SPOON RIVER FS, INC.
dlbla
RIVERLAND
FS, INC. (EllisvilIe)
(Property Identification Number
06-05-01-200-01)
Petitioner,
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY
)
Respondent.
)
NOTICE
DorothyM. Gunn, Clerk
Spoon River FS, Inc. dlb/a Riverland FS, Inc.
Illinois Pollution Control Board
Attn: Hermon Stier
James R. Thompson Center
5515
East County Road
17
100 West Randolph Street, Suite.
11-500
Ellisville,
IL 61431
Chicago, Illinois 60601
Steve Santarelli
Illinois Department of Revenue
101 West Jefferson
Post Office Box
19033
Springfield, Illinois 62794
PLEASE TAKE
NOTICE
that I have today filed with the Office of the Clerk of the Pollution
Control Board an APPEARANCE AND THE RECOMMENDATION of the Illinois Environmental
Protection Agency, a copy of whichis herewith servedupon you.
ENVIRONMENTAL PROTECTION AGENCY
OF THE STATE OF ILLiNOIS
By(~&&~
/S~S
Jam
s Allen Day
As istant Counsel
ivision of Legal Counsel
DATED:
December
16, 2004
Illinois Environmental Protection Agency
1021
North Grand Avenue East
Post Office Box 19276
Springfield,
Illinois 62794-9276
217-782-5544
~ECE~VED
BEFORE
THE ILLINOIS POLLUTION CONTROL
BOARD
RKS OFFICE
DEC 20
2004
)
)
)
PCBL~4~
)
(Tax Certification)
STATE OF ILLINOJS
Pollution Control Board
THIS FILING IS
SUBMIITED ON RECYCLED
PAPER
RLW~1VED
CLERKS
OFFICE
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
DEC 20
2004
SPOON RIVER FS, INC.
dibla
RIVERLAND
)
STATE OF ILliNOIS
FS, INC. (EllisvilIe)
)
pollution
Control
Board
(Property Identification Number
)
—
i
(~)
06-05-01-200-01)
)
Petitioner,
)
PCB O4~
)
(Tax Certification)
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY
)
Respondent.
)
APPEARANCE
The undersigned, as one of its attorneys, hereby enters
an APPEARANCE on
behalfofthe
Respondent, Illinois Environmental Protection Agency.
ENVIRONMENTAL PROTECTION
AGENCY OF THE STATE OF ILLiNOIS
By:/~~24//~
J
s Allen Day
sistant Counsel
Division ofLegal Counsel
DATED: December 16, 2004
Illinois Environmental Protection Agency
1021 North Grand Avenue East
Post Office Box 19276
Springfield, Illinois 62794-9276
217-782-5544
THIS FILING IS
SUBMITFED ON RECYCLED PAPER
~ECE~VED
CLERK’S OFFICE
BEFORE THE ILLINOIS POLLUTION CONTROL BOAReEC
202904
SPOON RIVER FS, INC.
d/b/a
RIVERLAND
)
STATE OF ILLINOIS
FS, INC. (Ellisville)
)
Pollution Control Boarc~
(Property Identification Number
)
06-05-01-200-01)
)
-i
Petitioner,
)
PCB JL4~
)
(Tax Certification)
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY
)
Respondent.
)
RECOMMENDATION
Now Comes the Illinois Environmental
Protection Agency (“Illinois EPA”) by James Allen
Day, one ofits attorneys,
and
pursuant to Section
125.204 ofthe Illinois Pollution Control
Board’s (Board) regulations files the following Recommendation regarding the tax certification
ofwater pollution control facilities pursuant to
35 Ill.
Adm. Code 125.204.
1)
On August 12, 2003, the Illinois EPA received a request from Spoon River FS, Inc. dlb/a
Riverland FS,
Inc. (“SpoonRiver”) for an Illinois EPA recommendation regarding the tax
certification ofwater pollution control facilities at its Ellisville, Illinois facility pursuant
to 35 Ill. Adm.
Code 125.204, and noted the request as log number TC-21-03. (Exhibit A)
2)
The applicant’s address is:
Spoon River FS, Inc.
dlb/a Riverland FS,
Inc.
5515
East County Road
17
Ellisville, IL 61431
3)
The waterpollution control facilities in this request are located at the above street address
in Section
1, Township
7 North, Range
1 East ofthe
4th
Principal Meridian in Fulton
County, Illinois
and consist ofthe following:
Agrichemical containment structures consisting ofone liquid agrichemical
operational area containment structure;
two dry fertilizer blended with pesticide
operational containment structures; one bulk liquid agrichemical secondary
THIS FILING IS
SUBMITTED
ONRECYCLED
PAPER
containment structure; the portion of the building over one bulk liquid
agrichemical operational area containment structure; associated collection and
recovery systems; two dry fertilizer operational containment structures; as
approved under the Agency endorsed Agrichemical Facility Permit No. 92071535
(Log No. 02097207).
4)
These facilities collect, transport,
and store agrichemical rinsates, residues, or washwaters
prior to reuse or disposal.
5)
Section
11-10 ofthe Property Tax Code,
35
IILCS 200/11-10 (2000), defines “pollution
control facilities” as: “any system, method, construction,
device or appliance appurtenant
thereto or any portion of any building or equipment, that
is
designed, constructed,
installed or operated for the primary purpose of:
(a) eliminating, preventing, or reducing
air or water pollution
.
.
.
or (b) treating, pretreating, modifying or disposing ofany
potential solid, liquid or gaseous pollutant which if released without treatment,
pretreatment modification or disposal might be harmful, detrimental or offensive to
human, plant or animal life, orto property.”
6)
Pollution control facilities are entitled to preferential tax treatment, 35 ILCS 200/11-5
(2000).
7)
Based on the information in the application and the purpose ofthe facilities (collecting,
transporting and/or storing agrichemical rinsates, residues, orwashwaters prior to reuse or
disposal), it is the Illinois EPA’s engineeringjudgment that the described facilities may
be
considered “pollution control facilities,” pursuant to 35
Ill. Adm. Code
125.200(a),
with the primarypurpose ofeliminating, preventing, or reducing water pollution, or as
otherwise provided in 35
Ill. Adm.
Code
125.200.
Therefore,
the facilities are eligible for
THIS FILING IS SUBMITTED
ON RECYCLED PAPER
tax certification from the Board.
8)
Therefore, the Illinois EPA recommends
that the Board issue the requested tax
certification.
Illinois Environmental Protection Agency,
By:______
Allen Day
Assistant Counsel
Division ofLegal Counsel
December 15, 2004
Illinois Environmental Protection Agency
1021
North Grand Avenue East
Post Office Box
19276
Springfield, Illinois
62794-9276
217-782-5544
THIS
FILING IS SUBMITTED ON RECYCLED PAPER
)
STATE OF ILLINOIS
COUNTY OF SANGAMON
)
)
)
)
PROOF OF SERVICE
I, the undersigned, on oath state that
1 have served the attached APPEARANCE AND
RECOMMENDATION,
upon the person to whom it is directed, by placing a copy in an
envelope addressed to:
Dorothy M. Gunn, Clerk
Illinois Pollution Control Board
James R. Thompson Center
100 West Randolph Street, Suite.
11-500
Chicago, Illinois 60601
Steve Santarelli
Illinois Department ofRevenue
101 WestJefferson
Post Office Box
19033
Springfield,
Illinois
62794
Spoon River FS,
Inc. d/b/a Riverland FS, Inc.
Attn:
Hermon Stier
5515
East County Road
17
Ellisville, IL 61431
and mailing it from Springfield,
Illinois on December 16,
2004 with sufficient postage affixed
for first class mail.
SUBSCRIBED AN) SWORN TO BEFORE ME
this sixteenth day ofDecember, 2004
OFFICIAL
SEAL
CYNTHIA L.
WOLFE
~
NOTARY
PUBUC,
STATE OF
ILLINOIS
:~
MY
COMMISSION EXPIRES ~
~otaryPublic
THIS FILING IS
SUBMITITED ON RECYCLED PAPER
State ofIllinois
Department ofAgriculture
AGRICHEMICAL FACILITY PERMIT
erate an
agrichemical
i.
~dwL&~
~L~PC
A
to—
~-~ci-
LLC~L~
Permittee:
Facility ID Number:
AC0573130000
Facility Location:
Ellisville, IL
Riverland FS, Inc.
-_______________________________
POBox2l7
:~.‘
~
.17.
-~i
Knoxville,
IL 61448
Permit #
AC92071535
Log Number
0209’~07
Facthty Type
Commercial
Retail D?er
Date Received
SepteT~ber13, 2002
~
0
Date Issued:
October 25, 2002
J
Expiration Date:
Octobe~
25, 2007
Permit is
hereby granted to
the above designated
permittee to
construct and oi
containment facility as
ws:
OPERATIONAL CONTAINMENT STRUCTURES
Operation ofan existii~
reinforced concrete operational containment structure n~easuring
32’ (width)
x 40’
(length) x 0.83’ (c1~pth)
with a total design capacity of 658.7 cubic feet (fl.3).
The floor shall
slope
to a series offour
(4),~sumps
(two (2) sumps for the recovery of solids and $wo (2) sumps forthe
recoveryofliquids), each sihiip measuring
1.5’
(diameter) x
1.75’ (depth)
to
faci1~tate
the collection
and recovery ofall escaped pro’&lct and/or agrichemicál wastewater.
All recov~red
effluent shallbe
transferred to one (1) oftwo
(2)
500
gallon recovery tanks with a manually activated sump pump.
Segregation shall be performed b
s
on the applicable target crop and label t~se.All loading,
unloading and washing ofbulk liquid agr7chemical transportation and app1icatiol~equipment shall be
performed upon the herein permitted s
cture.
SECOND
Y CONTAINMENT STRUC
S
Operation ofan existing reinforced concr~è-se~ondaiy
containment strudture measuring 20.67’
(width)
x 41.67’ (length) x
6’
(height) with a total design capacity of45~&4
cubic feet (fl.3).
The
floor shall slope to
a single sump measuring 2’ (di
eter) x 2’ (depth)
tQ, facilitate the collection
and
recovery ofall escapedproduct and/or agrichemica
wastewater.
A)Lre~overed
effluent shall be
transferred to one (1) ofthe two (2) aforemention
1500 gallon i4covery tanks with a manually
activated sump pump.
Segregation shall be perfo
b
e
n
e applicable target crop and
label
use.
All bulk liquid fertilizer shallbe stored within
aid structure.
—..
‘:
~
~
Sta~
Department ofAgriculture
Riverland FS, Inc.
AGRICHEMICAL FACILITY PERMIT
Page:
2
BULK DRY FERTILIZER STRUCTURES
Operation of an existing bulk dry fertilizer storage building with the greatest dimensions measuring
62’ (width)
x 72.7’ (length) with an estimated total storage capacityof 970 tons.
The structure is
composed of six (6) storage bins (one (1) bin measuring
12’ (width) x
33’ (length) with an estimated
storage capacity of 140 tons, two (2~
~
(length) with an
estimated storage capacity of 150 toi~pach,
one (1) bin measuring 11’ (width) x 33’ (length) with an
estimated storage capacity of 130 tons, ‘oz~e(1) bin measuring
12.8’ (width)
k4
1’ (length) with an
estimated storage capacity of200
tons, ant~
one (1) 13.5’ (width)
x 41’ (length~with
an estimated
storage capacity of200 tons each).
)
\
All bulk dry fertilizer shallbe stored
thin the herein permitted structure.
Operation ofan
existing rein~rced
concrete operational containment structuren easuring 21’ (width)
x
73.5’
(length).
All endload~
transfer ofbulk thy fertilizer between storage an
the blender shall be
performed upon the herein pe~nitted
structure.
Operation ofan existin~.xeii?forced
concrete operational containment structure n
asuring 12’ (width)
x
18’ (length).
The unl~adingofbulk dry fertilizer transportation and appiicatio4
equipment shall be
performed upon the h~f~in
permitted structure.
Operation ofan existik~
reinforced concrete operational containment structure 4asuring
34.7’
(width) x 46.3’ (length~x
0.83’ (depth) with’a total design capacity of 894.0 cubi~
feet (fl.3).
The floor
shall
slope to a single st~ip
measuring 2’ (diameter) x
2’ (depth) to facilitate the dollection and
recovery ofall escaped pr~4uct
and/or agrichemicalwastewater.
All recovered 4’fluent shallbe
transferred to one (1) ofthe’tw~
(2) aforementioned 1500 gallon recovery tanks
4rith
a manually
activated sump pump.
Segrega~nshall be performed based upon the applicabl~
target crop and label
use.
All loading ofbulk dry ferti’izer, including fertilizer impregnated with pes~icides,
all blending of
bulk dry fertilizer, including the iI~pj
ation ofdry fertilizer with pesticides, afl~storageofbulk dry
pesticides and all loading and unloading
o
bulk drypesticide transportation and
~pplication
equipment, shallbe performed upon the
erein permitted structure.
This structt~z~
shall be referred to
as DFOC4.
;
/
Operation ofan
existing reinforced co
Crete operational containment stru~i~e
measuring 9’ (width) x
25’ (length) x 0.12’ (depth). The floor sh
slope to
DFOC-1
to facilitate ~6ecollection and recovery
ofall escapedproduct and/or agrichemical
ewater.
The inductor and~mini-bullc
containers
utilized in the process ofimpregnating bulk dry
~lizerwith pesticides14hall be located upon the
herein permitted structure.
This structure shall be
ferred to as DFOCj.
There shall be no discharge ofwastewaterfro
the herein p
tted facilities.
This permit has been reviewed and approved by the I
is Environmental Protection Agency per the
attached permit endorsement. This permit is subject to standard conditions on the reverse side ofthis
document and the following special conditions:
State ofIllinois
Department ofAgriculture
Riverland FS, Inc.
AGRICHEMICAL FACILITY PERMIT
Page:
3
SPECIAL CONDITION 1:
The
permittee shall provide backflow protection in accordance
with the Illinois Department of Public Health Plumbing Code (77 Ill. Adm.
Code 890) and the
Illinois Environmental Protection Agency’s Technical Policy Statement
(35
Ill. Adm.
Code
•
653.803(c)(4).
SPECIAL CONDITION 2:
Thepermittee may dischargeacc~~ated
precipitation from the
herein
permitted
bulk
liquid
fert1liz~rsecondary
containment
structlke
pursuant
to
8
Illinois
Administrative Code 255.110
(a) (2)
(~)
and (B).
SPECIAL CONDITION 3:
~!~e permittee
shall
perform
all
ope\rtions
involving
the
impregnation ofbulk dry fertiliz~.t.~ith
pesticides, in accordancewith 8 Illinois Administrative Code
255.150.
Thepermittee ~hal1i~aintainand manage the operational containrn
nt structure employed
forthe pesticide inductoi~ursuant
to 8 Illinois Administrative Code
255.90.
SPECIAL CONDITION)4:
The permittee shall operate the exposed d
yfertilizer operations
pursuant to 8 illinois Adfininistrative Code 255.140 (a), (c) and (d);
8 Illinoi~Administrative Code
255.80 (a); and 8 fl~inoi~
Administrative Code 255.110 (a) and (c).
SPECIAL CON1~TION
5:
Thepermittee shall employ concentricpip ng forthe pipingspan
from
the bulk
li4uid
fertilizer
secondary
containment
structure
to
the
op
rational
containment
structure.
SPECIAL COND~~1~ION
6:
Thepermittee shall provide means forthe safe emergency access
to and exit from thehe?e~in
permittedbulk liquid fertilizer secondarycontainmei~it
structurepursuant to
8 fllinois Administrative~(~p~e
255.80 (c) (2) (E).
SPECIAL CONDITION 7:)
The permittee shall employ a totally en4osed conveyor for the
transfer ofbulk dry fertilizer
o
e unloading area to the storagebuilding~
THE STANDARD CONDITIONS OF I
SUANCE ON THE REVERSE SIDE~OF
THIS MUST BE
COMPLIED WITH IN FULL.
Warren D. Goetsch, P.E.
•anager
Division Manager, Natural Resources
.
~Field Operations
cc: illinois EPA:
WPC: Permits
file
a:057313.per
•aters:~:
L:r:r
~.eview
~
:~~eL_~~z
~vices
~~staiie~:
~iznatur~:
~-
Title:
WULCS:
~ Livestock waste ~s~cpiicd
to
c~:~tana.
*Agrlccemicai rinsate ~nu spiiia;~~srecycled
throuzn the t~cziitv
anwor i~na
a~piieã.
~ Other
__________________________________________________
Phvsicai
Descrrntion oiPolluüon Conuvi
Devices:
.~v!ewer~
-.4
\Q
~,:oov-’
~
~
T~-r.
~1~A
~
~ate:
1~r~
~-cT~.
u•a~~~Y-~
‘~‘I~I
c~•~
~
~
•
~-L.
~ ~‘3
‘~:)~‘~
-1~c-7z3j
•
~•—-‘-
v:~
Ocj-(Jy
~
Livestock
Con~c::
Phone:
Procercv
ID:
I
‘‘
Q~
3~-~
?~oviaea
~ir t.z.~n
Value:
F~th1.~
~f(
~
,•
~
Other
~i4U~89d5OT
1—920
P002/002
F—963
Inc.
125 PublicSquare
•
P0. Box217’ Knoxville, IllinOis 61448.0217. (309) 289-2383 or Fax
(309) 28~
James Allison
Illinois EPA
James,
November 3, 2004
In regards to our phone conversation, Spoon River PS, Inc., DBA
RIVERLA.ND FS, Inc.
is not requesting
tax
exempt
status
for
any dry
fertilizer storage buildings or mini bulk storage buildings at the below listed
facilities.
Williamsfield
Wataga
Maquon
Ellisville
Log #
Log#
Log #
Log #
TC-l 8-03
TC-19-03
TC-20-03
TC-2 1-03
If
I
may
be of
any
further assistance, please call.
Sincerely,
RIVERLAND FS, Inc.
Ron Blotna
General Manager
~wv
4a~
~
—
.
•,.,,~ii
;~I
- •
-
ILLINOIS
ENVIRONMENTAL PROTECTION
AGENCY
P.O. Box
19276,
Springfield,
IL
62794.9276
Tax
(en~j?caLwn
Jot Polliaion
Conirol Facilities
Page I of 2
8/00
This
Agency
is
authorized
to
request
this
information under
Illinois Revised Statue,.
1979.
Chapter.
120.
Section
502a-5.
Disclosure of
this
intormatton
is
voluntary.
However,
failure to
comply
could
prevent
your
application
from
being processed or ~uId
result in denial of your
p
application for certification.
APPLICATiON
FOR CERTIFICATION (PROPERTY
TAX TREATMENT)
POLLUTION
CONTROL
FACILITY
AIRE
WATER
~
FOR AGENCY USE
Fils
~
Date Received
Certification No.
Date
Sec. A
~
~
~
~
~
Company Name
Spoon River FS,
Inc.
D.B.A.
RIVERLAND FS,
Inc.
Person Authorized to Receive Certification
Person to
Contact for Additional Details
Hermon Stier
Kirk Heller
Street Address
Street Address
5515 East County
17
126 Public Square, P0 Box 217
Municipality. State & Zip
Code
Municipality,
State &Zip Code
Ellisville,
IL
61431
Knoxville, IL
61448
Telephone Number
Telephone Number
309—465—7231
309—289—2383
Location
of Facility
Municipality
Township
Quarter
Section
Township
Range
NE
of
NW
1
7
1
Ellisville
Lee
StreetAddress
County
Book Number
5515 East County
17
Fulton
Property
Identification Number
Parcel Number
06—05—01—200—001
Sec.
B
(D
~
~
~
~
~o
~
Nature ofOperations Conductedat the Above Location
Water Pollution Control Construction Permit No.
92071535
Date
Issued
October
5,
1992
NPDES PERMIT No.
Date
Issued
Expiration
Date
Air Pollution Control Construction
Permit No.
Date
Issued
Air PollutionControl Operating PermitNo.
Date Issued
Sec. C
~D
z
~w
~(J,
0
~
0
~e:
ze.
~
Describe
Unit
Process
MaterialsUsed in Process
.
‘
Sec. D
~
~
~
~
~
Describe
PollutionAbatement
Control
Facility
This
is an operational and secondary containment structure of agricultural
chemicals and fertilizers.
IDOA Facility #0573130000 issued
October
5,
1992.
~I~7~5T~\
IL
532-0222
APC
151
(Rcv. 8/00)
~-
~
AU5
12
2003
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY
BOWA’VPC/
PERMIT SECTION
(1)
Nature of
Contaminants
or
Pollutants
Material
Retained,
Captured
or Recovered
Contaminant or
Pollutant
DESCRIPTION
DISPOSAL
OR
USE
(2)
Poirit(s)of
Waste Water Discharge
None
Plans and
Specifications
Attached
Yes
No x
Are contaminants
(or
residues) collected
by the
control
facility?
Yes
No
X
(4)
Date
installation completed
~
status
of
installation
on date of
application
100
(5)
a.
FAIR CASH VALUE IF CONSIDERED REAL PROPERTY:
$
85,000
—
b.
NETSALVAGEVALUEIFCONSIDEREDREALPROPERTY:
$
64,100
c.
PRODUCTIVE GROSS ANNUAL
INCOME OF CONTROL FACILITY:
$
None
—
d.
PRODUCTIVE NETANNUAL INCOMEOFCONTROL FACILITY:
$
None
Sec.
F
Th~foIIowing
information is
submitted in accordance
with
the illinois Property Tax Code,
as amended, and to the bestof my
knowledge, is true and correct
The facilities claimed
herein are
pollution
control facilities’ as defined
in Section
11-10 of the
~:
Illinois Property Tax Code.
~
,.~.
/
~
Signature
Title
Sec. G
JNSTRUC11ONS
FOR
COMPILING
AND
FiLING
APPLICATION
General:
Separate applications must be
completed for each
control facility claimed.
Do not mix
types (water and
ar).
Where both
at
and
water operations are related,
file
two
app~cations. If attachments are
needed, record them consecutively
on an index sheet.
Sec. A
Sec. B
Information refers
to applicant as listed in the
tax records and the person
to be
contacted for further details or for inspection
of
facilities.
Define
facility
location by street address or legal description.
A plat
map
location is required for facilities located
outside ofmunicipal boundaries.
The property identification number isrequred.
Se~-explanatoy.Submit copies of all permitsissued
by local pollution control agencies.
(e.g.
MSD Construction Permit)
Sec. C
Sec. D
Refers to manufacturing processes
or
materials
on
which
pollutcn control facility is used.
Narrative description
of the pollution control
facility,
indicating that
its primaly purpose is to e~rninate,prevent or reduce pollution.
State the type of
control
facility.
State
permit number, date, and agency issuing pemiit
A narrative description and
a process
flow diagram describing the oollution control
facility.
Include
a ~sting
of each major piece of equipment
included in the claimed
fair cash value for real
property.
Include an averaoe analysis of the influent and effluent ofthe control
facility-stating the
~,
collection efficiency.
Sec.
E
List air contaminants,
or water pollution
substances released as effluents to the manufactising processes.
Ust also the final
disposal ofany contaminants removed
from
the manufacturing processes.
Item (1)
—
Refers
to pollutants and contaminants removed ~m
the process by the
pollution control
facility.
Item (2)
—
Refers
to water pollution but
can
apply to water-carried wastes from air
pollution control facilities.
Submit drawings,
which
cleaily
show
(a)
Point(s)
of discharge to receiving stream,
and
(b)
Sewers
and process
piping to and from the control
facility.
Sec.
F
Item
(3)—If
the collected
contaminants are disposed of other
than as
wastes,
state the disposition
of
the materials,
and the value
in
dollarsreclaimed by sale orreuse ofthe
collected
substances.
State the cost of reclamation
and
related expense.
Item (4)
—
State the
date
which
the
pollution
control
facility was first placed in service
and
operated.
If not, explain.
Item (5)
—
This
information is essential to the certification
and
assessment
actions.
This accounting data must
be completed to
activate project review prior tocertification
by this Agency.
SeIr.explanatOty.
Signature must be a corporate authorized
sçnature.
Subm(
to:
Attention:
Attention:
I~nois
EPA
Thomas
McSwiggin
Donald
E.
Sutton
P.O.
Box
19276
PermitSection
Permit Section
Springfield,
IL
62794-9276
Division ofWater
Pollution Control
Division
of
AirPollution Control
Tax
CellUlcazion JOt Pollution Control Facilities
Page2of2
8/00
Sec.
E
U)
I-
2
2
I-
2
0
(0
2
2
0
0
0
e.
PERCENTAGE CONTROL
FACILITY BEARS TO WHOLE
FACILITY VALUE:
33
