330 DEP sanitary Survey 2017 MassDEP Commonwealth of Massachusetts J 0
Executive Office of Energy &Environmental Affairs
Department of Environmental Protection
Western Regional Office•436 Dwight Street, Springfield MA 01103.413-784-1100
Charles D. Baker Matthew A.Bea
Governor Secret
Karyn E. Polito Martin Suubi
Lieutenant Governor Commissioi
March 1, 2017
Ms.Rhonda Culpepper, Administrative Assistant
National Water Services
River Valley Market Co Op330 North King Street
Northampton,MA 01060 Re: Northampton-DWP
National Water Services
PWS IDif: 1214004
Sanitary Survey
Dear Ms. Culpepper,
On February 14,2017,Jim Bumgardner of the Massachusetts Department of Environmental Protection
(MassDEP),Drinking Water Program(DWP)conducted a Sanitary Survey of the National Water Services
("NWS")public water system. A sanitary survey is an on-site review of the water sources,facilities,
equipment,operation and maintenance of a public water system for the purpose of evaluating the system's
ability to produce and distribute safe drinking water. The enclosed report includes the system description,
findings and compliance plan.
During the course of the survey,MassDEP identified areas in which improvements in the administration,and
operation and maintenance of the system could be made. MassDEP's evaluation of the water system,and the
specific required and recommended actions,were discussed during a debriefing meeting with Loren. This
report contains time sensitive requirements,which are summarized in the Compliance Plan Tables. Please
review the items noted in the report and Compliance Plan Table B,and return the signature page to
MassDEP by March 31,2017. Specifically,MassDEP requires the following actions to remedy items
{ noted in the inspection:
During the inspection, MassDEP observed that the Certified Operator for NWS accompany state or other
officials during inspections of the water system. MassDEP requires that the Certified Operator for
NWS accompany state or other officials during inspections of the water system.
Electronic File Location:Y:\DNP Archive\\VERO\Northampton-1214004-SS-2017-03-01
This information is available in alternate format.Contact Michelle Waters-Ekanem,Director of Diversity/Civil Rights at 617-292-5751.
TTY#MassRelay Service 1-800-439-2370
MassDEP Website:www.mass.govldep
Printed on Recycled Paper
NATIONAL WATER SERVICES PWS ID#: 1214004
INSPECTION DATE:FEBRUARY 14,2017 PAGE 2 OF 2
Questions regarding this document, or other drinking water issues,should be directed to Jim Bumgardner at
(413)755 2270.
Respectfully,
-4111VAPPPP
Deir. e Doherty, Section Chief
Drinking Water Program
Bureau of Water Resources
Attachments: Sanitary Survey Report
cc: Board of Health—Northampton,Boston—DWP,Jim Bumgardner,MassDEP WERO,Robert
Flagg
WERO File Location: W:\brp\w•s\CCE-SS\Northampton\1214004-National Water Services\National
Water Services jbumgardner-2017.doc
SANITARY SURVEY REPORT
National Water Services
March 1,2017
GENERAL DESCRIPTION
General:
The vending system consists of a National Water Systems,Model WDCA2-3-2 water purification treatment
system, distribution from the treatment to the dispenser,and the dispensing machine.
This vending machine model was issued"New Technology—Vending POU/POE"approval by MassDEP on
March 3,2016. The water to be used will be furnished by a pluming connection with the Northampton Water
Department.
Source:
The water source is the Northampton DPW public water system(1241000-01P). The source relies mainly on
treated surface water. A raw water tap is provided.
Storage:
An 80 gallon fiberglass storage tank is provided near the treatment unit upstairs.
Distribution:
A reduced pressure backflow prevention device located upstairs near the treatment unit,protects the
Northampton PWS(PWS ID#1214000)distribution system from cross contamination. The Northampton
Water Department tests the device on a regular basis. Treated water is stored in the fiberglas storage tank and
transported through the store and into the dispensing unit near the front of the store.
Treatment:
From the interconnection with the Northampton Water Department,water flows through an calcium
carbonate contactor,granular activated carbon,scale/corrosion prevention pre-treatment system,a 1.0 hp
reverse osmosis(RO)unit,an ion exchange resin unit,a conductivity meter,a volume flow meter,various
cartridge filters,and a UV Superstore#QU-4 ultraviolet disinfection unit. The unit is capable of providing
"High pH"water by recirculating the purified water through a media cartridge that contains a blend of
minerals.
The treatment unit backwash discharges to a floor drain in the upstairs floor that travels to the municipal
sewer.
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NATIONAL WATER SERVICES PWS ID#: 1214004
INSPECTION DATE: FEBRUARY 14,2017 PAGE 2
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INSPECTION DATE: FEBRUARY 14,2017 PAGE 3
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NATIONAL WATER SERVICES PWS ID#: 1214004
INSPECTION DATE:FEBRUARY 14,2017 PAGE 4
SANITARY SURVEY REPORT
National Water Services
March 1,2017
FINDINGS
SECTION 1: ADMINISTRATION,MANAGEMENT,AND STAFFING
System Classification:
NWS is classified as a Transient,Non-Community(TNC)public water system(PWS)because the facility
serves at least 25 people per day,for more than 60 days per year. The distribution systems for all non-
community public water systems are classified as VSS systems.
NWS retains the services of a Contract Certified Operator and monthly inspection logs were available at
the time of the NWS inspection.
NWS retains the services of a Contract Operator and has an up-to-date Certified Operator Compliance
Notice on file with MassDEP.
The following are personnel employed by NWS for the operation of its PWS:
Operator Name Grade License Primary Primary 11
Distribution Treatment
Robert Flagg 2T/2D 12072/11499 X
Robert Flagg 2T/2D 12072/11499 X
Table 1: NWS Certified Operators
NWS therefore meets MassDEP's Certified Operator requirements.
SECTION 2: OPERATIONS AND MAINTENANCE
The Certified Operator for NWS conducts routine visual inspections of all water system components.
The Certified Operator for NWS records the results of all inspections on an approved form and provides a
copy of that form to NWS at the end of each inspection.
The Certified Operator for NWS reads the water meter and records the water meter readings monthly on a
MassDEP-approved form.
The Certified Operator for NWS oversees the actions of uncertified individuals conducting.maintenance
on water system components.
During the inspection,MassDEP observed that the Certified Operator for NWS accompany state or other
officials during inspections of the water system.MassDEP requires that the Certified Operator for
NWS accompany state or other officials during inspections of the water system.
NATIONAL WATER SERVICES PWS ID#: 1214004
INSPECTION DATE:FEBRUARY 14,2017 PAGE 5
SECTION 3: TREATMENT
No treatment issues were identified during the Sanitary Survey inspection.
SECTION 4: DISTRIBUTION,STORAGE,AND PUMPING FACILITIES
A cross connection program review was completed during the inspection. Follow up distribution system
checks are conducted on a regular basis. All systems may be subject to a cross connection audit by
MassDEP,to ascertain whether the water system is in compliance with the cross connection regulations as
outlined in Section 22.22(16Xe)of the Massachusetts Drinking Water Regulations.
During the survey,MassDEP observed that Northampton DPW conducts regular annual cross connection
device testing.
SECTION 5: WATER QUANTITY
No water quantity issues were identified during the Sanitary Survey inspection.
SECTION 6:WATER QUALITY MONITORING AND REPORTING
MassDEP reviewed the most recent NWS Water Quality Sampling Schedule(WQSS)dated October 27,
2016. NWS is required to collect water quality samples according to that schedule. A spreadsheet' is
available from the MassDEP website that contains the monitoring requirements for every PWS in the
Commonwealth.
Bacteriological Monitoring Under the Revised Total Coliform Rule
The required number of total routine monthly coliform samples is based primarily on population-and
system characteristics. Under the Revised Total Coliform Rule,monthly routine sampling locations
representative of entry points and storage must also be provided in the Coliform Sampling Plan. If the
NWS population changes such that it exceeds or falls below a threshold listed in Table I of 310 CMR
22.05 NWS must contact the MassDEP regional office to update its Coliform Sampling Plan. System
characteristics such as storage,treatment facilities,source water quality, and the number of sources also
affect the total number of required coliform sampling locations. For those systems that treat the source
water,the Coliform Sampling Plan must include an additional routine monthly sample collected from the
raw water source(s)per 310 CMR 22.05(1)(a). The Coliform Sampling Plan must also list all
groundwater sources to be sampled to meet the requirements of the Groundwater Rule.
MassDEP reviewed the current Coliform Bacteria Sample Plan. The Plan was determined to satisfy the
following criteria from the regulations at 310 CMR 22.05 (1):
o Site(s)representative of the water throughout the distribution system:Dispenser Tap
o Site(s)representative of raw water prior to treatment: Pre-Treatment Tap
MassDEP advises NWS that the Revised Total Coliform Rule was implemented on April 1,2016
(see Section 8 for Revised Total Coliform Rule(RTCR)highlights). All Coliform Sampling Plans
'The file name is"locid.xls".
NATIONAL WA ER SERVICES PWS Mit: 1214004
WSPECITON DATE:FEBRUARY 14,2017 PAGE 6
will be updated to incorporate RTCR provisions and will be issued to PWSs when they are
completed. PWSs are still responsible for collecting all samples required under the RTCR,
including seasonal start-up samples(when applicable),even prior to receiving the updated
Coliform Sampling Plans. Please contact the Drinking Water Program in your regional office if
you wish to update your Coliform Sampling Plan now.
NWS has installed raw water sampling taps at its source and should be able to sample for bacteria at its
groundwater source within 24 hours of a bacteria detection as required in the regulations at 310 CMR
22.05(1). In the event of a bacteria detection for E.Coli,NWS must notify MassDEP and
Northampton DPW within 24 hours of the laboratory notification to NWS.
See Section 8 for Revised Total Coliform Rule(RTCR)highlights.
SECTION 7: SOURCE AND SOURCE PROTECTION
NWS is a consecutive system to Northampton DPW and does not have any of its own water sources.
SECTION 8: CURRENT AND FUTURE REGULATORY REQUIREMENTS
Revised Total Coliform Rule(RTCR)Highlights
Massachusetts incorporated EPAs' Revised Total Coliform Rule(RTCR) into its revised Drinking Water
Regulations which became effective April,2016. The RTCR contains the following provisions to
increase public health protection by focusing on measures that will reduce potential pathways for the
entry to fecal contamination into public water system(PWS)distribution systems. Under the RTCR,
PWSs that are vulnerable to microbial contamination are required to conduct detailed investigations to
identify and fix problems. The RTCR establishes an MCL for E. coli,since it is a more specific indicator
of fecal contamination and a potentially more harmful pathogen than other coliform bacteria. The Total
Coliform Rule's previous MCL violation for total coliform bacteria has been replaced by a Treatment
Technique trigger that requires a Level 1 Assessment.
Sampling
The number of routine monthly samples is still population-based,but there are requirements for additional
entry point and storage samples. All routine monthly samples must be collected, even if a Treatment
Technique trigger has been exceeded or there is an E. coli MCL.
Three repeat samples are required for every total coliform positive(TC+)location,regardless of system
size and even if the TC+location is at the end of the distribution system. Additional rounds of repeats
must be collected until a treatment technique trigger is exceeded or one clean round of samples has been
obtained.
Only systems on quarterly monitoring are required to collect additional routine samples in a month
following a TC+. All other systems collect their normal number of monthly routine samples.
Seasonal Systems
Seasonal systems that are not operated as PWSs on a year-round basis and start up and shut down each
operating season,must demonstrate completion of a state-approved Start-up Procedure and Certification
prior to serving water to the public each season.. The Certification must be submitted to MassDEP 7 days
NATIONAL WATER SERVICES PWS ID#: 1214004
INSPECTION DATE:FEBRUARY 14,2017 PAGE 7
prior to serving water to the public. The approved procedure must demonstrate completion of the
following activities, at a minimum:
• Notification to MassDEP and the Certified Operator of the planned date on which water will be
served to the public;
• Inspection of all water system components(i.e.,sources,treatment components,distribution lines
and storage tanks)along with completion of any required repairs and maintenance;
• Activation of source(s);
• Flushing of the entire distribution system(s); and,
• Collection of seasonal start-up samples from all routine monthly locations, as well as any additional
locations required within any re-activated portions of the distribution system.
Additional start-up activities may include chlorination of the tanks and distribution system,re-installation
and maintenance of required disinfection equipment,and re-installation of water meters and backflow
preventers, if applicable.
Treatment Technique TriRRers and Assessments:
PWSs must conduct Assessments after exceeding a Treatment Technique(TT)Trigger and must notify
MassDEP no later than 5 days after the collection date of the sample that triggered the assessment.
Level 1 Treatment Technique Triggers:
• More that 5%of monthly samples are TC+for a system collecting 40 or more samples per month
(former TC MCL)-NO PUBLIC NOTICE(PN)REQUIRED;
• More than 2 TC+samples per month for systems collecting fewer than 40 samples per month(former
TC MCL)-NO PN REQUIRED; and,
• Failure to take every required repeat sample after any single TC+ sample-NO PNREQUIRED.
Level 2 Treatment Technique Triggers:
➢An E. coli MCL Violation(Requires TIER 1 PN and same day notification to MassDEP):
• EC+repeat sample following a TC+routine sample(former acute MCL);
• TC+repeat sample following an EC+routine sample(former acute MCL);
• Failure.to take all required repeats following a EC+ routine sample; and,
• Failure to analyze for E. coli in a TC+repeat sample.
>A second occurrence of a level 1 Trigger within a rolling 12-month period-unless MassDEP
determines the reason for the TC+detection related to the first Level 1 Trigger and the PWS has
corrected that problem.
Level 1 and Level 2 Assessments are conducted to identify the possible presence of sanitary defects and
defects in distribution system monitoring practices. The elements of a Level 2 Assessment are generally
the same as those of a Level 1 Assessment,but each element is investigated in more detail.
At a minimum,both Level 1 and Level 2 Assessments must evaluate the following elements: atypical
events,changes in distribution system maintenance and operation,condition of the source and treatment,
and inadequacies in sample sites,sampling protocol and sample processing. Level 1 and Level 2
Assessments must describe any Sanitary Defects found,describe all completed Corrective Actions,and
propose a timetable for completing any Corrective Actions that have not been completed by the time the
Assessment Form is submitted(i.e.,30 days from the triggering event). MassDEP must be notified when
each of these Corrective Actions has been completed.
RTCR Violations and Public Notice Requirements
NATIONAL WATER SERVICES PWS ID#: 1214004
INSPECTION DATE:FEBRUARY 14,2017 PAGE 8
There are a number of new violations under the RTCR. All violations require some form of public notice.
There is also new mandatory health effects language for public notices and Consumer Confidence Reports
(CCRs). MCL,Monitoring and Treatment Technique Violations must be reported in CCRs along with
appropriate health language. CCRs must also contain information on E. coli detections and Level 1 and
Level 2 Assessments. All RTCR violations are listed below.
E.coli MCL Violations(individual types listed above) (Require TIER 1 PN within 24 hours and same
day notification to MassDEP)
Treatment Technique Violations(Require TIER 2 PN within 30 DAYS and notification to MassDEP no
later than end of next business day after learning of violation.):
• Failure to conduct a Level 1 or 2 Assessment or implement Corrective Actions within the
specified timeframe.
• Failure of a Seasonal System to complete a MassDEP-approved Start-up Procedure and
Certification prior to serving water to the public.
Monitoring Violations(Require TIER 3 PN within 1 YEAR and notification to MassDEP within 10 days
of learning of violation):
• Failure to take every required routine or additional routine sample in a Compliance Period.
• Failure to analyze for E. coli in a TC+routine sample.
Reporting Violations(Require TIER 3 PN within 1 YEAR):
• Failure to submit a monitoring report or Assessment Form by the required deadline,after
completing timely monitoring or Assessment.
• Failure to notify MassDEP of an EC+result by the end of the day on which the PWS was
notified of the result.
• Failure to notify MassDEP of an E. coli MCL violation by the end of the day on which PWS
learns of the violation.
• Failure to submit Certification of completion of a MassDEP-approved Seasonal Start-up
Procedure 7 days prior to the date on which the PWS will begin serving water to the public.
• Failure to notify MassDEP of a Treatment Technique Trigger within 5 days of the collection date
of the sample that triggered the Assessment.
• Failure to notify MassDEP of a coliform monitoring violation within 10 days of learning of the
violation.
Recordkeeping Violations(Require TIER 3 PN within 1 YEAR):
• Failure to maintain Assessment Forms,Corrective Action documentation or other summary
documentation of Sanitary Defects for at least 5 years.
• Failure to maintain a record of any repeat sample taken that meets state criteria for an extension
of the 24-hour period for collecting repeat samples(per 310 CMR 22.05(2)(a). f.
Emergency Plans,Response and Reporting Requirements:
On May 2, 2008,MassDEP issued revised regulations regarding emergency plans,response and reporting
requirements. As of that date,Public Water Systems were required to have prepared an Emergency
Response Plan,which includes appropriate response actions to potential or actual emergencies,including
but not limited to:
1. Loss of water supply from a source;
NATIONAL WATER SERVICES PWS ID#: 1214004
INSPECTION DATE:FEBRUARY 14,2017 PAGE 9
2. Loss of water supply due to major component failure;
3. Damage to power supply equipment or loss of power;
4. Contamination of water in the distribution system from backflow or other causes;
5. Collapse of a reservoir,reservoir roof, or pump house structure;
6. Break in a transmission or distribution line that could result in a loss of service to customers
for more than four hours;
7. Potential or imminent threat of chemical or microbiological contamination of the water supply
over limits specified by MassDEP's Office of Research and Standards' as set forth in the
Standards and Guidelines for Contaminants in Massachusetts Drinking Waters. (available on-
line at http://www.mass.gov/dep/water/laws/regulati.htm#chems);
8. Potential or imminent threat of an overfeed of an approved drinking water treatment chemical
into the system;
9. An act of vandalism or sabotage that has the potential to impact or impacts water quality or
the quantity of water available to the system.
10. A shortage or lack of resources that could affect the operations of the system, such as:
a. Staffing shortages:
b. Receipt of notice from a power utility of lengthy power outages; or
c. Imminent depletion of treatment chemical inventory; and
11. Any other failure of part or all of the water supply system due to equipment failure,human
acts(deliberate or accidental)or natural or human made disasters.
These requirements are described in sections 310 CMR 22.04(13)of the Regulations.
Section 310 CMR 22.15(9) of the regulations incorporates 2-hour and 24-hour emergency notification
requirements to both MassDEP and the Board of Health, for specified emergency. Within 30-days of a
reportable emergency,the water supplier must complete an Emergency Response Report and submit a
copy of that Report to MassDEP for Level III, Level IV or Level V emergencies, Cross Connection
incidents,and any of the emergency incidents listed in Items#1 through#11 above.
Every public water supplier was required to submit an Emergency Response(ERP)Compliance Checklist
to MassDEP by December 31, 2009.
NATIONAL WATER SERVICES PWS ID#: 1214004
INSPECTION DATE:FEBRUARY 14,2017 PAGE 10
SANITARY SURVEY COMPLIANCE PLAN
RESPONSE FORM for TABLE A or B
JVithin 30 days of receipt of this inspection report,you must complete and submit this response form if your
.ystem has TABLE A—Violations and/or TABLE B-Deficiencies (see attached Compliance Tables). Attach a
:opy of the completed tables listing the date that the corrective action was or will be taken by your system and
ill other applicable documentation. (310 CMR 22.04(12))
Please note that violations listed in TABLE A of the Compliance Plan are also a Notice of Noncompliance
(NON) pursuant to M.G.L. c.21A, §16 and 310 C.M.R. 5.00 and may require the submission of quarterly
written progress reports on the identified violations.
['he following corrective actions listed in the Sanitary Survey Compliance Plan(s)TABLE A and/or B has been
aken by the public water system.(Please check all that apply).
0 My system has taken ALL of the corrective actions listed within the timeframes specified in the Sanitary
Survey Compliance Plan(s).
• For each item,I have listed the completion date of the corrective action within each table.
• I have attached copies of supporting documentation as required.
❑ My system has taken SOME BUT NOT ALL of the corrective actions listed within the timeframes
specified in the Sanitary Survey Compliance Plan(s). My system HAS NOT complied with ALL of the
requirements set forth in the Sanitary Survey Compliance Plan(s).
• For each item,I have listed the actual or anticipated completion date of the corrective action within
each table.
• I have attached copies of supporting documentation as required.
• I have attached a revised corrective action schedule establishing timelines for my system to address
outstanding items and I will submit a written progress report each quarter(every 3 months)until all
items have been addressed. I understand that my system may be subject to further enforcement
action.
❑ My system is UNABLE to comply with some or all of the corrective actions within the timeframes
specified in the Sanitary Survey Compliance Plan(s). I understand that my system may be subject to
further enforcement action.
• An explanation is attached.
[hereby acknowledge receipt of the inspection findings and compliance plan table(s)of the sanitary survey conducted
by the Department of Environmental Protection's Drinking Water Program. I certify that under penalty of law I am
the person authorized to fill out this form and the information contained herein is true, accurate and complete to the
best of my knowledge and belief.
Water Commissioner,Owner,Owner Representative or Other Responsible Party:
Signature: Date:
Print Name: Title:
Return this form,a copy of each Compliance Plan Table and all attachments to:
DEP-BRP Drinking Water Program,436 Dwight Street,Springfield,MA 01103
Attention:Jim Bumgardner
NATIONAL WATER SERVICES PWS ID#: 1214004
INSPECTION DATE:FEBRUARY 14,2017 PAGE 11
INSPECTIONDATE:renruary 14,Lu1
SANITARY SURVEY
COMPLIANCE PLAN- TABLE B - REQUIREMENTS
Sanitary survey items that are required to be corrected to improve the protection of drinking water and public health pursuant to M.G.L. 111§ 160.
MassDEP/DWP will provide technical assistance to systems responding to these deficiencies. Please call your regional DWP office for referral to
the a.•ro.riate staff.erson.
Section Deficiencies Corrective Actions Deadline Sig. Completed
for Def.? Date
Taking
Corrective
Actions
O and M During the inspection,MassDEP observed that MassDEP requires that the Certified Operator On-going No
the Certified Operator for NWS accompany for NWS accompany state or other officials
state or other officials during inspections of the during inspections of the water system.
_ water system.
Monitoring NWS has installed raw water sampling taps at In the event of a bacteria detection for E.Coli, On-going No
and its source and should be able to sample for NWS must notify MassDEP and Northampton
Reporting bacteria at its groundwater source within 24 DPW within 24 hours of the laboratory
hours of a bacteria detection as required in the notification to NWS.
regulations at 310 CMR 22.05(1).
*MassDEP reserves the right to exercise its Order authority under M.G.L.Chapter 111,Section 160,or to take othcr appropriate action as permitted by law,in order to prevent the
pollution and to secure the sanitary protection of the water supply and to ensure the delivery of a fit and pure water supply to all consumers,including without limitation if
sufficient progress to meeting a recommended deadline is not achieved.
**MassDEP requests that periodic progress reports be submitted,e.g.,quarterly(each January ln,April l",August r,December 1st,etc.,for as long as necessary)or otherwise.
GWR SD=Ground Water Rule Significant Deficiency
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