WQ0006992_Final Permit_19930217

State of North Carolina
Department of Environment, Health and Natural Resources
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27604
James B. Hunt, Jr., Governor
February 17, 1993
Mr. William C. Howard, Jr., P.E.,
Manager, Water Quality Program
R. J. Reynolds Tobacco Company
Post Office Box 2959
Winston-Salem, North Carolina 27102
Jonathan B. Howes, Secretary
Subject: Permit No. WQ0006992
R. J. Reynolds Tobacco Company
R. J. Reynolds Building 604 Site
Groundwater Remediation Upgrade
Forsyth County
Dear Mr. Howard:
In accordance with your application received September 10, 1992, we are forwarding herewith
Permit No. WQ0006992 dated February 17, 1993, to R. J. Reynolds Tobacco Company for the
construction and operation of the subject infiltration gallery and operation of the subject new, partially
complete groundwater remediation facilities, which have replaced the old and inadequate remediation
system permitted by Permit No. WQ0000682. The purpose of this permit is to authorize the new, partially
complete remediation facilities. It is understood that the previously permited facilities are not in use and are
abandoned, and thus Permit No-WQ0000682, issued November 1, 1988, is hereby voided upon issuance
of this permit. Recovery wells and monitor wells as required by Permit No. WQ0000682 are being
included in this permit.
This permit shall be effective from the date of issuance until January 31, 1998, and shall be subject
to the conditions and limitations as specked therein. Please pay particular attention to the monitoring
requirements in this permit. Failure to establish an adequate system for collecting and maintaining the
required operational information will result in future compliance problems.
If any parts, requirements, or limitations contained in this permit are unacceptable to you, you have
the right to request an adjudicatory hearing upon written request within 30 days following receipt of this
permit. This request must be in the form of a written petition, conforming to Chapter 150B of North
Carolina General Statutes, and filed with the Office of Administrative Hearings, P.O. Drawer 27447,
Raleigh, NC 27611-7447. Unless such demands are made this permit shall be final and binding.
Regional Offices
Asheville Fayetteville Mooresville Raleigh Washington Wilmington Winston-Salem
704/251-6208 919/486-1541 704/663-1699 919/5714700 919/946-6481 919/395-3900 919/761-2351
Pollution Prevention Pays
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

One set of approved plans and specifications is being forwarded to you. If you need additional
information concerning this matter, please contact Mr. John Seymour at 919/ 733-5083.
ys
A. Preston Ho d, fir., P.E.
Acting Director
cc: Forsyth County Health Department
Winston-Salem Regional Office, Water Quality Section
Winston-Salem Regional Office, Groundwater Section
Jack Floyd, Groundwater Section
Aquaterra Environmental Consultants
Facilities Assessment Unit, Karen Colby
Training and Certification

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
RALEIGH
INFILTRATION GALLERY PERMIT
In accordance with the provisions of Article 21 of Chapter 143, General Statutes of North Carolina as
amended, and other applicable Laws, Rules, and Regulations
PERMISSION IS HEREBY GRANTED TO
R. J. Reynolds Tobacco Company
Forsyth County
FOR THE
operation of an existing 23,040 GPD groundwater remediation system consisting of four extraction wells
with submersible pumps capable of 4 GPM each, dual bucket type strainer filters, a groundwater storage
tank, a 16 GPM transfer pump, a 16 GPM water heating unit capable of 550 F to 1400 F, three (3) 20 foot
tall by 20 inch diameter air stripping towers in series with a 16 gpm transfer pump to supply towers 2 and
3 and each having 16.5 feet of packing and a 270 scfm (minimum) blower, a 16 gpm transfer pump, dual
500 pound carbon canisters piped in series, a thermal oxidizer unit to control air quality emissions when
needed, and all associated piping, valves, controls, alarms, protective structures, and appurtenances; the
construction and operation of a 100 foot by 15 foot by 7.5 feet deep infiltration gallery with dual 4 inch
distribution laterals and two subgrade piezometers, and all associated piping, valves, controls, alarms,
protective structures, and appurtenances to serve R. J. Reynolds Building 604 Site with no discharge to
the surface waters, pursuant to the application received September 10, 1992, and in conformity with the
project plan, specifications, and other supporting data subsequently filed and approved by the Department
of Environment, Health and Natural Resources and considered a part of this permit.
This permit shall be effective from the date of issuance until January 31, 1998, and shall be subject
to the following specified conditions and limitations:
I. PERFORMANCE STANDARDS
Upon completion of construction and prior to operation of this permitted facility, a
certification must be received from a professional engineer certifying that the permitted
facility has been installed in accordance with this permit and the approved plans and
specifications. Mail the Certification to the Permits and Engineering Unit, P.O. Box
29535, Raleigh, NC 27626-0535.
2. The Winston-Salem Regional Office, telephone number 919/ 896-7007, shall be notified at
least forty-eight (48) hours in advance of operation of the installed facilities so that an in -
place inspection can be made. Such notification to the regional supervisor shall be made
during the normal office hours from 8:00 a.m. until 5.00 p.m. on Monday through Friday,
excluding State Holidays.
3. This permit shall become voidable if the soils fail to adequately absorb the wastes and may
be rescinded unless the facilities are installed, maintained, and operated in a manner which
will protect the assigned water quality standards of the surface waters and ground waters.

4. In the event that the facilities fail to perform satisfactorily, including the creation of
nuisance conditions, the Permittee shall take immediate corrective action, including those as
may be required by this Division, such as the construction of additional or replacement
treatment or disposal facilities.
5. The issuance of this permit shall not relieve the Permittee of the responsibility for damages
to surface or groundwaters resulting from the operation of this facility.
6. Any sludge generated from these treatment facilities must be disposed of in accordance with
General Statute 143-215.1 and in a manner approved by the North Carolina Division of
Environmental Management.
7. Diversion or bypassing of the untreated groundwater from the treatment facilities is
prohibited.
II. DPERATION AND MAINTENANCE REQ—UIREMENTS
1. The facilities shall be properly maintained and operated at all times.
2. Upon classification of the facility by the Certification Commission, the Permittee shall
employ a certified wastewater treatment plant operator to be in responsible charge (ORC) of
the wastewater treatment facilities. The operator must hold a certificate of the type and
grade at least equivalent to or greater than the classification assigned to the wastewater
treatment facilities by the Certification Commission. The Permittee must also employ a
certified back-up operator of the appropriate type and grade to comply with the conditions
of Title 15A, Chapter 8A, .0202. The ORC of the facility must visit each Class I facility at
least weekly and each Class II,11I, and IV facility at least daily, excluding weekends and
holidays, and must properly manage and document daily operation and maintenance of the
facility and must comply with all other conditions of Title 15A, Chapter 8A, .0202. Once
the facility is classified, the Permittee must submit a letter to the Certification Commission
which designates the operator in responsible charge.
3. The facilities shall be effectively maintained and operated as a non -discharge system to
prevent the discharge of any wastewater resulting from the operation of this facility.
III. M NTT RING AND REPORTING REQUIREMENTS
1. Any monitoring deemed necessary by the Division of Environmental Management to insure
surface and ground water protection will be established and an acceptable sampling
reporting schedule shall be followed.
2. Noncompliance Notification:
The Permittee shall report by telephone to the Winston-Salem Regional Office, telephone
number 919/ 896-7007, as soon as possible, but in no case more than 24 hours or on the
next working day following the occurrence or first knowledge of the occurrence of any of
the following:
a. Any occurrence at the wastewater treatment facility which results in the treatment of
significant amounts of wastes which are abnormal in quantity or characteristic, such
as the dumping of the contents of a basin or tank; the known passage of a slug of
hazardous substance through the facility; or any other unusual circumstances.
7

IV.
b. Any process unit failure, due to known or unknown reasons, that renders the
facility incapable of adequate wastewater treatment such as mechanical or electrical
failures of pumps, aerators, compressors, etc.
C. Any failure of a pumping station, sewer line, or treatment facility resulting in a by-
pass directly to receiving waters without treatment of all or any portion of the
influent to such station or facility.
d. Any time that self -monitoring information indicates that the facility is not in
compliance with its permit limitations.
Persons reporting such occurrences by telephone shall also file a written report in letter
form within 15 days following first knowledge of the occurrence. This report must outline
the actions taken or proposed to be taken to ensure that the problem does not recur.
GIZQUNDHATER REQjLIRFMF_NTS
1. Groundwater monitoring wells MW-5, MW-6, MW-S, MW-9, MW-10, MW-14, and
MW-16 shall be sampled every January, April, July, and October for the following
parameters:
Water levels pH
Acetone Iso PropanoI
Normal Propanol MEK
Isopropyl Acetate Normal Propyl Acetate
Toluene Heptane
The measurement of water level must be made prior to sampling for the remaining
parameters.
The results of the sampling and analysis shall be sent to the N.C. Division of
Environmental Management on Form GW-59 (Compliance Monitoring Report Form) every
February, May, August, and November.
2. The influent and effluent from the treatment system shall be sampled monthly for the
parameters specified below:
pH
Acetone Iso Propanol
Normal Propanol MEK
Isopropyl Acetate Normal Propyl Acetate
Toluene Heptane
The results of the sampling and analysis shall be sent to the Groundwater Section in the
Winston-Salem Regional Office, within 30 days of sample collection.
3. The Compliance Boundary for the disposal system is specified by regulations in 15 NCAC
2L, Groundwater CIassifications and Standards. An exceedance of Groundwater Quality
Standards beyond the Compliance Boundary is subject to penalty provisions applicable
under General Statute 143-215.6(1)a. The sale of property, by the Permittee, which is
within or contiguous to the disposal system site may alter location of the Compliance
Boundary.
For facilities permitted on or after December 30, 1983, the Compliance Boundary is
established at the lesser of 250 feet from the infiltration gallery or 50 feet within the
property boundary.
3

If the title to any property which may affect the location of the Compliance Boundary is
changed, the Permittee shall notify the DEM Director within 14 days. The Director shall
then establish a modified Compliance Boundary which will be done as a modification to the
Permit.
The REVIEW BOTJJNDARY for the disposal system is specified by regulations in 15
NCAC 2L, Groundwater Classifications and Standards. A REVIEW BOUNDARY is
established around disposal systems midway between the Compliance Boundary and the
perimeter of the waste disposal area. When the concentration of any substance equals or
exceeds the maximum allowable concentration of that substance at the REVIEW
BOUNDARY, as determined by monitoring, the permittee shall tither (i) demonstrate,
through predictive calculations or modeling, that natural site conditions, facility design and
operational controls will prevent a violation of standards at the Compliance Boundary; or,
(ii) submit a plan for the alteration of existing site conditions, facility design or operational
controls that will prevent a violation of standards at the Compliance Boundary, and
implement that plan upon its approval by the Director.
4. All components of the groundwater recovery, treatment and disposal system shall be
properly weather -proofed to prevent freezing and failure of the system.
5. The groundwater recovery treatment and disposal system shall be inspected weekly. If it is
determined that the system is malfunctioning, all repairs should be made as soon as
possible and reported to the Winston-Salem Regional Office.
6. Any additional groundwater quality monitoring as deemed necessary by the Division of
Environmental Management shall be provided.
V . INSPECTIONS
1. Adequate inspection, maintenance and cleaning shall be provided by the Permittee to insure
proper operation of the subject facilities.
2. The Permittee or his designee shall inspect the groundwater recovery and treatment
facilities to prevent malfunctions and deterioration, operator errors and discharges which
may cause or lead to the release of wastes to the environment, a threat to human health, or a
nuisance. The Permittee shall keep an inspection log or summary including at least the date
and time of inspection, observations made, and any maintenance, repairs, or corrective
actions taken by the Permittee. This log of inspections shall be maintained by the Permittee
for a period of three years from the date of the inspection and shall be made available upon
request to the Division of Environmental Management or other permitting authority.
3. Any duly authorized officer, employee, or representative of the Division of Environmental
Management may, upon presentation of credentials, enter and inspect any property,
premises or place on or related to the disposal site and facility at any reasonable time for the
purpose of determining compliance with this permit; may inspect or copy any records that
must be kept under the terms and conditions of this permit; or may obtain samples of
groundwater, surface water, or leachate.
VI. GENERAL_ CONDITIONS
l . This permit shall become voidable unless the facilities are constructed in accordance with
the conditions of this permit, the approved plans, specifications and other supporting data.
4

2. This permit is effective only with respect to the nature and volume of wastes described in
the application and other supporting data.
This permit is not transferable. In the event there is a desire for the facilities to change
ownership, or there is a name change of the Permittee, a formal permit request must be
submitted to the Division of Environmental Management accompanied by an application
fee, documentation from the parties involved, and other supporting materials as may be
appropriate. The approval of this request will be considered on its merits and may or may
not be approved.
4. A set of approved plans and specifications for the subject project must be retained by the
Permittee for the life of this project.
5. Failure to abide by the conditions and limitations contained in this permit may subject the
Permittee to an enforcement action by the. Division of Environmental Management in
accordance with North Carolina General Statute 143-215.6A to 143-215.6C.
6. The annual administering and compliance fee must be paid by the Perrittee within thirty
(30) days after being billed by the Division. Failure to pay the fee accordingly may cause
the Division to initiate action to revoke this permit as specified by 15 NCAC 2H .0205
(c)(4).
7. The issuance of this permit does not preclude the Pennittee from complying with any and
all statutes, rules, regulations, or ordinances which may be imposed by other government
agencies (local, state, and federal) which have jurisdiction.
8. The Permittee, at least six (6) months prior to the expiration of this permit, shall request its
extension. Upon receipt of the request, the Commission will review the adequacy of the
facilities described therein, and if warranted, will extend the permit for such period of time
and under such conditions and limitations as it may deem appropriate.
9. Issuance of this permit hereby voids Permit No. WQ0000682 issued November 1, 1988.
Permit issued this the 17th day of February, 1993
NORM CAROLINA
Tr.,/P.E.,
Division of Environ
By Authority of the
Permit No. WQ0006992
MANAGEMENT COMMISSION
Director
Management Commission
5

Permit No. WQ0006992
February 17, 1993
Engineer's Certification
I, , as a duly registered Professional Engineer in the State of North
Carolina, having been authorized to observe (periodically, weekly, full time) the construction of the
project, , for the
Project Name Location
Permittee hereby state that, to the best of my abilities, due care and diligence was used in the observation
of the construction such that the construction was observed to be built within substantial compliance and
intent of the approved plans and specifications.
Signature
Date
Registration No

L.J Umi Loa 6
GREENSBORO 32 MI,
SCALE_ 1:24 000
t 2
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Author Drawing U
r.
AQUATERRA, INC. DLG
RALEIGH. GREENSBORO, CHARLO'I'1'E Job No. Revision F1
N0 R T H CARC LINE
G747
C. !
566 PHOTOREVISED 1987 I
DMA 4956 111 NE -SERIES V942
yers Date Title
10_29_91 Site Location Map
;ure Scale Project R.J. Reynolds
1 Winston Salem, North Carolina

RATING SCALE FOR CLASSIFICATION OF FACILITIES
rTEM
(1)
(2)
(3)
Name of Plant: ,J �e .�o�as — %�d��. Coo C�. W, leel-6;.97-404 5-(7-E
Owner or Contact Person:_C. I-/Ocy a ,_
Mailing Address: ._-Z ✓. le. 7QQAcc o C-,.
IJ (,0S Td 1)- 5 [ A) C Z T a Z ----
County: ��s �r.�! ,. Telephone: (�g1,
NPDES Permit No. NC00 Nondisc. Per. No._GJQceoc,g9.e
issueDate: Expiration Date. -
Existing Facility New Facility lVePoi Fi E,a F" el-1-1 ry
Rated By: I—f-,ff 67. 5,0�r^j c Date: /o - 7-�?2-
Reviewed (Train. & Cert.) Reg. Office - � I t I - -�-; -�f
Reviewed (Train. & Cert.) Central Office
ORO. Ve o-,y e 4 1/e pa Grade C L.4s5
Plant Class: (circle one)
POINTS
Industrial Pretreatment Units andlor
Industrial Pretreatment Program
(see definition No. 33)
4
DESIGN FLOW OF PLANT IN GPD
(not applicable to non -contaminated cooling waters, sludge
handling facilities for water purification plants, totally
closed cycle systems (def. No. 11), and facilities
consisting only of Item (4) (d) or Items (4) (d) and (11)
(d))
0 20,000..........................
1
20,001 50.000..........................
Q
50,001 -- 100,000..........................
3
100,001 250,000..........................
4
250,001 -- 500,000..........................
5
500,001--1,000,000..........................
8
1,000,001 -- 2,000.000 ........................
10
2,000.001 (and up) - rate 1 point additional for each
200,000 gpd capacity up to a
maximum of 30
Design Flow (gpd) :
PRELIMINARY UNITS (see definition no. 32)
(a) Bar Screens ................................
1
or
(b) Mechanical Screens, Static Screens or
Comminuting Devices ........... .............
2
(c} Grit Removal ...............................
1
or
(d) Mechanical or Aerated Grit Removal ...........
2
(e) Flow Measuring Device .................. . ....
1
or
(f} Instrumented Flow Measurement ..............
2
(g) Preaeralion................................
2
(h) Influent Row-Equatizalion ...................
2
(i) Grease or Oil Separators - Gravity ..........
2
Mechanical ..........
3
Dissolved Air Flotation. 8
(I') Prechlorination .............................. 5
PRIMARY TREATMENT UNITS
(a) Septic Tank (see definition no. 43) ..............
(b) Imhoff Tank ..................................
(c) Primary Clarifiers ............... ......... .
(d) Settling Ponds or Settling Tanks for Inorganic
Non -toxic Materials {sludge handling facilities
for water purification plants, sand, gravel,
stone, and other mining operations except
recreational activities such as gem or gold
mining) ......................................
2
5
5
2
() III IV Total Points.+
(5) SECONDARY TREATMENT UNITS
(a) Carbonaceous Stage
(i)Aeration - High Purity Oxygen System .....
20
Diffused Air System ...........
10
Mechanical Air System (fixed,
floating or rotor),,,,,,,,,,,,,,
Separate Sludge Reaeration .....
3
00 Trickling Filter
High Rate ...................
7
Standard Rate ...............
S
Packed Tower.........
(iii) Biological Aerated Filler or Aerated
Biological Filter ....................
(iv) Aerated Lagoons
10
..................... .
10
(v) Rotating Biological Contaclors .......... 10
(vi) Sand Fillers-
intermitlenl biological .... .
recirculating biological ... - .
(4) Stabilization Lagoons ...................
(viii)Ctarilier ..............................
(ix) Single stage system for combined
carbonaceous removal of SOD and
nitrogenous removal by nitrification
(see def. No. 12) (Points for this item
have to be in addition to items (5) (a)
N through (5) (a) (viu) .................
(x) Nutrient additions to enhance Bola
removal ...............................
(xi) Biological Culture ('Super Bugs') addition
to enhance organic compound removal .....
(b) Nitrogenous Stage
(i) Aeration - High Purity Oxygen System ... , .
Diffused Air System .......... .
Mechanical Air System (fixed,
floating, or rotor) ...... ......
Separate Sludge Reaeration .....
(ii) Trickling Filter -
High Rate ..............
Standard Rate ............
Packed Tower............
(iii) Biological Aerated Filter or Aerated
Biological Filter ........................
(iv) Rolaling Biological Contactors ............
(v) Sand Filter -
intermittent biological ....... .
recirculating biological ........
(v I) clarifier
2
3
J
5
B
5
5
20
10
a
3
7
5
5
10
10
2
3
5

(6) TLRTIARY OR ADVANCED TREATMENT UNIT
(a) Activated Carbons Beds -
without carbon regeneration ..................
with carbon regeneration ......... . ......... .
(b) Powdered or Granular Activated Carbon Feed -
without carbon regeneration .................
with carbon regeneration .... . ............. .
(c) Air Stripping ......... . ........... _ . .. .
(d) Denitrilicalion Process (separate process) . ... .
(e} Electrodialysis ....... . ..................... .
{(} Foam Separation .............................
(g) Ion Exchange ................................
(h) Land Application of Treated Effluent
(see definition no. 22b) (not applicable for
sand, gravel, stone and other similar mining
operations)
(i) on agriculturally managed sites (See del.
No. 4)...................................
(ii) by high rate infiltration on non -agriculturally
managed sites (includes rotary distributors
and similar lined nozzle systems) ...........
(iii) by subsurface disposal (includes low pressur
pipe systems and gravity systems except at
plants consisting of septic tank and nitrifica-
tion lines only) ....... . . ................... .
(i} Microscreens..................................
(j) Phosphorus Remo ral by Biological Processes
(See def. No. 26) ............................
(k) polishing Ponds - without aeration .......
with aeration ...... _ .. .
(1) Post Aeration - cascade ..............
diffused or mechanical .. .
(m) Reverse Osmosis ..............................
(n) Sand or Mixed -Media Fitters - low rate ..........
high rate ..........
(o) Treatment processes for removal of metal or
cyanide....................................
(p) Treatment processes for removal of toxic
materials other than metal or cyanide .........
(10) -CHEMICAL ADDITION SYSTEM (S) (See definition No. 9)
(not applicable to chemical additions rated as item
1 5
(3) 6). (5) (a) (xi), (6) (a), (6) (b). (7) (b), (7) (e)•
(9) (a), (9) (h), or (9) (c) 5 points each: List:
5
5
5
15
c J
5
10
5
(11) MISCELLANEOUS UNITS
5
(a) Holding Ponds, Holding Tanks or Settling Ponds
5
for Organic or Toxic Materials including wastes
from mining operations containing nitrogen and/or
phosphorous compounds in amounts significantly
greater than is common for domestic wastewater ..........
4
(b) Effluent Flow Equalization (not applicable to storage
basins which are inherent in land application systems). 2
10
(c) Stage Discharge (not applicable to storage basins
inherent in land application systems ....................................... 5
(d) Pumps ........ ..�._.._�___ .._ ._. _. _..... ._.
.. 3
4
ll
(e) Stand -By Power Supply..................
e
(f) Thermal Pollution Control Device .............................................
3
(4)
20
2
5
0
5
5
2
5
15
fe
t SLUDGE TREATMENT
(a) Sludge Digestion Tank - Heated ........... _ ... 10
Aerobic ............... 5
Unheated ............. 3
(b) Sludge Stabilization (chemical or thermal) ....... 5
(c) Sludge Drying Beds - Gravity ................. 2
Vacuum Assisted ....... 5
(d)
Sludge Elutrialion .... . . ......................
5
(a)
Sludge Conditioner (chemical or thermal) ........
5
(1)
Sludge Thickener (gravity) ... ...................
5
(g)
Dissolved Air Flotation Unit
(not applicable to a unit rates as (3) (i) .........
B
(h)
Sludge Gas Utilization (including gas storage) ....
2
(i)
Sludge Holding Tank - Aerated ................
5
Non -aerated ............
2
(j}
Sludge Incinerator - (not including activated
carbon regeneration) .....
10
(k)
Vacuum Filler, Centrifuge or Filter Press or other
similar dewalering devices ....................
10
(8) SLUDGE DISPOSAL including incineraled ash)
(a) Lagoons .........................................
2
(b)
Land Application (surface and subsurface)
(see definition 22a)
-where the facility holds the land app. permit ...
10
-by contracting to a land application operator who
holds the land application permit ................
2
-land application or sludge by a contractor who does
not hold the permit for the wastewater treatment
facility where the sludge is generated .........
10
(c)
Landlilied (burial) .............................
5
(9) DISINFECTION
(a)
Chlorination .............................
5
(b)
Oechlorinat'ron ........................
5
(c)
Ozone ..............................
5
(d)
Radiation.. . .......................
5
TOTAL POINTS
CLASSIFICATION
Class I ...................................... _ _ ... 5 - 25 Points
Class 11.... ..._............................................... 26- 50 Points
Class III ..... _.......................... 51- 65 Points
Class IV ................ ................ 66- Up Points
Facilities having a rating of one through four points, inclusive,
do not require a certified operator. Classification of all other
facilities requires a comparable grade operator in responsible
charge.
Facilities having an activated sludge process will be assigned
a minimum classification of Class 11.
Facilities having treatment processes for the removal of metal
or cyanide will be assigned a minimum classification of Class It,
Facilities having treatment processes for the biological removal
of phosphorus will be assigned a minimum classification of Class
III_
In -plant processes and related control equipment which are an
integral part of industrial production shall not be considered waste
treatment. Likewise, discharges of wastewater from residences
having a design flow of 1,000 gpd or less, shall not be subject to
rating.
/aDDITIQNAL COMMENTS: