HomeMy WebLinkAbout32348 XXX 115 12-15-2022 SWMR 4C-008EV7W40 OLT Inspection Report Environmental Landfill Inc UAD Environmental Landfill, Inc. : KQRW-TKQE-P5Z
Site Investigation Memo
Inspector: Otis Todd
Start Date: 12/15/2022 Completed Date: 12/29/2022
Inspection Information
1. Site Investigation Date 12/15/2022
2. Inspector Otis Todd @ Michael
Cruise
3. ADEM Complaint Number 4C-008EV7W40
4. Site Name Environmental Landfill,
Inc.
5. Physical Address
1317 Annie Lee Road,Trussville, AL 35173
6. Nearest City Trussville
7. County St Clair
8a. Site Coordinates Latitude 33.618734
8b. Site Coordinates Longitude -86.529356
9. Parcel Number 25-08-27-0-001-
003000, 25-05-22-0-
001-014000, 25-05-22-
0001-013002, 25-05-
22-0001-013001, 25-
05-22-0001-013000
10. Inspection Type Follow Up
11. Site Referred Yes
11a. Referred To ADEM Air Division
Contact Information 1
Contact Role Responsible Party
1. Name Environmental Landfill,
Inc.
2.Title Operators
3. Mailing Address 1 1317 Annie Lee Road
4. Mailing Address 2
5. City Trussville
6. State AL
1
ADEM Watermark
Environmental Landfill, Inc. : KQRW-TKQE-P5Z
Site Investigation Memo
Inspector: Otis Todd
Start Date: 12/15/2022 Completed Date: 12/29/2022
Contact Information 1
7. Zip Code 35173
8. Phone Number 205-369-7925
9. Email environmentallandfll@
yahoo.com
Contact Information 2
Contact Role owner, Responsible
Party
1. Name Russell Scott
2.Title
3. Mailing Address 1 4145 Black Jack Road
4. Mailing Address 2
S. City Trussville
6. State AL
7. Zip Code 35173
8. Phone Number
9. Email
Contact Information 3
Contact Role Property Owner
1. Name Russell Scott
Management Trust c/o
Carol Scott
2.Title
3. Mailing Address 1 1317 Annie Lee Road
4. Mailing Address 2
S. City Trussville
6. State AL
7. Zip Code 35173
8. Phone Number
2
ADEM Watermark
Environmental Landfill, Inc. : KQRW-TKQE-P5Z
Site Investigation Memo
Inspector: Otis Todd
Start Date: 12/15/2022 Completed Date: 12/29/2022
Contact Information 3
9. Email
ntact Information 4
Contact Role Complainant
1. Name Brian Jackson
2.Title
3. Mailing Address 1 1427 Annie Lee Road
4. Mailing Address 2
5. City Trussville
6. State AL
7. Zip Code 35173
8. Phone Number 205-283-4113
9. Email bjackson@alabamabarr
icade.com
tact Information 5
Contact Role Contact
1. Name James Mulkey
2.Title Fire Inspector
3. Mailing Address 1
4. Mailing Address 2
5. City
6. State AL
7. Zip Code
B. Phone Number
9. Email jmulkey@moodyalaba
ma.gov
Contact Information 6
Contact Role Contact
1. Name Chris Hall
s
ADEM Watermark
Environmental Landfill, Inc. : KQRW-TKQE-P5Z
Site Investigation Memo
Inspector: Otis Todd
Start Date: 12/15/2022 Completed Date: 12/29/2022
Contact Information 6
2.Title Captain
3. Mailing Address 1 911 Firefighter
Boulevard
4. Mailing Address 2
5. City Moody
6. State AL
7. Zip Code 35004
8. Phone Number 205-577-1628
9. Email chall@moodyalabama.
gov
Contact Information 7
Contact Role Contact
1. Name Carey Potter
2.Title BMP Coordinator/ RF
#1828
3. Mailing Address 1
4. Mailing Address 2
5. City
6. State AL
7. Zip Code
8. Phone Number
9. Email carey.potter@forestry.
alabama.gov
Contact Info lion 8
Contact Role Contact
1. Name Dan Dahlke
2.Title County Engineer
3. Mailing Address 1
4
ADEM Watermark
Environmental Landfill, Inc. : KQRW-TKQE-P5Z
Site Investigation Memo
Inspector: Otis Todd
Start Date: 12/15/2022 Completed Date: 12/29/2022
Contact Information 8
4. Mailing Address 2
5. City
6. State AL
7. Zip Code
8. Phone Number
9. Email jddahlke@stclairco.com
Information 9
Contact Role Contact
1. Name Patrice Kurzejeski
2.Title Director
3. Mailing Address 1
4. Mailing Address 2
5. city
6. State AL
7. Zip Code
8. Phone Number 205-884-6800
9. Email patricek@stcema.org
Contact Information 10
Contact Role Contact
1. Name James Hill
2.Title City Attorney for
Moody&Leeds
3. Mailing Address 1 2603 Moody Parkway
4. Mailing Address 2 Suite 200
S. City Moody
6. State AL
7. Zip Code 35004
5
ADEM Watermark
Environmental Landfill, Inc. : KQRW-TKQE-P5Z
Site Investigation Memo
Inspector: Otis Todd
Start Date: 12/15/2022 Completed Date: 12/29/2022
Contact Information 10
8. Phone Number
9. Email jhill@stclairlawgroup.co
m
lion 11
Contact Role Contact
1. Name Shane Woodham
2.Title Fire Specialist
3. Mailing Address 1
4. Mailing Address 2
S. City
6. State AL
7. Zip Code
8. Phone Number
9. Email Shane.Woodham@fore
stry.alabama.gov
Contact Information 12
Contact Role Contact
1. Name Tyler Givens
2.Title Work Unit Manager: St.
Clair,Talladega, Clay
and Randolph Counties
3. Mailing Address 1
4. Mailing Address 2
5. City
6. State AL
7. Zip Code
8. Phone Number
9. Email tyler.givens@forestry.a
labama.gov
6
ADEM Watermark
Environmental Landfill, Inc. : KQRW-TKQE-P5Z
Site Investigation Memo
Inspector: Otis Todd
Start Date: 12/15/2022 Completed Date: 12/29/2022
Contact Information 12
On-Site Contacts
On-Site Contacts
Name Title Phone Email comments
Tyler Givens work Unit tyler.9wensi0forestry.
Manager alabama. ov
Shane Woodham Fire Specialist shane.woodham@fore
stry.alabama. ov
Brian Jackson Complainant
Candice Jackson Complainant
Patrice Kurzejeski A.Clair patrimk@stcema.org
County EMA
Director
ames Mulkey Fire&Rescue jmulkey@moodyalaba
Inspector ma.gov
hris Hall Fire&Rescue chall@moodyalabama.
Captain ov
James Hill City of "hill@stclairlawgmup.c
Moody/Leeds om
Aftomey
Dan Dahlke St.Clair jddahlke@stdairm.co
County in
Engineer
Heather Carter jeffecron carterh@jcWl.org
County
Engineer
Site Investigation Details
1. Innocent Landowner No
2. Property Type Rural
3. Waste Description/Composition Other
3a. Specify Other Regulated solid waste
ash, scrap metal and
residual burned
rubbish
4. Estimated Volume of Regulated Solid Waste
Observation 12/15/2022
Determined:
10710: Removal & Response-Waste
Volume- Unauthorized Dump
7
ADEM Watermark
Environmental Landfill, Inc. : KQRW-TKQE-P5Z
Site Investigation Memo
Inspector: Otis Todd
Start Date: 12/15/2022 Completed Date: 12/29/2022
Site Investigation Details
Photo Taken: 12/15/2022 12:31:31 PM
Near southwest entrance of site,looking
southwest.
Photo Taken: 12/15/2022 12:31:34 PM
Near southwest entrance of site,looking
northeast.
Photo Taken: 12/15/2022 12:32:04 PM
Near southwest entrance of the site,looking
southwest.
8
ADEM Watermark
Environmental Landfill, Inc. : KQRW-TKQE-P5Z
Site Investigation Memo
Inspector: Otis Todd
Start Date: 12/15/2022 Completed Date: 12/29/2022
Site Investigation Details
Photo Taken: 12/15/2022 12:32:44 PM
Near southwest entrance of site,looking
northeast.Site office structure pictured.
Photo Taken: 12/15/2022 12:33:38 PM
Office structure near southwest entrance of site.
Photo Taken: 12/15/2022 12:33:41 PM
At office structure near southwest end of site,
looking southwest.
9
ADEM Watermark
Environmental Landfill, Inc. : KQRW-TKQE-P5Z
Site Investigation Memo
Inspector: Otis Todd
Start Date: 12/15/2022 Completed Date: 12/29/2022
Site Investigation Details
Photo Taken: 12/15/2022 12:33:48 PM
near office structure at southwest end of site,
looking northeast towards workshop.
Photo Taken: 12/15/2022 12:34:45 PM
Workshop looted on south-central area of site,
looking northeast.
Photo Taken: 12/15/2022 12:34:54 PM
Near workshop in south-central area of site,
looking northwest.
10
ADEM Watermark
Environmental Landfill, Inc. : KQRW-TKQE-P5Z
Site Investigation Memo
Inspector: Otis Todd
Start Date: 12/15/2022 Completed Date: 12/29/2022
Site Investigation Details
Photo Taken: 12/15/2022 12:34:56 PM
Near workshop in south-central area of site,
looking northeast.
Photo Taken: 12/15/2022 12:34:59 PM
Near workshop in south-central area of site,
looking west.
A
Photo Taken: 12/15/2022 12:35:48 PM
Near workshop in south-central area of site,
looking northeast.
11
ADEM Watermark
Environmental Landfill, Inc. : KQRW-TKQE-P5Z
Site Investigation Memo
Inspector: Otis Todd
Start Date: 12/15/2022 Completed Date: 12/29/2022
Site Investigation Details
Photo Taken: 12/15/2022 12:36:10 PM
Near workshop in south-central area of site,
looking southeast towards an adjacent residential
property.
Photo Taken: 12/15/2022 12:36:38 PM
South-central area of the site,looking east
Photo Taken: 12/15/2022 12:36:49 PM
_ North-central area of sae,looking northeast along
northern slope.
12
ADEM Watermark
Environmental Landfill, Inc. : KQRW-TKQE-P5Z
Site Investigation Memo
Inspector: Otis Todd
Start Date: 12/15/2022 Completed Date: 12/29/2022
Site Investigation Details
Photo Taken: 12/15/2022 12:36:51 PM
North- antral area of site,looking northeast along
northern slope.
Photo Taken: 12/15/2022 12:3]:10 PM
Fssures on north-central area of site,looking
north.Slope in this area beginning to give way.
Photo Taken: 12/15/2022 12:37:13 PM
Fssures on north-central area of site,looking
north.Slope in this area beginning to give way.
13
ADEM Watermark
Environmental Landfill, Inc. : KQRW-TKQE-P5Z
Site Investigation Memo
Inspector: Otis Todd
Start Date: 12/15/2022 Completed Date: 12/29/2022
Site Investigation Details
Photo Taken: 12/15/2022 12:37:15 PM
North-central area of site,looking north towards
adjacent residential property at bottom of
northern slope of site.
�_ _
Photo Taken: 12/15/2022 12:37:19 PM
North-central area of site,looking north towards
adjacent residential property at bottom of
northern slope of site.
Photo Taken: 12/15/2022 12:37:26 PM
North-central area of site,looking west along
northern slope.
t.a
14
ADEM Watermark
Environmental Landfill, Inc. : KQRW-TKQE-P5Z
Site Investigation Memo
Inspector: Otis Todd
Start Date: 12/15/2022 Completed Date: 12/29/2022
Site Investigation Details
Photo Taken: 12/15/2022 12:3]:33 PM
North-central area of site,looking west.
r � 1
Photo Taken: 12/15/2022 12:37:39 PM
North-central area of site,looking north towards
adjacent residential property.
Photo Taken: 12/15/2022 12:38:15 PM
North-central area of site,looking north towards
! adjacent residential property.
15
ADEM Watermark
Environmental Landfill, Inc. : KQRW-TKQE-P5Z
Site Investigation Memo
Inspector: Otis Todd
Start Date: 12/15/2022 Completed Date: 12/29/2022
Site Investigation Details
Photo Taken: 12/15/2022 12:38:19 PM
North-central area of site,looking northeast along
the slope at the time.Much of the north slope in
this area appeared to have slid down.
Photo Taken: 12/15/2022 12:90:05 PM
Pile of concrete in east area of site,looking
northeast.
Photo Taken: 12/15/2022 12:W:08 PM
Pile of concrete in east area of site,looking east
16
ADEM Watermark
Environmental Landfill, Inc. : KQRW-TKQE-P5Z
Site Investigation Memo
Inspector: Otis Todd
Start Date: 12/15/2022 Completed Date: 12/29/2022
Site Investigation Details
Photo Taken: 12/15/2022 12:W:38 PM
Pile of concrete in east area of site with a piece of
-i" metal condu¢protruding.
T
Photo Taken: 12/15/2022 12:W:59 PM
Drone snapshot at GPS 33.6201,-86.5266 near
the eastern end of the site:
Scrap metal observed within the wood ash and
solid waste ash
Photo Taken: 12/15/2022 12:41:34 PM
Northeast area of site looking northeast.
17
ADEM Watermark
Environmental Landfill, Inc. : KQRW-TKQE-P5Z
Site Investigation Memo
Inspector: Otis Todd
Start Date: 12/15/2022 Completed Date: 12/29/2022
Site Investigation Details
Photo Taken: 12/15/2022 12:42:08 PM
Northeast area of site,looking southeast.
Photo Taken: 12/15/2022 12:42:13 PM
Northeast area of site,looking northeast towards
northeast end of site.
Photo Taken: 12/15/2022 12:43:07 PM
Small fissure billowing smoke on northeast area
$ J--
of site.
- �fY
'v
18
ADEM Watermark
Environmental Landfill, Inc. : KQRW-TKQE-P5Z
Site Investigation Memo
Inspector: Otis Todd
Start Date: 12/15/2022 Completed Date: 12/29/2022
Investi ation Details
Photo Taken: 12/15/2022 12:43:22 PM
Drone snapshot at GPS 33.6199,-86.5266 along
the southern edge of the eastern end of the site:
Scrap metal obsenied within the wood ash and
solid waste ash
Photo Taken: 12/15/2022 12:43:43 PM
Northeast area of site,looking southwest along
southern slope.
Photo Taken: 12/15/2022 12:43:46 PM
Northeast area of site,looking west.
19
ADEM Watermark
Environmental Landfill, Inc. : KQRW-TKQE-P5Z
Site Investigation Memo
Inspector: Otis Todd
Start Date: 12/15/2022 Completed Date: 12/29/2022
Site Investigation Details
Photo Taken: 12/15/2022 12:4,09 PM
Northeast area of site,looking southwest along
southern slope.
Photo Taken: 12/15/2022 12:4,32 PM
Northeast area of site,looking south down
southern slope.
Photo Taken: 12/15/2022 12:4,41 PM
Northeast area of site,looking northeast towards
- east end of site.
20
ADEM Watermark
Environmental Landfill, Inc. : KQRW-TKQE-P5Z
Site Investigation Memo
Inspector: Otis Todd
Start Date: 12/15/2022 Completed Date: 12/29/2022
Site Investigation Details
Photo Taken: 12/15/202212:45:02 PM
Dron e snapshot at GPS 33.6199-86.5263 along
` pp the site's southern border near the eastern end:i,l Scrap metal and rubbish observed along the outer
^ A�( edge of the site.
n
o i
Photo Taken: 12/15/2022 12:45:03 PM
Northeast area of site,looking northeast down
northern slope.
Photo Taken: 12/15/2022 12:46:58 PM
Northeast area of site,looking east along
' I northern slope.
21
ADEM Watermark
Environmental Landfill, Inc. : KQRW-TKQE-P5Z
Site Investigation Memo
Inspector: Otis Todd
Start Date: 12/15/2022 Completed Date: 12/29/2022
Site Investigation Details
Photo Taken: 12/15/2022 12:48:19 PM
Northeast area of site,looking north down
northern slope.
Photo Taken: 12/15/2022 12:48:21 PM
Northeast area of site,looking west along
northern slope.
Photo Taken: 12/15/2022 12:48:43 PM
Northeast area of site,looking north down
northern slope.
22
ADEM Watermark
Environmental Landfill, Inc. : KQRW-TKQE-P5Z
Site Investigation Memo
Inspector: Otis Todd
Start Date: 12/15/2022 Completed Date: 12/29/2022
Site Investigation Details
Photo Taken: 12/15/2022 12:50:03 PlA
Northeast area of site looking northeast.Dirt
access road shown.
Photo Taken: 12/15/2022 12:51:27 PlA
Northeast area of site looking west along northern
slope.Adjacent residential property in north-
central area of site pictured in distance.
Photo Taken: 12/15/2022 12:52:03 PlA
Northeast area of site,looking east towards
northeast end of site.
Fr"
23
ADEM Watermark
Environmental Landfill, Inc. : KQRW-TKQE-P5Z
Site Investigation Memo
Inspector: Otis Todd
Start Date: 12/15/2022 Completed Date: 12/29/2022
Site Investi ation Details
Photo Taken: 12/15/2022 12:52:22 PM
Drone snapshot at GPS 33.6201,-86.5289 along
the northern edge of the site:
Scrap metal observed within the wood ash and
solid waste ash
s�
Photo Taken: 12/15/2022 12:54:04 PM
North-central area of site,looking northwest
towards adjacent residential structure.This
structure was damaged slightly during the initial
fire.
Photo Taken: 12/15/2022 12:54:27 PM
North-central area of the site looking northwest
Talong the northern slope.
24
ADEM Watermark
Environmental Landfill, Inc. : KQRW-TKQE-P5Z
Site Investigation Memo
Inspector: Otis Todd
Start Date: 12/15/2022 Completed Date: 12/29/2022
Site Investigation Details
Photo Taken: 12/15/2022 12:54:3]PM
North- entral area of site,looking northeast down
' the northern slope.
Photo Taken: 12/15/2022 12:55:33 PM
Drone aerial at GPS 33.6205,-86.5255 of the
northeast end of the site.
Photo Taken: 12/15/2022 12:55:56 PM
Drone aerial at GPS 33.6205,-86.5255 of the
northeast end of the site.
25
ADEM Watermark
Environmental Landfill, Inc. : KQRW-TKQE-P5Z
Site Investigation Memo
Inspector: Otis Todd
Start Date: 12/15/2022 Completed Date: 12/29/2022
Site Investigation Details
Photo Taken: 12/15/2022 12:58:32 PM
Fissure billowing smoke from the smolder in the
north-central area of the site.
Photo Taken: 12/15/2022 12:58:38 PM
Central area of site looking northwest.Slope in
this area appears to have settled and slid down.
Photo Taken: 12/15/2022 12:58:W PM
Central area of site,looking west towards western
end of site.
26
ADEM Watermark
Environmental Landfill, Inc. : KQRW-TKQE-P5Z
Site Investigation Memo
Inspector: Otis Todd
Start Date: 12/15/2022 Completed Date: 12/29/2022
Site Investigation Details
Photo Taken: 12/15/2022 12:59:22 PM
South-central area of site,looking northwest.Tap
of residential structure pictured on right.
Photo Taken: 12/15/2022 12:59:59 PM
Northwestern area of site looking north.Adjacent
residential structure at bottom of northern slope
in that area.
Photo Taken: 12/15/2022 1:00:02 PM
Northwestern area of site,looking northeast
towards adjacent hillside and residential
structures.
27
ADEM Watermark
Environmental Landfill, Inc. : KQRW-TKQE-P5Z
Site Investigation Memo
Inspector: Otis Todd
Start Date: 12/15/2022 Completed Date: 12/29/2022
Site Investigation Details
Photo Taken: 12/15/2022 1:00:05 PM
Western end of site,looking west towards
adjacent residential mobile home structure and
fissures billowing smoke from the smolder.
Photo Taken: 12/15/2022 1:00:19 PM
Western area of site looking south.Pile of
concrete pictured.
Photo Taken: 12/15/2022 1:00:23 PM
Fissure billowing smoke from the smolder in
central area of site.
28
ADEM Watermark
Environmental Landfill, Inc. : KQRW-TKQE-P5Z
Site Investigation Memo
Inspector: Otis Todd
Start Date: 12/15/2022 Completed Date: 12/29/2022
Site Investigation Details
Photo Taken: 12/15/2022 1:00:29 PM
Fissures billowing smoke from the smolder in
south-central area of site.
Photo Taken: 12/15/2022 1:02:30 PM
Honor box and signage looted in south-central
area of site.
e
Photo Taken: 12/15/2022 1:10:03 PM
Residential property looted directly adjacent and
south of the central area of she,looking
northeast.
29
ADEM Watermark
Environmental Landfill, Inc. : KQRW-TKQE-P5Z
Site Investigation Memo
Inspector: Otis Todd
Start Date: 12/15/2022 Completed Date: 12/29/2022
Site Investigation Details
Photo Taken: 12/15/2022 1:10:05 PM
Residential property located directly adjacent and
south of the central area of she,looking northeast
towards eastern end of site.
Photo Taken: 12/15/2022 1:10:08 PM
Residential property located directly adjacent and
.. �.' south of the central area of she,looking north
towards southern slope of site.
f1 +/
Photo Taken: 12/15/2022 1:13:30 PM
GASP air monitoring station located at the south
adjacent residential property.
�-
30
ADEM Watermark
Environmental Landfill, Inc. : KQRW-TKQE-P5Z
Site Investigation Memo
Inspector: Otis Todd
Start Date: 12/15/2022 Completed Date: 12/29/2022
Site Investigation Details
Photo Taken: 12/15/2022 1:13:35 PM
GASP air monitoring station located at the south
adjacent residential property.
Photo Taken: 12/15/2022 1:33:54 PM
Burned residual rubbish,scrap metal and solid
waste ash observed at the western end of the
'•i site,looking towards southwestern slope.
Photo Taken: 12/15/2022 1:34:05 PM
Solid waste ash and scrap metal observed at the
western end of the site,looking towards
southwestern slope.
'Y •�.a-.
31
ADEM Watermark
Environmental Landfill, Inc. : KQRW-TKQE-P5Z
Site Investigation Memo
Inspector: Otis Todd
Start Date: 12/15/2022 Completed Date: 12/29/2022
Site Investigation Details
Photo Taken: 12/15/2022 1:34:32 PM
Bricks,solid waste ash and wiring observed at
western end of site.
Photo Taken: 12/15/2022 1:35:07 PM
Bricks,solid waste ash and wiring observed at
southwestern end of site.
Xe a
Photo Taken: 12/15/2022 1:36:03 PM
Scrap metal and residual rubbish observed in the
smolder of the southwestern end of site.
32
ADEM Watermark
Environmental Landfill, Inc. : KQRW-TKQE-P5Z
Site Investigation Memo
Inspector: Otis Todd
Start Date: 12/15/2022 Completed Date: 12/29/2022
Site Investigation Details
Photo Taken: 12/15/2022 1:36:22 PM
Reber,scrap metal and solid waste ash observed
in the smolder of the southwestern end of site.
4a. Regulated Solid Waste Unit Cubic Yard
5. Number of Scrap Tires
6. Inspector Comments
O. Todd and M. Cruise, along with representatives from the City of Moody, the St. Clair County
Commission,the St. Clair County Emergency Management Agency,and the Alabama Forestry
Commission,visited the site to evaluate its current condition. The sky was clear and the winds were
blowing northeast at the time of inspection. There were numerous obvious surface fractures and
collapsed places, and the site had been completely devoured by fire, with the exception of some
areas on the surface. Throughout the site, areas of subsurface smolder emissions were visible. An
exact volume of regulated solid waste could not be calculated at the site given its current condition.
Scattered about the site, however,there was some rebar, scrap metal, rubbish residue, and solid
waste ash. Once the site has been pronounced safe by the authorities in charge of putting the fire
out, a more detailed inspection will be carried out.
3. Mulkey of the City of Moody's Fire& Rescue Team captured real-time aerial photos using a drone
that was launched from a neighboring property with permission from the property owner.
Site Ranking Criteria
1. Site Proximity To The Following: (Within View Of Site) Churches,Other
Populated Structures,
Utilities
2. Known Presence Of Human/Animal Infections Or Diseases? Undetermined
3. Fire Hazard (Lack Of Availability Of Adequate Water, Yes
Location/Composition Of Tire Piles)?
4. Suspected Presence Of Special Waste (ADEM Admin. Code R. 335-13-4 Undetermined
-.26)?
33
ADEM Watermark
Environmental Landfill, Inc. : KQRW-TKQE-P5Z
Site Investigation Memo
Inspector: Otis Todd
Start Date: 12/15/2022 Completed Date: 12/29/2022
Site Ranking Criteria
5. Environmental Justice Area? No
6. Adverse Impacts To Surface Water? Undetermined
7. U.S. Army Corps Of Engineers Wetland Referral? No
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ADEM Watermark