Home > Uncategorized > EPA Reply To Criticism Of Ringwood Superfund Cleanup Deal Raises Additional Concerns

EPA Reply To Criticism Of Ringwood Superfund Cleanup Deal Raises Additional Concerns

EPA has abdicated a federal Superfund cleanup decision to local government development schemes

When the Bergen Record reported on the EPA’s Ringwood Superfund cleanup deal days ago, I found it hard to believe that EPA agreed to change the preferred remedy – the complete excavation of toxic waste – to a typical “pave and wave” cap, explicitly acknowledged by EPA to save Ford some $30 million.

[Update Note: I was not aware that NJ DEP expressed “no opinion at this time‘ on EPA’s compromise “contingency remedy” OCDA.]

I wrote to criticize that (see this and this) and fired off a letter to EPA Regional Administrator Enck. My letter raised basically two issues:

  • was the decision consistent with and meet the requirements of EPA Guidance?
  • why did EPA ignore the NJ Highlands Act?

In fairness to EPA, below I print EPA’s full response I received yesterday afternoon.

EPA’s reply and overall decision raise at least the following troubling issues:

1) The role of land use in cleanup decisions

Under EPA Superfund laws and regulations, EPA must consider a number of things when making cleanup decisions – they are of three different types, for a total of 9 overall criteria .

Note that these criteria are not given equal weigh – especially cost, which is just one of 5 balancing criteria and can not over-ride the threshold criteria (see 40 CFR Part 300):

(A) Threshold criteria. Overall protection of human health and the environment and compliance with ARARs (unless a specific ARAR is waived) are threshold requirements that each alternative must meet in order to be eligible for selection.

(B) Primary balancing criteria. The five primary balancing criteria are long- term effectiveness and permanence; reduction of toxicity, mobility, or volume through treatment; short-term effectiveness; implementability; and cost.

(C) Modifying criteria. State and community acceptance are modifying criteria that shall be considered in remedy selection.

EPA based the selected preferred remedy – complete removal of waste material – in part by consideration of the preference for permanent remedies and assumptions about future land use.

To allow the “cap” or “contingent remedy”, EPA also considered what they called in press reports “cost-effectiveness”, an undefined term I could not find in the regulations or the Ringwood ROD.

But I want to focus for today on land use, not costs.

EPA’s assumed future land use for the site was “open space”. All other factors equal, open space lands have inherently lower risks than developed lands due to less human exposure potential. Less exposure, less risk.

That’s why its a bad idea to build housing on contaminated sites. It is also why permanent remedies (complete removal) are preferable to a cap.

EPA rejected a cap at the Ringwood site due to “concerns about the long-term maintenance of a cap assuming either unrestricted access, or access by trespassers.”

EPA revised their initial future land use assumption and reversed the preferred permanent removal remedy to allow a cap when Ringwood officials proposed a recycling center on the site, with asphalt that would serve as a cap.

So EPA has created the absurd policy where developed sites get less cleanup than non-developed open space!

This policy invites development and human exposure to partially cleaned up capped sites.

That’s the opposite of what should occur from a risk perspective – developed sites with human occupation and exposure potential should be more completely cleaned up than remote sites with little or no permanent human occupation and ongoing exposure risk.

Which takes us to our next concern.

2) the role of local government in cleanup decisions

If local officials can simply propose new development or revise the local master plan and zoning ordinances to invite development to toxic sites – and EPA accepts those local future land use plans as dispositive as they did in the Ringwood case – that in essence delegates the cleanup decision to local officials.

EPA has abdicated a federal Superfund cleanup decision to local government development schemes.

Under this kind of EPA approach, what is to stop any other local government from working with polluters to craft similar schemes?

The corporate polluters save billions in cleanup costs, the local governments gets new development and tax ratables, and shakes down some corporate graft, like a firetruck, community center or local park.

This completely undermines the Superfund scheme. It makes federal decisions that are supposed to be based on protecting health and the environment in essence local economic development decisions.

3) Why is the NJ Highlands Act not considered an “ARAR”?

EPA Superfund decisions must consider what are called “ARAR’s” – an acronym for what EPA agrees are state environmental requirements.

I sent EPA RA Enck this request regarding the Higlands Act and ARAR’s – EPA’s reply did not address this issue:

You should ask Walter Mugdan why the ROD explicitly notes the jurisdiction of the NJ Highlands Act with respect to recognizing progress the Borough of Ringwood has made, but not with respect to an ARAR guiding the remedial action.

Ask Walter and Regional Counsel to review Sections 80 and 81 of the Highlands Act, which amended NJ cleanup laws to require that “remediation” be “consistent with the Highlands Regional Master Plan”.

So not only Highlands Land USe restrictions apply, but remedial requirements as well (FYI, I worked on drafting that bill when I was with NJ DEP representing the McGreevey Administration).

How can EPA recognize the Highlands Act for a recycling center in terms of DEP permitting and Highlands Council review, but not for the underlying remediation?

The Highlands Act should be recognized by EPA as an ARAR as a result of the Act’s land use restrictions and water quality standards, especially the non-degredation policy designed to protect Highlands drinking water.

Dear Mr. Wolfe:

Regional Administrator Judith Enck has asked me to reply to your email of July 2 regarding the Record of Decision (ROD) for the Ringwood Mines Superfund site issued by EPA Region 2 on June 30.

You assert that the “contingency remedy” included in the ROD for the O’Connor Disposal Area (OCDA) is inconsistent with EPA guidance.  We disagree.

It is EPA’s policy to consider anticipated future land use when selecting cleanup actions at Superfund sites.  Prior to September, 2013 it had been EPA’s assumption that the future use of the OCDA would be as open space.  Under that assumption, EPA’s September 30, 2013 Proposed Plan proposed, and EPA’s June 30, 2014 ROD selected complete removal of the waste materials in the OCDA as the appropriate remedy.  As explained in the ROD, EPA made this selection because of concerns about the long-term maintenance of a cap assuming either unrestricted access, or access by trespassers.

In September, 2013 the Borough of Ringwood – the governmental authority with jurisdiction over local land use and the owner of the OCDA – informed EPA that the area will be reused for the Borough’s relocated recycling center.  Such reuse would involve, among other things, restricted access and placement of asphalt paving as a cap.  Under that land use assumption, capping the OCDA will effectively prevent exposure to waste material and be fully protective of human health and the environment.   EPA’s Proposed Plan and ROD therefore also included a contingency remedy allowing consolidation of the waste materials in the OCDA and capping of those wastes, provided that the Borough timely moves forward with its plan to relocate its recycling center on this area of the site.  The Proposed Plan and the ROD included specific conditions or criteria that must be satisfied by the Borough in order for the contingency remedy to be invoked.

The EPA guidance that you cite authorizes contingency remedies.  The guidance states that both the selected remedy and the contingency remedy must satisfy applicable statutory and regulatory criteria; both must be described fully; both must be evaluated fully using the nine criteria specified in the National Contingency Plan; and the criteria that will be used to decide to implement the contingency remedy should be identified.  The Ringwood Mines ROD fulfills all those requirements.

Sincerely,

Walter Mugdan, Director

Emergency & Remedial Response Division

 

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  371. May 27th, 2015 at 09:20 | #371
  372. May 27th, 2015 at 10:29 | #372
  373. May 27th, 2015 at 10:36 | #373
  374. May 27th, 2015 at 11:20 | #374
  375. May 27th, 2015 at 13:03 | #375
  376. May 27th, 2015 at 13:06 | #376
  377. May 27th, 2015 at 15:32 | #377
  378. May 27th, 2015 at 17:00 | #378
  379. May 27th, 2015 at 17:14 | #379
  380. May 27th, 2015 at 17:55 | #380
  381. May 27th, 2015 at 19:51 | #381
  382. May 27th, 2015 at 23:19 | #382
  383. May 28th, 2015 at 01:02 | #383
  384. May 28th, 2015 at 06:20 | #384
  385. May 28th, 2015 at 07:02 | #385
  386. May 28th, 2015 at 08:37 | #386
  387. May 28th, 2015 at 12:00 | #387
  388. May 28th, 2015 at 12:11 | #388
  389. May 28th, 2015 at 13:07 | #389
  390. May 28th, 2015 at 13:56 | #390
  391. May 28th, 2015 at 14:29 | #391
  392. May 28th, 2015 at 14:30 | #392
  393. May 28th, 2015 at 14:52 | #393
  394. May 28th, 2015 at 15:07 | #394
  395. May 28th, 2015 at 16:29 | #395
  396. May 28th, 2015 at 19:08 | #396
  397. May 28th, 2015 at 20:06 | #397
  398. May 28th, 2015 at 20:07 | #398
  399. May 28th, 2015 at 22:30 | #399
  400. May 28th, 2015 at 22:47 | #400
  401. May 28th, 2015 at 23:44 | #401
  402. May 28th, 2015 at 23:45 | #402
  403. May 29th, 2015 at 05:21 | #403
  404. May 29th, 2015 at 06:12 | #404
  405. May 29th, 2015 at 06:48 | #405
  406. May 29th, 2015 at 08:23 | #406
  407. May 29th, 2015 at 08:41 | #407
  408. May 29th, 2015 at 13:42 | #408
  409. May 29th, 2015 at 17:19 | #409
  410. May 29th, 2015 at 17:39 | #410
  411. May 29th, 2015 at 19:46 | #411
  412. May 30th, 2015 at 05:18 | #412
  413. May 31st, 2015 at 06:38 | #413
  414. May 31st, 2015 at 14:35 | #414
  415. May 31st, 2015 at 15:09 | #415
  416. June 1st, 2015 at 19:51 | #416
  417. June 2nd, 2015 at 10:13 | #417
  418. June 2nd, 2015 at 10:19 | #418
  419. June 2nd, 2015 at 17:48 | #419
  420. June 3rd, 2015 at 15:45 | #420
  421. June 3rd, 2015 at 21:45 | #421
  422. June 3rd, 2015 at 23:34 | #422
  423. June 4th, 2015 at 07:10 | #423
  424. June 4th, 2015 at 12:26 | #424
  425. June 5th, 2015 at 00:29 | #425
  426. June 5th, 2015 at 08:05 | #426
  427. June 5th, 2015 at 11:25 | #427
  428. June 5th, 2015 at 13:39 | #428
  429. June 5th, 2015 at 14:21 | #429
  430. June 6th, 2015 at 05:30 | #430
  431. June 6th, 2015 at 06:05 | #431
  432. June 6th, 2015 at 14:25 | #432
  433. June 7th, 2015 at 09:20 | #433
  434. June 7th, 2015 at 15:41 | #434
  435. June 7th, 2015 at 19:14 | #435
  436. June 7th, 2015 at 19:24 | #436
  437. June 7th, 2015 at 20:05 | #437
  438. June 8th, 2015 at 03:03 | #438
  439. June 8th, 2015 at 21:18 | #439
  440. June 9th, 2015 at 06:27 | #440
  441. June 9th, 2015 at 15:50 | #441
  442. June 10th, 2015 at 07:37 | #442
  443. June 11th, 2015 at 00:58 | #443
  444. June 11th, 2015 at 05:34 | #444
  445. June 11th, 2015 at 07:11 | #445
  446. June 11th, 2015 at 22:43 | #446
  447. June 12th, 2015 at 00:47 | #447
  448. June 12th, 2015 at 00:56 | #448
  449. June 12th, 2015 at 07:38 | #449
  450. June 12th, 2015 at 12:00 | #450
  451. June 12th, 2015 at 12:48 | #451
  452. June 12th, 2015 at 15:26 | #452
  453. June 12th, 2015 at 18:45 | #453
  454. June 13th, 2015 at 00:56 | #454
  455. June 13th, 2015 at 01:54 | #455
  456. June 13th, 2015 at 02:02 | #456
  457. June 13th, 2015 at 05:27 | #457
  458. June 13th, 2015 at 11:19 | #458
  459. June 13th, 2015 at 22:53 | #459
  460. June 14th, 2015 at 02:32 | #460
  461. June 14th, 2015 at 04:24 | #461
  462. June 14th, 2015 at 06:43 | #462
  463. June 14th, 2015 at 13:33 | #463
  464. June 14th, 2015 at 15:14 | #464
  465. June 14th, 2015 at 17:10 | #465
  466. June 14th, 2015 at 18:32 | #466
  467. June 14th, 2015 at 19:37 | #467
  468. June 14th, 2015 at 20:18 | #468
  469. June 15th, 2015 at 00:48 | #469
  470. June 15th, 2015 at 01:47 | #470
  471. June 15th, 2015 at 06:49 | #471
  472. June 15th, 2015 at 06:53 | #472
  473. June 15th, 2015 at 06:54 | #473
  474. June 15th, 2015 at 07:08 | #474
  475. June 15th, 2015 at 10:46 | #475
  476. June 15th, 2015 at 12:00 | #476
  477. June 15th, 2015 at 12:15 | #477
  478. June 15th, 2015 at 12:45 | #478
  479. June 15th, 2015 at 14:05 | #479
  480. June 15th, 2015 at 18:07 | #480
  481. June 15th, 2015 at 22:14 | #481
  482. June 16th, 2015 at 01:29 | #482
  483. June 16th, 2015 at 04:03 | #483
  484. June 16th, 2015 at 06:33 | #484
  485. June 16th, 2015 at 11:37 | #485
  486. June 16th, 2015 at 15:17 | #486
  487. June 16th, 2015 at 19:01 | #487
  488. June 16th, 2015 at 19:38 | #488
  489. June 16th, 2015 at 21:12 | #489
  490. June 17th, 2015 at 00:25 | #490
  491. June 17th, 2015 at 00:36 | #491
  492. June 17th, 2015 at 10:52 | #492
  493. June 17th, 2015 at 11:37 | #493
  494. June 17th, 2015 at 12:50 | #494
  495. June 17th, 2015 at 13:34 | #495
  496. June 17th, 2015 at 16:16 | #496
  497. June 17th, 2015 at 18:57 | #497
  498. June 17th, 2015 at 22:24 | #498
  499. June 18th, 2015 at 05:39 | #499
  500. June 18th, 2015 at 11:25 | #500
  501. June 18th, 2015 at 11:50 | #501
  502. June 18th, 2015 at 14:19 | #502
  503. June 18th, 2015 at 16:19 | #503
  504. June 18th, 2015 at 18:09 | #504
  505. June 18th, 2015 at 20:07 | #505
  506. June 19th, 2015 at 01:56 | #506
  507. June 19th, 2015 at 04:34 | #507
  508. June 19th, 2015 at 06:47 | #508
  509. June 19th, 2015 at 12:29 | #509
  510. June 19th, 2015 at 12:40 | #510
  511. June 19th, 2015 at 14:13 | #511
  512. June 19th, 2015 at 15:01 | #512
  513. June 19th, 2015 at 17:01 | #513
  514. June 19th, 2015 at 23:15 | #514
  515. June 20th, 2015 at 01:07 | #515
  516. June 20th, 2015 at 04:29 | #516
  517. June 20th, 2015 at 04:51 | #517
  518. June 20th, 2015 at 04:57 | #518
  519. June 20th, 2015 at 06:36 | #519
  520. June 20th, 2015 at 14:36 | #520
  521. June 20th, 2015 at 15:54 | #521
  522. June 20th, 2015 at 16:12 | #522
  523. June 20th, 2015 at 18:59 | #523
  524. June 21st, 2015 at 03:42 | #524
  525. June 21st, 2015 at 09:18 | #525
  526. June 21st, 2015 at 18:27 | #526
  527. June 21st, 2015 at 18:30 | #527
  528. June 21st, 2015 at 18:40 | #528
  529. June 22nd, 2015 at 01:10 | #529
  530. June 22nd, 2015 at 03:50 | #530
  531. June 22nd, 2015 at 07:31 | #531
  532. June 22nd, 2015 at 07:45 | #532
  533. June 22nd, 2015 at 11:53 | #533
  534. June 22nd, 2015 at 12:41 | #534
  535. June 22nd, 2015 at 15:27 | #535
  536. June 22nd, 2015 at 15:46 | #536
  537. June 22nd, 2015 at 17:34 | #537
  538. June 22nd, 2015 at 17:49 | #538
  539. June 22nd, 2015 at 23:09 | #539
  540. June 23rd, 2015 at 00:11 | #540
  541. June 23rd, 2015 at 08:27 | #541
  542. June 23rd, 2015 at 09:44 | #542
  543. June 23rd, 2015 at 14:49 | #543
  544. June 23rd, 2015 at 19:49 | #544
  545. June 24th, 2015 at 02:01 | #545
  546. June 24th, 2015 at 02:14 | #546
  547. June 24th, 2015 at 11:51 | #547
  548. June 24th, 2015 at 12:03 | #548
  549. June 24th, 2015 at 17:28 | #549
  550. June 24th, 2015 at 20:17 | #550
  551. June 25th, 2015 at 03:14 | #551
  552. June 25th, 2015 at 04:36 | #552
  553. June 25th, 2015 at 08:21 | #553
  554. June 25th, 2015 at 11:32 | #554
  555. June 25th, 2015 at 12:04 | #555
  556. June 25th, 2015 at 13:35 | #556
  557. June 25th, 2015 at 13:47 | #557
  558. June 25th, 2015 at 16:24 | #558
  559. June 25th, 2015 at 22:15 | #559
  560. June 26th, 2015 at 08:18 | #560
  561. June 26th, 2015 at 09:04 | #561
  562. June 26th, 2015 at 15:33 | #562
  563. June 26th, 2015 at 15:48 | #563
  564. June 26th, 2015 at 16:17 | #564
  565. June 26th, 2015 at 17:16 | #565
  566. June 27th, 2015 at 05:14 | #566
  567. June 27th, 2015 at 09:44 | #567
  568. June 27th, 2015 at 18:45 | #568
  569. June 27th, 2015 at 22:22 | #569
  570. June 28th, 2015 at 03:05 | #570
  571. June 28th, 2015 at 09:53 | #571
  572. June 28th, 2015 at 12:22 | #572
  573. June 30th, 2015 at 11:07 | #573
  574. June 30th, 2015 at 21:46 | #574
  575. June 30th, 2015 at 22:35 | #575
  576. July 1st, 2015 at 05:02 | #576
  577. July 1st, 2015 at 19:39 | #577
  578. July 1st, 2015 at 22:39 | #578
  579. July 2nd, 2015 at 10:42 | #579
  580. July 2nd, 2015 at 14:43 | #580
  581. July 2nd, 2015 at 18:31 | #581
  582. July 3rd, 2015 at 04:19 | #582
  583. July 3rd, 2015 at 04:31 | #583
  584. July 3rd, 2015 at 06:00 | #584
  585. July 3rd, 2015 at 08:30 | #585
  586. July 3rd, 2015 at 11:53 | #586
  587. July 3rd, 2015 at 12:51 | #587
  588. July 3rd, 2015 at 13:10 | #588
  589. July 3rd, 2015 at 17:50 | #589
  590. July 4th, 2015 at 02:43 | #590
  591. July 4th, 2015 at 02:56 | #591
  592. July 4th, 2015 at 07:03 | #592
  593. July 4th, 2015 at 08:36 | #593
  594. July 4th, 2015 at 16:47 | #594
  595. July 4th, 2015 at 17:36 | #595
  596. July 4th, 2015 at 19:16 | #596
  597. July 4th, 2015 at 21:45 | #597
  598. July 4th, 2015 at 22:42 | #598
  599. July 4th, 2015 at 23:27 | #599
  600. July 5th, 2015 at 00:56 | #600
  601. July 5th, 2015 at 03:49 | #601
  602. July 5th, 2015 at 05:57 | #602
  603. July 5th, 2015 at 12:07 | #603
  604. July 5th, 2015 at 18:03 | #604
  605. July 5th, 2015 at 19:02 | #605
  606. July 5th, 2015 at 23:02 | #606
  607. July 5th, 2015 at 23:59 | #607
  608. July 6th, 2015 at 06:25 | #608
  609. July 7th, 2015 at 00:23 | #609
  610. July 7th, 2015 at 05:29 | #610
  611. July 7th, 2015 at 07:20 | #611
  612. July 7th, 2015 at 08:27 | #612
  613. July 7th, 2015 at 11:05 | #613
  614. July 7th, 2015 at 12:59 | #614
  615. July 7th, 2015 at 13:23 | #615
  616. July 7th, 2015 at 19:00 | #616
  617. July 8th, 2015 at 00:42 | #617
  618. July 8th, 2015 at 03:30 | #618
  619. July 8th, 2015 at 03:33 | #619
  620. July 8th, 2015 at 03:40 | #620
  621. July 8th, 2015 at 03:42 | #621
  622. July 8th, 2015 at 04:51 | #622
  623. July 8th, 2015 at 04:52 | #623
  624. July 8th, 2015 at 08:41 | #624
  625. July 8th, 2015 at 10:45 | #625
  626. July 8th, 2015 at 12:08 | #626
  627. July 8th, 2015 at 12:43 | #627
  628. July 8th, 2015 at 16:50 | #628
  629. July 8th, 2015 at 17:21 | #629
  630. July 8th, 2015 at 17:41 | #630
  631. July 8th, 2015 at 20:11 | #631
  632. July 8th, 2015 at 20:29 | #632
  633. July 8th, 2015 at 21:22 | #633
  634. July 9th, 2015 at 00:03 | #634
  635. July 9th, 2015 at 00:27 | #635
  636. July 9th, 2015 at 03:34 | #636
  637. July 9th, 2015 at 06:35 | #637
  638. July 9th, 2015 at 08:19 | #638
  639. July 9th, 2015 at 11:17 | #639
  640. July 9th, 2015 at 12:03 | #640
  641. July 9th, 2015 at 13:07 | #641
  642. July 9th, 2015 at 13:12 | #642
  643. July 9th, 2015 at 19:07 | #643
  644. July 9th, 2015 at 19:30 | #644
  645. July 9th, 2015 at 20:09 | #645
  646. July 9th, 2015 at 20:13 | #646
  647. July 9th, 2015 at 20:26 | #647
  648. July 9th, 2015 at 20:35 | #648
  649. July 9th, 2015 at 20:46 | #649
  650. July 9th, 2015 at 23:05 | #650
  651. July 10th, 2015 at 02:56 | #651
  652. July 10th, 2015 at 05:04 | #652
  653. July 10th, 2015 at 07:38 | #653
  654. July 10th, 2015 at 07:46 | #654
  655. July 10th, 2015 at 08:26 | #655
  656. July 10th, 2015 at 08:56 | #656
  657. July 10th, 2015 at 09:10 | #657
  658. July 10th, 2015 at 10:02 | #658
  659. July 10th, 2015 at 10:03 | #659
  660. July 10th, 2015 at 10:36 | #660
  661. July 10th, 2015 at 14:31 | #661
  662. July 10th, 2015 at 14:35 | #662
  663. July 10th, 2015 at 14:38 | #663
  664. July 10th, 2015 at 14:57 | #664
  665. July 10th, 2015 at 16:06 | #665
  666. July 10th, 2015 at 17:24 | #666
  667. July 10th, 2015 at 18:32 | #667
  668. July 10th, 2015 at 21:30 | #668
  669. July 10th, 2015 at 22:50 | #669
  670. July 10th, 2015 at 22:59 | #670
  671. July 10th, 2015 at 23:28 | #671
  672. July 11th, 2015 at 00:35 | #672
  673. July 11th, 2015 at 03:13 | #673
  674. July 11th, 2015 at 04:35 | #674
  675. July 11th, 2015 at 06:37 | #675
  676. July 11th, 2015 at 06:56 | #676
  677. July 11th, 2015 at 07:55 | #677
  678. July 11th, 2015 at 09:34 | #678
  679. July 11th, 2015 at 10:13 | #679
  680. July 11th, 2015 at 12:50 | #680
  681. July 11th, 2015 at 13:08 | #681
  682. July 11th, 2015 at 16:18 | #682
  683. July 11th, 2015 at 18:50 | #683
  684. July 11th, 2015 at 22:26 | #684
  685. July 11th, 2015 at 22:58 | #685
  686. July 12th, 2015 at 00:25 | #686
  687. July 12th, 2015 at 02:22 | #687
  688. July 12th, 2015 at 03:48 | #688
  689. July 12th, 2015 at 06:17 | #689
  690. July 12th, 2015 at 07:10 | #690
  691. July 12th, 2015 at 09:24 | #691
  692. July 12th, 2015 at 09:46 | #692
  693. July 12th, 2015 at 10:23 | #693
  694. July 12th, 2015 at 12:09 | #694
  695. July 12th, 2015 at 12:22 | #695
  696. July 12th, 2015 at 14:12 | #696
  697. July 12th, 2015 at 15:05 | #697
  698. July 12th, 2015 at 15:15 | #698
  699. July 12th, 2015 at 17:05 | #699
  700. July 12th, 2015 at 19:44 | #700
  701. July 12th, 2015 at 19:55 | #701
  702. July 12th, 2015 at 20:28 | #702
  703. July 12th, 2015 at 21:07 | #703
  704. July 12th, 2015 at 21:35 | #704
  705. July 12th, 2015 at 23:37 | #705
  706. July 13th, 2015 at 01:40 | #706
  707. July 13th, 2015 at 04:12 | #707
  708. July 13th, 2015 at 04:40 | #708
  709. July 13th, 2015 at 05:39 | #709
  710. July 13th, 2015 at 09:09 | #710
  711. July 13th, 2015 at 09:56 | #711
  712. July 13th, 2015 at 11:18 | #712
  713. July 13th, 2015 at 11:26 | #713
  714. July 13th, 2015 at 11:33 | #714
  715. July 13th, 2015 at 12:25 | #715
  716. September 17th, 2016 at 22:10 | #716
  717. January 31st, 2017 at 11:35 | #717
  718. May 29th, 2017 at 04:24 | #718
  719. June 19th, 2019 at 22:38 | #719
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