Document JrjEj5QDqpOvKQM7Rbq0yEdDe

REPORT OF RCRA COMPLIANCE INSPECTION September 9, 2024 By TOEROEK ASSOCIATES, INC. and TETRA TECH INC. For U.S. ENVIRONMENTAL PROTECTION AGENCY Region 10 Land Enforcement Section INTRODUCTION At the request of U.S. Environmental Protection Agency (EPA) Region 10, Toeroek Associates, Inc. and its subcontractor Tetra Tech Inc. (Toeroek team) conducted hazardous waste compliance evaluation inspections (CEI) at sites owned or operated by the North Slope Borough (NSB) in , Alaska. Based on my observations, the NSB sites generating hazardous waste, used oil, or universal waste in consist of five sites with EPA ID numbers. These are: AKD983066051, Public Works Transit Shop/High School, at 1685 Okpik Street AKR000205229, the South Pad, on Nunavaaq Street AKR000210856, Fire Station 1, at 1040 Kogiak Street AKR000210864, Warm Storage/Shop 1/Shop 2, at 3429 Stevenson Street AKR000206623, Shop 3, at 3490 Stevenson Street Copies of the EPA notifications for active sites operated by the NSB in are included in Appendix A. Of these, the Public Works Transit Shop/High School, South Pad, and Warm Storage/Shop 1/Shop 2 consisted of more than one operation on contiguous property. Aerial photographs with the mapped sites and operations are included as Appendix B. I based these groupings of operations - Code of Federal Regulations (40 CFR) 260.10. The CEI was conducted under the authority of Section 3007 of the Resource Conservation and Recovery Act (RCRA), as amended, and the 2022 Consent Decree (case no. 3-22-cv-00059-JWS) between EPA and the NSB. The CEI covered requirements of the Consent Decree, as well as hazardous waste generator, used oil, and universal waste requirements. This report and its attachments present findings of the CEI. I have divided the report by site. On September 9, 2024, I arrived at the offices of the Department of Public Works (DPW) at 1689 Okpik Street I presented myself to the receptionist and explained the purpose of my visit. She told me that Ms. Stephanie Edwardson, the Program Manager for DPW, was home sick. She passed me to Ms. Olianne Tinker in the Water and Sewer department. I waited there for approximately 20 minutes until Mr. George Ahmaogak arrived. Upon Mr. arrival, I explained the purpose of the CEI. I presented my EPA credential and explained the scope and procedures for the CEI. I explained the right to make confidentiality claims and that I would provide a summary of findings at the conclusion of the inspection. Page 1 of 16 I conducted the visual inspection of the five sites listed above, accompanied by Mr. Ahmaogak. At the conclusion of the CEI, I conducted an exit briefing with Mr. Ahmaogak to discuss preliminary findings. All 124 photographs taken during the inspection are included in Appendix C. Observations during the inspection are also described in the photolog (Appendix C). PARTICIPANTS NSB: George Ahmaogak NSB Deputy Director of Roads, Airports & Sanitation Chris Battle NSB Transportation Coordinator Blake Mikesell Director of Maintenance and Operations for the NSB School District (NSBSD) Kalen Texeira Anthony Neakvok Randy Osborn NSB Maintenance Department Steven Watson NSB Maintenance Department Sone Pili NSB Shop Manager, Shop 1 Christian Caoile NSB Sanitation Supervisor Toeroek Team: Heather K. Wood, Inspector, 816-412-1768 Public Works Transit Shop/High School AKD983066051 The Public Works Transit Shop/High School notified of activity as a small quantity generator (SQG) on September 1, 2024. It was originally assigned in July 1988. It consists of the Transit Shop, the High School, and the Transit Waste Pad on contiguous property. I did not inspect the High School. Based on information collected during the inspection, the Transit Waste Pad is only a collection point for wastes generated at the Transit Shop and from a renovation of the High School. However, Mr. Ahmaogak said that much of the waste from the Transit Shop should have been going to the waste storage area at Shop 3 (described below). He said that it was possible that waste was being put at the Transit Waste Pad that had been generated at other sites from other sites, the site would be storing hazardous waste without a permit in violation of RCRA Section 3005. In addition, multiple waste streams had not been adequately characterized. If these waste streams are determined to be hazardous waste and the quantities exceed 1,000 kilograms (kg), additional findings may apply related to labeling and dating of containers and accumulation time limits, at minimum. If the quantities exceed 6,000 kg, large quantity generator (LQG) requirements would apply. Preliminary Findings 1. Failure to make a waste determination on inherently waste-like coolant, unknown wastes, used glycol coolant, waste paint and paint thinner, and unknown waste, as required by 40 CFR 262.11 (NOPF No. 1). 2. Failure to store used oil in a storage container in good condition, as required by 40 CFR 279.22(b)(1) (NOPF No. 2). Page 2 of 16 Transit Shop The Transit Shop is used to maintain buses and other vehicles used by the NSB and the NSBSD. During my inspection of the Transit Shop, we were met by Mr. Battle. During the inspection, I observed the following waste streams: One 55-gallon container (drum) of used oil (Photograph 1). The container was in good condition Battle, the shop generates three or four drums of used oil per year. It is ultimately taken to Shop 3, but is currently being taken to the Transit Waste Pad. One drum of used glycol coolant (Photograph 1). Based on the Comprehensive Hazardous Material, Solid Waste, Hazardous Waste, and Used Oil Management Plan (WMP) created as a condition of the Consent Decree, used antifreeze may or may not be hazardous, based on metal content. This used glycol coolant had not be analyzed for metals. I concluded that the site had failed to make a hazardous waste determination on the used glycol coolant, as required by 40 CFR 262.11 (NOPF No. 1). One approximately 15-gallon parts washer that will use aqueous parts washing solution (Photograph 2). The parts washer was new and empty. I asked Mr. Ahmaogak and Mr. Battle if they knew what kind of solvent would be used in the washer, but they did not. An empty 1-cubic-yard container for used lead-acid batteries (battery box). According to Mr. Battle, the site generates approximately 10 used lead acid batteries per year. According to Mr. Battle, used oil filters are punctured, hot drained, and put in the trash. I did not observe used oil filters in the Transit Shop. Transit Waste Pad After I inspected the Power Plant, Mr. Ahmaogak and I went to a container storage area on the opposite side of Okpik Street. We were met there by Mr. Mikesell. According to Mr. Ahmaogak, this area was intended to be a staging area for wastes generated during renovation of the High School and a storage area for equipment. However, he said that the Transit Shop had been bringing its waste to this area, rather than having it transported to Shop 3. He also said he was not sure if other sites had also brought their waste to this area. I observed numerous drums, totes, and other debris in the area, which was not under cover (Photographs 17, 21, and 23). Mr. Mikesell and Mr. Ahmaogak said that a nearby NSB building had caught fire and been mostly destroyed in the winter of 2023-2024. After the inspection, I found a news report that described the fire that destroyed the NSB Shipping and Receiving Building in late January 2024 (Appendix D). This building was approximately 600 feet southeast of the Transit Waste Pad, and its location is shown in Appendix B. Mr. Mikesell and Mr. Ahmaogak said that the runoff from this fire reached the Transit Waste Pad, resulting in numerous containers being immobilized by ice. He and Mr. Mikesell said that Clean Harbors had been at the area in April 2024 and had inventoried and attempted to transport the waste drums. However, because of the ice, they said that only half of the drums could be removed. I observed inventory numbers on many of the drums, presumably marked during the Clean Harbors inventory. After the inspection, I reviewed the e-Manifest database, but I could not find a record of this transportation event or any other shipment using this generator ID since January 2024. During my inspection, I observed that one of the containers of unknown waste had tipped over and discharged its contents to the ground (Photographs 25, 26, 28, and 29). Surface water adjacent to the container had a visible oil sheen. I was able to see the surface water with the sheen leaving the Transit Page 3 of 16 Waste Pad and flowing toward nearby Isatkoak Lagoon. If the waste that had been in the container was used oil, the site would have failed to immediately address a release of used oil, as required by 40 CFR 279.22(d). If it was hazardous waste and the site is, in fact, a SQG, the site failed to operate in such a manner to prevent a release of hazardous waste to the environment, as required by 40 CFR 262.16(b)(8). However, because of the large number of uncharacterized containers, I could not establish the actual generator status or the relevant regulatory citation. Due to the uncertainty about the type of waste released and the generator status, I did not make a specific preliminary finding regarding this release. During the inspection, I observed the following waste streams: One battery box and approximately 15 loose used lead-acid batteries on pallets and in shipping containers (Photographs 4, 5, 14, and 16). These were destined to be sent offsite for recycling under the conditions of 40 CFR Part 266 Subpart G. Four battery boxes of waste paint and paint thinner containers (Photographs 6, 7, 8, and 12). These containers were rusted and labels could not be read. I concluded that the site had failed to make a hazardous waste determination on the waste paint, as required by 40 CFR 262.11 (NOPF No. 1). Two battery boxes of oily water and sediment (Photograph 10). Mr. Ahmaogak was not sure what process had generated this waste. Six battery boxes in the lower tier that could not be opened due to the overlying containers (Photograph 6, 7, 9, 11, and 13). Approximately 20 drums identified as used oil and used coolant (Photograph 14, 17, 18, and 22). (Photograph 20). I concluded that the site had failed to store used oil in a storage container in good condition, as required by 40 CFR 279.22(b)(1) (NOPF No. 2). Five containers of unused glycol coolant (Photograph 30). Mr. Ahmaogak and Mr. Mikesell said that this coolant was still usable. Based on the condition of the five metal containers (dented and rusted), I considered these containers to be inherently waste-like. I concluded that the site had failed to make a hazardous waste determination on the inherently waste-like coolant, as required by 40 CFR 262.11 (NOPF No. 1). Approximately 40 containers of unknown waste (Photographs 15, 17, 18, 19, and 27). These containers were not labeled, although some had inventory numbers that presumably link to an inventory prepared by Clean Harbors in April 2024 (Photographs 21, 23, and 24). I concluded that the site had failed to make a hazardous waste determination on the unknown waste, as required by 40 CFR 262.11 (NOPF No. 1). Fifteen waste fire extinguishers (Photograph 13). Page 4 of 16 the site. I concluded that the site was meeting the requirements of the exemption at 40 CFR 279.23. One drum of crushed used oil filters under a filter crushing unit. The filters are drained into a used oil storage container, then taken to the crusher (Photographs 66 and 67). At the crusher, they are crushed and fall into the container, and the used oil drained from the filter flows into a 5-gallon used oil storage container, also under the unit (Photographs 68 and 69). The used oil transported to Shop 3 for recycling or disposal. I concluded that the site met the requirements for exemption in 40 CFR 261.4(b)(13). Osborne and Mr. Watson, the shop generates approximately 55 gallons used crushed used oil filters per year. Two drums of oily absorbent and rags (Photographs 62 and 63). According to Mr. Osborne and Mr. Watson, these are used to clean up spills of oil or grease, not coolant. They are not considered hazardous based on product and process knowledge. In the shop, one drum of used glycol coolant (Photograph 65), and, in the drum area, approximately 10 containers of used coolant, some mixed with used oil (Photographs 79 and 80). Based on the WMP, used antifreeze may or may not be hazardous, based on metal content. This used glycol coolant had not be analyzed for metals. I concluded that the site had failed to make a hazardous waste determination on the used glycol coolant, as required by 40 CFR 262.11 (NOPF No. 1). In the drum area, approximately 35 drums of contaminated fuel (Photographs 81, 83, 85 and 86). This included waste diesel fuel, fuel mixed with water, and waste gasoline. Per the WMP, contaminated fuel is generally considered hazardous. These mixtures had not been tested for flashpoint. I concluded that the site had failed to make a hazardous waste determination on contaminated fuel, as required by 40 CFR 262.11 (NOPF No. 1). Approximately 60 drums of oily liquids in the drum area east of the shop, including used oil mixed with fuel or coolant and oily water from the oil change pits (Photograph 82). These containers were labeled Because the used coolant had not been tested for metals and the contaminated fuels had not been tested for flashpoint, I concluded that the site had failed to make a hazardous waste determination on oily liquids, as required by 40 CFR 262.11 (NOPF No. 1). One drum of used aerosol cans awaiting puncture (Photograph 72 through 74). It was labeled as According to the WMP, used aerosol cans may be managed as universal waste, in which case they are not punctured. If they are not managed as universal waste, they must be characterized as hazardous or nonhazardous. Because these cans were being punctured, I concluded that they were not considered universal waste. The cans had not been characterized as hazardous or nonhazardous, as required by 40 CFR 262.11 (NOPF No. 1). According to Mr. Osborne and Mr. Watson, the shop generates approximately 55 gallons of used aerosol cans per year. One drum of aerosol can residue with an attached can puncture unit (Photographs 70 and 71). The puncture unit had an air filter over the second bung. Neither Mr. Osborne nor Mr. Watson knew how long this container had been accumulating waste. Because the used aerosol cans had not been characterized, I concluded that the residue had also not been characterized as hazardous or nonhazardous, as required by 40 CFR 262.11 (NOPF No. 1). Page 9 of 16 Used aqueous parts washer solution (Photograph 64). The parts washer in Shop 2 uses Ozzy Juice SW-3, a nonhazardous surfactant washer solution. Neither Mr. Osborne nor Mr. Watson knew when the solution had last been changed. One battery box (Photograph 75). This held approximately 25 batteries at the time of the inspection. Warm Storage Mr. Ahmoagak and I went to the Warm Storage building. I did not observe any waste in this building (Photograph 88). Shop 1 During my inspection of Shop 1, we were met by Mr. Pili. I observed the following waste streams: Two drums of used oil and one 250-gallon tank of used oil (Photographs 89, 90, and 92). The Pili estimated that the shop generates 110 to 165 gallons of used oil every month. When the heater is operational, the used oil is burned in a Black Gold Waste Oil Heater that is specifically designed to burn used oil (Photograph 91). According to Mr. Pili, the used heater is currently not operating, and the used oil is being transported to Shop 3 for recycling or disposal. I was unable to determine the model of the heater, but none of the Black Gold units currently sold burn at more than 500,000 British thermal units (BTU) (Heaters Black Gold Environmental Services). The unit was vented to ambient air, and, according to Mr. Pili, it only burns used oil generated at the site. I concluded that the site was meeting the requirements of the exemption at 40 CFR 279.23. One drum of crushed used oil filters next to a filter crushing unit (Photograph 94 and 95). The filters are crushed, then accumulated in a container that is transported to Shop 3 for recycling or disposal. I concluded that the site met the requirements for exemption in 40 CFR 261.4(b)(13). The used oil drained from the filter flows into a 5-gallon container that is immediately decanted into a nearby used oil storage container. Two drums of used glycol coolant (Photograph 93). According to Mr. Pili, the shop generates approximately 55 gallons of used coolant per month. Based on the WMP, used antifreeze may or may not be hazardous, based on metal content. This used glycol coolant had not be analyzed for metals. I concluded that the site had failed to make a hazardous waste determination on the used glycol coolant, as required by 40 CFR 262.11 (NOPF No. 1). One drum of used aerosol cans awaiting puncture (Photograph 96 through 98). It was not labeled or dated. Because these cans were being punctured, I concluded that they were not considered universal waste, per the WMP. The cans had not been characterized as hazardous or nonhazardous, as required by 40 CFR 262.11 (NOPF No. 1). According to Mr. Pili, the shop generates approximately 55 gallons of used aerosol cans per year. These are taken next door to Shop 2 to be punctured and drained using the unit there. One battery box (Photograph 99). This container was empty at the time of the inspection. Page 10 of 16 RCRA Site Detail Report run on: January 10, 2025 2:42:47 PM EST Transporter: Transfer Facility: Processor: Refiner: Off-Specification Used Oil Burner: No Marketer who directs shipment off-specification used No oil to off-specification used oil burner: No Marketer who first claims the used oil meets the No specifications: Yes Page 3 No No Appendix A Page 3 of 24 RCRA Site Detail Report run on: January 10, 2025 2:52:00 PM EST Destination Facility for Universal Waste: Transporter: Transfer Facility: Processor: Refiner: Off-Specification Used Oil Burner: No No Marketer who directs shipment off-specification used No oil to off-specification used oil burner: No Marketer who first claims the used oil meets the No specifications: Yes Page 3 No No Appendix A Page 7 of 24 RCRA Site Detail Report run on: January 10, 2025 2:58:26 PM EST Transporter: Transfer Facility: Processor: Refiner: Off-Specification Used Oil Burner: No Marketer who directs shipment off-specification used No oil to off-specification used oil burner: No Marketer who first claims the used oil meets the No specifications: No Page 3 No No Appendix A Page 15 of 24 RCRA Site Detail Report run on: January 10, 2025 3:10:11 PM EST Transporter: Transfer Facility: Processor: Refiner: Off-Specification Used Oil Burner: No Marketer who directs shipment off-specification used No oil to off-specification used oil burner: No Marketer who first claims the used oil meets the No specifications: Yes Page 3 No No Appendix A Page 18 of 24 RCRA Site Detail Report run on: January 13, 2025 4:20:50 PM EST Transporter: Transfer Facility: Processor: Refiner: Off-Specification Used Oil Burner: No Marketer who directs shipment off-specification used No oil to off-specification used oil burner: No Marketer who first claims the used oil meets the No specifications: Yes Page 3 No No Appendix A Page 21 of 24 , North Slope Borough, Alaska PHOTO LOG Photographer: Heather K. Wood Type of Camera: Samsung A53 5G UW, Serial # R5CT325KKDT Digital Recording Media: SD memory card All digital photos were copied by: Heather Wood All digital photos were copied to: Personal laptop computer Original copy is stored in: the original image files prior to storage on the server. Pic# Photographer 1 Heather Wood 2 Heather Wood 3 Heather Wood 4 Heather Wood 5 Heather Wood 6 Heather Wood 7 Heather Wood 8 Heather Wood 9 Heather Wood 10 Heather Wood 11 Heather Wood 12 Heather Wood 13 Heather Wood 14 Heather Wood 15 Heather Wood 16 Heather Wood 17 Heather Wood 18 Heather Wood 19 Heather Wood 20 Heather Wood 21 Heather Wood 22 Heather Wood 23 Heather Wood 24 Heather Wood 25 Heather Wood 26 Heather Wood 27 Heather Wood 28 Heather Wood 29 Heather Wood 30 Heather Wood 31 Heather Wood 32 Heather Wood 33 Heather Wood 34 Heather Wood 35 Heather Wood 36 Heather Wood 37 Heather Wood 38 Heather Wood 39 Heather Wood 40 Heather Wood 41 Heather Wood Date 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 Time 9:16 9:18 9:20 9:34 9:35 9:35 9:35 9:36 9:36 9:36 9:36 9:36 9:36 9:37 9:38 9:38 9:41 9:41 9:41 9:42 9:42 9:42 9:42 9:42 9:42 9:42 9:43 9:43 9:44 9:45 9:50 9:51 9:51 10:22 10:22 10:23 10:33 10:33 10:38 10:38 10:38 File Name 20240909_091627.jpg 20240909_091805.jpg 20240909_092010.jpg 20240909_093439.jpg 20240909_093510.jpg 20240909_093522.jpg 20240909_093551.jpg 20240909_093601.jpg 20240909_093612.jpg 20240909_093614.jpg 20240909_093622.jpg 20240909_093627.jpg 20240909_093636.jpg 20240909_093730.jpg 20240909_093843.jpg 20240909_093846.jpg 20240909_094100.jpg 20240909_094111.jpg 20240909_094121.jpg 20240909_094220.jpg 20240909_094230.jpg 20240909_094238.jpg 20240909_094244.jpg 20240909_094247.jpg 20240909_094255.jpg 20240909_094259.jpg 20240909_094302.jpg 20240909_094359.jpg 20240909_094405.jpg 20240909_094544.jpg 20240909_095017.jpg 20240909_095136.jpg 20240909_095140.jpg 20240909_102233.jpg 20240909_102248.jpg 20240909_102302.jpg 20240909_103348.jpg 20240909_103352.jpg 20240909_103808.jpg 20240909_103827.jpg 20240909_103834.jpg Appendix C Page 1 of 66 Pic# Photographer 42 Heather Wood 43 Heather Wood 44 Heather Wood 45 Heather Wood 46 Heather Wood 47 Heather Wood 48 Heather Wood 49 Heather Wood 50 Heather Wood 51 Heather Wood 52 Heather Wood 53 Heather Wood 54 Heather Wood 55 Heather Wood 56 Heather Wood 57 Heather Wood 58 Heather Wood 59 Heather Wood 60 Heather Wood 61 Heather Wood 62 Heather Wood 63 Heather Wood 64 Heather Wood 65 Heather Wood 66 Heather Wood 67 Heather Wood 68 Heather Wood 69 Heather Wood 70 Heather Wood 71 Heather Wood 72 Heather Wood 73 Heather Wood 74 Heather Wood 75 Heather Wood 76 Heather Wood 77 Heather Wood 78 Heather Wood 79 Heather Wood 80 Heather Wood 81 Heather Wood 82 Heather Wood 83 Heather Wood 84 Heather Wood 85 Heather Wood 86 Heather Wood 87 Heather Wood 88 Heather Wood 89 Heather Wood 90 Heather Wood 91 Heather Wood 92 Heather Wood 93 Heather Wood Appendix C , North Slope Borough, Alaska Date 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 Time 10:38 10:39 10:39 10:42 10:42 10:50 10:58 10:58 10:59 11:02 11:02 11:02 11:05 11:05 11:05 11:05 13:23 13:23 13:23 13:24 13:24 13:24 13:24 13:25 13:25 13:26 13:26 13:26 13:27 13:27 13:27 13:33 13:34 13:35 13:36 13:36 13:38 13:38 13:38 13:38 13:39 13:39 13:39 13:39 13:40 13:40 13:46 13:50 13:50 13:50 13:51 13:51 File Name 20240909 103856.jpg 20240909 103904.jpg 20240909 103938.jpg 20240909 104205.jpg 20240909 104227.jpg 20240909 105015.jpg 20240909 105854.jpg 20240909 105856.jpg 20240909 105908.jpg 20240909 110217.jpg 20240909 110240.jpg 20240909 110250.jpg 20240909 110500.jpg 20240909 110513.jpg 20240909 110518.jpg 20240909 110548.jpg 20240909 132333.jpg 20240909 132348.jpg 20240909 132353.jpg 20240909 132413.jpg 20240909 132421.jpg 20240909 132431.jpg 20240909 132452.jpg 20240909 132514.jpg 20240909 132520.jpg 20240909 132610.jpg 20240909 132612.jpg 20240909 132624.jpg 20240909 132712.jpg 20240909 132717.jpg 20240909 132728.jpg 20240909 133343.jpg 20240909 133400.jpg 20240909 133511.jpg 20240909 133638.jpg 20240909 133642.jpg 20240909 133815.jpg 20240909 133827.jpg 20240909 133836.jpg 20240909 133841.jpg 20240909 133900.jpg 20240909 133909.jpg 20240909 133913.jpg 20240909 133954.jpg 20240909 134010.jpg 20240909 134017.jpg 20240909 134645.jpg 20240909 135029.jpg 20240909 135039.jpg 20240909 135050.jpg 20240909 135145.jpg 20240909 135154.jpg Page 2 of 66 , North Slope Borough, Alaska Pic# Photographer 94 Heather Wood 95 Heather Wood 96 Heather Wood 97 Heather Wood 98 Heather Wood 99 Heather Wood 100 Heather Wood 101 Heather Wood 102 Heather Wood 103 Heather Wood 104 Heather Wood 105 Heather Wood 106 Heather Wood 107 Heather Wood 108 Heather Wood 109 Heather Wood 110 Heather Wood 111 Heather Wood 112 Heather Wood 113 Heather Wood 114 Heather Wood 115 Heather Wood 116 Heather Wood 117 Heather Wood 118 Heather Wood 119 Heather Wood 120 Heather Wood 121 Heather Wood 122 Heather Wood 123 Heather Wood 124 Heather Wood Date 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 9/9/24 Time 13:54 13:54 13:55 13:55 13:56 13:58 14:07 14:09 14:09 14:09 14:10 14:10 14:10 14:10 14:11 14:11 14:11 14:12 14:12 14:15 14:15 14:19 14:19 14:20 14:22 14:22 14:22 14:22 14:24 14:24 14:34 File Name 20240909 135430.jpg 20240909 135433.jpg 20240909 135551.jpg 20240909 135554.jpg 20240909 135610.jpg 20240909 135816.jpg 20240909 140755.jpg 20240909 140941.jpg 20240909 140949.jpg 20240909 140956.jpg 20240909 141029.jpg 20240909 141046.jpg 20240909 141051.jpg 20240909 141056.jpg 20240909 141125.jpg 20240909 141132.jpg 20240909 141151.jpg 20240909 141220.jpg 20240909 141226.jpg 20240909 141527.jpg 20240909 141530.jpg 20240909 141951.jpg 20240909 141956.jpg 20240909 142004.jpg 20240909 142211.jpg 20240909 142215.jpg 20240909 142218.jpg 20240909 142234.jpg 20240909 142449.jpg 20240909 142458.jpg 20240909 143418.jpg Appendix C Page 3 of 66 Appendix D Page 1 of 4 (b)(4) copyright (b)(4) copyright Appendix D Page 3 of 4 (b)(4) copyright Appendix D Page 4 of 4