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August 15, 2018
News Release
For Immediate Release
GrowFL Announces 2018 Florida Companies to Watch Finalists
Narducci Dental Group, P.A. Among Second-Stage Businesses
Competing to Earn Prestigious Honor
JACKSONVILLE, FL Narducci Dental Group, P.A. was among the first round of 2018 Florida Companies to Watch finalists recently announced by GrowFL. The awards event - now in its eighth year - honors 50 select second-stage companies from throughout the state for developing valuable products and services, creating quality jobs, enriching communities, and broadening new industries throughout Florida. Chosen from a candidate pool of 134 growing second-stage businesses, the finalists collectively represented $518 million in annual revenue and employed 2,743 full-time equivalent employees in 2017.
"Our team, Narducci Dental Group, is honored to be chose as a finalist as a 2018 Florida Company to watch. I started this company with a vision to build a team that would practice dentistry treating each patient like we would our own family. I grew up in an era where the dentist was feared and hated. I wanted to transform this experience into a positive and inspiring one, giving patients the will and desire to "perfect their smile." We wanted to make comprehensive dentistry accessible to all socioeconomic groups, which we have been able to achieve through accepting a wide range of corporate and government dental plans and even participating in missionary work to provide those who have nothing. We have also come up with a program for those that don't have insurance, making dentistry affordable for all stages of life.
I have been able to create the "wow experience" in dentistry with a team that share my vision and comes to work fueled with enthusiasm. Their enthusiasm gives our patients the desire to keep coming back excited to get their dental care. We are truly blessed to be able to provide dental care in offices throughout north Florida and central Florida. We care for our patients, and it starts with caring for our team. Through this synergy, we look forward to being a company whose vision spreads even to our competition to continue to transform dentistry into an experience that inspires and is attainable, no matter what stage of life you are in" –Nicholas A. Narducci, DMD, MAGD, MBA
The Florida Companies To Watch program consists of two rounds of selections. Finalists now advance to the second round, where they will be further evaluated based on their performance in the marketplace, innovative products, services or processes, philanthropy and empowered employees.
"We applaud these first round finalists who have shown how they stand out in their regions as innovative business leaders, going to the next level to grow their companies. They are true rock stars," says Dr. Tom O'Neal, GrowFL Executive Director.
The Finalists represent a unique group of scalable, high-growth enterprises that are already located within Florida. These high growth enterprises are an important segment of our economy and their numbers have been steadily increasing, which contributed to Florida's ranking of 24 on the 2018 Kauffman Index of Growth Entrepreneurship. According to this report, "entrepreneurship is not a monolithic phenomenon, and it includes many moving parts. Creating new businesses is a different economic activity from running small businesses, which in turn is different from growing businesses." Florida Companies to Watch recognizes the different approach needed to successfully grow and scale a business and celebrates those that are working to achieve this goal.
2018 FLCTW First Round Finalists – Add TWO
Developed by the Edward Lowe Foundation, Florida Companies To Watch is a distinguished awards program specifically designed to seek out second-stage businesses from a wide range of industries representing all areas of the state, not just those in major metropolitan areas. In addition to evaluating past growth and projected success, applicant companies are judged according to their special strengths and impact in their markets, communities and within the state – thus deeming them "worth watching."
The winners will be announced in MID-September. The 2018 honorees will be celebrated at the awards ceremony February 9th at the Straz Center for the Performing Arts in Tampa, FL.
For more information visit https://www.growfl.com/flctw18/.
About Narducci Dental Group, P.A.
Narducci Dental Group, P. A. is dedicated to improving the quality of life through exceptional oral health care. Narducci Dental Group's success is powered by talented professionals and their dedication to practice dentistry the way it was meant to be practiced; as an art, implementing knowledge, thought, creativity, and detail into the entire patient experience.
For additional information please visit www.narduccidental.com, www.facebook.com/narduccidental
About GrowFL
GrowFL was created in 2009 as an economic development program focused on assisting second-stage growth companies prosper in the state of Florida. By providing strategies, resources and support to second-stage companies for next level growth through Strategic Research, Peer Learning and Leadership Development, GrowFL helps companies overcome obstacles to growth and leads them towards prosperity. Based on the philosophy of Economic Gardening® — to grow existing businesses in a community, region or state — GrowFL, the Florida Economic Gardening Institute, is a critical component to the state's economic development strategy and Florida's entrepreneurial ecosystem. GrowFL is a statewide economic development organization certified by the National Center for Economic Gardening through the Edward Lowe Foundation. Learn more at www.GrowFL.com.

subset: commoncrawl


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Parade of forwards at top of NHL draft
Hugo Joseph | June 24, 2017, 7:52
Parade of forwards at top of NHL draft
The Devils went with forward Nico Hischier with the No. 1 overall pick in Friday night's draft, making Hischier the first Swiss-born player ever taken first. But he as high upside as a first-line center. "In the middle of the ice you want a player that can create offense, that can play defensively and he's got a presence in the middle of the ice".
The Golden Knights became the first expansion team to pick three times in the first round.
Glass was rated sixth by Central Scouting and that's exactly where he went but that didn't mean he was the picture of calm as the first five picks passed by.
This is not to say that I don't like Nico Hischier, I do. "Just to be a part of the Vegas organization is unbelievable". "When you're going somewhere and don't know anyone, it's tough for a guy to step in", Patrick said. I'm really happy I am here. I like him a lot.
"I kind of had a feeling I was going to end up in Philly, and I'm real excited about the chance to go there" said Patrick, whose dad, mom, two sisters and an uncle were at the draft.
"I think this still will be proven to be a good draft", Shero said. "He's a great guy, really amusing". I love the way he carries himself, he has future captain of the Flyers written all over him.
Hischier is a native of Naters, Switzerland.
That said, Patrick plays a very effective, NHL-style game and has since he was 16.
The Leafs, led by young first-round picks Auston Matthews, William Nylander and Mitch Marner, made tremendous strides last season and earned a playoff berth for the first time since 2013.
Hischier, an electric centre with game-breaking speed, rose into top spot with an emphatic first season in the Quebec Major Junior League, piling up 38 goals and 86 points in 57 games as a rookie for the Halifax Mooseheads. That was a significant step in Hischier's hockey evolution, especially with his defensive play. I think Hischier is a hybrid winger; that big center is so important.
Nolan's dad, Steve, played 250 National Hockey League games for the Buffalo Sabres, Quebec Nordiques and New York Rangers.
Hischier, listed at one inch shorter and 20 pounds lighter than Patrick, is thought to be the more skilled skater and playmaker.
Finally, some more encouraging words for the Devils.
The pair will see a lot more of each other in the coming years as Metropolitan Division rivals, an opportunity for fans of both teams to regularly gauge who got the better player Friday.


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LOCAL INFO: The Village is one of the top 15 largest municipalities in Illinois, featuring a unique blend of old and new. It's a progressive community that people are proud to call home and where young families like to establish their roots for generations to come. It's a community that offers vibrancy and interest.
Arlington Heights is an attractive destination for homebuyers, shoppers, businesses and visitors with its dynamic economy, award-winning schools, library, park district. Lake Arlington is popular for boating and fishing and includes a hiking trail which surrounds the lake. Nickol Knoll Park features a golf course and ballparks. The Crabtree Nature Center, includes woodlands, prairie, marshes, ponds and a vast number of bird species. Residents and visitors enjoy hiking in the Lakewood Forest Preserve Loop which offers scenic forest areas and lakes. The Deer Grove Loop includes forest landscape, marshes and ponds.
|Start dates
|End dates
JOB TITLE: Housekeeping/Front desk. Mainly housekeepers.
COMPANY TYPE: Hospitality
QUALIFICATIONS: Customer service. For Front desk experience in the field required.
GENDER: Preferably female
NATIONALITY: Mongolian, Philippines, Thai, Chinese preferable.
MINIMUM ENGLISH: For the front desk we require good English skills.
WAGE: 10.00 $ /h
AVERAGE HOURS: 35 weekly
OVERTIME: Available, paid
FREQUENCY OF PAY: Bi-weekly
WORK SCHEDULES: 7 days availability. Morning, afternoon, evening as required.
TRAINING: Yes. We have 3/4 days paid training with the more experienced worker. Then it depends on the employee
SICK/VACATION DAYS: No. Anyways, the schedule is mainly made according to the company needs, but if they request time off, we are pretty flexible.
LOCATION: Arlington Heights, IL.
WEBSITES: http://www.vah.com/
SECOND JOBS: You can apply for a second job as long as that job does not interfere with our schedule.
INTERNET AVAILABILITY: Available
TRAVEL TO WORK: hotel's room provided
DISTANCE FROM SHOPPING CENTER: grocery store is less than 1 mile, shopping center 3 miles. Since we have a shuttle we have been scheduling student once/twice a week to go grocery.
HOUSING: Hotel room
HOUSING COSTS: $100 weekly. No further expenses.
ARRIVAL INFO: Prior notice required
EMPLOYER PICK-UP: Yes


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Butterick 4900; 1970s; View A: lined drawstring bag (10.5 X 19.5") has circular bottom, purchased cord drawstring forming ruffle at upper edge, self loop at lower edge and topstitch trim. View B: lined bag (16" X 12.5" X 3.5") has self straps, zipper tennis racket cover and purchased fold over tape finish. View C: lined bag (16" X 12.5" X 3.5") has purchased webbing straps. Included are instructions and permeant iron on alphabet transfers (3 sets of capital letters A to Z).
Links to reviews/blog postsEdit
Community content is available under CC-BY-SA unless otherwise noted.


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Carrollton Hebron 3-Star QB Changes 'Tune,' Re-commits to Kansas
HEBRON, Texas — Clayton Tune is no longer on the market — again.
On Oct. 21, he opened his recruitment with an 18-word tweet:
I have opened up my recruitment! I'm going to put my faith in God and trust the process.
— Clayton Tune (@ClaytonTune7) October 22, 2017
On Sunday, per a report from Yahoo Rivals' Jayhawk Slant, Tune re-committed after Kansas coaches met with the quarterback and his family after recruiters were released to recruit on the road.
"Coach [David] Beaty, Coach [Kenny] Perry, and Coach [Perry] Riley all came to my house," Tune said to Jayhawk Slant. "It was cool to see them because I hadn't seen them in a while."
Tune, one of the Jayhawk's first quarterback offers of the 2018 season and one that holds offers from Baylor, Houston, Iowa, North Texas, Oklahoma, Oregon, North Texas, and Texas A&M. At the time of his de-commitment, Tune had passed for 1,475 yards and 14 touchdowns with two interceptions through seven games and Hebron was 6-1.
Little more than a month later, Tune finished with 2,409 yards and 23 touchdowns against nine interceptions and a 67 completion percentage. Hebron reached the bi-district round of the UIL 6A playoffs, falling to Allen High School, the Associated Press and USA TODAY High School Sports Experts' Super 25 No. 3 team.
Tune threw for more than 6,700 yards during his four-year career at Hebron and was voted as the District 5-6A MVP in 2016 after leading the Hawks to a 6-1 record and a second-place finish. At 6-foot-2 and 200 pounds, Tune is ranked as the No. 31 pro-style quarterback, the No. 103 overall prospect in the state, and the No. 764 athlete in the nation according to 247Sports Composite.
"They were telling me what to expect when I get there," Tune said. "One thing has stood out is their loyalty. We really liked them as coaches as well. It's exciting to know I'm going somewhere to try and have an immediate impact. So that's exciting."
The decision to veer away from his home state of Texas may be surprising given 247Sports' reports that he favored Baylor and Waco over the other eight candidate schools. Kansas finished the 2017 college football season 1-11 overall and 10th in the Big 12 Conference at 0-9 but kept pace with Kansas State and West Virginia in high-scoring losses.
Marcus Matthews-Marion is the managing editor of TexasHSFootball, covering prep football throughout the Lone Star State. Follow him on Twitter, @TheMJMatthews, and read more of his content here.
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Lately my mind has been cast on things of more serious nature than I would normally have liked. This, I feel has made my blogging heavier than I want and its time for some humor. Unfortunately, With such serious engagements in my near future I have either failed to see the humor in life (omit monkey and pig story) or simply nothing funny is happening right now. So, I hearken back to a story always good for a laugh; from my tenure in the Philippines.
To know me is to know my bowels ( a wise man once said) . Within the first 6 months of my mission in the Philippines I acquired a form of diarrhea that to this day physicians can not explain to me. It's entirely possible that I had this condition even earlier than said mission; nevertheless, I blame the Philippines.
As every good missionary knows; teaching the gospel to successful city folk is difficult. In other words people with money don't often feel inclined to hear about religion. If they already have religion they figure its working out for them so why should they need more. I can't imagine trying to teach successful white folk in American cities. ANYWAY; we would often travel as far to the out-skirts of our designated area as possible to find the really down and out people. Often we would have to ride a jeep-nee to get to one of these barrios. So, by time we started working in the morning we were often up to 20 miles away from our apartment.
One fateful night we had an appointment late in the evening (after dark) in this far away area. After our appointment was finished we began the walk home. Hoping that a Jeep-nee or even a man on a motorcycle would stop and pick us up. After we walked for about a mile or two, in the dark. It seemed as though getting a ride back to town was going to take some "divine intervention".
I began to feel that rumbly-in-my-tumbly (winnie the poo). It's is a feeling that I now characterize as the ten second warning. Having walked along this major highway for almost an hour and seeing no-one I began to wonder if it would be safe for me to just step of the side of the road and "take care of business" boy scout style. It very soon got to the point where I had no options; well ok I had two options but one of them made for a rather miserable walk home and even worse if someone picked us up. So I told my companion of my "quick and dirty" plan. I stepped about 10 feet of the side of the road, pulled my pants down and……
At this precise moment in time, a jeep-nee full of people stopped exactly on the side of the road where i was doing my "business". My companion quickly jumped on and asked the driver to wait for me. As I looked up in horror, there were about 30 Filipinos stuffed in this thing; some on top, all pointing and laughing at the American squatting in the bushes next to the "busy" highway. I did get on the jeep and got ride home but the "divine intervention" left something to be desired.
I really respect the Maori by the way. I had a companion in Philippines. who first showed me the Haka. Then at Snow college the "polys" as we affectionately called them did it durring a talent show.
The Haka is a Maori tradional dance. for those of you from Lubbock Maori is what the orginal New Zealanders where called. Its a war dance; meant to scare and intimidate the adversary.
I have posted the New Zealand rugby team doing it.. and then somthing that happend at my mothers house. Which do you think is more scary? Who can blame me for wanting to move back home.
A special thanks to a sister in-law (of course) who took the time to post this eye-sore
now maybe you'll belive there really is somthing wrong with me. (metabolicly I mean)..
Dude, read my blog… maaannn
well, I am sorry I have been delinquent in my blogging as of late. To be honest I came into a creative slump; and was waiting. Last week, I was reminded of an old corollary of mine.
Its the Dude/man command buffer. This is a great piece of wisdom sure to make all your communications greasy smooth. As human beings we are saddled with the unbearable duty to communicate. Personally I wish we could telecommunicate. It would be man-bliss to just go around not saying anything and yet knowing all things. I am sure that if we could telecommunicate; our wives would still verbalize their needs just for fun:) (is telecommunication the right word?)
Ok back to the Dude/man command buffer. The next time you have to give a command to a co-equal ie your friend, spouse, co-worker or sibling, simply say dude in front of the command and man at the rear. You will find that you can get anyone to do anything if you do this and they will not esteem thee to be their enemy. example:
example A
1) Turn of the lights!!!
2) Dude; Turn of the lights man.
example B
1) stop touching me !!!
2) Dude, Stop touching me man
example C
1) Get out of this bed and go feed you children some breakfast, get them ready and take them to school.
2) Dude,, get out of this bed and go feed you children some breakfast, get them ready and take them to school. man…
example D
1) Don't smoke in the house
2) dude, don't smoke in the house man.
Now, the caveat is this. Notice in my qualifying statement I said it had to be a co-equal. The command buffer doesn't work on kids or those who fancy themselves to be above you (funny thing about that). I tried the command buffer as a matter of shear second nature on a surgeon last week. Which category do you think he falls into. He is also elderly; so maybe I should ask myself next time "can this person check their own email"? that would be a good litmus test to go along with the command buffer. needless to say, the surgeon did not feel buffered at all.
to breast or to bottle? That is the question.
I am gonna get this breastfeeding post out of the way cuz; I can't sleep at night. Holding my readership in suspense is so cruel. 🙂
Why would I ever to commit to write a post about breastfeeding <to self> I've never breastfed anyone, heaven knows I've tried to breast feed myself. <butt out!! this is still to myself> . umm… I like breasts, I've seen my wife do it. I've dealt with the after math. <self, self, self>.
Ok, What I really want to do is make a mockery of people who try to breast feed but quit cuz " it hurts 😦 )" , Then I would go on to make them feel guilty by highlighting studies that show your kid will be a ding dong if you don't etc. etc. etc. But that line of conjecture has been played. Plus, its bad timing for me personally. So, Breast Feeding in Public.
Who can hate breastfeeding in public? not me. Sometimes, when my sister-in-law, or wife's friend is over, sitting on our couch. she'll say <looking at me> "is it alright if I feed him out here (in the open)"? Assuming this question is directed at me I say "absolutely its ok and I WILL LOOK ". I like to get that out in the open. Rather than continually fight the temptation to look I thinks its better if all the nursing women out there know. If your gonna wip it out in front of me, I WILL LOOK. and that's that. (your an exabitionist and I am a peeping tom get over it )
Did I ever tell you about the time I was a missionary in the Philippines and I was talking to a lady in the park when her 8 year old kid came up, lifted up her shirt and knocked back a few fingers of breast milk while I sat there and taught her about the savior? Or the time my wife and I went on an "overnight-er" to get away from our kids but forgot the breast pump. I spent about an hour milking her to relieve the agony.
This is pretty much all I want to say about the subject except this. if you do it, its not for ninnies. It hurts, your nipples will crack and bleed. you will probably get mastitis but if you give up….. well …..
the bull


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leopard print wedding decorations with 736x552 Resolution
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Rebecca Kiflom
Staff Writer
Larry Williams has been teaching for a total of 36 years. He taught one year at Logan Junior High, and the remaining years he has been at Logan High. The 2016/17 school year will be his last year of teaching as he is retiring at the end of May.
Williams graduated from Logan High and went on to Utah State University, graduating in 1981 with a bachelor's degree in marketing. He later went on to get a teaching certificate and eventually went back and earned a master's degree. A job at Logan Junior High later opened up, and Williams was hired and has worked in the Logan City School District ever since. Williams has taught economics, macroeconomics, personal financial planning, accounting 1050, accounting 1&2, entrepreneurship, and pretty much anything that doesn't use a computer and relates to business.
"I've had the pleasure to work with a lot of great teachers. Students are obviously the main focus of why I'm here."
Williams's favorite part about being a teacher is "the interaction between young people and other teachers who have the best interest of their students at the forefront of what they do." He added, "I've had the pleasure to work with a lot of great teachers. Students are obviously the main focus of why I'm here."
Williams also commented that his least favorite thing about teaching were the things that were out of his control but still have an impact on what he does in the classroom.
Williams shared how he knew that it was time for him to retire. "There were quite a few different things that led to my decision; I've been doing this a long time, and my hearing isn't the best anymore, so I have a hard time hearing students in class, and there are just things coming, changes, that I just don't think I can handle, so all of those were factors in my decision to retire."
Williams said he would miss quite a bit about teaching, including "the daily interactions with students and faculty and the aha moments in students when they understand something that we're talking about in class. There are a lot of positive aspects of teaching that I'll miss. For the most part I've been so fortunate to work with great colleagues and students, and I will just miss those experiences."
After Williams retires he plans on enjoying time with his wife, but also finding a new job. He also looks forward to new adventures and experiences.
Williams has been an amazing teacher and will definitely be missed by students and faculty here at Logan High. If you've had the opportunity to have him as a teacher, you know that he was one who will be remembered long after we leave these hallways.
Williams ended our interview with a few words for the students and faculty of Logan High: "Be positive! Don't be afraid of change, and remember to be inclusive of all students and be respectful to not only each other but of the knowledge and skills that your teachers have."
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Teacher of the Month
Some food for thought: These people have to deal with rotten, smelly teenagers for nearly seven hours, five days a week. Now, that's commitment. That's why here, we've dedicated a space for students to recognize teachers and their dedication. They deserve it.
July 2017


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About Us
Way back in 2005, Bambino Merino was conceived as a result of the search for natural merino baby sleepwear in the UK.
Over the next eleven years, Bambino Merino grew to be one of the UK's favourite baby sleepwear brands, with stockists in Europe, Asia and Australasia and customers worldwide.
A lifestyle change for our founders in 2016, led to relocation to the Southern Hemisphere, where we are now able to offer favourites from the Bambino Merino range directly from our New Zealand warehouse.
We are currently working on reviving our range, bringing back more of your favourite styles and introducing new garments in 2019.


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This week Pastor Ryan's sermon reminded us that God sent his son to establish HIS kingdom. When Christ came he turned the tables on what conventional wisdom said the Kingdom of God was going to look like and how it was going to come about. It is in understanding this that helps us to understand what our role in the Kingdom is all about. Jesus taught us to pray: "Our Father, who is in heaven, Hallowed be Your name. Your Kingdom come, Your will be done, on earth as it is in heaven..." The challenge we face as Christians in the world today is whether or not we are going to build our kingdoms and operate from out agenda or whether we will submit and seek to see His agenda and His Kingdom come in our hearts, workplace, school, homes, families and marriages.
My Next Step Today Is:
- I will read Matthew 5-7 and memorize 6:9-15.
- I will give up my agenda and my kingdom plan and trust my life to the kingdom vision/agenda of Jesus Christ
- I will focus on praying that God's kingdom come in my life, realizing that I am not asking God for something but offering him something.
- I will begin praying for and inviting people to Illuminate. (outreach event)
To Download Sermon MP3, Right Click Image To Left And Select "Save Target/Link As"


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Episode LII - The 10 Greatest Athletes of the 21st Century/
The X Millennial Man is here to end the debate and tell you who are the ten (plus) best athletes of the current century. Ty and RD each have a list of ten great sports people, and they are going to countdown, and debate, to the best athlete of the last 16 years. Come on in for a listen, and discover who is really the best at modern sporting.


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Ryman Composites (then known as NoseCone Manufacturing) Fibreglass Production crew has won the Employers First Award for Team of the year. Following a very busy year where the crew pulled together to produce volume and quality to meet extended demands from several clients this recognition of the qualities that make a great team was well appreciated at Christmas.
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Group 9
Group 9
Narrative comments submitted to DTSC and responsible parties:
Dear Tom, Rick, Mark et al.,
Thank you for the opportunity to comment on this report. Following are my
general and specific comments related to the pond area of the site including
Silvernale and r2 ponds as well as CDFF Coca/Delta Fuel Farm and (SPA)Storable
Propellant Area(s).
Ref:Group 9 RI/RFI report comments by Christina Walsh, cleanuprocketdyne.org,
Please confirm that you will accept these comments (due on Friday 6/3/11) in
light of my extension request dated 5/31/11.
General comments:
Since EPA has already acknowledged that radiological contamination from area IV has historically migrated through storm water runoff to this area, I request
that a technical meeting that includes both EPA and DTSC and the responsible
parties (all of them) participate in a much needed discussion about how this
investigation will properly deal with the drainage from Area IV issue, as
contaminants consistent with area IV are found in these areas, impacting surface water, surrounding soils as well as the groundwater below. These also include radiological constituents which are not dealt with here.
This is one of the most important areas to understand as it has received
contaminant runoff throughout the operational history of the site from both the
test stands and the radiological portion under the Conti order and recently
signed AOCs by DOE and NASA portions of the site and now, all water movement between the ponds for the purpose of "managing" storm water constituents, may also have a lasting affect on this area, that has not been adequately acknowledged by this report.
Please inform us PPG, SSFLCAG, and the communities surrounding the site (all
four sides)], as to what radiological constituents have been sampled for
throughout the period described as 1990 to 2009...2011?
How will the chemical and radiological investigation of these portions of the
site be coordinated? This has been an ongoing problem throughout the RI process.
Special Comment for entire report: Please update this report to reflect the
signed AOC by NASA and what regulating process will govern the Boeing portion and how the two will be handled on an integrated basis when these areas share impacts by all three parties [Boeing, DOE, and NASA]
Regulatory v Scientific process v political objective v needs of the impacted
communities. This is also the area that contains the historically most contaminated groundwater impacts due to the impact of tce runoff from all the major test stands according to the "historical maximum concentration maps for selected chemicals" prepared for Boeing by MWH in June, 2007.
Specifically, the inset for each of the maximum contaminant maps is for this
area as it contains many of the highest constituent concentration levels.
Figure NS-11: Chloroform in near surface groundwater shows levels of more than 10,000 ug/l when 80 ug/l is the screening level.
Figure NS-14: N-nitrosodimethylamine in near surface groundwater shows levels of more than 10 ug/l when .01 ug/l is the screening level.
Figure NS-15: Tetrachlorethene in near surface groundwater shows levels of more than 1000 ug/l when 5 ug/l is the screening level.
Figure NS-16: trans-1,2-Dichloroethene in near surface groundwater shows levels of more than 2500 ug/l when 10 ug/l is the screening level.
Figure NS-18: Vinyl Chloride in near surface groundwater shows levels of more
than 1000 ug/l when 0.5 ug/l is the screening level. Vinyl chloride is part of
the decay chain of TCE, of which half a million gallons was estimated to be
poured into the ground, and is also the most toxic.
Since the Screening level is likely to be less protective than the look-up table
chemical background USL (upper simultaneous limit), it seems that much closer coordination, with a path forward on how to comply with the AOC(s), as well as, the risk assessment process needed for the Boeing portion of the responsibility, given that they both contributed substantively to the existing contamination in these areas. All of these examples and many more, show this area to be the most highly contaminated portion of the site for many chemical constituents, making special attention, using 'process balancing criteria' to manage and coordinate the very different approaches to determining of the nature and extent of the problem, as well as the remedial solution most effective and applicable. We also need to detail and lay out the processes to coordinate those different objectives and methods to get there, and to meet both regulatory paths as well as the protective needs of the impacted surrounding communities [one uses risk assessment, the other does not].
These conflicts in approach and assessment will be detrimental if not adequately addressed. Here, they are not even mentioned.
Specific technical comments:
1-2 please correct the information about surrounding land use to accurately
reflect the BBI property as being owned by the American Jewish University as
that change took place now many years ago.
Please also correct the statement about rocket engine testing, as this area
received runoff contaminants from the rocket engine tests throughout the
lifetime of the site (60 years). This very important context is inadequately
detailed in the report.
184.108.40.206 describing the investigative process refers to chapter 6.8 of the health
and safety code and state superfund law when that particular change in process
is reflective of SB990 which is not being adhered to (and in fact was set aside
by the Boeing lawsuit and Judge Walters decision).
Since this area is shared between NASA and Boeing, as is the responsibility; how will the investigative process now work when NASA has signed the AOC agreeing to one process whereas Boeing quite specifically has not, and is under a different set of rules via the 2007 Riley Order, while simultaneously acting as a federal contractor for NASA who is bound by the 2010 AOC. We have repeatedly asked these questions about process with no adequate response provided by either party.
It is deeply troubling that these ponds that carry some of the most contaminated soils through storm water runoff, will be managed and investigated differently.
How will a cohesive solution be possible under these circumstances?
1-4 refers to the SAIC 94 report which discusses the Pond Dredge where
contaminated soils were mounded in the southern portion of area IV from these
ponds. Why is this process not detailed in this report investigating said
Why is a feasibility study from 1995 still being referenced when it is
considered completely out of date and therefore does NOT represent the current conditions of the site (as evidenced by the 2009 feasibility study and the ongoing work since that acknowledges the very limited view of the site in 1995?
As well as considerable work done in the last two years, which are not mentioned here. A detailed addendum is necessary.
220.127.116.11 why is radiological nature and extent not part of this objective when it
is clearly acknowledged by the regulating agencies (EPA and Dtsc) to be the
receiving water bodies of these contaminants from Area IV?
1-13 Structure. Why is the strike and dip tilt not adequately considered when
looking into potential migration pathways specifically to the north from
Silvernale to the neighboring American Jewish University property below?
Further, the Delta structure to the south was indicated as a fault and now has
been "erased" as a potential migration pathway to the southern buffer zone when in fact the seep contamination at Ws9a quite specifically calls for this
potential, yet appears to be ignored in this report, by which remedy decisions
will be made.
Considering that some of the highest core hole concentrations of VOCs at the
site have been observed in this area, this is extremely disappointing.
1-15 reference to extraction efforts at WS9a are incomplete and
misrepresentative as this process has been intermittent at best, and is not done
during rainfall which contributes to recharge of the groundwater levels that the
pumping is meant to alleviate. How can this be sufficient when it isn't even
attempted during periods when it is most needed?
188.8.131.52 why have no hydraulic pump tests been estimated here, when this
information is crucial to making informed decisions that avoid compounding the existing problem?
"the magnitude and horizontal gradient of groundwater flow varies as the pond
levels rise and fall" how is this being adjusted for, when the RPs are
purposefully moving water between the ponds to avoid discharge that is not
permitted according to the NPDES recent mandates due to the chronic water
quality violations and exceedances associated with this area?
18.104.22.168 Recharge: why are only old studies referenced here? Please update this
section to reflect the work done since 2007. Please consider this comment to
apply to all portions of this report where only old/insufficient data is
currently being detailed when the final remedy will in part, be based on the
assessment from this report.
1.2.4 please correct reference to BBI to reflect the current owner of the
neighboring property American Jewish University.
Surface Water Features - I believe the seeps and springs study still does not
reflect all the known seeps, and considering the ongoing contamination found at the seeps below WS9a, this should become a priority and be properly updated here to reflect that new information.
1-18 Silvernale Reservoir Area - please update this portion of the report to
accurately reflect the actiflow system installed, it's purpose and impact, and
contaminant constituents which are treated by the system, and how/where the
chemicals are stored and disposed of, for use within this system.
1.3 previous interim measures - here it is stated (again) that pump and treat
was ongoing through 2004. I reiterate my concern about this presentation of the facts as we were told repeatedly during the Groundwater U presentations that the pump and treat program was turned off in 2000. I attended many presentations between 2000 and 2004 where pump and treat was presented as a treatment meant to assure the surrounding communities that groundwater would not move from the site due to the resulting "cone of depression" and here we are told again that this occurred through 2004 when in fact It was turned off in 2000. I reiterate my repeated request that this inaccurate information be corrected and explained.
This is of extreme concern and remains deeply troubling and disappointing.
1.5.1 R2 pond sediment contamination - what sampling has occurred based upon the visual evidence brought forth by cleanuprocketdyne.org? (detailed photographs of sediment portion of pond when nearly empty, to be submitted electronically through website link [hi-res] Monday)
1-26 groundwater data selection criteria - why has this section not been updated to reflect all the work done since 2009, given that the comment process for this report is occuring after so much more work has been completed related to core holes in this area and groundwater site conceptual model data? Please update this report to reflect all work through June of 2011.
1-28 it is inappropriate to base exclusion of a COPC based on outdated
information. Please use current sampling data instead of relying on outdated
sampling using outdated methods.
Background comparison methods make no mention of the currently ongoing chemical background study and instead uses data from 1989? I find this extremely troubling and do not understand how this report can sit for so many years and still not be updated to reflect his new and very important information.
188.8.131.52 Potential human receptors -- assessment references SB990 which is not
being adhered to by Boeing at is time. Please explain in a detailed fashion how
this process will be integrated and managed when one party is working under the AOC and Boeing is not? This has direct bearing on how remedial solutions will be developed for this shared area and is very relevant to the cleanup and
investigative process described.
Potentially complete exposure pathways - why were seeps and springs excluded
from this review when Ws9a offers direct evidence to the contrary? This is
disappointing and of special concern. This section also references SB990 input parameters and has not been updated to reflect the bright-line not to exceed approach signed by NASA or how the two will be integrated when Boeing is not part of that agreement.
1-32 EPC calculation approach describes the UCL where the USL will be used for the purpose of the lookup tables, which are not even mentioned. Please update this portion to reflect the statistical approach to be used by NASA and Boeing when they are operating under different processes, safety code sections, and continue to both fail to adequately describe how this issue will be handled. I apologize if this seems redundant to my previous comments but these are such primary issues that are emphasized as to the impact on the result, as each part of this process is presented in the report making clear that real-life technical obstacles will also likely be compounded. It will not handle itself and MUST be discussed on a transparent basis which has been lacking in the process so far.
188.8.131.52 Risk Characterization: please update this section to accurately reflect
the no -risk based approach being used by NASA where the look-up table process as defined in the legally binding and signed AOC is to be used. This process should be laid out in detail, and is wholly absent from reference in this
Thank you for the opportunity to provide comment on this process. I will also
submit an addendum with more details, but because of the many documents, where comments are due at the same time (though actually dated 2009, it is unclear why they are all due now) I felt this preliminary version was appropriate to submit as an interim effort.
Christina Walsh
Sent from my iPad
Of special concern:
This area includes Coca/Delta Fuel Farm, SPA (storable propellant area) and the R2 and Silvernale Ponds.
Responsibility is shared by Boeing and NASA but runoff from DOE portions in Area IV also occurs and therefore responsibility for contamination in these ponds should be shared by all three parties.
Further, radiological constituents have not been adequately sampled for, but since EPA has confirmed this migration pathway from Area IV, this is a needed next step.
Group 9 Figures and Photographs by cleanuprocketdyne.org
Tuesday, June 7, 2011


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