A04_-_SoW.pdf

U.S. FISH AND WILDLIFE SERVICE REGION 7-ALASKA

KODIAK NATIONAL WILDLIFE REFUGE (NWR)

Soil and Groundwater SURVEY FOR TRIPLEX

STATEMENT OF WORK

U.S. FISH AND WILDLIFE SERVICE

LEGACY REGION 7 ALASKA

GENERAL

BACKGROUND:

The Kodiak NWR Triplex is located at 512 Mill Bay Road. This is Section 32 of the Seward Meridian, Township 27 South, Range 19 West as shown on the USGS Kodiak (D-2) Southeast quadrangle, Alaska, 1:25,000 series, topographic map, dated 1987. Lot information - USS 2538A LT 6C EAST REZANOF.

A site reconnaissance visit is encouraged to be conducted in a proven systematic and detailed approach suitable for the subject property's size and/or complexity. Current property and adjoining property conditions will be documented. Identify areas of concern such as odors, stained soil or pavement, stressed vegetation, pools of liquids, drums, unidentified containers, electric or hydraulic equipment, solid waste, wells or septic systems. In addition, any indication of similar conditions from past use of the property or adjoining properties will be recorded. Visual and physical geologic, hydro geologic, hydrologic and topographic characteristics of the property and adjoining properties will be noted for the potential of migration of contaminants. As appropriate, additional site visit information shall include as applicable, a general description of the structures, roads, potable water supply, and sewage disposal system.

Interviews with government workers or other approved persons shall be conducted in person and documented, by email or memo. The contractor shall work closely with the site representative for any questions about the use and physical characteristics of the property. Appropriate local government officials may also be interviewed to obtain the necessary information. The contractor shall keep detailed notes of all interviews. These notes shall become the sole property of the

USFWS.

CONTRACTOR QUALIFICATIONS:

Contractor experience must be approved by the Contracting Officer and will be based upon submission of the following information by the Contractor: Experience: Name and location of a similar project completed by the Contractor, including the name and telephone number of the purchaser of the services. Comply with ADEC regulations and applicable requirements of USEPA, ADEC, OSFM, and OSHA regulation. Contractor shall be a “qualified environmental professional who meets the regulatory requirements described in 18 AAC 75.33. Contractor shall have project experience with work of this nature, and his work crew shall have all necessary training and certifications.

CONFIDENTIALITY STATEMENT:

Contractor shall protect the confidentiality of all work accomplished under this scope of work. Quantity surveys and cost estimates shall remain the sole property of the USFWS and shall not be made available to others for any purpose. Do not publicly disclose any data generated for review under this contract. Attachments provided are sole property of the USFWS. Submittals and data generated under this contract shall become the property of the USFWS and distribution to any other source, unless authorized by the USFWS, is prohibited. Direct any public inquiries to the Contracting Officer (CO), Contracting Officer Technical Representative (COTR) or the Refuge Representative. Do not divulge, explain, or share project information with anyone other than the government representatives above unless it is necessary to obtain permits, or clearances, etc.

WORK DESCRIPTION:

The purpose of this project is to provide all labor, resources, equipment, materials, permits, and services to delineate horizontal and vertical limits of the soil and groundwater contamination and provide a workplan, site characterization and Corrective Action Report based on previous sampling and sampling conducted during this investigation. The work to be accomplished is:

1) Identify if contamination has moved off site to the AT&T property. Review previous sampling of site and develop sampling plan to determine any vertical and horizontal contamination of the site. (Request Access – FWS has made contact with Property Owner – but has to work through legal) If permission to access site is denied sampling will be conducted as close to property line as possible on FWS Property.

2) Evaluate the surface water drainage located along the western property boundary to determine if this area has been adversely impacted by the groundwater contamination present on the subject project.

3) Delineate soil contamination vertical and lateral and identify amount of soil that needs to be removed and provide estimated cost for removal. A minimum of twelve (12) soil boring samples will be taken. Workplan will designate where soil boring samples will be taken and if multiple samples per boring will be analyzed.

4) Install groundwater wells to delineate groundwater contamination (a minimum of three wells will be installed) to the west, south, and east of Monitoring Wells MW-4, MW-5, and MW-6. Provide cost for installation of additional wells and sampling. If additional wells are required because of free product in wells or samples identified concentrations about groundwater standards. Workplan will designate where groundwater wells will be installed.

5) Sample groundwater well MW1 and MW2, if wells cannot be located re-establish wells (Note: Were dry during last investigation) and new groundwater wells.

6) Recover free product from MW3, MW4, MW5, and MW6 during site visit. If the wells run dry, let the wells recharge and measure free product levels again prior to collecting free product again. Note: All wells with free product shall be pumped to recover free product identified. Provide cost estimated to recover free product if new well is identified with free product.

7) Properly dispose of all soil boring soil that is contaminated, groundwater sampling water, and free product collected from wells.

8) Develop a Site Characterization Report incorporating previous reports and current data collected during this contract.

9) Develop a Corrective Action Completion Report (CACR) that discusses the cost and pros/cons of mitigating the site using active remediation, engineered barriers, institutional controls (Land Use Control Plan), or a combination of these methods. The contractor shall provide a final recommendation based on this evaluation.

Please refer to DEC’s Field Sampling Guidance October 2024 for a list of analyte testing, sampling procedures and methods, and preservation of samples required for soil and water samples. This document is available at https://dec.alaska.gov/spar/csp/guidance-forms/. This data is required to evaluate the site for closure in the future.

Use Appendix F of ADEC’s Field Sampling Guidance, the following analysis and methods should be conducted for soil and groundwater: GRO (AK101); DRO (AK102); BTEX (EPA Method 8021B or 8260D); PAHs (EPA Method 8260D, 8270E, 8310); VOCs (EPA Method 8021B, 8260D).

Use Section 12 - Quality Control (QC) Measures of the Field Sampling Guidance Quality Control (QC) Measures to meet the Minimum Quality Assurance (QA) Requirements for Sample Handling, Reports, and Laboratory Data. The QA guidelines described in this memorandum are necessary to meet the requirements of 18 AAC 75.335; 75.360(2); and 18

AAC 78.007.

A Laboratory Data Review Checklist available at https://dec.alaska.gov/spar/csp/lab-approval/documents/ shall be provided for each analytical data package.

Use ADEC’s 2024 Site Closure Memorandum to ensure that future work at the site will move the site forward towards closure and is available at https://dec.alaska.gov/spar/csp/guidance-forms/.

Use ADEC’s Site Characterization Work Plan and Reporting guidance for Investigation of Contaminated Sites dated March 7, 2017. This document is available at https://dec.alaska.gov/spar/csp/guidance-forms/.

SCOPE of WORK:

• Conduct a kick-off/conference call meeting to review the proposed project work statement objectives and the project schedule. Contractor shall provide own meeting minutes and a list of action items, as needed..

• Prepare a Draft and Final Work Plan (WP), which includes as a minimum Site Assessment, Sampling and Analysis, Ecological Risk, Health and Safety. After the Work Plan is approved the Contractor shall provide the services outlined in the plan task by task. Providing a cost task by task is critical for funding accuracy. Work Plan shall include: notes, documents, reports, expert recommendations, and task cost breakdowns. Review of the listed reports is critical to formulating a Work Plan that will achieve the government’s desired result. Previous reports for the USFWS Kodiak NWR Triplex Hazard ID: 27197 site can be viewed on the Alaska Department of Environmental Conservation’s (ADEC) website: http://dec.alaska.gov/Applications/SPAR/PublicMVC/CSP/SiteReport/27197.

• Update Site Characterization Report for site based on historical data and data collected from this site.

• Develop a Corrective Action Completion Report (CACR) that discusses the cost and pros/cons of mitigating the site using active remediation, engineered barriers, institutional controls (Land Use Control Plan), or a combination of these methods. The contractor shall provide a final recommendation based on this evaluation.

Requirements:

• Work Plan:

https://dec.alaska.gov/spar/csp/guidance-forms/ http://dec.alaska.gov/Applications/SPAR/PublicMVC/CSP/SiteReport/27197

The Work Plan shall be prepared, submitted, and approved prior to conducting any work. The Work Plan shall describe the approach to waste stream identification and segregation, sample location selection, workplan deviations, Conceptual Site Model, field screening method, collection of samples, field documentation, field quality control measures, tracking of samples, Investigation-Derived Waste (IDW), Quality Assurance Project Plan (QAPP), safety and health precautions, repair of damage caused by sample collection (where necessary), the experience and qualifications of the personnel conducting the survey, and identity of the ADEC certified laboratories that will be used. The Work Plan will be delineated by Task such that each task can be priced separately and clearly defined.

• Quality Assurance/Quality Control:

The Contractor shall perform QC/calibration checks on all instruments (i.e. PID) in accordance with the instrument manufacturer’s PCS. At a minimum, calibration checks for each instrument shall be completed in accordance with the operator manual and the manufacturer’s PCS and documented if the final report. The calibration checks performed according to this paragraph that fall within the specification for the instrument shall demonstrate reading validity.

The Contractor shall follow Section 12 - Quality Control (QC) Measures of the Field Sampling Guidance Quality Control (QC) Measures to meet the Minimum Quality Assurance (QA) Requirements for Sample Handling, Reports, and Laboratory Data for all samples collected on-site.

The Contractor shall use a laboratory approved by ADEC for analyzing all samples.

• Contaminated Soils and Groundwater Survey and Sampling:

Contractor shall provide the services of a qualified environmental professional to perform a soils investigation to complete sampling at the site. Major elements of the effort shall consist of the following:

• Review all previous site reports and information and sample according to ADEC protocols. Also develop a hypothesis about where contaminants might migrate to if they have spread out of the immediate government owned area. This hypothesis will be part of the Contractors proposal. The government assumes twelve soil bore samples as a minimum. The location and depth will be recommended by the contractor, as long as this is consistent with ADEC protocols and also gives the government the best most accurate information about soil contamination amounts and contamination migration. Any other soil samples necessary will be pre-priced by the Contractor on a per sample basis. The pre-price will be part of the proposal.

• The Contractor shall conduct as many (a minimum of three (3)) groundwater samples as approved as necessary as long as this is consistent with ADEC protocols and also gives the government the best most accurate information about groundwater conditions. Additional samples necessary will be pre-priced by the Contractor on a per sample basis. The pre-price will be part of the proposal.

• Samples shall be submitted to an ADEC approved laboratory for analysis of Diesel Range Organics (DRO) by Alaska Method AK102, Gasoline Range Organics (GRO) and Benzene, Toluene, Ethylbenzene, and Xylene (BTEX), by Alaska Method AK101. Environmental samples shall be delivered to the laboratory using chain-of-custody procedures.

• Field headspace screening shall be performed on all soil samples taken from soil borings. Samples shall be screened using a Photo Ionization Detector (PID). Readings shall be logged.

• Mobilize at the site following receipt of an approved Work Plan. The contractor will secure all tools and materials before leaving the work area.

• Prepare the site (locates, interviews, meetings, etc.). Implement spill control and erosion control measures as needed.

• Provide analysis of the suspected extent and distribution (horizontal and vertical) of petroleum contamination in soil

• Conduct groundwater investigation to determine where groundwater at the site has been impacted and if it is feasible to recover free product and/or treat the groundwater.

• Perform all operations in a manner which will minimize dust, noise, and other nuisance. Maintain haul routes for disposal of material, clean and free of debris.

• Protect existing facilities from damage by falling debris, dust, and construction operations.

• Perform operations in a manner that in no way endangers personnel, public, existing structures, utilities, road

• Contractor shall be responsible for damage to personnel, public, roadways, streets, structures, utilities, facilities, and equipment caused by operations and shall repair any damage at its own expense or replace items damaged beyond repair.

• Materials to be removed will be permitted to accumulate on site. All materials shall be stored in a secured location at the end of the workday and in a manner to prevent contamination of the site.

• Do not operate vehicles or equipment on existing construction or roadways which could be damaged.

• Contractor shall relocate, as necessary, existing active miscellaneous piping, conduit, and electrical circuits and devices (if needed). Contractor is responsible for repairing any damaged assets or utilities.

• The Contractor shall maintain field notes, daily logs, and photographs to document all field activities to include: site maps, excavation size, visibly contaminated soil, samples locations, depth to groundwater, and other important observations and events. Submit Field Notes to the Contracting Officer. All field notes shall become the property of the Government.

• Provide the Contracting Officer with recommendations on further actions if necessary.

• The Site Characterization Report shall follow ADEC CSP Site Characterization Work Plan and Reporting

Guidance for Investigation of Contaminated Sites provide (As a minimum):

1) A description of the work effort with analytical results that describes the significance of detected concentrations relative to appropriate regulations.

a. Note any discrepancies between the project work plan and the actual project activities performed.

b. Note any discrepancies between the Sample Location Selection detailed in the Work Plan and any changes made during sampling, along with explanation of differences.

2) Results of the current round of sampling shall be provided in a spreadsheet with previous data collected 2017 and 2020 report and displayed on a map showing results and location of sample.

a. Date(s) of the survey and sample collection

b. Identification of field-portable methods used during the survey and applicable calibration check results.

c. Laboratory report and chain-of-custody forms

1) The Contractor shall require the laboratory to provide the information necessary for the Contractor to comply with the data evaluation/validation procedures outlined in this SOW. This shall include a data package containing the following information:

2) Cover page information including methods, dates, instruments, digestions, and signature of the laboratory director.

3) Sample information including identification and the results for samples, blanks, QC samples, dilution factors, and batch identification.

d. Comparison of the sample results to the cleanup levels for petroleum established by the Alaska Department of Environmental Conservation (ADEC).

3) In the conclusions and recommendations section, make a determination, using specific documentation and appropriate references, of whether chemical contamination is in the soil or groundwater, and if found, if the contamination may have been caused by the tank and/or piping.

4) The summary of all findings and recommendations shall be included in the Site Characterization Report and shall meet the requirements of the ADEC. The report shall be signed by a registered or licensed professional individual (s) in the employ of the Contractor as required by the State.

5) Respond to all comments received for U.S. Fish and Wildlife Service and ADEC.

• Develop a Corrective Action Completion Report and Submit to ADEC that addresses:

1. For the purposes of the CACR, the specific pathways in which exceedances are present must be addressed. The pathways in question are:

a. Soil ingestion and inhalation pathways,

b. Soil component to the groundwater ingestion exposure pathway.

c. Groundwater ingestion pathway

d. Groundwater to Surface water exposure pathway.

e. Indoor inhalation pathway (Vapor Intrusion) (if a building is built in this location in the future),

f. Construction worker inhalation pathway.

2. The CACR shall develop a Corrective Action Plan that discusses the cost and pros/cons of mitigating the site using active remediation, engineered barriers, institutional controls (Land Use Control Plan), or a combination of these methods. The contractor shall provide a final recommendation based on this evaluation.

3. If Institutional Controls (Land Use Control Plan) is selected, work with U.S. Fish and Wildlife to develop and submit Land Use Control Plan to ADEC that will be recorded in the Kodiak NWR Comprehensive Conservation Plan (CCP) as a possibility.

https://dec.alaska.gov/media/12119/site-characterization-work-plan-reporting-guidance-2017.pdf https://dec.alaska.gov/media/12119/site-characterization-work-plan-reporting-guidance-2017.pdf

4. Respond to all comments received from U.S. Fish and Wildlife and ADEC.

5. The report shall be signed by a registered or licensed professional individual (s) in the employ of the Contractor as required by the State.

DELIVERABLES:

● Pre-Work Meeting: Organize a pre-work meeting within 2 weeks of receiving the notice to proceed (NTP). Within 10 workdays of pre-work meeting, contractor shall submit a Draft Work Plan for approval. The Service requires 45 workdays to review and comment on the Draft Work Plan. After Draft Work Plan is approved, provide a copy of Final Work Plan within 10 workdays. With Final Work Plan ready, proceed to work site to complete all sampling activities. The Work Plan shall follow the ADEC 20217 Site Characterization Work Plan and Reporting guidance.

● Work Plans shall include a General Description Section followed by a Task Section:

● Each task shall be broken down into sub-tasks. Sub-task shall include pictures and figures describing items and locations for sampling and remediation. The Task Section of the work plan shall be followed by a Regulation Section with all applicable federal, state and/or local regulations that regulate the handling, transporting, and disposing of all contaminated material from the site. The Regulation Section shall also identify the closest disposal locations for each waste streams.

● A Dailey Field Report

● Complete the ADEC Contaminated Media Transport and Treatment or Disposal Approval Form. The form shall be submitted, prior to transport, to ADEC for approval in accordance with 18 AAC 75.325(i) and 18

AAC 75.360.

● Prepare and submit copies of DRAFT Site Characterization Report and a Corrective Action Remediation Report within 90 days of receipt of regulatory sample analyses. Provide copies of report to COR or his/her designee, Station, and ADEC.

● The government and ADEC shall have 45 days to comment on the Draft Reports. The Contractor shall then have 45 days to produce a Final Report. Provide copies of report to COR or his/her designee, Station, and

ADEC.

● The final deliverable shall be the Site Characterization Report and a Corrective Action Remediation Report in editable electronic Microsoft Word. The report shall include information needed to verify work completed conclusions, and recommendations. The final report shall include photographs and field notes.

SITE VISITS, CONDITIONS, AND INSPECTIONS

Contractor should become familiar with the site to examine conditions under which this work is to be performed.

Coordinate all site visits and work activities in advance with the Refuge On-Site Representative (OSR) and Contracting Officer Representative (COR), providing a minimum of five (5) business days of advance notice.

NOTIFICATIONS:

Contact the COTR, COR or his/her designee and Refuge Representative before departing to the site. Review concerns about time lines, transportation, equipment, personnel, permits, licensing, and contingencies. Keep the CO and COTR informed of progress. Daily reports, photographs, notes, and all documentation shall become the sole property of the government.

ON-SITE WASTE MANAGEMENT

All waste generated from this contract shall be disposed of off-site according to local, state, and federal requirements. An ADEC Soil Transport Approval Form is required before removing any contaminated media from the site.

ANALYSIS AND INVENTORY:

Provide documents that delineate a clear concise paper trail of how, when, and where contaminants were disposed of. This Statement of Work is not all-inclusive and shall not relieve the contractor of responsibilities as outlined in federal, state, and local regulations.

PROJECT SCHEDULE and REPORTING:

Within ten (10) work days after Notice to Proceed (NTP) shall provide a project work schedule. Verify and clarify travel, permits, payment schedules, report format, schedule of values, work plan actions, availability of equipment, etc.

Coordinate existing and new data to evaluate and recommend proper course of action. Daily reports, photographs, notes, and documentation shall become the sole property of the government. The project shall be completed by September 30, 2026.

Contractor shall notify the Government no less than ten (10) days prior to commencement of any work activities.

AVAILABILITY: Normal duty hours, Monday thru Friday 7:30 a.m.-4:00 p.m. Non-duty hours include weeknights, weekends, and federal holidays. Contractor shall request approval for any work outside normal duty hours.

ATTACHMENTS:

Use attachments as guides only. The government makes no claims as to the accuracy or usability of attachments.

PERMITS:

The Contractor shall be responsible for obtaining the necessary permits including preparing paperwork for permanent closure on behalf of the Government. Collect all data, maps, chemical analyses, etc., necessary to prepare complete and accurate report that meets the requirements of the ADEC.

Comply with inspection requirements of the State and local agencies. Inspect and ensure that no electrical, gas, water, structures, or other conditions are in the area that may affect work. Contact the local fire marshal and the public utilities office before beginning the work.

UNDERGROUND OBSTRUCTIONS:

There are no known underground piping, foundations, and other underground obstructions in the vicinity of excavation.

The Contractor shall contact the local public utility to ensure they can work safely. The Contractor shall still take care when performing drilling and excavation to ensure they are using all possible means to avoid unknown obstructions or utilities.

Protect underground facilities encountered during excavation until it is determined whether they are active or inactive.

Repair, without compensation, existing active facilities that should have been identified by Contractor inspection.

Notify the government immediately of any unexpected subsurface conditions and discontinue work until notified to resume.

FILL MATERIALS: (N/A for this Project) Fine aggregate: State standard FA-1.

REMOVAL PROCEDURES:

• Excavated soil shall be stockpiled, stored and sampled according to 18 AAC 75.370 and the methods in the Alaska

Department of Environmental Conservation’s Field Sampling Guidance. Contaminated soil disposal shall be in accordance with 18 AAC 75.325(i) and 18 AAC 75.360. A Contaminated Media Transport and Treatment or Disposal Approval Form shall be submitted prior to transport to ADEC for approval.

Any excavated material shall be placed in a separate stockpile pending disposal. The stockpile shall be located on an impermeable surface and shall be kept covered with plastic sheeting. Salvageable materials shall become property of Contractor and shall be removed from site as work progresses.

DISPOSAL OF MATERIALS:

An ADEC “Contaminated Media Transport and Treatment or Disposal Approval Form"is required before removing any contaminated media from the site. Contractor shall be responsible for proper disposal of all project derived waste material.

This includes, but is not limited to, recovered free product, excess excavated material, non-salvageable equipment and materials. Waste material shall be transported and disposed of using transporters and disposal facilities, which possess all required federal, state, or local licenses or permits. Submit manifests certifying destination, receipt, and disposal of demolition materials. Burning of waste lumber and other materials or trash on site shall not be permitted.

CLEANUP:

Maintain public streets, alleys, or other thoroughfares used in carrying out disposal free of litter or soil attributable to this operation. Equip and load trucks or other vehicles to prevent leakage, blowing off, or other escape of any portion of whatsoever is being hauled. Cost incurred by the Government in cleaning up such litter will be charged to Contractor and deducted from monies due or to become due it under this contract. Upon completion of work, thoroughly clean area of materials not to remain. Cleanup activities shall be in accordance with Federal, State, and Local regulations.

KEY PERSONNEL

The project team includes a Contracting Officer, Contracting Officer Representative, Program Manager, Project Manager/Lead Environmental Manager whom the Site Project Manager and Contractors reports to. The following is an overview of personnel directly responsible for supporting the efforts of this contract.

Contracting Officer Representative: Robert McGinn, Regional Environmental Compliance Coordinator Address: 5600 American Blvd W, Suite 990, Bloomington, MN 56001 Contact info, phone and email: (612) 518-1237, Robert_McGinn@fws.gov

Program Manager: Danielle, Fujii-Doe, Deputy Refuge Manager Address: 1390 Buskin River Road, Kodiak, Alaska 99615 Contact info, phone and email: (907) 308-6346, danielle_fujii-doe@fws.gov

PROPERTY CLEARANCE & ACCESS:

The contractor shall obtain clearances and access to the properties from the government and any other appropriate authorities. The contractor shall also arrange for and coordinate all locates with the local utility companies prior to subsurface investigations. The 2017 Report alludes that some contamination has possibly migrated off of federal property. The Contractor shall work closely and get approval from the Program Manager to coordinate/initiate any contact with the adjacent property owner.

GOVERNMENT-FURNISHED EQUIPMENT AND GOVERNMENT-FURNISHED INFORMATION:

There is no government furnished equipment with this project.

Attachments:

1. 2006 Kodiak NWR Triplex CAP Summary Report

2. 2017 Kodiak NWR – Former USFW Triplex SCR Report

3. 2020 Kodiak NWR – Soil and Groundwater Assessment and Remediation Report

Current Site Conditions – Photos taken 2025 by Livia Bracker, ADEC

PHOTO 1: Shared driveway between the USFWS and Alascom property.

PHOTO 2: Shallow water from rain on north edge of the USFWS property.

PHOTO 3: Site photo facing north.

PHOTO 4: Site photo facing south/southwest.

PHOTO 5: Shed #1

PHOTO 6: Shed #2 and #3.

PHOTO 7: Equipment parked on site property.

PHOTO 8: Wood pile #1 on south side of property (near former Test Pit 1).

PHOTO 9: MW-1?

PHOTO 10: MW-1 with Alascom building as reference.

PHOTO 11: MW-1 with Shed #2 as reference.

PHOTO 12: MW-2?

PHOTO 13: MW-2 with Shed #2 as reference.

PHOTO 14: MW-3

PHOTO 15: MW-3 with Alascom building as reference.

PHOTO 16: MW-3 with wood pile #1 as reference.

PHOTO 18: MW-4

PHOTO 19: MW-4 with wood pile #1 and shed #1 as reference.

PHOTO 20: MW-6

PHOTO 21: MW-6 with Shed #1 for reference.

PHOTO 22: MW-6

PHOTO 23: MW-5 suspected to be below wood pile #2 near Shed #2.

PHOTO 24: MW-5 suspected to be below wood pile #2 near Shed #2.

PHOTO 25: Unknown plastic pipe on back end of hill on south edge of property.

PHOTO 26: Plastic pipe seen in Photo #25 hidden in grass/bush. Shed #2 as reference.

PHOTO 27: Unknown shallow hole on NE edge of property (potentially off property).

PHOTO 28: NE edge with Shop #1 as reference.

PHOTO 29: Site photo facing east.