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HomeMy WebLinkAbout0296 WINTER STREET - Health 9y6�fl fe r_ tr6e Hyannis 310 '177 l �l ,F 'I 1 a 9 LWAtlantic DESIGN ENGINEERS,INC. f7, ov �2 March 17, 2018 -n cs"9 Mr. Thomas McKean r Director-Barnstable Board of Health Barnstable Town Hall 200 Main St. Hyannis,MA 02601 RE. Phase V Completion Statement and Permanent Solution with No Conditions 290,294, and 296 Winter Street,Hyannis,MA Dear Mr.McKean: The purpose of this letter is to inform the Barnstable Health Division that a Phase V Completion Statement(Phase V CS)and Permanent Solution with No Conditions(PSNC)has been filed for the 290, 294,and 296 properties in the Village of Hyannis(RTN 4-18675). This Phase V CS and PSNC is being filed following the completion of a Land Use Study in the area and the completion of Phase V monitoring operations in order to achieve a level of Permanent Solution. This public notification is being provided pursuant to the Massachusetts Contingency Plan, 310 CMR 40.1403(3) (f). This documentation has simultaneously been filed with the DEP Southeast Regional Office located at 20 Riverside Drive in Lakeville,Massachusetts.A copy of the report may be reviewed or obtained from the property owner, Mr. Scott Bearse. All documentation relating to the Site can be found on the DEP website under its associated tracking number. If you have any questions,please do not hesitate to call me at(508) 888-9282. Very truly yours, ATLANTIC DESIGN ENGINEERS,INC. Simon B. Thomas, PE, LSP .Principal P.O. Box 1051 Sandwich,MA 02563 (508)888-9282•FAX 888-5859 email: ade@atlanticcompanies.com www.atianticcompanies.com COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENVIRONMENTAL FMRS mpg DEPARTMENT OF ENVIRONMENTAL PROf0py SOUTHEAST REGIONAL OFFICE 20 RIVERSIDE DRIVE, LAKEVILLE, MA 02347 508-946-2700 MITT ROMNEY STEPHEN R.PRITCHARD Governor Secretary KERRY HEALEY ROBERT W.GOLLEDGE,Jr. Lieutenant Governor Commissioner November 10, 2005 Estate of Frank Bearse RE: HYANNIS-BWSC/SMP RTN 4-18675 Scott Bearse, Executor 296 Winter Street 2262 Main Street Transmittal#W068063 West Barnstable, Massachusetts 02668 PERMIT REVIEW STATUS Dear Mr.Bearse: The Massachusetts Department of Environmental Protection, Bureau of Waste Site Cleanup (the Department), has received a complete Tier IC Permit application and associated fee for the above-referenced Site. The official start date of September 15, 2005 has been established for this application. In accordance with 310 CMR 4.04(2)(a), 310 CMR 4.10(10) and 310 CMR 40.0.720(4), the.Department had 45 days from.this..date_to.perform its review of the application and provide (1) a decision to deny the Permit, (2) a decision to grant the Permit with conditions, or(3) a Notice of Review Extension to extend the review period for an additional 45 days. Since the Department did not issue a Notice of Review Extension, or a decision on the application, your application was presumptively approved in accordance with 310 CMR 40.0720(6) on October 29, 2005, which is also the Permit effective date, in accordance with 310 CMR 40.0750. The Permit Number is W068063. The Permit will expire on October 29, 2010. The Department urges you to review and familiarize yourself with the terms and conditions of the Permit and the MCP, 310 CMR 40.0000 et sea•, in order to complete the required response actions within the timelines set forth therein. Failure to comply with the deadlines in the Permit and MCP may result in the Department taking enforcement actions against you, including, but not limited to, the assessment of Administrative Penalties. Please*"be advised that.if a Response Action' Outcome (RAO), pursuant to 310 CMR 40.1000, or Remedy Operation Status, pursuant to 310 CMR 40.0893, can not be achieved at this Site prior to the 'expiration date of this Permit, an application for a Permit Extension, prepared in accordance with the provisions of 310 CMR 40.0706, must be submitted to the Department prior to the expiration date of this Permit. This information is available in alternate format.Call Donald M.Gomes,ADA Coordinator at 617-556-1057.TDD Service-1-800-298-2207. DEP on the World Wide Web: http://www.mass.gov/dep 1100 Printed on Recycled Paper cA A HYANNIS-BWSC/SMP RTN 4--18675 Page 2 of 2 Permit Review Status NECESSARY RESPONSE ACTIONS The Phase I Initial Site Investigation and Tier Classification Submittal,that was prepared on your behalf by Atlantic Design Engineers, LLC and submitted to the Department on September 9, 2005, states that groundwater concentrations at the Site are, "below the applicable Method 1, GW-2 standards." It further states, "The potential for the contamination to volatilize into airspace within the building is, therefore, determined to be very low." However, a review of the groundwater analytical data presented in Table 2 of the submittal indicates that the concentration of the C9-C18 Aliphatics in MW-2, MW-3 and MW-5 exceed the applicable Method 1, GW-2 standards. As such, the Department recommends that the potential for Site-related contaminants of concern to impact the indoor air of any residences located at, or adjacent to the Site be evaluated. At a minimum, a determination must be made as to whether a release to the environment has occurred that has resulted in a Condition of Substantial Release Migration, as defined at 310 CMR 40.0000 (Page 1477),or whether a release to the environment has occurred that is indicated by measurement within the groundwater of equal to or greater than five milligrams per liter of total volatile organic compounds at any point located within 30 feet of a school or occupied residential structure, where the groundwater table is less than 15 feet below the surface of the ground. If it is determined that the above has occurred, then you must notify the Department, pursuant to 310 CMR 40.0313 (4) or (5) and conduct an Immediate Response Action. If you have any questions please contact Molly Cote at the letterhead address or by calling (508) 946-2792. Sincerely, Gerard M.R. Martin,Chief Site Management&Permitting Section M/MC/mc PADocuments\PERMrrS\4-18675 Permit Letter.doc 6] cn CERTIFIED MAIL NO. 7003 1680 0001 4009 5006 E < rn c� ec: Town of Barnstable, Town Manager o Town of Barnstable, Board,of Health cn Simon Thomas, LSP—Atlantic Design Engineers, LLC DEP-SERO Attn: Data Entry a Atlantic i DESIGN ENGINEERS,LLC. ENGINEERS&ENVIRONMENTAL SCIENTISTS ; January 20, 2005 Board of Health Chairman Town of Barnstable 200 Main Street Hyannis, MA 02601 Re: Notice of Release Abatement Measure 296 Winter Street DEP RTN 4-18675 Dear Sir: This to advise you that Release Abatement Measure (RAM) activities are being conducted in accordance with the Massachusetts Contingency Plan(310 CMR 40.0000) on property at 296 and 290 Winter Street in Hyannis,Massachusetts. A Release Abatement Measure Plan has been submitted to the Massachusetts Department of Environmental Protection on or about January 21, 2005 for bioremediation of impacted soil and groundwater at the referenced Site. Please do not hesitate to contact us should you have any questions or comments regarding this matter. Yours truly, ATLANTIC DESIGN ENGINEERS,LLC Simon Thomas,P.E., LSP Principal I PQ BaK 1051 Sandwich,MA 02563 (508)888-9282 0 FAX 888-5859 email;adeinc@cape.com www.atlanticcomponles.com DAtlanfic DESIGN ENGINEERS,L.L.C. ENGINEERS&ENVIRONMENTAL SCIENTISTS September 15, 2008 Barnstable Town Hall Attn: Mr. Thomas A. McKean—Board of Health 367 Main Street Hyannis, MA 02601 RE: 29012941296 Winter Street Notice for Phase IV Remedy Implementation Plan Dear Mr. McKean, Atlantic Design Engineers, LLC has prepared and submitted a Phase W Remedy Implementation Plan for the ongoing remedial activities in Hyannis to the Massachusetts Department of Environmental Protection on September 15, 2008. If you have any question regarding this notice please do not hesitate to call me at(508) 888-9282. I Sincerely, ATLANTIC DESIGN ENGINEERS,LLC CP Simon B. Thomas,P.E., LSP Principal SBT/ksb P.O. Box 1051 Sandwich, MA 02563 j (508) 888-9282 • FAX 888-5859 email: ade@atlanticcompanies.com I www.atlanticcompanies.com i ~� COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PRO SOUTHEAST REGIONAL OFFICE l 20 RIVERSIDE DRIVE,LAKEVILLE,MA.02347 508-94 -2700 MITT ROMNEY ELLEN ROY HERZFELDER Governor Secretary KERRY HEALEY ROBERT W.GOLLEDGE,Jr. Lieutenant Governor Commissioner URGENT LEGAL MATTER:PROMPT ACTION NECESSARY December 9,2004 Mr. Scott Bearse,Executor RE: BARNSTABLE--BWSC Estate of Frank B.Bearse Estate of Frank B.Bearse 296 Winter Street ,r2-96-Wintef beet f-Hyannis Massachusetts 026GlI RTN#4-18675�� NOTICE OF RESPONSIBILITY M.G.L. c.21E,310 CMR 40.0000 Dear Mr.Bearse: On September 10, 2004. the Department of.Environmental Protection (the "Department") received.a Release Notification Form ("RNF"), which indicates that a release of oil and/or hazardous material has occurred at the location referenced above. The Massachusetts Oil._and Hazardous Material Release Prevention and Response Act, M.G.L. c.21E, and the Massachusetts Contingency Plan(the "MCP"), 310 CMR 40.0600,require the performance of response actions to prevent harm to health, safety,public welfare and the environment which may result from this release and/or threat of release and govern the conduct of such actions. The purpose of this notice is to inform you of your legal responsibilities under State law for assessing and/or remediating the release at this property. For purposes of this Notice of Responsibility, the terms and phrases used herein shall have the meaning ascribed to such terms and phrases by the MCP unless the context clearly indicates otherwise. The Department has reason to believe that the release and/or threat of release,which has been reported,is or may be a disposal site as defined by the M.C.P. The Department also has reason to believe that you(as used in this letter,"you"refers to the Estate of Frank B.Bearse)are a Potentially Responsible Party(a"PRP")with liability under M.G.L.c.21E§5,for response action costs. This liability is"strict", meaning that it is not based on fault,but solely on your status as owner,operator,generator,transporter, disposer or other person specified in M.G.L.c.21E§5. This liability is also"joint and several",meaning that you may be liable for all response action costs incurred at a disposal site regardless of the existence of any other liable parties. The Department encourages parties with liabilities under M.G.L. c.21E to take prompt and appropriate actions in response to releases and threats of release of oil and/or hazardous materials.By taking prompt action, you may significantly lower your assessment and cleanup costs and/or avoid liability for This information is available in alternate format.Call Donald M.Gomes,ADA Coordinator at 617-556-1057.TDD Service-1-800-298-2207. DEP on the World Wide Web: http://www.mass.gov/dep Zf1 Printed on Recycled Paper 2 costs incurred by the Department in taking such actions. You may also avoid the imposition of,the amount of or reduce certain permit and/or annual compliance assurance fees payable under 310 CMR 4.00. Please refer to M.G.L. c.21E for a complete description of potential liability. For your convenience, a summary of liability under M.G.L.c.21E is attached to this notice. You should be aware that you may have claims against third parties for damages, including claims for contribution or reimbursement for the costs of cleanup. Such claims do not exist indefinitely but are governed by laws which establish the time allowed for bringing litigation. The Department encourages you to take any action necessary to protect any such claims you may have against third parties. SITE INFORMATION Atlantic Design Engineers was retained in July 2004 to conduct a limited subsurface investigation to assess potential impacts associated with a former underground storage tank (UST). Three soil borings were advanced and I-inch groundwater monitoring wells installed. Groundwater—1 Standards apply to this site,as it is within the Zone II of a public drinking water supply well. Information provided on the completed Release Notification Form indicates that the following contaminants were detected in concentrations which exceed the applicable Reportable Concentration standards for Soil Category 1 (RCS-1)and Groundwater Category 1 (RCGW-1)as established in the MCP, 310 CMR 40.1600. CHEMICAL CONCENTRATION RCS-1 Extractable Petroleum Hydrocarbons C11-C22 Aromatic 733 mg/kg 200 mg/ka C9-C18 Aliphatic 2,330 mg/kg 1,000 mg/kg CHEMICAL CONCENTRATION RCGW-1 Extractable Petroleum Hydrocarbons C 11-C22 Aromatic 12,400 ug/L 200 ug/L C9-C18 Aliphatic 54,200 ug/L 1,000 ug/L C19-06 Aliphatic 17,600 ug/L 5,000 ug/L This site shall not be deemed to have had all the necessary and required response actions taken unless and until all substantial hazards presented by the release and/or threat of release have been eliminated and a level of No Significant Risk exists or has been achieved in compliance with M.G.L. c.21E and the MCP. Unless otherwise provided by the Department, potentially responsible parties ("PRP's") have one year from the initial date of notification to the Department of a release or threat of a release,pursuant to 310 CMR 40.0300, or from the date the Department issues a Notice of Responsibility,whichever occurs earlier, to file with the Department one of the following submittals: (1) a completed Tier Classification Submittal; (2) a Response Action Outcome Statement or, if applicable, (3) a Downgradient Property Status. The deadline for either of the first two submittals for this disposal site is September 10,2005.If required by the MCP, a completed Tier I Permit Application must also accompany a Tier Classification Submittal. The I 3 MCP requires that a fee of $1200.00 be submitted to the Department when a Response Action Outcome("RAO")statement if filed greater than 120 days from the date of notification. You must employ or engage a Licensed Site Professional ("LSP")to manage, supervise or actually perform the necessary response actions at this site. You may obtain a list of the names and addresses of LSPs from the Board of Registration of hazardous Waste Site Cleanup Professionals by calling (617) 556- 1145 or visiting http://www.state.ma.us/lsp. If you have any questions relative to this Notice,please contact Julie J.Hutcheson at the letterhead address or at (508) 946-2852. All future communications regarding this release must reference the following Release Tracking Number:4-18675, ry truly yours, Richard F.Packard,Chief Emergency Response Release Notification Section P/JJWre 4-18675.nor120 Attachments: Summary of Liability under M.G.L.c.21E fc: Board of Health Board of Selectmen Fire Department Atlantic Design Engineers P.O.Box 1051 Sandwich,MA 02563 ATTN: Simon B.Thomas,P.E.,LSP ade@atlanticcompanies.com COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PRO SOUTHEAST REGIONAL OFFICE Uky 20 RIVERSIDE DRIVE,LAKEVILLE,MA 02347 508-9 - 700 MITT ROMNEY ELLEN ROY HERZFELDER Governor Secretary KERRY BEAL Y ROBERT W.GOLLEDGE,Jr. Lieutenant Governor Commissioner URGENT LEGAL MATTER:PROMPT ACTION NECESSARY December 9,2004 Mr. Scott Bearse,Executor RE: BARNSTABLE—bWSC- Estate of Frank B.Bearse Estate of Frank B.Bearse -' 296 Winter Street 296 Winter Street a Hyannis,Massachusetts 02601 RTN#4-18675 0 :: m ,T o C-3 -`•.T. NOTICE OF RESPONSIBILITY M.G.L. G 21E,310 CMR 40.0000 - Dear Mr.Bearse: On September 10, 2004 the Department of Environmental Protection (the "Department") received a Release Notification Form ("RNF"), which indicates that a release of oil and/or-hazardous' material has occurred at the location referenced above. The Massachusetts Oil and Hazardous Material Release Prevention and Response Act, M.G.L. c.21E, and the Massachusetts Contingency Plan(the "MCP"), 310 CMR 40.0000,require the performance of response actions to prevent harm to health, safety,public welfare and the environment which may result from this release and/or threat of release and govern the conduct of such actions. The purpose of this notice is to inform you of your legal responsibilities under State law for assessing and/or remediating the release at this property. For purposes of this Notice of Responsibility, the terms and phrases used herein shall have the meaning ascribed to such terms and phrases by the MCP unless the context clearly indicates otherwise. The Department has reason to believe that the release and/or threat of release,which has been reported,is or may be a disposal site as defined by the M.C.P. The Department also has reason to believe that you(as used in this letter,"you"refers to the Estate of Frank B.Bearse)are a Potentially Responsible Party(a"PRP")with liability under M.G.L.c.21E§5,for response action costs. This liability is"strict", meaning that it is not based on fault,but solely on your status as owner,operator,generator,transporter, disposer or other person specified in M.G.L.c.21E§5. This liability is also"joint and several",meaning that you may be liable for all response action costs incurred at a disposal site regardless of the existence of any other liable parties. The Department encourages parties with liabilities under M.G.L. c.21E to take prompt and appropriate actions in response to releases and threats of release of oil and/or hazardous materials.By taking prompt action, you may significantly lower your assessment and cleanup costs and/or avoid liability for This information is available in alternate format Call Donald M.Gomes,ADA Coordinator at 617-556-1057.TDD Service-1-800-298-2207. DEP on the World Wide Web: http://www.mass.gov/dep L0 Printed on Recycled Paper 2 costs incurred by the Department in taking such actions. You may also avoid the imposition of,the amount of or reduce certain permit and/or annual compliance assurance fees payable under 310 CMR 4.00. Please refer to M.G.L. c.21E for a complete description of potential liability. For your convenience, a summary of liability under M.G.L.c.21E is attached to this notice. You should be aware that you may have claims against third parties for damages, including claims for contribution or reimbursement for the costs of cleanup. Such claims do not exist indefinitely but are governed by laws which establish the time allowed for bringing litigation. The Department encourages you to take any action necessary to protect any such claims you may have against third parties. SITE INFORMATION Atlantic Design Engineers was retained in July 2004 to conduct a limited subsurface investigation to assess potential impacts associated with a former underground storage tank (UST). Three soil borings were advanced and 1=inch groundwater monitoring wells installed. Groundwater—1 Standards apply to this site,as it is within the Zone R of a public drinking water supply well. P g PP Y Information provided on the completed Release Notification Form indicates that the following contaminants were detected in concentrations which exceed the applicable Reportable Concentration standards for Soil Category 1 (RCS-1)and Groundwater Category 1 (RCGW-1)as established in the MCP, 310 CMR 40.1600. CHEMICAL CONCENTRATION RCS-1 Extractable Petroleum Hydrocarbons C11-C22 Aromatic 733 mg/kg 200 mg/kg C9-C18 Aliphatic 2,330 mg/kg 1,000 mg/kg CHEMICAL CONCENTRATION RCGW-1 Extractable Petroleum Hydrocarbons C11-C22 Aromatic 12,400 ug/L 200 ug/L C9-C18 Aliphatic 54,200 ug/L 1,000 ug/L C19-06 Aliphatic 17,600 ug/L 5,000 ug/L This site shall not be deemed to have had all the necessary and required response actions taken unless and until all substantial hazards presented by the release and/or threat of release have been eliminated and a level of No Significant Risk exists or has been achieved in compliance with M.G.L. c.21E and the MCP. Unless otherwise provided by the Department, potentially responsible parties ("PRP's") have one year from the initial date of notification to the Department of a release or threat of a release,pursuant to 310 CMR 40.0300, or from the date the Department issues a Notice of Responsibility,whichever occurs earlier, to file with the Department one of the following submittals: (1) a completed Tier Classification Submittal; (2) a Response Action Outcome Statement or, if applicable, (3) a Downgradient Property Status. The deadline for either of the first two submittals for this disposal site is September 10,2005.If required by the MCP, a completed Tier I Permit Application must also accompany a Tier Classification Submittal. The 3 MCP requires that a fee of $1200.00 be submitted to the Department when a Response Action Outcome("RAO")statement if filed greater than 120 days from the date of notification. You must employ or engage a Licensed Site Professional ("LSP")to manage, supervise or actually perform the necessary response actions at this site. You may obtain a list of the names and addresses of .LSPs from the Board of Registration of hazardous Waste Site Cleanup Professionals by calling(617) 556- 1145 or visiting http://www.state.ma.us/IM. If you have any questions relative to this Notice,please contact Julie J.Hutcheson at the letterhead address or at (508) 946-2852. All future communications regarding this release must reference the following Release Tracking Number:4-18675, truly yours, Richard F.Packard,Chief Emergency Response Release Notification Section P/JJH/re 418675.nor120 ' Attachments: Summary of Liability under M.G.L.c.21E fc: Board of Health Board of Selectmen Fire Department Atlantic Design Engineers P.O.Box 1051 Sandwich,MA 02563 ATTN: Simon B.Thomas,P.E.,LSP ade@atlanticcompanies.com MOO No.----------------- lee----- - BOARD OF HEALTH TOWN OF BARNSTABLE Zpp[icationArlVe[I Con5tructionPermit Application is hereby made for a rmit to Construct (K), Alter ( ), or Wair ( )an . di idual Well at: Location — Address ASSessors�celi r _---_— —O Address w r s -�j 0. ---- -Installer —— Driller Address Type of Building Dwelling-- --- — AA-- - — - — Other - Type of Building lr -------- No. of Persons----------- -- -- �l Type of Well Ili ?VC---_—�a/�� Capacity—l' ---------------------- - Purpose of Well--- Agreement: The undersigned agrees to install the aforedescribed individual well in accordance with the provisions of The Town of Barnstable Board of Health Private Well Protection Regulation — The undersigned further agrees not to place the well in operation unti a ance has been issued by the Board of Health. 6 Signe — —— — — Z7 ate' — Application Approved By —� -— - - date Application Disapproved for the following reasons:---------— -- ——--— - ---— —--- ------- - - ------- ---------------- date Permit No. -- `�--�- - ---- Issued------------------------- — —— date BOARD OF HEALTH TOWN OF BARNSTABLE Certificate Of COMPIiance THIS IS TO CERTIFY, That the Individual Well Constructed ( ), Altered ( ), or Repaired ( ) y--— ——— Installer at- -— ----— -- -- -- - ----------- has been installed in accordance with the provisions of the Town of Barnstable Board of Health Private Well Protection Regulation as described in the application for Well Construction Permit No. ------ ------Dated----- ----- THE ISSUANCE OF THIS CERTIFICATE SHALL NOT BE CONSTRUED AS A GUARANTEE THAT THE WELL SYSTEM WILL FUNCTION SATISFACTORY. DATE- ---- -- --— — -- Inspector-------- - ----------—-- - , 4 ne N. BOARD OF HEALTH - TOWN OF BARNSTABLE zip ruationforVell CongtructionVermit Application is hereby''mad 11 e for a permit to Construct (K), Alter ( ), or Repair ( )an ' di idual Well at: Location— Address Assessors Map and Parce M1- 0w er t �p Address Installer - Driller Address Type of Building Dwelling _----- ---------------------- Other - Type of Building No.;of Persons------------------ ----- k Type of Well 1 T y�--�G��v�il/ Capacity-L" A--------------- Purpose of Well--- 1Ytow`�ov�__ — Sd�jlc„ti Agreement: fThe undersigned agrees Eo"install the aforedescribed individual well in accordance with the provisions of The Town of Barnstable Board of Health Private Well Protection Regulation - The undersigned further agrees not to place the well in operation unti�C- `e o-t- 'ance has been issued by the Board of Health. Signe — - - — Zj -- i Vz__ datlication A roved B -- �PP PP YAA / date Application Disapproved for the following reasons: date Permit No. - - ---- Issued=----------------- --------- date -- BOARD OF HEALTH . TOWN OF BARNSTABLE Certificate Of COMPhance THIS IS TO CERTIFY, That the Individual Well Constructed ( ), Altered ( ), or Repaired ( ) by---- ------- Installer - --- at- --- — --- ——----- -- - - ----- -- -- 1 has been installed in accordance with the provisions of the Town of Barnstable Board of Health Private Well Protection Regulation as described in the application for Well Construction Permit No. ---------------Dated---- ----- THE ISSUANCE OF THIS CERTIFICATE SHALL NOT BE CONSTRUED AS A GUARANTEE THAT THE WELL SYSTEM WILL FUNCTION-SATISFACTORY. DATE--------- -- --— - --- Inspector-- - ----------------- -- -------- t BOARD OF HEALTH TOWN OF BARNSTABLE Yell Con5tructioni3ermit No. ! - �, _ Fee- Permission is hereby granted a to Construct Alter ), or Re it ( ) Individual 11 at ew No. —— - - �� F C �- z/]/V /Y -- ---------- - - a----------------- Street as shown on the applicati•n for a Well C� struction Permit No. Dated- ---- —-- - pBoar�fo -------------------------- rf Health DATE—� __— ell b- Qj ' �1 lN/� ta �„( Ley Vtl1_l^{"fprM. r "qqN, -t Q C WELL - -