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HomeMy WebLinkAbout20003013.tiff F ROM Eric Dunker FAX HO. : 7203449629 Dec. 04 2000 12: 4mn 12-U4. i7U Y0:•[5 FAX 371.18-L92b4 DYF:EI2.EST DAIRY STATE OF COLORADO? B II Owen,. GuQemor Ione E.Neken,Eaccutin law ecter Dedtama as prom-ding any improving the health and ervironrnent olthe pevplr of Culnrado • 4300 Cherry Creek Dr.5. laberatory and Radlanon Sri-vitas Dwisiun `! Denver,Colorado 90244-1;53; 8100 Lowry Dlvd. Phone 4303)692.2000 Dena(CO 80230.6928 s:nt TOO line(303)Ei91-7700 (303)652-3090 Located in Glendale,Colorado PablicHowl, and E1Nrppmal:' h¢fainde vw.cdpha s,ata.acwa November 29, 2000 Tenance Dye Dye Crest Dairy 1137 North County Line Road Fort Collins,CO 80524 RE:: FOLLOW-UP LETTER TO ON-SITE VISIT ON OCTOBER 30,2000 Dear Mr. Dye: This is a follow-up letter to the on-site visit that I made to your dairy on October 30, 2000. Tom Hann and Eric Dunker with AgPro Environmental also were present. The on-site visit was rewired as a result of the Water Miry Control Division("the Division")receiving complaints from local residents about the dairy- You indicated that the dairy was permitted in 1964 or 1985 for 2000 animals and that ii has not expanded since that time. In addition, the dairy currently milks about 870 cows. Taking the 870 cows and factoring in dry cows,replacements,and calves,the dairy is clearly classified as a Concentrated Animal Feeding Operation(CAFO). Regulation No, 81 of the Water Quality Control Commission requires certain design criteria operation and maintenance requirements, ground water protection requirements.and requirements for beneficial use and disposal of manure and process wastewater- it was apparent during our visit that AgPro Environmental is serving you in these matters. The complainants about the dairy expressed concern that their was too much wastewater in the dairy's impoundments. We observed on October 30,however, that the three impoundments had at least two feet of freeboard, as required under subsection 81 3(C)(1), The complainants expressed concern that water that was being released from a point near the southwestern boundary of the dairy,may be contaminated by wastewater from the dairy's impoundments- In contrast,you indicated that the irrigated pasture field located g. EXHIBIT 2000-3013 � l FROM _ Eric Dunker FOX NO. : 72O3449629 Dec. R4 2000 -EH F 12, 01 00 10:17 FAX 170!819231 DSECREST DAIRY at the southeastern part of the dairy was drained of excess subsurface water via a n le drain system.. In addition. no evidence existed of seepage at the bottom of the toe slopes of the,impoundments. Finally,the water was clear and showed no indication of wastewater contamination. Therefore, evidence did not exist during our visit that the water being released to the southwest of the dairy either originated from or was contaminated by wastewater from the dairy's impoundments. The complainants expressed concern that the composting site and some pens do not drair into an impoundment. We observed, however, that stormwater from the composting site and calf hutches located at the north end of the diary pens and milking barn is contained by a long berm. The berm and catchment area have been in place since before 1992, thereby exempting this impoundment area from being lined in accordance with subsection 1U,4(A)(per subsection 81,4(C)). In addition,AgPro Environmental indicated that the bent height was raised recently so that it will contain a 25-year.24-hour stone. in accordance with subsection 813(8). The complainants expressed concern about wastewater being applied to pasture land. We observed the location of the pastureland and were informed that wastewater has been appli.ed at times to this the. We also were informed that the dairy uses the Tier II level c:t calculating agronomic rate of application(subsection 81.5(A)(5)((b)). Tier II requires that the"operator shall maintain copies of the agronomic analyses which are being relied upon;for the purpose of limiting land application rates of mature and process wastewater. Copies of such analyses shall be available for inspection at the facility and records shall be maintained for a minimum of three years" During our visit,the dairy did not have records of agronomic analyses that were being relied upon for the purpose of limiting land application rates of manure and process wastewater The dairy was,however, in the process of having AgPro take fall soil samples of the pasture area and develop records of agronomic analyses for any future wastewater applications. Results of analysis of the soils was provided to the Divisior.on November 27,2000. The amount of nitrate-nitrogen residual was 51 pounds per acre (lbs/a) in the top soil foot; 20 lbs/a in the second foot; and 21 lbs/ac in the third foot. These are tot excessive nitrogen amounts for the top three feet of soil. In summary,the Dye Crest dairy was in compliance with Regulation No. St on October 30,2000,except for having agronomic analysis records for wastewater applications to pasture land. Therefore,please submit to the Division an indication of how the dairy will comply with subsection S 1.5(AX5)(b) in the future. The Division may have occasion in the future to inspect your dairy. We encourage you to continue to be aware of CAPO regulations that apply to your dairy. For your information,the U.S. EPA will open up its CAP°regulations for review by December 15, 2000. Any changes in the EPA regulations,which probably won't be finalized unul about 2002, will likely result in changes to Colorado's Regulation No. XI. FROM : Eric Dunker FOX NO. : 7203449629 Dec. 04 2000 JJ: IFt f 12/04:00 1.045 FAX 97i4849251 DYECRFST DAIRY -- '+ Thank you for your time and cooperation during our visit. Contact me at 3003.692.3520 if you have any questions. Sincerely, I i Ron:f eps= Water Quality Control Division xe: Dave Akers,WQCD Susan Nachtrieb, WQCD Mtn Heren,AgPra Environmental Jean Eichheim Dave McCloskey,Larimer Co. Health Frank Sewald Keith Muffin. FROM : Eric Dunker FRX N0. : 7203449629 Dec. 04 2000 _ ': 1iF'1 F 43 E 1 Highway 0i;.Suite Longmont, CO 8050 Office (970) 1335-931 Fax (970):335-985,, 1.1 December 3, 2000 Ron Jepson Water Quality Control Division WQCD-PE-B2 4300 Cherry Creek Dr. S. Denver, CO 80222-1530 Subject: Dyecrest Dairy Dear Ron Jepson: This letter is in response to your Dyecrest Dairy inspection on October 30, 2000 and subsequent questions regarding record keeping and sample analysis at the dab) AgPro Environmental Services, LLC has been contracted to monitor the environmental compliance at Dyecrest Dairy and to respond to any requirements o regulatory actions regarding the dairy. We maintain the environmental compliance record keeping system for the dairy in accordance with the Colorado Confined Animal Feeding Operations Control Regulations. Enclosed is a copy of the soils analysis for the land application area you requested during your site visit. Soil samples were collected from the land application areas consisting of approximately 120 acres predominantly located on the south side of tin dairy. Approximately 15 cores were collected at 12-inch intervals to a total depth ,( 36 inches.Nitrate—Nitrogen results are 51 pounds of residual nitrate in the top 12 inches. Twenty-one pounds of residual nitrate is in the 12 to 24-inch and 24 to 3h inch horizons respectively. Your "Pro Ag" Environmental Professionals FROM : Eric Dunker FAX N0. : 7203449629 Dec. 04 2000 _:': 1. P December 3, 2000 Page Since your site visit, the grass pasture mix crop in the land application area has beer plowed under in preparation for alfalfa in crop year 2001. Our calculations indicate an additional application of nitrogen will be necessary for the new alfalfa crop in May of 2001. However, we plan to re-sample this field in the spring prior to our expected lagoon dewatering after this winter's storage of runoff. Expected harvest yields and final crop nutrient requirements will be calculated at that time. If you have any questions or require additional information,please call me at (970) 535-9318. Sincerely, homes Haren Environmental Consultant Your "Pro Ag"Environmental Professionals 7 So IL. 'ERTI! II RHPOI+1ii -- - -1AGPRO- El Ai. c, SUBMITTED BY ((SERVICES, LLC OLSEN'S }6508 WELD CO Rn 5 m AGRICULTURAL ERIE CO 80516 LABORATORY, INC. NAME DYECREST 3 P.O.BO%G70 McC(YJK.NE 69N1 8j 345 3&7O OFFICE a DATE RECEIVED: 11 / 17/2000 DATE REPORTED. 1 1 /21 /2000 m SOIL TEST RESULTS I., I 'l1�=4, % pH ' " B`E _""A:`G NITRATE pi Pi 3SC" h3JS • FOy�„it_ 1 S_n_FI i LAB SAMPLE - 11 EXJES wSALTS I MATTER F_ IN IN. IN I TOTAL SPAY Pt u BP'R3CU#TF P -F12 pH 7 NH O c ISO,.PI I -TP. I JUTABER CERTIFICATION — UbE mod.SP I mad AT1 Ca-o SOIL BUFFER mmhos'cm t % ppm lb 'A ppm Ihs'A ppm IbsIA Ibs'A OM! Fpm Fpm PFB1 o,r PT 1428 SOUTH FIELD 0 12 7. 5 H 1 . 62 2. 2 14 51 51 76 407 71 2. 4 1429 SOUTH FIELD 12 24 8.0 H 1 2.34 1 .2. . 9 21 21 50 352 62I 1 . 3 1430 SOUTH FIELD 24 36 8. 1 H 1 .82 1 .7• .7 21 21 65 300 341 1 . 8 I ' 1 LAB CALCIUAIYH4uAAGNESIUMM{Exchangeable) SODIUM IRON I MANGANESE COPPER I maim'1b13 CEO 1 BASE H^L SATURATION Rli N AF4MT�N PFI�ENf S4NO SILL PARTICLE SIZE ANALYSIS CI ? NUMBER r me HMy 5Ca g e RAU„80.ci FGm ppm ppm PpT PP PT" PPm L `s 4v °i TEXTJRE . .. 1428 2550 1030 153 16 .4 4.5 1 .6 1 .26 23.0 100 0 55 37 5 3 H., 11429 2350 1255 180! 14.6 3.41 1 :0 0.76 23.9 100 0, 49 44 4 3 I w 11430 2260 1115 148 14.4 3.7 1 . 0= 1 .2 22.0 100 0' 52 42 31 3 i i A a ID LT N U] SUGGESTED FERTILIZER RECOMMENDATIONS j,14.., LAB . SAMPLE CROP TO BE YIELD N P205 K20 S Zn Mg Fe IFa Cu B CI LIME CVF=:.'.i NUMBER IDENRFICATION GROWN GOAL bs'A bs'A hr'A J tsA MA ts'A I Iva IGs'A Its'A I Is'4 IG,:4 " s j T 31428 SOUTH FIELD 0 12 . I i i I #I 314291 SOUTH FIELD 12 24 ' I 314301 SOUTH FIELD 24 36 a t s n—VEH. rtlbrti,=.1,u!, '.A_MELc d.A. L .v..- ._ ., . = vNL 5L IF AT. A. CC ..� _ --rr, C-, r r r, , .7 'MMG—T(lRl MCTHnn it./r.4-T: -n irr '.. \1 %Y, ,o- eze, ///7/a000 is i. / '- Th SlL�/7 ralC c/' 4. IXHIsIT g WYATT, MARTELL, WEAVER & ROGERS L.Lc ATTORNEYS AT LAW BILL WYATT 222 WEST MAGNOLIA STREET TELEPHONE 19 7:0 4F 4 1112 JAMES A. MARTELL. FAX 1970, 4e4 II 'C L.ALLEN WEAVER FORT COLLINS, COLORADO 80521-2899 TODD W. ROGERS December 1, 2000 Weld County air: r?1n0 oeOt Department of Planning Services Weld County Administrative Offices 'ir'' : :'1 1400 North 17th Avenue Greeley, CO 80631 R £ C RE: DYELANDS DAIRY APPLICATION Dear Sir or Madam: I represent Sonja Stonestreet, who owns property adjacent to the property owned by Dyelands Dairy. It is my understanding that the Dyelands Dairy application will be heard by the County Commissioners on Wednesday, December 6. Dyelands Dairy has committed to build its employee housing next to the milking parlor rather than near Ms. Stonestreet's property. Enclosed please find a letter from Dyelands Dairy making such commitment, as well as a proposed site layout showing the change. Ms. Stonestreet will not be able to attend the Wednesday hearing before the Commissioners. Accordingly, I would appreciate it if you would please make the enclosed documents part of the record prior to the hearing. If you should have questions with regard to the matter, please do not hesitate to call me. Thank you. Sincerely, y M. 2 4&itr ames A. Martell sc Enclosures cc: Sonja Stonestreet [ 4 EXHIBIT LL use 4klq Terence Dye Registered Holsteins DYECREST DAIRY, L.L.C. 1137 North County Line Road r Fort Collins, Colorado 80524 a Phone: 970/484-9294 11 Fax: 970/484-9254 Email: dye@frii.com ASS. 51cnec*ee / a ( t �'s l D 10 t.tii it ec��s�i> ����1 J L' / �'oujliir� --( ' Tvebidl airy i ), ,, Me/0) c� � �, _ P IQin,'I�r ('clI l I YYou1'r R c it) -ibe , 0Q ItcpQ P �blelf ilc/I S le a(c7 4h 4) o f (lc c , L,J .Ditla L Daf v L. C. _C- '---1- CL'e. /Q J i 6,2/' 7)___57------- ___ Dyecrest Dairy,LLC:. Terence Dye 1137 North County Line Rd. Fort Collins CO 80524 o I U m Pei,M ur AgPro E'nvironmento/ Services, U C MS CM Mfg D S7 GVB'f 9�u/UVr% p�MIM� Pm*r a+.4 �►7 11.416 Brigx o amt(1�siFa I Ir r AM Oar*1 MIK r firm& `[rte �-iM+� r WELD COUNTY ROAD #86 _ i SN N f Pe) it n 1 r /J /7/ P C-P;; .. COIn -/7 / _ _1/_./:X. Ln \\ i El Willi!i Kw I.__Ce l 1i AI__a,i__m J a F.*.0.3 a — of \ ' . • r Q I COUP/OM Nvp MD rnas ry OM 05 NI (-) __ J.•..r��o IW\ 4 \�. �rl r/rl�p Mailir anr [n .��.. —rut NIMBI I 9 III�ryII {{II{I{I II J -4 91 Jb !, O I nominal..rr� O O �I rot ay� MP kW rII{u 1LJI JI1 !11 N I souk 1-- N. r.mo nQ No,yer ra Moral 8.5- I N4.4 i 03 WELD COUNTY ROAD /}84 — s. 0 1 v t m I a r� ._..� --.az.;,. ^<'�—.��'� a ° a rim, l Y BAWL fi t' IIIICOITY SE D III CALF HUT AREA FEED MANGER --1 CAFES&OPEN HEWERS BRED HEWERS DRY COOS n W .1W Em0020R C �ry r WWII(VMS&Flat YNad �.-� HdAFR 1RAMSIROR PEN - C III,' O O o 0 O D II IH I 1 1 Q �r m ulul 0016 ' w totd - plI YANUpppEEE> GTCH,APF.Y LJJ IJ J li — v. III Ii \` l•-Iml MI WO MILK PAWAR I CI 44 f F,, C Xq MX COWS 'YID MILK 0016 IDD YIIL CW6 I �t IlIII,IIU nI H O O . - O O J O 0 ]00 AQD \lt St RUED Wag E Ake YIQRR SCALE: 1' v 200' BROMIN RAISED DEE BELT(BFRY RAISED APPROX. 51 \i, Terence Dye Registerea /folste ns DYECREST DAIRY, L.L.C. 1137 North County Line Road 1� Fort Collins, Colorado 80524 l� Phone: 970/484-9294 Fax: 970/484-9254 Email: dye@frii.com ' ! C' yI , Slieet, i ; ;,S'1ces no ro o �-',l I'i ployee housing near your properly ,i • R.,-ti . . O • fl c o n plans are to construct the � � lv< t I .c the milking parlor. We hope that . i ecru:id , ,. A Meeting Transcript Page 20 M = Moderator A= Applicant AR = Applicant's Representative the hill, and its ditch deep, its common we run into it with Terry and feedlot projects all the time and this is all over the county. So it is not that uncommon. M Are there any, . . . Kathy. K A very common occurrence in Weld County are the chinook winds that come through in January. We very frequently have the majority of the snow melt off and then get a very major dump of snow. In winter and some of the other off seasons that, um, the gentlemen was discussing, he mentioned that, you know, how do you plan to manage the manure and composting when there are no crops to pick up the nitrogen? AR Well the issue there. . . and the error in that thinking is that you have to have a growing crop. Now here is how the capital regulations work. You cannot apply more to that land than the crop consumes,but how many farms apply solid manure all over Weld County? Do they do that when the crop is growing or in the fall after the crop goes off. They apply that in the fall for several reasons. First, they're not running over the crop. Second they usually wait until the ground is frozen so they don't have compaction problems. The regulations require to test the soil and if we see any soil leaching or it is applied in a manner that we can't balance to meet the crop requirement,we are in violation of the capital. That is subject to fine. Now in the program we are running on Terry's existing dairy, most samples of the farm ground when people are doing agronomics or fertilizer calculations think they sample maybe a foot. All of my dairy clients we sample at least 4 feet and I have some clients that we sample 12 feet just to make sure that we do not have migration in the soil horizon. So let's say there's 20 extra pounds at the end of the year and the crop has come off and we have done the agronomic calculations. That 20 pounds is put into our calculations for subsequent applications. It is a rolling balance. There is no snapshot in time. That is not how the capital regulations work. That is not how the environment works. (.....e. -n . �.. So the land application. . . there were some errors in the testimony and I would point out one / on the . . . on the manure and compost generation numbers, I can see where it would easily / be interpreted differently and the graph actually shows the column of pounds produced by / day, but then there are rows that are summarized at the bottom that show that we have 11,600 and some tons, that is actually an annual number. So in our experience with dairies that are this size and larger, and dairies that are this size and smaller, the compost . i :1 cannot see the manure with this site being an issue at all. [unclear] . . . the water foy 25 a ;,,\ year, 24 hour storm event, if we design a system that would hold a 25 y storm and e __._lagoons would be at the top at the end of that storm we wotil ' lre doing Terry vors. We used a-25 year numberb se rs wl"iai the regulations ha, v„,.but o agoon designs, like I said,this larger lagoon is 1argeTor!everkl seasons=—evaporation and catastrophic storm EXHIBIT 1452 ei_ AgPro Environmental Services,LLC 01.13.2000 Table 3-Manure Production enawensrOvrtOteplIMestaatutOtr MSS Maws .can n va Oea. n. ■ mate Type Nast*1141 otters nlwln.a. MI �� wan er,we a.rer tr/4l tg, qtr lal Mall a at 41404 LIB C,a� i t t 100 lox t0,. 0t.!J oQ06r a.�n .Nya�t4�`aa�� 1^ , I 1.30 0 u( 0.at0i 1.1 p0..]t 0 Oil 7 IMO t311 a M_ t t tar ate J.rr ant 0.41,{{ fj�l4a T.aaoar 37.04 #N0� '. I m� s1 1 Isle{� J / T..wrrrs�warrp�i�reM ' 'M.en Mace 11.at.r Vial .aro 1ST NO '/l V I O ()t 34F; Tara tirr'an0,d srr M% 12,103 Tons r r r MSS Ar . rw r r11203Or % 11A PA, 44 iy �___ __ r0 M� Nutrient Utilization G Nitrogen is the element that most ohs limits pant growth. Nitrogen is naturally abundant However,it is the natant seat fly llardng mop padrtapon bemuse the plant available forms of nitrogen in the sell ate mashattly upra/aieg a mehrmstioa Crops remove more nit ogee wan my awe same inns at The lisitedea is not related to the total amount of nitrogen available but to San the map man arse. Most nitrogen in plans is in the organic form and is leompassdSo weight,wino acids. by nitrogen makes up from I to 4 percent of l Essentially all of the nitrogen absorbed from the soil by plant roots is in the inorganic form of either nitrate or ammonium. Generally,young plants absorb more ammonium than nitrate;as the plant ages the reverse is true. Under favorable conditions for plant growth,soil microorganisms generally convert ammonium to nitrate,so nitrates generally are more abundant when growing conditions are most favorable. Manure and process wastewater is moot typically applied for fertilizers and soil amendments to produce crops. Generally,manure and process wastewater is applied to crops that are most responsive to nitrogen inputs. The primary objective of applying agricultural by-products to land is to recycle part of the plant nutrients contained in the by-product material into harvestable plant forage or dry matter. Another major objective in returning wastes to the land is enhancing the receiving soil's organic matter content As soils are cultivated,the organic matter in the soil decreases. Throughout several years of continuous cultivation in which crop residue returns are low,organic matter content in most soil decreases dramatically. This greatly decreases the soil's ability to hold essential plant nutrients. Land application of Dyelands Dairy stormwatedprocess wastewater to recycle valuable nutrients . is a practical,commonly accepted best management practice given that fertilization rates are applicable and that deep soil leaching does not occur. Reference material from Colorado State University is included in Appendix C of this CNMP for use by the operator in making sound decisions pertaining to the land application of stormwater. ' Dyelands Dairy,LLC Comprebnive Nutriant Management Plan ' 10 ...St_ .. t NT usyJ ing ...° s Ri 4r ',%"",:i'. .. t f a 1.♦ '� i. .. 'Y ar ��TT k'` b ' }� AS d [ 1 FMt { h. 7 M• ti,.... M1. . t': .A ..,'1t o^ .. N M1 ..,.u0... W S 1* Y r. } • x sw! K ate: � r: y it t A wi5x �# r : y Or �c • �,...-.. 1 ° ,, � S 1t. .#y a EXHIBIT a: } °s y`r (45R X1289 i 4 < ':' Y Sy' BIAS.. M1 7 IA �. Ga .,a -..._.T_-,.._.�_. _.....�_._.�..� --. __ '. .40 • xn Y 4 R i -,s,..-, {I ykH'Py i~ ,,°. F S,l, t r i" 1 i' i 31ffi 'l 5 —— A,v d:.q Tay, �.' _t ` ; �� - .. f - •* � •f V - ','1.1:-...TR-.1.11 . .,,-...g .;,-1,4* t A ₹ 1. ti's? • 1.a t to 4C-sn F^ s s .:, ,r � � ' ` i ,, 5 K ', @ir- p F` EXHIBIT 3, �� use 1tiza� Meeting Transcript Page 12 M = Moderator A= Applicant AR = Applicant's Representative our plan and design for that lagoon is that it will be dry and the slopes that we put on that lagoon are so Terry can get in there and mow the weeds when there is no water. I intend for this to be a minimal water use facility. There is a long primary sedentary lagoon so we can get any solids to bypass our concrete solid separator. The second stage lagoon, that is the primary lagoon we will be appl tbat ys• ieg-farerwgroundavith,fbbt;,and the third �ja3ne maj uc storm events that are required to be contat"ded pet, regulation. The regs require a 25 year, 24 hour storm and that is fine and Terry and I have J worked through this. We used to design fora 25 year, 24 hour storm. It made the lagoons much smaller. The problem is is you know the last few springs, you get one storm and two ClIP or three days later you get another. So,we have switched and started designing to a 10 day, a 10 year 10 day standard. It handled, it adds up being about twice what a 25 year, 24 hour storm handles,which is all the regulations require. That makes our lagoons look huge on the map, but Colorado is still a semi-arid state. We are almost a desert. We et 1 n.1 ' es of annual rainfall and we get 16 inches of�]pota • rr-90 ___�ag -unlsshave a catastrophicstpcnr men sis[trial-tide-signed` to a higher standard that can handle it. M All right are there any other questions? Fred F Kathy I would like to respond. Most of the houses are either west, southwest or south of this application, not north. K Is this incorrect or have I done something? F Well, I don't know whether you have it turned upside down or . . . K I am thinking that this is County Road 84 and the parcel goes this way. Is that in correct? F Where is 15 on there. K I don't know, that is [static] M I think you have to turn it around. You need to turn . . . north is the eight and a half. Turn it. - K Turn it this way? M There is north. North is at the top. K Okay, so the parcel goes like this? EXHIBIT Q Q Use *sari PRECIPITATION RECORD FOR USE WITH YOUR `Taylor 11" CLEAR-VU RAIN GAGE LOcw \q�J u )C ►2 t COUNTY LAJC I STATE CO TIME OF OBSERVATION G • ,.0 Ant YEAR / ' yL_— 64-•4,an A/ ,e FC ,45.2 t s-1A1,� it 2./.23 'i19/- 6.300 0 � • Jul 'fir Jon. Fab. March April a Jun Y Aug. Sapt. Oct. Nov. D•c. R•marl.` E s S ,� Z 3 . IC. . • o ! .0S 4 . 03 •Q�4 5 , JO .02 ••a- 6 ,p$ 7 1 8 9 10 .3.j • t . 11 is 4 - 12 , o(o .01 .1 13 , I :a •6I 14 mie I5 07 .01 • _ 16 •fig . 23 I7 •y.5 o` L 4SS _ 18 057, .05- ' erf x 19 20 •O5-1 ✓f8 21 09 a •o'{ a to 22 . 07 •ch 12.0 3' 23 I ,a,5' ©b$ 24 , IU 2s Zp . (L9 26 if' .3 e0 t _ S 27 .ol _ eD'a 28 rC`�j , Q, •SS 29 I. ,,O de 30 1,n2 (.1-.4o I - 31 `,� •03 . J-7 EXHIBIT. Total ,21 a .,IA Jig 3.79 2'Oil I.0 % 1 . 1S 1 . 2,2._.27 , ?1! - O -la— Cis SYBRON(Taylor Total Annual / 6, 73 1�♦ �lcZ tL - .. np N()qiVF V ^N 'Vfasglr(1 )[[)I[•1[[1N[+lIgI1NCMMq..nN.9MN NM\u C/.gf1L N.)r:)n. Hello