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HomeMy WebLinkAboutNCD980602163_19811022_Warren County PCB Landfill_SERB C_Draft Memorandum of Understanding - Attachment 1-OCRATTACHMENT 1 MEMORANDUM OF UND ER STANDING RETWE EN THE STATE OF NORTH CAROLINA AND THE UNITED STATES ENVIR ONMENTAL PROTECT ION AGENCY I. INTRODUCTION SITE STUDY PLAN PCB SPILLS NORTH CAROLINA Representatives of Envi r onmental Protection Agency (EPA), Ecology and Environment, Inc. (E&E), and State of North Carolina me t in Ralei gh during September 1981 to discuss problems related to polychlorinated biphenyl s (PCR) dumped along North Carolina hi ghways. At th ese meetings , a study to de termine \. the present status of the PCB was proposed based on the emergency_ action plan prepared by E&E for EPA during February 1981. The State r equest ed that EPA take the lead, and that the State correlate and monitor the s tudy . Technical support would be provided by E&E und er their contract with EPA . A. Site Description and Background 56f f:::.9-s,.. L ,h bl/') A ..i O '=i ~ I ] t> W ~ " f' Between June and August 1978, &vet 3'0-;000 gallous ~ Polychlorinated biphenyl (PCB) were dumped along 210 mil es of roadway i n North Carolina. These contaminated areas (Fig. 1) were discovered in at least 14 count ies and on remote roads of the Fort Bragg Military Reservation. The affected counti es i nclude: Alamance Chatham Edgecombe Franklin Granville Halifax Harnett Johnston Lee Nash Person Wake Warren Wilson Temporary remedial meas ures, which consist ed of spraying the sites wi th activated carbon and a thin asphalt , were implemented by the State as an attempt to preve nt PCB migration and to neutralize the hazard to humans. Extensive sampling studies were cond uc ted by EPA-SAD and North Carolina State investigators during 1978 and 1979. However, no additional sampling o r testing has occurred in the past two years, and r esults from recent field reconnaissance t rips sugges t the possibility that migration may have occurred. B. Purpose of Stu<ly This study will tes t the null hypothesis that PCB is presently immobilized at the ori g inal dump site s. The presence of PCB at a statistica lly significant number of off-sit e locations will result in rejection of this hypothesis. If the r e sults of the study indicate PCR migration , modeling of distribution and concentration patterns for extrapolat ion to geologically and topog raphically similar areas will be attempted . LOCATION MAP 11111111 PC B SPILLS FIGURE I 0 ~ •O 20 { ■ ■ WWl*WS SCAi.( OF MILES 30 ' ' / . . . ' II. SCOPE A. Reconnaissanc e Survey A reconnaissance survey will be conducted to delineate detailed sampling points at each of 30 s ample locations , .at Fort Bragg military facility, and at three locations where no PCB spills have been recorded (Fig. 2). B. Sampling Study Sampling teams from E&E accompanied by State and EPA representatives will collect samples at each of the sampling sites. These samples will be . analyzed for PCB concentrations . ~ M~~/MVM Af Zo l.~ Surface samples will be col lected and analyzed at each sample site to determine if lateral surface migration of PCB contaminated soil, s iment or carbon has occ~rred. Areal distribution patterns co mmon to areas with similar geologic or topographic characte,ristics 111a_y be de 1 i neated. Ho12.E S~M PLf;S 'HAY '2.E" TAt:.EN f\'r 'S rf8:, ~ w+:\£2.E -.:> N (_l)M~L\2f-. ToPc~Q.~fl-tW,~l, t:I.ND bB:Wbt<...A.C.... f'~1\)'€6 ,:;..~ ::l:::NC..Ou/lJ'fb2?{) o ~;>i>Q..t>V~'- 2 . A core sample will be collected and analyzed at each location in an ef,fort to determine whether possible vertical migra tion of PCB has occurred .~ithologic or structural paths of migration may be determined . To'E S~"MPJ.€ w'il\ 5c A CoMfDSJiE~ ~WI-P/..E f,zoM b'1 1"0 1~11 ,-o ~~~'r in~ I fO"OT U::.'\/El-, C. Statistical Analyses Statistical manipulations will be performed on the results of the laboratory analyses, and models depicting PCB mov ement may be constructed for extrapolation to similar areas along the 210 miles of roadway that will not be sampled .,during this study. D. Report Preparation 1 . Deliverables will be a draft report, and a final report of work to EPA and North Carolina State representatives . mLE 2. ~Reports will include sampling site ma ps, analytical results, statistical analyses, distribution and concentration maps, models (if appropriate), cone lus ions , and recommendations for follow-up work. III . RECONNAISSANCE SURVEY A reconnaissance team, which wi 11 consist of E&E geological and envi ronmental personnel, accompanied by North Carolin?t.!State and EPA r ep resentatives will . . h f 3 0 1 . h IL 1',-s(:)O ~l ~-d f . . 1 1 . v1s1t eac o ocat1ons tat were.se ecte as part o a stat1st1ca samp 1ng study from along the 210 miles of roadway spill. In addition, a PCB spill location on Fort Bragg property and one location in each of the three physiographic provinces (Piedmont, Coastal Plain, and Triassic Basin), on which no PCB spills were recorded, will be included in this survey. Off-site areas, adjacent to each of the 30 spill locations and the Fort Bragg location, that present the greatest probability (based on geoJo.8J~BEb and1 topographical criteria) of trapping PCB-contaminated runoff!~n 11'7:ie sMJ/ted for a detailed sampling study. These general areas will be delineated on sketch maps, and a site center marker established and flagged for the teams that will conduct the sample collection. -3- . ' ' Caswell ---~T ALAMANCE ~n \ l --1 I I . I . r· ··p- 1 ®'>(-\.:1·\RANVILLE\: VANCE PERSON j I (./xboro ! . ' i H nde I@.~ son I Oxfo d l __ I --~ I I .-/ I I 1-...... .... __ _, I ORANGE I I / ' \ ----........._ ----.. ..) (I\..) I / I l L, __ _ I I \ / / -JOHNSTON SAMPSON ROBESON \ \ \ \ I I LENOIR I _1......_ v I I DUPLIN LOCATION MAP PCB SPILLS Htl FIGURE 2 RAG G SAMPL ES . ND FT . B ®· CONTROL ~LE LOCATIONS 0 _ JO S .Jo ;,..o Samples from the 30 s pill locations will provide data for the statistical study. Samples f rom the three "non-spi 11 locations" wi 11 provide background control, and the Fort Bragg samples will provide data on the government property. Results of the reconnaissance survey will be reviewed, upon completion and prior to commencement of the sampling study, by EPA, E&E, and State representatives. IV. SAMPLING STUDY A. Field Schedule Following the site reconnaissance, the remainder of the field work will be conducted using two crews of three persons each. The crews wi 11 work out of the Ecology and Environment step vans. One crew will be used to conduct the site survey which will consist of locating the site center marker installed by the reconnaissance team, preparing the detailed site sketch and locating and marking the exact location of the s ampling points. Permission to sample privately owned land will be obtained by the State of North Carolina prior to departure of this team. The second crew will follow the first crew and will collect the samples, prepare the necessary documentation and ship the samples to the laboratory. The use of two separate crews will reduce the possibility of cross contamination of the samples in that the amount of on-site work and time on the site will be reduced to a minimal. The use of two field crews will also increase the efficiency of the field work. able to complete the sampling of eight sites per all of the samp.les for this study should require B. Personnel Assignments Two field crews should be week. The collection of approximately one month. The following personnel will be used 1n this investigation: Charles Lee -Project Officer Charles Wilson -Site Survey Team Chief Gene Oliver -Sampling Team Chief Roger Franklin -Site Survey Team Member Chris Leggett -Site Survey Team Member Neal Strickland -Sampling Team Member Jack Scott -Sampling Team Member V. STATISTICAL ANALYSES According to the Central Limit Theorem of Statistics (Parsons, 1974), for a sample size of 30 or more, the statistical sampling distribution that results will be close to normally distributed regardless of the shape of the original universe from which the samples were taken. A normal distribution is totally described if the mean and standard deviation of the distribution are known. Therefore, although geologically-related universes are commonly log-normally distributed, data from 30 sampling locations can be treated as if they are normally distributed to obtain mean and standard deviation using standard statistical equations. From these data, confidence interval estimates of the -5- universe mean value for PCB concentrations throughout the entiure 210 miles of spill can be mad e. In addition, confidence stat eme nts can be made concerning the amount of variance between the universe and sampling statistic. VI. REPORT PREPARATION Following receipt of analytical results from the laboratory, a draft report, which will include a description and summary of the field work, maps, and PCB analytical results will be submitted by E&E to EPA and North Carolina State representatives. Rased on these data, personnel from E&E, EPA, and the State will meet to discuss conclusions, recolT[llendations, and potential follow-up studies. At the conclusion of these meetings, when the parties are 1n agreement, a second draft and a final report will be prepared by E&E for EPA and State representatives that includes description and summary of field work, maps, analytical results, statistical analytical results, distribution and concentration maps, models (if appropriate), conclusions, and recommendations for follow-up studies. VII. METHODOLOGY A. Methodology for Sample Location Selection 7 . B. From the Emergency Action Plan (Lee, 16 February 1981, Table 1 p. 11-12) all spill locations were selected from which analyses indicate PCB values greater than or equal to 50 ppm. Consecutive numb ers were assigned to each of these spill locations and thirty locations were selected using random number tables. These locations were plotted on maps that appear as Appendix C. One location in each of th e three physiographic provinces (Coastal Plain, Piedmont, and Triassic Rasin) where no PCB spill is known, and one location on the Fort Bragg Military Reservation will be selected for sampling and analysis. The results of the "non-spill location" analyses will provide control data only, and will not be included in the stat istical study . Analyses from samples taken at Fort Bragg will provide data on the military facility and also will not be included in the statistics. How1=.vt:)l, cc~,-JbN C>~ Inf:. -foe.I &r<.~QQ SAM'Pl.€ ~~ r,;::i."f"'A lNl°'IVI ?i"Y\;e 5Th1'151lc.AL. HOT>El.. ('tl-A.Qi'Q .. tr<>Q:10.."1'E) MA'f e,i::: ·~!>l:C"9 llfo-o(1P,~I!!. ,..,A,.,, (3E t;e4='o~e'O A map of all the sample locations is included as Figure 2. Site Survey Methodology Each of the individual sampling locations will have been identified and marked by the reconnaissance team. The survey team will establish the exact location of each individual sampling point . A steel rod will be installed approximately six inches below the soil surface at each sampling point so that a metal detector can be used to reloc ate this point in t he future should this be necessary. Each of the sampling points will be referenced to distances and angles. The topography and geology the number of samples to be collected. Each site than 20 samples½;> Upstream and downstream samples • \J N U:55 f v'1.. Tn 1!7t. SA.M f LE:, ""f.k "1'Z>Po'=1~9°A\t.~L . · • ~NI) bc1:>U>E,\~L S11'\J-P.."f\l>N$ ~NO -6- the site center marker by of each site will dictate will consist of no more from those sites having ~ v',e.e-o 1)1.)f" -ro COl"t°'P~ ~il-E -ti." Prlt>'{E£> B'1 c?A streams will be collected by EPA, Surveillance and Analysis Division. Surface sampl es will be collected at all locati o~s with the exception of one point on the shoulder of . the road in wh i c~~A ~l/,"tt sample wi 11 be 11~~ II II I collected ~ a depth of 0F1e fo81... {. sA?<JO I 13 ,o 12.d'~E::NT 7'nf" ) LEc.L • Sufficient sampling points will be selected to fully determine the migration of PCB from the site. Each of these points will be marked with a steel rod and will be referenced to the site center marker. A detailed sketch will be prepared for each sampling location which will show the location of each sampling point. A hypothetical sampling location is shown as Figure 3. The site sketch will be augmented with photographs of each location. C. Sampling Methodology The collect1on of samples and all field ~easurements involved in this field investigation will be conducted in accordance with the Standard Operating Procedures and Quality Assurance Manual (Draft), August 29, 1980 as published by the Region IV Surveillance and Analysis Division of the U.S . Environmental Protection Agency. The following is an outline of those procedures to be used in the collection of samples for this investigation. Soil samples will be collected at the surface leve l throughout the sampling site to determine lateral migration of the PCB. The ground cover will be removed from the sampling point and the exposed soil will be collected using a clean stainless steel spoon or spatula. One sampling location on the shoulde:c: of thejioad wt· 11 then.~ sampled between a depth of 611 and f8" . io ~t:PJ2.J:.-Se-rr-E. I ooT /..1:_V , . . inches. An iron ro will e place in the hole to mark the sampling point and the hole will be filled . Positive steps will be taken to prevent cross-contamination of the samples. The sample containers will be new one quart g lass containers which have been rinsed twice with pesticide grade petroleum ether and allowed to dry. After the sample has been collecte d, the sample container will be sealed in a polyethylene bag. All equipment used in the collection of the sample ~NC.,\..vOE will be cleaned with detergent and water, rins<:_d with pesticide grade_ lAH\_,..T"' acetone and rinsed again with distilled water.)( Other steps wi 11 include w,\\ ~ the use of disposable coveralls, booties and gloves which wi 11 he changed l:ib'!e: W))½ · .., lb1J • between sampling sites. Those samples expected to have the least amount of Sbh>Tlbi,: PCB contamination, due to location and proximity to initial spill, will be collected before those expected to have a greater degree of contamination . D. Chain-of-Custody Methodology After each of the samples has been collected, it will be tagged with a serialized tag to insure proper identification. The sample will then be sealed with a signed and dated custody seal which wi ll he broken only by the analytical laboratory. A serialized chain-of-custody record form will accompany the sample to the analytical laboratory. Appendix A contains examples of the sample tag, and the chain-of-custody record form along with instructions for their use. -7- a: V) \,) z ('. PEBBLE 0 ~1 ... 0 V'l 0 0 FLAT PLAIN ::JJ 0 (') '.A -< HIGHWAY CUT . PRIVATE DRIVE -MR. JOHN SMITH HYPOTHETICAL SAMPLING SITE FIGURE 3 VIII. SAMPLE ANALYSIS Due to the large number of samples re quired to complete this study, the samples may have to be split between two or more analytical la bo ratories. A portion of these samples may be sent to laboratories under existing contracts with EPA. Additional laboratory capacity may have to be obtained via contract with other private laboratories. A quality assurance program will have to be developed by the Laboratory Services Branch of the Surveillance and Analysis Division, EPA. The quality assurance program will be developed based on the number of laboratories required to analyze the samples. -9- APPENDIX A SAMPLE DOCUMENTATION SAMPLE TAG 1. Leave Project Code Blank 2. Sampling Site No. 1346-E-00-0 Where: 1346 -State Road Number E -East Side of Road 00 -Sampling Site Number 0 -Sample Station Number 3. Location of Sampling Station, i.e., 115 SE, which desi gnates 115 feet southeast of cent e r marker 4. Date sample was collected 5. Military time sample was collected 6. Signatures of two (2) samples 7. Check type of samples 8. Sample tag number must be entered on field sheet 9. Leave Blank 10. Indicate sampl e is soil or sediment. Also indicat e whether the sample was collected on -site or off-site. Record HWS I (Hazardo us Was t e Site Investigation)., 11. Indicate analysis, i.e., PCB 1260 12. Do not check these blocks 13. Indicate sample has not been preserved 14. N/ A Project Code ..... ., Station Local,on Month/Day/Yea, Designate: Comp. Grab Samplers (S,,;n.ituresl ~ 1------~--,-~-,---,--r:--,..=-lf-=.,-:::::,-:=-,r=--r:----r=-ir-:-:=-=~---r---i :D OJ 3: -u < ""CJ 0 0 C) 3:: s: -u C) (fl OJ 0 r-., er Cf) ., 3 'O iii z ? ct) "" s ct) 0 '° '< ~ ~ = 0 ~ 0 3 ~ V> ~ "" "" "" ct> .□ D "" ~ :::, ~ n :::, a. ~ ~ <O c=,· :::, :::, c:: 0 "' a. a. "' -< :><"' (1) ct> '< n ct> -< V> 0 :::, a. -u V> ~ n 0 )> n ct> s> V> 0 )> 0 (/') 0 C) ct> ..... :::, z '° '< = .0 "" Cf) '< "" c:: ---V> z ':!! 0 )> ::, Cl) c:: :::, "" s: -=. V> r n ;,! (fl -< V> V> ct> 0 ;,! ':!! C/) V> m (fl C/) (fl UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 4 Surveillance and Analysis Division College Station Road Athens, Georgia 30308 &EPA -< (l) "'O Ill ... (I) D CII (I) ... < z ~ ~ 0 < (l) D 0 0 CHAIN OF CUSTODY RECORD 1. Leave project number blank 2 . Record N.C . PCB Spill: Not sample location 3. Signatures of two (2) samplers 4. Record type of sample container, i.e ., one quart glass-soil 5. Indicate site number: Sampling Site No . 1346-E-00-0 Where: 1346 -State Road Number E -East side of road 00 -Sampling site number 0 -Sample station number 6. Record date sample was collected 7. Record'military time sample was collected 8 . Leave Blank 9 . Check if sample was a grab 10. Write description of sample collection location, 1.e., 115 SE, which designates 115 feet southeast of center marker 11. Record number o·f sample containers 12 . Record number of each type container 13. Record tag numbers of samples and any special warning to lab concerning samples 14. Record the name of the persons relinquishing custody of the samples 15. Date samples were relinquished 16. Military time samples were relinquished 17. Sugnature of person receiving samples. If the Federal Express agent will not sign the form, record "Federal Express" and the airbi 11 number. 18. Signature of laboratory personnel receiving samples 19. Re cord any remarks concerning custody of samples ,IRONMENTAL PROTECTION AGENCY Survlllllance and Analysis Division CHAIN OF CUSTODY RECORD 1ROJ. NO. PROJECT NAME 0 0 NO. 'v1PLERS'. (Signature) 0 OF .. 4 CON· 0: co TAINERS .\.NO. DATE TIME ~ <( STATION LOCATION 0 a: -u (.:l ~5) (6 (7) ra~ \. ') 19 \. 10) 01) G2) . ' ) nquished by: (Signature) Date / Time Received by: (Signature) Relinquished by: (Signature) e @ @ ® nquished by: (Signature) Date / Time Received by: (Signature) Relinquished by: (Signature) nquished by: (Signature) Date / Time Received for Laboratory by: Date /Time Remarks (Signatur8) @ Distribution: Original Accompanies Shipment; Copy to Coordinator Field Files . Q3 Date / Time Date /Time I @ REGION 4 College Station Ro~d · Athens, Georgia 30613 REMARKS . n .. ~ 77. ~1' I Received by: (Signaturo) Received by: (Signature) " f") f"'\ -1 . APPENDIX B SAFETY PLAN ECOLOGY & ENVIRONMENT, INC. FIELD INVESTIGATION TEAM SITE SAFETY PLAN DATE: October 9, 1981 SITE: N.C. PCB Spills PREPARER: C. H. Wilson LOCATION: Durham, N.C. Vicinity TDD NO.: F4-8109-02 INVESTIGATIVE OBJECTIVE(S): To determine mi grat ion of PCR from N.C. Highways ---------'------------------'----"---------PROPOSED DATE OF INVESTIGATION: undertermined _B_A_C_K-GR-OU_N_D_R_E_V_I_E_W_: ___ C_O_MP_L_E_T_E_ (] · PRELIMINARY □ -------------- DOCUMENTATION/ SUMMARY: OVERALL HAZARD SERIOUS □ MODERATE_[] UNKNOWN □ SITE/WASTE CHARACTERISTICS WASTE TYPE(S): LIQUID(] SOLID SLUDGE □ GAS □ CHARACTERISTIC(S): CORROSIVE IGNITABLE □ RADIOACTIVE □ VOLATILE □ TOXIC (] REACTIVE UNKNOWN □ OTHER □ FACILITY DESCRIPTION: SIZE 210 miles of highway BUILDINGS none -----------TOPOGRAPHY varies -generally rolling PRINCIPAL DISPOSAL METHOD (type and location) ....,..-,-------,-----,,------,-illegal dumping of PCB along highway shoulder .UNUSUAL FEATURES (dike integrity, power lines , terrain, etc.) STATUS (open, closed, unknown) HISTORY (worker or non-worker injury; complaints from public; previous agency action): No cleanup actiorr has been initiated on the site No reports of health problems or in jury are on file HAZARD EVALUATION PCB (Aroclor-1260) was illegally dumped on the shoulder of 210 miles of N.C. Highways in 1978. The PCB was covered with a layer of activated carbon and liquid asphalt to control migration, however, all visible signs of this covering are gone . The site was sampled by the State of N.C . and the U.S.EPA. Disposal booties, Tyvek coveralls and disposable gloves will be used by sampling personnel to prevent cross-contamination of samples. This level of protection is adequate to protect personnel as PCR has only a moderate toxic effect via oral and dermal routes. Personnel are to avoid contact with contaminated areas. WORK PLAN INSTRUCTIONS I. PERIMETER ESTABLISHMENT: MAP/SKETCH ATTACHED □ SITE CONTROL □ PUBLIC PERIMETER IDENTIFIED □ ZONE (S) OF CONTAMINATION IDENTIFIED □ NOTES: Maps/sketchs to be prepared during field reconnaissance ~ND 6 r1 Ci::. S\JQ.-.f £'1 I I. PERSONAL CLOTH ING: LEVEL OF PROTECTION: A □ B □ C □ D [] MODIFICATIONS: Disposable boo ties , Tyvek cove ralls and dispo sable gl oves to be worn and changed between sampling sites SURVEILLANCE EQUIPMENT AND MATERIALS: Clhuio11slv c<JJ;1tBffliPiatcd disr,@~P.ls- -elsthiR~ uill 's e l;)urle<J QR site . All other disposable clothing will be collected and will be di sposed of at the conclusion of the s tudy. Tu~~t;;: III. DECONTA.~INATION PROCEDURES: HOT LINE LOCATI ON (initial): N/A ~--~---------------------COMMAND POST LOCATION (initial): N/A -----------------------PD S STATIONS: 1. _________ 2. 3. --------~-4. --------5. EQUIPMENT AND MATERIALS/SPECIAL FACILITIES: b-()\~IN 1,v\-\t..r w,\\ &£ PONE w,~ 't> I ~~t>~S\~LE C.Lt)"'\Y'IINg '\NO D' C.pl\J So\uT ~oN .S IV. SITE ENTRY PROCE DURES : V. TE AM SIZE: E & E 3 ea EPA STATE 7 .. OTHER ---ENTRY BRIEFING (date) STATION DESIGNATION (name/responsibility): 1. Chuck Lee -Project Officer 2. C.H. Wilson -Te am Leader 3. Gene Oliver, Team Leader -----~---------------4. Roger Franklin -Team Member 5. Jack Scott, Team Member -------'-----------------6. Chris Leggett, Team Member 7. Nea l Strickland, Team Member ---------'--------------WORK SCHEDULE/LIMITATIONS: none -------'---------------------- NOTES: EMERGENCY PRECAUTI ONS : ACTIVE EXPOSURE SYMPTOMS 1. Chloracne 2. Nausea -Vomiting 3. Loss of weight 4. e dema 5. Abdominal Pain 6. OTHER HOSPITALS/POISON CONTROL CENTERS (address, t ele ph one no.) 1. Duke University Medical Center, Durham, N.C. 684-8111 2. 3. 4. 5. FIRST AID Remov e personnel from site - Take to Hospital EMERGENCY TRANSPORTATION SYSTEMS (fire, police, ambulance) 1. Durham Police Department 688-8251 2. Durham Fire Department 683-4242 3. Duke University Medical Center Ambulance 684-8111 VI. EMERGENCY ROUTES 1. Markam Avenue to Duke Street, West on Chapel Hill Street to University Grounds 2. 3. 4. SCBA □ APR □ CYLINDERS □ CARTRIDGES □ EXPLOS IMETER □ 02 INDICATOR □ DRAEGER PUMP □ TUBES □ RADIATION SURVEY METER □ RADIATION CONTAMINATION METER □ Approved by~FITL /J-/ OC.T/f'r/ EQUIPMENT CHECKOUT EYE WASH UNIT[] FIRST AID KIT [] DRINKING WATER SUPPLY □ PERSONAL CLOTHING (] DECONTAMINATION MATERIALS □ ORGANIC VAPOR ANALYZER □ OTHER □ APPENDIX C MAPS OF SAMPLE LOCATIONS ~- .._ I /-• . : Sil I ,.: ___._ .. 11!!----. 1004~ -------. ,oo, .. -~ ~ JIJ L ' AJ.,___ ., '.JT1 !_•~ ' • \__ • '!t<I. ,... ,~ , CP" ( __ ·, \ \ \. \ \~ ->'" ~ ~~ Y. ·-. 1, .,_' ' ~> " I , _ ____.,~\.~ • • I J . . - \\ \ ~i SAMPLE B f '1 -.,;1 .. ,,~ , · ~~ rr,1. . ~ '>, ' ____ ,.. \,%' ,, = 1,1u' · .O· I ~_HA~ - ! -~ I LEE co. l ' ; I / \ I ] I -~ 11,• \ I : I :( ' ~-... ~ 1\ 1,-~ .. w ~-~·- • SAN 0 ' ri , '\ ~ ' \ •1' . ., .. -.,J-:. --..._ __ c '1)4 '! ~+ .. ;:. --s -.. --.c .,, .!..~~!f.-..,. ✓>:;::--~ ~ ---· ~•1 <"!'--~ ) / ~ ,/,<CW '\ ,;;, I -,'6y .-.,\.t: ) . . 8 ~a ~ Bill! \ \ I ~-"! / r1 ', / \j I I \ J I .Jl fl . / '..!.11. , ,,11 .. 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'/,•~ ~ (AS1"'-'JA ,.,-;,,, :us -~ • ..J.!Jl / ;~ -. .. ·, . ., . . ··"")~ ' c.., ,I,· '---,.-. -~, ' .J ....__, .-1 ...,. _ • 1 s ........._, ::::__,,, r) '-~-. ....-~. -cAs · ---'W );-··~ ,,-. •j-°1-"'·-· -r" --,, , ----:--"""'<;::-~ ..A ---RrJ.41,:11, -,_ --' ....... I' ... ,,. ! .