Loading...
HomeMy WebLinkAboutWater Letter BUTTE COUNTY FWWSTryAM@Oti w - rp/gip, %f�iw iR.. 'l NxNY1pV LI y, O'.kvpl Lttl nb lZ. APR �$%"q� V'ry" �V. rf ttdr.ar" nx4 ' uhJYri rrr wRir raua„u� . 'Water Boards a6s pROMppLE,µ ywNypRMA ikt Y14'F tUNV "V "^wr dr P4 '4VrtA rf o,tiVCd.IV State Water Resources Control Board DiOsion of Drhkr ng Watei April 4, 2016 90M OF SUPEOM Bred Banner, Director APR 0 6 20% Butte County Environmental Health OROVKJJ,0 202 Mira Larva Drive Croville, CA 95965 Dear Mr. Banner: Qn September 9, 2015, the State Water Resources Control Board-Division of Drinking Water (Division) representatives conducted an annual evaluation of the Local Primacy Agency (LPA) Program for Butte County for fiscal year (FY) 2014-2015. The representatives conducting the evaluation were Dan Cikuth- Associate Sanitary Engineer and Wendy Killou-Senior Environmental Scientist (Supervisor) Representing. the LPA were Mike Huerta-Program Manager and Amanda Aguiar-Senior REHS. The evaluation and report are mandated by California Health and Safety Code (CHSC) Section 116339(d). The purpose of the evaluation is to determine the P'rogram's status with respect to the objectives set forth in the Butte County LPA Work Plan for FY 2014- 2015 and compliance with the requirements set forth in the LPA Delegation Agreement (LPDA) and California Code of Regulations (CCR) Title 22, Sections 64263 through 64260. Theis report summarizes the fundings, directives, and recommendations of the Division as it relates to requirements of the LPA Program. The Division finds that Butte County is in compliance withal[ requirements of the current LPA Delegation Agreement. In addition, the LPA has substantially met the Program objectives that were outlined in the approved FY 2014-2615 work plan and the LPA Program requirements set forth in CCR Title 22, Sections 64253 through 64260. The findings of this evaluation are detailed in the enclosed Attachment A. Upon completion of the evaluation, Division representatives find the items listed below are required to be addressed by the Butte County LPA Program. Please submit a written response demonstrating willingness to comply with the items below by April 22, 2016. 1'r lj't 7 r,r xg 1, `;,ir,i anaro4`i"r r.,h 15ki 4 IVIO'di n.I A¢ fines Fr C; Hox DO ac a ni ir',u'a, ,a 1 ra,r^_(1 YU: � 'A �w watowl )ti.i r� go" Brad Banner - 2 - March 22;'20116 DIRECTIVES 1. By May 2, 2016, the LPA shall require groundwater systems that provide treatment to submit monthly operation reports.' The LPAshall review and track the operation reports to ensure that the treated water meets all primary and secondary drinking water standards. 2. Starting May 2, 2016, the LPA shall require that all SWTR systems send mgnth.[y reports of the filtration and disinfection compliance data to the LPA. The LPA must review, track, and follow-up on monthly SWTR reports to determine compliance with filtration and disinfection requirements. For<water system'ahat are in noncompliance with the SWTR, an add ressing'enforcement action-shall be issued. 3. By May 2, 2016, the LPA shall amend the FY 2016-2017 work plan by adding the following systems that did not receive a Permit in FY 2014-2015 work plan: • Concow School (PWS No. 0400064) • Paradise.Adventist Church (PMIS No. 0409190) 4. 'By December 31; 2016, the LPA shall evaluate all community and nontransient non community (NTNC)Water systems to`determine whether an SOC waiver is applicable far each source. The LPA shall use the criteria as stated in CCR Title 22, 64445 (d)(1) &(2)"'to determine if each`source can be designated as nonvulnerable. Documentation may"be obtained from the SWRCB-DDW District Office;.the Butte County.Agricultural.Commission"via submittal of a public records ..request form "(htt" s://Www buttecount :net/Pbrtals/2/Public.lnformatidn -Re nest: 'df) or CalAgPermits website (httr)s://www.calagpermifs.org/Member§hip/Contacts.htt1). All SOC waivers are valid for a maximum of three years as stated in CCR Title.22,. Section 64.445 (d}(4}• NEW"REQUIll,EMENT 1. Beginning July 1, 2016, the LPA shall begin submitting to the Division in PDF format a copy of each citation, compliance order, and any court,filings issued by the LPA. Further guidance will be provided to the LPA from.the Division. (LPDA- Section 2.05 (a)(iii)) Brad Banner - 3 - March 22, 2016 RECOMMENDATIONS 1 The Division recommends that the LPA review water systems' water quality sampling data within their regulatory jurisdiction by either the LPA accessing the water quality sampling history via the DRINIC portal-Water Quality Inquiry database at ht.tr)ml/drinc.ca.,(iov/'dnri/,Ap u a..51 p icafions/WaterQ uali I _spj or logging directly into the Division Water Quality Inquiry database (request for logon credentials required). We suggest that this be completed during the file review, prior to conducting a sanitary survey, to ensure that a water system's contracted certified environmental health laboratory is successfully transmitting the water quality data electronically to the Division as required in CCR Title 22, Section 64469 (c). 2. Continue to comply with the electronic annual report (eAR) requirements as stated in the LPDA-Section 2.06. For the 2015 eAR, the Division will be evaluating compliance with this section based on submittals from community and non-transient non-community (NTNC) water systems 3. Continue to update the water quality monitoring and reporting requirement notices to water systems to include the following: contaminant name, storet code, frequency of sampling, and any other sampling and reporting requirements applicable to a water system. Provide the updated notices at a minimum frequency of three (3) years for community water systems and five (5) years for non-community water systems, for example, send with the annual fees., (LPDA- Section 2.04 (a)) 4. The LPA should create a tracking system to track and follow-up with water systems sanitary survey deficiencies to ensure that they are corrected in a timely manner, based on their priority. 5. Continue to review water system files to ensure that there is a current emergency notification plan (ENP) on file. The County should use the State approved format. This form should be updated annually or when there is a change in the contact information/emergency plan. (CCR Title 22, Section 64255 (a)(3)) The Division looks forward to our continued partnership as we share the oversight of small public water systems in Butte County. If you have any questions regarding this letter, please, contact Wendy Killou-Primacy Liaison Unit at 916-449-5158. Brad Banner - 4 - March 22, 2016 Sincerely, Wendy Killou Senior Environmental scientist (Supervisor) Primacy Liaisons Unit cc: Butte County Board of Supervisors Deese Crenshaw, Valley District Engineer Enclosures ATTACHMENT A LOCAL PRIMACY AGENCY ANNUAL EVALUATION FORM FOR FISCAL YEAR 2014-2015 (July 1, 2014 — June 30, 2015) COUNTY OF BUTTE INTRODUCTION In order to comply with Health and, Safety Code (CHSC) Section 116330(d) the State Water Resources Control Board—Division of Drinking; Water (Division) is required to evaluate a Local Primacy Agency (LPA) annually to ensure that the LPA is complying with the requirements of the Local Primacy Delegation Agreement (LPDA), California Code of Regulations (CCR), California Health and Safety Codes (HSC), and has achieved the workplan goals for Fiscal Year (FY) 2014-2015. In order to fulfill the annual evaluation requirement, we are requesting the LPA complete this forme to assist the Division in evaluating whether or not the LPA is in compliance with the requirements of the LPDA and has met the workplan goals. Please complete this form for the period from July 1, 2014— June 30, 2015 and email or mail it back to your District field office prior to the annual evaluation meeting. EVALUATION 1. Previous Year's Evaluation Directives - Check the directives- that have been completed or resolved. F Did, not receive Previous Year's Evaluation Recommendations - Continueto prepare and submit a work plan annually to the Valley District office and the Small Water Systems Unit in Sacramento no later than May 1, 2014 for the 2014-2015 FY. Continue to review water system files to ensure that there is a current emergency notification plan (ENP) on file. The County should use the State approved format. This plan should be updated annually and could be required to be updated with the, annual operating permit fees. Last Updated-812212014 Page 1 of 11 Local Primacy Annual Evaluation Form Fiscal Year 2014-2015 County of Butte Z Continue to incorporate the CDPH Permit Policies and Procedures Manual in the development and issuance of water supply permits. Reissue a permit whenever the original permit does not adequately describe the current system or is more than 10 years old using the State formatted permit template. Section 116525 (c) of the CHSC grants the LPA authority to renew, reissue, revise, or amend any domestic water supply permit whenever the LPA deems it to be necessary for the protection of public health whether or not an application has been filed. The Department recommends the following prioritization scheme when issuing new permits for water systems: L Systems adding new facilities (wells, treatment, etc.) ii. Surface water systems iii. Systems treating for a primary MCL violation (Nitrates are of the highest priority of MCL violations) iv. Systems that are changing ownership. By April 1, 2014, the LPA is recommended to send a letter notifying all public water systems within their regulatory jurisdiction of the requirement to complete the electronic Annual Report (eAR) for calendar year 2013. Emailed ADril 17t"' El Continue to ensure that all new systems and all systems undergoing a change in ownership meet the applicable Technical, Managerial, and Financial (TMF) capacity requirements by evaluating the TMF capacity of those water systems during the permitting process to ensure that the systems can at all times provide water that meets drinking water standards to the public. Mail the completed and signed TMF assessment with a copy of the Staff' Evaluation Form each to George Faggella in Sacramento headquarters and the Valley District Office. Prior to a sanitary survey, the LPA is recommended to request a Water Quality Monitoring Report from CDPH to ensure that a water system's registered environmental health lab is successfully transmitting the water quality data electronically to CDPH, as stated in 22 CCR 64469(c). Revised 711612015-wkk Page 2 of 11 Local Primacy Annual Evaluation Form, Fiscal Year 2014-2015 County of Butte Strive to get 100% of projected inspections/sanitary surveys as stated in the FY 2013-2014 work plan. Continue to retain and update technical reports, bacteriological sample site plans, and emergency notification plans as necessary when information is developed or as inspections are conducted. Continue to file and retain bacteriological water quality results for minimum of five (5) and chemical water quality results for minimum of ten (110) years in each water system file. Continue to file all correspondences, including enforcement letters, memoranda, or any other written records for a minimum of three (3) years. The County should utilize the CDPH Lead and Copper Rule database for tracking compliance with monitoring action level exceedances and monitoring and reporting of sampling for lead and copper. Continue to submit EDT data files to the SWS Unit monthly. Now_qg2rterly Ensure water systems with a groundwater or surface water source that is adding a chemical disinfectant to any part of their treatment process or provides water that contains a chemical disinfectant are monitoring for TTHMs and HAA5s at the frequency that is stated in the disinfection byproduct rule (DBPR), refer to CCR-Title 22 section 64530. Issue an addressing enforcement action if a water system fails the monitoring and reporting requirements as stated in the DBPR. Follow-up with water systems that exceed the DBPR MCLS as stated in CCR-Title 22 section 64534 and impose increased monitoring requirements, if needed. Issue an addressing enforcement action if a water system fails a DBPR MCL, F-1 The County should utilize the DBPR tracking spreadsheet that is utilized by the Valley District Office to track water systems that are required to monitor for DBPs and ensure that they are complying with the DBPR. Contact Valley District Staff for a copy of the spreadsheet and training. ??? unsure what this is?? Staff in the Small Water System Program must have detailed knowledge of all aspects of small water systems as well as the laws and regulations governing PWSs. Therefore, it is important that Butte County Environmental Health Department continues to allocate the resources to Revised 711612015-wkk Page 3 of 11 Local Primacy Annual Evaluation Form Fiscal Year 2014-2015 County of Butte recruit, develop, retain, promote, and support staff to assure an able, knowledgeable, and motivated workforce in the Small Water System Program. Strive to implement addressing enforcement actions as described, herein, particularly for MCL violations, to avoid water systems totaling points towards EPA's Enforcement Targeting Tool (ETT) when Notice of Violation is utilized. 2. Water Supply Permits (CCR Title-22, Section 64254 Now Permit (Full) 1 3 Amended Permit (Treatment 1 1 or Change of Ownership) Updated/Renewed, 1 0 Permit (Full) TOTAL PERMITS ISSUED 3 Water Systems currently without a Water Supply Permit Paradise Adventist Church Refer to Attachment B-Table 1 aand 1 b for detailed water supply permit information. > Did the LPA meet the workplan goal of permits to be issued for each type of permit listed above? n Yes E No If no, please describe why, Permit Amendment: New Permit: Concow School: working with D.E, currently in process of being issued. Paradise Adventist Church: awaiting information. > Is the LPA issuing water supply permits that are in the Division approved format, including the special operating provisions and a technical report in support of the permit? E Yes E] No If no, please describe why. Insert Description Here Revised 711612015-wkk Page 4 of 11 Local Primacy Annual Evaluation Form Fiscal Year 2014-2015 County of Butte > Did the LPA evaluate the technical, managerial, and financial (TMF) capacity by completing TMF assessments for new and change of ownership water supply permits that were issued? Z Yes Ej No If no, please describe why. Insert Description Here > Now does the LPA track their water supply permits? R Database ❑ Spreadsheet Z Other- Specify 3. Water System Inventory (CCR 5 , Title 22, Section 64?L) Refer to Attachment B-Tables 2-6 for detailed inventory information. > How does the LPA maintain their water system inventory? Z Database Z Spreadsheet R Other- Specify 4. Surveillance - Sanitary Surveys (CCR, Title 22, Section 64255) Per the LPDA, this section will be evaluated based on the minimum requirement of conducting an on-site sanitary survey of each community water system every three (3) years and non-community water system every five (5) years, unless other specified frequency is stated in the annual workplan. M "e"g)'M 11 101M 5, F, J Community Water System 7 8 Non-transient Non- 12 13 community Water System Transient Non-Gommunity 6 6 Water System TOTAL SANITARY 25 27 SURVEYS CONDUCTED Refer to Attachment B-Table 7 and 8 for detailed sanitary survey information. > Did the LPA meet the workplan goal of sanitary survey to be completed? Yes Z No If no, please describe why. One systems frequency's changed and another system was no, longer defined as a PWS. > How does the LPA track sanitary surveys conducted? Z Database Z Spreadsheet R, Other- Specify Didthe LPA review the water system water supply permit and files prior to conducting each sanitary survey? Z Yes El No Revised 711612015-wkk Page 5 of 11 Local Primacy Annual Evaluation Form Fiscal Year 2014-2015 County of Butte If no, please describe why. Insert Description Here > Did the LPA evaluate the water system's ability to produce and distribute safe and reliable drinking water by looking at the required eight (8) elements when conducting the sanitary survey? Z Yes F] No If no, please describe why. Insert Description Here > If water system deficiencies were found during the sanitary survey, did the LPA outline a corrective action schedule and provide it to the water system within 60 days of the completion, of the sanitary survey? Z Yes Z No If no, please describe why. stetaII orr ctiv toriswere pr9vided; In writing witlith" 'd*,-' 4thtis s&hei(hing that 1""'66"11" marked'co"". '064 vee actions are. ,a[ ajjy, sedtion ta ,E�ue.y. dui ll" jn�spqo ,/son! ry. ry > Did the LPA provide the water system with a complete sanitary survey report within 90 days of the completion of the sanitary survey? M Yes n No If no, please describe why. Insert Description Here > Did the LPA follow-up with the corrective action plan schedule to ensure that the water system compiled with the noted deficiencies? E] Yes Z No If no, please describe why. For the most,,pert yep Wo,rl lrig,,dn a system to traolt syste Mrs. tb ,s�fdr, c, veat on > If the deficiencies were not met in a timely manner, was an enforcement action issued to the water system? E] Yes Z No "o 'W ay n requIred. If no, please describe why. l 5. Sampling and Monitoring (CCR, Title 22, Section 64256), Refer to Attachment B, Table 9 for detailed information on enforcement actions issued for monitoring and reporting violations. > Does the LPA provide, in writing, the water quality monitoring and reporting requirements to their water systems at a minimum frequency of three (3) years for community water systems and five (5) years for non-community water systems? Z Yes F-1 No If no, please describe why. Insert Description Here > Does the notice referred to above, include the contaminant name, storet code, frequency of sampling, and any other sampling and reporting requirements applicable to a water system? n Yes Z No If no, please describe why. Does not Includestoret, code. > How does the LPA track chemical and radiological water quality monitoring and reporting compliance? E] Database, E:] Spreadsheet E] Other- Specify Revised 711612015-wkk Page 6 of 11 Local Primacy Annual Evaluation Form Fiscal Year 2014-2015 County of Butte > At what frequency does the LPA review the chemical and radiological water quality analyses received? Z Monthly E] Quarterly E] Annuall Z Other— As it comes in. Does the LPA confirm that the water quality results were successfully submitted to the State's Water Quality Inquiry (WQI) database? F] Yes No If no, please describe why. Unsure how to do thin, > For surface water systems, does the LPA receive and track the monthly SWTR reports? n Yes El No If no, please describe why. System is in: process of being permitted. > How does the LPA track compliance of the: monthly SWTR reports? 0 Database n Spreadsheet F] Other- Specify > For groundwater systems that provide treatment, does the LPA require a monthly operations report be submitted and review and track the submission of the monthly operations reports? F-1 Yes Z No If no, please describe why. We do not ask them to be submitted monthly. It is reviewed during inspections andl provided when requested. > How does the LPA track compliance of the monthly operations reports for treated groundwater systems? [:] Database F-1 Spreadsheet n Other- Specify > How does the LPA track bacteriological water quality monitoring and reporting compliance? E] Database Z Spreadsheet n Other- Specify > At what frequency does the LPA review the bacteriological, water quality analyses received? Z Daily Z Monthly F Other- Specify > Does each public water system have a current and complete Bacteriological Sampling, Plan (BSSP) on file? Z Yes 0 No If no, please describe why. Insert Description Here > If the public water system is a groundwater system, does the BSSP comply with the requirements of the Groundwater Rule (GWR)? Z Yes F-1 No If no, please describe why. Insert Description Here > How does the LPA ensure that each water system has a BSSP on file that meets all regulatory requirements and is not more than 10 years old? Database 0 Spreadsheet Z Other— During Inspections or permit amendments > Has the LPA issued any water quality monitoring waivers, exemptions, or variances outside of the Title 22 regulations? E Yes Ej No If yes, has the LPA provided documentation to each water system file regarding the background on the waiver, exemption, or variance granted? El Yes Z No If no, please describe why. Changed in Chemical Monitoring Schedules. Revised 711612015-wkk Page 7 of 11 Local Primacy Annual Evaluation Form Fiscal Year 2014-2015 County of Butte Has the LPA notified the district engineer of the waiver, exemption, or variance granted? F-1"Yes 2 No If no, please describe why. Was not aware that we needed to. 6. Reporting (CCI?. Title 22, Section 6425TI Defer to Attachment B, Table 9 for detailed information on enforcement actions issued, for the all violations. Does the LPA have a database of record that is capable of reporting all required data elements to the Division in the format designated by electronic submission requirements? Z Yes [] No If no, please describe why. Insert Description Here If yes, what type of database is the LPA currently using? 0 Decade Software-EnvisionConnect n SDUW'IS ❑ Other- Specify Based on the data reporting requirements table below, is the LPA meeting or exceeding those requirements? [] Yes [:] No If no, please describe why. Insert Description Here IHS �,�,��'F rt��,,,��,a �1 �1 6'.f' /ldlrr J/Y%fifilliil///!t ilii G i r✓0%1//e1Pfa ', 'violations Monthly Enforcement Actions Monthly Water Supply Permits Quarterly Sanity Survey Quarterly. Leat! and Copper Rule Monitoring Quarlerl Water System Invenito Annual Note Currently, the LPAs have not been directed to do this. Is the LPA submitting to the Division in a PDF format a copy of each citation, compliance order, and any court filings issued by the LPA? n Yes E No If no, please describe why. Insert Description Here v Did the LPA issue a written notice to all public water systems directing thein to electronically submit to the Division an electronic annual report (eAR) no later than July 1"? Z Yes n No If no, please describe why. Insert Description Here Does the LPA review and, if adequate, accepts each eAR, which is filed with the Division? N Yes 0 No If no, please describe why. Insert Description Here A If the eAR is deficient in any manner, does the LPA notify the water system of the deficiency and direct them to correct and resubmit the eAR? Z Yes ® No Revised 711612015-wxk Page 8 of 11 Local Primacy Annual Evaluation Form Fiscal Year 2014-2015 County of Butte If no, please describe why. Insert Description Here ➢ If a water system did not submit an eAR, did the LPA follow-up with a reminder email/notice about the requirement to submit the eAR? ® Yes ❑ No If no, please describe why. SUBMIT AN EXAMPLE LETTER/EMAIL SENT TO WATER SYSTEMS REQUESTING THEM TO COMPLETE THE 2014 eAR ➢ Does the LPA issue enforcement actions that meet the addressing/formal action criteria listed below? ® Yes ❑ No • The Action must describe the specific provision of statue or regulation that has been violated. • The Action must cite the applicable provision of statue or regulation. • The Action must describe specific actions to be performed by the water system to return to compliance (i.e. directives). • The Action must include a compliance schedule. • The Action must inform the water system that failure to comply with the Action is, in and of itself, an enforceable action (i.e. Civil Penalty Clause). If no, please describe why. Insert Description Here SUBMIT AN EXAMPLE OF A MCL AND A MONITORING & REPORTING ENFORCMENT ACTION ISSUED WITHIN THE FISCAL YEAR. ➢ Does the LPA include the appropriate public notification directive with the enforcement actions issued? ® Yes ❑ No If no, please describe why. Insert Description Here ➢ Is the LPA following-up with directives stated in the enforcement actions issued? ® Yes ❑ No If no, please describe. Insert Description Here ➢ Does the LPA work with the DE and water system to complete and submit a funding application through the Financial Assistance Application Submittal Tool (FAAST)? ® Yes ❑ No If no, please describe why. Insert Description Here 7. Program Management (CCR, Title 22, Section 64259) ➢ List the funding sources for the LPA program. Insert Description Here Revised 7/16/2015-wkk Page 9 of 11 Local Primacy Annual Evaluation Form Fiscal Year 2014-2015 County of Butte Refer to Attachment B, Table 10 for detailed information on, Small Water System Program fees, Based on the level of adequate staff stated in the workplan, was the LPA able to maintain an adequate staffing level? Z Yes [:1 No If no, please describe why. Insert Description Here Does the LPA have a time accounting system in place? Z Yes F1 No If no, please describe why. Insert Description Here How does the LPA maintain the water system files? F-1 Hardcopy [:] Electronically Z Both 0 Other- Specify ➢ For each water system, does the LPA maintain the following information: • Current water supply permit and technical report. Z Yes F-1 No • Permit applications, permit technical reports, and all technical reports supporting the water supply permits for a minimum of 10 years. Z Yes n No • Current plans and specifications pertaining to source information, treatment information, storage facilities, distribution plans, water quality plans, total coliform sample siting plans, and emergency plans. M Yes [:] No • Copies of bacteriological water quality analyses for a minimum of 5 years. Z Yes R No • Copies of water quality monitoring data for a minimum of 10 years. Z Yes F-1 No • Correspondence, memoranda, and other written records pertaining to the water system issued or written within the past 3 years. E Yes E] No • Copies of all compliance orders, citations, court actions, and other enforcement documentation issued. Z Yes n No If no, please describe why. Insert Description Here How does the LPA ensure that each water system, if applicable, has a certified operator? 0 Database Z Spreadsheet [:j Other- Specify 8. Workplans (CCR, Title 22, Section 64260) > Did the LPA submit a workplan for this FY? ZYes F-1 No If no, please describe why. Fees and General Funds Revised 711612015-wkk Page 10 of 11 Local Primacy Annual Evaluation Form Fiscal Year 2014-2015 County of Butte DOCUMENTS THAT WILL BE REVIEWED IN A FILE REVIEW a. Current water supply permit and technical report b. Most recent sanitary survey report c. Current water quality monitoring requirement notice d. Report detailing their last sample dates for the constituents that they are required to monitor and report for (i.e. database print-out, spreadsheet, etc.), including chemical, radiological, LCR e. Most recent CCR Report f. Current BSSP g. Emergency notification plan h. Water system operation plan i. For chlorinated water systems, the most recent DBP monitoring plan j. Any water quality monitoring waivers, exemptions, or variances issued k. Email/letter sent notifying the water system about the eAR requirement I. Enforcement action(s) that were issued for primary and secondary MCLS, monitoring and reporting, treatment technique, and state violations m. Public notices that were included with each above enforcement action n. For surface water systems, the most recent SWTR monthly monitoring report and CT report o. For conventional surface water systems, the most recent quarterly TOC report Form Completed By: Amanda Aguiar REHS 08/26/2015 Revised 7/76/2015-wkk Page 11 of 11 ti 0 i' o) E Co a o Q a v 3 E (D cn : OU) is = ai . CJC ; 3 a- Z (V Z N J to Q N 00 CO O �-- N {- co cu O O +�- C 0 uim Q d V C O 4 +� co o E 4-- i O ❑ ❑ ❑ ❑ p o F- LO Ea - - r—c OL o a J 4 cV w C �:.Q O N A� mQ � C � CnQ � CL N N C = O C N 3' LLJ CU to Uzi � o z z �'` LO � .� NQ'acz , o LO !- V N ❑ +; QC}.} NYo Wd Q.QN o z LL V d 0 a':< ❑ ❑ ❑ ❑ C :in o aL. a U. . o EE U w o U a N v UU z Q cn .vU U Z z O v W z O � J V s = U a z � � E 6 EN E o w _o O N c F- 47 c N Z _ 0 z z I z o C -a Vy E Q v gcy, U5 w 2 C wa U0 E2 3 V7 O Q N c w- o L C D a lL © m 1 I U U d o d7 d D U) O ti J LU o O� o E J E O E a M � O O C7 Eo m (L = Oi o u°7i Q z It 4 4 U Q z u ami �. O O O H O 11 S� '" > A cn v, cl r "� O CDSCD r' C7 - " 0 (n m rn O C rn _ p` L}; JIM44 i3 {o G. 0 by xID Sp SD" 3 Cld C. ty Adv %u 0) rr ra. Z Ca. � 0 CD CD CL dU) 'C CIS ° (D CID 0 CD CL CL CCP FD cn rn z rn '. rn o .z CI) zG) ' Ull ro N o a C^7 0C C7 ED Sp `". SD CCR 1 d CD W A -10 CD C: (D 0 C: O flyhlT u) FT CID V CD O '-9 w O w > ti w (13 o v o . o V U. . o O o) QM Cl) Z O LU „` m o t;-O =3 ~. L E m ; O < to Q U) sa °- :cOOU) 7 ED o o c � -0 -0 m L IL cv z m p J tm C LU �: ? :0, J Lf d' I.- LU J ;v O c O � � L LL g w.^ y L L o Ow C ~ w a LL, N 21 .) E w N ~ 3 E le U > d tl� o I- CL: N N c:M 0 (!1 N' U c W V>:}Z-- w U I— I . Z Z Z Z a Z U) N 2 12 W rn z U Q 41 w tla o ro Z E Z c F cn o o LL E o O v O ' N E o a� u30 LU N (13o O O = 0 a Z p 12W _w .l co w U o � Z (5 co m 2 C7 U o 3 Z Z O ° `° co wa � a E w LL IL o 0 0 o E a J Z o EZ 9 O o O E m a o ao 0 0 0 011 H v I— Z v a ocaccc� Cc� ,ems z ai a c "0 0 0 0 CD 0 � 0 C � r 4 a * A 0 -3 o0 CD 0 � � c rn LT U) C3', C0 PN 00 0 — .� 6<1 cn CD 0 co c p � CL 0 ria - < 0 CD CD r ' oCL 0 p � � ( z cn 0c 0 ro rn " -� co 0 cn CD Mffinf , � 00 mb V W LIS '�Q r% , 00 Cl)77777777 .Q' d 0) CD 0) ►r Ca —M r�" -- =a - •. :. ';tT cn Zh CSS Cil CJ7 P., CL k-0 Or C Cl Cd @ C , C' W 41? 0 , ❑ 1:1 ❑ 1:1 ❑ ❑ ❑ ❑ ❑ ❑ p C' C C' 0. C. 0. C11 tC� CD C} `4 4- 0 CL c►r E,E z T- ca T— r C.d Cr) Q T CV CSI CV LOCEJ cy) N (o u 7 0 r 0 0) 0') raj � 04 Cr) 41) Co CCS 0) CSS iuc- (D c e- C) a It 0 0 US :3 E E a) CU) 3 0co 0 @S ( Co ua U) �} .- 0) CL O 0 y C) Q CL :> LLl U) L., '� r13 Cf5 r CS -j Of EQ- 40, M LU � QAC :3 -J! � �, � � CLQ (n asC C ? � crs rco cit m 0 d CL Ip'_ CD LLH C) u_ LL CL Z (DC) co u_I(n 0 _ 0 r'- C0 C(C.7 0 � c- r C) r (D � Q0 Tom-- sl--- CO m p 0 � A I- _ r,) CD C) C> C. C: c� Ca CS C0 C� � c� T cr, T ca 8ol C Z r a 11-T¢ i i i i i a u w i r ' � a i 4 o i i 0 to 0 0 C) C:) CD 0 0 0 0 0 O Cl C7 CD C7 0 CD 0 0 0 ZI CD 0 c ro (Do C �x Z7 rr CDCL T. :3C L17 'CD CD tn ur N � "w "� E Z tli CD / o ro '0 / CD rn F 41 CD C7 /i f Jif/: 0CD ch i CCDDCh w CD lok, tvCD CD "d O �-r rn ❑ El cn CD 63 �` ❑ ❑ ❑ ❑ �t cc CD f) CD ~�C W .- LU0 Q) C Q Q O z 5 0 G LU ❑ ❑ ❑ ❑ cU LU 0 0 L 6_ 00 cyj (6 00 d N MI. p7 p 0 0 0 ml (D O co: C ®' QC`. 9 E EC) LO 0 0 O f7 Cl E E Ca 0 C QQ M 04 c aLOLO � I D. J � od cy El ❑ ❑ til 0 ; LC7 El J 0 w 'm❑ LLL p ❑ — 0' 0 Ul n < c n zC) m CO v tai 2 ❑ ❑ ❑ ❑ ❑ ❑ 0 cn e Q E 2 z `a u.M 0 Z C v t� o W `m LL7 IE ca c w C) E o cn Z .w•• 47 U) � tf) � 0 U Iti, Q) c o E 3ti co E Cfi f a) 0 ua a— C 47 *" C E RS Z. Cl1 U) U) (D rte. �> i p C � (� �s i- E a V— H (IJ J L1 alJ t CL a Z 0