NC0024201_Staff Comments_19940926

NPDES DOCUMENT SCANNING COVER SHEET
NC0024201
Roanoke River WWTP
NPDES Permit:
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Correspondence
Owner Name Change
Staff Comments
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
September 26, 1994
This document is printed on reuse paper - ignore any
content on the reYerse side

DIVISION OF ENVIRONMENTAL MANAGEMENT
September 26,1994
TO:
Construction Grants
FROM:
Rob Brown
Don Sa ,
Water I i y
SUBJECT: Roanoke Rapids Sanitary District
After reviewing the files and recalling our discussion, it is my opinion that
the current modifications in house (A to C for 503 upgrades) do not constitute
an expansion and therefore is not grounds to require the relocation to the
Roanoke River.
The Permit amendment issued 3/3/93 gave them until expiration or
expansion to relocate. If the region wants this evaluated further, I suggest
that they (or you) communicate this with the District. Of course, now is better
then waiting until 1997. We (Technical Support Branch) would like to
participate in the review of the study to principally ensure consistency with
similar situations.
The study results can be used to decide whether or not the relocation is
warranted at renewal, with or without a plant expansion, in accordance with
the current permit requirements.
cc: Raleigh Regional Office
Permits & Engineering Unit
Instream Assessment Unit
Bobby Blowe

Very truly yours,
G. Macon Reavis, Jr.
Superintendent
cc: Piedmont Olsen Hensley, Inc.
Mr. Tim Donnelly, Raleigh Regional Office
Roanoke Rapids Sanitary District
ilair *Ado.
P.O. Box 308 635 Hamilton Street Roanoke Rapids, North Carolina 27870 [phone]
August 10, 1994
Ms. Coleen H. Sullins, P. E.
Supervisor, Permits and Engineering Unit
Division of Environment Health and Natural Resources
Division of Environmental Management
P. O. Box 29535
Raleigh, North Carolina 27626-0535
Re: Roanoke Rapids Wastewater Treatment Plant
Application Number ACAD24201 060024.Z01
Dear Ms. Sullins:
As stated in the transmittal letter which accompanied the con-
tract documents delivered to your office on June 27, 1994, the
District received bids for this work on August 3, 1994. It is
the District's intention to issue Notice of Award to the low bid-
der at our Board's next meeting on August 16, 1994.
The existing sludge treatment system(s) presently meet all 503
Regulations with the exception of the vector attraction require-
ments. The contract specifications were written to ensure comple-
tion of this project by February 13, 1995. Beginning that date
the District would be in non-compliance with the VAR requirements
of the 503 Regulations for which this facility is being con-
structed.
Ro
Realistically, we would anticipate that de -bugging and start" of
the proposed system could extend the final acceptance until rch
15, 1995.
-u n
We would ask your assistance in issuing the Authorization -to on-
struct as soon as possible so that we can minimize the p to rial
for non-compliance for this facility.
bi

AUTHORIZATION TO CONSTRUCT
NPDES PERMIT
REPORT AND RECOMMENDATIONS
August 11, 1994
Project No.: ACA024201
SOC PRIORITY PROJECT: No
If Yes, SOC No.:
To: Sean Goris, Water Quality Permits and Engineering Unit
From: Randy 'Jones, Raleigh Regional Office
County: Halifax
Permit No: NC0024201
PART I - GENERAL INFORMATION
1. Facility Name and Current Address:
Mr. G. Macon Reavis, Jr.
Roanoke Rapids Sanitary District
PO Box 308
Roanoke Rapids, NC 27870
2. Date of most recent NPDES Staff Report (attach copy):
11/25/91 and copy attached
3. Changes since previous action on NPDES Permit:
N/A
4. Verify Discharge Point(s) on plans with current NPDES
Permit. List for all discharge points:
The discharge point is not identified on the A to C
plans. This modification involves only an expansion of
the facility and does not involve modifications to the
discharge point. The latitudes and longitudes specified
below are those previously specified on the NPDES permit
staff report.
Latitude: 36° 26' 10" Longitude: 77° 36' 34"
1

Attach a USGS map extract and indicate treatment facility sle
and discharge point on map:
A copy of the previously submitted map is attached.
U.S.G.S. Quad No.: B28NE U.S.G.S. Quad Name: Weldon
5. Treatment plant classification (attach completed ratings
sheet):
Class IV ; Ratings Sheet attached.
PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS
1. Existing treatment facility
a. What is the current permitted capacity of the
facility?
8.34 MGD
b.
Date(s) and construction activities allowed by
previous Authorizations to Construct issued in
the previous two (2) years:
N/A
c. What is the actual treatment capacity of the
current facility (design volume)?
d.
8.34 MGD
Please provide a description of existing or
substantially constructed wastewater
treatment facilities:
4
The existing 8.34 MGD treatment facilities
consist of a bar screen, comminutor, grit
chamber, bypass channel, dual primary clarifiers,
dual high rate trickling filters, triple aeration
basins, dual final clarifiers, a gravity
thickener, triple anaerobic digesters, lime
stabilization facilities, sludge storage basins
and tank, sludge drying beds, and all associated
pumps, meters, piping, valves, wiring, and
appurtenances.
2. Please provide a description of proposed wastewater
treatment facilities:
2

The proposed facilities consist of the installation of a
cylindrical fine screen and conveyor capable of handling 12
MGD for removing floating particulate or fibrous material from
the plant influent flow stream, the installation of 200 GPM
pumps in primary clarifiers 1 & 2, the installation of a new
150 GPM digester recirculation pump to circulate sludge
through the heat exchanger, the installation of a 300 GPM pump
in digester 3, the construction of three 12,000 gallon
capacity vector attraction reduction (VAR) tanks with
submersible mixers to maintain the blended slurry of thickened
waste activated sludge and calcium lime, the installation of
two 300-400 GPM pumps for the delivery of lime stabilized
waste activated sludge, the installation of a 75 GPM pump in
the primary sludge pump station, the installation of sonic
flow meters to measure the sludge and wastewater flow rates,
and all other appurtenances (some of the pump installations
include the removal of existing pumps).
3. Residuals handling and utilization/disposal scheme:
a. If residuals are being land applied, please
specify DEM permit no.:
WQ0001989
Residual Contractor: AMSCO
b. Residuals stabilization: By pH adjustment.
c. Landfill: N/A
d. Other disposal/utilization scheme (Specify): N/A
4. Important SOC, JOC or Compliance Schedule dates, if
applicable: (Please indicate):
N/A
3

III. EVALUATION AND RECOMMENDATIONS
The submitted information is for the construction of
additional facilities at the Roanoke Rapids Sanitary
District WWTF to include: tanks and ancillary equipment to
upgrade the lime stabilization treatment process to comply
with the 503 Vector Attraction Reduction Requirements, the
replacement and upgrade of existing sludge pumps and
digester recirculation pumps, and the replacement of the
existing influent bar screen with a cylindrical fine screen
and conveyor. The submitted plans/specifications have been
reviewed by personnel in the RRO. We recommend issuance of
the appropriate approval documents upon consideration of the
following comments:
1) Please be advised that this project is on a somewhat
tight time schedule;
2) The submitted specifications document is not
signed/sealed by an NC Professional Engineer;
3) Page 11930-2 of the specifications, numbers 1.5 A &
B refer to paragraphs 1.3.D. It appears that this
referral should be to paragraphs 1.3.E; and
4) Attached, for your information, is a copy of a
memorandum to the Construction Grants and Loans
Section. Please note that the first paragraph on
page 2 of the memorandum addresses the issue of
relocating the outfall. As stated in the
memorandum, the RRO has proposed a study to further
consider this previously specified requirement.
Signature oij Rep • •t Preparer
Quality Regional
Water Q y g pervisor
ACA024201
file: ACA24201.SR
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DIVISION OF ENVIRONMENTAL MANAGEMENT
RALEIGH REGIONAL OFFICE
June 28, 1994
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MEMORANDUM
TO
THROUGH
FROM : Randy Jones
Raleigh Regional Office Z.
SUBJECT : Roanoke Rapids Sanitary District
201 Facilities Plan
Halifax County
I was asked to review and comment on a document titled
"Amendment to the 201 Facilities Plan for the Roanoke Rapids
Sanitary District", which is dated March 1994, and was prepared by
Piedmont Olsen Hensley. I have reviewed this document and have
found that it addresses a multitude of issues that are generally
associated with the wastewater needs of the Roanoke Rapids Sanitary
District (RRSD) and specifically an upgrade of the Roanoke Rapids
WWTF.
Bobby Blowe, Chief
Construction Grants and Loans Section
Timothy Donnelly, P. E.
Water Quality Regional Supervisor
The primary objective of the amendment is to identify measures
that will enable the WWTF to meet future discharge limits and the
requirements of the 503 sludge regulations. In that regard,
optimization of plant operations is discussed along with specific
alternatives for upgrading the facilities treatment capabilities.
One of the conclusions that I find somewhat surprising is that
additional hydraulic capacity is not warranted at this time. The
document states that this conclusion was reached by reviewing the
long term records of the plant's hydraulic influent waste stream,
area population growth rates, and reduced water consumption by
large industrial water users in the area. My primary question
involves the projected population growth rates for the area, which
are low. The best that we can do is accept the projections as
developed by the experts.
In March 1993, the Division provided the RRSD with speculative
limits for the WWTF. These limits were based upon an expansion of
the facility to 12.0 MGD. The speculative limits included CBOD
limits of 17.0 mg/1 and 25.0 mg/1 summer and winter respectively,
-afecal coliform limit of 200 mg/1, and a total residual chlorine
limit of 28 micrograms/1. The speculative limits did not include
a specific limit for NH3-N.
E D
;a94
CTiOrt
THIS BELONGS TO QPF/P

Roanoke Rapids 201 Memorandum
June 28, 1994
Page 2
The present facilities do not have disinfection. The document
acknowledges that disinfection will be required in the future,
that a chlorine residual limitation will have to be met, and that
the permit requires the outfall to be relocated to the Roanoke
River. The RRO is having second thoughts about the relocation of
the outfall. We are proposing a study that will assess three
alternatives: (1) not -moving the outfall; (2) moving the outfall
downstream of the confluence of Chockoyotte Creek with the Roanoke
River; and (3) moving the outfall to the Roanoke River and
requiring a diffuser (this alternative will be expensive due to the
difficulty of construction). At the time that the document was
developed, the Interim Roanoke River New or Expanding Discharge
Policy was not developed, so the specified limits of that policy
were not available. This policy specifies BOD5 limits of 15.0 mg/1
and 30.0 mg/1 and NH3-N limits of 4.0 mg/1 and 8.0 mg/1 summer and
winter respectively. The letter which transmitted the speculative
limits in March 1993, stated that the relocation of the discharge
from Chockoyotte Creek to the Roanoke River prior to the current
permit's expiration date of May 31, 1997, would not affect the
current effluent limitations; therefore, it is not really clear to
me, but I must assume that the new and expanding policy would not
apply to this facility if no expansion is proposed.
The two construction alternatives that were evaluated
primarily focus on providing increased hydraulic aeration times.
The present retention time is approximately 4.2 hours. Alternative
1 proposes modifications that will result in approximately 9-10
hours of aeration time being provided. Alternative 2 proposes
modifications that will result in approximately six hours of
aeration time being provided. Alternative 2 is identified as the
accepted alternative. The document concludes that six hours of
aeration time will be satisfactory to achieve the anticipated
limits; however, as stated earlier, the question of the
applicability of the interim limits may be a factor.
Let me know if you wish to discuss this matter further.
file: RORAP201.ME

State of North Carolina
Department of Environment, Health and Natural Resources
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27604
James B. Hunt, Jr., Governor Jonathan B. Howes, Secretary.
March 3, 1993
Mr. G. Macon Reavis, Jr., Superintendent
Roanoke Rapids Sanitary District
Post Office Box 308
635 Hamilton Street
Roanoke Rapids, NC 27870
Dear Mr. Reavis:
Subject: NPDES Permit NC0024201
Roanoke Rapids Sanitary District
Halifax County
On January 29, 1993, the Division of Environmental Management issued NPDES Permit
No. NC0024201 to Roanoke Rapids Sanitary District. A review of the permit file has indicated
that an error was inadvertently made in the permit. Accordingly, we are forwarding herewith
modifications to the subject permit to correct the error. The modifications are as follows: Part III,
Condition J, has been modified to require that the outfall be relocated upon plant expansion or
upon permit renewal.
Please find enclosed the amended Special Conditions sheets which should be inserted
into your permit. The corresponding old sheets should be discarded. All other terms and
conditions contained in the original permit remain unchanged and in full effect. This permit
modification is issued pursuant to the requirements of North Carolina General Statutes 143-215.1
and the Memorandum of Agreement between North Carolina and the U. S. Environmental
Protection Agency.
If any parts, measurement frequencies or sampling requirements contained in this permit
are unacceptable to you, you have the right to an adjudicatory hearing upon written request within
thirty (30) days following receipt of this letter. This request must be in the form of a written
Regional Offices
Asheville Fayetteville Mooresville Raleigh Washington Wilmington Winston-Salem
704/251-6208 919/486-1541 704/663-1699 919/571-4700 919/946-6481 919/395-3900 919/896-7007
Pollution Prevention Pays•
�..
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone],15.
An Equal Opportunity Affirmative Action Employer

Page Two
Mr. Reavis
petition, conforming to Chapter 150B of the North Carolina General Statutes, and filed with the
Office of Administrative Hearings, Post Office Drawer 27447, Raleigh, North Carolina 27611-
7447. Unless such demand is made, this decision shall be final and binding.
If you have any questions concerning this permit modification, please contact Charles M. Lowe
at telephone number 919/733-5083.
Sincerely yours,
eston How d, Jr., P.E.
Acting Director
cc. Mr. Jim Patrick, EPA
Raleigh Regional Office
Permits and Engineering Files
.Central Files
Piedmont Olsen Hensley

Part III Permit No: NC0024201
F. CHRONIC TOXICITY PASS/FAIL PERMIT LIMIT (QRTRLY)
The effluent discharge shall at no time exhibit chronic toxicity using test procedures outlined in:
1.) The North Carolina Ceriodaphnia chronic effluent bioassay procedure (North Carolina
Chronic Bioassay Procedure - Revised *September 1989) or subsequent versions.
The effluent concentration at which there may be no observable inhibition of reproduction or
significant mortality is 1.3% (defined as treatment two in the North Carolina procedure
document). The permit holder shall perform quarterly monitoring using this procedure to
establish compliance with the permit condition. The first test will be performed after thirty days
from the effective date of this permit during the months of January, April, July and October.
Effluent sampling for this testing shall be performed at the NPDES permitted final effluent
discharge below all treatment processes.
All toxicity testing results required as part of this permit condition will be entered on the Effluent
Discharge Monitoring Form (MR-1) for the month in which it was performed, using the
parameter code TGP3B. Additionally, DEM Form AT-1 (original) is to be sent to the following
address:
Attention:
Environmental Sciences Branch
North Carolina Division of
Environmental Management
4401 Reedy Creek Road
Raleigh, N.C. 27607
Test data shall be complete and accurate and include all supporting chemical/physical
measurements performed in association with the toxicity tests, as well as all dose/response data.
Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine
is employed for disinfection of the waste stream.
Should any single quarterly monitoring indicate a failure to meet specified limits, then monthly
monitoring will begin immediately until such time that a single test is passed. Upon passing, this
monthly test requirement will revert to quarterly in the months specified above.
Should any test data from this monitoring requirement or tests performed by the North Carolina
Division of Environmental Management indicate potential impacts to the receiving stream, .this
permit may be re -opened and modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum
control organism survival and appropriate environmental controls, shall constitute an invalid test
and will require immediate retesting(within 30 days of initial monitoring event). Failure to
submit suitable test results will constitute noncompliance with monitoring requirements.
G. POLLUTANT ANALYSIS CONDITION
The pennittee shall conduct a test for pollutants annually at the effluent from the treatment plant.
The discharge shall be evaluated as follows: 1) A pollutant analysis of the effluent must be
completed annually using EPA approved methods for the following analytic fractions: (a)

purgeables (i.e., volatile organic compounds); (b) acid extractables; (c) base/neutral extractables;
(d) organochlorine pesticides and PCB's (e) herbicides; and (f) metals and other inorganics. The
Annual Pollutant Analysis Monitoring (APAM) Requirement Reporting Form A and
accompanying memo, to be provided to all discharges affected by this monitoring requirement,
describes the sampling and analysis requirements and lists chemicals to be included in the
pollutant analysis. This monitoring requirement is to be referred to as the "Annual Pollutant
Analysis Monitoring Requirement" (APAM).
(2) Other significant levels of organic chemicals must be identified and approximately
quantified. For the purpose of implementing this requirement, the largest 10 GC/MS peaks in the
purgeable base/neutral extractable, and acid extractable fractions (or fewer than 10, if less than
10 unidentified peaks occur) for chemicals other than those specified on the APA Requirement
Reporting Form A should be identified and approximately quantified as stated in the APAM
Reporting Form A instructions. This part (item 2) of the APAM requirement is to be referred to
as the "10 significant peaks rule").
H. ENGINEERING ALTERNATIVES ANALYSIS CONDITION
The permittee shall continuously evaluate all wastewater disposal alternatives and pursue the
most environmentally sound alternative of the reasonably cost effective alternatives. If the
facility is in substantial non-compliance with the terms and conditions of the NPDES permit or
governing rules, regulations or laws, the permittee shall submit a report in such form and detail
as required by the Division evaluating these alternatives and a plan of action within sixty (60)
days of notification by the Division.
J. OUTFALL RELOCATION CONDITION
The permittee is hereby advised that an Authorization to Construct shall be requested from the
Division of Environmental Management prior to plant expansion. Plans and specifications
submitted to the Division for review as part of the request for Authorization to Construct shall
include the relocation of the existing discharge from Chockoyotte Creek to the Roanoke River
proper. If plant expansion is not anticipated prior to permit expiration (May 31, 1997), the
Division shall require that the outfall be relocated from Chockoyotte Creek to the Roanoke River
proper upon permit renewal. This requirement shall be a condition of the renewed permit.

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DIVISION OF ENVIRONMENTAL MANAGEMENT
RALEIGH REGIONAL OFFICE
AUGUST 24, 1992
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MEMORANDUM
TO : Don Safrit, P.E., Supervisor
Permits and Engineering Unit
THROUGH : Arthur Mouberry, P.E.
Regional Supervisor, f, i
THROUGH 'mothy L. Donnelly, P.E.
Regional Water Quality Supervisor
FROM : Water Quality Staff
Raleigh Regional Office
SUBJECT :
ROANOKE RAPIDS SANITARY DISTRICT
DRAFT PERMIT
Halifax County
The Raleigh Regional Office has reviewed the subject draft
permit and requests the following changes/corrections be made:
1. Recommend the date for the relocation of the outfall to
the Roanoke River be placed in the permit.
2. Recommend that CBOD not be used instead of BOD. Tracking
this will be very difficult for the region.
3. Change the wording from "triple aeration basins" to
"three aeration basins" on item #1 of the supplement
page.
AM:BMc:bas
•
•

AC.12ig
SEP 16 1992
State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Marine Fisheries
P.O. Box 769 • Morehead City, North Carolina 2S ;57-0769
James G. Martin, Governor William T. Hogarth, Director
[phone]
7
William W. Cobey, Jr., Secretary
MEMORANDUM:
TO: A. Preston Howard, Jr.
THROUGH: Mike Street
FROM: Sara E. Winslow
SEP
SUBJECT: Comments on the notice of intent to issue State NPDES, _.
Permit No. NC0024201, Roanoke Rapids Sanitary District ::-
DATE: August 13, 1992
DIV. OF ENVIRONMENTAL. MGMNI
DIRECTOR'S OFFICE
The North Carolina Division of Marine Fisheries is concerned
with the continuing potential impacts of this domestic wastewater
discharge on the aquatic resources of Chockoyotte Creek and the
adjacent waters of the Roanoke River. The Divisions principle
concern is that the discharge goes directly into Chockoyotte
Creek, however the permitted discharge limits reflect the
assimilative capacity of the river (ie. 7Q10 flow of 1500.0 cfs).
Normally small streams, such as Chockoyotte Creek, in their
natural state are very productive. We realize the discharge is
only a short distance from the Roanoke River, but due to the flow
of the river much of the wastewater is retained in the creek and
slowly dispersed into the river. Particularly, during high flow
levels in the river the wastewaters may back up into the creek
and severely limit the aquatic resources.
We have been informed by the DEM Raleigh Regional Office
that the permit renewal does not contain provisions for
relocation of the discharge. Therefore, the Division recommends
that the discharge be relocated to the river because the point of
discharge and assimilative capacity of the creek is not adequately
•
reflected in the discharge permit limitations.
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DIVISION OF ENVIRONMENTAL MANAGEMENT
Raleigh Regional Office
July 15, 1992
Don Safrit, Supervisor
Permits and Engineering Unit
MEMORANDUM
TO:
THROUGH: Arthur Mouberry, P.E.
(e)
Regional Supervisor
THROUGP3,x Tim Donnelly, P.E.
Regional Water Quality Supervisor
FROM:
Rick Hiers
Environmental Engineer
SUBJECT: Roanoke Rapids Sanitary District
NPDES Permit No. NC0024201
Draft Permit Comments
Halifax County
REVIEW ENGINEER: Charles Lowe
This purpose of this memo is to provide regional comments on the
renewal permit which is about to be drafted again for the subject
facility. According to the files, a renewal permit was originally
drafted on December 5, 1991 and went to public notice on December 24,
1991. Based on the wasteload allocation, the stream flow/waste flow
ratio at the time was 80:1 (and this was in the river, not in the
creek where the facility actually discharges), requiring a fecal
coliform limitation by the then current standard operating procedures.
This office therefore recommended, and the draft permit included, an
interim period to allow the permittee time to install disinfection.
facilities in order to meet the fecal coliform limit, although such
installation was not listed in the supplement to the cover sheet. The
draft permit also included monitoring for fecal coliform during the
interim period, and a dechlorination requirement. The permittee then
responded in a letter to the Director dated January 22, 1992 with a
request to reconsider certain items in the permit prior to final
determination. Two of the requests were to allow a CBOD instead of a
BOD limit, and to correct the description of the treatment processes
at the facility, neither of which this office obj pted to. A third
request was to delete fecal coliform monitoring;_"durring the interim
period, at which time there would be no chlorinat,ion .which was also
•

acceptable to this office. The fourth request was to delete the
dechlorination requirement due to the dilution factor in the river.
Again, this office had no objections, although the discharge is
actually into Chockyotte Creek, and not the Roanoke River, as
aforementioned.
Somewhere along the project's change of hands in your office, the
issue seems to have become one of whether to require a fecal coliform
limit at all, although this office has no record of the permittee
requesting anything more than the four items above. It seems that the
permittee had accepted the fecal coliform limit and the disinfection
schedule since they did not object to those items in their letter. A
subsequent memo from the stream modelling group then recommended
effluent, upstream, and downstream monitoring for fecal coliform in
lieu of a limit, as called for by standard operational procedures for
existing discharges with a downstream flow to waste flow ratio of less
than 331:1, of which the permittee's was recalculated as 77:1 (again,
into the river and not the creek). This office then faxed comments to
your office, reiterating that we had recommended a disinfection
schedule in the original staff report, and further recommending that a
requirement to relocate the discharge to the river be included in the
supplement to the cover sheet in the draft permit.
Upon receiving a call from your office requesting final comments
before the issuance of the second draft permit, this office contacted
Mr. Macon Reavis, Superintendent of the Roanoke Rapids Sanitary
District, and discovered that your office sent a letter to the
Sanitary District's engineer stating that no fecal coliform limit
would be required in the new permit, and that there was concern in
previous years about chlorinating the effluent due to potential
chlorinated by-products resulting from Champion International's
industrial discharge upstream. This being the case, and as it now
appears to be policy, this office recommends that the draft permit be
issued without a fecal coliform limit and corresponding disinfection
schedule, even though this seems to be giving the permittee more than
they originally asked for. This office still recommends that the
supplement to the cover sheet include authorization to move the
discharge point to the river upon receiving an Authorization to
Construct to do so, since we have been modelling the discharge as if
it were into the river. Mr. Reavis was agreeable to moving the pipe
given time to do so.
If you have any questions regarding this memo, please give me a call.
AM:TD:RH:rh