Guidelines For Water Line Repairs And Replacements In .

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Guidelines for Water LineRepairs and Replacementsin Areas with Lead ServiceLinesPWS-06-001Division of Drinking and Ground WatersIssued: November 1, 2018

PWS-06-001: Guidelines for Water Line Repairs and Replacements in Areas with Lead Service Lines1.2018IntroductionThe purpose of this document is to provide guidance to public water systems (PWSs) with public (systemowned) or private (customer owned) lead service lines (LSLs) on how to achieve simultaneous compliancewith the requirements of Ohio Administrative Code (OAC) Rule 3745-81-84 – Lead Service LineRequirements and OAC Rule 3745-83-02 – Disruption of Service. Each of these rules have specific leadnotification requirements, as well as other required actions involving water line work of various types. Thisguidance document will outline the steps a PWS must take depending on the type of work being done andwhere it occurs.This document first establishes the requirements for disruptions of service and water main repairs. Next, itoutlines the requirements for water main replacements in areas of LSLs; both planned, and emergencyreplacements are discussed. Should an emergency replacement be required, systems may have to meet therequirements of both OAC Rule 3745-81-84 and 3745-83-02. The document then explains what actions arerequired during an LSL replacement. When systems perform LSL replacements in conjunction withdisruptions of service or planned water main replacement projects, the requirements of all correspondingrules must be met. This document provides guidance for water systems to achieve simultaneous compliancewith these regulations.This guidance was written in consultation with the Ohio Section of American Water Works Association(AWWA) who provided valuable insight for its development.1.1BackgroundThere is some evidence that when LSLs are disturbed, particulate lead may be released into the drinkingwater, potentially reaching the consumer’s tap. OAC Rules 3745-81-84 and 3745-83-02 introduced newrequirements that PWSs notify consumers in areas of LSLs when water line work may disturb these leadlines. There are also requirements for the PWS to notify affected consumers with a boil water notice ordrinking water advisory if contamination or a potential for contamination exists when a PWS is conductinga water main repair or a depressurization occurs. This guidance document will assist PWSs in integrating thesubstantive requirements of these rules into existing standard operating procedures for water line repairsand replacements. The Division of Drinking and Ground Waters issued this draft on August 21, 2018.1.2Table of Contents1.Introduction . 12.Disruption of Service Summary Tools . 23.Overview of Applicable Regulations . 54.Disruption of Service Events in Areas of Lead Service Lines. 65.Water Main Replacements in Areas of Lead Service Lines . 106.Lead Service Line Replacements . 137.Drinking Water Treatment Unit Filters . 178.Simultaneous Compliance Examples . 19Appendix A: Approved Lead Language . A-1Appendix B: Optional Lead Awareness Campaign . B-1Appendix C: Disruption of Service Lead Notification Templates . C-1Appendix D: Pre-Construction Notification Templates . D-1Appendix E: Lead Service Line Sample Request Templates .E-1Appendix F: Ohio EPA Contact Information. F-11

PWS-06-001: Guidelines for Water Line Repairs and Replacements in Areas with Lead Service Lines1.32018DefinitionsBelow are definitions of terms used throughout this guidance document.Table 1: DefinitionsOAC Rule 3745-83-02Affected Area(Main Repair)The portion of the distribution system where the pressure of the system has dropped below 20 poundsper square inch gauge (psig) at ground level.Main RepairAny incident that requires the installation of pipe which does not exceed one section of pipe or 20feet when using fusible pipe material.Main ReplacementAny incident that requires installation of pipe which exceeds one section of pipe or 20 feet when usingfusible pipe material. An emergency main replacement is a disruption of service that requires thereplacement of more than one section of pipe.OAC Rule 3745-81-84Full LSLReplacementReplacing both the PWS-owned portion of the LSL and the consumer-owned portion of the serviceline or replacing the entirety of the portion of the service line made of lead where no lead pipe remainsin any portion of the service line.Impacted Area(Main Replacement)Any service lines that are moved, replaced, or reconnected to the main during the main replacement.Impacted Area(LSL replacement)Buildings, residences, or lines served by the service line being replaced (either partially or fully)Partial LSLReplacementReplacing only the portion of an LSL necessary to make the repair and/or reconnection to a serviceline or the replacement of just the portion of an LSL owned by the water system, where lead piperemains in any portion of the service line between the water main and the structure.Main ReplacementAny incident that requires installation of pipe which exceeds one section of pipe or 20 feet when usingfusible pipe material. An emergency main replacement is a disruption of service that requires thereplacement of more than one section of pipe.2.Disruption of Service Summary ToolsOhio EPA has developed several tools and templates for water systems to comply with these regulations.Figure 1: Disruption of Service Summary Flowchart provides an overview of the utility-to-consumernotification requirements for different types of events. This flowchart is interactive; depending on thescenario, users can click on the text to be directed to the appropriate notification template. All notificationtemplates, as well as Ohio EPA-approved language for the notifications, can be found in the appendices at theend of this document. Table 2: Disruption of Service Summary Table outlines the OAC requirements fordifferent types of line work, including disruption of service events, main replacements, and LSLreplacements. The headings in Table 2 link to the corresponding sections of this guidance.2

PWS-06-001: Guidelines for Water Line Repairs and Replacements in Areas with Lead Service LinesNo additionalnotificationrequired by OhioEPA.2018No notificationrequired by OhioEPA.FullPrior notification(45 days)**including requiredlead language.Filters, service linesamples, andconsumer notice ofresults required forall residents servedby the partial LSL.Are lead servicelines in theaffected area?NoYes orUnknownType 1***Disruption ofServicePartialNoDoes your PWSimplement anoptional leadawarenesscampaign?Notify owner ofintention toreplace line andoffer to completea full LSLreplacement.Lead ServiceLineReplacement*YesWhat type ofevent?RepairPrior notification(45 days)**including requiredlead language andfilters for all usersin the impactedarea.YesNoEmergencyReplacement*NoAre lead servicelines in theimpacted area?Notification includinglead language requiredfor all users in theaffected area.Ensure your PWS meetsthe optional leadawareness campaignminimum requirements.Boil/Water Use Advisoryincluding lead languagefor all users in affectedarea.Will this require aline repair or aline replacement?Will any part of anyLSL in the impactedarea be replaced?*Yes orUnknownNo notificationrequired by OhioEPA.Notification required forcritical users only, inaccordance with yourcontingency plan.Yes orUnknownPlannedWater MainReplacementType 3 or 4Disruption ofServiceAre lead servicelines in theaffected area?NoBoil/Water Use Advisoryincluding required leadlanguage for all users inthe affected area. Filtersrequired for users inimpacted area.Boil/Water Use Advisoryfor all users in affectedarea.*If an LSL is replaced in conjunction with a disruption of service event, LSL replacement requirements must be met for those served by the line.**Less than 45 days’ notice is allowed in instances of emergency repairs, emergency replacements, or other mitigating circumstances.*** If pressure is not monitored during what would otherwise be considered a Type 1 or Type 2 repair, a Type 3 response must be conducted as a precaution, including Type 3 notification requirements.Figure 1: Disruption of Service Summary Flowchart3 CLICK FOR LINKS TO TEMPLATES CLICK FOR LINKS TO TEMPLATES Will it be a fullor partial LSLreplacement?Type 2***Disruption ofService

PWS-06-001: Guidelines for Water Line Repairs and Replacements in Areas with Lead Service Lines2018& ElevationDefinitionTable 2: Disruption of Service Summary TableType 1 EventType 2 EventControlled pipe repair wherepositive pressure is continuouslymaintained during the repair andthere are no signs of contamination.Controlled repair of a distribution systemcomponent where positive pressure ismaintained until a controlled shutdown ofaffected area can be completed and thereare no signs of contamination.Elevate to Type 2 if Type 1 eventresponse cannot be completed.Elevate to Type 3 if Type 2 event responsecannot be completed.Documentation & Repair/ReplacementOhio mpleDisruption of service or water linerepair where there is a loss ofpressure at repair site and localizeddepressurization adjacent to repair,an uncontrolled shutdown, and/orthere are signs of possiblecontamination intrusion.Type 4 EventMain ReplacementLSL ReplacementCatastrophic failure with widespreaddepressurization in the system oractual contamination intrusion.Newly constructed potablewater main or disruptionof service requiring theuse of more than onelength of pipe (or 20 feetwhen dealing with fusiblematerial).A partial LSL replacement occurs whenonly the portion of an LSL necessary tomake the repair and/or the portion ofan LSL owned by the water system isreplaced, where lead pipe remains inany portion of the service line betweenthe water main and the structure. Aftera full LSL replacement, no lead piperemains in any portion of the serviceline.Elevate to Type 4 if event cannot belocalized to area adjacent to repair.Note: Elevate to Type 3 if pressure is not monitored upstream and downstream or someother Director approved method is not used.FiltersType 3 EventNote: If a Type 3 or 4 event requires greater than one length of pipe, replacement requirements must also be met.Note: If LSLs are replaced during a mainreplacement or disruption of service, LSLreplacement requirements must also be met. Monitor and record pressureupstream/ downstream of repair orfollow director approved procedure. Excavate below repair and maintainpit water level below repair Repair under positive pressure anddisinfect using AWWA StandardC651-14 Section 4.11.3.1 Test chlorine residual or verifydisinfectant presence Monitor and record pressureupstream/downstream of repair or followdirector approved procedure. Excavate below repair and maintain pitwater level below repair Conduct controlled shut-down of affectedarea and disinfect using AWWA StandardC651-14 Section 4.11.3.2 Test chlorine residual or verify disinfectantpresence Disinfect, repair, and flush usingAWWA Standard C651-14 Section4.11.3.3 Test for chlorine residual and complywith minimum chlorine residual Disinfect, repair, and flush usingAWWA Standard C651-14 Section4.11.3.3 Test for chlorine residual and complywith minimum chlorine residual As applicable, comply withAWWA Standard C651-14 Test for chlorine residualand comply with minimumchlorine residual As applicable, comply with AWWAStandard C651-14 Ohio EPA recommends completing all LSLreplacements in accordance with AWWAStandard C810-17 Replacement andFlushing of Lead Service Lines Document Type 1 response afterrepair in operation and maintenancerecords Document Type 2 response after repair inoperation and maintenance records Document possible contamination Notify Ohio EPA as soon as possible,but within 24 hours if disruption affects10% of users or more than 100 serviceconnections Document Type 3 response throughoutand submit to Ohio EPA following event Document actual contamination In consultation with Ohio EPA as soonas possible, but within 24 hours ifdisruption affects 10% of users ormore than 100 service connections Document Type 4 responsethroughout and submit to Ohio EPAfollowing event For water mainreplacements in areas thatcontain or are likely tocontain LSLs, comply withrecord keepingrequirements of OAC Rule3745-81-90(J). Comply with record keeping andreporting requirements of OAC Rule 37481-90 None Notify critical users as soon as possible, butwithin 24 hours Notify users in areas of LSLs unless utilityhas an Optional Lead Awareness Campaign Issue precautionary boiladvisory/water use advisory toaffected users as soon as possible, butwithin 24 hours in accordance withcontingency plan process Notify users in areas of LSLs Issue boil advisory/water useadvisory to affected users as soon aspossible, but within 24 hours inaccordance with contingency planprocess Notify users in areas of LSLs Notify consumers inimpacted areas 45 days inadvance (or less during anemergency) None None Special purpose Total Coliform samples Special purpose Total Coliformsamples Sample using AWWAStandard C651-14 Section5.1 All LSL replacements: notify owner of theintention to replace the PWS-ownedportion of the SL, and offer to replacecustomer-owned portion Partial LSL Replacement: notifyconsumers served by the line 45 days inadvance (or less during an emergency) LSL sample following a partial LSLreplacement None None In areas of LSLs, required if more thanone pipe length is used andreplacement requirements must also bemet Required if an LSL is partially replacedand LSL requirements must be met In areas of LSLs, required if more thanone pipe length is used andreplacement requirements must alsobe met Required if an LSL is partially replacedand LSL requirements must be met Required for consumers inthe impacted area in areasof LSLs (SLs served byreplaced main), unless nolead remains on public orprivate side4 Full LSL replacement: None Partial LSL replacement: Required tothose served by SL

PWS-06-001: Guidelines for Water Line Repairs and Replacements in Areas with Lead Service Lines3.2018Overview of Applicable RegulationsPWSs with LSLs (public or private) in their distribution are required to comply with multiple rules that areinterwoven with one another. This guide will assist PWSs in achieving simultaneous compliance with thelead notification requirements required during water line repairs and replacements. This section outlinesthe regulations discussed in this guide.3.1OAC Rule 3745-83-01: Operational RequirementsThis rule establishes the disinfection requirements for water mains prior to being placed into service or aftera disruption of service. PWSs are required to meet the requirements of American Water Works (AWWA)Standard C651-14 Disinfecting Water Mains and monitor and comply with their minimum chlorine residual.3.2OAC Rule 3745-83-02: Disruption of ServiceIf a PWS is unable to maintain a minimum pressure of 20 pounds per square inch gauge (psig) at all pointsin the distribution system, the incident is considered a disruption of service. This rule establishes additionalrequirements for PWSs that experience a disruption of service, beyond those established in OAC Rule 374583-01. Depending on the type of disruption event, a PWS is required to follow a specific procedure to disinfectthe line, make the repair, notify the public, and document the response to Ohio EPA.Additionally, OAC Rule 3745-83-02 specifies the difference between a water main repair and a water mainreplacement and outlines specific consumer notification requirements for PWSs completing a water mainrepair in an area that contains or is likely to contain LSLs.3.3OAC Rule 3745-81-84: Lead Service Line RequirementsThis rule outlines requirements for PWSs conducting a water main replacement in an area that contains oris likely to contain LSLs. Systems are required to provide prior notice of the work to be performed and offera drinking water treatment unit filter to consumers in the affected area.OAC Rule 3745-81-84 also establishes individual LSL replacement requirements. When a system is planningan LSL replacement, with or without a water main replacement, the system must first provide the owner aprior notice of the work to be performed and offer to replace the private side of the service line (may be atproperty owner’s expense). If the owner declines the offer and the PWS conducts a partial LSL replacement,the PWS must collect a service line sample following the replacement and offer a drinking water filtercertified to remove lead.3.4OAC Rule 3745-81-85: Public Education, Supplemental Monitoring Requirements,and Consumer Notification of ResultsWhenever a lead and copper sample is taken, PWSs are required to issue a consumer notice (CN) of resultsto the owner and those served by the line within two business days of receiving the laboratory results. Thisrule also outlines the mandatory lead public education requirements following an action level exceedance;some language from these requirements may be useful in establishing an optional lead awareness campaign.3.5OAC Rule 3745-81-86: Monitoring Requirements for Lead and Copper in Tap WaterThis rule established LSL mapping requirements for all community water systems. In addition, watersystems must sample for lead and copper in accordance with this rule, including service line samplesfollowing a partial LSL replacement.3.6OAC Rule 3745-81-90: Reporting and Record Keeping RequirementsThis rule outlines the reporting and record keeping requirements for the rules controlling lead and copper.PWSs shall retain all information required by the rules for no fewer than 12 years.5

PWS-06-001: Guidelines for Water Line Repairs and Replacements in Areas with Lead Service Lines4.2018Disruption of Service Events in Areas of Lead Service LinesIn the event a PWS is unable to maintain a minimum pressure of 20 psig at ground level at all points in thedistribution system, the incident shall be deemed a disruption of service. Disruptions of service are split intofour types, depending on the potential for risk to human health. A Type 1 disruption of service eventrepresents the least amount of risk and a Type 4 disruption of service event represents a catastrophic failurewith widespread depressurization in the distribution system or contamination intrusion.When responding to a disruption of service event, PWSs must comply with OAC Rule 3745-83-02, whichstates: “in affected areas that are known or likely to contain LSLs, that experience a disruption of serviceevent, PWSs shall provide public notification as follows: in areas where repairs are conducted in Type 2, 3,and 4 events, the PWS shall provide a notice acceptable to the director; in areas where replacement isconducted, the PWS shall comply with provisions contained in [OAC Rule 3745-81-84].” These provisionsinclude a lead notice and the offer of drinking water treatment unit filters to consumers in the impacted area.To be considered a water main repair, a water system must use acceptable repair methods and may not usemore than one length of pipe when responding to the event; refer to Section 1.3: Definitions for moreinformation on the differences between a water main replacement and water main repair. Water mainreplacement requirements are discussed further in Section 5: Water Main Replacements in Areas of LeadService Lines; however, if a water main replacement is needed in response to a disruption of service event,systems will be required to meet the requirements of both Section 4 and Section 5 to be in compliance withthe rule.OAC Rule 3745-83-02 requires notifications and/or advisories depending on the disruption of service eventtype, response, and location. Table 3: Disruption of Service Notification Requirements gives a generaloverview of these requirements and the rest of this section details the specific requirements for leadnotification. Appendix C: Disruption of Service Lead Notification Templates includes sample templates forthis section.Table 3: Disruption of Service Notification RequirementsEventTypeResponseLocationType 1RepairAnyNo LSLsType 2RepairRepair orReplacementType 3 orType 4RepairReplacementConsumer Notification RequirementsNone.Notify consumers who have a critical need of water.Areas thatcontain or arelikely to containLSLsNotify all users in affected area of work to be performed includingapproved lead language OR notify Critical Users and meet theminimum requirements for an Optional Lead AwarenessCampaign.No LSLsIssue a boil water or water use advisory (precautionary or actual)to all potentially affected consumers.Areas thatcontain or arelikely to containLSLsAreas thatcontain or arelikely to containLSLsIssue a boil water or water use advisory (precautionary oractual), including approved lead language, to all potentiallyaffected consumers.Issue a boil water or water use advisory (precautionary or actual)to all potentially affected consumers and meet the requirementsof OAC Rule 3745-81-84*.*Note: the lead notification requirements of 81-84 may be integrated into the boil water/water use advisory; see Section 5 foradditional information on the requirements for water main replacements.6

PWS-06-001: Guidelines for Water Line Repairs and Replacements in Areas with Lead Service Lines4.12018Affected AreaThe affected area for a disruption of service event is the portion of the distribution system where thepressure drops below 20 psig at ground level. The affected area can be determined using pressure gauges,or another method acceptable to the director. In affected areas that are known or likely to contain LSLs,utilities completing Type 2, 3, or 4 repairs are required to issue a public notification acceptable to thedirector.Utilities can determine if the affected area is known or likely to contain LSLs by using their lead maps.Guidance on developing these maps using historical records, maintenance records, customer self-reportingand other information is detailed in Ohio EPA’s PWS-04: Guidance for Lead Mapping in DistributionSystems. Areas listed as “unknown” on the map are considered to be areas of LSLs for lead notificationpurposes, unless the system can verify otherwise. Maps should be easily accessible and updated regularly sothat systems can easily respond to disruption of service events.4.2Notice RequirementsNotices may be required during a disruption of service event, regardless if the affected area contains or islikely to contain LSLs. If the affected area contains or is likely to contain LSLs, a lead notice may also berequired. Table 3 offers a summary of the notification requirements for disruptions of service.Type 1 Disruption of Service EventA Type 1 event is “a controlled pipe repair where positive pressure is continuously maintained during therepair, and there are no signs of contamination intrusion. No notice to consumers is required during Type 1events, even if the affected area contains or is likely to contain LSLs.Type 2 Disruption of Service EventA Type 2 event is “a controlled repair of a distribution system component where positive pressure ismaintained until a controlled shutdown of the affected area can completed, and there are no signs ofcontamination intrusion.” In areas documented to not have LSLs, PWSs are required to notify critical usersin the affected area in accordance with the PWS’s contingency plan. However, in affected areas that containor are likely to contain LSLs, utilities are required to provide a lead notification acceptable to the director.Notices should be delivered to users in the affected area in advance of the repair or as soon as possible (ASAP)but within 24 hours of the repair.For Type 2 disruption of service events only, Ohio EPA will consider an Optional Lead Awareness Campaignto serve as the notification acceptable to the director. In order for a utility to use the campaign in lieu ofdirect-consumer notification during a Type 2 event, the campaign must meet the minimum requirementsoutlined in Section 4.4: Optional Lead Awareness Campaign Requirements. More information on thiscontent of this program can be found in Appendix B: Optional Lead Awareness Campaign.Type 3 or Type 4 Disruption of Service EventA Type 3 event is “a disruption of service or water line repair where there is one or more of the following: aloss of positive pressure at the repair site and localized depressurization adjacent to the repair prior to acontrolled shutdown; an uncontrolled shutdown; or there are signs of possible contamination intrusion.” AType 4 disruption of service event means “a catastrophic failure with widespread depressurization in thesystem or actual contamination intrusion.” During Type 3 and 4 disruption of service events, consumers mustbe directly notified with either a boil water advisory or a water use advisory. In affected areas that containor are likely to contain LSLs, utilities are required to include within the advisory a lead notification acceptableto the director. Notices must be delivered as soon as possible but within 24 hours of the disruption of service.7

PWS-06-001: Guidelines for Water Line Repairs and Replacements in Areas with Lead Service Lines4.32018Lead Notice Language for Disruption of Service EventsLead notices must include language acceptable to the director. At a minimum, the notice must explain thatthe work being performed may cause a temporary increase in the lead levels in drinking water and provideguidance on measures the consumers can take to reduce lead levels at the tap. Refer to Appendix A:Approved Lead Language for language that is acceptable to the director for use during a disruption ofservice event.Should an affected area that contains or is likely to contain LSLs experience a disruption of service thatrequires a water main replacement, systems must also comply with the provisions contained in OAC Rule3745-81-84. These provisions require a lead notice to consumers in the impacted area that offers drinkingwater treatment unit filters to consumers in the impacted area in addition to explaining that the work beingperformed may cause a temporary increase in the lead levels in drinking water and providing guidance onmeasures the consumers can take to reduce lead levels at the tap. More information on main replacementrequirements can be found in Section 5.Example templates with acceptable lead language are included in Appendix C. The highlighted portion in thetemplates include the approved lead language and should be used in its entirety. Systems should, however,remove the additional filter language when a water main repair is conducted. Beyond this change, if a systemwishes to modify the highlighted section, the PWS must gain approval from its district office prior to sendingthe notice to consumers. PWSs are strongly encouraged to modify the non-highlighted portion of the noticesto include information specific to the event.4.4Optional Lead Awareness Campaign RequirementsIf a PWS wants to use this voluntary program in lieu of completing direct consumer notification during Type2 disruption of service events, the system will be required to implement an optional lead awarenesscampaign. More information on creating and implementing an optional lead awareness campaign can befound in Appendix B. At a minimum, systems must: 4.5Implement at least 3 types of consumer awareness activities.o 1 high impact print material that includes Type 2 notification language (Appendix A.2).o 1 other type of activity with high consumer education impact.o 1 other activity from Table B.1: Consumer Awareness Activities.Submit a Lead Awareness Campaign Certification Form (Appendix B.4) to Ohio EPA yearly with thePWS’s Consumer Confidence Report (CCR).Include an explanation of the campaign annually in the CCR.o Include information as to where consumers can find the mater

Nov 01, 2018 · AWWA Standard C651-14 Section 4.11.3.3 Test for chlorine residual and comply with minimum chlorine residual AWWA Standard C651-14 Section 4.11.3.3 Test for chlorine residual and comply with minimum chlorine residual As applicable, comply with AWWA Standard C651-14 Test for chlorine residual and comply with minimum chlorine residualFile Size: 1MB

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