Home > Uncategorized > Christie DEP Relaxes Toxic Vapor Intrusion Standards

Christie DEP Relaxes Toxic Vapor Intrusion Standards

Industry Consultants Rewrite Toxic Cleanup Standards

Stunning Hypocrisy In Light of Drinking Water Standards Debate 

[VERY Important updates below - please read results of DEP meeting.]

In another illustration of the “regulatory relief” policy mandated by Gov. Christie’s Executive Order #2, after months of meetings with an industry work group, DEP quietly relaxed standards for “vapor intrusion” (VI)  - just exactly as we repeatedly predicted, see this and this and this.

The VI standards rollback was announced in a January  17, 2013 DEP email to private Licensed Site Professionals and will be presented at 1 pm today at the DEP building.

The DEP’s new Vapor Intrusion Guidance (VI) document relaxes standards for several toxic chemicals found in groundwater, soil, and indoor air of buildings. Strict VI standards were set by DEP in 2007 (see the 2007 stricter standards).

[Update: DEP weakened (increased) VI standards for 103 screening values, some by thousands of times, but strengthened just 13 standards – that means 89% of changes made were to weaken protections. see below.]

As the Bergen Record reported back on May 31, 2011, the weaker standards to be announced today were developed by an industry work group (see Polluters rewriting rules for site cleanup:

Key committees writing rules for New Jersey’s new program to clean up contaminated sites are made up entirely of the polluting companies and their contractors. 

The 16 committees, which have been putting together rule and guidance documents,include no one from environmental or resident advocacy groups, no health specialists, and no outside experts who aren’t affiliated with the cleanup industry. [....]

O’Brien & Gere also has a representative on a committee. The contractor was hired by DuPont to install vapor mitigation systems in homes in Pompton Lakes affected by a plume of contamination that spread from an old factory site. Environmental advocate Bill Wolfe, a former DEP official now with Public Employees for Environmental Responsibility, is concerned that contractors and polluters are writing the guidelines.

“It’s like a blank check to technical consultants to write their own requirements,” he wrote on his blog.

The weaker VI standards come at a time when, after 3 years, the Christie DEP has not strengthened any environmental standard and is supporting a chemical industry Legislative initiative to put industry representatives on the Drinking Water Quality Institute to write drinking water standards and undermine the science of risk assessment.

Ironically, the chemical industry DWQI kill bill is justified by false claims that the DWQI is not transparent and does not allow industry input.

But in stunning contrast with the DWQI, the VI standards development truly was non-transparent, completely dominated by industry, and are based on, at best, opaque science – yet all these real and serious flaws are ignored while sham industry claims are backed by DEP. Truly stunning.

Further politicizing DEP science and standards issues, DEP Commissioner Martin - who has no training in science - even went so far as to falsely claim that the nationally recognized DWQI science was “shoddy”. Here are direct quotes from Martin testimony to the Legislature, per Bergen Record):

Under questioning from state Senate Majority Leader Barbara Buono during budget hearings on Tuesday, Martin said he originally intended to sign the proposed rule until he realized “our science was shoddy and I refuse to sign anything that doesn’t have adequate science to back it up.”

He said of the DEP researchers: “The data they provided was poor, not organized, anecdotal at best.” Martin also said nobody was able to document the public health risk of the chemical to his satisfaction.

Yet the the DWQI meets openly, allows all parties to provide input, conducts nationally recognized risk assessment, and provides a robust scientific justification of their recommendations for drinking water standards.

See for yourself – here is an example of that work –  note how the DWQI Report clearly states which specific chemical standards they recommend, explains the the scientific basis for those recommendations, and identifies whether recommendations would increase or decrease any existing standard so the public can see exactly what is going on and why.

Now compare that DWQI work to the DEP justification for relaxing  the 2007 Vapor Intrusion standards.

1. Note how it is impossible to determine the scientific justification of the VI changes, which are not transparent because they are hidden in various models – and seemingly cherry picked apples and oranges from various EPA regions.

2. Note especially how DEP fails to specify which chemical standards are increased (weakened) and which are lowered (strengthened). This makes it very difficult for the public to be made aware of the implications of the changes.

3. Note that, contrary to the DWQI independent science, that the DEP VI standards are developed by an industry dominated work group that was established by invitation onlythe participants were hand picked by DEP managers, and some have alleged that “pay to play” was involved.

The linkage between political “pay-to-play” donations and access to DEP prompted a scathing Star Ledger editorial about how one engineering firm dominated the process:

Langan Engineering & Environmental gave $25,000. It received $2 million from state agencies last year, and a senior associate of the firm sits on the state’s Site Remediation Professional Licensing Board, which oversees cleanups of contaminated sites.

None of this is criminal. To qualify as a bribe, evidence would have to show that these payments were explicitly linked to winning government favors. No one has alleged that here.

But Christie himself, when he was a federal prosecutor, favored the ban on big donations from firms doing business with the government.

He understood that it’s a sleazy practice that puts both parties within winking distance of a bribe, and that it engenders widespread mistrust.

( Langan Engineering had 9 staff involved in writing the DEP cleanup requirements, by far more than any other consulting firm, providing not only access but obvious insider knowledge, a distinct competitive advantage in the consultant marketplace – for details, see this).

4. Note that, contrary to the DWQI scientific process, that  there was no transparency or opportunity for the public to comment in the development or adoption of the changes made by DEP to the standards in the 2007 Vapor Intrusion Guidance.

5. Note that, contrary to the DWQI, the DEP VI standards are adopted informally as Guidance and not subject to formal public notice, public comment and public hearing rule making procedures.

6. Worse, a 2009 law that privatized the NJ state toxic site cleanup program allows private consultants to deviate from DEP cleanup standards as long as they write their own permission slip.

Section 14 of the Site Remediation Reform Act explicitly allows consultants to ignore DEP guidance based on their own judgement:

When there is no specific requirement provided by the technical standards for site remediation adopted by the department, and guidelines issued by the department are not appropriate or necessary, in the professional judgment of the licensed site remediation professional, to meet the remediation requirements listed in paragraph (1) of this subsection, the licensed site remediation professional may use the following additional guidelines to make decisions regarding a remediation, and shall set forth justification for such use, in the relevant submittal.

So, we have the worst of all possible worlds here – let’s recap what’s going on:

  • driven by Gov. Christie’s policy and Order to provide “regulatory relief”, a hand picked group of private industry representatives, with access to DEP provided by “pay to play” politics, develops their own cleanup standards – all with no public or independent science involvement;
  • private industry then applies and implements the standards they developed; and
  • if they don’t like the standards, private industry can ignore them and write their own standards.

Only in NJ – all the ugly details, with links to all the documents, from our friends at PEER

[Update: 4 pm – I attended the 1 pm DEP/LSRP presentation, just got home, and can report the following:

DEP obviously responded to specific criticisms we made above. DEP is getting good at rapid response!

1. At the meeting, DEP distributed a new table that compared the new 2013 values with the 2007 values for groundwater, soil and indoor air. Based on a rapid review of that comparison I made during the meeting,  it looks like DEP weakened (increased) 103 VI standards and strengthened just 13.  

These changes were consistently downplayed in the power point handout and misleading presented by DEP during the briefing by specifically identifying the few standards that were lowered, but not providing the same level of explanation for the 103 (89%) that were increased.

This comparison table was not provided in the original email or posted on DEP’s website, so it seems very likely that it was done in response to the above criticism, where I compared the VI changes to the DWQI recommendations.

2. Again responding to our criticism, DEP’s explained that the toxicological basis for the changes came from national data and EPA IRIS values, which were input into DEP models, equations, and calculations (we had suggested cherry picked EPA  regional values and some non-transparent or unsourced assumptions/values.

But NJ has the analytical chemistry and toxicological staff expertise to generate independent and more stringent State standards and methods and historically has done that –  so reliance on national methodology and criteria illustrates the pernicious rollback effects of the “federal standards” consistency policy in Governor Christie’s Executive Order #2: Existing more stringent state standards get rolled back!

3. The DEP changes (i.e. weakenings) will result in hundreds or perhaps even thousands of current groundwater contamination, immediate environmental concern, and/or vapor intrusion cases dropping out of the regulatory system and closed out resulting in no further action on vapor problems (DEP calls this a “reclassification” of a case).

Yet very few existing cases will be reopened, because DEP mis-applied the Brownfield law. That law limits DEP ability to re-open a case to only when standards decrease (i.e. get more stringent) by an “order of magnitude” (10 times). But the Brownfields Act was not intended to and did NOT APPLY TO VAPOR RISKS – DEP is mis-applying law here to limit the impact on old cases that DEP said were clean but that never addressed vapor risks.

Worse, the reclassification (dropping) of cases will be done via an email conversation between the LSRP and the DEP staffer – there is no public notification or involvement whatsoever in this process.

This means that a toxic site near your home that may be creating a vapor problem in your home will not be addressed, will not be cleaned up, and you will know nothing about it.

4. There is no longer any effective distinction between the private sector and DEP – the DEP, LSRP Association, LSRP members, and the LSRP Board have overlapping functions and essentially share functions – one big happy family.

5. There is a bizarre perspective shared by those inside this privatized and DEP captured LSRP culture bubble.

  • One LSRP complained that his “clients will squawk” about having to do vapor intrusion investigations and will oppose the increased cost, making the LSRP have to “justify” the DEP standards.
  • I asked one LSRP sitting in front of me why the LSRP’s all opposed DEP requirements to do various vapor investigations and additional cleanup, because they have a legal duty to protect public health and obviously would make lots more money doing more work, and therefore should SUPPORT additional DEP requirements. He looked at me like I had just landed from outer space, laughed and said because the “responsible parties” – clients – will oppose having to pay for it! So, just as I expected, the LSRP’s are loyal primarily to the bottom line of their RP clients, not to their duty to protect the public, the environment, and public health.
  • Seemingly from the Twilight zone, one LSRP seemed to feel that too many vapor cases have installed vapor mitigation systems that were not needed! AS if there is TOO MUCH VAPOR REMEDIATION GOING ON! He complained that because many standards were being increased, some of his cases would no longer have a vapor problem and drop out of the system. He quipped: Would DEP pay for the systems allegedly needlessly installed in those homes?
  • A DEP staffer revealed his bias and ignorance and insensitivity to public health. Explaining why DEP does not require vapor investigations for buildings on or near landfills(how crazy is that!), he said that DEP felt “it is not fair to require vapor investigations for somone else’s problem”. This shows how DEP looks out for the polluter – Totally ignored were the impacts on the people exposed to those vapors, regardless of who caused the problem. This perspective of the nature of the problem and ignoring public health in favor of the polluters’ interests came up numerous times in numerous technical issues. This same DEP staff presenter also seriously misrepresented the health risks of benzene and why benzene was selected as the most toxic indicator of groundwater pollution from gasoline stations.His boss had to step in any correct him. This staffer just so happens to be the guy who overaw the Dupont Pompton Lakes scandal. Coincidence?

6. I was allowed to ask a question and made two points:

  • Citing comments made by DEP staffers in the room, I objected to DEP decisions to rely on less sensitive analytical methods for mercury and naphthalene, in favor of method reliability over sensitivity. I used these two examples as an illustration of why the DEP should have proposed the Guidance for expert and public review before unilaterally just imposing it.
  • I clarified that the 2013/2007 comparison table was not provided before the meeting or posted on the website and objected that the public had no role in participating in the development or review of these new standards. In response, Barry Frasco of DEP said that DEP would propose the standards as remedial standards regulations in 18 months to 2 years.
7. DEP confirmed that the new/weaker standards were developed by a 7 member Committee (3 LSRP’s and 4 DEP managers), with no representatives of  public interest, public health, or independent scientific expertise.

Vapor Intrusion Standards Relaxed in New Jersey

No Public Review of New Guidance to Industry Consultants on Toxic Cleanups    

Trenton — Without public notice, the Christie administration has rolled back public health protections against seepage of deadly gases into homes, schools and businesses, according to Public Employees for Environmental Responsibility (PEER).  Effective immediately, new state “Guidance” relaxes cleanup levels for several hazardous chemicals.

In a January 17 email to private consultants, called “Licensed Site Remediation Professionals” (LSRPs), the New Jersey Department of Environmental Protection (DEP) unveiled new guidelines governing how much of an array of toxic chemicals may remain in indoor air, soil and groundwater following cleanup of a residential or commercial site.  As the changes did not go through any rule-making process, the public had no opportunity to review them prior to their going into effect.

DEP provided no independently derived scientific basis for the changes.  The agency claims that the revisions are based on various federal guidance values, which were then recalculated to reflect New Jersey’s statutory 1 in a million cancer risk standard.  Nonetheless, the changes would dramatically weaken previous allowable levels for a number of known toxic chemicals, including –

  • The indoor residential limits for tetrachloroethene (PCE) were tripled from 3 µg/m3 (micrograms per cubic meter) to 9 µg/m3.  At the same time, the groundwater screening level for PCE jumped from 1 part per billion to 31 parts per billion; and
  • The allowable soil levels for MTBE (commonly due to leaking gas station tanks) was more than tripled from 2 ug/m3 to 9 ug/m3.

DEP relied on an industry “Stakeholder” group to develop the Guidance for the state cleanup program, which is under the control of the LSRPs, who work for the private parties responsible for the pollution and liable for the cleanup costs.   Instead of formally revising statewide groundwater standards through rule-making to reflect actual vapor risks, DEP chose to rely on a Guidance document that is not strictly enforceable.

“This is an objectionable stealth rule-making where public health protection got dealt away in the backroom,” stated New Jersey PEER Director Bill Wolfe, a former long-time DEP analyst, noting that the Christie administration has yet to back a single strengthening of environmental regulations.  “The maximum limits for toxic chemicals we are inhaling or ingesting in schools, homes, hospitals or any structure within the plume of past industrial pollution should be the product of a transparent process where science independent of the affected industry is brought to bear.”

Vapor intrusion is a major public health problem in New Jersey, the nation’s most densely populated state, where more than 6,500 sites have groundwater contamination which in hundreds of cases is seeping into nearby homes and buildings.  Some communities, such as Pompton Lakes, have been plagued by dangerous vapor intrusion problems for decades.

“The state’s privatized system of toxic cleanup creates dangerous incentives to cut corners and allow hidden hazards to fester,” Wolfe added. “Residents would be well advised not to breathe too deeply around reclaimed industrial sites in New Jersey.” 

###

See the new Vapor Intrusion Guidance

Look at the DEP email to industry

Trace the privatization of vapor intrusion regulation under Gov. Christie

Examine corporate control of the state’s environmental science 

New Jersey PEER is a state chapter of a national alliance of state and federal agency resource professionals working to ensure environmental ethics and government accountability

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  1. jean public
    January 31st, 2013 at 16:07 | #1

    christie administration is doing this in many many areas and in his re election campaign this should be an issue. the public is locked out. in nj div fish wildilfe killing, the public is similarly locked out. dep has pals who are called “stakeholders”. if you dont agree with policies, you are locked out. same thing.

  2. jean public
    January 31st, 2013 at 16:07 | #2

    christie administration is doing this in many many areas and in his re election campaign this should be an issue. the public is locked out. in nj div fish wildilfe killing, the public is similarly locked out. dep has pals who are called “stakeholders”. if you dont agree with policies, you are locked out. same thing.

  3. January 31st, 2013 at 21:27 | #3

    Enhance the protection of NJ Residents Not Reduce their protection against poisonous gases! Progression not Regression – why are we going backwards? People first than worry about making nicey-nice with corporate polluters! No public review?? WHY??? I say all making this decisions can move right into the toxic plume in Pompton Lakes! How about it?

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  231. April 30th, 2015 at 14:12 | #231
  232. April 30th, 2015 at 14:16 | #232
  233. April 30th, 2015 at 14:43 | #233
  234. April 30th, 2015 at 14:48 | #234
  235. April 30th, 2015 at 14:55 | #235
  236. April 30th, 2015 at 15:26 | #236
  237. April 30th, 2015 at 15:27 | #237
  238. April 30th, 2015 at 15:32 | #238
  239. April 30th, 2015 at 15:33 | #239
  240. April 30th, 2015 at 15:43 | #240
  241. April 30th, 2015 at 15:56 | #241
  242. April 30th, 2015 at 15:56 | #242
  243. April 30th, 2015 at 15:56 | #243
  244. April 30th, 2015 at 15:58 | #244
  245. April 30th, 2015 at 16:45 | #245
  246. April 30th, 2015 at 17:00 | #246
  247. April 30th, 2015 at 17:00 | #247
  248. April 30th, 2015 at 17:01 | #248
  249. April 30th, 2015 at 17:09 | #249
  250. April 30th, 2015 at 17:11 | #250
  251. April 30th, 2015 at 17:37 | #251
  252. April 30th, 2015 at 17:40 | #252
  253. April 30th, 2015 at 17:52 | #253
  254. April 30th, 2015 at 18:13 | #254
  255. April 30th, 2015 at 18:23 | #255
  256. April 30th, 2015 at 18:24 | #256
  257. April 30th, 2015 at 18:26 | #257
  258. April 30th, 2015 at 19:01 | #258
  259. April 30th, 2015 at 19:01 | #259
  260. April 30th, 2015 at 19:04 | #260
  261. April 30th, 2015 at 19:11 | #261
  262. April 30th, 2015 at 19:41 | #262
  263. April 30th, 2015 at 19:41 | #263
  264. April 30th, 2015 at 19:41 | #264
  265. April 30th, 2015 at 19:58 | #265
  266. April 30th, 2015 at 20:02 | #266
  267. April 30th, 2015 at 20:26 | #267
  268. April 30th, 2015 at 20:30 | #268
  269. April 30th, 2015 at 21:04 | #269
  270. April 30th, 2015 at 21:08 | #270
  271. April 30th, 2015 at 21:24 | #271
  272. April 30th, 2015 at 22:03 | #272
  273. April 30th, 2015 at 22:04 | #273
  274. April 30th, 2015 at 22:05 | #274
  275. April 30th, 2015 at 22:05 | #275
  276. April 30th, 2015 at 22:06 | #276
  277. April 30th, 2015 at 22:09 | #277
  278. April 30th, 2015 at 23:11 | #278
  279. April 30th, 2015 at 23:12 | #279
  280. April 30th, 2015 at 23:12 | #280
  281. May 1st, 2015 at 02:41 | #281
  282. May 1st, 2015 at 02:41 | #282
  283. May 1st, 2015 at 02:41 | #283
  284. May 1st, 2015 at 05:31 | #284
  285. May 1st, 2015 at 05:32 | #285
  286. May 1st, 2015 at 05:32 | #286
  287. May 1st, 2015 at 06:28 | #287
  288. May 1st, 2015 at 06:28 | #288
  289. May 1st, 2015 at 06:28 | #289
  290. May 1st, 2015 at 11:51 | #290
  291. May 1st, 2015 at 11:51 | #291
  292. May 1st, 2015 at 11:54 | #292
  293. May 1st, 2015 at 11:54 | #293
  294. May 1st, 2015 at 11:57 | #294
  295. May 1st, 2015 at 11:57 | #295
  296. May 1st, 2015 at 11:58 | #296
  297. May 1st, 2015 at 12:15 | #297
  298. May 1st, 2015 at 12:15 | #298
  299. May 1st, 2015 at 14:45 | #299
  300. May 1st, 2015 at 14:46 | #300
  301. May 1st, 2015 at 14:46 | #301
  302. May 1st, 2015 at 16:10 | #302
  303. May 1st, 2015 at 16:10 | #303
  304. May 1st, 2015 at 16:10 | #304
  305. May 1st, 2015 at 22:47 | #305
  306. May 1st, 2015 at 22:47 | #306
  307. May 1st, 2015 at 22:47 | #307
  308. May 1st, 2015 at 23:10 | #308
  309. May 1st, 2015 at 23:10 | #309
  310. May 1st, 2015 at 23:16 | #310
  311. May 1st, 2015 at 23:16 | #311
  312. May 1st, 2015 at 23:19 | #312
  313. May 1st, 2015 at 23:19 | #313
  314. May 2nd, 2015 at 00:20 | #314
  315. May 2nd, 2015 at 00:20 | #315
  316. May 2nd, 2015 at 00:21 | #316
  317. May 2nd, 2015 at 00:53 | #317
  318. May 2nd, 2015 at 00:54 | #318
  319. May 2nd, 2015 at 00:54 | #319
  320. May 2nd, 2015 at 07:10 | #320
  321. May 2nd, 2015 at 07:10 | #321
  322. May 2nd, 2015 at 07:10 | #322
  323. May 2nd, 2015 at 07:39 | #323
  324. May 2nd, 2015 at 09:24 | #324
  325. May 2nd, 2015 at 09:24 | #325
  326. May 2nd, 2015 at 09:29 | #326
  327. May 2nd, 2015 at 09:29 | #327
  328. May 2nd, 2015 at 09:32 | #328
  329. May 2nd, 2015 at 09:32 | #329
  330. May 2nd, 2015 at 09:34 | #330
  331. May 2nd, 2015 at 09:35 | #331
  332. May 2nd, 2015 at 10:06 | #332
  333. May 2nd, 2015 at 10:06 | #333
  334. May 2nd, 2015 at 10:14 | #334
  335. May 2nd, 2015 at 10:15 | #335
  336. May 2nd, 2015 at 11:17 | #336
  337. May 2nd, 2015 at 11:17 | #337
  338. May 2nd, 2015 at 11:17 | #338
  339. May 2nd, 2015 at 15:42 | #339
  340. May 2nd, 2015 at 15:42 | #340
  341. May 2nd, 2015 at 15:42 | #341
  342. May 2nd, 2015 at 19:21 | #342
  343. May 2nd, 2015 at 19:21 | #343
  344. May 2nd, 2015 at 19:24 | #344
  345. May 2nd, 2015 at 19:24 | #345
  346. May 2nd, 2015 at 19:30 | #346
  347. May 2nd, 2015 at 19:31 | #347
  348. May 2nd, 2015 at 19:41 | #348
  349. May 2nd, 2015 at 19:41 | #349
  350. May 2nd, 2015 at 19:43 | #350
  351. May 2nd, 2015 at 19:43 | #351
  352. May 2nd, 2015 at 20:15 | #352
  353. May 2nd, 2015 at 20:15 | #353
  354. May 2nd, 2015 at 22:11 | #354
  355. May 2nd, 2015 at 22:11 | #355
  356. May 2nd, 2015 at 23:32 | #356
  357. May 2nd, 2015 at 23:33 | #357
  358. May 2nd, 2015 at 23:33 | #358
  359. May 3rd, 2015 at 05:20 | #359
  360. May 3rd, 2015 at 05:20 | #360
  361. May 3rd, 2015 at 05:24 | #361
  362. May 3rd, 2015 at 05:24 | #362
  363. May 3rd, 2015 at 05:39 | #363
  364. May 3rd, 2015 at 05:40 | #364
  365. May 3rd, 2015 at 05:56 | #365
  366. May 3rd, 2015 at 05:56 | #366
  367. May 3rd, 2015 at 05:58 | #367
  368. May 3rd, 2015 at 05:58 | #368
  369. May 3rd, 2015 at 06:35 | #369
  370. May 3rd, 2015 at 06:35 | #370
  371. May 3rd, 2015 at 08:58 | #371
  372. May 3rd, 2015 at 08:58 | #372
  373. May 3rd, 2015 at 09:02 | #373
  374. May 3rd, 2015 at 09:02 | #374
  375. May 3rd, 2015 at 10:51 | #375
  376. May 3rd, 2015 at 10:51 | #376
  377. May 3rd, 2015 at 14:13 | #377
  378. May 3rd, 2015 at 14:13 | #378
  379. May 3rd, 2015 at 15:13 | #379
  380. May 3rd, 2015 at 15:13 | #380
  381. May 3rd, 2015 at 15:26 | #381
  382. May 3rd, 2015 at 15:26 | #382
  383. May 3rd, 2015 at 15:42 | #383
  384. May 3rd, 2015 at 16:09 | #384
  385. May 3rd, 2015 at 16:10 | #385
  386. May 3rd, 2015 at 16:15 | #386
  387. May 3rd, 2015 at 16:15 | #387
  388. May 3rd, 2015 at 17:03 | #388
  389. May 3rd, 2015 at 17:03 | #389
  390. May 3rd, 2015 at 17:36 | #390
  391. May 3rd, 2015 at 19:57 | #391
  392. May 3rd, 2015 at 19:57 | #392
  393. May 3rd, 2015 at 22:08 | #393
  394. May 3rd, 2015 at 22:08 | #394
  395. May 3rd, 2015 at 22:09 | #395
  396. May 4th, 2015 at 00:44 | #396
  397. May 4th, 2015 at 01:27 | #397
  398. May 4th, 2015 at 01:59 | #398
  399. May 4th, 2015 at 01:59 | #399
  400. May 4th, 2015 at 02:32 | #400
  401. May 4th, 2015 at 02:36 | #401
  402. May 4th, 2015 at 02:37 | #402
  403. May 4th, 2015 at 03:28 | #403
  404. May 4th, 2015 at 03:28 | #404
  405. May 4th, 2015 at 06:52 | #405
  406. May 4th, 2015 at 06:52 | #406
  407. May 4th, 2015 at 09:01 | #407
  408. May 4th, 2015 at 09:01 | #408
  409. May 4th, 2015 at 11:45 | #409
  410. May 4th, 2015 at 11:45 | #410
  411. May 4th, 2015 at 12:23 | #411
  412. May 4th, 2015 at 12:24 | #412
  413. May 4th, 2015 at 13:00 | #413
  414. May 4th, 2015 at 13:03 | #414
  415. May 4th, 2015 at 13:03 | #415
  416. May 4th, 2015 at 14:08 | #416
  417. May 4th, 2015 at 17:49 | #417
  418. May 4th, 2015 at 20:10 | #418
  419. May 4th, 2015 at 20:11 | #419
  420. May 4th, 2015 at 20:42 | #420
  421. May 4th, 2015 at 20:46 | #421
  422. May 4th, 2015 at 20:47 | #422
  423. May 4th, 2015 at 21:51 | #423
  424. May 4th, 2015 at 21:52 | #424
  425. May 4th, 2015 at 22:11 | #425
  426. May 4th, 2015 at 22:11 | #426
  427. May 4th, 2015 at 22:24 | #427
  428. May 4th, 2015 at 22:24 | #428
  429. May 4th, 2015 at 23:03 | #429
  430. May 4th, 2015 at 23:04 | #430
  431. May 4th, 2015 at 23:09 | #431
  432. May 5th, 2015 at 00:32 | #432
  433. May 5th, 2015 at 00:32 | #433
  434. May 5th, 2015 at 04:34 | #434
  435. May 5th, 2015 at 04:34 | #435
  436. May 5th, 2015 at 16:52 | #436
  437. May 7th, 2015 at 18:53 | #437
  438. May 8th, 2015 at 01:54 | #438
  439. May 8th, 2015 at 01:54 | #439
  440. May 8th, 2015 at 01:54 | #440
  441. May 8th, 2015 at 01:55 | #441
  442. May 8th, 2015 at 01:55 | #442
  443. May 8th, 2015 at 01:55 | #443
  444. May 8th, 2015 at 01:56 | #444
  445. May 8th, 2015 at 01:56 | #445
  446. May 8th, 2015 at 01:56 | #446
  447. May 8th, 2015 at 01:56 | #447
  448. May 8th, 2015 at 01:57 | #448
  449. May 8th, 2015 at 01:57 | #449
  450. May 8th, 2015 at 01:57 | #450
  451. May 8th, 2015 at 01:57 | #451
  452. May 8th, 2015 at 01:58 | #452
  453. May 8th, 2015 at 01:58 | #453
  454. May 8th, 2015 at 01:58 | #454
  455. May 8th, 2015 at 01:58 | #455
  456. May 8th, 2015 at 01:59 | #456
  457. May 8th, 2015 at 01:59 | #457
  458. May 8th, 2015 at 01:59 | #458
  459. May 8th, 2015 at 01:59 | #459
  460. May 8th, 2015 at 02:00 | #460
  461. May 8th, 2015 at 14:14 | #461
  462. May 8th, 2015 at 20:51 | #462
  463. May 8th, 2015 at 20:52 | #463
  464. May 8th, 2015 at 20:52 | #464
  465. May 8th, 2015 at 20:52 | #465
  466. May 9th, 2015 at 01:24 | #466
  467. May 9th, 2015 at 01:24 | #467
  468. May 9th, 2015 at 01:24 | #468
  469. May 9th, 2015 at 01:25 | #469
  470. May 9th, 2015 at 01:27 | #470
  471. May 9th, 2015 at 01:27 | #471
  472. May 9th, 2015 at 01:27 | #472
  473. May 9th, 2015 at 01:27 | #473
  474. May 9th, 2015 at 01:45 | #474
  475. May 9th, 2015 at 01:45 | #475
  476. May 9th, 2015 at 01:46 | #476
  477. May 9th, 2015 at 01:46 | #477
  478. May 9th, 2015 at 01:46 | #478
  479. May 9th, 2015 at 01:46 | #479
  480. May 9th, 2015 at 02:17 | #480
  481. May 9th, 2015 at 02:17 | #481
  482. May 9th, 2015 at 02:17 | #482
  483. May 9th, 2015 at 02:18 | #483
  484. May 9th, 2015 at 02:18 | #484
  485. May 9th, 2015 at 08:03 | #485
  486. May 9th, 2015 at 08:45 | #486
  487. May 9th, 2015 at 14:31 | #487
  488. May 9th, 2015 at 14:39 | #488
  489. May 9th, 2015 at 22:40 | #489
  490. May 10th, 2015 at 11:30 | #490
  491. May 11th, 2015 at 00:29 | #491
  492. May 11th, 2015 at 22:11 | #492
  493. May 11th, 2015 at 22:22 | #493
  494. May 11th, 2015 at 22:24 | #494
  495. May 11th, 2015 at 22:25 | #495
  496. May 11th, 2015 at 22:26 | #496
  497. May 11th, 2015 at 23:56 | #497
  498. May 12th, 2015 at 00:13 | #498
  499. May 12th, 2015 at 00:15 | #499
  500. May 12th, 2015 at 01:09 | #500
  501. May 12th, 2015 at 01:13 | #501
  502. May 12th, 2015 at 01:26 | #502
  503. May 12th, 2015 at 01:47 | #503
  504. May 12th, 2015 at 01:47 | #504
  505. May 12th, 2015 at 01:48 | #505
  506. May 12th, 2015 at 02:46 | #506
  507. May 12th, 2015 at 03:34 | #507
  508. May 12th, 2015 at 03:38 | #508
  509. May 12th, 2015 at 05:12 | #509
  510. May 12th, 2015 at 05:37 | #510
  511. May 12th, 2015 at 06:53 | #511
  512. May 12th, 2015 at 07:01 | #512
  513. May 12th, 2015 at 07:07 | #513
  514. May 12th, 2015 at 07:15 | #514
  515. May 12th, 2015 at 08:22 | #515
  516. May 12th, 2015 at 08:22 | #516
  517. May 12th, 2015 at 08:38 | #517
  518. May 12th, 2015 at 09:47 | #518
  519. May 12th, 2015 at 10:05 | #519
  520. May 12th, 2015 at 10:27 | #520
  521. May 12th, 2015 at 11:13 | #521
  522. May 12th, 2015 at 11:48 | #522
  523. May 12th, 2015 at 11:56 | #523
  524. May 12th, 2015 at 12:42 | #524
  525. May 12th, 2015 at 12:47 | #525
  526. May 12th, 2015 at 13:06 | #526
  527. May 12th, 2015 at 13:36 | #527
  528. May 12th, 2015 at 13:48 | #528
  529. May 12th, 2015 at 13:52 | #529
  530. May 12th, 2015 at 14:02 | #530
  531. May 12th, 2015 at 14:33 | #531
  532. May 12th, 2015 at 15:57 | #532
  533. May 12th, 2015 at 17:09 | #533
  534. May 12th, 2015 at 18:33 | #534
  535. May 12th, 2015 at 18:34 | #535
  536. May 12th, 2015 at 18:54 | #536
  537. May 12th, 2015 at 20:44 | #537
  538. May 12th, 2015 at 21:29 | #538
  539. May 12th, 2015 at 21:48 | #539
  540. May 12th, 2015 at 22:18 | #540
  541. May 12th, 2015 at 23:34 | #541
  542. May 12th, 2015 at 23:50 | #542
  543. May 13th, 2015 at 01:09 | #543
  544. May 13th, 2015 at 01:29 | #544
  545. May 13th, 2015 at 04:36 | #545
  546. May 13th, 2015 at 07:13 | #546
  547. May 16th, 2015 at 07:33 | #547
  548. May 18th, 2015 at 05:38 | #548
  549. May 20th, 2015 at 02:23 | #549
  550. May 20th, 2015 at 16:13 | #550
  551. May 21st, 2015 at 03:42 | #551
  552. May 21st, 2015 at 17:16 | #552
  553. May 22nd, 2015 at 02:11 | #553
  554. May 22nd, 2015 at 02:11 | #554
  555. May 22nd, 2015 at 02:12 | #555
  556. May 22nd, 2015 at 02:12 | #556
  557. May 22nd, 2015 at 02:48 | #557
  558. May 22nd, 2015 at 02:49 | #558
  559. May 22nd, 2015 at 02:49 | #559
  560. May 22nd, 2015 at 02:49 | #560
  561. May 22nd, 2015 at 03:03 | #561
  562. May 22nd, 2015 at 03:03 | #562
  563. May 22nd, 2015 at 03:04 | #563
  564. May 22nd, 2015 at 03:04 | #564
  565. May 22nd, 2015 at 03:27 | #565
  566. May 22nd, 2015 at 03:27 | #566
  567. May 22nd, 2015 at 03:28 | #567
  568. May 22nd, 2015 at 03:28 | #568
  569. May 22nd, 2015 at 03:30 | #569
  570. May 22nd, 2015 at 03:30 | #570
  571. May 22nd, 2015 at 03:30 | #571
  572. May 22nd, 2015 at 03:30 | #572
  573. May 22nd, 2015 at 06:31 | #573
  574. May 22nd, 2015 at 10:31 | #574
  575. May 22nd, 2015 at 12:15 | #575
  576. May 22nd, 2015 at 19:37 | #576
  577. May 22nd, 2015 at 23:38 | #577
  578. May 22nd, 2015 at 23:39 | #578
  579. May 22nd, 2015 at 23:39 | #579
  580. May 22nd, 2015 at 23:39 | #580
  581. May 23rd, 2015 at 00:25 | #581
  582. May 23rd, 2015 at 00:25 | #582
  583. May 23rd, 2015 at 00:25 | #583
  584. May 23rd, 2015 at 00:25 | #584
  585. May 23rd, 2015 at 00:26 | #585
  586. May 23rd, 2015 at 00:27 | #586
  587. May 23rd, 2015 at 06:32 | #587
  588. May 23rd, 2015 at 12:09 | #588
  589. May 23rd, 2015 at 18:10 | #589
  590. May 23rd, 2015 at 18:39 | #590
  591. May 23rd, 2015 at 19:58 | #591
  592. May 23rd, 2015 at 20:30 | #592
  593. May 23rd, 2015 at 20:30 | #593
  594. May 23rd, 2015 at 20:31 | #594
  595. May 23rd, 2015 at 21:15 | #595
  596. May 23rd, 2015 at 21:37 | #596
  597. May 23rd, 2015 at 21:40 | #597
  598. May 24th, 2015 at 03:42 | #598
  599. May 24th, 2015 at 04:23 | #599
  600. May 24th, 2015 at 10:06 | #600
  601. May 24th, 2015 at 14:34 | #601
  602. May 24th, 2015 at 20:21 | #602
  603. May 24th, 2015 at 20:42 | #603
  604. May 24th, 2015 at 22:54 | #604
  605. May 24th, 2015 at 23:49 | #605
  606. May 25th, 2015 at 00:20 | #606
  607. May 25th, 2015 at 00:22 | #607
  608. May 25th, 2015 at 00:29 | #608
  609. May 25th, 2015 at 01:49 | #609
  610. May 25th, 2015 at 03:26 | #610
  611. May 25th, 2015 at 05:39 | #611
  612. May 25th, 2015 at 12:04 | #612
  613. May 25th, 2015 at 16:03 | #613
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