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HomeMy WebLinkAboutDERR-2025-000952Facilities | Environmental | Geotechnical | Materials 1 Cover Page Monitoring Well Installation and Second Quarterly Groundwater Monitoring Report Former Murray Fleet Facility 4400 South Main Street Murray, Utah Facility ID 4000598, Release Site NCD January 31, 2025| Terracon Project No. 61237057 Prepared for: Lumen Technologies, Inc. Broomfield, Colorado 6952 South High Tech Drive Ste. B Midvale, Utah 84047 P (801) 545-8500 Terracon.com Facilities | Environmental | Geotechnical | Materials i Cover Letter January 31, 2025 Utah Department of Environmental Quality Division of Environmental Response and Remediation 195 North 1950 West Salt Lake City, Utah 84114-4840 Attention:Ms. Liberty Coe Telephone: (801) 536-4100 Email:lcoe@utah.gov RE: Monitoring Well Installation and Second Quarterly Groundwater Monitoring Report Former Murray Fleet Facility 4400 South Main Street, Murray, Utah Facility ID 4000598, Release Site NCD Terracon Project No. 61237057 Dear Ms. Coe: Terracon Consultants, Inc. (Terracon) is pleased to submit this Monitoring Well Installation and Second Quarterly Groundwater Monitoring Report documenting the installation of one monitoring well and two consecutive quarterly groundwater sampling events conducted at the Former Murray Fleet Facility site, located at 4400 South Main Street, Murray, Utah. Terracon has performed this work pursuant to the Monitoring Well Installation Work Plan dated October 7, 2024. A corrective action was implemented at the site and documented in the Corrective Action Plan Implementation Report (September 16, 2024), which was submitted to the Utah Department of Environmental Quality (DEQ) Division of Environmental Response and Remediation (DERR). The work was performed as part of the cleanup of a Leaking Underground Storage Tank (LUST; Release Site ID NCD) present at the site. We appreciate the opportunity to have performed these services for you. Please contact our office at (801) 545-8500 if you have questions regarding this information or if we can provide any other services. Sincerely, Terracon Consultants, Inc. Andrew Turner Amy Austin Project Manager Authorized Project Reviewer ' P \ ' X V W L Q Facilities | Environmental | Geotechnical | Materials ii Table Of Contents 1.0 Introduction ................................................................................ 1 1.1 Site Description ..................................................................................... 1 1.2 Scope of Services ................................................................................... 2 1.3 Standard of Care .................................................................................... 2 1.4 Additional Scope Limitations .................................................................... 3 1.5 Reliance ................................................................................................ 3 2.0 Monitoring Well Installation ........................................................... 3 3.0 Groundwater Sampling Event ........................................................ 4 3.1 General Observations ............................................................................. 4 4.0 Laboratory Analytical Methods ....................................................... 4 5.0 Data Evaluation ........................................................................... 5 5.1 Quality Control ....................................................................................... 5 6.0 Findings And Conclusions .............................................................. 5 Appendices Appendix A Exhibits Exhibit 1:Topographic Site Overview Exhibit 2:Monitoring Well Location Appendix B Data Table Table 1:Groundwater Analytical Results Appendix C UDEQ Post Remediation Groundwater Monitoring Letter, September 19, 2024 Appendix D Chain of Custody and Laboratory Data Sheets Monitoring Well Installation and Groundwater Monitoring Report Former Murray Fleet Facility, Murray, Utah January 31, 2025 | Terracon Project No. 61237057 Facilities | Environmental | Geotechnical | Materials 1 1.0 Introduction 1.1 Site Description Site Name Former Murray Fleet Facility; Release Site NCD Site Location/Address 4400 South Main Street, Murray, Utah Facility Identification No. 4000598, Release Site NCD General Site Description The entire site is approximately 1.94 acres occupying one parcel. The previous on-site building has been demolished, and the entire site is currently under development. Exhibit 1 (Appendix A) illustrates the approximate location of this parcel in relation to the surrounding area.Exhibit 2 is a site diagram indicating the current and historic excavation areas and approximate location of the newly installed groundwater monitoring well. The facility had previously been operated by US WEST, Qwest Communications, and CenturyLink (now Lumen). Two petroleum underground storage tank (UST) releases reported to the Utah Department of Environmental Quality (UDEQ) Division of Environmental Response and Remediation (DERR) were identified at the facility during ownership and operation by Lumen. One of the releases, Release HDA, involved a former gasoline and diesel fuel UST area in the northern portion of the site, and the second release, Release NCD, involved a former used oil UST in the southern portion of the site. Site investigations, groundwater monitoring, and remediation activities to address the releases were conducted from early 1990s to the middle 2010s. A corrective action was performed in 2013 with removal of impacted subsurface soils, and post-remediation reports detailing this work in both release areas were submitted to DERR. Release HDA received regulatory “No Further Action” status from the DERR in March 2014. A portion of the impacted soils of Release NCD could not be removed and was left in place below the western portion of the facility’s former maintenance building. DERR agreed to wait until the building located above a portion of Release NCD was demolished prior to requiring further remedial action in that area. The property is now owned by Evergreen-45th & Main Land, LLC, who is currently redeveloping the property. A request for a Corrective Action Plan Requirements letter (dated May 26, 2022) was issued by DERR to Lumen, and Terracon developed a Corrective Action Plan (CAP; dated May 17, 2023). The CAP was approved by DERR in a letter dated August 1, 2023, and site work by the current owner was initiated in August 2024. Monitoring Well Installation and Groundwater Monitoring Report Former Murray Fleet Facility, Murray, Utah January 31, 2025 | Terracon Project No. 61237057 Facilities | Environmental | Geotechnical | Materials 2 In August 2024, the building covering the former Release Site NCD area was demolished to redevelop the area. Soil excavation, transportation, disposal, and groundwater treatment were conducted at the site between August 16, 2024, and August 23, 2024 following the CAP. Confirmation soil samples collected from each of the four sidewalls and one from the floor of the excavation indicated that concentrations of petroleum hydrocarbons in soil at the extent of excavation were below DERR’s Initial Screening Levels (ISLs). A Corrective Action Implementation Report was issued by Terracon on September 16, 2024, detailing the remediation work conducted at the site. The DERR issued a letter dated September 19, 2024 (Appendix C), that indicated post-remedial groundwater monitoring would be required to evaluate the effectiveness of the remedial action. DERR requires that Groundwater monitoring continue until two consecutive events indicate that petroleum impacts to the groundwater are below DERR’s ISLs. Terracon submitted a Monitoring Well Installation Work Plan for the site (October 7, 2024) that proposed the installation and sampling of one groundwater monitoring well in the vicinity of the recent excavation and remediation area. The Work Plan was approved by the DERR on October 11, 2024. This report documents the results of two consecutive quarters of groundwater monitoring at the site. 1.2 Scope of Services The Scope of Services outline the installation and sampling of one groundwater monitoring well to assess the current groundwater conditions after the recent excavation and remediation work conducted at the site. The Post Remediation Groundwater Monitoring request issued by DERR requires that groundwater monitoring should continue until two consecutive sampling events indicate petroleum impacts to the groundwater are below ISLs. The first groundwater sampling event was conducted on October 30, 2024. The second sampling event was conducted on January 28, 2025. 1.3 Standard of Care Terracon’s services were performed consistent with generally accepted practices of the profession undertaken in similar studies in the same geographical area during the same time period. Please note that Terracon does not warrant the work of laboratories, regulatory agencies, or other third parties supplying information used to prepare the report. These services were performed in accordance with the Scope of Services agreed with you, our client, as reflected in our proposal, and were not restricted by ASTM E1903-19. Monitoring Well Installation and Groundwater Monitoring Report Former Murray Fleet Facility, Murray, Utah January 31, 2025 | Terracon Project No. 61237057 Facilities | Environmental | Geotechnical | Materials 3 1.4 Additional Scope Limitations Findings, conclusions, and recommendations resulting from these services are based upon information derived from the on-site activities and other services performed under this scope of services. Such information is subject to change over time. Certain indicators of the presence of hazardous substances, petroleum products, or other constituents may have been latent, inaccessible, unobservable, non-detectable, or not present during these services, and we cannot represent that the site contains no hazardous substances, toxic materials, petroleum products, or other latent conditions beyond those identified during this investigation. Subsurface conditions may vary from those encountered at specific borings or wells and/or during other surveys, tests, assessments, investigations, or exploratory services. The data, interpretations, findings, and recommendations are based solely upon data obtained at the time and within the scope of these services. 1.5 Reliance This report has been prepared for the exclusive use and reliance of Lumen and the Utah Department of Environmental Quality (UDEQ). Use or reliance by any other party is prohibited without the written authorization of Lumen and Terracon. Reliance on the report by the client and all authorized parties will be subject to the terms, conditions, and limitations stated in the proposal, report, and Terracon’s Terms and Conditions. The limitation of liability defined in the Terms and Conditions is the aggregate limit of Terracon’s liability to the client and all relying parties. 2.0 Monitoring Well Installation Prior to monitoring well drilling and installation, the public utility location service (Blue Stakes of Utah) was notified at least 48 hours prior to digging or drilling as required by law and site access was obtained from the current site owner. In addition, a subcontracted private utility location service, Direct Push Services, was used to identify and mark subsurface utilities around the well location. The groundwater monitoring well was drilled by Direct Push Services on October 25, 2024, using a direct-push (Geoprobe) drill rig. The monitoring well was drilled to an approximate depth of 15 feet below ground surface (bgs). The monitoring well was constructed as follows: installation of 10 feet of 2-inch diameter (15–5 feet bgs), 0.010-inch machine slotted polyvinyl chloride (PVC) well screen with a threaded bottom cap installation of 2-inch diameter, threaded, flush-joint PVC riser pipe to the surface addition of silica sand pack for annular sand pack around the well screen from the bottom of the boring to approximately 2.5 feet above the top of the well screen Monitoring Well Installation and Groundwater Monitoring Report Former Murray Fleet Facility, Murray, Utah January 31, 2025 | Terracon Project No. 61237057 Facilities | Environmental | Geotechnical | Materials 4 placement of hydrated bentonite chips above the sand pack to the surface placement of a locking cap at the end of the PVC The well was completed with a well cover inset in a flush-mounted concrete well pad when the surrounding concrete ramp was installed in December 2024. Prior to the ramp being installed, a removable 10-foot PVC riser had been attached to the well and was being protected by a larger diameter PVC pipe. After installation, the well was developed using a surge block and bailer. Approximately 5 gallons of water (approximately 6 purge volumes) was purged from the well after surging, with the water becoming progressively clearer. The limited soil cuttings generated during drilling were thinly spread across the ground in the vicinity of the monitoring well. Purge water generated during development activities was spread on-site and allowed to infiltrate into the ground. 3.0 Groundwater Sampling Event The second sampling event was conducted on January 28, 2025. Terracon gauged the depth to water and collected a groundwater sample from the on-site monitoring well (MW-A; Exhibit 2 (Appendix A). Prior to collecting the groundwater sample, the well was purged using a single-use disposable plastic bailer and twine which was discarded after use. The water meter used for depth to water measurements was decontaminated using an Alconox wash followed by a rinsing with potable and distilled water. The well was purged with a minimum of three well volumes (2.64 gallons, calculated volume of water within the initial water column) extracted prior to sampling. No sheen or distinct odor was noted during the purging or sampling. Purge water was thin spread across the surface of the site and allowed to evaporate or infiltrate into surface soils. Care was taken to not allow purge water to affect nearby receptors (stormwater catch basins, utilities, etc.). 3.1 General Observations Depth-to-water measurements are presented in Table 1 (Appendix B). Free product was not observed during this sampling event. 4.0 Laboratory Analytical Methods The groundwater sample was collected and placed in laboratory-prepared containers, labeled, placed on ice in a cooler, and transported to Chemtech-Ford Laboratories in Sandy, Utah. The groundwater sample was submitted for analysis of Total Petroleum Hydrocarbons Monitoring Well Installation and Groundwater Monitoring Report Former Murray Fleet Facility, Murray, Utah January 31, 2025 | Terracon Project No. 61237057 Facilities | Environmental | Geotechnical | Materials 5 (TPH) Gasoline Range Organics (GRO) using United States Environmental Protection Agency (EPA) Method 8260B, TPH Diesel Range Organics (DRO) using EPA Method 8015C, and methyl tert-butyl ether, benzene, toluene, ethylbenzene, xylenes, and naphthalene (MBTEXN) using EPA Method 8260D. The executed chain-of-custody form and laboratory data sheets are provided in Appendix D. 5.0 Data Evaluation Results of the groundwater sampling event are summarized in Table 1 (Appendix B). The sample location is shown on Exhibit 2 (Appendix A). As presented in Table 1, all analytes were not-detected above the reported detection limit (RDL). 5.1 Quality Control Quality control for the sampling program was provided by using standardized sample collection and handling methods, documenting pertinent field information, and keeping chain-of-custody records, as well as using a Utah-certified laboratory. All sampling procedures followed Terracon’s Standard Operating Procedures and industry practices, and the sample was collected by a Utah-certified Soil and Groundwater Sampler. A review of the field procedures indicates that standard operating procedures were followed with regards to sample collection, handling, and documentation. The analytical laboratory report indicated that samples were extracted and analyzed within appropriate sample holding times. Internal laboratory QA/QC procedures and results are presented in the laboratory report and were within acceptable limits set by the laboratory, except where noted. 6.0 Findings And Conclusions The groundwater sample did not report petroleum hydrocarbons above the laboratory RDLs for all analytes. Hence, results were also below the ISLs. This is the second consecutive round of groundwater monitoring that indicates the absence of these analytes above regulatory screening levels. Closure of this release site is requested. Appendix A Exhibits N: \ G I S \ 6 1 2 3 7 0 5 7 _ L u m e n \ 6 1 2 3 7 0 5 7 _ L u m e n . a p r x Exhibit terracon.comPH. 801-545-8500 6952 S High Tech Dr, Ste B Midvale, UT Reviewed By: Drawn By: Nov 2024 Date: 61237057 Project No.: Former Murray Fleet Facility 4400 South Main Street Murray, Utah Monitoring Well Location 2 ABA AST DATA SOURCES: ESRI - Basemaps @AMW-20 0 70 14035 Feet ³ ³ @A Monitoring Well Soil Excavation Area Historic Excavation Area Former UST Approximate Site Boundary Appendix B Data Table Table 1 - Groundwater Analytical Results Former Fleet Facility - 4400 South Main Street, Murray, Utah Facility ID 4000598, Release Site NCD Terracon Project No. 61237057 Analyte CAS Method Units ISL Tier 1 Result Q RDL Result Q RDL TPH-GRO 8006-61-9 8260B mg/l 1 10 <0.125 0.125 <0.125 0.125 TPH-DRO 68334-30-5 8015C mg/l 1 10 <1.0 1.0 <1.0 1.0 BENZENE 71-43-2 8260B mg/l 0.005 0.3 <0.005 0.005 <0.005 0.005 ETHYLBENZENE 100-41-4 8260B mg/l 0.7 4 <0.012 0.12 <0.012 0.12 METHYL TERT-BUTYL ETHER 1634-04-4 8260B mg/l 0.2 0.2 <0.008 0.008 <0.008 0.008 NAPHTHALENE 91-20-3 8260B mg/l 0.7 0.7 <0.012 0.012 <0.012 0.012 TOLUENE 108-88-3 8260B mg/l 1 3 <0.012 0.012 <0.012 0.012 XYLENES, TOTAL 1330-20-7 8260B mg/l 10 10 <0.038 0.038 <0.038 0.038 mg/l - milligrams per liter 9.97 Qualifiers (Q): Utah Department of Environmental Quality's Initial Screening Levels (ISLs) and risk-based Tier 1 Screening Levels (Tier 1) for petroleum hydrocarbons in groundwater at underground storage tank sites. Lab Sample ID 24J2592-01 Monitoring Well ID MW-A Date Collected 10/30/2024 25A1942-01 MW-A 1/28/2025 17.25* * - The length of the well was extended approximately 8 feet using a PVC riser due to a concrete ramp being installed around it. Depth to Water (ft) Page 1 of 1 Appendix C UDEQ Post Remediation Groundwater Monitoring Letter, September 19, 2024 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144840 • Salt Lake City, UT 84114-4840 Telephone (801) 536-4100 • Fax (801) 359-8853 • T.D.D. (801) 536-4284 www.deq.utah.gov Printed on 100% recycled paper State of Utah SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor Department of Environmental Quality Kimberly D. Shelley Executive Director DIVISION OF ENVIRONMENTAL RESPONSE AND REMEDIATION Brent H. Everett Director ERRL-0409-24 September 19, 2024 CERTIFIED MAIL RETURN RECEIPT REQUESTED Stephanie M. Miller Lumen 1025 Eldorado Boulevard 23-201 Broomfield, Colorado 80021 Re: Post Remediation Groundwater Monitoring Former Murray Fleet, located at 4400 South Main Street, Murray, Utah Facility Identification No. 4000598, Release Site NCD Dear Ms. Miller: On September 16, 2024, the Division of Environmental Response and Remediation (DERR) received a Corrective Action Implementation Report for the above-referenced Site. After reviewing this information, the DERR project manager has recommended further investigation to determine the full extent of subsurface contamination. The Corrective Action Plan for this site was approved by the DERR on August 1, 2023 and remedial activities were carried out from August 16, 2024 through August 27, 2024. This included the excavation and removal of 225 tons of contaminated soil and the treatment of groundwater. Groundwater was treated by adding a 35% hydrogen peroxide solution and ferrous sulfate to the bottom of the soil excavation. No groundwater samples were collected as part of the Corrective Action. However, a Limited Subsurface Investigation conducted in April 2023 indicated groundwater contamination above Initial Screening Levels (ISLs). Due to the presence of contaminated groundwater, the Division Director is requiring Post- Remediation Groundwater Monitoring to evaluate the effectiveness of the Corrective Action Plan. Groundwater monitoring should occur quarterly until two consecutive sampling events indicate the petroleum impacts to the groundwater are below ISLs. All environmental samples must be collected by a Utah certified groundwater and soil sampler following sampling protocol as outlined in Utah Admin. Code R311-205. The report associated with these requirements must be submitted to our office within 90 days from the receipt Facility ID# 4000598 Page 2 of this letter. Environmental samples must be analyzed for gasoline and diesel using the methods indicated in the enclosed Table of Analytical Methods for Sampling. If you have any questions regarding this matter, please contact Liberty Coe, the DERR project manager, at (801) 536-4100. Sincerely, Brent H. Everett, Director Division of Environmental Response and Remediation BHE/LC/rr Enclosure: Table of Analytical Methods for Sampling cc: Dorothy Adams, Executive Director, Salt Lake County Health Department Jay Clark, Environmental Health Director, Davis County Health Department Andrew Turner, P.G., Terracon Consultants, Inc. Amy Austin, Terracon Consultants, Inc. Analytical Methods for Environmental Sampling at Petroleum Storage Tank Sites in Utah (September 2022) Substance or Product Type Contaminant Compounds to be Analyzed for Each Substance or Product Type ANALYTICAL METHODS1 Soil, Groundwater or Surface Water Gasoline Total Petroleum Hydrocarbons (purgeable TPH as gasoline range organics C6 - C10) EPA 8015 or EPA 8260 Benzene, Toluene, Ethyl benzene, Xylenes, Naphthalene, (BT EXN) and MTBE EPA 8021 or EPA 8260 Diesel Total Petroleum Hydrocarbons (extractable TPH as diesel range organics C10 – C28) EPA 8015 Benzene, Toluene, Ethyl benzene, Xylenes, and Naphthalene (BT EXN) EPA 8021 or EPA 8260 Used Oil Oil and Grease (O&G) or Total Recoverable Petroleum Hydrocarbons (T RPH) EPA 1664 or EPA 1664 (SGT*) Benzene, Toluene, Ethyl benzene, Xylenes, Naphthalene (BT EXN) & MTBE; and Halogenated Volatile Organic Compounds (VOX) EPA 8021 or EPA 8260 New Oil Oil and Grease (O&G) or Total Recoverable Petroleum Hydrocarbons (T RPH) EPA 1664 or EPA 1664 (SGT*) Other Type of analyses will be based upon the substance or product stored, and as approved by the DERR Division Director Method will be based upon the substance or product type Unknown Total Petroleum Hydrocarbons (purgeable TPH as gasoline range organics C6 - C10) EPA 8015 or EPA 8260 Total Petroleum Hydrocarbons (extractable TPH as diesel range organics C10 – C28) EPA 8015 Oil and Grease (O&G) or Total Recoverable Petroleum Hydrocarbons (T RPH) EPA 1664 or EPA 1664 (SGT*) Benzene, Toluene, Ethyl benzene, Xylenes, and Naphthalene (BT EXN) and MT BE; and Halogenated Volatile Organic Compounds (VOX) EPA 8021 or EPA 8260 1 The following modifications to these certified methods are considered acceptable by the DERR Division Director: • Dual column confirmation may n ot be required for TP H and BTEXN/MTBE analysis. • A micro-extraction or scale-down technique may be used for aqueous samples, but only for the determination of extractable TP H as diesel range organics (C10 – C28). • Hexane may be used as an extraction solvent. • *Silica Gel Treatment (SGT) may be used in the determination of Total Recoverable P etroleum Hydrocarbons. NOTE: The sample preparation method and any modification(s) to a certified method must be reported by the laboratory. Appendix D Chain of Custody and Laboratory Data Sheets The analyses presented on this report were performed in accordance with the National Environmental Laboratory Accreditation Program (NELAP) unless noted in the comments, flags, or case narrative. If the report is to be used for regulatory compliance, it should be presented in its entirety, and not be altered. Client Service Contact: 801.262.7299 Attn: Carver, Jeremy Work Order: 25A1942 Project: Murray - Lumen UST #61237057 1/30/2025 Approved By: Reed Hendricks, Lab Director 9632 South 500 West Sandy, Utah 84070 Serving the Intermountain West since 1953 801.262.7299 Main 866.792.0093 Fax www.ChemtechFord.com Page 1 of 4 xx Chemtech-Ford Laboratories Serving the Intermountain West Since 1953 Certificate of Analysis 9632 South 500 West Sandy, UT 84070 O:(801) 262-7299 F: (866) 792-0093 www.ChemtechFord.com Carver, Jeremy PO#: Receipt: Date Reported: Project Name: 1/28/25 13:25 @ 11.0 °C 1/30/2025 Murray - Lumen UST #61237057 Sample ID: MW-A Lab ID: 25A1942-01Matrix: Water Flag(s)Units Analysis Date/Time Date Sampled: 1/28/25 12:42 Preparation Date/Time Sampled By: Mark Lilly Minimum Reporting Limit MethodResult MBTEXn mg/L 1/28/251/28/250.005 EPA 8260D/5030BNDBenzene mg/L 1/28/251/28/250.012 EPA 8260D/5030BNDEthylbenzene mg/L 1/28/251/28/250.008 EPA 8260D/5030BNDMethyl-tert-butyl ether (MTBE) mg/L 1/28/251/28/250.012 EPA 8260D/5030BNDNaphthalene mg/L 1/28/251/28/250.012 EPA 8260D/5030BNDToluene mg/L 1/28/251/28/250.038 EPA 8260D/5030BNDXylenes, total Gasoline Range mg/L 1/28/251/28/250.125 EPA 8260B/C /5030A/[CALC]NDGasoline Range Organics Diesel Range mg/L 1/29/251/28/251.0 EPA 8015 CNDDiesel Range Organics Project Name: Murray - Lumen UST #61237057 CtF WO#: 25A1942 www.ChemtechFord.com Page 2 of 4Page 2 of 4 xx Chemtech-Ford Laboratories Serving the Intermountain West Since 1953 Certificate of Analysis 9632 South 500 West Sandy, UT 84070 O:(801) 262-7299 F: (866) 792-0093 www.ChemtechFord.com Carver, Jeremy PO#: Receipt: Date Reported: Project Name: 1/28/25 13:25 @ 11.0 °C 1/30/2025 Murray - Lumen UST #61237057 Report Footnotes Abbreviations ND = Not detected at the corresponding Minimum Reporting Limit (MRL). 1 mg/L = one milligram per liter or 1 mg/kg = one milligram per kilogram = 1 part per million. 1 ug/L = one microgram per liter or 1 ug/kg = one microgram per kilogram = 1 part per billion. 1 ng/L = one nanogram per liter or 1 ng/kg = one nanogram per kilogram = 1 part per trillion. On calculated parameters, there may be a slight difference between summing the rounded values shown on the report vs the unrounded values used in the calculation. Project Name: Murray - Lumen UST #61237057 CtF WO#: 25A1942 www.ChemtechFord.com Page 3 of 4Page 3 of 4 Jeremy Carver Per Andrew Turner request,bill Jeremy Carver.Send report to both Jeremy and Andrew. -rah-1/28/25 Page 4 of 4