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HomeMy WebLinkAbout24049_211 Trimble_AWP_20210330Via Email Revised March 30, 2021 North Carolina Department of Environmental Quality Division of Waste Management — Brownfields Program 1646 Mail Service Center Raleigh, North Carolina 27699-1646 Attn: Mr. Jim Rudder Re: Brownfields Assessment Work Plan Trimble Plant Road Property 175 Yadkin Road Southern Pines, Moore County, North Carolina Brownfields Project No. 24049-20-063 H&H Job No. SIL-015 Dear Jim: 1.0 Introduction hart hi kman SMARTER ENVIRONMENTAL SOLUTIONS On behalf of Rickhouse Properties, LLC (Prospective Developer or PD), Hart & Hickman, PC (H&H) has prepared this Work Plan to conduct Brownfields assessment activities for the Brownfields property located at 175 Yadkin Road in Southern Pines, Moore County, North Carolina (subject Site or Site). The Site received eligibility into the North Carolina Department of Environmental Quality (DEQ) Brownfields Program via a Letter of Eligibility dated October 23, 2020 (Brownfields Project No. 24049-20-063). Proposed redevelopment plans for the Brownfields property include construction of new buildings for operation of a distilled spirits facility with associated office, retail, and warehousing spaces. The Site is comprised of one parcel of vacant land that totals approximately 15.04 acres in size. A Site location map is provided as Figure 1, and the Site and surrounding area are shown in Figure 2. The subject Site is located adjacent and west of the former Proctor-Silex facility (261 Yadkin Road), which previously manufactured chrome plated electric irons from approximately 1963 to \\hhfs0I \MasterFiles\AAA-Master Projects\silex - SIL\Southem Pines\Brownfields Activities\Workplan\revised to hart : h i c k m a n DEQ\Brownfields Assessment Work Plan Trimble Plant Road Property (BPN 24049-20-063).doc SMARTER ENVIRONMENTAL SOLUTIONS Mr. Jim Rudder March 30, 2021 Page 2 1982. Under contract to the DEQ Inactive Hazardous Sites Branch (IHSB) Superfund Section, H&H is conducting assessment and remediation activities in association with the former Proctor- Silex facility. Results of assessment activities indicate that the chlorinated volatile organic compound (VOC) trichloroethylene (TCE) and TCE degradation compounds cis-1,2- dichloroethylene and vinyl chloride have been detected in groundwater samples collected from monitoring wells located on the former Proctor-Silex facility property and/or the adjacent property to the north of the subject Site. On February 17, 2021, the PD, DEQ Brownfields, DEQ Superfund, and H&H participated in a conference call to discuss areas of potential environmental concern, proposed redevelopment plans, potential data gaps, and the scope of Brownfields assessment activities needed to address the data gaps. H&H understands that costs related to Brownfields assessment activities will be managed under a separate contract between H&H and DEQ Superfund. To address DEQ Brownfields' requests for additional assessment at the Site, H&H proposes to conduct soil, groundwater, pore water, surface water, sediment, and vapor intrusion assessment activities to evaluate potential impacts at the Site. Proposed Brownfields assessment activities are outlined in the following sections. \\hhfs0 I\MasterFiles\AAA-Master Projects\silex - SIL\Southem Pines\Brownfields Activities\Workplan\revised to DEQ\Brownfields Assessment Work Plan Trimble Plant Road Property (BPN 24049-20-063).doc 14 hart hickman SMARTER ENVIRONMENTAL SOLUTIONS Mr. Jim Rudder March 30, 2021 Page 3 2.0 Brownfields Assessment Activities The proposed Brownfields assessment activities will be performed in general accordance with the DEQ Inactive Hazardous Sites Branch (IHSB) Guidelines for Assessment and Cleanup (Guidelines) dated January 2020, the DEQ Division of Waste Management (DWM) Vapor Intrusion Guidance dated March 2018, and the most recent versions of the U.S. Environmental Protection Agency (EPA) Region IV Science and Ecosystem Support Division (SESD) Field Branches Quality System and Technical Procedures guidance. Prior to conducting field activities, H&H will contact North Carolina 811 One -Call, the public utility locator service, to mark subsurface utilities at the Site. H&H will also team with a private utility locator to identify and mark locations of sub -grade utilities at the Site that may not be marked by the public locator. 2.1 Receptor Survey H&H will perform a Brownfields receptor survey in accordance with DEQ Brownfields Section guidance. The receptor survey will utilize the Brownfields Property Receptor Survey Form and will include information about land use in the Site area including zoning. H&H will also conduct a field search for water supply wells, basements, utility manways and chases, storm sewers, other underground utilities, drains, and surface water within a 1,500 ft radius of the Brownfields property boundaries. 2.2 Groundwater Assessment Activities H&H proposes to subcontract with a North Carolina licensed drilling contractor to advance borings for installation of five (5) permanent Type II groundwater monitoring wells via sonic drilling techniques. The approximate locations of the proposed monitoring wells are shown on Figure 3 and are generally located in the central and northeastern portions of the Site and in the vicinity of proposed buildings. \\hhfs0I \MasterFiles\AAA-Master Projects\silex - SIL\Southem Pines\Brownfields Activities\Workplan\revised to hart : h i c k m a n DEQ\Brownfields Assessment Work Plan Trimble Plant Road Property (BPN 24049-20-063).doc SMARTER ENVIRONMENTAL SOLUTIONS Mr. Jim Rudder March 30, 2021 Page 4 During drilling, soil samples will be collected and logged for lithologic description and field screened for presence of staining and elevated concentrations of volatile organic vapors using a calibrated photoionization detector (PID). The monitoring wells will be constructed of 2-inch diameter PVC with 10 or 15 ft of well screen set to bracket the water table (estimated at between approximately 25 to 30 feet below ground surface [ft bgs]) and 2-inch diameter PVC well casing to the ground surface. A sand filter pack will extend from below the base to approximately 2 ft above the top of the well screens followed by at least 2 ft of hydrated bentonite followed by grout to the ground surface. All monitoring wells will be completed flush with the ground surface inside flush mount manholes secured with 2 ft by 2 ft concrete pads. Following a minimum of 24 hours after installation, the monitoring wells will be developed by removing a minimum of 3 to 5 well volumes and observing stable field parameters (i.e., pH ± 0.1 SU and conductivity varies no more than 5%). After development, depth to groundwater information will be collected and a groundwater sample will be collected utilizing low flow/low stress purging techniques using a peristaltic pump and disposable polyethylene tubing. The intake point of the pump tubing will be placed approximately in the mid -portion of the screened interval of the well and groundwater will be removed at a rate no greater than 200 milliliters per minute. H&H will utilize a water quality meter to measure pH, temperature, dissolved oxygen, oxidation reduction potential, turbidity, and specific conductivity at 3 to 5- minute intervals during purging. Purging will be considered complete when water quality parameters stabilize (i.e., pH ± 0.1 SU, conductivity varies no more than 5%, and turbidity is less than 10 NTUs). Once groundwater parameters stabilize, groundwater samples from the monitoring wells will be collected directly into laboratory supplied sample containers. VOC samples will be collected using the "soda straw" method to minimize volatile loss through the peristaltic pump head. The sample containers will be labeled with the sample identification, date, and requested analysis, and then placed in a laboratory supplied cooler and iced. The samples will be delivered to a \\hhfs0I \MasterFiles\AAA-Master Projects\silex - SIL\Southem Pines\Brownfields Activities\Workplan\revised to hart : h i c k m a n DEQ\Brownfields Assessment Work Plan Trimble Plant Road Property (BPN 24049-20-063).doc SMARTER ENVIRONMENTAL SOLUTIONS Mr. Jim Rudder March 30, 2021 Page 5 North Carolina certified laboratory under standard chain of custody protocols for analysis of VOCs by EPA Method 8260, semi-SVOCs by EPA Method 8270, and Resource Conservation Recovery Act (RCRA) metals plus hexavalent chromium, nickel, and zinc by EPA Methods 6020/7470/7199. To assist DEQ Superfund with evaluation of groundwater remedial activities conducted at the former Proctor-Silex facility property, groundwater samples will also be submitted for analysis of natural attenuation parameters including methane, ethane, ethene (MEE), sulfate, and total organic carbon (TOC). Upon completion of groundwater sampling activities, the monitoring wells will be surveyed to obtain locations and top -of -casing elevations. 2.3 Soil Sampling Activities H&H proposes to advance five (5) soil borings using a decontaminated hand auger to evaluate potential impacts to soil in proposed grading areas to determine potential risk to construction workers and future Site users. The approximate locations of the proposed soil borings are shown on the sample location map, which is presented as Figure 3, and are generally located in the central, eastern, northeastern, and southern portions of the Site and in the vicinity of proposed buildings. H&H will team with a qualified drilling contractor to advance the soil borings to approximately 6 ft bgs. Continuous soil samples will be collected from the borings and samples will be logged for lithological description and field screened for indication of potential impacts by observation for staining, unusual odors, and the presence of volatile organic vapors using a calibrated PID. One sample will be collected from each soil boring at a depth interval interpreted most likely to be impacted based on field observations and PID readings. If evidence of impacts is not observed, a soil sample will be collected from the interval corresponding with the post - development proposed grade (e.g., for soil borings located in an area with a proposed cut of 2 ft, soil samples will be collected from the 2-4 ft bgs interval). The preliminary grading plan is included as Attachment A. \\hhfs0I \MasterFiles\AAA-Master Projects\silex - SIL\Southem Pines\Brownfields Activities\Workplan\revised to hart : h i c k m a n DEQ\Brownfields Assessment Work Plan Trimble Plant Road Property (BPN 24049-20-063).doc SMARTER ENVIRONMENTAL SOLUTIONS Mr. Jim Rudder March 30, 2021 Page 6 Soil samples will be placed in dedicated laboratory -supplied sample containers, labeled with the sample identification, date, and requested analysis, and placed in a laboratory -supplied cooler with ice. Soil samples will then be submitted to a North Carolina certified laboratory under standard chain of custody protocols for analysis of VOCs by EPA Method 8260, SVOCs by EPA Method 8270, and RCRA metals plus hexavalent chromium by EPA Methods 6020/7471/7199. Following sampling activities, the soil borings will be properly abandoned and the surface will be repaired similar to pre -sampling conditions. Additionally, the soil sample locations will be estimated using a hand-held GPS unit. 2.4 Pore Water Assessment Activities H&H proposes to collect four (4) pore water samples from the streambed of the downgradient western tributary to McDeeds Creek. Samples will be collected from upstream, central, and downstream locations of the tributary within the wetland areas to delineate groundwater impacts and assess potential discharge to the stream and wetland area. Proposed pore water sample locations are depicted on Figure 3. Samples will be collected in order from the most downstream location to the most upstream location. Pore water samples will be collected using Henry PushPoint (HPP) samplers. Each HPP sampler will be inserted into streambed sediments to a depth of approximately one foot. A syringe or peristaltic pump will then be used to develop the sampler at a low -flow sampling rate (50 200 milliliters per minute). At least 50 ml of purge water will be removed. H&H will utilize water quality meters to collect measurements of pH, temperature, dissolved oxygen, oxidation reduction potential, turbidity, and specific conductivity of pore water at each sample location. Multiple readings will be collected every 3-5 minutes until parameters have stabilized (pH within ±0.1 and specific conductivity within f5%). \\hhfs0 I\MasterFiles\AAA-Master Projects\silex - SIL\Southem Pines\Brownfields Activities\Workplan\revised to DEQ\Brownfields Assessment Work Plan Trimble Plant Road Property (BPN 24049-20-063).doc 14 hart hickman SMARTER ENVIRONMENTAL SOLUTIONS Mr. Jim Rudder March 30, 2021 Page 7 Following stabilization, pore water samples will be collected directly into laboratory -supplied sample containers. The sample containers will be labeled with the sample identification, date, and requested analysis, and placed into a laboratory supplied cooler and iced. The surface water samples will be delivered to a North Carolina certified laboratory under standard chain of custody protocols for analysis of VOCs by EPA Method 8260, SVOCs by EPA Method 8270, and RCRA metals by EPA Methods 6020/7470. The pore water sample locations will be estimated using a hand-held GPS unit. 2.5 Surface Water and Sediment Assessment Activities H&H proposes to collect three (3) co -located surface water and sediment samples for laboratory analysis from the tributary to McDeeds Creek. Co -located surface water and sediment sample locations are shown on Figure 3. The surface water and sediment samples will be collected in a downstream to upstream order. If portions of the stream in the area of a proposed sample location are found to be dry, a sample will be collected at the nearest location with surface water. H&H will utilize water quality meters to collect measurements of pH, temperature, dissolved oxygen, oxidation reduction potential, turbidity, and specific conductivity of surface water at each sample location. Surface water samples will be collected during base flow conditions. Sediment samples will be collected from the base of the stream in the mid -portion of the stream channel at each sample location using a decontaminated stainless steel AMS dredge sampler or similar sampler. Surface water and sediment samples will be collected directly into laboratory -supplied sample containers. The sample containers will be labeled with the sample identification, date, and requested analysis, and placed in a laboratory supplied cooler and iced. The surface water samples will be delivered to a North Carolina certified laboratory under standard chain of custody protocols for analysis of VOCs by EPA Method 8260, SVOCs by EPA Method 8270, and RCRA metals by EPA Method 6020/7471. In addition, surface water samples will also be \\hhfs0 I\MasterFiles\AAA-Master Projects\silex - SIL\Southem Pines\Brownfields Activities\Workplan\revised to DEQ\Brownfields Assessment Work Plan Trimble Plant Road Property (BPN 24049-20-063).doc 14 hart hickman SMARTER ENVIRONMENTAL SOLUTIONS Mr. Jim Rudder March 30, 2021 Page 8 analyzed for hardness by Standard Method 2340B to calculate North Carolina surface water standards for metals which are hardness dependent. Upon completion of sampling, the co -located surface water and sediment sample locations will be estimated using a hand-held GPS unit. 2.6 Vapor Intrusion Assessment Activities H&H proposes to conduct soil gas assessment activities to evaluate the potential for structural vapor intrusion into future buildings. To complete the assessment, 15 soil gas samples will be collected within the footprints of future Site buildings. Sample locations are depicted on Figure 3, and are generally located in the central, eastern, northeastern, and southern portions of the Site and in the vicinity of proposed buildings. The proposed soil gas assessment will be performed in general accordance with the DEQ DWM Vapor Intrusion Guidance dated March 2018 and as described below. Each soil gas point will be installed to depths of approximately 5 to 9 ft bgs using a hand auger and/or direct -push technologies (DPT) drill rig. The target depth for soil gas points is approximately 5 ft below the post -development proposed grade (Attachment A). The soil gas points will each be installed with a 6-inch 0.010-inch stainless steel screen set at the base of the boring connected to the surface with 1/4-inch Teflon® tubing. The annular space will be filled with filter sand followed by a bentonite and grout seal to prevent short-circuiting of air from the surface. Soil gas points will be completed as temporary points. At least 24 hours following soil gas point installation and prior to sampling the soil gas points, a leak check will be conducted at each location by constructing a shroud around the soil gas point and sampling train and flooding the air within the shroud with helium gas. Using a syringe, a sample will be collected from the gas in the shroud into a Tedlar® bag and analyzed for helium concentrations using a helium gas detector. Vapor from the monitoring points will be purged and sampled outside of the shroud into a separate Tedlar® bag and analyzed using the helium \\hhfs0I \MasterFiles\AAA-Master Projects\silex - SIL\Southem Pines\Brownfields Activities\Workplan\revised to hart : h i c k m a n DEQ\Brownfields Assessment Work Plan Trimble Plant Road Property (BPN 24049-20-063).doc SMARTER ENVIRONMENTAL SOLUTIONS Mr. Jim Rudder March 30, 2021 Page 9 gas detector to ensure that helium concentrations are less than 10% of the concentration measured within the shroud. Following a successful field leak check, the soil gas samples will be collected into one -liter Summa canisters for laboratory analysis by connecting the Teflon® sample tubing to an airflow regulator using a brass nut and ferrule assembly to create an air tight seal. The airflow regulator will be calibrated by the laboratory to allow the Summa canisters to fill slowly at a rate not greater than 200 milliliters per minute. The vacuum pressure in each Summa canister upon completion of the sampling event will be between three and six inches of mercury. Upon completion of sample collection, the air flow regulator will be removed from the Summa canister and the samples will be submitted to a nationally accredited laboratory under standard chain of custody protocols for analysis of VOCs by EPA Method TO-15. H&H will request the full VOC list, which will include naphthalene and 1,3-butadiene. Upon receipt of the samples, the laboratory will record the final received vacuum pressure for each Summa canister. 2.7 Quality Assurance/Quality Control Samples Non -dedicated equipment and tools will be decontaminated prior to use at each boring or sampling location or following exposure to soil, sediment, soil gas, or water samples. To evaluate the reproducibility of the sample results, H&H will collect one duplicate sample per sample media. The duplicate samples will be submitted for the same laboratory analysis as their respective parent samples. Laboratory quality assurance and quality control (QA/QC) procedures will be employed to ensure appropriate sample handling and analysis and to aid in the review and validation of the analytical data. QA/QC procedures will be conducted in accordance with the method protocols and will include regular equipment maintenance, equipment calibrations, and adherence to specific sample custody and data management procedures. Samples will be analyzed in conjunction with appropriate blanks, laboratory duplicates, continuing calibration standards, \\hhfs0I \MasterFiles\AAA-Master Projects\silex - SIL\Southem Pines\Brownfields Activities\Workplan\revised to hart : h i c k m a n DEQ\Brownfields Assessment Work Plan Trimble Plant Road Property (BPN 24049-20-063).doc SMARTER ENVIRONMENTAL SOLUTIONS Mr. Jim Rudder March 30, 2021 Page 10 surrogate standards, and matrix spiking standards in accordance with approved methodologies to monitor both instrument and analyst performance. Laboratory reporting limits for each analyte will be at or below appropriate screening criteria, where possible. Additionally, H&H will request that the laboratory include estimated concentrations for compounds that are detected at levels above the laboratory method detection limit, but below the laboratory reporting limit (i.e., J flags). The laboratory analytical data report and QA package for each group of samples submitted to and analyzed by the subcontracted laboratory will be provided in an appendix to the final report. Laboratory QA data consistent with Level II documentation will be requested for this project. A copy of the completed chain -of -custody record and shipping receipt will be appended to the corresponding laboratory analytical report included with the final report. 2.8 Investigation Derived Waste Investigation derived waste (IDW), which will consist of saturated soil cuttings from drilling, decontamination water, and well development and purge water from the assessment activities, will be containerized in 55-gallon drums and temporarily stored on Site. Soil cuttings generated from the unsaturated zone will be thin -spread on -Site. A composite sample of the IDW soil drums and IDW water drums will be collected and submitted for laboratory analysis of toxicity characteristic leaching procedure (TCLP) VOCs by EPA Method 8260, TCLP SVOCs by EPA Method 8270, and TCLP RCRA metals by EPA Method 6020/7471. Should laboratory analytical results indicate that IDW is characteristically non -hazardous, it will be thin -spread and/or discharged to the ground surface at the Site. 2.9 Reporting Following completion of the assessment activities and receipt of the analytical data, H&H will document our findings in a Brownfields Assessment Report. The report will include a description of the sampling activities, figures depicting sample locations, sample data, soil \\hhfs0I \MasterFiles\AAA-Master Projects\silex - SIL\Southem Pines\Brownfields Activities\Workplan\revised to hart : h i c k m a n DEQ\Brownfields Assessment Work Plan Trimble Plant Road Property (BPN 24049-20-063).doc SMARTER ENVIRONMENTAL SOLUTIONS Mr. Jim Rudder March 30, 2021 Page 11 boring logs, laboratory analytical data, a discussion of the data in comparison to regulatory screening levels, Brownfields receptor survey results, IDW manifests, and conclusions and recommendations concerning our activities. Please contact us if you have any questions or require additional information. Sincerely, Hart & Hickman, PC #C-1269 Engineering #C-245 Geology SEAL 2257 3/30/21 C. BP ��•` 411111104 Justin Ballard, PG Project Manager North Carolina Professional Geologist #2257 Attachments: Figure 1 — Site Location Map Figure 2 — Site Map Figure 3 — Proposed Sample Location Map Attachment A — Preliminary Grading Plan cc: Ms. Jessica Halling, Rickhouse Properties, LLC (via email) Ms. Sharon Eckard, DEQ Brownfields (via email) Ms. Beth Hartzell, DEQ Superfund (via email) Mr. Scott Drury, Hart & Hickman (via email) \\hhfs0 I\MasterFiles\AAA-Master Projects\silex - SIL\Southem Pines\Brownfields Activities\Workplan\revised to DEQ\Brownfields Assessment Work Plan Trimble Plant Road Property (BPN 24049-20-063).doc Lisa Nickels, PG Project Geologist 14 hart hickman SMARTER ENVIRONMENTAL SOLUTIONS Figures \\hhfs0 I\MasterFiles\AAA-Master Projects\silex - SIL\Southem Pines\Brownfields Activities\Workplan\revised to DEQ\Brownfields Assessment Work Plan Trimble Plant Road Property (BPN 24049-20-063).doc 14 hart hickman SMARTER ENVIRONMENTAL SOLUTIONS 4H • � { L _ • f' IY�y ` � � j �L y + • _ : d d.. -, z'' � l � yea + ►4 z J � � � �� III /!, H •� P - ',1► 04 �10 400 1 f + p av a Im J • •.g 9G4 �' ' j Ii ' so 4 �i, .,.! � � _ -� � YrIJ a• 'I • it 1'+•• _ P •• 4 �' N 1l •• .6 .1 �a �d I•a .4w +i°f • a 4• f ` d H _ . • RRr r�k_ss• t•PN APPROXIMATE N 0 2000 4000 SCALE IN FEET U.S.G.S. QUADRANGLE MAP SOUTHERN PINES, N.C. 1957 (PHOTOREVISED 1984) NIAGARA, N.C. 1957 (PHOTOREVISED 1983) QUADRANGLE 7.5 MINUTE SERIES (TOPOGRAPHIC) I MULTIPLE CHANNEL AREA II J r i i / / \ WESTERN TRIBUTARY / (BYPASS) A./ 1 NC SELF / / / /� - �� ♦ ♦ STORAGE (FORMER PRIDE /� / / /� / �` ♦ TRIMBLE) LEGEND SITE PROPERTY BOUNDARY OFF -SITE PROPERTY BOUNDARY RIGHT OF WAY FENCE STREAM -------- WETLANDS EXTENT PROPOSED RESTAURANT/BAR, KITCHEN, DISTILLERY AND OFFICES 0 PROPOSED WAREHOUSES NORTHERN TRIBUTARY I.\ / JPOND~~ / WOODED ! INTERMITTENT STREAM I"! II ' / 1 j( 1 \ Ill I 1/ WOODED HAMILTON BEACH FACILITY YgDk�N 1 / i i / 9 APPROXIMATE 0 300 600 SCALE IN FEET SITE MAP TRIMBLE PLANT ROAD BROWNFIELDS PROPERTY 175 YADKIN RD SOUTHERN PINES, NC hart ''`• h i c k m a n 2923 South Tryon Street -Suite 100 Charlotte, North Carolina 28203 704-586-0007(p) 704-586-0373(f) SMARTER ENVIRONMENTAL SOLUTIONS License # C-1269 / #C-245 Geology PROPOSED PARKING DATE: 12-28-20 1 REVISION NO. 0 JOB NO. SIL-015 FIGURE NO. 2 / WESTERN \ TRIBUTARY (BYPASS) / / II l- � j / / l rPONDr rr INTERMITTENT STREAM A / / I I �J, / 1 LEGEND BROWNFIELDS PROPERTY BOUNDARY PROPERTY BOUNDARY RIGHT OF WAY FENCE STREAM WETLANDS EXTENT PROPOSED RESTAURANT/BAR, KITCHEN, DISTILLERY AND OFFICES PROPOSED WAREHOUSES PROPOSED PARKING PROPOSED PERMANENT MONITORING WELL LOCATION ® PROPOSED SOIL VAPOR SAMPLE LOCATION • PROPOSED SOIL SAMPLE LOCATION - PROPOSED PORE WATER SAMPLE LOCATION ® PROPOSED SURFACE WATER AND SEDIMENT SAMPLE LOCATION 0 APPROXIMATE 200 400 SCALE IN FEET Attachment A Preliminary Grading Plan \\hhfs0 I\MasterFiles\AAA-Master Projects\silex - SIL\Southem Pines\Brownfields Activities\Workplan\revised to DEQ\Brownfields Assessment Work Plan Trimble Plant Road Property (BPN 24049-20-063).doc 14 hart hickman SMARTER ENVIRONMENTAL SOLUTIONS NITIV16" E chi 73.80' N31'17'1 cha 87 It l •,[,po re 1993) NQT54'14`.� chm 79.85 N08101'16ir ch-a 119.1 N26'S6'11 ch- 100.00 4 Opp s 44 OF444 , dF • TIE UNE S041Q''28"E ,ter N663'35"W YUD�M� �•' 117.04 !� 1 or �tl.aoat]o�e slrrnm of Sir.1 L12 Lt3 L t 6f-0 f ` ww+idr 1 9370.7 La 3z' 0.� I 0373.5 • ti � 1 Ow 04 r r � qp `%.. 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