qCEVE
CLERK’S
OFFIC
NOV
‘12
2008
TATE
OF
ILLINOIS
OFFICE OF THE ATTORNEY GENERAL
contro’
Board
STATE OF ILLINOIS
Lisa Madigan
ATTORNEY
GENERAL
I
November
6,
2008
John
T.
Therriault, Assistant Clerk
Illinois Pollution
Control
Board
James R.
Thompson
Center,
Ste.
11-500
100
West Randolph
Chicago, lllnois
60601
Re:
People v. Whalen Manufacturing
Co. &
Yetter Manufacturing
Co.
Dear
Clerk:
Enclosed for filing please find the original and ten copies of a Notice of Filing,
Entry of
Appearance and
Complaint in regard to
the
above-captioned matter. Please file
the originals
and
return file-stamped
copies to me
in the enclosed, self-addressed envelope.
Thank you
for
your cooperation and
consideration.
Andrew
J.
cholas
Environmental Bureau
500 South
Second Street
Springfield, Illinois 62706
(217) 782-9031
AJN/pk
Enclosures
500
South Second Street, Springfield, Illinois 62706 • (217) 782-1090 • TTY:
(877)
844-5461
• Fax: (217) 782-7046
100 West Randolph Street, Chicago, Illinois
60601
• (312)
814-3000 • TTY:
(800)
964-3013
• Fax: (312) 814-3806
BEFORE
THE ILLINOIS
POLLUTION
CONTROL
BOARD
PEOPLE
OF THE
STATE
OF
ILLINOIS,
Complainant,
)
vs.
)
PCBNo.
(Enforcement
-
Water)
WHALEN
MANUFACTURING
COMPANY,
)
an Illinois
corporation,
and
YETTER
)
MANUFACTURING
COMPANY,
an
)
Illinois
corporation,
)
Respondent.
)
cOFFb0E
NOTICEOF
FILING
4OJ
22OOS
Lt$OS
To:
Whalen
Manufacturing
Company
and
STPjntro
Board
Yetter
Manufacturing
Company
do
William
H.
Campbell,
Registered
Agent
Davis
&
Campbell
L.L.C.
401
Main Street
Suite 1600
Peoria,
IL
61602-1
241
PLEASE
TAKE
NOTICE
that
on this
date I mailed
for filing
with the
Clerk of
the Pollution
Control
Board of
the
State
of
Illinois,
a
COMPLAINT,
a
copy
of which
is
attached
hereto
and
herewith served
upon
you.
Failure to
file an answer
to
this
Complaint
within
60 days
may
have
severe
consequences.
Failure
to
answer will
mean
that
all
allegations
in this
Complaint
will
be
taken
as
if
admitted
for
purposes of
this
proceeding.
If you
have any
questions
about
this
procedure,
you
should
contact
the hearing
officer assigned
to
this
proceeding,
the Clerk’s
Office
or
an
attorney.
1
FURTHER, please
take notice
that
financing
may
be available,
through the Illinois
Environmental Facilities Financing Act, 20 ILCS 3515/1 (2006), to
correct the pollution
alleged
in
the Complaint filed
in this case.
Respectfully submitted,
PEOPLE OF THE
STATE OF ILLINOIS
LISA MADIGAN,
Attorney
General of the
State of
Illinois
MATTHEW J.
DUNN, Chief
Environmental Enforcement/Asbestos
LWgatioi
Andrew
J.
icholas
Assistant
Attorney
General
Environmental Bureau
500
South Second Street
Springfield,
Illinois 62706
21 7/782-9031
Dated: November 6,
2008
2
CERTIFICATE
OF
SERVICE
I hereby
certify that I did
on
November
6,
2008, send
by
certified
mail, with postage
thereon
fully prepaid,
by depositing in
a
United
States
Post Office Box
a
true
and correct
copy
of the following
instruments
entitled NOTICE
OF FILING,
ENTRY OF APPEARANCE
and
COMPLAINT:
To:
Whalen
Manufacturing
Company
and
Yetter
Manufacturing
Company
do William
H. Campbell,
Registered Agent
Davis
& Campbell L.L.C.
401
Main Street
Suite 1600
Peoria, IL 61602-1241
and the original
and ten copies
by First Class Mail
with postage thereon
fully prepaid of
the
same
foregoing instrument(s):
To:
John
T. Therriault,
Assistant
Clerk
Illinois
Pollution Control
Board
James R.
Thompson Center
Suite 11-500
100 West
Randolph
Chicago, Illinois
60601
Andrhas’4
Assistant
Attorney General
This filing
is
submitted
on recycled
paper.
BEFORE THE ILLINOIS
POLLUTION CONTROL
BOARD
PEOPLE
OF
THE STATE OF
)
ILLINOIS,
)
Complainant,
)
vs.
)
PCBNo.
)
(Enforcement - Water)
WHALEN
an Illinois
MANUFACTURING
corporation, and YETTER
COMPANY,
)
)
ECEVED
CLERK’S
OFFICE
MANUFACTURING COMPANY, an
)
Illinois corporation,
)
NOV
12
2008
)
Respondents.
)
STATE
OF
ILLINOIS
Pollution
Control
Board
ENTRY OF APPEARANCE
On behalf of the
Complainant, PEOPLE OF THE STATE OF ILLINOIS, Andrew
J. Nicholas,
Assistant
Attorney General of the State
of Illinois,
hereby
enters his
appearance as attorney
of
record.
Respectfully
submitted,
PEOPLE OF
THE STATE OF ILLINOIS,
LISA
MADIGAN
Attorney
General
of the
State of
Illinois
MATTHEW
J.
DUNN,
Chief
Environmental Enforcement/Asbestos
Litigation Divisi
BY:_________________________
Andrew
Environmental
Bureau
Assistant Attorney General
500 South
Second Street
Springfield,
Illinois 62706
217/782-9031
Dated:
November 6, 2008
BEFORE
THE
ILLINOIS
POLLUTION
CONTROL
BOARD
PEOPLE OF THE STATE
OF
ILLINOIS,
)
Complainant,
)
v.
)
PCBNO.
0
)
(Enforcement
- Water)
WHALEN
MANUFACTURING
COMPANY,
an
)
Illinois
corporation
&
)
YETTER
MANUFACTURING
COMPANY,
an
)
Illinois
corporation,
)
Respondents.
)
GLE
o’3
2
200B
COMPLAINT
Sntrc60
Complainant,
PEOPLE
OF THE STATE
OF ILLINOIS,
by LISA MADIGAN,
Attorney
General of the State
of Illinois,
complains
of the Respondents,
WHALEN
MANUFACTURING
COMPANY and
YETTER MANUFACTURING
COMPANY (“Respondents”
collectively,
“Whalen”
and “Yetter” individually),
Illinois
corporations,
as
follows:
COUNT I
SPECIAL WASTE
PERMIT VIOLATIONS
- YETTER
MANUFACTURING
1.
This Complaint is
brought by the
Attorney General
on her own motion
and at
the
request
of the Illinois Environmental
Protection
Agency (“Illinois
EPA”),
pursuant
to the terms
and
provisions
of
Section
31 of the Illinois
Environmental
Protection Act
(“Act”), 415 ILCS
5/31
(2006).
2.
The Illinois EPA
is an agency
of the State of Illinois
created by
the Illinois
General Assembly in
Section 4
of
the Act, 415 ILCS 5/4
(2006),
and
charged, inter alia, with
the
duty
of enforcing
the Act.
3.
Whalen Manufacturing
Company
is, and was, at all
times relevant
to this
Complaint, an Illinois corporation in
good standing authorized
to do
business in
the State of
Illinois. On information and
belief Whalen is located at 1270 East
Murray Street, Macomb,
Illinois.
4.
Yetter Manufacturing
Company is, and was, at all times relevant
to this
Complaint,
an
Illinois corporation
in good standing
authorized to do business
in
the
State of
Illinois. On information and belief,
Yetter is located at 109
S. McDonough, Colchester, Illinois.
5.
On information and belief, Whalen
and Yetter are corporate affiliates.
6.
Whalen manufactures
outdoor fire pits and related equipment.
Yetter
manufactures
agricultural
equipment.
7.
Yetter uses coolants
and metal cleaning solutions during its
manufacturing
process. The coolants
are
used for a variety of metal working
machines. The cleaning
solutions contain
phosphoric acid and are
used
in the
parts
washer
and the wash bay to clean
and coat metal parts in preparation for painting.
8.
On February 8, 2006, the Illinois EPA inspected
the Yetter facility. The
inspector observed a 300-gallon plastic tank filled with liquid waste. It was
learned that wastes
from
the parts washer and the wash bay were collected into the 300-gallon
plastic
tank and
hauled to the
Whalen
facility in Macomb, Illinois.
9.
As of February 8, 2006, approximately 600 gallons of
waste solution
was
hauled
every 30 to 60
days. The liquid waste is dumped into
a
sanitary
sewer that
is tributary
to the
Macomb
sanitary system.
10.
As
of February
8,
2006, Yetter did
not have a
valid
nonhazardous special waste
hauling permit
issued by
the
Illinois
EPA.
11.
On
or
before February
8, 2006, Yetter hauled nonhazardous special waste
for
storage and/or
disposal to their Whalen facility
in Macomb.
2
12.
On
or before February 8,
2006, Yetter failed to use a manifest to ship
nonhazardous
special waste to Whalen.
13.
On or
before February 8, 2006, Yetter
delivered
special waste to a person who
did not have a
valid special waste
hauling permit.
14.
Section 809.201
of the Board’s Water Pollution Regulations, 35 Ill. Adm.
Code
809.201 (2005),
provides:
No person may
haul or otherwise transport any nonhazardous special waste
generated within Illinois
or
any
nonhazardous special waste
to be disposed of,
stored, or treated within
Illinois without
a current,
valid nonhazardous
special
waste
hauling permit issued by the Agency in accordance with the requirements
of this
Subpart unless the transporter participates in the Uniform Program or
is
exempt from the
nonhazardous special waste hauling permit requirements
under
this Subpart.
15.
Section 809.301 of the
Board’s Water Pollution Regulations,
35
Ill. Adm.
Code
809.301 (2005),
provides:
No
person may
deliver any special waste generated within
Illinois
or for disposal,
storage or treatment
within Illinois unless that person concurrently delivers
a
manifest completed in
accordance with Subpart E of this Part
to a
special
waste
transporter who holds a
current nonhazardous special waste hauling permit
or
Uniform Program
Registration
and Permit Issued
by the Agency under Subpart
B
or C of
this Part.
16.
Section 809.302(b) of the
Board’s Water Pollution Regulations,
35 III. Adm.
Code
809.302(b) (2005),
provides:
****
(b)
No
person may deliver special waste in Illinois for disposal, storage
or
treatment
unless
the person who accepts the special waste
has a current,
valid operating permit issued
by
the Agency and the
necessary
supplemental permits required by 35 III. Adm.
Code
807,
as
well
as all
other
applicable permits as required by the Act and Board regulations.
17.
Section 809.501(a) of the
Board’s
Water Pollution Regulations, 35 III. Adm.
Code
809.301
(2005),
provides:
(a)
Any person who
delivers
special waste to a permitted nonhazardous
3
special or hazardous waste transporter
shall complete
a
uniform
hazardous waste manifest to accompany the
special
waste from delivery
to the destination
of the
special
waste. The
manifest
form will be
provided
or
prescribed
by
the Agency.
18.
Seclion 21 of the Act, 415 ILCS 5/21 (2006),
provides,
in
pertinent part, as
follows:
No
person shall:
****
G)
“Conduct any
special waste transportation operation in violation of
any
regulations,
standards
or permit requirements adopted
by
the
Board under this
Act....”
19.
Yetter
is
a
“person” as
that
term is defined under Section 3.315
of the
Act,
415 ILCS 5/3.315 (2006), as
follows:
“Person” is any
individual, partnership, copartnership,
firm,
company,
corporation,
association, joint stock company,
trust,
estate,
political subdivision, state agency, or any
other legal entity,
or their legal
representative, agency or
assigns.
20.
Section 809.103 of the
Board’s Water Pollution
Regulations, 35 Ill. Adm. Code
809.103 (2005),
defines “nonhazardous
special waste” as
follows:
“Nonhazardous
special waste” means any
special waste, as defined in
this Section, that has
not been identified, by
characteristics or listing,
as
hazardous pursuant to
Section 3001 of the Resource
Conservation
and
Recovery Act of
1976 (42
USC
6901 et seq.) Or
pursuant to Board
regulations.
****
21.
Section 809.103 defines a
“special waste transporter” as
any person who transports
special waste (as defined in
Section 3.475
of
the Act) from any
location.
22.
Section 3.475 of the Act,
415 ILCS 5/3.475 (2006), provides in
pertinent
part, as
4
follows:
“Special waste”
means any of the following:
*** *
(c)
industrial process
waste
or pollution control waste...
****
23.
Yetter is
a
special
waste transporter
as that term is defined under Section
809.103 of the Board’s Water Pollution
Regulations, 35111. Adm. Code 809.103 (2005),
and
Section 3.475 of
the
Act,, 415 ILCS 5/3.475
(2006).
24.
By hauling or otherwise transporting nonhazardous
special
waste
generated
within Illinois without a current, valid nonhazardous
special waste hauling permit, Yetter violated
Section
809.201 of
the
Board’s
Regulations, 35 III. Adm. Code 809.201 (2005).
25.
By
delivering
non
hazardous special waste generated within Illinois
without
concurrently
delivering
a
manifest to a special waste transporter, Yetter violated
Section
809.301 of the
Board’s
Regulations, 35111. Adm. Code 809.301 (2005).
27.
By delivering nonhazardous
special waste in Illinois for disposal, storage or
treatment
to
a person who does not have
a current,
valid
operating permit issued by the Illinois
EPA,
Yetter has violated Section 809.302(b)
of the
Board’s Regulations,
35
III.
Adm. Code
809.302(b)
(2005).
28.
By conducting
a
special
waste transportation operation in violation of regulations,
standards or
permit requirements
adopted
by the Board under the Act, Yetter has violated
Section 21
(j)
of the Act,
415 ILCS 5/21
(j)
(2006).
PRAYER FOR RELIEF
WHEREFORE, Complainant, the PEOPLE OF THE STATE
OF
ILLINOIS,
respectfully
request that the Board enter an Order against the Respondent, YETTER MANUFACTURING
5
COMPANY:
A.
Authorizing
a hearing
in this
matter at which
time
the Respondent
will be
required to
answer the allegations
herein;
B.
Finding
that
the Respondent
has
violated
the Act and regulations
as
alleged
herein;
C.
Pursuant
to
Section 42(a)
of the Act, 415 ILCS
5/42(a)
(2006),
impose upon
the
Respondent
a
monetary penalty of
not more than the
statutory
maximum;
D.
Pursuant to
Section 42(f) of
the Act, 415 ILCS 5/42(f)
(2006), award
to
Complainant
its costs
and reasonable
attorney fees; and
E.
Grant
such
other relief as the Board
deems appropriate.
COUNT II
SPECIAL WASTE
PERMIT
VIOLATIONS
- WHALEN
MANUFACTURING
1-22.
Complainant
realleges and
incorporates
by
reference herein paragraphs
1
through 22 of
Count I as paragraphs
I
through
22 of this Count
Il.
23.
As
of February 8, 2006,
Whalen did
not
have
a
special waste
permit granted
by
the
Illinois EPA
to
store special
waste.
24.
As of
February 8,
2006, Whalen
did
not
have a Development
Permit granted
by
the
Illinois
EPA.
25.
As
of
February
8,
2006, Whalen
did not have an
operating permit granted
by the
Illinois
EPA to
use
or
operate
a new
solid waste facility.
26.
On
or
before
February
8,
2006, Whalen conducted
a
special waste
storage
operation
and
received
special waste
for storage, treatment
or disposal
from
Yetter.
27.
On or
before
February
8, 2006,
Whalen accepted
waste for storage, disposal
or
treatment
from
a
special
waste
hauler who did not have
a valid special waste
permit.
6
28.
Section 807.201 of the
Board’s
Water
Pollution Regulations,
35
III. Adm.
Code
807.201 (2005), provides:
Subject to such exemption as expressly
provided in
Section
2
1(e) (III.
Rev. Stat.
1988,
ch. 111 1/2, par. 1021(e))
of
the Act as to the
requirement
of obtaining
a
permit, no person shall cause or allow the
development of any new
solid
waste management site
or
cause or
allow
the
modification of
an existing solid waste management site without a
Development Permit issued by the Agency.
29.
Section 807.202(a) of the Board’s
Water
Pollution Regulations,
35
Ill.
Adm.
Code
807.202(a) (2005),
provides:
a)
New
Solid
Waste Management
Sites. Subject
to such exemption
as expressly provided in
Section
21(e)
of the
Act (Ill.
Rev.
Stat.
1982, ch. 1111/2, par. 1021(e)) as to the
requirement
of
obtaining a permit, no person shall cause or allow the use or
operation of any solid waste management site for which a
Development Permit is required under Section 807.201 without
an
Operating Permit issued
by the
Agency, except for such testing
operations
as may be
authorized
by
the Development Permit.
****
30.
Section
809.302(a)
of
the Board’s Water Pollution Regulations, 35 III. Adm.
Code
809.302(a)
(2005), provides:
a)
No
person
may accept
any special waste for disposal, storage
or
treatment within Illinois from
a
special waste transporter unless
the special waste transporter has a valid nonhazardous special
waste hauling permit or Uniform
Program Registration
and
Permit
issued by the Agency under Subpart
B
or J of
this
Part and
concurrently
presents to the
receiver
of the special waste,
or the
receiver’s
agent, a completed, signed
manifest as required
by
Subpart
E
of
this Part, which manifest designates the receiver’s
facility as the destination for the special waste.
31.
Section
21 of the Act, 415 ILCS 5/21 (2006),
provides,
in pertinent part:
No person
shall:
****
(d)
Conduct any waste-storage, waste-treatment, or waste-disposal
7
operation:
(1)
without
a permit granted by the
Agency...
****
(2)
in
violation of any regulations
or standards adopted
by the
Board under
this Act; or....
****
(e)
Dispose,
treat,
store or
abandon any waste, or transport any
waste
into this
State for disposal, treatment, storage or
abandonment, except
at a site or facility which meets
the
requirements of
this Act and of regulations and standards
thereunder.
32.
Section 3.470 of
the Act, 415 ILCS 5/3.470 (2006), defines “solid waste”
as
follows:
“Solid waste” means waste.
33.
Section 3.535 of the Act, 415 ILCS
5/3.535
(2006), defines “waste” in
pertinent
part as follows:
“Waste” means any garbage, sludge from a waste treatment plant, water
supply
treatment plant, or air pollution control facility or other discarded
material, including solid, liquid, semi-solid, or contained gaseous material
resulting
from industrial, commercial, mining and agricultural
opertations.
34.
Whalen is a
“person”
as that term is defined under Section 3.315 of the
Act,
415 ILCS 5/3.315
(2006),
as follows:
“Person” is
any
individual,
partnership, copartnership, firm,
company, corporation,
association, joint stock company, trust,
estate, political subdivision,
state agency, or any other legal entity,
or
their
legal
representative, agency or assigns.
35.
By
operating,
causing or allowing the development of a solid waste management
site without
a Development Permit, Whalen has violated
Sections
807.201(a) and 807.202(a)
of
the
Board’s Regulations, 35 Ill. Adm. Code 807.201 (a), 807.202(a)
(2005).
8
36.
By accepting special
waste for
disposal,
storage or treatment
within
Illinois from
a
special
waste
transporter
who does
not have a valid
nonhazardous special
waste hauling
permit, Whalen
has violated Section
809.302(a)
of the Board’s Regulations,
35 III. Adm.
Code
809.302(a)
(2005).
37.
By conducting
a waste storage
operation, Whalen
has violated
Section 21(d)
of
the Act, 415 ILCS
5/21(d) (2006).
38.
By disposing, treating,
storing
or abandoning
any waste, Whalen
has
violated
Section 21(e)
of the
Act,
415
ILCS
5/21(e) (2006).
PRAYER
FOR
RELIEF
WHEREFORE, Complainant,
the PEOPLE
OF THE
STATE
OF
ILLINOIS,
respectfully
request
that the
Board
enter an Order
against
the Respondent,
WHALEN
MANUFACTURING
COMPANY.
A.
Authorizing
a hearing
in this matter
at
which
time the
Respondent will
be
required
to answer the allegations
herein;
B.
Finding
that the Respondent
has violated
the Act and regulations
as alleged
herein;
C.
Pursuant to Section
42(a) of the
Act,
415
ILCS 5/42(a)
(2006), impose
upon the
Respondent
a
monetary
penalty of not more
than the statutory
maximum;
D.
Pursuant to Section
42(f) of the Act, 415
ILCS
5/42(f)
(2006), award
to
Complainant
its costs and
reasonable
attorney
fees; and
E.
Grant
such
other
relief
as
the
Board deems appropriate.
COUNT III
NPDES
PERMIT
VIOLATIONS
- WHALEN MANUFACTURING
& YETTER
MANUFACTURING
1-22.
Complainant
realleges and
incorporates
by reference herein
paragraphs
I
9
through 22 of Count I as paragraphs I through 22 of
this
Count 1W.
23.
As
of February
8,
2006,
Yetter did not have an National Pollutant Discharge
Elimination
System
(“NPDES”)
permit.
24.
As of February
8,
2006, Whalen
did not have an NPDES permit.
25.
As of February 8, 2006, Yetter hauled approximately
600
gallons
of waste
solution every 30 to 60 days to Whalen.
26.
On
or before February
8,
2006,
Whalen dumped the waste solution into
a
sanitary
sewer that is a
tributary
to the Macomb sanitary system.
27.
Section 12(f) of the Act,
315
ILCS
5/12(f)
(2006), provides
the following
prohibitions:
No person shall:
(f)
Cause, threaten or allow the discharge of
any contaminant into
the waters of the
State, as
defined herein, including
but not limited
to,
waters to any sewage works, or into any well
or from any
point
source within the
State, without an
NPDES
permit for point source
discharges
issued by the Agency under Section 39(b) of this
Act,
or in violation
of any term or condition imposed by such permit,
or
in violation
of any NPDES
permit
filing
requirement
established
under Section
39(b), or
in violation
of any regulations adopted
by
the Board or
of any order
adopted
by the Board with respect
to
the NPDES program.
28.
Section 3.165 of the Act, 415 ILCS 5/3.165 (2006), defines “contaminant,”
as
follows:
“Contaminant”
is any
solid, liquid, or
gaseous matter, any odor, or any
form of
energy,
from whatever source.
29.
Section 309.204(a) of the Board’s Water Pollution Regulations, 35
Ill.
Adm.
Code
309.204(a)
(2005), provides:
(a)
No person shall
cause
or allow
the
use
or operation of any
treatment works,
pretreatment
works
or
wastewater
source
without
an
operating
permit issued by the Agency, except as
provided
in
subsections
(b), (c) and (d).
10
(b)
No operating permit is required under
this
Section for
any
discharge:
(1)
For which
an
NPDES
permit is required;
or...
****
30.
By causing, threatening
or allowing the discharge of contaminants into waters
of
the State without a
valid NPDES
permit, Whalen
and Yetter have violated Section 12(f) of
the
Act, 415 ILCS 5/12(f) (2006).
31.
By causing
or
allowing
the use or operation of
a treatment works, pretreatment
works or wastewater source without an NPDES
permit, Whalen and Yetter have violated
Section 309.204(a) of the Board’s
Regulations, 35 Ill. Adm. Code 309.204(a) (2005).
PRAYER
FOR
RELIEF
WHEREFORE,
Complainant, the PEOPLE
OF THE STATE OF ILLINOIS, respectfully
request that the
Board
enter an Order against the Respondents, WHALEN
MANUFACTURING
COMPANY and
YETTER MANUFACTURING
COMPANY:
A.
Authorizing a hearing
in this matter at which time the Respondent will be
required to
answer the allegations herein;
B.
Finding that the Respondents have
violated
the
Act and
regulations
as alleged
herein;
C.
Pursuant to Section 42(a)
of the Act, 415 ILCS 5/42(a) (2006), impose
upon the
Respondents a
monetary penalty of
not more than the statutory maximum;
D.
Pursuant to Section 42(f)
of the Act, 415 ILCS 5/42(f) (2006), award to
Complainant its costs
and reasonable
attorney fees;
and
E.
Grant such other relief
as the Board deems appropriate.
11
Respectfully
submitted,
PEOPLE
OF THE STATE
OF
ILLINOIS,
ex rel. LISA MADIGAN,
Attorney General
of the
State of Illinois
MATTHEW
J.
DUNN,
Chief
Environmental
Enforcement/Asbestos
Litigation Division
BY:
THOMAS E.
DAVIS, Chief
Environmental
Bureau
Assistant
Attorney General
Of
Counsel:
ANDREW J. NICHOLAS
500
South Second Street
Springfield, Illinois 62706
217/782-9031
Date:
f
12
