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Address Info: 1150 O Street, P.O. Box 758, Greeley, CO 80632 | Phone:
(970) 400-4225
| Fax: (970) 336-7233 | Email:
egesick@weld.gov
| Official: Esther Gesick -
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20080532.tiff
Esther Gesick From: Esther Gesick Sent: Tuesday, February 12, 2008 8:37 AM To: larryhosier@q.com' Subject: FW: county bussiness Attachments: LEUraniumEmail.doc .EuraniumEmail.doc (57 KB) Mr. Hosier, Please see the attached response. Esther E. Gesick Deputy Clerk to the Board 915 10th Street Greeley, CO 80631 (970) 356-4000 X4226 (970)352-0242 (fax) Original Message From: William Garcia Sent: Monday, February 11, 2008 3 :16 PM To: Esther Gesick Subject: FW: county business From: LARRY HOSIER [mailto:larryhosier@q.com] Sent: Monday, February 11, 2008 10:37 AM To: William Garcia Subject: county business Bill Garcia, Because you took the time to talk with residents i think you have compssion for weld citizens which has been lacking for years. #1 you all have the right to denie all permits for urainium mining.it's not only the cleanup after mining how about during.if 1 well is contaminated during mining at what price is this county willing to pay for 1 human being suffering or death for an accident during mining. there schould never even be able to mine in the area of under or through an equifer let alone by the inexsperienced company all for the love of money ,greed i would really like an answer to this . #2 i agree we need mass transit but not on taxpayers dime , it should be funded strictly off of generated proceeds basicly off of what it takes in & if it just town to town then county residents have no benifit because they have to travel to town to use it , i know alot of people who are barely making it in these hard times & it's going to get worse but every needs to know we need to curb growth because we are over populated for our resources .some body needs to step up & say enough is enough right now we are importing food from china & the rural lifestyle will become a thing of the past look what there doing with oil, you cut off supplies & without even a fight your country has been taken over all in the name of greed , if you think this isn't going to happen guess again . we are outsourcing jobs even in weld county greencards at walmart capped wages for long term employees . but as a native weld county citizen i object to any new taxes for special interest groups & for funding for mass transit cost of living is rediculas not everyone was born with a silver spoon in their mouth alot of people live paycheck to paycheck everyday is a struggle to pay bills not becauce of lack of planning but by cirrcumstances beyond their control .i would like your feedback on this & would like to know about other future developements that affect us rural community . thank you for your time & god bless you . larry -! ?EY1 144a r:ca.�u'>�,o mil- G �.2JZJ�' Esther Gesick From: Bill Jerke Sent: Thursday, February 07, 2008 5:29 PM To: Esther Gesick Subject: FW: Information from EPA Attachments: Salazar letter.pdf; Denver Basin strat col.pdf F0 Fan.. Salazar letter.pdf Denver Basin strat (427 KB) col.pdf(36... Original Message From: Trevor Jiricek Sent: Thursday, February 07, 2008 4 :35 PM To: Bruce Barker; Mark Wallace; Rob Masden; Douglas Rademacher; William Garcia; Bill Jerke; Dave Long; Thomas Honn; David Bauer; Lauren Light Subject: Information from EPA FYI. I am forwarding y'all an email I rec'd from Valois Shea at EPA. Attached is the letter from Senator Salazar and a stratigraphic column of the area. I will email her and request that she forward their response to Salazars letter when it is completed. Trevor Jiricek, M.A. Director, Environmental Health Services Weld County Department of Public Health & Environment 1555 N. 17th Ave Greeley, Colorado 80631 970-304-6415, ext. 2214 (office) 970-304-6411 (fax) Original Message From: Shea.Valois@epamail.epa.gov [mailto:Shea.Valois@epamail.epa.gov] Sent: Thursday, February 07, 2008 8:52 AM To: Trevor Jiricek Subject: letter from Senator Salazar Hi Trevor, Sorry it has taken me so long to get this to you. I also included a stratigraphic column of Denver Basin aquifers for reference. (See attached file: Salazar letter.pdf) (See attached file: Denver Basin strat col.pdf) Valois Shea US EPA Region 8 8P-W-GW 1595 Wynkoop Street Denver, CO 80202-1129 phone: 303-312-6276 fax: 303-312-6741 CeYrt./'+'u-u Lt 1'W -'2D -'2tTi3Z7 1 4/299 .. .. e13 3 1 268 82 F.2/3 e a A L'C &SC- //-/2/-C'7 t.y14) aF'd fn; sfy-1�'C��L., KEN SALAZAR C S' it tat '-97v.AsrlINGTON tr (4LOAAc4) 'e.a.:..an w+r•3..;:. ua,wcw•- ri-GA • tS*i,n@8. CUR:AM:0 AGRICut iunr.NUTRITION.AND FORESTAY 'Amtcd tate mote -ra K.4tr ` rlV�.j�tW Lt1Y" .m a; nzu r rl�s.-t ENERGY'AND NATURAL RESOURCES WASHINGTON.DC 20510 2 �'-•.. FINANCE .�:-e....v.•.-..,�..- SPECIAL COSAITTU ON AGING SELECT COMMITTEE ON ETHICS - November 9, 2001 Robert Roberts, Regional Administrator US IPA Region 8 MC-Else 1505 Wynkoop St Denver. CO 80202-1 129 Dor Administrator Roberts: - I am writing to you regarding the proposed Powertech uranium mining project in Weld County.also known as the Centennial Project. The citizens of Northern Colorado have expressed their grave concerns to me about the potential negative economic and environmental impacts that this project may have on their communities. The proposed project would be located within 30 miles of a population of approximately 300,000 people. Many are worried that the in-situ leeching (1SL)process employed at the mines will result in contamination of their groundwater. 1-he Environmental Projection Agency will be tasked with reviewing the project's application for an Underground Injection Control Program Class II1 permit. I am concerned that the scope of this review may be limited to the Laramie-Fox Hills aquifer in the immediate vicinity of the proposed mina I seek your assurance that any potentially induced hydrogeologic connection to the larger Denver Basin aquifer system L.it1 be considered in your review and evaluation of the proposed project. Further, I request a summary of the known history of environmental impacts from in-situ milting under EPA's Underground Injection Control Program, both in EPA Region 8 and in the continental U.S. I also request that you provide me with a summary of the cumulative experience EPA has had with remediation of aquifer excursions and other types of site contamination caused by ISL mines. •AC'�to�1 L r`-. $a. �, %o;^ni„L Q'.I I ;-_';'. 'y " ,'Hit••. ., U htskotlC eryitp(, r , era . 1me.0 '_ f-, �:1, +`, '' -ri tL S C,p ),I�,. rerneei(0.r,,:):-, b" G7'.,1',` ". r‹eyC), 1:.iC': '5 4 G�k-{1Q1 PC . .. • lhhT60 On Xh:,a r V..MT t •II• • �(I;r 11/09/2007 FRI 14:55 ITX/RX Nn 575(11 GTnn9 Witter is our lifeblood. It is critical that the citizens of Northern Colorado rcceit c an accurate and complete analysis of the risks that this project may pose to their groundwater. I respectfully urge you take etvery possible step to safeguard the water quality for the surrounding communities and citizens of Northern Colorado. Hook fopward to commencing a dialogue with you on this critical issue. Sincerely, Ken Salazar United States Senator • • • • • • • 11/09/2007 FRI 14:55 ¶TX/RX NO 57501 f1Joo3 Esther Ges[ck From: Edquist, Jeff[JEFF.EDQUIST@aei.com] Sent: Thursday, February 14, 2008 2:37 PM To: Esther Gesick Cc: robin@mustanghollow.com;jbw@frii.com Subject: Please file for future reference, Documentation regarding teh dangers of Uranium Mining Attachments: haskell_dissent.pdf; image001.png; imageO02.png .a .721 haskell_dissent.pdf image001.png (621 image002.png(622 (446 KB) B) B) Ms. Gesick, Please be so kind as to file this with previous documentation I have sent with regard to Uranium Mining in Weld County. Thanks for your support, Jeff Edquist Virginia State Bill: http://legl.state.va.us/cgi-bin/legp504 .exe?000+cod+45.1-283 <http://console.mxlogic.com/redir/?II6zCXwVVASOOC_ssUCr01D-hhWAZD_ 6tVKC08n8ixx_A1DXItUvVaZXw1J100b3_8BQTCj t-KyOehd7bagbxKVIhZRTLg5CVkC2J- nbCT64SkhNJ5eXdQTXCzBcSYedxoZFVEwtAvVEwtH4QgeJPrzVEwzXLN-5LOcQglRrdG_2uPBmlEwzV7oEiwhd44_ 9Cy13o4vzgQgltd40j zI9dGCy0rB2_k29KvxYY1NJ4SMrppjvKehhdMOBg6skM> § 45.1-283 <http://console.mxlogic.com/redir/?II6zCXwVVASOOC ssUCr01D-hhWAZD 6tVKC08n8ixx_A1DXItUVVaZXw1J100b3_8BQTCj t-KyOehd7bagbxKVIhZRTLg5CVkC2J- nbCT64SkhNJ5eXdQTXCzBcSYedxo_ZFVEwtAvVEwtH4QgeJPrzVEwzXLN-5L0cQglRrdG_2uPBmlEwzV7oEiwhd44_ 9Cyl3o4vzgQgltd40jzI9dGCy0rB2k29KvxYY1NJCSMrppjvKehhdMOBg6skM> . Uranium mining permit applications; when accepted; uranium mining deemed to have significant effect on surface. Notwithstanding any other provision of law, permit applications for uranium mining shall not be accepted by any agency of the Commonwealth prior to July 1, 1984, and until a program for permitting uranium mining is established by statute. For the purpose of construing § 45.1-180 <http://console.mxlogic.com/redir/?mm3hPtMsYOrppjvKesjdwOP_ BEZiuPzeYTj 04bA9gM_OaPZSeYfYBuZMOSGw05x_AiWbRPt-KyOehd7bagbxKVIhZRTLg5CVkC2J- nbCT64SkhNJ5eXdQTXCzBcSYedxoZFVEwtAvVEwtH4QgeJPrzVEwzXLN-5L0cQglRrdG_2uPBmlEwzV7oEiwhd44_ 9Cyl3o4vzgQgltd40jzI9dGCy0rB2k29KvxYY1NJASMrppjvKehhdMOBg6skM> (a) , uranium mining shall be deemed to have a significant effect on the surface. (1982, c. 269; 1983, c. 3 . ) Health reference: http://www.centerforpolitics.org/programs/govcon/wilder_bio-ehaskell.htm 1 <http://console.mxlogic.com/redir/?2OMgerK3DCjrbarZNPypI05rUj- bJoHlfBelGs0lNgdictlFx6FCR000AuxYhkxaFvOuQa-uvMl3t-KyOehd7bagbxKVIhZRTLg5CVkC2J- nbCT64SkhNJ5eXdQTXCzBcSYedxo ZFVEwtAvVEwtH4QgeJPrzVEwzXLN-5L0cQglRrdG_2uPBmlEwzV7oEiwhd44_ 9Cyl3o4vzgQgltd40j zI9dGCy0rB2k29KvxYY1NJwSMrppjvKehhdMOBg6skM> Elizabeth H. Haskell http://www.centerforpolitics.org/programs/govcon/images/spacer.gif http://www.centerforpolitics.org/programs/govcon/images/spacer.gif Elizabeth H. Haskell has spent 30 years in environmental public service. She was a member of Virginia's State Air Pollution Control Board for 16 years, including six as its chair, before becoming Governor L. Douglas Wilder's Secretary of Natural Resources. Since leaving state government she has been active in Martinsville community affairs, including service on city council. She is presently president of Thomas Jefferson's Poplar Forest, a director of The Southern Environmental Law Center and an executive of the Martinsville Bulletin, Inc. She is both of Martinsville and Washington, Virginia. This message, including any attachments, may contain information that is confidential and proprietary information of Advanced Energy Industries, Inc. The dissemination, distribution, use or copying of this message or any of its attachments is strictly prohibited without the express written consent of Advanced Energy Industries, Inc. 2 Elizabeth H. Haskell Martinsville, Virginia 24112 COMMENTS ON THE US/UAG REPORT A Different Perspective I do not agree with the recommendation of the Uranium Subcommittee/ Uranium Administrative Group (US/UAG) that the moratorium on uranium development can be lifted. The case for uranium mining and milling in Virginia has not been made, in my opinion, despite extensive studies by the US/UAG, consultants and the industry. The burden of proof is on those who wish mining to proceed and this burden has not been met for me. The risks of cancer deaths and illnesses from radiation released from the uranium ore and waste products called tailings are high in the state's proposal. The great many unknowns about the development and its impacts could push health risks much higher and raise costs to the Commonwealth, substantially reducing projected economic benefits. If Virginia allows uranium mining and milling, it would be the first state to do so in a climate where rainfall exceeds evaporation and where many people would be exposed potentially to the resulting radiation in the water and air. Previous domestic uranium mining has been in arid, sparcely populated Western regions where transmission of radiation in water is not a concern. In Virginia's wet climate where water is discharged from the site and filters through tailings, the transmittal of radiation to people through streams and the groundwater is a major issue. The experimental nature of the uranium industry in Virginia's wet climate and the environmental problems from radioactive tailings disposal in the West 21 have caused the General Assembly to be justifiably cautious in approving the industry. Legislation has called for the assessment of risks and benefits. The US/UAG has had no actual experience to evaluate. French uranium is cited by the industry as similar, but no impacts data were produced on this situation. Rather, the UTF and US/UAG reports and conclusions about costs, benefits and risks of a uranium industry are based on consultants predictions using mathematical models and other techniques to speculate about future effects of one mine and one mill. This site is known as the Swanson site in Pittsylvania County. No estimates were made of impacts of a statewide industry. In my judgment, the consultants risk assessment study and cost/benefit analysis on which the UTF and US/UAG reports are based underestimate the health risks and overstate the benefits of the Swanson uranium mining and milling for the following reasons: 1.) The Swanson risk and cost/benefit calculations assume no negative impacts on ground water or surface waters. It is assumed that there will be no leaching of radioactive wastes or heavy metals to groundwaters that are used by neighbors, no substantial polluted discharges to streams, no accidents, no long-term deterioration or collapse of the 100 foot high tailings pile by flood, earthquake, erosion or design failure for the thousands of years the tailings are radioactive. These are unrealistic assumptions in the net precipitation climate of Pittsylvania County, where groundwater reaches close to the surface and where above-ground tailings disposal will be required exposing the waste to weather and collapse. Mill Creek will be diverted around the site but no negative impacts are projected. An open-pit mine will be dug to 850 feet through the Chatham Fault and tailings disposed near the Bannister River, using an undemonstrated containment technology. 22 A VPI/SU professor consulting with the UTF concluded that virtually all contaminants that would be disposed in the proposed tailings pile will eventually leach to groundwater. When and how fast pollutants will filter out will depend on the thickness and material of the liner under the tailings pile. If the study's assumptions are wrong and polluted groundwaters flow through the rock fractures to affect groundwater supplies or surface water pollution increases, then the risks and economic costs to individuals and the state would rise. 2.) The US/UAG report estimates that up to .56 additional cancer deaths will result from the one mine/one mill Swanson development in the 13 years of operation. This assumes that the maximum exposed individual will receive 7.8 millirems of radiation, based on the industry and state consultant estimates. However, the UTF and the US/UAG have proposed state standards that would allow 285 millirems of radiation to the maximum exposed person, which is estimated to produce up to 21 cancer deaths during the 13 years. It is reasonable to expect that if the law permits 285 millirems that the industry could emit up to that level. If more than one mine and one mill is developed in Pittsylvania County or other parts of the state, additional people will be exposed and risks increase. To estimate the maximum cancer risk from a uranium industry, rather than just one mine and mill, calculations should be based on the proposed statutory total radiation standard of 285 millirems. This amount of radiation could produce anywhere from 28.5 to 399 additional cancer deaths in an average population of one million exposed persons. Various scientific 23 organizations have differing views about just how many cancer deaths to expect. The state's consultant used the lower extreme of 28.5, while other governmental scientific organizations predict up to 399 cancer deaths. 3.) Health risks, other than neighbors' cancer deaths, were not estimated for the Swanson development. Traditional risk assessment methods are limited to predicting fatal cancers in the general public. The following risks are reasonable to expect: * Worker accidents, illnesses and deaths were not included in the risk assessment but were left to future analyses. In addition to the employee risks associated with any surface mining, they will be exposed to radioactive materials in the mine, mill and tailings areas. * Illnesses in the general population, including cancer, that do not result in death,were not included. * Impacts on sensitive persons, notably children and pregnant women, would be more substantial than the impacts on the average population projected. * Health risks were based on normal, expected operating conditions and do not, because they cannot, predict effects of a catastrophic event such as a flood, major accident or design failure that could collapse the tailings pile. 4.) Benefits calculations assume that the Swanson mine and mill will operate at full production for the 13 years of expected operation, producing 468 full—time jobs, while the history of the industry is one of cyclical unemployment. Benefits to employees would decrease and costs to the Commonwealth increase if periodic unemployment occurs. 24 5.) No calculations were made by the consultants, UTF, or the US/UAG of the long-term health and environmental effects and costs to the Commonwealth, those that occur for many years after closure of the mine and mill. Risks, costs, and benefits are projected for only the 13 years of operation, although risks and costs will continue for many years after the 13 years of benefits cease. The US/UAG estimates that first year costs to the Commonwealth to regulate the Swanson site to be $850,510. Recurring costs during mining operations are projected to be $664,410 a year. No post-closure costs are projected, although the General Assembly should expect some to occur. After closure, the Commonwealth or the Federal Government will assume permanent ownership of the tailings pile, along with the costs of monitoring and managing the site, and responsibility for damages and cleanup should an environmental problem occur. In the event the tailings management technology fails or a flood or earthquake occurs, a very expensive tailings remedy could be required. These calculations of long-term costs and predictions of catastrophic events were not made by state officials because of the very high degree of uncertainty about such impacts of uranium mining and milling in Virginia. A great deal of hard work and investigation by legislators, state officials, private citizens and the industry has been devoted to improving our understanding of impacts of a Virginia uranium industry. The Swanson site-specific research was a valuable case study, which enabled the UTF to draft better uranium standards. However, while knowledge of a Virginia uranium industry has improved greatly over the past two years, uranium mining and milling in our climate and population density would be an experiment. Predicting impacts of such development are informed guesses, at best. 25 In my judgment, the unknowns and the identified risks to the public and the environment exceed the projected benefits and call for retaining the moratorium on mining and milling. This is a conservative approach that asks for a higher level of confidence before approving this unique industry. However, if the General Assembly weighs the risks, costs and benefits differently, is willing to accept the uncertainties, and lifts the moratorium on uranium mining and milling, I endorse the US/UAG and UTF recommendations for legislation. The total radiation dose standard should be made more protective for the public than the 285 millirems a year proposed in Recommendation 2 of the report. This proposal would expose an individual to the equivalent of 10 chest X-rays a year. This is added to the naturally occurring radon at the Swanson site of 130 millirems or about 5 chest X-rays, for a total of 15 X-rays each year of operation. In my view, this is too high a level of risk for Virginia to accept. Regulators hope to set lower exposure limits in the uranium permitting process, but lower levels should be specifically written into any uranium mining law. A better alternative standard is a total radiation dose standard of 25 millirems per year above background for sources other than radon and a concentration standard of 0.5 picocurie per liter for radon, for a total of approximately 170 millirems a year. In addition the concept of setting radiation exposure limits in a uranium permit that are more stringent than the statutory limit (known as As Low As Reasonably Achievable or ALARA) should be specifically authorized in any uranium mining law, so that radiation limits below 170 millirems are possible. A trust fund should be established in any authorizing statute to cover long-term state costs of monitoring and managing a closed tailings site, including 26 funds to pay for remedial action if a major environmental problem occurs. The mining companies and not the taxpayers of Virginia should bear this burden. IX 1 * d//b, .- Elizabeth H. Haskell Member, Uranium Administrative Group 27 LIS > Code of Virginia> 45.1-283 Page 1 of 1 previous I next § 45.1-283. Uranium mining permit applications; when accepted; uranium mining deemed to have significant effect on surface. Notwithstanding any other provision of law, permit applications for uranium mining shall not be accepted by any agency of the Commonwealth prior to July 1, 1984, and until a program for permitting uranium mining is established by statute. For the purpose of construing § 45.1-180 (a), uranium mining shall be deemed to have a significant effect on the surface. (1982, c. 269; 1983, c. 3.) previous I next I new search I table of contents I home http://legl.state.va.us/cgi-bin/1egp504.exe?000+cod+45.1-283 2/15/2008 LIS > Code of Virginia>45.1-283 Page 1 of 1 previous next § 4.5.1-283. Uranium mining permit applications; when accepted; uranium mining deemed to have significant effect on surface. Notwithstanding any other provision of law, permit applications for uranium mining shall not be accepted by any agency of the Commonwealth prior to July 1, 1984, and until a program for permitting uranium mining is established by statute. For the purpose of construing § 45.1-180 (a), uranium mining shall be deemed to have a significant effect on the surface. (1982, c. 269; 1983, c. 3.) previous I next I new search I table of contents I home e http://legl.state.va.us/cgi-bin/legp504.exe?000+cod+45.1-283 2/15/2008 LIS > Code of Virginia> 45.1-180 Page 1 of 2 previous I next § 45.1-180. Definitions. The following words and phrases when used in this chapter shall have the meanings respectively ascribed to them in this section except where the context clearly requires a different meaning: (a) Mining. - Means the breaking or disturbing of the surface soil or rock in order to facilitate or accomplish the extraction or removal of minerals; any activity constituting all or part of a process for the extraction or removal of minerals so as to make them suitable for commercial, industrial, or construction use; but shall not include those aspects of deep mining not having significant effect on the surface, and shall not include excavation or grading when conducted solely in aid of on-site farming or construction. Nothing herein shall apply to mining of coal. This definition shall not include, nor shall this title, chapter, or section be construed to apply to the process of searching, prospecting, exploring or investigating for minerals by drilling. (b) Disturbed land. - The areas from which overburden has been removed in any mining operation, plus the area covered by the spoil and refuse, plus any areas used in such mining operation including land used for processing, stockpiling, and settling ponds. (c) Overburden. -All of the earth and other material which lie above a natural deposit of minerals, ores, rock or other solid matter and also other materials after removal from their natural deposit in the process of mining. (d) Spoil. - Any overburden or other material removed from its natural state in the process of mining. (e) Operator. - Any individual, corporation or corporation officer, firm,joint venture, partnership, business trust, association, or any other group or combination acting as a unit, or any legal entity which is engaged in mining. (I) through (i) Repealed.] (j) Mining operation. - Any area included in an approved plan of operation. (k) Reclamation. - The restoration or conversion of disturbed land to a stable condition which minimizes or prevents adverse disruption and the injurious effects thereof and presents an opportunity for further productive use if such use is reasonable. (1) Mineral. - Ore, rock, and any other solid homogeneous crystalline chemical element or compound that results from the inorganic processes of nature other than coal. (m) Division. -The Division of Mined Land Reclamation. (n) Refuse. - All waste soil, rock, mineral tailings, slimes and other material directly connected with the mine, cleaning and preparation of substances mined including all waste material deposited in the permit area from other sources. (1968, c. 734; 1972, c. 206; 1974, c. 312; 1977, c. 312; 1984, c. 590.) http://legl.state.va.us/cgi-bin/legp504.exe?000+cod+45.1-180 2/15/2008 UVA Center for Politics Page 1 of 1 i!/,!/Lff.GMa c�St. us �/ ile Map Search } �� Godwin '4N '99 L. Douglas Wilder HoltonDalton F • R f Robb '01 1990 - 1994 Baines O, • `Wilder'C) Home> Programs > Gov. Project > Wilder'03 > Agenda Elizabeth H. Haskell Elizabeth H. Haskell has spent 30 years in environmental public service. She was a member of Virginia's State Air Pollution Control Board for 16 years, Including six as its chair, before becoming Governor L. Douglas Wilder's Secretary of Natural Resources. Since leaving state government she has been active in Martinsville community affairs, including service on city council. She is presently president of Thomas Jefferson's Poplar Forest, a director of The Southern Environmental Law Center and an executive of the Gob. Proj. Ilona Martinsville Bulletin, Inc. She is both of Martinsville and Cynic! Herne Washington, Virginia. Copyright©2003 U.Va. Center for Politics.All rights reserved. Center for Politics 2400 Old Ivy Road P.O. Box 400806 Charlottesville,VA 22904 Tel: 434.243.8468 Fax: 434.243.8467 http://www.centerforpolitics.org/programs/govcon/wilder bio-ehaskell.htm 2/15/2008 vi i• ._ tai re e.v * @ i 65G� C C C V VT ` r S 40 V � h E da 45 PO + Y e ea 4i w $ cg a + . client 1 ai Li 4 = et 0 ` .. C P Q g Q Ce P IS CO q = E '� O C C _� r t v :i C t• s n > i4 a .5 At z 0 E. c : i 4 43 Co _ c ii, a, a Q � c c Ems o °3 r. z a �,irt r- 2 E IS 4C '• x,, .47 4 ti* � � = 'r �' P O •C M C dJ O L a. 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