PETITIONED PUBLIC HEALTH ASSESSMENT ADDENDUM
SHAFFER EQUIPMENT COMPANY
MINDEN, FAYETTE COUNTY, WEST VIRGINIA
Comparison values for ATSDR public health assessments are contaminant concentrations in specific media that areused to select contaminants for further evaluation. The values provide guidelines used to estimate a dose at whichhealth effects might be observed. Comparison values used in the Environmental Contamination and Other Hazards and the Public Health Implications sections of this public health assessment are listed and described below.
* CREG= Cancer Risk Evaluation Guides
* DWEL = Drinking Water Equivalent Level (µg/L)
* EMEG= Environmental Media Evaluation Guides
* MCL = Maximum Contaminant Level (µg/L)
* MCLG= Maximum Contaminant Level Goal (µg/L)
* MRL = Minimal Risk Level (mg/kg/day)
* PEL = Permissible Exposure Limit (mg/m3)
* RfD = Reference Dose (mg/kg/day)
* ppm = milligrams per liter (mg/L water)
milligrams per kilogram (mg/kg soil)
* ppb = micrograms per liter (µg/L water)
micrograms per kilogram (µg/kg soil)
* kg= kilogram
* mg= milligram
* µg= microgram
* pg= picogram
* L= liter
* m3= meters cubed
Cancer Risk Evaluation Guides (CREGs) are estimated contaminant concentrations that would be expected to causeno more than one excess cancer in a million (10E-6) persons exposed over a lifetime. CREGs are calculated fromEPA's cancer slope factors.
EPA has not established a final cancer slope factor for benzo(a)pyrene. Therefore, the comparison value used forcarcinogenic PAHs is based on an interim cancer slope factor.
The drinking water equivalent level (DWEL) is a lifetime exposure level specific for drinking water (assuming thatall exposure is from that medium) at which adverse, noncarcinogenic health effects would not be expected to occur.
Environmental Media Evaluation Guides (EMEGs) are based on ATSDR minimal risk levels (MRLs) and factor inbody weight and ingestion rates.
Maximum Contaminant Levels (MCLs) represent contaminant concentrations that EPA deems protective of publichealth (considering the availability and economics of water treatment technology) over a lifetime (70 years) at anexposure rate of 2 liters of water per day (for an adult).
Maximum Contaminant Level Goals (MCLGs) are drinking water health goals set at levels at which no known oranticipated adverse effect on the health of persons occurs and which allows an adequate margin of safety. Suchlevels consider the possible impact of synergistic effects, long-term and multi-stage exposures, and the existence ofmore susceptible groups in the population. When there is no safe threshold for a contaminant, the MCLG should beset at zero.
A Minimal Risk Level (MRL) is an estimate of daily human exposure to a chemical (in mg/kg/day) that is likely tobe without an appreciable risk of deleterious effects (noncarcinogenic) over a specified duration of exposure. MRLsare based on human and animal studies and are reported for acute (< 14 days), intermediate (15-364 days), andchronic (> 365 days) exposures. MRLs are published in ATSDR Toxicological Profiles for specific chemicals.
The Occupational Safety and Health Administration's Permissible Exposure Limit (PEL) in air is an 8-hour, time-weighted average developed for the workplace. The level may be exceeded, but the sum of the exposure levelsaveraged over 8 hours must not exceed the limit.
EPA's Reference Dose (RfD) is an estimate of the daily exposure to a contaminant that is unlikely to cause adverse health effects. However, RfDs do not consider carcinogenic effects.
Date: July 4, 1990
From: Medical Officer, HIB, DHS
Subject: Health Study Investigation of Oak Hill, W.V., in regards to petitioned health assessment on Shaffer Equipment Company in Minden, W.V.
To: Donald Y. Joe, P.E., Environmental Engineer, DHAC, EEB
As requested, the Health Investigations Branch as reviewed a report of the cancer mortality statistics in Oak Hill, Fayette County, West Virginia for 1979-1981 prepared by the West Virginia Department of Health issued January 11, 1983. Fourty-four deaths due to malignant neoplasms were reported in the 3-year time period. The total number of cancer deaths was reported in the 3-year time period. The total number of cancer deaths was stratified by sex and by two site-specific cancer groupings (respiratory cancer and all others). Crude and age adjustment methods are not presented in this report.
The expected number of deaths was calculated based upon U.S. mortality rates using an "indirect method" of age standardization for each sex. The Standardized Mortality Rates (SMR) were calculated to compare observed to expected numbers of cancer mortality. These comparisons were made utilizing a p-value. However no confidence intervals were calculated at the 95% level.
According to the authors, the rates of Oak Hill were then compared to U.S. mortality rates as these rates were felt by the authors to be a more reasonable and reliable standard than the West Virginia age-specific mortality rates. It is not clear why West Virginia rates were not used, and why the U.S. mortality rates were considered to be more reasonable.
It is also noteworthy that the original time period of this study consists of three years, whereas the U.S. mortality rates are calculated on an annual basis. It would be important to clarify whether the U.S. mortality rates are for a three year period.
The authors found that there was a greater rate of respiratory cancers in males in the Oak Hill population than in the entire United States. Based on this data, recommendations were made for further investigations.
It should be borne in mind that in a community such as Oak Hill, which is located in the mining region of West Virginia, it would be expected that the male inhabitants would have a probable history of working in the local coal mines. This is considered to be a risk factor for developing respiratory cancers. Other significant contributory factors for respiratory tract cancer mortality would be smoking habits and this should also be addressed. West Virginia ranks among those states with lower per capita income than the entire United States. Socio-economic factors should also be considered as risk factors such as should wood and oil burning stoves as sources for heat be considered as risk factors for respiratory cancers.
The author's report shows an increase in the rate of the respiratory cancers in males in Oak Hill West Virginia. However we are concerned about the conclusions drawn from this study. One concern is the use of a p-value alone to determine statistical significance. It would be more appropriate to calculate 95% confidence intervals, in order to visualize and better understand the significance of these statistics.
Another important concern is comparing statistics from a three-year interval to annual mortality statistics. No data are provided to demonstrate this and it does not appear the author has taken the difference in the two time periods into consideration.
A third concern is the choice of the U.S. standardized mortality rates. While these rates show an increase, due to the probable cofounder such as mining, smoking, and other risk factors West Virginia statistics would have been more appropriate.
Gale Savage, M.D, M.P.H.
REVIEW OF COMMUNITY HEALTH STUDY IN MINDEN, WEST VIRGINIA
The Health Investigation Branch has been asked to review two studies conducted in 1986 and 1989.
While each study taken independently provides useful information within the limitations of the techniques used, the time separating the data collection of the two studies limits the utility for comparing the results. Additional data collection might be helpful if it is performed in accordance with accepted epidemiologic practice.
In the summer of 1986, the Concerned Citizens to Save Fayette County (CCSFC), West Virginia, sponsored "a health registry of random sampling of Minden and Rock Lick residents." CCSFC is a local citizens' voluntary organization, formed in 1985 to monitor the Environmental Protection Agency's (EPA's) activities at the Shaffer Manufacturing site in Minden, West Virginia. This study was conducted by Vanderbilt University's Appalachian Student Health Coalition, and is commonly known as the "Vanderbilt Study." It was a symptom-and-disease prevalence study and consisted of surveying residents of Minden with a health status questionnaire.
Soil sampling for PCBs and water sampling for fecal coliforms were carried out at the time of the survey at each residence. The analysis of the samples was done by laboratories at Virginia Tech. Analytical methods for water and soil samples were well documented. This portion of the study established the presence and degree of PCB contamination in the Minden township.
|Strengths||This study indicated a direction for future investigations of Minden with regard to possible diseases for closer attention.|
Questions concerning smoking habits and occupation were not included in the survey instrument.
Random sampling methods were not used. (Sampling every third house in one neighborhood was not true randomization). There is no indication that the sample was representative of the total Minden population.
No pre-study workshop was conducted for the Minden residents as was done in the later (Page) study.
During the summer of 1989 the CCDSC community group sponsored a "follow up health survey in Page, West Virginia, a community demographically similar to Minden but without a PCB contamination problem."
For this study, a different questionnaire was administered, which requested information regarding smoking habits and occupational history not asked on the Minden study. Soil and water PCB concentration were not measurable.
The data from both studies were then compared and conclusions were drawn based upon this comparison. Four diseases or symptoms (shortness of breath, unexplained weight loss, persistent cough, kidney/bladder infections) were found to be statistically significant.
Questions concerning smoking and occupation were included in the survey instrument of this study.
This study identified diseases of concern to the community.
The same survey instrument was not used as in the original study.
There was a three-year time gap between the two studies.
No environmental sampling was carried out to definitively establish the lack of PCB in the Page environment.
A workshop was conducted for the Page community to explain survey methodology, materials and interviewing practices in order to avoid potential biases. However, this increased the deference in access to information between the two communities.
Socioeconomic status and nutritional status were not addressed in the Page study.
This comparative study examined the populations of two towns within the same geographic region and compared them with respect to symptom-and-disease prevalence. However, a clear relationship could not be established between PCB contamination and the significantly different observed rates of the four symptoms.
In this type of study, it is essential to account for confounding factors such as age, smoking or a history of working in mines, all of which may affect symptom prevalence, independent of PCB. Such variables as age, socioeconomic status and nutritional status should also be considered.
These variables were not addressed in the two surveys. When such variables are not controlled for, one cannot determine what accounted for the findings.
The Health Investigations Branch provides technical assistance or consultation to State health agencies or other groups concerning studies of this nature, and will gladly review subsequent proposals or reports related to this study.
Comments Received During the ATSDR Public Comment Period
January 25 - February 23, 1993
Note: The commenters' comments are taken directly from the letters written to ATSDR. No changes were made tospelling, wording, or sentence structure to avoid misrepresentation of the comment.
Comment 1: In April 1989 the EPA and the state of West Virginia met with Senator John D. Rockefeller IV andthe citizens of Minden. the EPA made a commitment to the Senator and the community to take samples of the barkand core of the trees in a three mile radius and to this present day the EPA has not lived up to this commitment. Thetrees in this area are used for firewood in heating homes. Also Woodchipper Operation operates in this vicinitymaking wood chips that are used by Dupont as a catalyst for making special metal. During cold weather whenfirewood is burned for heating homes the cold weather temperature inversion holds the smoke from this combustionin the communities of Minden and Rock Lick. The PCDDs and PCDFs become a major health problem. Enclosingletters of said commitment of 1989 of the three mile radius study AR300010, AR300016, and AR300025. (supporting documents AR300010, AR300016, and AR300025 are in Appendix 5 of this document)
Response to comment 1: ATSDR has forwarded this comment and the supporting documents to EPA.
Comment 2: Samplings done on March 20-21, 1990; May 22, 1990; and November 27, 1990 confirms theinadequacy of the first cleanup and in no way is this new dumping as stated by the OSC. Sampling done November27, 1990, 12 to 15 inches deep confirms the underground water flow. Said samples were not done on the waterAR100562. (supporting document AR100562 is in Appendix 5 of this document)
Response to comment 2: ATSDR conclusions regarding the site's potential impact on public health involves theevaluation of all available past and present data. ATSDR evaluated the data from the above mentioned samplesand subsequent samples conducted at the site to formulate the conclusions and recommendations made in thispetitioned public health assessment.
Comment 3: The dumping pit east of the Shaffer building said pit as stated by workers 60 ft. x 20 ft. deep wherethousands of gallons of PCBs were dumped poses a greater health threat due to combustion of said slate pile. Thispit is a disaster waiting to happen and one of the reasons that we have a Federal Surface Mine ReclaimationProgram for abandon mining operations. If this slag pile ignites it will be a disaster not only to the people of thecommunity but also the people that have to reclaim it.
Response to comment 3: ATSDR has no data regarding dumping or contamination at the dumping pit/slatepile/slag pile. Specific information and or data are needed to determine whether this dumping pit/slate pile/slag pileposes a health threat. ATSDR has forwarded this comment to EPA for any necessary actions needed to obtain thisdata. Any further information or documentation (location, history, etc.) regarding this dumping pit/slate pile/slagpile should be provided to EPA.
Comment 4: PCB-1260 is the main PCB on this site is a false statement. The highest concentration of PCB on thissite is PCB-1254 (which was directly over the main water line which broke) at a concentration of 260,000 PPM.
Response to comment 4: ATSDR believes that this comment refers to the PCB concentration of 260,000 ppmwhich was discussed in the June 29, 1990, report prepared by the NUS Corporation. That concentrationrepresented soil at the site prior to EPA removal actions in 1987. ATSDR, in this public health assessmentevaluated more recent data which includes the current (January 1991) maximum on-site soil concentration ofaroclor 1260 at a concentration of 1020 mg/kg (or ppm). Furthermore, for health evaluation purposes ATSDRdoes not distinguish between aroclor 1254 and 1260 or any of the other aroclors since the toxic effects of thearoclors are essentially identical at similar concentrations.
Comment 5: Home gardening for supplement food still continues in Minden; therefore continuing to pose as ahealth hazard.
Response to comment 5: Based on ATSDR's site visit, it was noted that there were no farm animals or vegetablegardens observed in the vicinity of the site and that exposure pathway was eliminated in the Pathways Analysissection. The food chain can become contaminated only if it comes in contact with contaminated media (i.e., soil,water, air). Since there is no evidence of gardens in the vicinity of the site where they could come in contact withcontaminated media at levels which can result in bioaccumulation, this pathway was determined to be an eliminatedpathway.
Comment 6: Fecal Coliform Bacteria of the surface water flowing through Minden in Arbuckle Creek as well asPiney Creek in Raleigh County is over 28, 000 count, 70 times above what is allowed which is 400 count. Both ofthese creeks flow into the New River which is used for recreational white water rafting and game fishing.
Arbuckle Creek also contains two different types of leeches not native to this area. This is why OSC refused tocleanup the 190 PPM PCBs in the sediment of Arbuckle Creek. Flooding continues on the average of three times ayear into the community and homes presenting major health hazards.
Response to comment 6: ATSDR has recognized the presence of high fecal coliform counts in Arbuckle Creekand has made recommendations based on that information. The high fecal coliform counts in Piney Creek has notbeen addressed in this public health assessment. ATSDR cannot determine the impact that these streams might haveon the water quality of the New River without actual water quality analyses. But the fecal coliform counts shoulddecrease greatly when those tributaries empty into the New River. However, your comments regarding Piney Creekand the New River, as well as, a copy of this public health assessment with its recommendations regarding ArbuckleCreek will be forwarded to the local authorities.
In regard to the second part of comment 6, ATSDR has addressed the issue of PCBs in sediment in the PathwaysAnalysis and the Public Health Implication sections as a completed exposure pathway. Current data (March 1990)shows sediment in Arbuckle Creek with a maximum PCB (aroclor 1260) concentration of 5.2 mg/kg (or ppm).
Comment 7: Early 1985 the EPA Contract Laboratory on Record Keeping Mr. Gary M. Hacker, EnvironmentalScientist Monitoring Applications Divisions, Versar Inc., Springfield, Virginia interviewed workers (present andpast at the time) and documented all operations of the site.
Response to comment 7: ATSDR notes the comment that workers have been interviewed and that site operationshave been documented. If further information is needed regarding worker interviews or site operations, ATSDRwill contact Versar Inc.
Comment 8: Failure of EPA in its investigation of a junk dealer in Raleigh County who had bought transformersfrom Mr. Shaffer to get the copper his site also being a Superfund Action site by burying his PCB contaminated soilon private property.
Response to comment 8: ATSDR has forwarded this comment to EPA.
Comment 9: ATSDR statement of the "potential" health hazard exists for the subpopulation such as fetuses andbreast-fed infants "if" the mother is exposed to PCBs. There is no doubt that the mothers were exposed to PCBsemphasis 11 PPB in the one child.
Response to comment 9: The accuracy of the test that for the child showing a sera PCB level of 11 ppb isquestioned in paragraph 5 of the Health Outcome Data Evaluation subsection. Therefore, based on the suspect datathere is some question as to whether the child's blood shows PCB contamination, in which case exposure to thechild's mother is also in question. Actions to be taken to verify the level of PCBs in that child by followup testingand further health followup actions to be taken, if elevated PCB levels are verified, are made in recommendationnumber 7. This is also addressed under number 4 in the Public Health Action Plan.
Comment 10: It is a sad day in America when the ATSDR makes its public health assessment totally on the hardwork done by the people of the community of Minden, knowing that all the community's efforts in working withother groups establishing their health and contamination problems. The ATSDR and the EPA know this very wellbecaused this was not sanctioned nor financed by any agency of the federal government, knowing that it has novalidity because it was neither sanctioned nor financed by any agency of the government. Each year the Secretaryof Health and the Secretary o Internal Revenue must report to the House of Representatives and the U.S. Senate onHealthcare cost containment, as long as the government continues in this frame of mind we will never address thehealth problems of Minden as well as the rest of the communities of America. As it has been stated by everySurgeon General and other agencies of the government in the past and present smoking and/or chewing tobacco, theuse of alcohol, promiscuous life style, and aides draws a clear picture of said government agencies view of"BLAME THE VICTIM FOR HIS HEALTH" while they coverup their own inadequacies while covering corporateAmerica's backside in their detriment to their workers and communities. As long as we continue with this attitudethere will be no controlling the healthcare cost nor providing healthcare for our people.
Response to comment 10: ATSDR has used all data available in an effort to evaluate the Shaffer EquipmentCompany site for any evidence of actual or theoretical threat to public health using current science. ATSDR is anindependent agency funded under CERCLA (Superfund Act) and owes no allegiance to any governmental, private,commercial, or industrial concerns. ATSDR remains committed and true to its mission to prevent or mitigateadverse human health effects and diminished quality of life resulting from exposure to hazardous substances in theenvironment.
Comment 11: In reviewing the above referenced report, I found one recommendation on page 28, item 2 of the Recommendations and HARP Statement to be misleading.
The recommendation reads as follows:
"Even if turtles are not contaminated with PCBs, no aquatic life from Arbuckle Creek downstream of theOak Hill Wastewater Treatment Plant should be eaten unless thoroughly cooked, because of the fecalcoliform bacteria contamination of Arbuckle Creek. Arbuckle Creek downstream of the treatment plantshould be posted. Recreational uses of Arbuckle Creek should be restricted and surface water fromArbuckle Creek should be sterilized before being used. Such actions are recommended until fecal coliform bacteria levels are below regulatory standards."
If I had no knowledge of the workings of the Minden Wastewater Treatment Plant, I would gather from readingRecommendation No. 2 that the fecal coliform content found below the treatment plant was being placed intoArbuckle Creek as a result of improper treatment of the plant. Was sampling not done above the plant site: Ifsampling was performed on Arbuckle Creek at any point above the plant, I would imagine high levels of fecalcoliform bacteria would be found.
This is primarily due to areas outside the corporate limits, such as the five-street area encircled in yellow on theenclosed map (see Appendix 5), not being sewered. This area drains into a tributary (see green highlight) ofArbuckle Creek (see pink highlight), which flows through the City of Oak Hill and down into Minden, past ournewly constructed wastewater treatment plant. Comments such as that made in Recommendation No. 2 would leadone to believe that the Minden plant was discharging effluent into Arbuckle Creek that did not meet therequirements of our National Pollutent Discharge Elimination System (NPDES) permit, when, in fact, our effluentquality is well within the regulatory standards as set forth in our permit.
Response to comment 11: ATSDR acknowledges that the source of fecal coliform in Arbuckle Creek has not beenidentified. Based upon comment 11, ATSDR will restate recommendation number 2 of this public healthassessment so that the upstream wastewater treatment plant is not implicated as the source.
United States Senate
Washington, DC 20510-4802
July 17, 1990
I have received a letter from Larry Rose of the Concerned Citizens to Save Fayette County. In this letter Mr. Rose raises a number of concerns regarding the three mile radius study that EPA committed to do in response to my request in in April 1989.
There seem to be a variety of activates occurring at the Schaffer site. To ensure that all parties have a thorough understanding of the activities undertaken by EPA at Minden, it would be helpful to have a listing of completed tasks and those that remain.
I am forwarding a copy of Mr. Rose's letter to you. My staff has informed me that you are aware of the contents of the letter and have begun responding to the concerns that have been raised.
Ted, the satisfactory resolution of the situation at Minden is a top priority. If you need additional information or assistance, please do not hesitate to contact me or Kiena Smith of my staff.
John D. Rockefeller IV
Mr. Edwin Erickson
Environmental Protection Agency
Philadelphia, Pennsylvania 19107
United States Senate
Washington, DC 20510-4802
July 5, 1990
As you know my staff, members of your pre-remedial response team, and the Citizens to Save Fayette County met and toured the Shaffer facility and the surrounding community of Minden, West Virginia. The purpose of the meeting and the subsequent tour was to permit the citizens to show EPA the areas that they wanted to have included in the sampling process.
I am very pleased that EPA involved the community in this effort. However, I would like to be sure that the three mile sampling that was promised in April 1989 will be performed. I am concerned about reports from my staff that lead me to believe that future sampling efforts may hinge on the results of the confimatory samples taken in May.
These samples taken in March and then confirmed in May were only on the Shaffer site, not from a three mile radius. I will not be satisfied that the commitment made to me and the residents of Minden in April of 1989 has been upheld if further sampling is not performed.
The matter of the contamination inside the building continues to be a problem. Will EPA be able to collect samples from inside the building?
Ted, this situation has to be resolved an I implore you to make every effort to do so. If my office can be of assistance, please do not hesitate to call me or Kiena Smith of my staff.
John D. Rockefeller IV
Mr. Edwin Erickson
Environmental Protection Agency
Philadelphia, Pennsylvania 19107
United States Environmental Protection Agency
841 Chestnut Building
Philadelphia, Pennsylvania 19107
Honorable John D. Rockefeller, IV
United States Senate
Washington, DC 20510
Dear Senator Rockefeller:
Thank you for calling me yesterday to convey the anxiety felt by residents of Minden concerning the Environmental Protection Agency's commitment to proceed with the Superfund cleanup of the Shaffer Equipment site.
As we discussed, the Enivronmental Protection Agency discovered several PCB-contaminated locations at the Shaffer site, and we have scheduled the removal of these contaminated soils for late October or early November of this year. I have concurred in the documentation to support the funding for this cleanup, and have every reason to believe that it will be approved at EPA Headquarters in the very near future.
I learned yesterday that a media report speculated about the potential impact of a substantial sequestration of federal funds on the Minden project. While no one knows for sure how a sequestration will affect specific Superfund activities, EPA intends to more forward with the cleanup as soon as we can. Should a sequestration require a delay in the cleanup, I will immediately inform you about it:
I hope that our telephone conversation and this letter are helpful to you. You communication with the citizens of Minden has been appreciated.
Edwin B. Erickson
Environmental Technology Inc.
To: Bob Caron, EPA-OSC
Thur: Craig Hill
From: Clay Mullican
Subject: PCB Soil Sampling to determine the depth of contamination
Date: November 30, 1990
On Tuesday, November 27, 1990 three hours were spent purchasing, gathering, and loading supplies needed to perform PCB soil sampling at the Shaffer site. Wednesday at 0545 hours Clay Mullican and Lee Baumgardner of ETI departed Richmond in route to the Shaffer site in Minden, West Virginia. At 12 noon, ETI personnel arrived on site. The area to be sampled was measured and found to be approximately 32' x 40'. The faded grid markings from a previous sampling effort were re-painted and the sampling equipment and supplies were set up. At 1235 hours TAT member Mona Khail arrived on site.
All sampling equipment was decontaminated prior to and between each sample being taken. Decontamination consisted of a five step process. Those steps were: 1) soapy wash; 2) distilled water rinse; 3) hexane wash; 4) distilled water rinse; 5) distilled water rinse.
Sixteen Soil samples were taken. Figure A shows the grids, there corresponding numbers, and sample locations indicated by letter. All grids are approximately 5' x 8' except grid number nine which is 4' x 10'. Table 1 shows the sample number, the time at which the sample was taken, grid location and depth sample was taken. Samples S05 and S08 will be split at the laboratory and spike duplicates run. Sample S12 is a field duplicate. S14 is a background sample taken on the surface 20 yards from the dirt pile on the side opposite of the contaminated areas.
While attempting to dig the clay layer, water collected in the holes of sample points A, C, F, and G. The water level was found at a depth of 12-15 inches at each of the sample locations. At sampling locations where water was found soil samples were taken just above the water level.
No water samples were taken. ETI completed soil sampling at 1700 hours and completed the decontamination of all equipment at 1730 hours. AT 1730 hours ETI and TAT personnel departed the site.
Samples were sent via overnight mail to MDS laboratories in Reading, Pennsylvania on Thursday, November 29, 1990. A seven working-day turn around time was requested.
|S01||1348||A2 - Sec 10 - 6 inches (a)|
|S02||1352||A2 - Sec 10 - 1 foot (a)|
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|S05 (spike duplicate)||1415||A2 - Sec 9 - 6 inches (c)|
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|S08 (spike duplicate)||1503||A2 - Sec 7 - 1 foot 5 inches (e)|
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|S12 (filed duplicate)||1547||A2 - Sec 13 - 6 inches (g)|
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|S14 (background)||1620||AB - Sec 01- surface (h)|
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