HomeMy WebLinkAbout930874.tiff RESOLUTION
RE: ACTION OF BOARD CONCERNING SHOW CAUSE HEARING CONCERNING SPECIAL REVIEW
PERMIT #540 - NORTHERN COLORADO BRINE, C/O MIKE CERVI
WHEREAS, the Board of County Commissioners of Weld County, Colorado,
pursuant to Colorado statute and the Weld County Home Rule Charter, is vested
with the authority of administering the affairs of Weld County, Colorado, and
WHEREAS, on May 19, 1993, a Show Cause Hearing was conducted to consider
revocation of Special Review Permit #540, issued to Northern Colorado Brine, c/o
Mike Cervi, and
WHEREAS, at said hearing on May 19, 1993, said matter was continued to
June 23, 1993, then again continued to July 7, 1993, at which time said matter
was again continued to August 30 and 31, 1993, at 10:00 a.m. , and
WHEREAS, Mike Cervi is the owner of the facility located on property
described as part of the NEI of Section 26 and part of the NW,' of Section 25, all
in Township 5 North, Range 67 West of the 6th P.M. , Weld County, Colorado, and
WHEREAS, at said hearing on August 30, 1993, the Board deemed it advisable
to continue said matter to November 17, 1993, based upon the recommendation of
the Planning staff, to allow further review after November 1, 1993.
NOW, THEREFORE, BE IT RESOLVED by the Board of County Commissioners of Weld
County, Colorado, that the Show Cause Hearing concerning revocation of Special
Review Permit #540, issued to Northern Colorado Brine, c/o Mike Cervi, be, and
hereby is, continued to November 17, 1993, at 10:00 a.m.
The above and foregoing Resolution was, on motion duly made and seconded,
adopted by the following vote on the 30th day of August, A.D. , 1993.
BOARD OF COUNTY COMMISSIONERS
ATTEST: WE COUNTY, COLORADO
/0gAL
Weld County Clerk to the Board
Constance L. Harbert, Chairman
BY: /l g&.) EXCUSED DATE OF SIGNING (AYE)
Deputy Jerk to the Board W. H. ebster, Pro-Tem
APPROVED AS TO FORM:
George,e.- Baxt r
ounty Attorn y � —Ba1eK. Hall
arbara J. Kirkmey r
930874
pi_ c L1,
HEARING CERTIFICATION
DOCKET NO. 93-22
RE: SHOW CAUSE HEARING TO CONSIDER REVOCATION OF USR #540 - NORTHERN
COLORADO BRINE, C/O MIKE CERVI
A public hearing was conducted on August 30, 1993, at 10:00 A.M. , with the
following present:
Commissioner Constance L. Harbert, Chairman
Commissioner W. H. Webster, Pro-Tem
Commissioner George E. Baxter
Commissioner Dale K. Hall
Commissioner Barbara J. Kirkmeyer
Also present:
Acting Clerk to the Board, Shelly Miller
Assistant County Attorney, Lee Morrison
Planning Department representative, Keith Schuett
Health Department representative, John Pickle
The following business was transacted:
I hereby certify that pursuant to a notice dated April 12, 1993, and duly
published May 6, 1993, in the Windsor Beacon, a public hearing was
conducted on May 19, 1993, to consider the revocation of USR #540 issued
to Northern Colorado Brine, c/o Mike Cervi. At said hearing of May 19,
1993, said matter was continued to June 23, 1993, then again continued to
July 7, 1993, at which time it was again continued to August 30 and 31,
1993, at 10:00 a.m. At the August 30, 1993 hearing, Lee Morrison,
Assistant County Attorney, made this a matter of record. Keith Schuett,
Planning Department representative, said he inspected the site on
August 27, 1993, and the aeration system was reviewed and approved by the
Health Department on August 4. He indicated Planning staff's opinion is
that issues are being or will be corrected and the operation will be in
compliance with the State's stipulation and agreement and other agreements
by November 1; therefore, said matter should be continued. Mr. Schuett
indicated no violations have been found concerning the pending Air Quality
Agreement. He also stated two ponds are dry, with the large pond going
down approximately three-eights of an inch per day due to lack of
production and the weather being conducive to evaporation. Chairman
Harbert stated concerns about the liner cracking if the ponds are dry.
Mr. Schuett said he would let Mr. Lind respond to Chairman Harbert's
concern, and he responded to a question from Commissioner Kirkmeyer
stating that, upon review of the records, there were 918 barrels received
on August 26, 1993. Ken Lind, Attorney representing Northern Colorado
Brine, gave an update on the status of operations. He said a full
stipulation was entered into on July 30 concerning the air emissions
permit, and an amended air emissions permit was submitted on August 12,
which the State indicated is granted, thereby bringing the facility into
compliance with the State concerning the 2,000 barrel-per-day limitation.
Mr. Lind submitted said stipulation and agreement with the Air Pollution
Control Division as Exhibit 100. He explained, for the record, that he
started exhibits presented at today's hearing with the number "100". Mr.
Morrison noted that Exhibit 100 is the same as Exhibit VVV already in the
file. In reference to the agreement deadlines, Mr. Lind said the final
design was completed in June, the equipment was ordered at the end of
June, and construction for installation of the new equipment commenced the
first week of July; therefore, all requirements were ahead of schedule.
He indicated all new equipment is on site, and the building permit has
been applied for and is in the final stage of review. As Exhibit 101, Mr.
Lind submitted a list of questions, received from the Health Department on
July 9, and responses, submitted on July 15, concerning the new heater-
treater equipment. He said, upon the determination of the Health
Department, a Design and Operation Plan was submitted on August 20 and
930874
C?C ; i�t'
RE: HEARING CERTIFICATION - NORTHERN COLORADO BRINE, C/O CERVI
PAGE 2
questions concerning same were received and responded to on August 27.
Concerning the aeration and misting system, Mr. Lind submitted two
letters, dated July 15, 1993, and August 4, 1993, from Trevor Jiricek of
the Health Department. He said the aeration and misting system will be
removed when the facility is updated with the new equipment, and an
agreement has been made with the Health Department that no new equipment
will be installed without County review and approval. However, it is
anticipated such equipment will not be necessary. In regard to the odor
abatement plan, Mr. Lind said several plans have been submitted and
reviewed; the most recent being the two-tier bioremediation. He explained
phase one, the bioremediation plan, was approved and went into effect
immediately. It will be followed by phase two, the installation of the
new equipment, which will complete the final phase of the odor abatement
plan. Mr. Lind indicated the skimming program is used to remove skim at
the surface. He noted there are two additional storage tanks on site
temporarily, but the skim is almost non-existent since the bioremediation
treatment began. In reference to the depth of Pond 4, aka Pond E, Mr.
Lind referred to detail, diagrams, and letters from the engineer and
County and State Health Departments. He explained the agreement entered
into with the County requires Pond 4 to be brought down to 30 inches of
freeboard and to remain at or below 30 inches unless a plan is reviewed
and approved by the County. He submitted, as Exhibit 103, letters from
the Health Department and Nelson Engineers as confirmation of the 30-inch
freeboard height. Mr. Schuett clarified the pond would consist of no more
than 6 inches of salt accumulation, 24 inches of brinewater, and 30 inches
of freeboard. Mr. Lind indicated Vern Nelson, Nelson Engineers, said Mr.
Schuett's clarification is correct and is part of the Design and
Operations Plan. He explained the actual pond structure is more than five
feet deep, but the freeboard will not exceed 30 inches of water. On
behalf of the Board, Mr. Schuett reiterated the depth may consist of 6
inches of salt accumulation, 24 inches of brinewater, and 30 inches of
freeboard, but may not exceed five feet. Mr. Lind explained the pond is
still in evaporation status, with no water added since April 1, and review
and erosion control matters being taken care of in an agreement with the
Health Department. In response to a question from Mr. Schuett, Patty
Deplazes, Eastern Plains Environmental Service, said the estimate was not
yet completed concerning the rate of evaporation or how much longer it
would be until the pond was down to 30 inches. Mr. Lind indicated the
pond would be at or below 30 inches by November 1, and, in response to a
question from Commissioner Kirkmeyer, Mr. Lind said the floor varies in
depth from 3 to 5 feet. Mr. Schuett said it would be the responsibility
of the engineer to show elevations. Mr. Lind confirmed pond depth would
be shown in the plan to the County and indicated there are gauge height
markers on all ponds. He reiterated, on behalf of Commissioner Webster,
that an aeration and misting system plan would be submitted to the County
for review and approval prior to installation; however, the need is not
anticipated. In response to a question from Commissioner Hall, Mr. Lind
said an agreement has been entered into with the County Health Department
for review and inspection of Ponds 3a and 3b, which are being dried out.
He explained Empire Labs and Nelson Engineers are in the process of
inspection and coring tests, and, if the ponds are in compliance, they
will be brought back into operation. In turn, another pond will be put
into Ponds 3a and 3b and that pond will be tested. In response to
questions from the Board, Mr. Lind said water haulers will take the water,
if it meets the necessary requirements, and it may be used for irrigation
if it meets irrigation quality standards. Mr. Lind said, in regard to
continuing today's hearing, it may be beneficial to hear this matter after
November 1, to include the State's status and allow review in final
operation. He suggested November 17 or December 1 as continuance dates.
Commissioner Baxter questioned whether the existing water with the
bioremediation treatment would still be run through the other equipment.
Mr. Lind said there would be no need to go through the new system, because
the bioremediation treatment was better than expected. In response to
questions from Chairman Harbert, John Pickle, Health Department
representative, stated odor readings have been taken in response to
complaints; however, there have been no violations in the interim period
with the highest reading being 7: 1, which is not a violation. In response
930874
RE: HEARING CERTIFICATION - NORTHERN COLORADO BRINE, C/O CERVI
PAGE 3
to another question from Chairman Harbert, Mr. Pickle said the smell could
be noticeable from Highway 34 and not necessarily be in violation,
depending on the variables. Mr. Schuett said he is not a certified nose;
however, the intensity of odor has been greatly reduced, and the clarity
of the water on the edges has increased, which indicates less bacteria.
Mr. Pickle confirmed greater clarity would show a reduction in
hydrocarbons, etc. , and said he had no further comments concerning the
Design and Operation Plan other than those in his memo. In response to a
question from Commissioner Webster, Mr. Lind reiterated he recommended
continuing said matter to November 17 and indicated Mr. Nelson is
available to give an update on Pond 3, if desired. Chairman Harbert
recalled that two or three years ago when Mr. Cervi took over the
facility, she understood that when the ponds were dry or shallow, the odor
was more intense. Mr. Schuett said he did not recall that meeting;
however, he walked into the dry pond and there was no odor. Mr. Nelson
said Ponds 3a and 3b are vacant of brine water; however, they are not dry
or they would crack. He explained there is 18 to 22 percent moisture
which allows the ponds to remain stable. He mentioned, on behalf of
previous comments by the Board, that he does not know whether they were
dry in the past, but the current conditions of the material have been
tested and there appears to be at least three inches of very good quality
clay material. Mr. Nelson said they are expecting the permeability to be
good, and, if there is leakage, then heavy equipment will be used to
recompact the very adequate material to the optimum. He said this process
will be continued throughout all the ponds, which will take quite a while.
He said synthetic liners on slopes or in ponds will be considered if
necessary to avoid cracking. He also explained the original Design and
Operation Plan indicates the depth of the water allowable as being 24
inches of water and 6 inches of accumulated salt and/or sediment, which
was based on a prediction over a 15-year period. Mr. Nelson noted Ponds
3 and 4 contained maybe one inch of salt and two inches near the entry,
but on the average, less than one inch. In response to questions and
concerns from Chairman Harbert, Mr. Nelson said he doubted the ponds were
cleaned when Mr. Cervi took over, and indicated he expected four inches of
sedimentation, based on the prediction, over ten years. He also said if
it is determined conclusively the dikes are leaking, Mr. Cervi will
guarantee installation of a synthetic liner. On behalf of Commissioner
Harbert, Mr. Morrison said the Board may choose to hear public testimony;
however, it is not required at a show cause hearing. Commissioner
Kirkmeyer, in reference to Operation Standard #15, questioned Mr. Morrison
as to why Mr. Lind feels review and approval of systems are not needed.
Mr. Morrison said Weld County's position is that changes do require
review. Mr. Lind clarified the existing system, pursuant to the operation
standards, in his opinion, did not need review; it only needed to be
installed. However the agreement with Weld County requires review and
approval prior to installation of the new aeration system. In response to
further questions from Mr. Schuett, Mr. Lind indicated the existing
aeration system would be removed before November 1, depending on when the
ponds are emptied of water. Commissioner Baxter stated the Planning
staff's recommendation was to continue and review said matter after
November 1; therefore, he moved to continue the Show Cause Hearing to
consider the revocation of USR #540 issued to Northern Colorado Brine, c/o
Mike Cervi, to November 17, 1993, at 10:00 a.m. Commissioner Webster
seconded the motion, and Commissioner Kirkmeyer requested the depth of
Pond E be determined by November 17, to show whether it is in compliance
with Operation Standard #7a. The motion carried unanimously. Mr. Nelson
intervened to relay Mr. Cervi's invitation to the Board to visit the site
as soon as the construction for the new equipment is completed. In regard
to the Board touring the facility, Mr. Morrison said all legalities must
be followed by conduting a noticed tour, if testimony is to be taken, or
a self-guided tour, if no testimony to be taken. Chairman Harbert said
the Board would discuss the visit with legal counsel and thanked Mr. Cervi
for the invitation.
930874
RE: HEARING CERTIFICATION - NORTHERN COLORADO BRINE, C/O CERVI
PAGE 4
This Certification was approved on the 1st day of September, 1993.
J �j APPROVED:
ATTEST: �f,/� JJ BOARD OF COUNTY COMMISSIONERS
411, x","47 WEL COUNTY, COLORADO
Weld County Clerk to the Board
By: A, /� /y �jt/ Constance L. Harbert, Chairman
Deputy jerk to the Board
EXCUSED DATE OF APPROVAL
W. H/Webster, Pro-Tem
TAPE #93-29ef _
/gE 'Baxt r 7t
DOCKET #93-22
Dale K. H 11
PL0059
jja 4.Y ca Cia/kv
TBarbara J. Kirkmey -r
930874
SHOW CAUSE
DATE: August 30, 1993
CASE NUMBER: ZCH-97 and ZCH-98
USR NUMBER: USR-540
PROPERTY OWNER
Northern Colorado Brine
c/o Mike Cervi
10600 Weld County Road 54
Milliken, CO 80543
LEGAL DESCRIPTION: Part of the NE4 of Section 26 , and part of the NW4 of
Section 25, all in T5N, R67W of the 6th P.M. , Weld County,
Colorado.
LOCATION: Approximately 1 mile east of State Highway 257, south of and adjacent
to Weld County Road 54.
It is the opinion of the Department of Planning Services' staff that this request
be continued. The issues of this Show Cause Hearing are being corrected or will
be corrected by existing agreements.
RUG 27 '93 10:05 F nil WELD CO TREASURER TO CENTr"VIAL BLDG PRGE.002i006
t1UlrLI-yj M1S1 tl.Ui r.UC
MEMORAt1DUf 11
Wi p
Keith 5chvett, W•C. Planning August 27. 1993
To oats
JOfd)RAbO John S. Pickle, H•S.E.R., Director, Environmental Beal
from
Robiet Northern Colorado Brine, DER-540
Environmental Protection Services has reviewed all submitted materials regarding
the El Toro Management Systems, Inc. water treatment and odor emission control
system which will be installed at the Northern Colorado Brine
facility. The
following conditions are recmmended to be part of any apP
1) The use shall be an oil and gas brine water disposal and oil recovery
facility as described in the submitted materials. only brine which occurs
as the result of exploration and production of gas and oil wells shall be
accepted for disposal at this facility. No hazardous wastes or non-
hazardous industrial waste shall be allowed at the site. The facility
shall be designed, constructed and operated to comply with the Solid Wastes
Disposal Sites and Facilities Act, Title 30-20, Part 1, CRS 1973, as
amended.
2) The facility shall not operate nor install any type of bubbler, misting, or
other type of aeration system. The design and operation of such a system
must be approved by the Weld County Planning and Health Departments and the
Solid Waste Division of the Colorado Department of stealth prior to
construction.
3) All structures not on the facility prior to May 19, 1993, must be reviewed
and approved by the local Fire District. Approvals must be submitted to
the Weld County Health Department and Planning Department.
4) All necessary permits and approvals must be obtained from the Water Quality
control Division of the Colorado Department of Health or the Colorado l
fi Gas Commission prior to discharging or removing any processed
off-
site.
5) A responsible employee, trained to differentiate between brine water and
other fluids, shall observe all disposal operations.
6) The disposal ponds on this facility shall be operated to maintain a mini
of 30 inches of freeboard. Freeboard shall be measured from the top
water surface to the top of the liner. Any deviation from the approved
freeboard distance must be approved by the Weld County Health Department.
7) The facility shall comply with the Stipulation and Agreement with the Air
Quality Control Commission signed July 30, 1993.
8) The facility shall consist of only those features and as described in the
submitted materials.
JSPIcs-1689 (J cn it
AU6 27 1993 11
AUG 27 •93 06=09 Wifablep?t 1.BIBFRIRg
1
AUG 27 '93 10:05 F'"-'M WELD CO TREASURER TO CENTT ' 'IAL BLDG PAGE.003'00G
INSPECTION REPORT
DATE: August 27, 1993
CASE NUMBER: ZCH-97 and ZCH-98
USR NUMBER: USR-540
NAME: Northern Colorado Brine
c/o Mike Cervi
10600 Weld County Road 54
Milliken, CO 80543
LEGAL DESCRIPTION: Part of the NE4 of Section 26, and part of the NW4 of
Section 25, all in T5N, R67W of the 6th P.M. , Weld County,
Colorado.
LOCATION: Approximately 1 mile east of State Highway 257, south of and adjacent
to Weld County Road 54.
The property was inspected to determine compliance with Operation Standards 1,
3, 6, 7-A, 7-H, 7-I, 7-J, 8-A, 15, and 16. Theses standards were identified as
part of the Probable Cause hearing.
Operation Standard Number 1 states as follows:
The use shall be an oil and gas brine water disposal and oil recovery
facility as described in the submitted application materials. No hazardous
wastes or nonhazardous industrial waste shall be allowed at the site. The
facility shall be designed, constructed, and operated to comply with the
Colorado Department of Health Solid Wastes Disposal Sites and Facilities
Act, Title 30-20, Part 1, CRS 1973, as amended.
The inspection showed that the use of the property is being maintained in
compliance at this time.
Noncompliance of this standard in the past has been noted as follows.
- Nonhazardous waste from Monfort and other facilities have not been
received at the facility after the noncompliance was identified. Prior
to this inspection, the use of the property was not limited to the oil
and gas disposal and oil recovery facility as described in the
submitted application materials. Nonhazardous waste from Monfort and
other facilities were been disposed of at this site.
• No Frac tanks other than the two allowed on-site for pond skimming
were observed. Prior to this inspection the facility was used for oil
field equipment storage.
No material other than brine water and approved waste have been
disposed of at the site after the noncompliance was identified. Prior
to this inspection materials other than brine water had been disposed
of at the facility. Receipt Numbers 40925 and 40862 indicate that
motor oil and other materials were disposed of at the facility.
AUG 27 '93 10:06 F'' M WELD CO TREASURER TO CENT' NIAL BLDG PAGE.004/006
INSPECTION REPORT, ZCH-97 ZCH-98
Northern Colorado Brine
Page 2
▪ The depth of the pond "E" is being reduced, however, the depth is
still in excess of 5 foot. The depth of all ponds is not consistent
with the application materials. The pond depth is not to exceed 5
feet (30 inches for freeboard, 6 inches for salt accumulation, and 24
inches for brine water).
Ponds A, B, C, and D meet the 30 inches of free board, pond A and B
are dry at this time. Prior to this inspection all Ponds were not
maintained with the minimum freeboard of 30 inches. Freeboard is a
part of the 5 foot pond depth from the top of the pond liner (30
inches of freeboard, 6 inches of salt accumulation, and 24 inches of
brine water) .
The inspection showed that less than 2,000 barrels per day are being
received. Prior to this inspection the facility had accepted more
waste than it was designed for. The facility was designed for no more
than 2,000 barrels per day. The facility had received as much as
9,000 barrels of brine water in ono day.
With less than 2,000 barrels per day received, the required 24 hour
retention time should be obtained. The facility was designed for a
retention time of 24 hours within the skim tanks prior to the release
into the ponds. Prior to this inspection the retention time of the
brine water had been as short as 4 to 6 hours with the amount of water
(9,000 barrels) that the facility has received.
The inspection showed that appropriate records are being maintained
at this time. Prior to this inspection appropriate recorded had not
been maintained.
- The inspection showed that the contaminated soils have been removed
from the site. Prior to this inspection contaminated soils had been
located on the property and not properly handled. Contaminated soils
were placed on the ground without any barrier or liner.
▪ Slight odors were observed during the inspection, these odors were noc
as intensive as what was observed on past inspections. Prior to this
inspection the facility had been cited for odor violations (2.1,2 of
Solid Waste Regulations)_
Operation Standard Number 3 States:
There shall be one (1) point of ingress and egress to the facility from
Weld County Road 54. The point of access shall be located, designed and
constructed in accordance with the submitted application materials and Use
by Special Review Permit Plan Map.
- Only one access was observed during this inspection. Prior to this
inspection more than one access to the facility was observed.
3
AUG 27 '93 10:06 F^"IM WELD CO TREASURER TO CENT' VIAL BLDG PAGE.005i006
INSPECTION REPORT, ZCH-97 ZCH-98
Northern Colorado Brine
Page 3
Operation Standard Number 6 states:
A six (6) foot chain link fence with three (3) strand barbed wire top shall
enclose the Use by Special Review area.
The inspection showed that the facility is enclosed with a (6) foot
chain link fence with three (3) strand barbed wire top.
Operation Standard Number 7-A states:
The four (4) evaporative ponds shall be engineer-designed and operated in
accordance with the submitted application materials and Use by Special
Review Permit Plan Hap.
The inspection showed Pond "E" was not constructed in compliance with
the submitted application materials (30 inches for freeboard, 6 inches
for salt accumulation, and 24 inches for brine water).
The water level of this pond is greatly reduced and should be in
compliance in the near future.
Operation Standard Number 7-H states:
A gauge height indicator shall be installed in the evaporation ponds. The
gauge must clearly indicate the depth of brine water waste.
The inspection showed that gauge height indicators have bean
installed.
Operation Standard Number 7-I states:
The evaporation pond(s) shall be kept free and clear of oil skims.
A small amount of pond skim was observed on pond C (the southwest
pond). Prior Inspections showed that pond skim was present on ponds
A, B, C, and D.
Operation Standard number 7-J states:
An aeration system shall be installed and operated on the four evaporative
ponds. In the event of an odor problem emanating from the ponds, an odor
abatement program shall be instituted.
AUG 27 '93 10:06 Ff^M WELD CO TREASURER TO CENT' NIAL BLDG PAGE.006i006
INSPECTION REPORT, ZCH-97 ZCH-98
Northern Colorado Brine
Page 4
• The inspection showed that an approved aeration system has not been
installed on all ponds and a complete odor abatement program has not
been submitted for review. An aeration system and a sprayer/misting
system has been installed on all ponds. Prior to this inspection odor
violations had been issued by the Weld County Health Department. The
aeration system and the sprayer system is proposal to be removed after
the new heater treater system is installed.
Operation Standard Number 8-A states:
The dump and skim tanks shall be engineer-designed in accordance with the
submitted application materials and Use by Special Review Permit Plan Map.
- The skim tanks are to be designed to have a minimum retention time of
24 hours. Due to the size and design of the existing skim facility,
and the amount of water received, the 24 hour retention time of the
brine water is being maintained. Prior to this inspection retention
time was as low as 4 to 6 hours due to the amount of brine water
received (9,000 barrels in one day) .
Operation Standard Number 15 states;
The Use by Special Review shall be limited to the plans shown hereon and
governed by the Standards as stated above and all applicable Weld County
Regulations. Any material deviations from the plans and/or Standards as
shown or stated above shall require the approval of an amendment of the
Permit by the Weld County Planning Commission and the Board of County
Commissioners before such changes from the plans and/or Standards are
permitted. Any other changes shall be filed in the office of the
Department of Planning Services.
- The inspection showed that the Use by Special Review site has not been
limited to the plans shown and has not been maintained in compliance
with all applicable Weld County Regulations. The Use by Special
Review site is not in compliance with all Development Standards and
all applicable Weld County Regulations and amendments to the approved
plans have not been applied for.
Operation Standard Number 16 states:
The property owner and/or operator of this operation shall be responsible
for complying with all of the above stated Standards. Noncompliance with
any of the above stated Standards may be reason for revocation of the
Permit by the Board of County Commissioners.
- The inspection showed that the property owner and/or operator of this
operation has not maintained compliance with all operation standards.
** TOTAL PAGE.005 **
5
Hello