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IMPV-11-2023-208176.TIF
Permit#:,kPlr-U-zaV -2oJr76 ' ROY COOPER•Governor NC DEPARTMENT OF H EEAk ' WICES KODYH.K)N$LEY•Secretary MARK RENTON•Deputy Secretary for Health SUSAN KANSAGRA•Assistant Secretary for Public Health " ;vision of Public Health Submittal Includes: a2)Improvement Permit ,,e2}Construction Authorization 0 Fee$ tt IMPROVEMENT PERMIT FOR G.S. 13QA-33S(a2) County: �r[1GIl' PIN/Lot identifier: 4 b Q1 O 4 So`]3)8 Issued To: ()( 1,rMS LL C Property Location: la tn'inG l.r+ Sht:rril C N' is +-a- �- a 9(e'73 SeStlrchr,,rK s�,�,,,,.-., /-o?<. Subdivision(if applicable) ‘SAk(d(ebr,.l(. Lot it; alg Block: Section: LSS Report Provided: Yes No❑ If yes,name and license number of LSS: ntye1 115 hicy euiLrviS It /23 New[3------ Expansion rJ System Relocation 0 Change of Use ElProposed Structure: 1 ete/rwH1 ers,titElh1 } Number of bedrooms; LI Number of Occupants: 8 Other: Design Wastewater Strength: omestic 0 high strength 0 industrial process Proposed Design Daily Flow: L/60 GPO � Proposed LTAR(Initial): 03 Proposed LTAR(Repair): 6' 3 Proposed Wastewater System Typea f g -_ct‘e•f k/7�-Crewrl y (Initial) Pump Required: ❑yes Eificr❑May be required Proposed Wastewater System TypePl e46- Fb 4 ui'K- `"f''p i%s..+c (Repair) Pump Required: �s ❑No 0 May be required 'Please Include system classification for proposed wasrewotersystem types In accordance with 15A NCAC 18A.1961 Table V(o) Saprolite System(initial):❑yes @ilo Saprolite System(repair):❑Yes alifc Fill System(Initial):❑Yes [3i if yes,specify:0 New 0 Existing (when adding more than 6 inches of fill to system area provide a fill plan) Fill System(repair):❑yes Ergr-c-if yes,specify:0 New 0 Existing (when adding more than 6 inches of fill to system area provide a fill plan) Usable Soil Depth(Initial): � Usable Soil Dep th(Repair): i/i1 yL{ �y -. d Max.Trench Depth(Inittal)i: ? y Max.Trench Depth(Repaid': .. " 7/ • Measured on the downhill side of the trench Artificial Drainage Required: []Yes raN6 I{yes,please sp ecify details: Type of Water Supply:❑Private well 0 Public well 0 Shared well Drainfield 919 location meets requirements of Rule.1945: Yes�"�+�w— unkipal Supply ❑Spring ❑Other• Q ❑ Dra infield location meets requirements of Rule.1950: Yes B—NB❑ Permit valid for: ears(site plan submitted pursuant to GS 130A-334(13a)) 0 No expiration(plat submitted pursuant to GS 130A-334(7a)J Permit conditions: , Licensed Soil Scientist Print Name: ( Ache t. k'c1.t rrnj Licensed Soil Scientist Signature: �/ / /�i (�t�� ( •=t ( E��-.=L . Date: The LSS evaluation Is being submitted pursuant to and meets the requirements of G.S.130A-335(a2). *See attached site sketch* NC DEPARTMENT OF HEALTH AND HUMAN SERVICES • DIVISION OF PUBUC HEALTH LOCATION:5605 Six Forks Road,Building 9,Raleigh,NC 27809 MAILING ADORES&1632 Mail Service Center,Raleigh,NC 27699-1832 www.ncdhha.gov • TEL:919-707-5854 • FAX:919-845.3972 AN EQUAL OPPORTUNITY I AFFIRMATIVE ACTION EMPLOYER I Permit#: IMPV-11-2023-208176 SaddlebrooK Lot 22 This Section for Local Health Department Use Only Initial submittal received: 10/30/2023 by RP Date initials G.S. 130A-335(a3)states the following: When an applicant for an Improvement Permit submits to a local health department an Improvement Permit application,the permit fee charged by the local health department,the common form developed by the Department,and a soil evaluation pursuant to subsection(a2)of this section,the local health department shall, within five business days of receiving the application,conduct a completeness review of the submittal.A determination of completeness means that the Improvement Permit includes all of the required components.If the local health department determines that the improvement Permit is incomplete,the local health deportment shall notify the applicant of the components needed to complete the improvement Permit.The applicant may submit additional information to the local health department to cure the deficiencies in the Improvement Permit.The local health department shall make a final determination as to whether the Improvement Permit is complete within five business days after the local health department receives the additional information from the applicant.lithe local health department fails to act within any period set out in this subsection,the applicant may treat the failure to act as a determination of completeness.The Department shall develop a common form for use as the improvement Permit. The review for completeness of this Improvement Permit was conducted in accordance with G.S. 130A-335(a3). This Improvement Permit is determined to be: 0 Incomplete(If box is checked, information in this section is required.) The following items are missing: Copies of this were sent to the LSS and the Applicant on Date State Authorized Agent: Date: ©Complete fff State Authorized Agent: '�!�`t/fd,1,1-- Fi j Date: 11/9/2023 This Improvement Permit is issued pursuant to G.S.130A-335(a2)and(a3)using the signed and sealed LSS/LG evaluation(s) attached here. The issuance of this permit by the Health Department in no way guarantees the issuance of other permits.The permit holder is responsible for checking with appropriate governing bodies in meeting their requirements.This permit is subject to revocation if the site plan,plat,or the intended use changes. The Improvement Permit shall not be affected by a change in ownership of the site. This permit is subject to compliance with the provisions of the Laws and Rules for Sewage Treatment and Disposal and to the conditions of this permit. The Department,the Department's authorized agents,and the local health departments shall be discharged and released from any liabilities,duties,and responsibilities imposed by statute or in common law from any claim arising out of or attributed to evaluations,submittals,or actions from a licensed soil scientist or licensed geologist pursuant to GS 130A-335(a2). Improvement Permit Expiration Date: 11/9/2028 *See attached site sketch* G.S. 130A-335(a2)Common Form 2 V.2023.07 . NC DEPARTMENT0 � OF 'f t M°PER• n0f = � KODY FL it�tSi.EY.g� MARK MINT ON•Deputy Searetery for Hsieh '. Oh-Won cf Public Health SUSAN KANSAORA•Mildew 8*oretary for Public Health AppHca$on for Services This appfication,,n union with the departments to be used for appagons inset to G.S. 3 actcrdence With .S. 3 (a3),Is oPtIonal for). (hereinafter,&t 14-d (a3J and tbas (W,ta; and bat health . t l d►tAnouanHerstAernMtomd(�lbastruction A"teOI n2Iiillmpnivernent Permit 1a2)0:Instructionwon Please check one of the following: 0 [a2} icons ,erbe,Auk 0 EXPIndian Relocation 0 Change of Use ClBerate0ce � npf0Ylded}Non-Ex p� � P asdstlheerkln G.S.1�334(7*} Y as Nam*: L Property Owner Melling Address: !h Property Owner Phone Number: "I Property Owner Emdl Addy+ st APPaCant Name: Applicant Maims Addreet Applikant Phone Number: _ Applicant Email Address: V Does Include.or is sr to,any of the folowh nty ❑Ye:s ario �or identified YesEP Approval by edgier public agencies ; enatiasdlmertt;,or other areas subject to legal El A site plan or plat is wombed,a the site sketch d the system / Min Include the following: (A)edging and pn'posad faelllf and )asew(g)Proposed showing n [s reference winds) existing and proposed seltkefer oposed (f7 sur existing ace eraesp watt `wells, water tins:and drainage featums,and ail eat and artlfichel drainage,as scab e. Requesting DHHS review:Chges Elio I understand that the documentation and fees.is niquired In are used Improvement P, end/or GM purulent and(a6),attached to this authortzed comity and state offIciab are • • • right of entry to the property indicated__�pNcatlom the apconduplication for an I inspections to determine compliance with . ' and odes. on this n formation t and o .t the ParrINt " seedier ,iaV ;r- Autfarhadon!s S information then to Ac►prkant slenaeu,� /'`n, ;#1. 4P/Edn� . , Wiled,changed,or the sibs altered,thee► owners ` //�/ Z�'��i�ru�'� i �r Data: I , ;J? ) NC MEP ' Orden. • �realm IVICaIS • OMtteON OF PUNUC HEALTH • coCAIIO t ee06, Fnd. ,#aip 3•R NC 27e s wwwrwdhNapovr• 7O7•ea64 WI '• nut e1 r NC 27110.1 QS2 AI4 a OPPORTUNITY/APIgniA ACTION 9a+LOY=R SIB & FORESTRY SERVICES OF THE CAROLINAS, PA www.soilandforestryservices.com Project#: 23-0015 September 6th, 2023 VR Farms LLC Attn: Ray Short Email:vrshortjrCa@aol.com RE: Soil&Site Evaluation for a 4 Bedroom Residence at Saddlebrook Subdivision Lot 22,0.77 ac Parcel, PIN#(460904507318)Sherrills Ford, NC 28673. Mr. Short: At your request Soil & Forestry Services of the Carolinas(S&FS) has performed soil/site evaluations on parcel noted above.The Lot size is noted on the attached survey map& soil evaluation form.The purpose of our work was to identify soil areas with potential to support subsurface wastewater disposal systems and provide design details for Session Law submittal to Catawba County Health Department. Site Conditions At the time of our evaluation land cover on the property was partially cleared/graded for the house pad and open field.Topography within the evaluated area was gentle slope near the house site and proposed drainfield area. Property lines and corners were marked at the time of the evaluation by Derek Bunton.The surveyor provided an Autocad File of a survey with house envelopes as a basemap.The proposed septic layout was located via GPS&tape measures and used to produce the attached Site Plan.The house envelope was located via Survey by Derek Bunton Surveying. Backhoe pits were located via GPS. Methodology We evaluated soil areas through the use of backhoe pits. Soil morphological conditions including color, texture, structure, etc.were reviewed in the field with eleven backhoe pit locations on the property flagged and located via tape measure. Eight of the eleven backhoe pits are located in or adjacent to the proposed septic layout. Soil suitability was determined by referencing 15A NCAC 18A.1900"Laws and Rules for Sewage Treatment and Disposal Systems".Soil&Site Evaluation Forms were utilized to record the soil morphological data for each pit.The house envelope was located via survey.An on-ground layout of system and repair was performed using a laser level. Pin flag locations of the layout were also located by GPS and tape measures. Detailed system & repair information is summarized in the following paragraph for this Lot. Saddlebrook Subdivision- Lot 22 (See Attached Design) The septic layout for this lot (9'centers)yielded a total of 617 linear feet of line.The primary system is proposed as 268 linear feet of HPPBPS(50% Reduction) drainfield with gravity distribution.Trench depth is specified at 30 inches(Low Side).The repair system is proposed as 267 linear feet of HPPBPS(50% Reduction)drainfield with low pressure distribution.Trench depth is specified at 30 inches(Low Side). There is 349 linear feet of repair available. Session Law Requirements All information needed to issue the IP must be submitted with the application.The application shall include all information described in 15A NCAC 18A.1937(d) and be accompanied by a signed and dated statement from the applicant (owner or owner's legal representative) that reads as follows: "The LSS/LG evaluation(s)attached to this application is to be used to issue an Improvement Permit in accordance with G.S. 130A-335(a2)and(a3)." Owner Date Print Name Lei.4dNAll U, : P V, /L Signature //AVM V�'�%,f/'% * /O �T /- The LSS evaluation shall i lude a state ent bea g the LSS seal and signature that reads as follows: "The LSS evaluation is being submitted pursuant to and meets the requirements of G.S. 130A- 335(a2)." Disclaimer This report reflects the findings of S&FS, PA. This LSS evaluation is being submitted pursuant to and meets the requirements of G.S. 130A-335(a2)."Any site modifications that impact the proposed septic areas on the site may nullify this design for Lot 22-Saddlebrook Subdivision,Sherrills Ford, NC 28673. System design requirements and site requirements shall be adhered to for installation and Operations Permits to be issued by the local Health Department. If you have questions regarding these requirements a Pre-Construction meeting should be scheduled to discuss. Please contact S&FS if you have any questions regarding this report or the attached information. S&FS also offers septic system inspection,wetland delineation and fore • serllices. SOIL S Sincerely, e0 et `A. R 4 .,L jt' r 1 '‘+ is 2. SI F 7231 F C,P S.Ashley Rollans, LSS NORTH Attachment: Septic Design • SOIL Xr FORESTRY SERVICES OF THE CAROLINAS, PA www.soilandforestryservices.com Attached is a proposed design for an HPPBPS Septic System with gravity dist. for a 4 bedroom single family residence at Saddlebrook subdivision, Lot 22 Sherrills Ford,NC Catawba County,PIN#(460904507318) Contents: Page Information for the Installer 1 Design Information Design Specifications 2-3 Layout Specifications 4 Site Plan/System Plan 5 Calculations 6 Profile Descriptions 7 �° Sc Application Ag � 8-9 Crv ;.e57A7 `� � (� o tip, 1 pA CA Form ---1" — fit — • — IP Form Air„ 11 Application for Services 04 —G 12 RTH Gp, September 6,2023 Project#: 23-0015 Design By: Soil& Forestry Services of the Carolinas, PA 1 INFORMATION FOR THE INSTALLER: The permit should be read very carefully prior to bidding. The following are details that must be considered along with all other considerations. - Tanks shall be approved by NC DHHS, and certification supplied by the manufacturer. - Tanks shall be water tested prior to installation. - The installer shall be responsible to the owner for placement of the tanks and to insure that final grades are returned to the original natural grade, with exception of added structural features. - The supply trench shall be compacted to eliminate cavities left during initial fill placement. - Installation of the system shall be during dry conditions in order to protect the soil structure. - All fittings shall be pressure rated fittings. - All joints shall be cleaned with PVC pipe cleaner and a heavy bodied glue applied to weld all joints. - Where required by the county health department, post installation inspections by the designer must be scheduled 5 week days in advance. - Trenches shall be carefully excavated so the bottom is within 2" from the highest to . the lowest points of elevation within the trench. If the bottom elevation needs adjusting after it has been trenched, it will be done by removing high points rather than filling low points. It is extremely important to insure that trenches are not over excavated during initial trenching. All fine grading within the trench will be hand done with a shovel. No loose material will be left in the trench - All pipe openings in the tanks shall be properly grouted. This also applies to the joints around the riser. - All tanks shall be properly back filled and compacted to prevent slump at a later date. - Earth dams, constructed of relatively impervious material, shall be installed at the beginning and end of each lateral. - No heavy equipment shall be used on the field during or after installation. The use of a small loader (i.e. Bobcat) or a trencher(i.e. Ditch Witch 2300/2310) may be used for installation. - Elevations at pinflag locations should be checked by the installer prior to beginning trenches. - Septic tank riser shall be a minimum of 6" above finished grade. - System is specified as a gravity HPPBPS installation. - Repair is specified as a HPPBPS with low pressure distribution installation. 2 GRAVITY HPPBPS SYSTEM FOR WASTEWATER TREATMENT Applicant: VR Farms LLC Address: 7172 Long Island Rd Catawba,NC 28609 Phone: 704.516.2344 County: Catawba Location: Palomino Court- Lot 22 Sherrills Ford, NC 28673 Source of Wastewater Flow: 4 Bedroom Single Family Residence Estimated Gallons Per Day Flow: 480 System Flow: N/A Design Specifications Drainfield Size: 268 Loading Rate (gpolft.2): 0.3 Depth of Gravel in Trench: N/A Gravel Size: N/A Trench Depth (LOW SIDE): 30 in. Repair Trench Bottom 30 in. Trench Width: 36 in. Septic Tank Size: 1000 Estimated Supply Line Length: 13 Supply Line Diameter: 4 in. SCH 40 PVC Supply Line Volume: 1.31 Dosing Volume: N/A Supply Manifold: N/A Supply Manifold Length: N/A Supply Manifold Volume: N/A Recommended Float Controls: N/A Recommended Control Panel: N/A Pressure Head: N/A Friction Head: N/A Elevation Head: N/A Total Dynamic Head: N/A Threaded Union: N/A Gate Valves: N/A Check Valves: N/A Anti-Siphon Hole: N/A Additional Comments: Soil suitability was performed by Soil & Forestry Services of the Carolinas 3 Palomino Court- Lot 22 HPPBPS SYSTEM DESIGN FLOW (gpd): 480 SOIL APPLICATION RATE (gpd/ft.2): 0.3 TOTAL AREA TRENCH BOTTOM: 804 TOTAL LATERAL LENGTH: 268 NUMBER OF FIELDS: 1 LATERAL LENGTH REQUIRED PER FIELD: 267 SUPPLY LINE LENGTH: 13 TOTAL DYNAMIC HEAD: N/A MANIFOLD SIZE: N/A DOSING VOLUME: N/A PUMP TANK DRAW DOWN*: N/A SEPTIC TANK SIZE: 1000 PUMP TANK SIZE: N/A 4 Layout Specifications- Palomino Court-Lot 22 Project#:23-0015 LAYOUT FOR 4 BEDROOM HOME 9/6/2023 FLAG FLAGGED DESIGN LINE# COLOR BS HI FS ELEVATION LINE LENGTH LINE LENGTH TBM INSTR. 1 1 RED 49 49 2 ORANGE 52 52 3 ORANGE 42 42 4 YELLOW 50 50 5 BLUE 80 80 6 PINK 76 67 7 RED 67 67 8 ORANGE 70 67 9 YELLOW 67 67 I0 BLUE 64 64 Total 617 605 SOIL LOW SIDE LINE LTAR SYSTEM LTAR TRENCH TRENCH LENGTH GPD/FT2 TYPE GPD/FT2 SYSTEM DISTRIBUTION DEPTH *System 268 0.300 MOD.CONY 0.300 HPPBPS GRAVITY 30" Repair 349 0.300 MOD.CONV 0.300 HPPBPS LOW 30" PRESSURE Notes: **All measures in feet **Nitrification lines are demonstrated on contour via colored pin flags **Nitrification lines were located by GPS&Tape Measure 5 GRAVITY HPPBPS SPECIFICATIONS - Palomino Court- Lot 22 SYSTEM Line Color Elevation Length Hole Size Flow/hole 1'rcneh Area #of Panels 6 PINK NM 67 N/A N/A 201 15 7 RED NM 67 NM N/A 201 15 8 ORANGE NM 67 NM N/A 201 15 9 YELLOW NM 67 N/A N/A 201 15 804 60 total feet = 268 gal/min= N/A Des.Flow 480 Pump Run= N/A soil LTAR 0.3 LTAR+5% 0.315 LTAR with mod. 0.6 LTAR with mod..+5% 0.63 7 CALCULATIONS Location Palomino Court- Lot 22 Sherrills Ford, NC 28673 Project Number 23-0015 Lot No: 22 No. of Bedrooms 4 Design Flow 480 gal/day LTAR 0.300 gal/ft2day PPBPS? (YES OR NO) YES Supply Line Length 13 ft. Supply Line Volume 8.489 gal. FRICTION FACTOR INTERPOLATER Required Feet of Line 266.6667 ft. 2" SCH 40 PVC Amount of Line from Layout 268 ft. GPM f 20 0.84 Gallons per Minute N/A gal/min -0.88 25 1.27 Required Septic Tank Capacity 1000 gal. -1.28 Septic Tank Size 1000 gal. 30 1.78 -1.76 Panel Volume N/A gal. 35 2.37 #of Panels 60 -2.25 Dosing Volume N/A gal. 40 3.03 43.07 3.48 45 3.77 48.14 4.28 50 4.58 57.11 5.89 60 6.42 Tank Draw Down N/A Pump Run Time Elevation Head N/A ft. Pressure Head N/A ft. Friction Factor N/A ft./100 ft. (From the interpotater.) Friction Head N/A ft. Total Dynamic Head (+15%) N/A ft. �r 85°54' S5' E 312 . 61 • . ' N 7 . 48 • % 7 ' T II 54 . o P92 NM iVI 0'92 vJ o HOUSE E N ,, SLAB a 1�91 -� W • N CO OS No 0 �� cS • I ,212 9' r 1> �� O o �// i 0 _ coo ". __ T igg D 4 9 ( i riii 6 O O 6` NS` O Fri ACR -� P. 0-w E O mi• O 51 '1 - Q\ .55P59 SCALE 1 la=40' 167 . 54' - lir 4 • ' 55» W 953 . 34' __ 5 8 5 5 __-- - r Sheet 1 of 2 PROPERTY ID#: 460904507318 ' COUNTY: Catawba SOIL/SITE EVALUATION for ON-SITE WASTEWATER SYSTEM (complete all fields in full) OWNER: VR FARMS LLC APPLICATION DATE: ADDRESS: 7271 Long Island Rd,Catawba NC 28609 DATE EVALUATED: PROPOSED FACILITY: 4 Bedroom Residential-480 GPD PROPERTY SIZE: 33,507 SF LOCATION OF SITE: Saddlebrook subdivision,Sherrills Ford NC 28673-Lot 22 PROPERTY RECORDED: WATER SUPPLY: ❑ Private 0 Well ❑ Spring 0 Other County water EVALUATION METHOD: 0 Auger Boring ❑Pit ❑Cut TYPE OF WASTEWATER: LI Sewage ❑ Industrial Process ❑ Mixed P R O SOIL MORPHOLOGY OTHER .1940 (.1941) PROFILE FACTORS PROFILE F LANDSCAPE HORIZON I POSITION/ DEPTH CLASS L SLOPE% (IN.) .1942 <AR E .1941 .1941 .1943 .1956 .1944 STRUCTURE/ CONSISTENCE/ SOIL SOIL SAPR RESTR # TEXTURE MINERALOGY WETNESS/ DEPTH CLASS HORIZ 0-23 FILL 23-30 RBSCL WFSBK FR SS SP 51 L/5% 30-63 BRC WMSBK FR SS SP 40" N/A Unsuitable 0-25 FILL FR SS SP 25-31 BSCL WFSBK FR SS SP 52 L/5% 31-55 RBC WMSBK FR S P 30" N/A Unsuitable 0-10 FILL 53 L/5% 10-16 BRSCL WFSBK FR SS SP 48" N/A PS 0.3 16-58 BRC WMSBK FR SS SP 0-28 RBC WMSBK FR SS SP 28-64 RBCL WFSBK FR SS SP C SAP 54 L/5% 64" N/A PS 0.3 0-12 FILL 12-24 BRC WMSBK FR SS SP 55 U6% 24-59 RBCL WMSBK FR SS SP F SAP/Quartz 47" N/A PS 0.3 Vein 0-15 FILL FR SS SP 15-23 RBC WMSBK FR SS SP 56 U5% 23-59 RBCL WFSBK FR SS SP 44" N/A PS 0.3-.325 0-8 BRCL WFSBK FR SS SP COMPACTED 8-23 BRC WFSBK FR SS SP 57 L/50/ 23-53 RBCL WFSBK FR SS SP F SAP 53" N/A PS 0.3-325 0-27 FILL 58 U6% N/A Unsuitable 0-24 FILL 24-44 BRCL WFSBK FR SS SP 91 U5% 44-60 BRC WMSBK FR SS SP 36" N/A PS 0.275 0-20 FILL 20-39 BRCL WFSBK FR SS SP 92 L/5% 39-54 BRC WMSBK FR SS SP FEW FE DEPL 34" N/A PS 0.25 DESCRIPTION INITIAL SYSTEM REPAIR SYSTEM OTHER FACTORS(.1946): SITE CLASSIFICATION(.1948): PS Available Space(.1945) PS PS EVALUATED BY: Ashley Rollans System Types(s) HPPBPS-Gravity HPPBPS 50%-Low Pressure OTHER(S)PRESENT: Chad Wagner&Mason Freeman Site LTAR 0 3 0.3 COMMENTS: 1 Sheet 2 of 2 PROPERTY ID#: 460904507318 COUNTY: Catawba SOIL/SITE EVALUATION for ON-SITE WASTEWATER SYSTEM (complete all fields in full) P R O SOIL MORPHOLOGY OTHER .1940 (.1941) PROFILE FACTORS PROFILE F LANDSCAPE HORIZON I POSITION! DEPTH CLASS L SLOPE% (IN.) .1942 <AR 1941 .1943 .1956 .1944 STRUCTURE/ CONSISTENCE! SOIL SOIL SAPR RESTR # TEXTURE MINERALOGY WETNESS/ DEPTH CLASS HORIZ 0-3 FILL 3-16 BRCL WFSBK FR SS SP 93 L/5% 16-45 BRC WMSBK FR SS SP C SAP 58" N/A PS 0.3 45-61 RBCL WFSBK FR SS SP 4.2 „.........,-.........,:z c.->,\\ 44/ vt7 .0%icep f yret a, -1 1 D V . 4f/.IAQY.W�� l' COMMENTS