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  1. #1
    BS Detector, Esquire 10,000 PLUS POSTER Tony Shelton's Avatar
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    More misdirection. Why is this happening?

    I recently read the latest Eclean Magazine.

    There is an article about the PWNA Bmps. In the article there is a reference to statements attributed to a regulator from Nevada.

    The statement reads:

    "Anything that physically, chemically, or biologically changes the water is considered a pollutant." then adds "elevating the temperature means you are creating a pollutant".



    Really?

    How do radical filter salesmen get a regulator to make a statement like that? What kind of things could they possibly tell a regulator that we, as cleaners, are doing to our water to turn it into a pollutant?

    I did a little research throughout the Federal Epa database to find where and in what context this regulator could have said this statement and it wasn't very hard to find. It states in "Definitions":

    THERMAL TREATMENT (in the RCRA program) means the treatment of hazardous waste in a device which uses elevated temperature as the primary means to change the chemical, physical, or biological character or composition of the hazardous waste. Examples of thermal treatment processes are incineration, molton salt, pyrolysis, calcination, wet air oxidation and microwave discharge. (See also "incinerator" and "open burning")

    What kinds of videos, pictures, evidence or just plain false information could the PWNA give a regulator in reference to the simple HOT WATER CLEANING that we do to make him equate this definition, which is speaking of the TREATMENT of hazardous waste, with us?????

    This reference is in regard to treatment plants and treatment of hazardous waste, not a powerwasher cleaning soda pop spills off the sidewalk of a Jack in the Box or gum out in front of a grocery store!

    In the article, after the reference to the RCRA treatment definition Robert Hinderliter, the Environmental Co-Chair of the PWNA goes on to add his own two cents as if he speaks for the EPA himself and states:

    "High Pressure Power Washing with hot water or chemicals dislodges more contaminants than a rain event and cannot be treated the same."

    This is the crux of the PWNA bmps. Unless they include "hot water" in the same category as "chemicals" they can't possibly force a BMP that essentially requires everything we clean to be collected. It's not good enough for them to require reclaim of chemically cleaned areas. If they are going to promote the sales of reclaim equipment, they must force it in every situation, including the situations where we use hot water. That is the only way to ensure that every commercial powerwasher worth his salt in America is forced to buy the equipment the PWNA is selling through Robert Hinderliter and Jim Gamble.

    Please don't fall for the smoke and mirror effect that Robert is now recently starting to add to his statements because of the backlash he is receiving. Recently he has recanted his earlier stance the "nothing" can go down the drain, but is now reporting, (as I told him over two years ago) that "some" wash water, properly screened, may go down the storm drain as permitted by law. Don't fall for it. It is a concession that really means nothing if he can get your hot water considered hazardous as he and he PWNA have been attempting to do.

    A while back I spent a couple of days researching EPA documents. There is nothing anywhere in the EPA documentation or regulations that state anything about hot water being an emulsifier to create pollutants or anything that resembles that. This is a concept that has been created and is being promoted by Robert Hinderliter and the PWNA. It is reminiscent of the "nothing down the dr@in but rain" phrase that I searched a couple of years ago and found the oldest reference on the entire internet came from Robert Hinderliter and Delco back in the early 90's.

    This is an assault on your family gentlemen. It is a direct grab in your pocketbook with the government holding the gun while the PWNA searches your pockets.

    Do you support such misinformation? Do you want laws to be made based on false propaganda that Robert puts out that is effective enough to make a regulator equate our industry with the waste water treatment industry?

    If not, please let the PWNA know that we don't want such "snake oil salesmen" representing us to the government. If they won't listen, remove your financial support of this agenda.

    At the UAMCC we are dedicated to presenting our industry as the ENVIRONMENTAL CLEANERS we are. We are trying to educate contractors on the law and educate lawmakers on contractors. We are working on a campaign to change the way we are perceived by regulators by presenting them honest pictures of normal cleaning situations rather than the PWNA's incessant barrage of pictures of land owners who are violating the law and dumping pollutants down the storm drain.

    We need multiple volunteers from each state to battle his misinformation and save the small to medium sized pressure washing business from extinction though regulation meant to make everyone have to buy a $100,000 Jim Gamble filter rig just to operate legally. If you think that isn't coming in the future if we do nothing you are in for a big surprise.

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  • #2
    Member Honorary Professor Newlook's Avatar
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    So based on this EPA guys quote....If you power wash and add heat.....you are creating pollution thus need to reclaim? Is this how I read this? Can someone clarify?

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  • #3
    Exterior Restoration Specialist 21000 PLUS POSTER Ron Musgraves's Avatar
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    Carlos the Ft worth BMP's pretty much say it. No Hot water
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  • #4
    Member 7000 PLUS POSTER Scott Stone's Avatar
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    That is Robert's stance. It appears that the Nevada guy said the same thing. That is not making a lot of sense to me, because it was so closely related to what Robert said. If it wasn't Allison reporting it, I would have even more questions.
    I am wondering if the Enivro Dude was thinking we were doing something that is not typical, or if he was talking about something in a narrow definition of terms.
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  • #5
    Member Graduate Student Allison Hester's Avatar
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    I asked him to repeat that statement during his talk and once again afterward to make sure I got his statement about hot water correct. He said that comes straight from the Clean Water Act.

    He was not that familiar with -- or honestly very concerned about -- pressure washing, pressure washing BMPs, or the PWNA (and their BMPs). He just said that contract cleaners need to develop their own BMPs, take them to their local AHJs and work on coming up with something acceptable. In fact, he refused to answer some questions that got into the nitty gritty of what the disagreements are in the pressure washing industry.

    He stressed over and over his job was to protect the waters of the U.S. and the state...period. He did say that some things that are promoted in the industry, such as discharging to landscape or on private property, were not always acceptable choices. It doesn't mean that action will be taken against contractors (because he's got bigger fish to fry), but there were times that those options would not be considered acceptable...such as if the landscape discharge drained off of private property, into groundwater, or into waters of the U.S or the State.

    Finally, I can't remember if he said that storm water discharge was ever ok. I don't know that given his job position he ever could say that, if that makes sense. On those questions, he'd usually just answer, "My job is to protect the waters of the U.S. and the State." I do know he said that it's easier just to not discharge to the storm sewer.

    Again, these answers were pretty generic and he stressed they were based on the Clean Water Act and his job to enforce it, not based on specific pressure washing situations. He also made it clear he had hundreds of other industries and issues to worry about that were bigger concerns than pressure washing.
    Allison Hester
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  • #6
    Member Graduate Student Allison Hester's Avatar
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    And as for Robert and hot water, it's my understanding that back when all this started 20 years ago, regulators originally defined "hot water" as anything that came out of the tap that had any amount of heat added to it. So if your water was 40 degrees out of the tap and you raised it to 42, it was "hot" water. Robert fought to get that temperature to 110 degrees. The municipalities were the ones that said hot water was an emulsifier and therefore using it meant that you were dislodging more than a rain event would.
    Allison Hester
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  • #7
    Member Graduate Student Allison Hester's Avatar
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    Quote Originally Posted by Newlook View Post
    So based on this EPA guys quote....If you power wash and add heat.....you are creating pollution thus need to reclaim? Is this how I read this? Can someone clarify?
    Can't send it down the storm drain.
    Allison Hester
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  • #8
    BS Detector, Esquire 10,000 PLUS POSTER Tony Shelton's Avatar
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    Quote Originally Posted by Allison Hester View Post
    I asked him to repeat that statement during his talk and once again afterward to make sure I got his statement about hot water correct. He said that comes straight from the Clean Water Act.

    He was not that familiar with -- or honestly very concerned about -- pressure washing, pressure washing BMPs, or the PWNA (and their BMPs). He just said that contract cleaners need to develop their own BMPs, take them to their local AHJs and work on coming up with something acceptable. In fact, he refused to answer some questions that got into the nitty gritty of what the disagreements are in the pressure washing industry.

    He stressed over and over his job was to protect the waters of the U.S. and the state...period. He did say that some things that are promoted, such as discharging to landscape or on private property, were not always acceptable choices. It doesn't mean that action will be taken against contractors (because he's got bigger fish to fry), but there were times that those options would not be considered acceptable...such as if the landscape discharge drained off of private property, into groundwater, or into waters of the U.S or the State.

    Finally, I can't remember if he said that storm water discharge was ever ok. I don't know that given his job position he ever could say that, if that makes sense. On those questions, he'd usually just answer, "My job is to protect the waters of the U.S. and the State." I do know he said that it's easier just to not discharge to the storm sewer.

    Again, these answers were pretty generic and he stressed they were based on the Clean Water Act and his job to enforce it, not based on specific pressure washing situations.
    Allison, THANK YOU, THANK YOU, THANK YOU.

    I don't know why, two weeks later someone who attended the event could not have spent 5 minutes letting us know the content of his talk.

    Robert within hours after the gentleman spoke at the event Robert texted me the following:

    "NV EPA says you need a state permit."

    After some back and forth texts Robert then wrote:

    "A State of NV Permit for every discharge location to the MS4. These can be applied for on line. Effective 1-113. There are 15 general permits and ainumus (sp) permit. I told him that some contractors make discharges to 200 different locations. it make any difference. The number of location did not make any difference."

    He then added:

    "I asked for a general permit to be developed for our industry".

    After explaining to him in further texts that we already have a permit through the joint NPDES permit held by Las Vegas, North Las Vegas and Henderson municipalities, he responded:

    "He said that you would have to have a permit for each location as Jan 1, 2013."

    Then later "The comment period has already passed".

    (These texts are available in screenshots in their entirety)



    So you can see, Allison, why I, as a contractor operating in the state of Nevada was concerned with the content of that talk.

    Does what Robert has said have any resemblance to what was stated at the event?

    This is why is it important not to meet with regulators outside your own state discussing potential permits or new legislation without allowing local contractors to be present at the meeting. It leads to nothing but opportunities to spread more false propaganda to the public with no accountability.
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  • #9
    Member Graduate Student Allison Hester's Avatar
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    Quote Originally Posted by Tony Shelton View Post
    Allison, THANK YOU, THANK YOU, THANK YOU.

    I don't know why, two weeks later someone who attended the event could not have spent 5 minutes letting us know the content of his talk.

    Robert within hours after the gentleman spoke at the event Robert texted me the following:

    "NV EPA says you need a state permit."

    After some back and forth texts Robert then wrote:

    "A State of NV Permit for every discharge location to the MS4. These can be applied for on line. Effective 1-113. There are 15 general permits and ainumus (sp) permit. I told him that some contractors make discharges to 200 different locations. it make any difference. The number of location did not make any difference."

    He then added:

    "I asked for a general permit to be developed for our industry".

    After explaining to him in further texts that we already have a permit through the joint NPDES permit held by Las Vegas, North Las Vegas and Henderson municipalities, he responded:

    "He said that you would have to have a permit for each location as Jan 1, 2013."

    Then later "The comment period has already passed".

    (These texts are available in screenshots in their entirety)



    So you can see, Allison, why I, as a contractor operating in the state of Nevada was concerned with the content of that talk.

    Does what Robert has said have any resemblance to what was stated at the event?

    This is why is it important not to meet with regulators outside your own state discussing potential permits or new legislation without allowing local contractors to be present at the meeting. It leads to nothing but opportunities to spread more false propaganda to the public with no accountability.
    I HAVE to pick up my kids, so I will respond more later. But yes, what Robert said was true. The representative said that technically you would have to get a permit for each project cleaned (and the people who attended argued that was insane.) Robert asked about a general permit and he said while he would "consider it," he wouldn't consider it for long. It was too complicated to do and not really his top priority.

    I'll respond more later...
    Allison Hester
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  • #10
    BS Detector, Esquire 10,000 PLUS POSTER Tony Shelton's Avatar
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    Quote Originally Posted by Allison Hester View Post
    And as for Robert and hot water, it's my understanding that back when all this started 20 years ago, regulators originally defined "hot water" as anything that came out of the tap that had any amount of heat added to it. So if your water was 40 degrees out of the tap and you raised it to 42, it was "hot" water. Robert fought to get that temperature to 110 degrees. The municipalities were the ones that said hot water was an emulsifier and therefore using it meant that you were dislodging more than a rain event would.
    Allison you have been told an untruth as a blanket statement. The EPA only has one source document with with the word "emulsifier" in a search of their entire website and it is speaking only of chemicals. The city of FT worth is the only municipality I could find in the country that uses the word "emulsifier" in conjunction with pressure washing and there is no doubt where that came from.

    As far as the "hot water" issue goes, the EPA was dealing with SUPERHEATED water discharging directly from industrial plants right into the waterway back in the day that Robert was talking about.

    This can't possibly happen in our industry unless we are working on a dock.

    We cleaned the streets of a city here in Las Vegas using 190 degree water to remove gum on a 106 degree night. (I have photos of the bank thermometer that night I have posted before) By the end of the block, the runoff had already reached 118 degrees. We were not using soap and were required to filter for debris. At the outlet of the filter the water was 110 degrees which is 5-20 degrees lower than the ambient daytime temps in the summer! Once the filtered water reached the storm drain I'm pretty certain it would have cooled to less than the outside ambient temperature as it was underground.

    It's time for us as an industry to stop allowing what we do to be compared to industries that clogged and polluted our waterways in the 70's!

    Thank you for your writings Allison!
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  • #11
    BS Detector, Esquire 10,000 PLUS POSTER Tony Shelton's Avatar
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    Quote Originally Posted by Allison Hester View Post
    I HAVE to pick up my kids, so I will respond more later. But yes, what Robert said was true. The representative said that technically you would have to get a permit for each project cleaned (and the people who attended argued that was insane.) Robert asked about a general permit and he said while he would "consider it," he wouldn't consider it for long. It was too complicated to do and not really his top priority.

    I'll respond more later...
    So, in effect, what Robert has gotten this man to say is that while these BMP's which are still in place in Las Vegas are null and void:

    http://www.lvstormwater.com/pdfs/bmp_brochure.pdf

    and that we now fall into one of these 11 categories after decades without one single powerwashing complaint or citation in the state:

    http://www.lvstormwater.com/bmps_industry.htm

    And that in order to clean a Walgr#ens entrance for $80 we need a $200 permit.

    The Monday after the event I requested a meeting with the head of the Las Vegas Stormwater Authority. They had never heard of such a need for a permit and suggested we continue operating as we have been, fully compliant with the law.

    This quote speaks volumes Allison:

    He was not that familiar with -- or honestly very concerned about -- pressure washing, pressure washing BMPs, or the PWNA

    This is the exact reason the PWNA will be held financially liable if their introducing false presumptions about our industry via Robert and Jim causes financial harm to any Nevada Contractor.

    Our laws were, and are, an effective control on pollutant levels in our waterways and have produced no prior need to interfere with the operation of power washers.

    Coming into the state of a contractor and inviting more regulation i.e. "I tried to get them to issue a general permit" is a direct attack on the contractors in our state.

    This is the method of operation of the PWNA. Every member who does not demand change is well advised that no state is immune from their influence. YOU WILL RECLAIM, OR YOU WILL PAY. That is their silent motto.
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  • #12
    BS Detector, Esquire 10,000 PLUS POSTER Tony Shelton's Avatar
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    The eleven industries that need NPDES permits as per federal EPA

    The PWNA is working hard through their environmental committee to start a 12th category just for us:

    http://cfpub1.epa.gov/npdes/stormwater/swcats.cfm

    Category One (i): Facilities subject to federal stormwater effluent discharge standards in 40 CFR Parts 405-471
    Category Two (ii): Heavy manufacturing (for example, paper mills, chemical plants, pretroleum refineries, and steel mills and foundries)
    Category Three (iii): Coal and mineral mining and oil and gas exploration and processing
    Category Four (iv): Hazardous waste treatment, storage, or disposal facilities
    Category Five (v): Landfills, land application sites, and open dumps with industrial wastes
    Category Six (vi): Metal scrapyards, salvage yards, automobile junkyards, and battery reclaimers
    Category Seven (vii): Steam electric power generating plants
    Category Eight (viii): Transportation facilities that have vehicle maintenance, equipment cleaning, or airport deicing operations
    Category Nine (ix): Treatment works treating domestic sewage with a design flow of 1 million gallons a day or more
    Category Eleven (xi): Light manufacturing (For example, food processing, printing and publishing, electronic and other electrical equipment manufacturing, and public warehousing and storage).


    Our industry would be much better served if we had leadership showing the net positive effect we have on the environment so that common health and safety powerwashing could be added to these exempt categories instead:

    http://www.epa.gov/compliance/resour...litychart.pdf1

    Allowable Non-Storm Water Discharges:
    1. Discharges from fire fighting activities
    2. Fire hydrant flushing (testing)
    3. Potable water including water line flushing (testing)
    4. Uncontaminated air condition or compressor condensate
    5. Irrigation drainage
    6. Landscape watering, provide all pesticides, herbicides, and fertilizers have been applied
    in accordance with manufacturers instructions
    7. Pavement wash water where no detergents are used and no spills, leaks of toxic or
    hazardous materials have occurred (unless all spilled material has been removed)

    8. Routine external building wash down which does not use detergent
    9. Uncontaminated groundwater or spring water
    10. Foundation or footing drains where flows are not contaminated with process materials
    11. Incidental windblown mist from cooling towers that collects on rooftops or adjacent
    portions of your facility, but NOT intentional discharges from cooling towers


    We have 20 years of catching up to do.
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  • #13
    Member Graduate Student Allison Hester's Avatar
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    Local municipalities trump state regulations, so I assume the lv bmps are the authority in your area.

    His comment was that the guys who attended were obviously concerned about doing the right thing, and he wasnt too worried about any this industry. There was no promoting of specific bmps or methods or technologie no arguing ( except that a permit for each job didn't seem reasonable). Just a few questions (such as whether hot water can be allowed down the storm drain). Very civil, professional discussion. He made it clear he has other more pressing industries to worry about. His comment was just to work with your local AHJ to come up with an acceptable plan.

    As for the dates on the permits, etc.m I don't remember the specifics of any of that. I think the permit for each job was just a quick response he gave, but I assume that's up to the local municipalities. The general permit was asked about after the individual permits came u p as a way to possibly prevent the unrealistic comment about a permit for each job.
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  • #14
    BS Detector, Esquire 10,000 PLUS POSTER Tony Shelton's Avatar
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    The reason I keep bringing up Jim and Robert is because without the support and backing of the PWNA they are nothing more than two contractors running around making waves. (Which in itself is bad).

    But by lending them credibility to penetrate into our states the PWNA is responsible for the havoc they introduce into the industry.

    Remember these words "The PWNA will not shop or present the BMPs to municipalities". This is what was used to convince contractors to adopt the PWNA Bmps.

    I guess they figure shopping them to state EPA officials like the one they brought into the Nevada event after the local municipalities turned them down is technically shopping to the "state" instead of the municipality.

    Do you really want to support an org that does the opposite of what it says?
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  • #15
    BS Detector, Esquire 10,000 PLUS POSTER Tony Shelton's Avatar
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    Quote Originally Posted by Allison Hester View Post
    Local municipalities trump state regulations, so I assume the lv bmps are the authority in your area.

    His comment was that the guys who attended were obviously concerned about doing the right thing, and he wasnt too worried about any this industry. There was no promoting of specific bmps or methods or technologie no arguing ( except that a permit for each job didn't seem reasonable). Just a few questions (such as whether hot water can be allowed down the storm drain). Very civil, professional discussion. He made it clear he has other more pressing industries to worry about. His comment was just to work with your local AHJ to come up with an acceptable plan.

    As for the dates on the permits, etc.m I don't remember the specifics of any of that. I think the permit for each job was just a quick response he gave, but I assume that's up to the local municipalities. The general permit was asked about after the individual permits came u p as a way to possibly prevent the unrealistic comment about a permit for each job.
    Thanks Allison. It would have been nice for Robert to have told me these things in his text exchange.

    The slanted information I got from the texts is like asking someone what the Bible says and having them skip over the salvation part and say "It says you must Remember the Sabbath and keep it Holy". lol.

    If only they would make it their goal to spread the word that the entire professional power washing industry has a goal of doing the right thing for the environment we would all be the better for it.

    And the hot water issue is the most crucial of all. That is why it is so important for them to bring it up.

    I'll try to make this simple. IF you are a commercial cleaner, there is usually only one way to avoid using soap. That is to use HOT WATER.

    If you clean with hot water and no soap, most municipalities allow you to screen for debris and not worry about fines for discharging into the storm drain, just like the construction industry.

    This type of cleaning represents a huge untapped private and municipal market that is not currently required to reclaim water or use filters.

    If Robert can make HOT WATER to be viewed the same as soap by repeating this over and over again and using statements that pertain to wastewater treatment facilities and industries that dump hot water directly into fishable waterways, then the market for reclaim and filtration is instantly captured by law and must use equipment that Robert currently sells and Jim has claimed he plans to make to sell in the future, if he isn't already.

    It's just as Robert stated before. You have to follow the "economic revenue stream" in order to decipher the reasons behind actions that, on the surface, just don't make any sense.
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  • #16
    Member Honorary Professor Lightning Gene's Avatar
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    Whats wrong with your phone Tony? Tried calling you

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    Member Honorary Professor Lightning Gene's Avatar
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    Maybe so.....LOL

  • #19
    BS Detector, Esquire 10,000 PLUS POSTER Tony Shelton's Avatar
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    Quote Originally Posted by Lightning Gene View Post
    Maybe so.....LOL
    Nice talking Gene!

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  • #20
    Member Honorary Professor Lightning Gene's Avatar
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    Good hearing from you Tony.......Happy Trails To You.....Till We Meet Again

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