Document RJ6gmL2arZEM5Lq9769EDxeyk

* TO EXECUTIVE CONTACTS OF CMA MEMBER COMPANIES Dear Executive Contact: Subject: Member Company Comments on Proposed CMA Chemical Release Reduction Policy and Program -- March 1. Fe: X-F: ________ 1989 Briefing The purpose of this letter is to urge the attendance of your senior environmental, health, safety and legal managers at a March 1, 1989, briefing on a proposed major new CMA program concerning Title III, Section 313 releases. The proposed program encourages CMA member companies to increase their efforts to reduce releases to the environment and to increase the understanding of health effects from these releases. Public policy debates on Section 313 release inventories are anticipated, to gain momentum.when EPA releases its computerized inventory later this year. This new program will position the industry in a positive light for any follow up debates. The proposal is the product of an intensive six month process involving health, safety, environmental, government relations, legal, and communi cations experts from the member companies, with careful oversight by the Executive Committee and Board of Directors. The proposed voluntary policy and programs, built upon CMA's existing air quality policy and waste minimization program, are crafted to respond to immediate public concerns focused on the Section 313 release reports and to demonstrate industry leadership. To assist you in preparing for the briefing, I am attachine,^r copy of the proposal. Please treat these materials as confidential.^--^ - CMA's Environmental Management Committee will evaluate comments and make revisions over the next two months and make a final presentation to the Board of Directors in April. The March 1 briefing is designed for senior environmental, health and safety, and legal managers, to review the proposed policy and program, discuss the relationship to other CMA initiatives, its implementation, communication strategy, impact on local operations, and to provide opportunities for attendees to ask questions. A tentative agenda is enclosed. The briefing will be held at the Raraada Renaissance Hotel, 1143 New Hampshire Avenue, N.W., Washington, D.C. (-202)' ^ 77'S'CS ^c8a?"00DD beginning at 9:00 a.m. A block of rooms has been reserved for l*1'' those who will arrive the night before. (When making reservations refer to 1 RR #392. The cut off date is February 15, 1989.) \ y" A$ &X a Vr^ $ 2501 M Street. NW, Washington, DC 20037 202-887-1100 'Telex 89617 (CMA WSH) VVV 000028464 * ft Executive Contacts January 30, 1989 Page 2 r. 0 (Z) <^r ,t; r C> JL C^--" To assure that all member companies will be accommodated at the special briefing, I am requesting that you designate no more than two represent atives to^attend-s------1 would flppimiaLo ~ygur contacting David W. .Carroll's office ,-2027867-1185. Ms. Stephanie jleiny^I^to advise who your represent- ative^a>_j4ii4-^e-for tnei March i. 19S97~Tffrefc4ng. We aak that each attendee bring a check made out to CMA in the amount $35TD$"~to defray the costs for continental breakfast, coffee break, am tngNroom. If you have any questions on this matter, please contact Djavid W. Carroll, Director,. Environmental Programs, (202) 887-1164 or Ann MJ Mason, Associate Directing--Environmental Division (Air Programs), (202) 8817^1180. f) Attachments cc: Environmental Management Contacts Health and Safety Contacts Responsible Care Coordinators Title III Contacts CAER Coordinators Legal Contacts Washington Offices State Contacts VVV 000028465 t* t * TENTATIVE AGENDA PROPOSED CHEMICAL RELEASE REDUCTION POLICY AND PROGRAM BRIEFING MARCH 1, 1989 7:30 9:00 a.m. Registration and Continental Breakfast 9:00 9:15 Introductory Remarks - R. A. Roland, President, CMA Section 313 Impact and CMA's Responsible Care Program J. Holtzman, Vice President-Communications, CMA 9:35 Draft CMA Chemical Release Reduction Policy - C. T. Seay, Chairman, Environmental Management Committee 9:50 Questions and Answers 10:15 Break 10:30 Programmatic Support Proposals Regional Monitoring and Modeling - R. Bradford, Leader, ad hoc Chemical Release Reduction Group Health Effects Evaluation Program - R. Van Mynen, Vice Chairman, H&SC Smaller Company Assistance - R. Bradford Communications Program - J. Holtzman 11:15 Questions and Answers 11:40 Concluding Remarks -- C. T. Seay 11:45 noon Adjournment VVV 000028466 i s H :-.:~:ys 4 -ia vi kf &*' % iu ' ' jVj I-:a';d' ti| fTworrrAT. mtjcask ON POLICY CONFIDENTS CHA will prwti, --nig its member companies, prsctiess thst protect the safety sad health of employees aad residents of communities in.which they operate. Oar industry1 s goal is to assure that employees and communities are not adversely affected by oar operations and to encourage others, including our suppliers and easterners, to achieve the sane goal. (9Id understands the public concern regarding health effects frea releases into the environaent. Ott also believes better inforaatian on the effect of these releases is needed to assure fally infotned action by govemaant, industry and the public. Qtt neaber ceapaniea will increase their efforts to reduce releases to the environaent and to increase the understanding of health effects fraa these releases. Existing industry activities will be consolidated to bring focus to thi offort so that the industry's perforaance will be iwproved and the industry's nargin-of-safety will be increased. This Qtt policy, recoaeended for lapleaentstion by each neaber coapany at each of its operations, includes the following elenents: 1) Using SARA Section 313 reports as a base, inventory existing raleaaea to all media. Chemicals other than those covered by Section?;313 will be included aa appropriate. 2) Establish priorities for the inventoried releases-boned on factoss including their potential iapact and the level of-co--unity concern. 3) Foranlate a release reduction plan, baaed on this ranking, to increase the current nargin-of-safety, increase operation efficiency, and address areas of public concern. In the plan, transferring releases fron one nedla to another should be used only if the overall volune, toxicity, and environaental inpact is reduced. Reductions nay be achieved by any of the following nethoda, but it is recognized that such reduction efforts are listed in declining order of desirability aad neaber eoapaniea will direct their efforts accordingly: i) Source reduction. ii) Recycle/Reuse. y ill) Treatment to reduce volune and/or toxicity before release or diapoaal. 4) Initiate a systea to report release reduction progress. 5) (~i --nil h ill overall plans and progress to employees aad the public. In addition, to increase understanding of the efforts of ch--leal releases, CHA will work to better determine the concentrations Of chemical* in tha environaent and the health affects of such chemicals. Finally, in Implementing all of the above, CHA will foster assistance to snaller plants and companies. CHA EC 1/17/89 vvv 00286/ t *r.; V REGIONAL MONITORING AND HOPELLIHS PROJECT '"S'Vonrrsv i'JV* i \U',V PROJECT EACRSROUND Hm public ptrciivw that no BMivMiat data exists on Section 313 chanicals released to tho air, nrfae* water, or trnanibattr. Aartfort, they btlitvt "toxica" ara a health throat. United nnn-ftorfng data indicate that there are wry aaall concentrations of eheaicala ia caaanaitlee. SPA ad others have indicated that the gairal air quality ia i^raviag. The objective of this project la to proactively obtain aore data to conflrn that Section 313 ehaaicale generally do not poee a risk to cooaaaitles. In addition, it designed to achieve a secondary benefit of getting anblent data syetena ia place to nenitor progress. The project proposal focaaes on air lasses as the initial priority with possible snbseqseat phase in of surface end groundwater progress to assure a nsltl-aadia perspective. The project will provide for data collection using regional air dispersion nodalling to predict hotshots end optiaiae the location of a of five to tea nenitors per senpliag location. Five to tan target regions: are istrieniieri es the nlnlnnn level of effort. . ;Svyv OPTIONS CONSIDERED Three progr--tic levels of activity were considered. The firstalternative is a base case that supports Options 2 & 3. Option 2 places the local CIC's in the leadership position but the bulk of the total coat still aoat be assuned by ths local industry. Considering CMA's budgetary constraints, this is ths rscoanandad option. Option 3 creates a new area of activity for CMA, and carries a high prleetsg, although it delivers the niana leverage, visibility, and credibility. 1. Base Case Gather available data into a central reference systen (e.g., Houston Regional Monitoring Network data, Bay Area Air Tonies Study,EPA indoor air study, and volunteer date acquisition by naaaber conpaaiea). This central reference syatan on nonitored data can be eupplananted with a CHA regional dispersion nodal and e CMA regional ssapling protocol. Development of the eodeling/aonitoriag protocols will cost shout $50,000. Protocols can be developed by contractors by June 1989. The data gathering effort will cost spproxlnstely $50,000. 2. Proactive CIC Activity Replicate the Houston Regional Monitoring project, or nodlfied approaches, in priority areas through CMA leadership. Local prograns will be conducted by consultants with local industry flnencial support and technical direction. This option places the entire financial and sanpowsr burden on local industry and ia probably limited to those ,028*6 VVV 000 i mas with existing, active CIC's. Dtta gctharad In this way My have lass credibility because the public perceives that it Is "industry** generated rather than s cooperative effort lead by rn--inlty leaders. The total costs fron local Industry for significant nodalling/Monltorlng progress typically will be in the range of $500,000 to $1 Million per region per year. Top don nanagenent support fron Ott nanber conpanies vill be necessary to establish regional Monitoring prograMS under this option. 5. Proactive Aetiwitw fpd ttHWJftr ttmRJtt Osing the Houston Regional Monitoring Network as a Meriting Model, CMA esn offer Matching grants sad technical assistance to state and local agencies, CIC's, or foundations and ooonissiens to establish and carry out regional air Monitoring progress keyed around significant 313 releases. Funding will be leveraged and industry will be visibly Involved in assuring valid data collection for progress proposed by the local coHsunities. Under this option, CMA will cover at lease a third and possibly nore of the total cost for at least the initial year. CMA's direct cost vill be approxinately $1 to $3 Million dollars for the initial year. Mir.TTHimTA TOTAL PROGRAMS -,* Groundwater and Surface Water progress can be introduced on a delayed tine line. 1. Groundwater Support stats wellhead protection progress through partnerships with local govarnsent. Local industry night provide data and technical expertise, i.e., tenporary locals of hydrogeologists, for exanple, as well as grant noney for groundwater Monitoring within the wellhead protection progran. This progran is not currently funded at the Federal level, yet the States are anxious to protect their public water supply as suggested in the 1986 Safe Drinking Water Act Aaendaents. 2. Surface Water Provide grants to organisations, such as, the Chesapeake Bay Foundation, The Mississippi River Coalition. Surface water quality could be Monitored in the iMediate area of nanber-conpany facilities to supplenent State Monitoring efforts. CMA EC 1/17/89 BD 1/18/89 wyV 0000*8*69 t *. CONFIDENTIAL SUPPORT INFORMATION FOR REGIONAL MONITORING MODELLING 1. Tirwt Aru for Rational Modolliw^/Mp"****^*** lontoB, IX Baton Rong, LA OiMttr Nw York/New Jersey Philadelphia, PA hfflo/Ni|ira Falla, NT Bay Araa District, CA Sooth Coast (Los Angolas) District, CA Chicago, IL Kanawha Vailay, W Washington, DC (control) 2. Houston Raaional Monito^-fl Experience Ihs Hooston Regional Monitoring Corporation (BRM) was formed in 1979 by local araa businesses to obtain anblant air nonitoring data for the criteria air pollutants. Eleven (11) nonitoring stations were established. The priaary purpose of HRM was to enable coapantes to satisfy Prevention of Significant Deterioration (PSD) permit application requirements. Slncw its inception, the focus of data collection and analysis has shifted to neat *4****g,fwg needs. Collected osone data, in particular, has bean very useful to industry and the State in evaluating air quality, the effects of various emission sources and controls, and the significance of monitor placement. In 1987, the HRM's focus was expanded to include collecting ambient air concentration data for about 170 specific chemicals, including many SARA Section 313 chenicals of concern. Samples are obtained for a 24*hour period every sixth day at six existing monitoring stations covering about 900 square miles. This monitoring is intended to assess long-term community exposure to these substances in outdoor air. During each sampling period, a 15-liter canister is filled at a rate of 6 cc/min, and then the canister is transferred to the Radian Corporation for analysis. Extensive QA/QC procedures are employed. Meteorological conditions are recorded for each site to support assessments of the data. The cost of this targeted monitoring is approximately $80,000-l00,000/statlon/year. The monitoring stations are operated by Radian Corporation, and the entire HRM effort is supported by member-company contributions of about $50-$60 per manufacturing employee. 3. Baton Rouse Area "t Air Monitoring In early 1988, several companies in the Baton Rouge, LA, area initiated an effort to better understand the ambient air quality in the Baton yW 000028470 CONFIDENTIAL Rouge area and the effect of --ImIcm on air quality. Ilia effort included short'tan ambient air sampling and analysis by Radian Corporation and modeling by Trinity Consultants. The total cost is expected to be approximately $190,000. Monitoring consisted of the collection of 24-hour composite sanples at four (4) locations for three (3) consecutive days at each site and included significant QA/QC procedures. Total cost for the 12 sanples, analyses, and QA/QC, including setup of the temporary nonitoring station, vas $65,000. The sanpllng and analytical procedures were the sane as for the >r>hn HRM project. Modeling consisted of dispersion calculations for the emissions of 17 substances fron 13 area facilities. In addition, the OEMS aodel vas used to estiaate exposure and risk In the area for tvo of the substances. Total cost of the aodelling effort is about $65,000. On-site personnel involved in the Interpretation and use of the nonitoring and aodeling data with interested public consider the nonitoring data to be nost believable and, therefore, the aost useful. 4. Petrochaalr n] fomplax Monitoring fTntxm) In early 1968, enhanced Industry Hygiene (IH) collection tube nonitoring techniques were used to obtain aabient air quality data for eight VOCs in the vicinity of a aajor petrocheaical coupler. The enhanced techniques were capable of quantifying low ppb concentrations of the substances. Sanpllng was conducted at eight locations with seven 48-hour coaposite samples obtained at each location over a three-week period. Total cost for sanpllng, analysis, and QA/QC was $50,000. Based on the success of this effort, the seme technique has been employed at other locations. *& Dispersion modelling is now being initiated in the area to estimate the ambient contribution at 400 receptor locations of tan cheaicals. From 200 emissions sources at five facilities, the modeling coat la estimated at $25,000. CMA EC 1/17/89 BD 1/18/89 00002`*',V CONFIDENTIAL % OPTIONS rat CCMfONITT HEALTH EFFECTS EVALUATION PROGRAM lACEBOUND: Hi* Ad Hoc Okwlctl Release Reduction Verk Group, nd the Health and Safety CoalttM have developed eight optIona for responding to the public's concern about exposure to chanical releasee. These options are presented to help Identify the aost beneficial coarse of action for l^lanantlng this progran element. Evaluating the effect of chanical exposure on r it--nulfy health is central to addressing the poblic's concern about chanical releases. Clear and widely accepted nethods to identify acceptable levels of exposure are essential to explain the of Title III, release reduction, and waste minimi nation data. After a discussion of all options, the consensus of the Ad Hoc Vork Group, and the Health and Safety Connlttee focuses Increasingly on CMA sponsoring the developnent of consensus nethodology(s) at en.orsanitation such as CIIT. (See Options 5 and 6 below.) The cost of pursuing this option is approximately $250,000. The longer tern application of the consensus method(s) by other groups to a wide variety of substances entails additional costs. PROGRAM DESCRI1 The Cu--mnlty Health Effects Evaluation program seeks to identify methods to characterise exposures of the general public to chemicals. The effort will work to identify existing methods to determine safety, and to improve the existing state of science in determining safety. Moreover, the program will work to improve the public acceptability of the measures used to judge safety. PROGRAM OPTIONS: Options considered for the program are listed In their order of resources required: Option 1: iwwMMy (Tnrirppfnf $rt1nn Safety is a matter of public perception and acceptability. Industry's activities will always be suspect and CMA should encourage government regulatory agencies to set safety standards. Until standards are set, industry will use existing measures to judge safety and explain these to the public. Option 2: Encouraxe Research. Industry could encourage research by government agencies and universities to improve methods by which to judge safety. q00028^72 vvv I* CONFIDENTW Such nieonri|iMot will only b suggestions that this is a serious issue that needs attention. Option 3: Fund Research. Industry could fund research by universities, national laboratories or consultants to Inprove nethods by which to judge safety. Option 4: Build onCMA's Informs**"" tomsiiye Values. for Community CMA could exanine the mnminltj exposure values obtained through its information exchange progran. Consensus areas could be identified, and a needs assessment end feasibility study could be done for future work in developing exposure Option It Dnseloo Consensus on Methodology^ s). Industry could further develop consensus on nethod(s) by which to establish community exposure values. The nethod(s) will not be applied to specific ehenlcals, but published in the scientific literature for use by individual companies or governnent agencies. Tbs application of any netted to specific ehenlcals will often require the development of additional data on that substance to fora a scientific decision. Option 6: Fund an Independent Organization. The chsnical industry could fund an outside organization, such as CUT, to develop and apply a netted for setting cosunity exposure values. Option 7; Industry Could Develop and Apply a Methodology for Setting Co--unitv Exposure Values. An industry group could develop a method for setting m--unity exposure values. This netted and data on specific chemicals could then be turned over to a standard setting organization such as AIHA, ACGIH, ASTM, or EPA. Option 8: Fund an Independent Expey* scientific Panel to Develop and AppIv a Methodology for Setting Community l Exposure Values. The chemical industry could fund an independent expert scientific panel, through a university research canter or national laboratory, to develop and apply a consensus method for setting community exposure values. The method and values will then be made available to standard setting organizations. VW 000028473 RESOURCE EEC l| CONFIDENTIAL Costa: Coots will Tory dfsHni 00 ths options sslsetsd. Costs rags fron nothing for option 1, to $30,000 - $50,000 for option 4, $250,000 for options 5, 6 sad 7, sad $600,000 for option 8. Tins: Dopsndiag on ths options sslsetsd, lnpl--sntstlon coaid tsks tno to fits years. Ths tins rsqslrsd dspsnda grsatly on ths . rssoorcss dsvotsd to ths projsct. Option 6, for Instones, will raqolrs 2 ysars whils option 1 will dspsad an ths spssd with which rsgalatory sgsnclss set. Options 5, 6, and 7 will rwpirs ons ysar to dsrslop conaonsws nsthod(s) with additional tins rsqairsd for application to spsclfic substaacss. CMA EC 1/17/89 ID 1/18/89 000028474 VVV i ( i i CONFIDENTIAL ASSISTANCE TO HIT** COMMUTES PEQJBCT gACKGSOONP The iwbir companies of CMA m eoalttad to the nceMifol implementation of both tho Utttr and tho spirit of Title XII. SoWTtr, many ntllu companies are hirlai difficult time imple menting key components (wrfwcy planning, accident prevention. Mission reporting, etc.) of the lev. Poor perfomsnee by any eonpeny, snail or large, nay affect the nany positive proactive neaanres node by CMA nenber eonpaaies. CMA nanber i onpantes should provide technical assistance to their castoners and saaller eonpaaies to enhance overall environmental, health and safety prograns. ornews The following options were considered to assist seal lei companies with, their envlroonental, health and safety prograns. The saatlnent of thn* eork group is that an inpleneatation strategy that conbiaes several of these options will be the noat effective. 1. Mcnher eonpaaies will coonoalcate to and provide direct assistance to saaller eonpaaies through existing product stewardship prograns. Mail infornation packets - Invite custoners in for training - Send technical service representatives out to custoners CMA will work with the Council of ChMlcal Association Execu tives, U.S. Chanber of Conerce, State ChMlcal Councils and other national organizations to davalop coMunication piecea on technical assistance available to saaller eonpaaies and how to access the process. Approximate cost for CMA to laplament the activity is $10,000. Coanualcations regarding technical assistance to saaller companies will begin in early Hay. 2. Member companiee and CMA, possibly using contractors, will conduct oa-site training for companies In the following areas: - Vaata alnlmlxation/releasa reduction principles and methodologies - Process safety - Emergency planning and preparedness - CoMunieating with employees snd ths community - Public health issues. As an alternative, CMA and member companiee will develop SMinars/ workshops on a regional/local basis to provide information on the key issues highlighted above. They will be highly participatory and hands-on. They will use case studies presented by experienced plant personnel. The seminars will partially pay for themselves, VVV 000028475 I CONFIDENTIAL although funds trill be needed to develop guidsncs materials in bom of the trtu Mntiontd (approximately $75,000). The workshops could bo acbodulod for lots raMr or early fall. Ths seminar/workshops will bo developed and co-sponsored by: Individual member companies - Stato chemical organioptions - CMA/other trado associations Council of Ch--icol Association Executives. 3. Member canpanlos could mobilise tboir rotiroos to provide nany of tho services listed above. Tltere are nany unknowns including personnel availability and interest, cost, and tining. Nevertheless, this option is worthy of further consideration. 4. CHA could establish a technical assistance hotline for smaller companies to call and request help. tfe recognise that each company requesting assistance will have different needs, pressures, and time constraints. Hie hotline could cost approximately $170,000 per year (including staff) unless it can be consolidated into on existing CMA service. The hotline will begin operation in Jhly 1989. ^4 5. Establish assistance programs with key universities whereby undergraduate and graduate engineering stndants assist smaller companies in their waste minimisation and release reduction programs. A team (3-4 students) could have a project (defined by the company) to work on for the semester. The final report will include ways to minimise waste/releases and operational costa, and eaximise effectiveness of Implementation plans. This process could be initiated through state chemical organizations. Pro jected costs are not clearly defined at this tine. r CMA EC 1/17/89 BD 1/18/89 VVV 000028476 I t < I ^^irr r The Advice 1. Communications in this negative climate of opinion should be low key, humble and soft. Promises that smack of arrogance will break credibility and perhaps be counterproductive. Do not throw a lot of technical and scientific facts at people. 2. -i ** The-goal of public .information activities should be grudging acceptance of chemicals, not .arm-waving favorability. The goal is tolerance, not winning/a popularity contest. Facts, messages and themes ... should not try to demolish the hard-core anti-chemical activists. To address the issue, deal with the problem, not the activist critic. 3. Communications must strive to build a perceived need argument for why chemicals should be used and tolerated. Stressing and amplifying a need for ch<cala is the single best way to lower public anxieties about chemicals. 4. To the extent that some statements must be made about health 3 and safety Issues, they should stress "learning from the past? - that is, admit that mistakes have been made and we've learned, from them. They should also focus on people, not products and technologies. 5. Public understanding and acceptance of chemicals is a process of building tolerance, not a one-time sale. Given the irresistible temptation of the media to always publicize the negatives about chemicals, only pro-active activities can engage the public. It is trench warfare, not quick and neat surgical strikes. t VVV 000028477 9Z>8Z0000 AAA et^szoooo AAA qspa Suponpaj Aqyjaqq 'pxezsq uo anooj oq opiqnd eqq SupAOppa *a3ajqno eonpaj oq Xqpunqjoddo aqq eppAOjd ao m exqpj. VHVS *aox *Swqno eqq deeq `spjyzaq /sop ^Ta S&nap jp noA ji *uopqputunnre joj qp Aae jo qp jouSt jeqqpe JLeqj, *e8ajqno Aq eqq uaq* aqap pjazaq 03 ueqspp lou op apdoa^ qapj anopjas sc as a qaqft eaouSp pup qspj pTATJ3 e as m qaqA qnoqa aeveueq oS eqq Xq sp qaqj, 'pjazaq 03 saop qp uaqq eSajqno 03 ejoo spuodeej oppqnd eqx *eojnos qq qsruq 03 eaeuffoppppA uo spuadap 3|spj qdaoaa 03 sseuSupxiTrt *seojnos XqqjoAqanjx *9 qpnopjppp auopasnoapp qpjeuaq/qapj aaqam qunooa Xu an sap pajom anooaq saq uopqnppod ay ^qppauaq 43 sqeS oq puy qapj eqq qdaooa 03 saq oq* up ay 'jpaj *$ $8upppa 92v noA uaqA jo `SupApjp eqq Supop aj t noX uaq japas xp noA op `epdoexe jo^ 'xanppAppup eqq Aq pojquoo padoqg `paoao Aoq `suopqvnoaA `apppde aja epqaJooieH *xq2oaatD qojq * appea `uopqaonpe 4sjnoq quapd 'xapTT*J ' ' Z -X>.J..facrv.*'i----- fr. ^aaaooadyquapd, Aau .uo oo AOi*/ ^uopqaooj; * Mayoqo.pq Foopepoapup paAXOAUp t&qpaznaDoo aqq-qa^ . *e>Jiap^brm*fnqpufaa aejqq appa AxequnpoAUi) -AjaqimxoA *p fflPgr-'-: T-fciiri;. -?a - 'J, ... -------*"* -1 ' Jit.,- ro*-TtsE*. t. ^O^srzj.'*.: r ? 3>- ' _'l. * _ .. . J.Wi f.i. l.te'VrlM **4rce? r <..*.:r* ..* -c-p-ts?:... <* >;: ~ 'akajquo pnpaj 03 ajoqoaj _ --Sv-3*W* W5* <-v. r.i J>j 5r i" 4?ic aqaqap aqq aavajp qi `Aatzom aaapaj qj ^Supo8 4ax*s*j* a.qapfqay:>r'wq' 'JMtT?^payq*aaAooTaip ^wqq^-aps'fTt--;. z-is jqop ' rr ^ anxd pjazaq peT cfq*Ti iojiuopqpupjapuquaxejjpp'aiapq `opxqn1a aqxcl .jr.;, i-. - . :scy xxtrcii3^-JX'C&-' ' -r - :2 cy.rx^'-' T- ^`^'^^Aa^spqq^o^anaoaq pajufup-aq^oq OJ SupoS 8JB noA saouaqo aqq aaa qaq :pjazaq aa Jjapj saoe Ajqanpux