United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park NC 27711
EMB Report 79-ELC-6
May 1979
Air
Steel Industry
Electric Arc Steel
Foundaries

Emission Test Report
Armco Steel
Torrance, California

-------
    FUGITIVE EMISSION EVALUATION REPORT
           ELECTRIC ARC FURNACES
                 Armco Steel
            Torrance, California
              Prepared for the
    U.S. Environmental Protection Agency
        Emission Measurement Branch
Research Triangle Park, North Carolina  27711
                 Prepared by
   Clayton Environmental Consultants,  Inc,
            25711 Southfield Road
         Southfield, Michigan  48075
           EMB REPORT NO. 79-ELC-6
             Work Assignment 15
           Contract No. 68-02-2817

-------
                   TABLE OF  CONTENTS

                                         Page

1.0    Introduction                       1

2.0    Discussion of Results              2

3.0    Observation Locations and          8
       Emission Points

4.0    Observation Procedures            11



APPENDICES

A.     Project Participants

B.     Field Data Sheets

       B-l.     Visible Emissions

       B-2.     Fugitive Dust

-------
                    LIST OF FIGURES
Figure                                       Page

 3.1      Plan view of electric arc furnaces   9
          and observation points

 3.2      Isometric view of electric arc      10
          furnace

-------
                   LIST OF TABLES




Table                                        Page




  2.1     Summary of Tapping Results            4




  2.2     Summary of Reladling Results          5

-------
                  1.0  INTRODUCTION




     The U.S. Environmental Protection Agency  (EPA)




retained Clayton Environmental Consultants, Inc.




to conduct both visible and fugitive emissions




observations at Armco Steel in Torrance, California.




Procedures similar to those outlined in EPA Methods




9 and 22 were incorporated to evaluate fugitive




emissions from two (10 and 25 ton) electric arc




furnaces  (EAF) on May 30 and 31, 1979.




     To evaluate methods of determining visible




emissions escaping from the EAF control systems,




visible emission data were collected by observers




located inside the building housing these units.




This study was commissioned as Project No. 79-ELC-6,




Contract No. 68-02-2817, Work Assignment 15.

-------
           2.0  DISCUSSION OF RESULTS




GENERAL OBSERVATIONS




     Light-type was both natural  (sky lights and exit




openings) and artificial (hanging lamps at ceiling level




and on the overhead crane).   At the respective observa-




tion points, light meter readings did not exceed 10 foot




candles, even when the light meter was pointed directly




at the source during tapping.  During Tap 4  (May 31) a




light reading of 30-50 footcandles was taken approximately




5 feet from the. furnace, but overall surrounding light




levels were low and plume contrast hard to notice.




     The greatest difficulty encountered in observing




emissions at the EAF units was the very bright light




created by the molten metal during pouring.  This




made emission reading extremely difficult, in that the




back-lighting made the emissions appear denser.  Both




opacity and fugitive observations on May 30 at the 10




and 25-ton furnaces were read 1-2 feet above the spout.




The remaining observations on May 31 were obtained about




6 feet above the launder to reduce light interference




from the metal.  The bright light, however, remained




an interfering factor, since it reflected off the




furnace and generally illuminated the entire pit area.




     Emissions appeared minimal except at the onset of




tapping.   As the melt hit the ladle, a dense cloud would




rise to the roof.   The plume  then dissipated about
                           -  2  -

-------
2-4 feet above the pit/pouring spout.  Sometimes the




smoke hung in the air at this point before dissipating.




This could have biased subsequent readings, as more




emissions were being added to the suspended cloud




throughout the tapping operation.




     Quite a lot of air turbulence was noted near the




spout area.  This could be a result of heat (convective




rise) from the molten metal; dust collector draft;




and, depending on wind direction, a draft from a main




throughway located just west of the 25-ton furnace pit.




     Consideration could be given to taking future




emission readings at a higher level (15-20 feet), where




a more even dispersion of smoke occurs and air turbulence




is lower, although suspended particles could still be a




problem at that level.




Fugitive/Opacity Data




     Tables 2.1 and 2.2 summarize the tapping and re-




ladling results, respectively, for both furnaces.  The




lowest and highest opacity readings and the overall average




for each tap, are presented for each observer.  Fugitive




emission readings are summarized as specified by




Method 22.





     A  total of  seven taps were  observed,  three  on the




 10-ton  furnace  and  four on the 25-ton  furnace.   The




 furnaces were  tapped  approximately  every  4  1/2   and 6  1/2




 hours,  respectively.  Pouring  lasted  only  2 1/2  minutes
                          - 3 -

-------
                                 TABLE 2.1.  SUMMARY OF TAPPING RESULTS8

Furnace
Number
10 ton
10 ton
10 ton
25 ton
25 ton
25 ton
25 ton

Date
5/30/79
5/31/79
5/31/79
5/30/79
5/30/79
5/31/79
5/31/79
Time

Start Finish
1037 1039:49
0926 0928:25
1404 1406:21
0750 0754:45
1319 1323:48
0805 0810:41
1255 1259:51
Method 22 Results (Percent)


Observer
(T. Harrison)
Accum .
Obser . ,
m i n : sec
3:06
2:27
2: 26
4:54
4:27
5:36
4:07
Accum .
Emis s ion}
min : sec
3:03
0:37
0:44
4:45
3:09
5:31
4:05


Observer
(W. Maxwell)
Accum .
Ob ser . )
min : sec
2:55
2:29
2: 19
4:31
4:43
5:40
4:11
Accum .
Emi s s ion
min : sec
1:10
0:24
0:42
4:26
3:38
5:35
4:07
Inside Opacity Results (Percent)


Observer
(D. Lazarevic)
Low High
40 70
0 20
0 20
10 >70
0 40
5 70
10 75
Avg.
55
6
7
—
20
42
42



Observe r
(D. Schick)
Low
30
0
0
20
0
0
0
High
55
40
30
80
40
50
75
Avg.
47
11
14
48
28
35
46
tapping  is  defined  as  the  period  of time from start of metal flow to end of metal  flow.

-------
                                 TABLE 2.2.  SUMMARY OF RELADLING  RESULTS
Furna ce
Number
10 ton
10 ton
10 ton
25 ton
25 ton
25 ton
Date
5/30/79
5/31/79
5/31/79
5/30/79
5/31/79
5/31/79
Time
Start Finish
1005 1006
0858 0859:19
1334 1335:47
1243 1246:41
0727 0730:22
1230 1232:42
Method 22 Results (Percent)
Observer
(T. Harrison)
Accum .
Obser .,
min: sec
1:05
b
1:49
3 :41
3:24
2:43
Accum .
Emis s ion.
min : sec
0:59
b
0:42
2:56
3 :20
2 :37
Observer
(W. Maxwell)
Accum .
Obser . 5
min : sec
1 :08
1:25
1 :45
3 :38
3:24
2:40
Accum .
Emiss ion
min : sec
1:08
1 :25
0:33
3 :08
3 :19
2:36
Inside Opacity Results (Percent)
Observer
(D. Lazarevic)
Low
35
30
0
0
20
0
High
40
75
10
65
80
75
Avg.
"38
64
4
36
59
52
Ob se rve r
(D. Schick)
Low High Avg.
50 80 65
0 90 57
0 30 15
0 60 38
30 70 48
0 70 56
aReladling is defined  as  the  period  from start of metal flow to end of metal  flow.
b.
 Photographs were being  taken  at  this  time.

-------
 for the 10-ton and 4 to 5 minutes for the 25-ton furnace.




 Due to the short duration of this operation, the




 average of only 12 readings was  calculated on the




 10-ton furnace and 20 readings on the 25-ton furnace.




     A total of six reladles were observed, three




 at  each furnace.  Reladling lasted a little over 1-




 minute for the 10-ton and about 3-minutes for the




 25-ton furnace.




     Consideration was given to taking additional




readings at night, but poor lighting would have biased




the  results.





     Opacity readings taken during  tapping  on  the




 first  day  for  both  furnaces showed  a maximum




 variance  of about 8-percent opacity  between the  two




 observers.,  Differences on the second  day for



 the  10-ton  furnace  were  5  and  7-percent  opacity,




 and 7  and 4-percent  opacity for  the  25-ton  furnace.




     Opacities  taken  on  the first  day during reladling




 showed a  variance between  two  observers  of  27  and  2-




 percent opacity  for  the  10 and  25-ton  furnaces,  respec-




 tively.   On the  second  day, differences  were  7  and  11-




 percent opacity  for  the  10-ton  furnace and  11  and  4-




 percent opacity  for  the  25-ton  furnace.




     During  tapping,  Method 22  also pr-oduced  the  greatest




 variance  between two observers  on the  first day  with an




 accumulated emission difference  of 1-minute and  53-
                        _ 6  -

-------
seconds on the 10-ton and 19 and 29-seconds on the 25-




ton furnace.  The differences ranged from 2 to 13-




seconds on the second day of observations.




     The accumulated emission difference, during




reladling for both days of the study was 9-seconds




on the 10-ton furnace.  On the 25-ton furnace, the




difference for the first day was 12-seconds and 1-




second for the second day.




Summary




     Considering all the difficulties encountered in




reading opacities at the EAF units (back-lighting




from the molten metal, plume suspension, etc),




Method 22 appears to be the better of the two methods




for evaluating this particular process.  Further




consideration should be given to obtaining a larger




data base in order to allow for meaningful statistical




comparison of individual readings and evaluation of any




significant differences between methods.

-------
  3.0  OBSERVATION LOCATIONS AND EMISSION POINTS






      Figure 3.1 presents a plan view of the electric




arc furnaces, along with respective observation points.




Figure 3.2 presents an isometric view of the EAF




units showing the location of emission points observed.




      Observation point A was a six foot high platform




located approximately 30-feet west of the 25-ton




furnace pit.  The platform is used as an access point




for assembling and repairing electrodes.  The remaining




observations for this furnace were made at point B




(ground level), approximately 10 feet south of the pit.




      All observations of the lO-to^n furnace were made




from point C.  This ground level location was about




15 feet south of the furnace.




      Since the observers had to contend with three




overhead cranes, the pouring ladle, spraying molten




metal, etc.,safety was an important and limiting factor




in determining observation locations.  Observation points



B and C not only permitted optimum viewing of the




tapping operation, but were also the safest observing




po sit ions.




      Opacities were read only during tapping, although




emissions were also noted emanating from the top of the




furnace during oxygen lancing and charging.
                          -  8  -

-------
i
vo
I

Baghouse.

.•IT
V __.J
1 .£,., _ . ....


K— •



Mold
pouring Overhead
area crane


\^




^l
~\
d

A
\ i
i .
\
\
i

.



7 '

r^r















^



IN



Scrap


yard
\
1 ' ' ^
_t — „ — _ 	






n
Enc lo sed
pit





-_^— •
*ar^
-^
	 — — — — — —
Exhaus t
"" hoods ^ ^^.

5 A /To\_
| ton 1 i ton L_
x^

v /
^ Launders



c »
Enclo sed
pit



B


C

— — . *•. — .







1

1
k
\
1 v
\
x'x.




\ Overhead
\ 1
crane
\
x i
^


^
' Overhead

c
crane
b • •••=
1 	

Mold making area









-\
= >>
\
              Figure  3.1.   Plan view of electric arc furnaces  and  observation points
                           (not to scale).

-------
                                Electrodes
 Furnace
Exhaust
 hood
Observed
emis sion
  point
    Pit
                        Ladle
      Figure 3.2.  Isometric  view  of  electric  arc  furnace
                   (not  to  scale).
                               - 10 -

-------
            4.0  OBSERVATION PROCEDURES




      Visible emission observations were performed in




accordance with EPA Method 22, Visual Determination of




Fugitive Emissions from Material Processing Sources,




and a varied form of EPA Method 9, Visual Determination




of the Opacity of Emissions from Stationary Sources.




Messrs. Terry Harrison of EPA and William Maxwell of




MRI employed Method 22, while Mses. Donna L. Schick




and Dusanka Lazarevic of Clayton Environmental Consul-




tants, Inc. observed using Method 9.  This allowed for




comparison of individual readings and evaluation of




differences between the two methods.




      Observations were conducted during the reladling




and tapping cycle  with respective results reported




herein.




      Opacity readings were documented by certified




visible emissions observers simultaneously with the




fugitive emission readings.  Due to overcast skies, no




outside readings were taken.




      Opacities were read according to width gradients




across the pit (0-1/2 ft, 1/2-1 ft, 1-2 ft, 2-4 ft,




4-8 ft, 8-12 ft) and by depth as presented in Figure 4.2,




The readings were usually averaged over the width




gradient since certain sections of the emission cloud




were denser than others, especially the area directly




above the spout.








                          -  11  -

-------
     APPENDIX  A




PROJECT PARTICIPANTS

-------
            PROJECT PARTICIPANTS
Clayton Environmental Consultants,  Inc.

Donna L. Schick       Environmental Data
                      Specialist

Dusanka Lazarevic     Environmental Data
                      Specialist
Midwest Research Institute

William Maxwell


U.S. Environmental Protection Agency

Terry Harrison

-------
       APPENDIX B




   FIELD DATA  SHEETS




B-l.   Visible  Emissions




B-2.   Fugitive Dust

-------
B-l.  Visible Emissions

-------

-------
         iy₯*
                             o-fc
                                     LUMlkggy

) I 
-------
                                                                    •f-
Q
                     /)
                                            .  Otierv;«r- _
±£M.
              Jo.
     v^w-

•k'.bK-\ Type
                                                T
                                                                      iode
                                                           — -<«kVN
-------

-------
J  ) 0^-«-
  JX
C-

-------

-------

-------
 n
 3o
 J/S
-3
 3"
 u.s
 V
  y
b
1  -
^vjpccv.'t i
Ob£erv«V  -
                                                                                   ^N
                                                                                   JJ
                         -
                     / -  *• •?' ••
                   Type
                                     ^ /&OVU-6L.
                                     ,f

                                                                              >
                                                                                      •   5D
                                                                                         4'0
                                                                                45
                                                                                        CD
                                                                                                    i,-
                                                                                                    /b c»r

-------
~~
                             tr
tT   «
 Type  ^
                                                 - •t^ww™«T"~\ec**''Vt<*v\. ~ '*•'
           -ty
  i .....
                                                    0

. v. I ~ V .



„.. -..
"" - -1 •— — *

. .._ ,_--. -,„*.. .
"^?.
.,..#_,..
i£i
— i — *
' D > '-

' /P .
' U • •
'60




'••••- 	 -••

.
ft -U
"".i.w. _.T?


	











-

— 	 -..

-

• • - • - 	


ir^
/O CfT tnof«. ,
dirtt^ti w
s iQ. ("A If 1 v^^
/vev^t ~~ ,^^^^^
r^^; (
A"1" , J^da"1
.,'-*>, ^ 1 /) • / ,
0J)AO-^ ^ JU=»
n ^-' .51 i
fl .. . / /_. K 0 .
KJ/A-^ U J^1
^V^1"*
t^v "'
•
u*<^
^ n s \ ^ l\
1 4^r\
kc«^ ^f'.
) ( • ff/ Jx<9.d1
] l a- NT
^ tr
A// ^ L^1^
^ i 0 - -
h
AAU-V^-
uyu***?^
^IC^
-rv\A-^
. . .TJti-^
-rir^^° A
IIH- j Jn, — .
0 AU^^ ,
J^ ^
HN H^^

-------

-------

-------

-------
                                                              "*«-
I » r>-\ _

 Jx
O
\r*
V.
                                                                        Ov\    CC.C-V J

                                                      •c)o's«-Tv' €r—\OCAJ^; i ovvr^T^K^^i" ~ ^ o-crc*
                       -  \
0
                                                       40. rt
                                                                       lo
                                                        /G <5
                                                                    A^W-

-------

-------
GjOYrvGeo^y
                C 0
        £/ld4'^
                           t
    Type  _
4; 46
                            2&r
                                            JO
                                                          ic
                                           OUWv-?   V^_i_V?.ll
                                           r_	 •   T
                                                      5^
                                                       60
                                                       60
                                                       (00
                                                       SO
                                                       60
                                                       •6D
                                                               /G


-------
o
30
y

-------
a
J/S
3"

^
-------
j I 
-------
        c
  0-
 a
16
3*0
5

-------
o
)*>•
y

                                                    .13 do  . 6>
                                        (00
                                         lo
                                         60
70
                                                       /
                                                       /b or

-------
   T
   - >-
 >#.
50
'60
35
At>.
 6
 5
      IffO.
      lao
                 /
                 /b
                 4:47

-------
B-2.   Fugitive Dust

-------
                                   INSPECTION
Company
                                         Inspector
                         i r r
Location
Company Rep. _

Facility Type
        Affiliation     U .5 . £ P

        Date 	J
$\yf .
                                         Emission Sonrr «.
                                Jy vs CXC
                                                                o
Sky Conditions

Precipitation .
         Wind

         Wind  Speed
Sketch emission  source,  indicate  observer position relative to source;
indicate potential  emission  points;  and/or actual emission points.
                                 OBSERVATIONS^.)^
Clock
Time
jo'.os'




&*>
f —i y ' r '''.•'/
- vwi cxt VwrW x/oJ^vP ^s «.i fc^i,' ^l>^'1^*?
\ - pOiAY^

Uslk. U J v


-------
                                FUGITIVE EMISSION
                          -T  i  ,    INSPECTION
                          -I-'\ck>OT-
Company
                               Inspector
Location
    \ O y v-
        *_,
Company Rep,
                   Affiliation

                   Date
                                                         l).S.  £  (PA
Facility Type £  y-SDs
                               Emission Source
Sky Conditions

Precipitation .
               \
           V
Wind Direction

Wind Speed	
Sketch emission  source,  indicate observer position relative  to  source;
indicate potential  emission points; and/or actual emission points.
      (
                                 OBSERVATIONS
Clock
 Time
Ac cumul ated
Observation
   Period
  (min : sec)
Accumulated
  Emission
    Time
  (min : sec)
                                                     Comments
                                                                            vVV
                                                                          (^"W • )\ ^ f
                                                            \Kc\b
                                            Bii!

-------
                                   INSPECTION
Company
Inspector _
Location
             0  4r>A
Company Rep,
Affiliation

Date
                     '
Facility Type
Emission Source
                    f-
Sky Conditions

Precipitation .
                  • y\Sj I o*-*
Wind Direction   A/A

Wind Speed	
Sketch emission  source,  indicate observer position relative  to  source;
indicate potential  emission points; and/or actual emission points.
                                 OBSERVATIONS
Clock
Time
/Oo5~


j»r






I
i

I
!

t

Accumul a ted
• Observation
Period
(rain: sec)
/•' oS>


<2 • 35~












Accumulated
Eiais sion
Time
(min : sec )
/10&


I'-IO


-••









Comments
5 10#f&- /'3'<-a d>d si0/^^ 5x?^^T ^ rerz-t^ioc,'^, • /? J Cx^.^-b
1 f f 9 — ' 1 J- 1
K<2.&J """ //** 'sPc>^
/ «












-------
                                   INSPECTION
Company
                 — T
                          C&-
Location
Company Rep.
Facility Type
                      rv-^.fc .r
                                         Inspector
                                         Affiliation

                                         Date
                                         Emission Source
                                                           I «"~>
Sky Conditions

Precipitation .
                                         Wind Direction

                                         Wind Speed
Sketch emission  source,  indicate  observer position relative to source;
indicate potential  emission  points;  and/or actual emission points


I
r~=r^^ ;i
^^j

OBSERVATIONS ,.
Clock
Time
0=1.70

0-30

/3sr

flo*?



\

\



Accumulated
Observation
Period
(min: sec)
I". 2. 6

•2:Zcl

/=4£

P-'-l*)









Accumulated
Emission
Time
(min : sec)
(-ZZ

0:2 1_

^-33

0 •- X| 7_









Comments
IZaLJL - ^^c,^-lwffc.J
I
C*^JU>UeJ

Re(ftJ ^












-------
FUGITIVE EMISSION
.,    INSPECTION
c
I
c
I
l\ "T*^ . if
ompnn" VV v^xC O Inspector K . V\ N Oum s- v\~.
,o cat ion
)ompany B
'acility
i
Sky Ctsnd^
/\
Pre^xCpit^
c
~~~\ r^^f^> f A•F-f^^^1^-lnn f\C /^ tPfl
\ (^,*<" *<~ ^\. \T\ ^ 'P V °*-- V..X t AIIillclLlUH L / i N * L> »J^(
V
pp. Date S/-3u/-Jc\
Type TOu^-^cvrv . Emission Source t/ec"ii-«c ^^^ ^~.w.v~v\o<--^
/ " C~
tir,nc Wind Direction
Unn . Wind Speed

Sketch emission source, indicate observer position relative to source;
indicate potential emission points; and/or actual emission points.
X-
xla'
!\
^^^ /onjurrj^
1i~CX
/.J-'".. , ^
S^5^i^,, ' 'r5'7
. OBSERVATIONS,-.. . , . -^ ^r^K ^ $3 ^ *."
Clock
. Time .
tl&Q ^




••• *i.

7TMS^^






' *** \ *^ * ^1 C }


-


Ac cumu lated
Ob servation
Period
(inin: sec)
3\ S-N
	 	 	 .


3'.4\






Hf.P"?




Accumulated
Emission
Time
(rain : sec)
I'-V^
	 	 —


3; 5^C

-




3^ o«\




Comments
Siu??e^ vo^eK^ -W** «^-j^ .r^rf^^p-lTN^Q^
^O^t ^P(pr-«<. 1 V>0 ^ . ^
ne<4 eA «V <^ Uo ^k
'
X
v OX^VA** c/ — ( Vi\Now\4 ^'JO °^-^ ^"CJO\_M\I"^ r^ "T AJ^W>^^ \/ \
C" \ / L. f\.
^Z^'muiv-fr-x -0 JO B5 /f^vf^ji.^^.'*- ^
•"•V-X^O -o^Ly^. 0^«J) ^ ^u/.*? XnO
^b *3o1-^-A^

5\Xft ^v^.oViStr^Vx^.- «.«K\U\ \*\l AW
"Ko w<3r~ooevT7" aev^ UL rWfh'c^p
at vwi.



-------
                                  FUGITIVE EMISSION
                                  ,. INSPECTION
                                 O«Jv^
 Company
                                           Inspector
                                                                 H
 Location
 Company  Rep.
                   Affiliation

                   Date
                                                             ^. c;
                                                        xm
 Clock
  Time
          Accumul ated
          Observation
             Period
            (niin: sec )
Accumulated
  Emis sion
    Time
  (min : sec )
                                                        Comments
                                                      C) c~
                                                      **•?
-+
 ICTVN
 TA

                                                ^M^L
> Sb'.Q ',"
                                     Jl£
                                                 -2£-
                                                                      tT^S-W..
                                         } s-~O
                                                   ^T
                                                                                    J_i

-------
INSPECTION
c
I
c
I
c\ mn i n V - . f" ^ ' *
^ocation
Company F
"acility
>
Sky Condi
Precipi ta
c
S«5
en.
Type

t io ns
t ion

7 ~~ ^o^-C»AVCC Inspector /l/'\/^XuJ£d.t_
\ o r*- VT-^-OV^ c € Affiliation / / ( 1 1> uj £-5 T \^&3 G-AVZ^ ^/
Date So /AA'*\x' "l^
crXi/" - A~0cx/-vc.lr'l-j- Emission Sonrpp 1 A-f*
1 • ..
"X^Dc.^ p.'S Wind Direction M\
/V/^j Wind Speed /V4

sketch emission source, indicate observer position relative to source;
indicate potential emission points; and/or actual emission points.
&
j
©L
J) 1 0?
£> i x •
1
ps



. OBSERVATIONS :
Clock
Time
OT^o

/2'15

I32o












Ac cumul ate.d
Observation
Period
(rain : sec)
x? : -$i

3 - .3^

>f:>/3











Accumulated
Emission,
Time
(min : sec)
^Z^

3-'c>&

J]3y










V.
Comments


fad ~2-*~. &.^*u^ U^le ^o^v"^ re-k~*ci~
y
A-f(/»^ i 1 ^ / Vs / c( *IX- 14- -t«












-------
                               FUGITIVE  EMISSION
                                   INSPECTION
Company
                 - T
Location
Company Rep,
Facility Type
                   o rc.g
Inspector
                                         Affiliation
                                         Date
Emission Source
Sky Conditions

Precipitation
Wind Direction   /V4

Wind Speed	
Sketch emission source,  indicate  observer position relative to source;
indicate potential emission  points;  and/or actual emission points.

O

. 	 /

(
OBSERVATIONS
Clock
Time
Oll^S

OZlo

/£32

(Z5~5~









Ac cumulated
Ob servat ion
Period
(rnin: sec)
J •'£-*(

S^ff

2-^j>

^-l|









Accumulated
Emis s ion
Time
(min : sec )
-3- I6*

5"1- 3 .-T"

<2'2(s

^l-cl









Comments
&./«d/;^ • *,t(^ L^ UK-c
t /


foLJ/*












-------