spill prevention and spill response plan, v. Contact information for plant personnel, emergency responders, and regulatory agencies, vi. Approval procedures of users, vii. Operational requirements for users, and viii.If reclaimed water is to be stored for greater than 72 hours prior to use, include a description of how reclaimed water quality standards will be meet at the time of use. b. Education program shall be developed and implemented to inform City employees of the proper use of reclaimed water for each of the approved uses. c. Education program shall be developed and implemented to inform bulk reclaimed water users of the proper use of reclaimed water for each approved use. Educational material must be provided to all individuals accepting the bulk reclaimed water. d. Educational material shall be maintained consistent with the reclaimed water uses utilized by the Permittee. Educational material shall be made available to the Division upon request. e. Use of reclaimed water for power washing or vehicle washing shall be conducted in a manner to ensure no surface runoff. f. Use of reclaimed water for power washing is acceptable provided that dual disinfection with UV and chlorination is provided. g. Where reclaimed water is used for industrial purposes, disposal of the utilized reclaimed water shall meet the conditions included in all State approved permits held by the industry (e.g. NPDES, Non -Discharge, or Pretreatment permits). WQ0032515 Version 1.0 Shell Version 070320 Page 4 of 11 h. The Permittec shall approve tank truck drivers for participation in the bulk reclaimed water distribution program prior to distribution of reclaimed water. In addition, the Permittee shall provide bilingual (English and Spanish) training to all tank truck drivers approved to participate in the bulk reclaimed water distribution program at a regular frequency. These sessions shall provide training on, but not limited to, the following topics i. Reclaimed water description and safety, ii. Approved and disapproved uses of reclaimed water, iii. Procedures for the application (including buffer maintenance), uses, and storage of reclaimed water as well as the disposal of unused reclaimed water, iv. Procedures for spill prevention, countermeasures, and control as well as notification requirements, v. Personal safety and hygiene issues, and vi. Interaction with the general public. i. Tank trucks used to transport reclaimed water shall meet the following requirements: i. Tank trucks and other equipment used to distribute reclaimed water shall be clearly identified with advisory signs. Signage could include but is not limited to "CAUTION: RECLAIMED WATER — DO NOT DR1NK", "NON -POTABLE WATER", or a combination of similar phrases ii. Tank trucks used to transport reclaimed water shall not be used to transport potable water that is used for drinking or other potable purposes. iii. Tank trucks used to transport reclaimed water shall not be filled through on -board piping or removable hoses that may subsequently be used to fill tanks with water from a potable water supply. iv. Tank trucks shall not have been used to haul septage, biosolids, or other waste or chemical transport. v. Tank trucks shall not have any type of removable container or portable bladder except if the tank/bladder is permanently labeled for reclaimed water use only and a letter from the truck owner is submitted to the Permittee indicating that in no case shall any removable container or portable bladder be used for both reclaimed and potable water at any time. 6. The Permittee shall develop and maintain a program of routine review and inspection of reclaimed water users. 7. The residuals generated from these treatment facilities must be disposed / utilized in accordance with 15A NCAC 02T .1100. The Permittee shall maintain a residual management plan pursuant to 15A NCAC 02T .0914. IV. MONITORING AND REPORTING REQUIREMENTS Any monitoring (including groundwater, surface water, soil or plant tissue analyses) deemed necessary by the Division to ensure surface and ground water protection will be established and an acceptable sampling reporting schedule shall be followed. 2. All laboratory analyses for effluent, ground waters, or surface waters shall be made by a laboratory certified by the Division for the required parameters under 15A NCAC 02H .0800. WQ0032515 Version 1.0 Shell Version 070320 Page 5 of I 3. Flow through the bulk distribution operation shall be continuously monitored and daily flow values shall be reported on Form NDMR. The Permittee shall maintain an appropriate flow measurement device consistent with approved engineering and scientific practices to ensure the accuracy and reliability of flow measurement. Flow measurement devices selected shall be capable of measuring flows with a maximum deviation of less than 10 percent from true flow, accurately calibrated at a minimum of once per year, and maintained to ensure that the accuracy of the measurements is consistent with the accepted capability of that type of device. The Permittee shall keep records of flow measurement device calibration on file for a period of at least three years. At a minimum, data to be included in this documentation shall be: a. Date of flow measurement device calibration, b. Name of person performing calibration, and c. Percent from true flow. 4. The effluent from the subject facilities shall be monitored by the Permittee at the frequency(ies) and location(s) for the parameter(s) specified in Attachment A. 5. The Permittee shall maintain adequate records. These records shall include, but are not necessarily limited to, the following information: a, Date and time of bulk distribution event, b. Name and drivers license number of truck operator, c. Bulk fill certification number (proof of certification provided to reclaimed water User), d. Name of end customer, c. Intended use of the bulk reclaimed water, f. Number of gallons provided at each bulk distribution event, g. Turbidity measurement results, and h. Total volume of bulk reclaimed water distributed each month. 6. A maintenance log shall be maintained at this facility including but not limited to the following items: a. Visual observations of the plant and plant site. b. ' Record of preventative maintenance. c. Date of calibration of the portable turbidity meter 7. Three copies of all monitoring data [as specified in Conditions IV.4. and IV.5.] on Form NDMR for each point prior to irrigation (PPI), as specified in Attachment A, shall be submitted on or before the last day of the following month. If no activities occurred during the monitoring month, monitoring reports are still required documenting the absence of the activity. All information shall be submitted to the following address: Division of Water Quality Information Processing Unit 1617 Mail Service Center Raleigh, North Carolina 27699-1617 WQ0032515 Version 1.0 Shell Version 070320 Page 6 of 11 V. 8. Inspection and maintenance records shall be maintained for a period of at least three years. 9. Noncompliance Notification: The Permittee shall report by telephone to the Raleigh Regional Office, telephone number (919) 791- 4200, as soon as possible, but in no case more than 24 hours or on the next working day following the occurrence or first knowledge of the occurrence of any of the following: a. Any occurrence at the wastewater treatment facility which results in the treatment of significant amounts of wastes which are abnormal in quantity or characteristic, such as the dumping of the contents of a sludge digester•, the known passage of a slug of hazardous substance through the facility; or any other unusual circumstances including ponding in the reclaimed utilization area or runoff from the reclaimed utilization areas. b. Any process unit failure, due to known or unknown reasons, that render the facility incapable of adequate wastewater treatment such as mechanical or electrical failures of pumps, aerators, compressors, etc. c. Any failure of disposal system resulting in a by-pass directly to receiving waters. d. Any time that self -monitoring information indicates that the facility has gone out of compliance with its permit limitations including, but not limited to, freeboard measurements, effluent limitations, exceedances of groundwater standards, or overloading of any utilization area. For any emergency that requires immediate reporting (e.g., discharges to surface waters, imminent failure of a storage structure, etc.) outside normal business hours must be reported to the Division's Emergency Response personnel at telephone number (800) 662-7956, (800) 858-0368, or (919) 733- 3300. Persons reporting such occurrences by telephone shall also file a written report in letter form within five (5) days following first knowledge of the occurrence. This report must outline the actions taken or proposed to be taken to ensure that the problem does not recur. 1. Adequate inspection and maintenance shall be provided by the Permittee to ensure proper operation of the subject facilities. A general observation of the entire reclaimed distribution system shall be conducted at least once per year. 2. If any single party obtains more than 25,000 gallons of reclaimed water from the bulk fill operation in any single day, or more than 100,000 gallons in any single week, The City shall visit the sites where that party is using the reclaimed water to ensure compliance with the conditions of this permit, The City shall maintain records of those site visits for at least three years. 3. The Permittee or his designee shall inspect the wastewater treatment and disposal facilities to prevent malfunctions and deterioration, operator errors and discharges which may cause or lead to the release of wastes to the environment, a threat to human health, or a nuisance. The Permittee shall keep an inspection log or summary including at least the date and time of inspection, observations made, and any maintenance, repairs, or corrective actions taken by the Permittee. This log of inspections shall be maintained by the Permittee for a period of five years from the date of the inspection and shall be made available upon request to the Division or other permitting authority. WQ0032515 Version 1.0 Shell Version 070320 Page 7 of 11 4. Any duly authorized officer, employee, or representative of the Division may, upon presentation of credentials, enter and inspect any property, premises or place on or related to the disposal site or facility at any reasonable time for the purpose of determining compliance with this permit; may inspect or copy any records that must be maintained under the terms and conditions of this permit, and may obtain samples of groundwater, surface water, or leachate. NI. GENERAL CONDITIONS 1. Failure to abide by the conditions and limitations contained in this permit may subject the Permittee to an enforcement action by the Division in accordance with North Carolina General Statute 143- 215.6A to 143-215.6C. This permit shall become voidable unless the facilities are constructed in accordance with the conditions of this permit, the approved plans and specifications, and other supporting data. This permit is effective only with respect to the nature and volume of wastes described in the application and other supporting data. No variances to applicable rules governing the construction and / or operation of the permitted facilities are granted unless specifically requested and granted in this permit. 4. The issuance of this permit does not exempt the Permittee from complying with any and all statutes, rules, regulations, or ordinances, which may be imposed by other government agencies (local, state, and federal) that have jurisdiction. Of particular concern to the Division are applicable river buffer rules in 15A NCAC 02B .0200, erosion and sedimentation control requirements in 15A NCAC Chapter 4 and under the Division's General Permit NCG010000, and any requirements pertaining to wetlands under 15A NCAC 02B .0200 and 02H .0500. 1n the event there is a desire for the facilities to change ownership, or there is a name change of the Permittee, a formal permit request must be submitted to the Division on official Division forms, documentation from the parties involved, and other supporting materials as may be appropriate. The approval of this request will be considered on its merits and may or may not be approved. The Permittee of record shall remain fully responsible for compliance until a permit is issued to the new owner. 6. The Permittee shall retain a set of approved plans and specifications for the life of the facilities permitted herein. 7. The Permittee shall maintain this permit until all permitted facilities herein are properly closed or permitted under another permit issued by the appropriate permitting authority. WQ0032515 Version 1.0 Shell Version 070320 Page 8 of 11 8. The Permittee must pay the annual fee within 30 days after being billed by the Division. Failure to pay the fee accordingly may cause the Division to initiate action to revoke this permit pursuant to 15A NCAC 02T .0105(e). Permit issued this the 21" of December 2007 NORTH OLiNA ENVIRONMENTAL MANAGEMENT COMMISSION -�-Coleen H. Sullins, Director Division of Water Quality By Authority of the Environmental Management Commission Permit Number WQ0032515 WQ0032515 Version 1.0 Shell Version 070320 Page 9 of 11 Permit No. WQ0032515 December 21, 2007 ENGINEER'S CERTIFICATION Partial Final I, , as a duly registered Professional Engineer in the State of North Carolina, having been authorized to observe (periodically, weekly, full time) the construction of the project, Project Narne Location and County for the Permittee hereby state that, to the best of my abilities, due care and diligence was used in the observation of the construction such that the construction was observed to be built within substantial compliance and intent of this permit, the approved plans and specifications, and other supporting materials. Signature Date Registration No. WQ0032515 Version 1.0 Shell Version 070320 Page 10 of 11 ATTACHMENT A - LIMITATIONS AND MONITORING REQUIREMENTS Permit Number: WQ0032515 Version: 1.0 PPI 001 - Bulk Fill Operation' Certification Date -- December 21., 2007 RECLAIMED WATER CHARACTERISTICS RECLAIMED WATER LIMITS MONITORING REQUIREMENTS Parameter Description - PCS Code Monthly Average Weekly Average Daily Maximum Measurement Frequency Sample Type Nitrite plus Nitrate Total I DET. (as N) - 00630 Weekly b Composite Solids, Total Suspended - 00530 5 mg/l 10. mg/1 Daily - Weekdays b Composite Chloride (as Cl) - 00940 3 X year c Composite Nitrogen, Ammonia Total (as N) - 00610 4 mg/l 6. mg/l Daily - Weekdays it Composite BOD, Carbonaceous 05 Day, 20C M 80082 10 mg/l 15. ing/l Daily - Weekdays b Composite Coliform, Fecal MF, M-FC Broth,44.5C - 31616 (geom.mean) 14 d #/100ml 25. 9/100m1 2 X month Grab Turbidity, HCH Turbidimiter - 00076 a 10. ntu See Permit Grab Plow, in conduit or thru treatment plant - 50050 See Permit Recorder pH - 00400 6.0 — 9.0 f su 9.0 Su Daily - Weekdays b Grab a Effluent sample location for all parameters except turbidity and fecal coliform.. shall be sampled at the effluent sampling point associated with NPDES Permit NC0023841. Turbidity and fecal colifonn sampling shall be sampled at the bulk fill station. b Sampling frequency is set to match NPDES permit sampling frequency. Sample results associated with NPDES permitting requirements can be used for meeting the sampling requirements for this permit as long as the sampling locations remain the same in both permits. The City may request reduced sampling frequency for parameters with sampling frequencies matching the NPDES monitoring frequencies. 3 X year sampling shall be performed every March, July and November. Monthly average for fecal coliform shall a geometric mean. 'Turbidity sampling shall be performed immediately prior to a1l bulk filling procedures. Recorded turbidity meter results shall be documented and maintained with each bulk filling event. The highest turbidity value recorded for each day of operation shall be reported. f The effluent pH shall not be less than 6.0 standard units nor greater than 9.0 standard units WQ0032515 Version 1.0 Attachment A Page 11 of 11