2006 - Spring (PDF: 521KB/6 pages)

Upcoming Water Operator
Certification Exam Dates
Disinfection Byproducts/Surface
Water Rules Take Effect
By David Rindal
The U. S. Environmental Protection Agency (EPA)
administrator signed notices for final versions of the Stage 2
Disinfectants and Disinfection Byproducts Rule (Stage 2
DBPR) and the Long Term 2 Enhanced Surface Water
Treatment Rule (LT2 ESWTR) on December 15, 2005.
The tables below outline upcoming deadlines for the rules,
which strengthen protection against microbial contaminants,
especially Cryptosporidium, and potential health risks of
DBPs. They also include significant public water system
(PWS) monitoring requirements prior to the standard threeyear post-rule period. EPA has developed web-based data
collection and analysis tools that are expected to facilitate
compliance with its early implementation provisions.
March 9, St. Cloud
March 31, Rochester
April 4, Wells
April 7, Bloomington
April 28, Grand Rapids
June 9, Deerwood
See calendar on back page for more details
For more on the rules, go to page 6 >>>
Initial Distribution System Evaluation (IDSE)
Imminent Stage 2 DBPR Deadlines
40/30 Certification OR
Standard Monitoring Plan OR
System Specific Study Plan
Complete IDSE
(if no 40/30)
Submit IDSE Report
(if no 40/30)
Community Water Systems (CWS)
serving at least 100,000 AND all
consecutive systems (9 in Minnesota)
October 1, 2006
September 30, 2008
January 1, 2009
CWSs serving 50,000-99,999 AND all
consecutives (2 in Minnesota)
April 1, 2007
March 31, 2009
July 1, 2009
CWSs serving 10,000-49,999 AND all
consecutives
October 1, 2007
September 30, 2009
January 1, 2010
Imminent LT2 ESWTR Deadlines
Submit Source Water
Monitoring Sampling
Schedule
Begin Source Water
Monitoring
End Source Water
Monitoring
Surface Water PWSs serving at least
100,000 (2 in Minnesota)
July 1, 2006
October 1, 2006
September 30, 2008
Surface Water PWSs serving 50,000-99,999
(2 in Minnesota)
January 1, 2007
April 1, 2007
March 31, 2009
Surface Water PWSs serving 10,000-49,999
January 1, 2008
April 1, 2008
March 31, 2010
Public Water Systems (PWS)
Public Water Systems
Spring 2006
Volume Thirteen/4
Inside: Agendas for Spring Water Operator Schools
Ely SWAMP Becomes a Training Haven
Below-Market-Rate Loans for Public Water Systems
Training News
2006 Metro School
The 2006 Metro Waterworks Operators School will be held from Wednesday, April 5 through Friday, April 7 at the Ramada
Mall of America and Thunderbird Convention Center in Bloomington. The certification exams will be held on Friday
afternoon, and a representative from the University of Minnesota Raptor Center will bring various raptors, including an eagle,
and make a presentation during the breakfast that morning. Participants in the school will receive 16 credit hours for their
attendance at the school. The registration for the school is $135 ($170 after March 24 or at the door).
Registration will begin at 7 a.m. on April 5 with the sessions beginning at 8 a.m.
A registration form is on page 7. Those wishing to stay at the Ramada Inn can make guest room reservations by calling the
hotel at 952-854-3411 by March 17. Mention AWWA to get the rate of $86 + tax per night.
Wednesday, April 5
Friday, April 7
8:00-11:30
• Water Installation in a Remote Village in Tanzania
and Water for People
7:30 Breakfast
Minnesota AWWA Section Chair
John Lapointe
• Meth Labs
•
•
•
•
Speaking Program:
University of Minnesota Raptor Center
•
12:30-3:30
Concurrent Session I
• Chlorine and Ammonia
• Testing of Chlorine, Phosphate, and Fluoride
• Chemical Feed
• Chlorine Safety
9:00 Product Exposition with Mini-Sessions
10:30 TopOps Competition
or
9:00 Study Session
•
or
•
•
•
•
12:30 to 3:00
• Certification Exams
Concurrent Session II
• Dig Safely
• Web-based Ticket Management
• Records Retention
• Maps and Recordkeeping
For updates on the Metro School agenda, as well
as agendas for other district schools, go to
http://www.mnawwa.org/section/districtschools.html
or
New Home for Metro School in 2007
Thursday, April 6
After many years at the Thunderbird Hotel in Bloomington,
the Metro District school will be moving to the Earle Brown
Heritage Center in Brooklyn Center starting in 2007.
A sharp increase in meeting room costs at the Thunderbird
made the move necessary. The 2007 school will be held
from Wednesday, April 18 to Friday, April 20.
Exam Study Session
7:30 to 11:00
Concurrent Session I
• What Do You Do When OSHA’s at Your Door?
• Workplace Violence Prevention
• Fall Protection
• Emergency Planning Issues
Change in Date for
Spring Teleconference
The American Water Works Association teleconference
originally scheduled for Thursday, March 9 is now scheduled
for Thursday, March 16. The topic will be Innovative
Operator Tools with a focus on SCADA, automated meter
readings, and geographic information systems. The
downlink locations serving the Minnesota Section will be the
Minnesota Department of Health (Snelling Office Park) in
St. Paul, Memorial Union Hall on the campus of the University of North Dakota in Grand Forks, and Lake Superior
College in Duluth. Participants will receive 4 contact hours.
A registration form is on page 7. Additional information is
available at http://www.awwa.org/Education/teleconf/
teleconfsites.cfm.
or
Concurrent Session II: Wells
or
Exam Study Session
•
•
•
•
•
11:45-3:30
Off-site sessions (choice of one)
• Waterous
• St. Paul Meter Shop
• Eagan, Bloomington, Lakeville, Minneapolis Water Plants
2
Spring 2006 Schools
Other spring schools are the Southeast School, March 29-31 at the Ramada Hotel and Conference Center (formerly the
Best Western Apache), Rochester; Southwest School, April 4; Northeast School, April 26-28 at Ruttger’s Sugar Lake Lodge
in Grand Rapids; and Central School, June 6-9 at Ruttger’s Bay Lake Lodge in Deerwood.
For the Northeast School, Ruttger’s is holding a block of rooms until March 26 at the rate of $65.70 per night for a studio
room and $104.03 per night for a lodge room (prices include tax). Attendees may call 1-800-450-4555 and mention American
Water Works Association to get the special rate.
For the Central School, licensed operators in the region will receive a school and lodging registration form in the mail.
Others may obtain one by contacting Jeanette Boothe at 651-201-4697 or via e-mail at [email protected].
Below are agendas for the Southeast and Northeast schools. A registration form for the schools is on page 7.
Southeast School Agenda
Northeast School Agenda
Wednesday, April 26, 2006
8:45-noon
• Grant Monies
• Water System Security
• Minnesota Department of Health Update
• Water Resources Program
or
Wednesday, March 29, 2006
8:00-11:30
• Panel: Southeastern Minnesota Water Systems
• Water System Security
• Iron and Manganese Operation & Maintenance
• Water for People
or
Exam Study Session
Exam Study Session
12:30-3:30
• Filter Maintenance for Water Operators
• Distribution Issues Panel
• The Nutts and Bolts of Hydrant Maintenance
• Disinfection Byproducts of the DBP Rule
1:00-4:00
• Northeast District Business Meeting
• Gopher State One Call
• Trends in Membrane Treatment
• Recreational Surface Water Technologies
or
or
Exam Study Session
Exam Study Session
Thursday, March 30, 2006
7:30-11:30
• Operator Breakfast
• Exhibitor and Product Fair
• TopOps Competition
4:00: Operator Interface
Thursday, April 27, 2006
8:00-4:00
• Tour of Blandin Paper Mill and/or Grand Rapids
Water Plant
• Tour of Forest History Center
12:30-3:30
• Polypigging
• High-Density Polyethylene
• Water Audits/Leak Detection
Friday, April 28, 2006
8:00-noon
• Meters
• Hydrant Maintenance
• Automation and Flow Control
• Sampling Techniques and Preservation
• Panel Discussion on Operator Issues
or
Exam Study Session
Friday, March 31, 2006
8:00-noon
• Southeast District Business Meeting
• Changing Workforce
• Certification Corner
• Contamination Plumes
• The Good, the Bad, and the Ugly
or
• Certification Exams
MRWA Technical Conference
The 2006 Minnesota Rural Water Association (MRWA)
Technical Conference will be held at the St. Cloud Civic Center
from Tuesday, March 7 through Thursday, March 9.
For more information, contact the MRWA office at
218-685-5197 or via e-mail at [email protected].
or
Certification Exams
3
SWAMP Provides Training, Networking Experiences in Unique Setting
“Our biggest obstacle has been
An existing generic classroom at
convincing people that ‘free’ really
the OLC has been used for water
means free,” says Steve Kleist of
courses as well as other kinds of
Vermilion Community College’s
skills training, such as law enforce(VCC) small-system water training
ment. But with the new training
near its campus in Ely.
came a specialized classroom, added
Kleist has been with the college
onto the existing building, that is a
since it began its water-wastewater
hands-on treatment facility. Begun
technology program in the
in mid-2005 and completed by the
mid-1970s. A former operator who
end of the year, the classroom has a
had worked in the environmental
groundwater and a surface-water
field in other capacities, Kleist has
source as well as a place to do lab
taught courses on water quality and
work, water testing, and operations
watershed science and is now a key SWAMP training is held on Fall Lake outside of Ely. training. The groundwater is
part of the SWAMP program (an acronym for Safe Water
provided by a 285-foot-deep well outside the classroom buildfor All Minnesota People).
ing, and the surface water from Fall Lake. Kleist says that
SWAMP began as a result of money from the U. S.
the water from the lake is hard and colored, providing treatEnvironmental Protection Agency to state primacy agencies
ment challenges in the classroom process demonstration.
to assist with the training of operators from small water
With a faculty of a dozen experts from around the state,
systems. An advisory committee developed a curriculum for
SWAMP courses were first offered in 2004 in the generic
the program; unlike the water technology courses at VCC,
classroom with topics that include groundwater, surface
it was not geared toward a degree but rather for specialized
water, general operations, lab testing, wells and well
training for existing operators as well as those just entering
maintenance, and pipes, pumps, and plumbing. Employees
the profession. “Having lots of rural, surface, and small
of public water systems that serve fewer than 3,300 people
systems in northern Minnesota, it was a perfect fit,” said
are eligible for up to four free two-day classes (as well as
Kleist. “Our students come from small communities, resorts,
free food and lodging) as long as the grant money lasts.
campgrounds, rural schools, trailer parks, and other water
Kleist notes the opportunities afforded by the unique
systems that benefit from those grant dollars.”
setting of a remote complex, pointing out that students
Beyond the curriculum was the need for a facility.
network as well as learn by spending time together during
“In addition to the college, one of the things we wanted
and after the classroom sessions. Activities such as
was a place available anytime of the year that small-water
cookouts and lake excursions are a normal part of the
students to go to,” added Kleist. That place is the Outdoor
experience. “Fishing might be the excuse,” he says, “but it
Learning Center (OLC), which is approximately five
doesn’t take very long and pretty soon people are talking
miles northeast of Ely. Formerly a resort and now owned
shop. There’s certainly a wealth of information to be learned
by the U. S. Forestry Service, the OLC is on Fall Lake,
in classes, but making those other professional connections,
which is partially in the Boundary Waters Canoe Area.
sharing perspectives, sharing solutions is as much of a
The OLC has been in operation for a number of years and
learning opportunity as sitting in a classroom.”
has eight cabins (with enough room to handle the maximum
More information is available on the SWAMP
of 20 students per class), a food service, and waterfront
at http://www.vcc.edu/departments/swamp or by calling
access.
1-800-657-3609.
“The SWAMP is a legacy that will go on long past the time the grant is gone,” says Steve Kleist, standing by the well (left) and in the
under-construction specialized classroom building (right). Kleist calls the program, “An opportunity to help a lot of people.”
4
Below-Market-Rate Loans for Public Water Systems
By John Schnickel
If it is time to upgrade your water system, then we have
the loan program for you. Proposals are being accepted to
place public water system construction projects on the
Drinking Water Revolving Fund (DWRF) Project Priority List
(PPL). Projects must be on the PPL to be eligible for belowmarket-rate DWRF loans.
Interest rates vary by project, but they have recently
averaged in the 2 percent range. Loans are typically for
wells, treatment plants, water towers, and distribution lines.
Priorities are for projects that solve a public health problem,
bring systems into compliance with drinking water standards,
and that are for communities below the median household
income. Funding is not for economic expansion nor for fire
suppression improvements.
May 19, 2006 is the deadline for receiving proposals for
the Project Priority List. A project must be on the list if a city
is to eventually obtain a DWRF loan, but listing a project
does not obligate a city to obtain a loan. Projects must also
be placed on the DWRF Intended Use Plan if a loan will be
sought, and construction is expected to start before June 30,
2007. The deadline for placing a project on the intended use
plan is June 9, 2006. Please note there is no guarantee that
all projects placed on the Intended Use Plan will be in the
funding range.
Within the last eight years, the fund has been used to
finance 190 projects for a total of $291 million.
The Minnesota Department of Health and the Minnesota
Public Facilities Authority jointly manage the DWRF
program. Instructions for submitting a proposal for the project
priority list can be found at the department of health web site
at http://www.health.state.mn.us/divs/eh/water/dwrf. Click
on Project Priority List, and then in the left margin click on
Instructions. An alternative is to call 651-201-4658.
Instructions for placing a project on the intended use plan
can be found at the public facilities authority web site at
www.deed.state.mn.us/community/assistance/pfa.htm. Scroll
down to Drinking Water Revolving Fund. Click on
Instructions for Placement on 2007 PPL and IUP, and then
scroll to the IUP section. Contact the authority at
651-296-2838 if you do not have web access.
If you have any questions, contact me at 651-201-4658 or
[email protected].
Waterworks Quiz
Words to Live By
1. In cases where carbon dioxide gas is produced in a
submerged combustion chamber or purchased in some
form for stabilization, extreme care must be taken to:
a. apply a protective coating on submerged piping.
b. control resulting taste and odor problems.
c. install an adequate ventilation system.
d. post “no smoking” signs.
It’s easier to fight for one’s principles
than to live up to them.
The person who starts by saying,
“Maybe I’m wrong,” is often right.
Experience is what you get when you were
expecting something else.
2. Breakpoint chlorination is achieved when:
a. free ammonia can be tasted in the water.
b. no chlorine residual is detected.
c. the strong chlorine taste at the plant did not
persist in the distribution system.
d. a corresponding increase in residual is detected
when chlorine dosage is increased.
Do your worrying before you place your bet,
not after the wheel starts turning.
The best way to succeed in life is to act
on the advice we give to others.
3. When the static level of the groundwater is 50 feet
below the ground surface, the most suitable type of
pump is a(n):
a. air lift pump.
b. gear pump.
c. horizontal centrifugal pump.
d. turbine pump.
Be thankful for problems. If they were less
difficult, someone with less ability
might have your job.
Make other people like themselves a little
better, and you can rest assured they’ll like
you very much.
Bonus Question
Translate: Exclusive dedication to necessitous
chores without interludes of hedonistic diversion
renders John a hebetudinous fellow.
“If I knew I was going to live this long,
I’d have taken better care of myself.”
—Mickey Mantle
Answers on page 7
5
More on the Disinfection Byproducts/Surface Water Treatment Rules
page 1). Two systems will fall into the second stage of IDSE
requirements and must submit an IDSE plan by April 1, 2007.
Seven of the 11 systems are those that purchase water from
a utility that serves more than 50,000 people. The low DBP
concentrations found at most Minnesota systems may allow
MDH to grant “40/30 certification” to the remainder of state
CWSs. Such certification is possible for systems where no
individual Stage 1 DBPR sample exceeded 0.040 milligrams
per liter (mg/L) TTHM or 0.030 mg/L HAA5 during a
specified two-year period. As a result, many Minnesota systems
will be allowed to skip the IDSE step of the compliance
process. The remaining 11 will need to begin their planned
IDSE monitoring within 12 months from plan submission.
The LT2 ESWTR will prompt source water monitoring
plans from two Minnesota surface water systems by July 1,
2006 and two more systems by January 1, 2007 (see Table 2
on page 1). Such source water monitoring (for those four
systems) will include sampling for Cryptosporidium, E. coli,
and turbidity, and will be required to start only three months
following plan development. Systems may use
(grandparent) previously collected data in lieu of new
monitoring if the data was generated using EPA-approved
methods. Minnesota utilities will work with the MDH
Laboratory in arranging source water monitoring.
The various early implementation requirements of both
rules have prompted EPA to develop a more comprehensive
set of guidance documents and to design a group of webbased tools for use by water utilities and MDH. EPA
provided an introduction to, and training with, those tools during
a pair of web presentations during January 2006. MDH
expects to work closely with PWSs during early rule activities while routing much of the utility data submission through
the EPA tools. Resources such as the Information Processing and Management Center (IPMC) and IDSE Tool may
allow utilities to simplify Stage 2 DBPR IDSE electronic data
submissions. Similarly, the IPMC and Data Collection &
Tracking System will allow utilities, laboratories, and MDH
to work with a central LT2 ESWTR Web portal. At the
same time, EPA plans to publish several written guidance
documents that utilities may use to assist with Stage 2 DBPR
IDSE and consecutive system issues and LT2 ESWTR source
water monitoring and grandparenting, microbial toolbox
choices, and simultaneous compliance issues.
By David Rindal—continued
The Stage 2 DBPR and LT2 ESWTR are the second
phase of rules required by Congress through 1996
amendments to the Safe Drinking Water Act. Stage 2 DBPR
built upon the existing Stage 1 DBPR to reduce potential
cancer and reproductive and developmental health risks from
DBPs in drinking water. Compliance monitoring
requirements were stiffened for trihalomethanes (TTHM)
and haloacetic acids (HAA5). Some Minnesota community
water supplies (CWSs) will be required to include an Initial
Distribution System Evaluation (IDSE) process to locate sites
with high DBP levels. IDSE results will be used to
determine Stage 2 DBPR compliance monitoring locations.
Compliance with TTHM and HAA5 maximum contaminant
levels (MCLs) will be evaluated for each distribution system
monitoring location, using what is referred to as a locational
running annual average. Finally, it is important that
all consecutive systems note that the Stage 2 DBPR
regulates CWSs and nontransient noncommunity water
systems that produce and/or deliver water that is treated
with a disinfectant other than ultraviolet light.
The LT2 ESWTR was promulgated to reduce illness linked
with Cryptosporidium and other pathogenic microorganisms in drinking water. Higher risk systems, identified
through the rule’s required source water monitoring, may
need to improve microbial treatment based on classification
in a treatment category (bin). Also, systems must review
their current level of microbial treatment before making a
significant change in their disinfection practice. The LT2
ESWTR and Stage 2 DBPR were promulgated
simultaneously due to concerns about risk tradeoffs between
pathogens and DBPs. Finally, compliance deadlines are based
on the sizes of public water systems (PWSs) and are
generally staggered from larger population to smaller
population (with consecutives following the schedule of the
largest system in their combined distribution system).
Two significant deadlines will affect water utilities
serving greater than 50,000 people (one affecting systems
that purchase water from such utilities) within the next 18
months.
The Minnesota Department of Health (MDH) expects
that nine Minnesota systems will be required to submit a
Stage 2 DBPR IDSE plan by October 1, 2006 (see Table 1 on
Waterline
Published quarterly by the Drinking Water Protection Section, Minnesota Department of Health
Editor: Stew Thornley
Staff: Dick Clark, Jeanette Boothe, Noel Hansen
To request this document in another format, call 651-201-4700; TDD 651-201-5797
or toll-free through the Minnesota Relay Service, 1-800-627-3529 (ask for 651-201-5000).
Past issues of the Waterline are available at:
http://www.health.state.mn.us/divs/eh/water/newsletters.htm
6
Lead and Copper Data Declared Private and Nonpublic
The Minnesota Department of Administration has declared
that lead and copper results that are tied to a specific
address, as well as the name, address and telephone number
of the owner/participant, are nonpublic and private and
cannot be released to the public except for test results that
can be shared with homeowners for their residence only.
The ruling was the result of an application made to the
Department of Administration by the Minnesota Department
of Health (MDH) and the cities of New Hope, St. Paul,
Moorhead, and Fairmont after a media request was made to
obtain street addresses with the corresponding lead and
copper results.
The MDH and the cities objected to releasing
address-specific data because it might render the entire
sampling program unworkable by discouraging voluntary
participation and be considered an invasion of privacy of the
participating homeowners; in addition, since results can vary
from day to day (based on a variety of factors), the results
are not necessarily representative of the amount of lead and
copper a homeowner may be exposed to on a continuous
basis.
The MDH and all community water systems are still
obligated to release lead and copper results that are
associated with site numbers but not addresses. Community
water systems must not release owner’s names, addresses,
and telephone numbers of participants in the lead and copper
sampling program.
The classifications of nonpublic and private for certain data
associated with lead and copper testing at community water
systems is considered temporary until the state statute is
amended by the legislature during the 2006 session.
Any questions you might have on this topic should be
directed to Dick Clark at 651-201-4667 or via e-mail at
[email protected].
Answers to Quiz
Bonus Question:
All work and no play makes Jack a dull boy.
1. c
2. d 3. d
REGISTRATION FORM FOR TELECONFERENCE AND SPRING SCHOOLS
You may combine fees on one check if more than one person is attending a school; however, please make a copy of this
form for each person. Questions regarding registration, contact Jeanette Boothe at 651-201-4697.
To receive an exam application and/or study guide, contact Noel Hansen at 651-201-4690 or Mark Sloan at 651-201-4652.
AWWA Teleconference, Innovative Operator Tools, March 16, 2006.
Fee: $65 ($85 after March 9 or at the door) for Duluth; $55 ($75 after March 9 or at the door) for St. Paul (no lunch
served at this site); $65 for Grand Forks until March 9 (no late registrations accepted for this site).
Check the location you wish to attend: ____ Duluth ____ St. Paul
____ Grand Forks
Southeast School, March 29-31, 2006, Ramada Hotel and Conference Center, Rochester. Fee: $125 ($135 after March
20 or at the door).
Southwest School, April 4, 2006, Wells. Fee: $25 ($30 at the door).
Metro School, April 5-7, 2006, Ramada Inn and Thunderbird Convention Center. Fee: $135 ($170 after March 24 or at
the door).
Northeast School, April 26-28, 2006, Ruttger’s Sugar Lake Lodge, Grand Rapids. Fee: $115 ($125 after April 19 or at the
door).
Name
Employer
Address
City
Zip
Day Phone
E-mail Address
Please enclose the appropriate fee. Make check payable to Minnesota AWWA. Mail this form and fee to Drinking
Water Protection Section, Minnesota Department of Health, P. O. Box 64975, St. Paul, Minnesota 55164-0975.
7
CALENDAR
Water Operator Training
Minnesota Section, American
Water Works Association
*March 29-31, Southeast Water
Operators School, Ramada Hotel and
Conference Center, Rochester. Contact
Paul Halvorson, 507-292-5193.
*April 4, Southwest Water Operators
School, Wells. Contact Mark Sweers,
507-389-5561.
*April 5-7, Metro Water Operators
School, Ramada Inn and Thunderbird
Convention Center, Bloomington.
Contact Jeanette Boothe, 651-201-4697,
or Stew Thornley, 651-201-4655.
*April 26-28, Northeast Water
Operators School, Ruttger’s Sugar Lake
Lodge, Grand Rapids. Contact Jeanette
Boothe, 651-201-4697, or Stew Thornley,
651-201-4655.
*June 6-9, Central Water Operators
School, Ruttger’s Bay Lake Lodge,
Deerwood, Contact Lyle Stai,
320-212-8590.
Minnesota Rural Water Association Contact Kyle Kedrowski, 800-367-6792.
*March 7-9, Technical Conference,
MRWA Nonmunicipal and
St. Cloud Civic Center
Class E Training
April 12, Operation & Maintenance,
Elbow Lake
March 8, St. Cloud
April 11, Austin
April 20, Cohasset
American Water Works Association Teleconference
March 16 (note new date), Innovative Operator Tools,
St. Paul, Duluth, and Grand Forks, N. D. Contact Stew Thornley,
651-201-4655.
Midwest Regional Water Utility Management Institute
March 13-15, Continuing Education and Conference
Center, St. Paul. Contact Glen Gerads, 952-563-8775.
*Schools/meetings marked with an asterisk include a water certification
exam. To be eligible to take a certification exam, applicants must have
hands-on operations experience at a drinking water system.
For an up-to-date list of events, see the training calendar on the MDH web site at:
http://www.health.state.mn.us/divs/eh/water/wateroperator/trng/wat_op_sched.html
MDH Drinking Water Protection web page: http://www.health.state.mn.us/divs/eh/water
Presort Standard
US Postage
PAID
Permit No. 171
St. Paul, MN
Environmental Health Division
625 North Robert Street
P. O. Box 64975
St. Paul, Minnesota 55164-0975
ADDRESS SERVICE REQUESTED