From Boucher Michael

Sent Tuesday May 19 2009 723 PM GMT

To rnccabe.catherineepa.gov

Cc Boucher Michael rnboucherrnckennalong.corn Edens Geri

gedensrnckennalong corn Bill Pitcher wcpitcher@buckrnan corn

Subject Unregistered arnrnonia for water treatrnent

Attach Buckrnan Laboratories Inc .pdf

Dear Ms McCabe

On behalf of our client and the sole U.S ammonia registrant Buckman Laboratories Inc the

attached submission respectfully requests that the U.S Environmental Protection Agency exercise its

non-discretionary duty under sections and 12a1A of the Federal Insecticide Fungicide and

Rodenticide Act FIFRA to require that all products containing ammonia and distributed or sold

for use in connection with chlorine to treat water be registered as pesticide products under FIFRA

We look forward to your reply and invite any questions that you may have about the attached

submission We will send confirmation copy of the submission to you by UPS Next Day Air

Sincerely

Michael Boucher

Geraldine Edens

Outside counsel to Buckinan Laboratories Inc

Michael Boucher Partner

McKenna Long Aldridge LLP

1900 Street NW Washington DC 20006

Tel 202.496.7729 Fax 202.496.7756 mboucher@mckennalonci.com
McKenna Long Albany A1dride New York

Atlanta

AItneys Lw Philadelphia

Brussels San Diego

1900 Street NW Washington DC 20006

Denver Tel 202.496.7500 Fax 202.4967756 San Francisco

Los Angeles

www mckennalong.com Washington DC

MICHAEL BOUCHER EMAIL ADDRESS

202 496-7729 mbouchermckennaIong.com

GERALDINE EDENS gedensmckennalong.com

202 496-7371

May 19 2009

ELEcrRoNIc MAIL

Catherine McCabe Acting Assistant Administrator

Office of Enforcement and Compliance Assurance 2201A

U.S Environmental Protection Agency

Ariel Rios Building South Room 3204

1200 Pennsylvania Avenue NW

Washington D.C 20460

Re Registration of Ammonia for Water Treatment

Dear Ms McCabe

On behalf of our client and the sole U.S ammonia registrant Buckman

Laboratories Inc Buckman we respectfully request that the U.S Environmental

Protection Agency EPA or the Agency exercise its non-discretionary duty under

sections and 12a1A of the Federal Insecticide Fungicide and Rodenticide Act

FIFRAl to require that all products containing ammonia and distributed or sold for

use in connection with chlorine to treat water be registered as pesticide products under

FIFRA We also request that EPA take the foregoing action within thirty 30 calendar

days from today i.e by Thursday June 18 2009 The rationale for our request is as

follows

On March 2007 EPAs Office of Pesticide Programs OPP registered

ammonia2 as pesticide under FIFRA Specifically the Agency issued two pesticide

product registrations for ammonia to our client Buckman one for Busan 1215 EPA

Reg 1448-433 and another for BCMW EPA Reg No 1448-432 Busan 1215 contains

U.S.C 136a 136ja1A

2EPA Pesticide Chemical PCcode 5302 Chemical Abstracts Service Registry Number 766441-7

DC50622410.4
Catherine McCabe Acting Assistant Administrator

May 19 2009

Page

ammonia as the active ingredient and is registered by EPA for use in connection with

chlorine to treat water BCMW also contains ammonia as the active ingredient but is

registered by the Agency for different use namely to manufacture pesticide products

that are used in connection with chlorine to treat water.3 Copies of Buckmans

ammonia registrations are attached hereto as Attachments and respectively

By registering Busan 1215 and BCMW EPA has established that ammonia used

in connection with chlorine to treat water is pesticide Accordingly ammonia used in

connection with chlorine to treat water must be registered under FIFRA or its

distribution and sale are prohibited by FIFRA 12a1A Yet unregistered ammonia

products remain on the market for use in connection with chlorine to treat water

including Nalcon 60620 which is produced sold and distributed by Nalco Company

Nalco Under FIFRA EPA does not have the discretion to authorize the continued

distribution and sale of such unregistered ammonia

In short by registering Buckmans ammonia products EPA has established that

ammonia used in connection with chlorine to treat water is pesticide As

consequence the Agency has non-discretionary duty under FIFRA and

12a1A to require the registration of all ammonia that is distributed or sold for use

in connection with chlorine to treat water In addition EPA cannot lawfully authorize

Nalco or anyone else to distribute or sell ammonia for use in connection with chlorine

for water treatment without FIFRA registration irrespective of the claims that Nalco

makes for its unregistered ammonia

For the foregoing reasons Buckman respectfully requests EPA to require that all

products containing ammonia and distributed or sold for use in connection with

chlorine to treat water be registered as pesticide products under FIFRA Buckman also

requests that the Agency take such action within thirty 30 days of today i.e by

Thursday June 18 2009 If EPA is unwilling perform its non-discretionary duty under

FIFRA Buckman will have little choice but to seek declaratory and injunctive relief in

the appropriate judicial forum

3At present Busan 1215 is the only pesticide product registered with EPA for use in connection with

chlorine to treat water

DC50622410.4
Catherine McCabe Acting Assistant Administrator

May 19 2009

Page

We look forward to your reply and invite any questions that you may have about

this letter

Very truly yours

Michael Boucher

Geraldine Edens

Outside counsel to Buckman Laboratories Inc

/mb

Attachments 11 pp

Attachment EPA Reg No 1448433 as amended Busan 1215

Attachment EPA Reg No 1448-432 BCMW

cc William Pitcher Esq Vice President General Counsel Corporate Secretary

Buckman Laboratories International Inc

DC506224104
ATTACHMENT
U.S ENVIRONMENTAL PROTECTION

AGENCY

Office of Pesticide Programs

Antimicrobials Division 75101

1200 Pennsylvania Avenue NW

Washington D.C 20460

NOTICE OF PESTICIDE

Registration

Reregistration

under FIFRA as amended

Name and Address of Registrant Include ZIP Code

Buckman Laboratories Inc

1256 McLean BIv

Memphis TN 38108

Note Changes in labeling differing In substance from that accepted In connect Ion with this registratIon must be submitted to and accepted by the

Registration Division ptior to use of the label in commerce In any correspondence on thIs product always rater to the above EPA registration number

On the basis of information furnahed by the registrant the above named pesticide is hereby registered/reregistered under the Federal tnsectlclde

Fungicide and Rodenticide Act

Registratton is in no way to be construed as an endorsement or recommendatIon of this product by the Agency in order to protect health and the

environment the Administrator on his motion may at any time suspend or cancel the registration of pesticide in accordance with the Act The

acceptance of any name in conneGtion with the registration of product under this Act Is not to be construed as giving the registrant rght to exclusive use

of the name or to its use fit has been covered by others

This product is conditionally registered in accordance with FIFRA sec 3c7C

provided that you

Submit and/or cite all data required for registration of your product under FIFRA

sec 3c5 when the Agency requires all registrants of similarproducts to submit such

data and submit acceptable responses required for re-registration of your product under

Fl FRA section

Make the labeling changes listed below before you release the product for

shipment

Revise the EPA Registration Number to read EPA Reg No 1448-433

Si natu of Approving Ott ctai Date

Vhiiv

Product Manager Team-31

Regulatory Management Branch

Antimicrobials Division 751 OP

EPA Rag Date of Issuance

Number

1448-

Term of issuance

Conditional

Name of Pesticide Product

BUSAN 1215

EPA Form 8570-6
Submit three copies of your final printed labeling before distributing or selling

the product bearing the revised labeling

If these conditions are not complied with the registration will be subject to

cancellation in accordance with FIFRA sec 6e Your release for shipment of the

product constitutes acceptance of these conditions

stamped copy of the label is enclosed for your records

Sincerely

Velma Noble

Product Manager 31

Regulatory Branch

Antimicrobials Division 751 OP

Enclosure
DIrections Sortie

BUSAN 1215

pULP AND PAPER faLLS SUSAN 1215 can be used as mloroblocide In the manufsiiure ofpa 5U$.Nisi tmdVni ntostiod .-

1je and paperboard that contas food

ed5emu olpapmdpoeepestaus AclwrlsaasoemTst

II Ifl

Eyes

Hold mye nd aeollyvdthetfrt tS.20 syaggs

onox iosss tresmnt mSertIs kitS fliz escstisiiiIis CaS pn onital center or stOor fort therte ner adakz

This woduct Is applied In Conjunction with sorilum htpobltiorlte 12.5% at to form man thb me

slower soling less aggressive oxidizIng microblodcle The products are added to rrnution water

achieve minimum molar ratio of 1.51.0 product to 1.0 of ammonia to oxidant and this ratio

obtained by combining 0.6 lIvid ounces of SUSAN 1215 to shad ounce ci sodium hypochlorite 12

at To ensure both handling safety and effectiveness the moiioctttoramine solution must 

generated and fed Into the treatment water systelne through proper chemical teed skid only by

trained Buckanan represestatiuL Use of this product for any other purposes or contrary to the u

.4fr4I i.wtfll halw ie wthlHo4

Dosage Rates When noticeably foted apply uEticlard product and sodium hypothlodle to achieve

total chlorle residual of at least tppm in excess of the system oxidant demand Once control

achieved treatment rates can be reduced to sub-demand rates from 60% to 80% of system deman

The product may be added to the system continuously or Intermittently as needed to any area of t

system where uttitorm mixing can be obtained

For IntermIttent treatment mIx 0.8 fluId ounces of SUSAN t215 to fluId ounce of sodIu

hypochiodie 12.5% at. Apply solution at rate to obtain to2 ppm In excess of the system oxidan

demand roaxantan of ppm measured as total chlorine In the process water or stock being treate

for to 80 minutes every Ito hours The frequency of feeding and the duration of treatment w

depend on the seventy of the problem Badly fouled systems should be cleaned before initi

traatmenL

For continuous treatment mIx 0.8 fluId ounces of SUSAN 1215 tel that ounc of sodium hypodhtiodl

12.5% a.l. Apply solution at rate to obtain at least ppm In excess of system oxidant deman

maximum of ppm measured as total chlorine In the process water or stock being treated on

continuous basis The frequency of feedIng and the duration of treatment will depend on the severity

oftheproblem Sadly fouled systems should be cleaned before Initial treatment

Precautionary Statements

HAZARDS TO HUMANS AND DOMESTIC ANIMALS cAtmosu Hsm1t Ceratwad Avcit trea5 vapor Avoid oveavsh ale ees ordhfr be nealIzd by the addition of sodium mats blulflts Wean thamrdywh iO kid iititati kid bt 5olt5 St

until the loramine is no to detected

EO5$S5flAL HAZAF Do no cremate elnt cootitmieg this arodwa Into liS itrsare ponta eitzealss gcow ordtat urdess In sonwirem van 5i uIqervar ala

NadonŒl Pchaard Dochios deMtan Stelam PSpetite kit Srpit eutnesily lee

been tte.d ur vdIes pmrw daj Qanal g.dtm sysuene idthaul prevla%r$fr noWdn the local sanapa tesaunent plant ashority For oidenoo cataO yor Sisis Water Bond or Reglonat OBoe othe

KEEP OUT OF REACH OF CHILDREN

CAU11ON

FIRST AID

on

It

Ott mtsnxcad dathe

sea em kmw to Is

ptetity at wait tar 1$20names

cetaw ordathom kr llsamwrd

Calpclm control ceRerordcowInvnemem beattte stoles

Ilevs person sip plies Obtest etoswaost

uses petson to ieh

a1 San ples etSidsi aeptatmi

___________ IIi usee tIs

Hav the product Container or label with you when ceilings Poison Control

Center or doctor or going for treatment You may also contact 901-278-0330

or t-SOOSUCKM toemeroençymeeiinformaao

VI EMrI4gData4

MAH -6 2007

Jfldertienlbrj.sel

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5floRadefldcda as aznepd OGdhdi DIlStjOjde

qlaternd wtde EPAReg Nit /4 44/3J
7/15/X

Lj Lf.3 133 1ED TATS EHYIRONMENTAL PROT lON AGENCY

JUt152O

Mr Carl Watson PhD

Sr Regulatory Toxicologist

Buckman Laboratories Inc

1256 McLean Blv

Memphis TN 38108

Subject Busan 1215

EPA Registration Number 144843

Application Dated June 2007

Received Date June 11 2007

Dear Mr Watson

The f000wing label revisions submitted in connection with registration under the Federal

Insecticide Fungicide and Rodenticide Act FIFRA as amended is acceptable

Proposed Labeling

New Use Industrial water systems

General Comment

Should you have any questions concerning this letter please contact DrusiQa

Copetand at 703 308-6224 or Velma Nobe 70 308-6233

Sincerely

Velma Nobel

Product Manager 31

Regulatory Management Branch

Antimicrobials Division 751 OP

Qrrut4 kI

cOKCrnuw.fl

5fl$OL nn send 5S fldStOdeflSflQSS 55sefladss g3SBeflSGflS SflSSflS 4.flflSSSS 3HM tddtdflCflflh$fl SSSSee.SsfleOSSS S56S eflSflSSSd3 ..S4.SSQfld IE

EPA Fn 14A PdR.qthdhpr F$C$M VILE COPY
\l

KEEP OUT OF REACH OF CHLDREN

CAUTION

If In Hold eye open and rinse slowly and garithj with water for 18-20 mInutes

Eyes Remove contact lenses if

present after the firstS minutes then continue rinsing eyc

CelIa noon rolcenteror brsrfurther treatment advice

If on

Skin

Clothes

Tate oft contaminated clothing

Rinse skin hnmedlatety with plenty of wster for 15-20 minutes

CelIa poison control center ordoctorfor treatment advice

If

Swallowed

Cat poison control center or doctor Immediately for treatment advice

Have person sips glass of water if able to swallow

Do not induce vomiting unless told todo so by the poison control center or doctor

by mouth to an uonaciouspetsce

Precauftonary Statements

HAZARDS TO HUMANS AND DOMESTIC ANIMALS

CAW1OIt Harmful if swallowed Avoid breathing vapor Avoid contact wIth aldn eyes or clothing

Wear protective eye-wear goggles lace shield or safety glasses Impervious ctremlcal-seaistard

gloves and full body clothing long sleeved shin and long pants socks and shoes alien handling

Wash thoroughly with soap and water after handling and batons eating drInking chewIng gum or

usindooc

ENVIRONMENTAl NAZNWS Do not discharge effluent containing this product into lakes

streams ponds estuaries oceans or other waters unless in accordance with tea requirements of

National Pollutant Discharge Etimmabon System NPDES perest and the permitting authority has

been notified meriting prior to discharge Do not discharge effluent containing this product to sewer

aystems without previously notifying the local sewage treatment plant authority For guidance

contact ysur State Water Board or Regional Office of the EPk

For intenrilttent treatment mix 0.8 fluid ounces of SUSAN 1215 to 1.0 fluid ounce of sodium hypoctilorite less then or equal to

18.0% at/wi Apply the solution eta rate to obtaIn 102p in excess of tIre system oxidant demand maximum of ppm

measured as total chlorine In the water being treated for to 80 minutes every toe hours The frequency of feeding and the

duration of lrealmerd will depend on the severityof the problem Badly fouled systems should be cleaned before initlel treatment

For continuous treatment mIx 0.8 fluid ounces of SUSAN 1215 to 1.0 fluId ounce of sodium hypochlorite less than or equal to

15.0% wI/WI Apply the solution ala rate to obtain OSlo ppm in access of system oxidant demand maximum of ppm

measured as Inlet chinririe In the water being treated one continuous basis The frequency of feeding and the duration of

treatment alt dipend on the sevedtyoftheptcbtem Badly fouled systems should be cleaned before initial treatment

If chloramine is detected In the effluent II can be neutralized bytes addition of sodium metebisultlte until the chloramine Is no

longer deletlied

INDUSTRIAL V1ER SYSTEMS SUSAN 1215 is used for the control of algal bacterial and flangal deposits in lmtustrtal cooling towers recirculating cooling water systems evaporative condensers Influent water- systems brewery and food pasteurizer

industrial fresh water- systems air-washers seawater desalination arid reverse osmosis systems paint apray booth swaps non-fish

containing decorative fountains and ponds used for cooling purposes sewage and wastewater ayslom This product Is also used

for tIre control of algae bacteria fungi and mollusks in both aeawater arid freshwater Influent systents

4hen this product is used to treat sewage and wastewater systems seawater and freshwater Muerit systems for once4tuougtr

industrial water systems and seawater desalination arid reverse osmosis systems and the system water Is nOt sent toe P01W resided levels of cirtoramine in tIre effluent met be monitored and smifralized using On4ine monitoring and control equipment

ffien this product taused to treat reorculatlng cÆtlrsg water systems evaporative condensers InIluent aster systems riot pest of

once-through industrial water systems brewery and food pasteurizera airweshors paint spray booth sumpe and non-fish

containing decorative fountalne and ponds used for cooling pwposes effluent detedlon of trloramrne should be conducted at least

once per shift If diloramlne Is detected in tire effluent Itcan be neutralized by the addition of sodium mefabisutflte until lire

chlorsmlme is no longer detected

This product Is applied in cor4unction with eodsrm hypochiorite to lena monoclrloramine slower acting less aggressive oxidizing

nrlcrobloclde The products are added to dilution water to achieve minimum molar ratio of 1.0 to 1.0 SUSAN 1218 to sodium

hypodilodle This ratt nay be obtained by combIning 0.5 fluid ounces of SUSAN 1215 to 1.0 fluid ounces of sodlrrn hypotdoflte

less than or equal to 15.0% wI/at To insure both handling safety and effectivenees the menocirloramine solution must be

generated and fed Into tIre treatment eater process through closed metered drernloat feed systase The system operator must be

trained by Budiman representative in the rae of the chenricalfeed system Use of this productfor arty other purposes or contrary

to tire use directions spedflnd below Is prohibited

Dosage Rates When noticeably fouled apply suffIcIent pmrtrict arid sodium hypoctilonte io wchteve total chlorine residual of at

least ppm In excess of the system osidarit demand Once control Is achieved treatment rates can be rethaed to sub-demand

rates from 50% to 80% of system demand The product maybe sddedto the eyatsm ootrtinuoualycrlrderrrtltienlty as needed to any

area of the system swrere uniform muting can be obtained

For Intermittent treatment mix 05 fluid ounces of SUSAN 1215 to 1.0 fluid ounce of sodium hypochlonite less than or equal to

15.0% MM Apply the solution at rate to obtaIn 1102 ppm In excess of the system oxidant demand maximum of ppm

measured as total chlorine litthe waler being treated for to 60 mInutes every to hours The frequency of feeding and the

duration of treatment will depend on the severity of the problem Sadly fouled aysterra should be dewed before initial treatment

For continuous treatment mIx 05 fluId ounces of BUSAN 1215 to 1.0 fluId ounce of sodium hypocirtonira less th5n or equal to

15.0% at/wi Apply the solution ate rate to obtain 0.5 to ppm in excess of the system orddant demand maximum of ppm

measured as total chlorine In tire waler being treated one continuous basis The frequency of feeding and the duration or

lrealnienl wit depend on lire secerity of the problem Badly fouled systems should be cleaned before Inlltal Irsabrre.rt

-_

Directions for Use

SAN 21 It is aldetatlen of Federal lewIs tweeds product bra swear lncarielstent wIth Its labellri

________ PULP AltO PAPER MILLS SUSAN 1215 is seed as microbiocide In the manufacture of paper and papeitoard that contacts ausm is areglstaredaademas

rilicrobiocide for controlling algal bacterial and fungal deposits in Inhtuent waler systems end at

process water systems used for the manufacture of paper and paperboard produds and It industrial

mis pro apitej in corluncon seth sodium hypocPdorila to form monocliloramba slower acting less aggressive oxidizing

cooling towers reclrctdathrg cooling water systems evaporative condensers inltuerri water systems marobiocide The products are added to dilution water to achieve minimum molar ratio of 1.0 to 1.0 SUSAN 1215 to sodium

brewery and food pastsurizers Industrial fresh water systems airwashera seawater desalination ttypocttorite This ratio may be obtained bycontbrning 0.5 fluId ounces of SUSAN 1215 tolD fluId ounces of sodium hyçioclifonite

and reverse osmosis systems paint spray booth eumps non-fish contalntrrg decorative fountains less than or equal to 15.0% wI/wi To lnsre both handling safety end effectiveness the monochloranrttre solution must be end ponds used for cooling purposes sewage and wasteweter systems This product is also used generated and ted Into the treetmerit water systems through proper chemical feed skid only bye trained Budiman representative for the control of algae bacteria fungi and motuske in both seawater arid freshwater influent Use of the product for any other purposes or contrary to the use directions specified beluw Is prohIbited

systems

ACTIVE INGNEDIENTS Dosage Rates When noticeably fouled apply sufficient product arid sodium hypodilorda to achieve total dilorlire residual of cli

Mtrnonla ___ 7% least ppm in excess of the system oxidant demand Once centrol is achieved treatment rates can be reduced to sub-demand

INERT lNGOENTe.................. ft2 41% tales trots 50% to 80% of system demand The prcdut may be added to the system 000tinuously or intermittently as needed to

TOTA___.__._____.___ any area of the system where uniform mIxing can be obtained

I9RST AID

If Move per-son to fresh air

Inhaled If

person is not breathmg call till or an ambulance then give artificial respiration

preferably by mouthto-rrrouth If possible

-catapoinon control center or doctor for further trsratnrent advice

NOT UstIn wuaramu

Have the product container or label with you when calling Poison Control

Center or doctor or going for treatment You may also contact 901-278-0330

or 1-800-8UCKMAN for emeroency medical treatment information

14-CC EPTrEb ..JUL 152008

M

E

E

P

L
ATTACHMENT

44 /1

U.S ENVIRONMENTAL PROTEC1ION Of Issuance

EN Nwnber

Office of Pesticide Programs 1448- 2007

Antimicrobias Division 7510P 432

1200 Pennsylvania Avenue NW

Washington D.C 20460

Term of Issuance

Conditional

NOTICE OF PESTICIDE

.L Registration

Name of Peshcide Product

Reregistration BCMW

under FiFA as amenood

Name anti Address of Registrant tncude ZIP Code

Buckman Laboratories Inc

1256 McLean Blv

Memphis TN 38108

Note Changes in labeling differing in substance from that accepted in connection with thts registration must be submUad to and accepted by the

Registration Division prior to use of the label in commerce in any correspondence on this product always refer to the above EPA registration number

On the basis o1 Information furnished by the registrant the above named Oestictde is hereby registered/reregistered under the Federat Insecticide

Fungicide and Rodenticide Act

Registratron in no way to be construed as an endorsement or recommendation oi this product by the Agency in order to protect health anti the

environment the Administrator on his motion may at any time suspend or cancel the registration of pesticide in accordance with the Act The

acceptance of any name in connection with the registration of product under this Act is not to be constitred as giving the registrant right to erciusive use

or the name or to ts use tilt has been covered by others

This product is conditionafly registered in accordance with FIFRA sec 3c7C

provided that you

Submit and/or cite all data required for registration of your product under FIFRA

sec 3c5 when the Agency requires all registrants of similarproducts to submit such

data and submit acceptable responses required for re-registration of your product under

FIFRA section

Make the labeling changes fisted below before you release the product for

shipment

Revise the EPA Registration Number to read EPA FReg No 1448-432

OaIe

Ima No le

Product Manager TeaTm3l 2007

Regulatory Management Branch

Antimicrobials Division 751 OP

EPA Form 8570-6
Submit three copies of your final printed labeling before distributing or selling

the product bearing the revised labeling

If these conditions are not complied with the registration will be subject to

cancellation in accordance with FIFRA sec 6e Your release for shipment of the

product constitutes acceptance of these conditions

stamped copy of the label is enclosed for your records

Sincerely

elma Noble

Product Manager 31

Regulatory Branch

Antimicrobials Division 751 OP

Enclosure
BCMW

KEEP OUT OF REACH OF CHILDREN

CAUTION

HOco 1s TmooHt.ooftiii

-Miii iMi

-cispo

iiI

Iii it4i 64111 ormfl idiG6 $Sn Ifol iiJii4ii4iiifi

or fiii capa Pthiii DoWif Ct6rillibisIisi

Psecaulionaiy Statements

HAZARDS TO HUMANS AND DOMESTIC ANIMALS CAIflIM I4iisM Avl fo64ifo vapo AaI t64gI iiior

iiiIEfoftiVgiidorfrW iifouuii.ii.i

INVWflTM MIZAI lIt Do orfMi lsIVeluiiticrtMig 6iplor iuuii paid orbjfoi or 4w iiiias fo idi Iii rÆai$uii PItd bd4w Sy.foii OIlIS paird sal Ii psii iiusa6 iibaitl foiifotfo Dl 64 4wsa iii64t Mi p16d1M fo ial0a 64 MiiiMiauMi KsqA44Mi

O4aldOf torUs

aialFshm4fowt sasMi 4foiiwidiiMi.da I4 PiSi ad P6pui

...... ml t---al Ia

MAR -6 2007

hr bdemI bimctIck

ng1c1de eisa

eiEMeg l.a/I/f- i71J2s