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HomeMy WebLinkAboutWI0400603_UIC NOI 7-18-2023_202307144 2023 NC DEQ, NC Department of Environmental Q�wion of Water Resources (DWR) NOTIFICATION OF INTENT (NOI) TO CONSTRUCT OR OPERATE INJECTION WELLS The following are "permitted by rule" and do not require an individual permit when constructed in accordance with the rules of ISA NCAC 02C.0200 (NOTE: This form must be received at least 14 DAYS prior to iniection1 AQUIFER TEST WELLS Its.► E Cl2fs.02201 These wells are used to inject uncontaminated fluid into an aquifer to determine aquifer hydraulic characteristics. IN SITU REMEDIATION I15A N!LAC: 02C 022sf or TRACER WELLS (f5A 1vt AC �2e .02241: 1) Passive Injection Systems - In -well delivery systems to diffuse injectants into the subsurface. Examples include ORC socks, iSOC systems, and other gas infusion methods (Note: Injection Event Records (IER) do not need to be submitted for replacement of each sock used in ORC systems). 2) Small -Scale Injection Operations — Injection wells located within a land surface area not to exceed 10,000 square feet for the purpose of soil or groundwater remediation or tracer tests. An individual permit shall be required for test or treatment areas exceeding 10,000 square feet. 3) Pilot Tests - Preliminary studies conducted for the purpose of evaluating the technical feasibility of a remediation strategy in order to develop a full scale remediation plan for future implementation, and where the surface area of the injection zone wells is located within an area that does not exceed five percent of the land surface above the known extent of groundwater contamination. An individual permit shall be required to conduct more than one pilot test on any separate groundwater contaminant plume. 4) Air Injection Wells - Used to inject ambient air to enhance in -situ treatment of soil or groundwater. 5) In -Situ Thermal Wells (IST) Used to `heat' contaminated groundwater to enhance remediation. Print Clearly or Type Information. Illegible Submittals Will Be Returned as Incomplete. 07/18 23 W10400603 DATE: , ZO PERMIT NO. (to be filled in by DWR) NOTE- If this NOI is being submitted as notification of modification of a previously issued NOI for this site (e.g., different injection wells, plume, additives, etc.) and still meets the deemed permitted by rule criteria, provide the previously assigned permit tracking number and any needed relevant information to assess and approve injection: Permit No. WI WI0400603 Issued Date: 07/18/2023 A. WELL TYPE TO BE CONSTRUCTED OR OPERATED (1) Air Injection Well ....................................... Complete sections B through F, J,>M (2) Aquifer Test Well ....................................... Complete sections B through F, J, M (3) Passive Injection System ............................... Complete sections B through F, H-M (4) Small -Scale Injection Operation ...................... Complete sections B through M (5) Pilot Test ................................................. Complete sections B through M (6) Tracer Injection Well..... .............................. Complete sections B through M (7) In -Situ Thermal (1ST) Well ........................... Complete sections B through M B. STATUS OF WELL OWNER: Choose an item. Deemed Permitted G W Remediation NO[ Rev. 2-17-2020 Page I C. WELL OWNER(S) — State name of Business'Agency, and Name and Title of person delegated authority to sign on behalf of the business or agency: Name(s): W. Scott Snow. PEfRJ Reynolds Tobacco Company Mailing Address: 401 N Main Street City: Winston, -Salem State: NC__, Zip Code.27101 County: Forsyth Day Tele No.: 336-741-2236 Cell No.: EMAIL Address: snoww2oRJRT.com Fax No.: D. PROPERTY OWNER(S) (if different than well ownerfapplicant) Name and Title: Jill Peters?Wake Health cro WFIO Holdinlas _ Company Name WHO Holdines Mailing Address: 575 N Patterson Ave. Suite 550 _ City: Winston-Salem State: _NC Zip Code:27101 County: Forsyth Day Tele No.: 336-713-7154 Cell No.: EMAIL Address: igeters@wakehealth.edu Fax No.: E. PROJECT CONTACT (Typically Environmental ConsultingiEngineering Firm) Name and Title: Michael Burns Company Name Kleinfelder, Inc. Mailing Address: 3200 Gateway Centre Blvd, Suite 100 City: Morrisville State NC_ Zip Code:27560 County: Wake Day Tele No.: 919-397-3734 Ce11 No.: EMAIL Address: mburns(a)kteinfelder.com Fax No.: F. PHYSICAL LOCATION OF WELL SITE (1) Facility Name & Address: Wake Health Parking Lot, 0 N Research Park►nyCity: Winston-Salem County: Forsyth Zip Code: 27101. (2) Geographic Coordinates: Latitude" : " or 360.102016 Longitude": °_F "or 8V.237557 Reference Datum: GoogleEarth Pro Accuracy: —23m Method of Collection: GoogleEarth Pro "FOR AIR INJECTION AND AQUIFER TEST WELLS ONLY: A FACILITY SITE MAP WITH PROPERTY BOUNDARIES MAY BE SUBMITTED IN LIEU OF GEOGRAPHIC COORDINATES. G. TREATMENT AREA Land surface area of contaminant plume: 15,000 (7GCL) square feet Land surface area of inj. well network: 1,100 square feet (. 10,000 ft2 for small-scale injections) Percent of contaminant plume area to be treated: (must be < 5% of plume for pilot test injections) Deemed Permitted GW Remediation NOI Rev 2-17-2020 Put 2 H. INJECTION ZONE MAPS —Attach the following to the notification. (1) Contaminant plume map(s) with isoconcentration lines that show the horizontal extent of the contaminant plume in soil and groundwater, existing and proposed monitoring wells, and existing and proposed injection wells; and (2) Cross -sections) to the known or projected depth of contamination that show the horizontal and vertical extent of the contaminant plume in soil and groundwater, changes in lithology, existing and proposed monitoring wells, and existing and proposed injection wells. (3) Potentiometric surface map(s) indicating the rate and direction of groundwater movement, plus existing and proposed wells. 1. DESCRIPTION OF PROPOSED INJECTION ACTIVITIES AT THE SITE — Provide a brief narrative regarding the cause of the contamination, and purpose, scope, goals of the proposed injection activity: The site previously utilized seven (7) underground storage tanks (US'I's): three (3) USTs in the western portion of the site including two (2) — 12,000-gallon diesel (TK-91015 and TK-91016) and one (1) -- 12,000-gallon gasoline (TK-91017); three (3) USTs in the eastern portion of the site including one (1) — 4,000-gallon motor oil (TK-91019), one (1) — 2,500-gallon used oil (TK-91019), and one (1) _ 550-gallon antifreeze (TK-91020); and, one (1) 550-gallon skimmed oil UST (TK-91021) in the southern portion of the site. On May 27, 2009, the UST systems were removed. A release from the northern diesel dispenser was apparent from the closure samples. Soil beneath the dispenser was excavated to a depth of 12 feet. Soil encountered within the excavation appeared to be impacted by a previous release ofgasoline, presumably from the USTs in operation prior to July 1986. An exploratory excavation to a depth of 19 feet revealed apparent higher concentrations of volatile vapors. Free product had been detected within monitoring well MW-1 and free product recovery was conducted. Free product has not been detected since at least 2014. The source of the free product was believed to be the previous tank system. Petroleum constituents have historically been detected in MW-1 and FW-1 above the Gross Contaminant Levels (GCLs). The goal of the injection is to evaluate the effectiveness of the small-scale injection of BOS200 to reduce benzene concentrations in the area of monitoring well MW-1. The injection event will consist of I 1 injection points up - gradient and around monitoring well M W-1 in the 20 feet to 28 feet interval with a total of 1,650 gallons of the BOS200 mixture. WELL CONSTRUCTION DATA (1) No. of injection wells: 1 I Proposed Existing (provide NC Well Construction Record (G W-1) for each well) (2) Appx. injection depths (BLS):.__ 20 feet to 28 feet (3) For Proposed wells or Existing wells not having GW-Is, provide well construction details for each injection well in a diagram or table format. A single diagram or line in a table can be used for multiple wells with the same construction details. Well construction details shall include the following (indicate if construction is proposed or as -built): (a) Well type as permanent, Geoprobei'DPT. or subsurface distribution infiltration gallery (b) Depth below land surface of casing, each grout type and depth, screen, and sand pack (c) Well contractor name and certification number Deemed Permitted GW Remediation NO[ Rev 2-17-2020 Page 3 K. INJECTION SUMMARY NOTE: Onl} iniectants aroved by the ePidetniologn,.section of the NC Division ojPublic Health. Denartmen! of Health and Human Services can be infected approved iniectants can be found online at hti :t ,nc.&2vaabouttdivisions/water-resources.fwater-resources-permtt5twastewater-branchtground-water- ttroteclion� gamut-d--w- er-approved-injectants. All other substances must be reviewed by the DHHS{.srior to use. Co►>tact the UIC Program for more into if you wish to get approval for a di(jerent additive. However, please note it may take 3 months or longer. If no iniectants are to be used use N/A. Injectant: ROS200 Total Amt. to be injected (gal)/event: 1,650 Injectant: Total Amt. to be injected (gal)/event: Injectant: Total Amt. to be injected (gal)/event: Injectant: Total Amt. to be injected (gal)/event: Injectant: Total Amt. to be injected (gal)/event: Total Amt. to be injected (gallevent): - 1,650 No. of separate injection events: I Total Amt. to be injected (gal): 1,650 Source of Water (if applicable): Municipal L. MONITORING PLAN — Describe below or in separate attachment a monitoring plan to be used to determine if violations of groundwater quality standards specified in Subchapter 02L result from the injection activity. See attached iniection plan M. SIGNATURE OF APPLICANT AND PROPERTY OWNER Well OwnerrAppticant: "l hereby certt)�-, under penalty of law, that 1 am familiar with the information submitted in this document and all attachments thereto and that, based on my inquiry of those individuals immediately responsible for obtaining said information, I believe that the information is true, accurate and complete. I am aware that there are significant penalties, including the possibility of fines and imprisonment, for submttttng false information, 1 agree to construct, operate, maintain, repair, and if applicable, abandon the injection well and all related appurtenances in accordance with the 1 SA NCAC 02C 0200 Rules. " W. Scott Snow, Sr. Environmental Manager Signature of Applicant Print or Type Full Name and Title Property Owner (if the property is not owned by the Well OwnerlApplicantl: "As owner of the property on which the injection well(s) are to be constructed and operated, ! hereby consent to allow the applicant to construct each injection well as outlined in this application and agree that it shall be the responsibility of the applicant to ensure that the injection well(s) conform to the Well Construction Standards ((�A.R'r ' OZ('.0200) " Deemed Permitted GW Remediation NQt Rev 2.17-2020 Pag¢ 4 "Owner" means any person who holds the fee or other property rights in the well being constructed. A well is real property and its construction on land shall be deemed to vest ownership in the land owner, in the absence of contrary agreement in writing. and Title ThisI o m. Please send 1 (one) hard color copy of this NOI along with a copy on an attached CD or Flash Drive at least two (2) weeks prior to injection to: DWR — UIC Program 1636 Mail Service Center Raleigh, NC 27699-1636 Telephone: (919) 707-9000 Deemed Permitted GW Remediation NOl Rev. 2-17-2020 plat 5 (OKLEINrELDER Bright People. Right Solutions. April 25, 2022 Kleinfelder File No. RAL22R139543 Mr. Max Hopkins RJ Reynolds Tobacco Company Environmental, Health, and Safety 401 North Main Street Winston-Salem, NC 27101 SUBJECT: Work Plan for In -Situ Chemical Injection Pilot Testing RJRT Former Downtown Trucking Facility 699 North Research Parkway, Winston-Salem, NC Groundwater Incident No. 21334 Kleinfelder Project No. 20224711.001A Dear Mr. Hopkins: On behalf of RJ Reynolds Tobacco Company (RJRT), Kleinfelder has developed this Work Plan for In -Situ Chemical Injection Pilot Testing at the RJRT Former Downtown Trucking Facility located at 699 North Research Parkway, Winston-Salem, NC (herein referred to as the "site"). This Work Plan describes the In -Situ Chemical Injection Pilot Testing (injection pilot test), safety, monitoring, and reporting activities necessary to remediate petroleum impacted groundwater. The objective of the injection pilot test is to reduce residual dissolved phase petroleum constituents currently observed in groundwater at the site to concentrations below the gross contaminant levels (GCLs). SITE BACKGROUND AND REGULATORY STATUS Site Description The approximately 12.7-acre subject site is located at 699 North Research Parkway (formerly Linden Street) in Winston-Salem, Forsyth County, North Carolina (Figure 1). According to information available by the Winston-Salem Tax Assessor, the site is comprised of one (1) parcel of land identified by Parcel ID Number (PIN): 6835-48-5445. The parcel (6835-48-5445) has a listed owner of WFIQ Holdings, Inc. 20224711.001A I RAL22R139543 Page 1 of 11 April 25, 2022 © 2022 Kleinfelder www.kleinfelder.com KLEINFELDER 3200 Gateway Centre Blvd. Suite 100, Morrisville, NC 27560 p 1919.755.5011 r 10HR Bright Pwpie. Right Solutiom The site was the former location of the downtown trucking facility for RJRT. The site is generally flat and is currently occupied by paved asphalt parking lot surrounded by maintained grass right- of-way and landscaped areas. A east -west oriented strip of maintained grass area mostly separates the southern and northern portions of the site. The western adjoining property, which contains off -site groundwater monitoring wells, is also occupied by paved asphalt parking lots, beyond which a north -south oriented railroad easement is apparent. The site is bound to the east by John Gold Memorial Expressway and its southbound on -ramp, to the north by Martin Luther King Jr. Drive, to the west by North Research Parkway, and to the south by East 5ch Steet. Based on a review of available historical aerial imagery, the site was previously occupied by five (5) commercial canopy structures used for truck storage from at least 1993 to 2010. The structures were apparently demolished between 2010 and 2012. Based on property tax records, the site was converted to paved asphalt parking lots between 2014 and 2017. Regulatory Status The site previously utilized seven (7) underground storage tanks (USTs): three (3) USTs in the western portion of the site including two (2) — 12,000-gallon diesel (TK-91015 and TK-91016) and one (1) — 12,000-gallon gasoline (TK-91017); three (3) USTs in the eastern portion of the site including one (1) — 4,000-gallon motor oil (TK-91018), one (1) — 2,500-gallon used oil (TK-91019), and one (1) — 550-gallon antifreeze (TK-91020); and, one (1) 550-gallon skimmed oil UST (TK- 91021) in the southern portion of the site. On May 27, 2009, the UST systems were removed. A release from the northern diesel dispenser was apparent from the closure samples. Soil beneath the dispenser was excavated to a depth of 12 feet. Soil encountered within the excavation appeared to be impacted by a previous release of gasoline, presumably from the USTs in operation prior to July 1986. An exploratory excavation to a depth of 19 feet revealed apparent higher concentrations of volatile vapors. Free product had been detected within monitoring well MW-1 and free product recovery was conducted. Free product has not been detected since at least 2014. The source of the free product was believed to be the previous tank system. A monitoring well location/site map is provided as Figure 2. Petroleum constituents have historically been detected in MW-1 and FW-1 above the Gross Contaminant Levels (GCLs). 20224711.001A I RAL22R139543 Page 2 of 11 April 25, 2022 © 2022 Kleinfelder www.kleinfelder.com KLE/NFELOER Hrtghtpeeple. fthr-wUrb- In June 2015, Kleinfelder submitted a Corrective Action Plan (CAP) proposing monitored natural attenuation as the best option to remediate the petroleum impacted groundwater. Between the July 2016 and July 2021 groundwater sampling events, benzene concentrations have been detected above the GCL within monitoring well MW-1 during all events except in 2016. Benzene concentrations within monitoring well FW-1 were above the GCL in 2016, 2017 and 2018, but have been below the GCL in 2019, 2020 and 2021. Ethylene dibromide (EDB) has been detected at concentrations that exceed the GCL within monitoring well MW-1. A November 2021 email from NCDEQ includes a request for developing an active remedial strategy. Area Land Use Many of the properties in the vicinity of the site are parking lots and commercial development to the west, north, and south with a mixture of commercial and residential properties to the east. Site Utilities Subsurface utility conduits are located on and adjacent to the site along North Research Parkway. According to information obtained from the City of Winston-Salem, the area is serviced by the municipal water and sewer system. Overhead utilities consist of power lines with some local underground power lines. Based on previous assessments and research, underground utilities are buried above the seasonal high-water table and are not a migration pathway for groundwater. Please refer to Figure 3 for a depiction of site and adjacent utilities. ENVIRONMENTAL SETTING Risk Classification The site has a risk classification of Intermediate due to the presence of concentrations in excess of the GCLs. The risk classification can be lowered to Low when concentrations no longer exceed the GCLs. Once the site's risk classification is Low, then the incident can be closed by filing a Notice of Residual Petroleum. Geology The site is located in the Piedmont physiographic province of North Carolina. The site is mapped in a northern extension of the Charlotte Belt between the contacts with the Milton Belt and Carolina 20224711.001A I RAL22R139543 Page 3 of 11 April 25, 2022 © 2022 Kleinfelder www.kleinfelder.com (KL INFEE-LOHR BrightPeopfe. Rrght Soh th— Slate Belt. Rock in the area has been classified as biotite gneiss and schist. Bedrock has been encountered as part of the subsurface investigation activities conducted at the site at 80 ft-below the ground surface (bgs). Hydrogeology According to historical groundwater level measurements, the apparent groundwater flow direction at the site was to the southwest. Groundwater levels in the area of monitoring well MW-1 have historically been measured at between 20-ft to 22.5-ft below the top of casing (TOC). Groundwater levels measured on the western side of North Research Parkway around monitoring wells FW-1, FW-2 and FW-3 have historically been between 14-ft to 17.5-ft below TOC. Potential Sensitive Receptors According to information obtained from the City of Winston-Salem, there are no private or public water supply wells within 1,500 feet of the site. There is a piped stream (Linden Branch) located about 400 feet downgradient of monitoring well MW-1. The location of Linden Branch is provided on Figure 3. The injection event is to be performed at a sufficient distance and depth to not pose a threat to the piped stream. As mentioned, the stream is fully enclosed and is only exposed about 2,000 feet south of the site. There are no known basements in the vicinity of the injection pilot test area. The area in the vicinity of the injection pilot test area is primarily paved with the closest structure being over 700 feet to the west. REMEDIAL ALTERNATIVES EVALUATED In addition to chemical injection, other remedial alternatives evaluated included air sparging, multi- phase extraction (MPE), and passive in situ chemical oxidation. Air sparging was not selected due to the limited space on -site and the potential damage to existing infrastructure. MPE was not selected due to the low aquifer recovery rates and limited radius of influence. The passive in situ chemical oxidation which would consist of deploying oxygen release compound (ORCO) socks into monitoring well MW-1 was evaluated. Deploying ORCO socks in monitoring well MW-1 was not selected due to the suspected limited radius of influence. INJECTION WORK PLAN Based on information collected during site groundwater monitoring events since CAP implementation, it is apparent that monitored natural attenuation has been effective in reducing concentrations of dissolved -phase hydrocarbons within the groundwater in the area of FW-1 but 20224711.001A I RAL22R139543 Page 4 of 11 April 25, 2022 © 2022 Kleinfelder www.kleinfelder.com LK E/NFELOER Bright People. Right SoWiom has been less effective in the area of MW-1. Concentrations of benzene and ethylene dibromide or 1,2-dibromoethane (EDB) above the GCLs continue to be detected within monitoring well MW- 1, however analysis of for EDB has not been conducted since 2017. The approximate extent of benzene concentrations that exceed the benzene GCL is depicted on Figure 4. The target/proposed injection area covers approximately 1,100 square feet (ft2). The proposed injection area is shown on Figure 5. It is assumed that the impact extends up to eight (8) feet vertically into the apparent water table, i.e., from approximately 20 to 28-ft below ground surface (bgs), encompassing a total volume of approximately 326 cubic yards (yds3). Please refer to Table 1 for site groundwater monitoring data. Kleinfelder plans to inject BOS 2000, a reagent manufactured by Remediation Products, Inc. (RPI) and installed by AST Environmental, Inc. (AST), to remediate saturated zone soils and groundwater within the area of monitoring well MW-1. According to the manufacturer, BOS 2000 is a Trap & TreatO in situ remediation technology specifically designed to degrade petroleum hydrocarbons. BOS 2000 is a complete system effecting accelerated biodegradation of various organic compounds on an activated carbon platform that includes micro and macro nutrients, time release terminal electron acceptors, and a blend of facultative organisms designed to flourish within the aerobic to anaerobic conditions present in the pore structure of the carbon. The BOS 2000 bacteria will remain active as long as there are hydrocarbons and terminal electron acceptors (sulfate) available. A material safety data sheet (MSDS) for BOS 2000 is provided in Appendix A. Prior to the injection pilot test, AST will perform a remedial design characterization (RDC) that will be used to prepare a high -resolution conceptual site model (CSM). The CSM will help refine the injection process. Kleinfelder has successfully implemented a similar remedial strategy for NCDEQ groundwater incident 36955 in the Mooresville Region. The project site for groundwater incident 36955 had similar geologic, hydrogeologic, and concentrations as the subject site. Chemical Dosage RPI/AST calculated the estimated contaminant mass within the target area to predict the dosage of BOS 2000 required for a pilot -scale study of the degradation rate of the petroleum hydrocarbons. Based on these calculations, approximately 6,600 pounds of BOS 2000 20224711.001A I RAL22R139543 Page 5 of 11 April 25, 2022 © 2022 Kleinfelder www.kleinfelder.com r 0EW ,\ Bright penph. Righ, Salulia (Appendix B) are proposed for the injection pilot test. The BOS 2000, supplemental bacteria, and additional additives (gypsum, magnesium sulfate, food grade starch, and yeast extract) will be mixed with 1,650 gallons of water. The list and quantity of additional additives are included in Appendix B. Note that the refined CSM will help to adjust the dosage as needed. Injection Permitting The target/proposed injection pilot test scope of work is proposed to be conducted as a pilot -scale study which will only require submittal of a notification form to the NCDEQ Underground Injection Control (UIC) Program. BOS 2000 is on the list of approved injectants. Chemical Injections Kleinfelder plans to inject BOS 2000 within the target/proposed area using GeoprobeO drilling techniques. The target/proposed area map is provided on Figure 5. Based on the observed subsurface conditions; injection points will be placed at a triangular pattern with a separation distance of 10 feet. A total of 11 injections points will be used to address the target area (MW-1). The proposed injection area is shown on Figure 5. BOS 2000 slurry will be applied to the subsurface directly through the Geoprobe0 tools. Injection pressures and injection flow rates will be dictated by the geology and thus determined during field application activities. The field selected injection rate will be selected to prevent excessive mounding of the water table and lateral spread of the plume. Upon completion of the injection, the boreholes will be grouted to within one foot of surface grade and capped with clean fill. If a boring is located in an area where the existing surface is asphalt or concrete then approximately one foot of concrete will be utilized to complete borehole closure to surface grade. Remediation Waste Remediation waste is not anticipated to be generated during this work; however, if any wastes are generated, they will be containerized, handled and disposed of in accordance with all applicable state and federal regulations. HEALTH AND SAFETY Work performed at this site will be completed in substantial compliance with Occupational Safety and Health Administration (OSHA) regulations under 29 CFR 1910.120. A site -specific Health and Safety Plan (HASP) will be prepared prior to beginning any of the baseline monitoring or injection activities. Kleinfelder will amend the HASP as necessary to address the BOS 2000 20224711.001A I RAL22R139543 Page 6 of 11 April 25, 2022 © 2022 Kleinfelder www.kleinfelder.com l KLE/NFELVER Brlghr People. Right Saluriam related hazards. This HASP will be on site during all field activities described herein, and will be monitored and updated as observations and/or data encountered deem necessary. Additional activities to ensure the health and safety of employees, the general public, and the environment are outlined below. Site Control The site is an active parking lot for the commercial businesses in the area. Access to the injection area will be restricted to authorized personnel during the injections by the use of cone barriers and flagging. All personnel will enter and exit the area through specific work zones. Prior to the start of work, a safety officer will establish specific work zones to reduce the transport and exposure of contaminants at the site. The following work zones will be established. • Exclusion Zone: The Exclusion Zone is an area centered on (at least a 20-foot radius, if possible) the point of activity. All personnel in the exclusion zone will be required to wear the level of personal protective equipment (PPE) specified by the site safety officer. Entry and exit to the exclusion zone will be regulated and will be permitted only in a pre -specified area. • Support Zone: The Support Zone is established in a clean or non -contaminated area away from (and upwind when possible) from the Exclusion Zone. This area will contain support facilities and areas for potable water, first aid, and eating and changing. Normal work clothes are permitted in this area. Safety Meetings Prior to the start of work each day, the site safety officer will instruct field personnel and others that will be on site during the injections of the following: • The anticipated scope of work. • Location of nearest medical facility. • Review of the site -specific HASP. • Review the Job Loss Analysis (JLA) for each task. • Review known potential hazards with the work/chemicals. Safety meetings will also be conducted to address site -specific potential hazards prior to the start of work on a daily basis. 20224711.001A I RAL22R139543 Page 7 of 11 April 25, 2022 © 2022 Kleinfelder www.kleinfelder.com LK E/NFELOER Bright People Right Solutions. Material Handling and Spill Control A chemical measuring and mixing area will be set-up adjacent to the drilling/injection location. The area will be lined with six (6) mil polyethylene sheeting to prevent unintended discharge to the ground surface and bermed at the edges to contain chemicals. Dilute BOS 2000 slurry is relatively harmless, thus adverse chemical reactions are not anticipated. During application, the water quality and headspace of proximal observation wells will be monitored for adverse changes such as excessive heat or vapor -phase VOC generation, and large fluctuations in groundwater pH. If adverse effects such as surface breakout(s) are observed, then the injections will be terminated and the observation wells will continue to be monitored to verify that the effects have diminished. If the effects do not subside in a reasonable time frame, then clean water will be flushed through the injectors in order to dilute the chemicals in the subsurface. If adverse effects are observed following the application, then the frequency of vapor and groundwater monitoring will be increased to further assess the condition. MONITORING PROGRAM The objectives of the monitoring program are to demonstrate that the pilot study is protective of human health, safety, and the environment and to assess the effectiveness of the chemical injections. The program will consist of groundwater and soil vapor monitoring before, during, and after the injection activities to achieve these objectives. Baseline Monitoring Within one (1) month prior to the injections, vapor and groundwater monitoring of selected wells and sewer manholes will be conducted. Monitoring well MW-4 will serve as the up -gradient control. Wells MW-1, FW-1, FW-2, and FW-3 will be used to assess the treatment area and downgradient. The monitoring well locations are provided on Figure 2. The well headspace at monitoring wells MW-1, FW-1, FW-2 and FW-3 will be monitored for oxygen (02), total volatile organic vapors (TVOVs) using a photo -ionization detector (PID), lower explosive limit (LEL), and carbon dioxide (CO2). Sewer manholes will be screened with a PID to evaluate for the presence of TVOVs above background levels. The sewer manhole locations are provided on Figure 3. The background levels will be determined prior to the injection activities. Groundwater monitoring of wells MW-1, MW-4, FW-1, FW-2, and FW-3 will be measured for depth to water, dissolved oxygen (D02), oxidation-reduction potential (ORP), pH, conductivity, and 20224711.001 A I RAL22R139543 Page 8 of 11 April 25, 2022 © 2022 Kleinfelder www.kleinfelder.com KLE/MFELOER Bright People. Right Solutions. temperature. Groundwater samples will be collected from monitoring wells and submitted for laboratory analysis of VOCs in accordance with EPA Method 6200B with EDB, as well as nitrite, nitrate, and sulfate by EPA Method 300. Injection Monitoring Injection pressures and flow rates will be actively monitored at each injection location. During the injection activities, vapor and groundwater at monitoring wells MW-1, MW-4, FW-1, FW-2, and FW-3 will be monitored periodically. The well headspace vapor will be monitored for 02, TVOVs, LEL, and CO2. The monitoring wells will be monitored for depth to water, DO, ORP, pH, conductivity, and temperature during low flow purging. Post -Injection Monitoring Following the chemical injections, groundwater at monitoring wells MW-1, MW-4, FW-1, FW-2, and FW-3 will monitored within 90 days following the injections and semi-annually thereafter for the remainder of the year after the remediation event. The well headspace vapor will be monitored for 02, TVOVs, LEL, and CO2. The wells will be monitored for depth to water, DO, ORP, pH, conductivity, temperature, and turbidity during low flow purging. Kleinfelder will observe the groundwater being purged to evaluate whether the activated carbon has made the well unusable due to high turbidity levels. The groundwater samples from these monitoring wells will also be analyzed for VOCs and EDB in accordance with EPA Method 620013, as well as nitrite, nitrate and sulfate by EPA Method 300. REPORTING The effectiveness of the injection pilot test will be based on groundwater data. Following the initial injection, Kleinfelder will resample the monitoring wells within 90 days. The injection pilot test results, and the groundwater data will be provided in a monitoring report. Generally, decreases in primary indicators such as VOCs and EDB as well as nitrite, nitrate, and sulfate levels will indicate that the injections were effective. The following the initial monitoring results will be presented and evaluated in the subsequent groundwater monitoring reports will be submitted to the NCDEQ on a semi-annual schedule. 20224711.001A I RAL22R139543 Page 9 of 11 April 25, 2022 © 2022 Kleinfelder www.kleinfelder.com KLE/NFELOER Bight PWPfa Right S.IWI-.. COST ESTIMATE The cost to complete the injection pilot test are listed below. NAME Materials COST ESTIMATE $53,000 Installation $13,000 RDC $7,000 Private Utility Locate $800 Professional Services $25,000 Monitoring Events x 2 $13,200 Total Estimated Cost $112,000 LIMITATIONS Kleinfelder's work has been performed in a manner consistent with that level of care and skill ordinarily exercised by other members of its profession practicing in the same locality, under similar conditions and at the date the services are provided. Kleinfelder's conclusions, opinions and recommendations have been based on a limited number of observations and data. It is possible that conditions could vary between or beyond the data evaluated. Kleinfelder makes no guarantee or warranty, express or implied, regarding the services, communication (oral or written), report, opinion, or instrument of service provided. The information included on graphic representations in the report has been compiled from a variety of sources and is subject to change without notice. Kleinfelder makes no representations or warranties, express or implied, as to accuracy, completeness, timeliness, or rights to the use of such information. These documents are not intended for use as a land survey product, nor are they designed or intended as a construction design document. The use or misuse of the information contained on these graphic representations is at the sole risk of the party using or misusing the information. 20224711.001A I RAL22R139543 Page 10 of 11 April 25, 2022 © 2022 Kleinfelder vmv.kleinfelder.com r L ER \` Blight People. Right S.IWA S CLOSING Should you have any questions, please do not hesitate to contact the undersigned at (919) 755- 5011. ,Illuli Sincerely, KLEINFELDER SEA ' i' e'•�'9 COL .q klllllHl l Michael J Burns, PG Environmental Program Manager Brett Miller, PG Program Manager MJB/BM:asp Attachments: Table 1 — Summary of Groundwater Analytical Data Figure 1 — Location and Vicinity Map Figure 2 — Site Map Figure 3 — Sewer and Drainage Lines Figure 4 — Benzene Isoconcentration Map Figure 5 — Proposed Injection and RDC Areas Map Appendix A — MSDS for Bos200@ Appendix B — Work Sheet 20224711.001A I RAL22R139543 Page 11 of 11 © 2022 Kleinfelder April 25, 2022 www.kleinfelder.com KLE/NFELOER &fight P-ple Mght S.I t— TABLE 20224711.001A I RAL22R139543 April 25, 2022 © 2022 Kleinfelder www.kleinfelder.com 7�2�} oil ■ ■■ ■ ■ ■■ ■ - !!m§#§ ;al:;;,gym (||$(2|\flE,!/! � -11 1 z Z Z! 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Tb—,, Can ylPq—sQW—,7.1I NIT A - RJRfl Po )t I sl rg Fq. —r G IS' :J Payr b—o C,)—a ylPa;,ct,,\20224711.001A - P-JRT —d D,,',:4;MQG22 L-r.EA,L,, KLE/NFELOER \� J Bdght People. Right Solutions APPENDIX A MSDS FOR BOS2000 20224711.001A I RAL22R139543 April 25, 2022 © 2022 Kleinfelder www.kleinfelder.com .ice} ICaIgOf1Cat`b0i'1® TRAP & TREAT® BOS 2008 Safety Data Sheet SECTION 1: Identification of the Substance/Mixture and of the Company/Undertaking 1.1. Product identifier Product name TRAP & TREAT® BOS 2000 Product form Mixture Product code 13967 Other means of identification Activated carbon; Steam activated carbon 1.2. Relevant identified uses of the substance or mixture and uses advised against Use of the substance/mixture : Adsorbent 1.3. Details of the supplier of the safety data sheet Calgon Carbon Corporation P.O. Box 717 Pittsburgh, PA 15230 412-787-6700 1.4. Emergency telephone number Emergency number - CHEMTREC (24 HRS): 1-800-424-9300 SECTION 2: Hazards Identification 2.1. Classification of the substance or mixture Issued:05/28/2020 Supersedes: 06/05/2015 Version: 2.0 GHS-US classification Combustible Dust Not classified as a simple asphyxiant. Product does not displace oxygen in the ambient atmosphere, but slowly adsorbs oxygen from a confined space when wet. Under conditions of anticipated and recommended use, product does not pose an asphyxiation hazard. 2.2. Label elements GHS-US labeling Signal word (GHS-US) Warning Hazard statements (GHS-US) May form combustible dust concentrations in air 2.3. Other hazards Other hazards not contributing to the Wet activated carbon can deplete oxygen from air in enclosed spaces. If use in an enclosed classification space is required, procedures for work in an oxygen deficient environment should be followed. 2.4. Unknown acute toxicity (GHS-US) No data available SECTION 3: Composition/Information on Ingredients 3.1. Substance Not applicable 3.2. Mixture Name Product identifier % Activated carbon _ Gypsum (Hydrated calcium sulfate) (CAS No) 7440-44-0 z 80 (CAS No) 13397-24-5 < 20 SECTION 4: First Aid Measures 4.1. Description of first aid measures First -aid measures general If exposed or concerned, get medical attention/advice. Show this safety data sheet to the doctor in attendance. Wash contaminated clothing before re -use. Never give anything to an unconscious person. First -aid measures after inhalation IF INHALED: Remove to fresh air and keep at rest in a position comfortable for breathing. First -aid measures after skin contact IF ON SKIN (or clothing): Remove affected clothing and wash all exposed skin with water for at least 15 minutes. First -aid measures after eye contact IF IN EYES: Immediately flush with plenty of water for at least 15 minutes. Remove contact lenses if present and easy to do so. Continue rinsing. First -aid measures after ingestion IF SWALLOWED: Rinse mouth thoroughly. Do not induce vomiting without advice from poison control center or medical professional. Get medical attention if you feel unwell. 05/28/2020 TRAP & TREAT® BOS 2000 For Internal Use Only: PR#85 Page 1 of 7 OSHA SDS Product Code: 13967 TRAP & TREAT® BOS 2008 Product Code: 13967 Safety Data Sheet 4.2. Most important symptoms and effects, both acute and delayed Symptoms/injuries after inhalation Not expected to present a significant hazard under anticipated conditions of normal use. Dust may cause irritation respiratory system. Symptoms/injuries after skin contact Dust may cause irritation. Symptoms/injuries after eye contact Dust may cause irriation and redness. Symptoms/injuries after ingestion Not expected to present a significant hazard under anticipated conditions of normal use. 4.3. Indication of any immediate medical attention and special treatment needed No additional information available. SECTION 5: Firefighting Measures 5.1. Extinguishing media Suitable extinguishing media Water spray. Carbon dioxide. Dry chemical. Foam. Sand. Unsuitable extinguishing media None known. 5.2. Special hazards arising from the substance or mixture Fire hazard Dust maybe combustible under specific conditions. Maybe ignited by heat, sparks or flames. Explosion hazard Dust may form explosive mixture in air. Reactivity No dangerous reactions known under normal conditions of use. Carbon oxides, ammonia, or toxic halide fumes may be emitted upon combustion of the material. 5.3. Advice for firefighters Firefighting instructions Wear NIOSH-approved self-contained breathing apparatus suitable for the surrounding fire. Use water spray or fog for cooling exposed containers. Evacuate area. SECTION 6: Accidental Release Measures 6.1. Personal precautions, protective equipment and emergency procedures General measures Evacuate area. Keep upwind. Ventilate area. Spill should be handled by trained clean-up crews properly equipped with respiratory equipment and full chemical protective gear (see Section 8). 6.1.1. For non -emergency personnel No additional information available. 6.1.2. For emergency responders No additional information available. 6.2. Environmental precautions Prevent entry to sewers and public waters. Avoid release to the environment. Product is not soluble but can cause particulate emission if discharged into waterways. Dike all entrances to sewers and drains to avoid introducing material to waterways. Notify authorities if product enters sewers or public waters. 6.3. Methods and material for containment and cleaning up For containment Sweep or shovel spills into appropriate container for disposal. Minimize generation of dust. Methods for cleaning up Sweep or shovel spills into appropriate container for disposal. Minimize generation of dust. Dispose of material in compliance with local, state, and federal regulations. 6.4. Reference to other sections No additional information available SECTION 7: Handling and Storage 7.1. Precautions for safe handling Precautions for safe handling Avoid dust formation. Avoid contact with skin, eyes and clothing. Do not handle until all safety precautions have been read and understood. Wash hands and other exposed areas with mild soap and water before eating, drinking or smoking and when leaving work. Keep away from sources of ignition - No smoking. 7.2. Conditions for safe storage, including any incompatibilities Storage conditions Keep container tightly closed in a cool, dry, and well -ventilated place. Keep away from ignition sources. SECTION 8: Exposure Controls/Personal Protection 8.1. Control parameters Activated carbon (7440-44-0)' OSHA PEL (TWA) (mg/m3) <_ 5 (Respirable Fraction) 5 15 (Total Dust) 05/28/2020 TRAP & TREAT® BOS 2000 For Internal Use Only: PR#85 2/7 OSHA SDS Product Code: 13967 TRAP & TREAT@ BOS 2008 Product Code: 13967 Safety Data Sheet Gypsum (Hydrated calcium sulfate) (13397-24-5)' OSHA PEL (TWA) (mg/m3) <_ 5 (Respirable Fraction) <_ 15 (Total Dust) "Exposure limits are for inert or nuisance dust. No specific exposure limits have been established for this activated carbon product by OSHA or ACGIH. 8.2. Exposure controls Appropriate engineering controls Provide adequate general and local exhaust ventilation. Use process enclosures, local exhaust ventilation, or other engineering controls to control airborne levels below recommended exposure limits. Use explosion -proof equipment with flammable materials. Ensure adequate ventilation, especially in confined areas. Wet activated carbon can deplete oxygen from air in enclosed spaces. If use in an enclosed space is required, procedures for work in an oxygen deficient environment should be followed. Personal protective equipment Gloves. Safety glasses. Protective clothing. Insufficient ventilation: wear respiratory protection. 00 (5 00 Hand protection Gloves should be classified under Standard EN 374 or ASTM F1296. Suggested glove materials are: Neoprene, Nitrile/butadiene rubber, Polyethylene, Ethyl vinyl alcohol laminate, PVC or vinyl. Suitable gloves for this specific application can be recommended by the glove supplier. Eye protection Use eye protection suitable to the environment. Avoid direct contact with eyes. Skin and body protection Wear long sleeves, and chemically impervious PPE/coveralls to minimize bodily exposure. Respiratory protection Use NIOSH-approved dust/particulate respirator. Where vapor, mist, or dust exceed PELs or other applicable OELs, use NIOSH-approved respiratory protective equipment. SECTION 9: Physical and Chemical Properties 9.1. Information on basic physical and chemical properties Physical state Solid Appearance Granular, powder, or pelletized substance Color Black Odor Odorless Odor threshold No data available pH No data available Relative evaporation rate (butyl acetate=l) Not applicable Melting point Not applicable Freezing point Not applicable Boiling point Not applicable Flash point No data available Auto -ignition temperature > 220 °C Decomposition temperature No data available Flammability (solid, gas) > 220 °C Vapor pressure Not applicable Relative vapor density at 20 °C Not applicable Apparent density 0.4 - 0.8 g/cc Solubility Carbon and gypsum are insoluble; fertilizer components are soluble Log Pow Not applicable Log Kew Not applicable Viscosity, kinematic Not applicable Viscosity, dynamic Not applicable Explosive properties No data available Oxidizing properties No data available Explosive limits No data available 9.2. Other information No additional information available. 05/28/2020 TRAP & TREATO BOS 2000 For Internal Use Only: PR#85 OSHA SDS Product Code: 13967 3/7 TRAP & TREAT® BOS 2000 Product Code: 13967 Safety Data Sheet SECTION 10: Stability and Reactivity 10.1. Reactivity No dangerous reactions known under normal conditions of use. 10.2. Chemical stability Stable under use and storage conditions as recommended in section 7 10.3. Possibility of hazardous reactions None known. 10.4. Conditions to avoid Avoid dust formation. Heat. Ignition sources. Exposure to high concentrations of organic compounds may cause bed temperature to rise. 10.5. Incompatible materials Alkali metals. Strong oxidizing agents. 10.6. Hazardous decomposition products Carbon monoxide (CO), carbon dioxide (COZ). Ammonia. Toxic halide fumes. SECTION 11: Toxicological Information 11.1. Information on toxicological effects Acute toxicity Not classified Activated carbon (7440-44-0) LDso oral rat I > 2000 mg/kg Skin corrosion/irritation Not classified Serious eye damage/irritation Not classified Respiratory or skin sensitisation Not classified Germ cell mutagenicity Not classified Carcinogenicity Not classified Silica: crystalline, quartz (14808-60-7) ]ARC group I 1 -Carcinogenic to humans The International Agency for Research on Cancer (IARC) has classified "silica dust, crystalline, in the form of quartz or cristobalite" as carcinogenic to humans (group 1). However these warnings refer to crystalline silica dusts and do not apply to solid activated carbon containing crystalline silica as a naturally occuring, bound impurity. As such, we have not classified this product as a carcinogen in accordance with the US OSHA Hazard Communication Standard (29 CFR §1910.1200) but recommmend that users avoid inhalation of product in a dust form. Reproductive toxicity Not classified Specific target organ toxicity (single exposure) Not classified Specific target organ toxicity (repeated Not classified exposure) Aspiration hazard Not classified Symptoms/injuries after inhalation Not classified Symptoms/injuries after inhalation Not expected to present a significant hazard under anticipated conditions of normal use. Symptoms/injuries after skin contact Dust may cause irritation of the skin. Symptoms/injuries after eye contact Dust may cause irritation and redness. Symptoms/injuries after ingestion Not expected to present a significant hazard under anticipated conditions of normal use. SECTION 12: Ecological information71 12.1. Toxicity No additional information available. 12.2. Persistence and degradability No additional information available. 12.3. B]oaccumulative potential No additional information available. 12.4. Mobility in soil No additional information available. 12.5. Other adverse effects No additional information available. 05128/2020 TRAP & TREAT® BOS 2000 For Internal Use Only: PR#85 OSHA SIDS Product Code: 13967 an TRAP & TREATS BOS 2000 Product Code: 13967 Safety Data Sheet SECTION 13: Disposal Considerations 13.1. Waste treatment methods _ Waste treatment and disposal methods Vacuum or shovel material into a closed container. Dispose in a safe manner in accordance with local/national regulations. Do not allow the product to be released into the environment. Additional information Activated carbon is an adsorbent media; hazard classification is generally determined by the adsorbate. Consult U.S. EPA guidelines listed in 40 CFR 261.3 for more information on hazardous waste disposal. SECTION 14: Transport Information 14.1. In accordance with DOT Not classified as hazardous for domestic land transport UN-No.(DOT) None on finished product DOT NA no. None on -finished product Proper Shipping Name (DOT) Not regulated Department of Transportation (DOT) Hazard None an finished product Classes Hazard labels (DOT) None on finished product Packing group (DOT) None on finished product DOT Quantity Limitations Passenger aircraft/rail None on finished product (49 CFR 173.27) 14.2. Transport by sea Not classified as hazardous for water transport IMO / IMDG UN/NA Identification Number : None on finished product UN- Proper Shipping Name : Not regulated Transport Hazard Class : None on finished product 14.3. Air transport Not classified as hazardous for air transport ICAO / IATA UN/NA No : None on finished product UN- Proper Shipping Name : Not regulated Transport Hazard Class : None on finished product Packing Group None on finished product Marine Pollutant None on finished product 14.4. Additional information Other information Under the UN classification for activated carbon, all activated carbons have been identified as a class 4.2 product. However, this product type or an equivalent has been tested according to the United Nations Transport of Dangerous Goods test protocol for a "self -heating substance" (United Nations Transportation of Dangerous Goods, Manual of Tests and Criteria, Part lll, Test N.4 - Test Method for Self Heating Substances) and it has been specifically determined that this product type or an equivalent does not meet the definition of a DOT self -heating substance (class 4.2) or any other hazard class. This information is applicable to the steam activated carbon product described in this document. SECTION 15. Regulatory Information 15.1. US Federal regulations TRAP & TREAT® BOS 2008 All chemical substances in this product are listed as "Active' in the EPA (Environmental Protection Agency) "TSCA Inventory Notification (Active - Inactive) Requirements Rule' ("the Final Rule') as of February 2019 or are otherwise exempt. SARA Section 311/312 Hazard Classes Physical hazard - Combustible dust Cobalt (7440-48-4)* Listed on the United States TSCA (Toxic Substances Control Act) inventory Listed on United States SARA Section 313 SARA Section 313 - Emission Reporting 0.1 Present below de mimmis level 15.2. International regulations No additional information available. ......---.._............._.....---._.........---....... .._........ _.-.._._...... 05/28/2020 OSHASIDS TRAP & TREATS BOS 2008 Product Code: 13967 For Internal Use Only: PR#85 5n TRAP & TREAT® BOS 2008 Product Code: 13967 Safetv Data Sheet 15.3. US State regulations California Proposition 65 ® WARNING: This product can expose you to chemicals including silica: crystalline, quartz, which are known to the State of California to cause cancer. For more information go to www.P65Warnings.ca.gov. Component Carcinogenicity Developmental Reproductive Reproductive No significant Maximum toxicity toxicity male toxicity risk level (NSRL) allowable female dose level (MADL) Silica: crystalline, X quartz (14808-60-7) Titanium dioxide X Not available (13463-67-7) Cobalt (7440-48-4) 1 X Component State or local regulations Aluminum oxide (1344-28-1) U.S. - New Jersey - Right to Know Hazardous Substance List U.S. - Massachusetts - Right To Know List U.S. - Pennsylvania - RTK (Right to Know) - Environmental Hazard List Calcium sulfate (7778-18-9) U.S. - Massachusetts - Right to Know List U.S. - New Jersey - Right to Know Hazardous Substance List U.S. - Pennsylvania - RTK (Right to Know) List Silica: crystalline, quartz (14808-60-7) U.S. - New Jersey - Right to Know Hazardous Substance List U.S. - Pennsylvania - RTK (Right to Know) List U.S. - Massachusetts - Right To Know List Gypsum (Hydrated calcium sulfate) (13397-24-5) U.S. - New Jersey - Right to Know Hazardous Substance List U.S. - Pennsylvania - RTK (Right to Know) List Ammonium nitrate (6484-52-2) U.S. - New Jersey - Right to Know Hazardous Substance List U.S. - Massachusetts - Right To Know List U.S. - Pennsylvania - RTK (Right to Know) List Limestone (1317-65-3) U.S. - Massachusetts - Right To Know List U.S. - New Jersey - Right to Know Hazardous Substance List U.S. - Pennsylvania - RTK (Right to Know) List SECTION 16: Other Information Indication of changes Revision 2.0 Revision Date 05/28/2020 Other information Author: BCS. For internal use only PR #85 Prepared according to Federal Register / Vol. 77, No. 58 / Monday, March 26, 2012 / Rules and Regulations NFPA health hazard 0 - Exposure under fire conditions would offer no hazard beyond that of ordinary combustible materials. NFPA fire hazard 1 - Must be preheated before ignition can occur. NFPA reactivity 0 - Normally stable, even under fire exposure conditions, and are not reactive with water. HMIS III Rating Health 0 Flammability 1 .......__..__...._._................ .._.._._..-._._........... ----.._..._------ -- .._..-.._._.._._..__._........... -.... ..........._.._......_..- ....... .._.-.-._._.--. 05/28/2020 TRAP & TREAT® BOS 2006 OSHA SDS Product Code: 13967 For Internal Use Only: PR#85 6n TRAP & TREAT® BOS 2000 Product Code: 13967 Safetv Data Sheet Physical Personal Protection This information is based on our current knowledge and is intended to describe the product for the purposes of health, safety and environmental requirements only. It should not therefore be construed as guaranteeing any specific property of the product. The information is this document applies to this specific material as supplied. It may not be valid if product is used in combination with other materials. It is the user's responsibility to determine the suitability and completeness of this information for their particular use. While the information and recommendations set forth herein are believed to be accurate as of the date hereof, Calgon Carbon Corporation makes no warranty with respect to the same, and disclaims all liability for reliance thereon. 05/28/2020 TRAP & TREAT® BOS 2000 For Internal Use Only: PR485 7/7 OSHA SIDS Product Code: 13967 (,-- LK DIER \_ Brlyht People. 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