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HomeMy WebLinkAbout7607_GreatOakMSWLF_tonnageincrease_SubstantailPermitAmend_FID1321743_2019053 2520 Whitehall Park Dr., Suite 450, Charlotte, NC 28273 | 704-504-3107 Environmental Consulting & Contracting May 31, 2019 File No. 02215305.10 Mr. Ming-Tai Chao, PE Division of Waste Management / Solid Waste Section North Carolina Department of Environmental Quality 1646 Mail Service Center Raleigh, North Carolina 27699-1646 ming.chao@ncdenr.gov Subject: Major Permit Modification Request for Daily Tonnage Increase Great Oak Landfill, Permit No. 7607-MSWLF-2015 Randolph County Dear Mr. Chao: On behalf of Randolph County and Waste Management of Carolinas, Inc., SCS Engineers, PC submits this request to modify the Facility Permit to change only the daily tonnage rate from 2,000 tons per day to 4,000 tons per day. No other changes are proposed at this time and all remaining parts of the Permit to Construct (PTC) Application for the existing permit are unchanged. To facilitate this change, the following are enclosed: • Revised Franchise Agreement (Attachment A) • Permit to Construct Application Great Oak Landfill cover sheet (Attachment B). A revision date and footnote were added. • Revised Facility Plan pages 9 and 11 to reflect the revised daily tonnage. (Attachment C). The Facility Plan (Section 3 of the PTC Application) for the Great Oak Landfill was originally submitted February 2015 and revised September 2015. • Revised Engineering Plan page 17 and Appendix II to reflect the revised daily tonnage (Attachment D). The Engineering Plan (Section 4 of the PTC Application) for the Great Oak Landfill was originally submitted February 2015 and revised September 2015. In addition, WM is currently working with Randolph County and NCDOT to post signage along approved access routes. During the process of completing this tonnage increase request, we became aware of an error in the original PTC and subsequent Permits to Operate. The Gross Capacity of the landfill stated in the original PTC (January 19, 2016, pages 9 and 15) was actually the Net Airspace volume as defined in Appendix II of the Engineering Plan. The corrected Gross Capacity volumes for each Phase of the landfill are tabulated in the revised calculation provided in Attachment D. Ming-tai Chao May 31, 2019 Page 2 We appreciate your assistance on this submittal. If you have any questions, please contact either Susan Harrison (WM) at 678-436-2719, or Steve Lamb (SCS) at 704-576-4731. Sincerely, Steven C. Lamb, PE Project Director/Vice President SCS Engineers, PC cc: Susan Harrison, Waste Management of Carolinas, Inc. Paxton Arthurs, Randolph County Encl. ATTACHMENTS ATTACHMENT A Revised Franchise Agreement ATTACHMENT B Permit to Construct Application Great Oak Landfill cover sheet PERMIT TO CONSTRUCT APPLICATION GREAT OAK LANDFILL WASTE MANAGEMENT OF CAROLINAS, INC. RANDOLPH COUNTY, NORTH CAROLINA Volume II S&ME Project Nos. 7235-14-001 and 7235-14-002 February 16, 2015 Revised October 21, 2015 Revised May 29, 20191 of Carolinas, Inc. 1 Sections 2.2 and 3.2 of the Facility Plan and 7.1.1 of the Engineering Plan were revised by SCS Engineers, PC to reflect a daily disposal increase from 2,000 tons per day to 4,000 tons per day. ATTACHMENT C Revised Facility Plan pages 9 and 11 FACILITY PLAN GREAT OAK LANDFILL RANDOLPH COUNTY, NORTH CAROLINA Prepared for: of Carolinas, Inc. 1850 Parkway Place Marietta, Georgia 30067 Prepared by: Charlotte, NC 28273 February 16, 2015 Revised September 21, 2015 Revised: May 29, 20191 1 Sections 2.2 and 3.2 were revised by SCS Engineers, PC to reflect a daily disposal increase from 2,000 tons per day to 4,000 tons per day. Facility Plan Great Oak Landfill S&ME Project No. 7235-14-001 Revised September 21, 2015 Revised: May 29, 20191 9 1 Section 2.2 was revised by SCS Engineers, PC to reflect a daily disposal increase from 2,000 tons per day to 4,000 tons per day. 2. WASTE STREAM 2.1 Types of Waste The types of waste specified for disposal include household waste, commercial solid waste and industrial solid waste as defined by 15A NCAC 13B .1602 of the Solid Waste Management Rules. 2.2 Disposal Rates1 The Great Oak MSWLF facility is currently permitted to receive an average daily intake and disposal rate of 4,000 tons per day or a maximum daily intake and disposal rate of 5,500 tons per day to account for times when intake rates peak, including periods when emergency debris management is required after floods, hurricanes, tornados or other such events. For an operating factor of 286 days per year, the annual disposal rate will be up to 1,144,000 tons per year. The disposal rate calculations are presented in the Engineering Plan. Future disposal rates may vary due to the population, industrial, and commercial growth within the region, recycling efforts, and/or availability of other landfills or alternative waste disposal methods. 2.3 Service Area Randolph County anticipates that the waste stream for the Great Oak MSWLF will be generated from residents, agricultural facilities, commercial businesses, and industrial facilities within the State of North Carolina. No out-of-state waste will be accepted. 2.4 Procedures for Segregated Management The landfill plans to accept typical waste streams for a fully permitted municipal solid waste (MSW) landfill in North Carolina, including: 1. Municipal Solid Waste (MSW); 2. Construction and Demolition (C&D) debris; 3. Waste water treatment plant (WWTP) sludge; 4. Asbestos containing material (ACM), properly packaged; 5. Commercial waste; 6. Industrial waste (solid, non-hazardous), a.k.a. special waste; 7. Shredded tires; 8. Off-spec food, animal carcasses (covered immediately for vector control); and 9. Non-regulated, non-infectious (treated) medical waste. The Great Oak MSWLF will implement a load checking program to detect and discourage disposal at the facility of unacceptable waste [.1626 (1)(f)]. The load checker and the load checking program will include random inspections [.1626 (1)(f)(i)] as described in the Operations Plan, located in Section 7, Volume III of the Permit to Construct Application. 2.5 Equipment Requirements The primary functions of heavy landfill equipment are as follows: • Spreading and compacting solid waste, • Excavating, hauling, and spreading cover material, and • General site maintenance. 11 Facility Plan Great Oak Landfill S&ME Project No. 7235-14-001 Revised September 21, 2015 Revised April 23, 20191 1 Section 3.2 was revised by SCS Engineers, PC to reflect a daily disposal increase from 2,000 tons per day to 4,000 tons per day. 3. LANDFILL CAPACITY AND SOIL RESOURCES 3.1 Data and Assumptions Landfill capacity calculations were performed for the Great Oak MSWLF from proposed grading and closure plans using the anticipated annual disposal rate data presented previously in Section 2.2 of this Facility Plan. The gross capacity consists of the volume between the top of the liner protective cover and the top of the final cover. Soil for construction, operation and closure of Phases 1-9 will be obtained from the excavation of the landfill footprint as well as from on-site borrow areas as needed. Landfill capacity and soil quantity estimates are discussed in the following sections of this Facility Plan. 3.2 Operating Capacity1 The gross capacity of the proposed Great Oak MSWLF is approximately 38.4 million cubic yards. The net airspace volume is approximately 37,800,000 cubic yards. Assuming 4,000 tons per day, 286 days a year, and a utilization factor of 0.75 tons/yd3, the estimated airspace utilization rate is approximately 1,525,333 cubic yards per year and the resulting estimated life of Phases 1 through 9 is approximately 24.8 years. In the table below are the estimated usable volumes and lifetimes of Phases 1-9: Phase Estimated Net Airspace (cubic yards) Estimated Lifetime (years) 1 6,978,961 4.58 2 6,161,656 4.04 3 4,216,559 2.76 4 1,378,226 0.90 5 5,032,069 3.30 6 1,828,832 1.20 7 3,530,065 2.31 8 4,282,475 2.81 9 4,392,158 2.88 TOTALS 37,801,001 24.78 3.3 Borrow and Required Soil Quantities Based on the borrow soil evaluation presented in the Engineering Plan, about 5.5 million cubic yards of soil will be required for construction, operation and closure of Phases 1-9 of the Great Oak MSWLF, while about 4.0 million cubic yards of soil will be generated during construction. Soil excess or deficit was estimated throughout the life of landfill Phases 1-9. There is a net deficit of soils during all events. The peak deficit of approximately 1.5 million cubic yards is during final closure. There is anticipated to be a deficit of stockpiled soil after Phase 1 operations of approximately 66,000 cubic yards. It is anticipated that during this event, additional soil will be obtained from on-site borrow sources. ATTACHMENT D Revised Engineering Plan page 17 and Appendix II ENGINEERING PLAN GREAT OAK LANDFILL RANDOLPH COUNTY, NORTH CAROLINA Prepared for: of Carolinas, Inc. 1850 Parkway Place Marietta, Georgia 30067 Prepared by: Charlotte, NC 28273 Revised October 21, 2015 Revised: May 29, 20191 1 Section 7.1.1 and Appendix II were revised by SCS Engineers, PC to reflect a daily disposal rate increase from 2,000 tons per day to 4,000 tons per day. Engineering Plan Great Oak Landfill S&ME Project No. 7235-14-001 October 21, 2015 Revised: May 29, 20191 17 1 Section 7.1.1 was revised by SCS Engineers, PC to reflect a daily disposal rate increase from 2,000 to 4,000 tons per day. 7. DESIGN ANALYSES The Phase 1 area has been evaluated for compliance with the requirements set forth in the Rules. A summary of the design analyses performed for the Phase 1 area is presented below and includes a brief discussion of the analytical methods, critical conditions, and assumptions used in the evaluations. Copies of the individual calculations are provided in the appendices and are grouped into the following categories: Appendix II: Landfill Capacity and Borrow Area Evaluation Appendix III: Stability Calculations Appendix IV: Geosynthetics and Leachate Generation Calculations Appendix V: LCS/LDS Piping Calculations Appendix VI: Stormwater Management Calculations Engineering Plan drawings can be referenced in Appendix I. 7.1 Landfill Capacity and Borrow Soil Quantities 7.1.1 Landfill Capacity1 The landfill capacity for the Phase 1 was estimated using the proposed grading and closure plans. The capacity of Phase 1, which consists of the airspace between the top of the protective cover soil and the top of final cover, was estimated to be on the order of 7,160,621 cubic yards. The net airspace volume for Phase 1 (measured between the top of the protective soil cover to the top of the intermediate cover) is approximately 6,978,960 cubic yards. Assuming 4,000 tons per day, 286 days a year, and a utilization factor of 0.75 tons/yd3, the estimated airspace utilization rate is approximately 1,525,333 cubic yards per year and the resulting estimated life of Phase 1 is approximately 4.58 years. At 3,000 tons per day, the estimated life of Phase 1 is 6.1 years. The capacity Phases 1 through 9 is estimated to be approximately 38,414,398 cubic yards. The net airspace volume is approximately 37,800,000 cubic yards. Assuming 4,000 tons per day, 286 days a year, and a utilization factor of 0.75 tons/yd3, the estimated airspace utilization rate is approximately 1,525,333 cubic yards per year and the resulting estimated life of Phases 1 through 9 is approximately 24.8 years. At 3,000 tons per day, the estimated life of Phases 1-9 is 33 years. 7.1.2 Borrow Soil Quantities Soil for construction, operation, and closure of the Phase 1 area and future phases will be obtained from the excavation of the landfill footprint. If sufficient material is not available, additional soil may be obtained from on-site borrow areas or off-site sources as needed. An evaluation of soil volumes available from site grading activities during construction and required for landfill operations and closure was performed. Based on the proposed grading plan for the Phase 1 area and conceptual grading plans for future phases, the available borrow soil quantities were estimated for each phase. These volumes were in turn compared with the required soil volumes needed for general site filling during construction, protective cover soil, operational and intermediate soil covers, and final covers. The soil demand APPENDIX II – Landfill Capacity and Borrow Area Evaluation •Landfill Capacity and Borrow Soil PROJECT NO. 7235-14-001 SHEET NO. 2 / 5 DATE 02/13/15 JOB NAME Great Oak Landfill COMPUTED BY IKB SUBJECT Landfill Capacity and Borrow Soil CHECKED BY JAM OBJECTIVE: This calculation estimates the airspace and lifetime for the Great Oak Landfill. This calculation also provides a comparison between on-site borrow soil supply and anticipated soil demand during operations and closure of the Great Oak Landfill, and estimates potential stockpiling requirements. METHOD: The total landfill airspace and on-site borrow soil supply were estimated by creating three-dimensional surfaces in AutoCAD Civil 3D 2015 to estimate volumes. Anticipated waste generation rates provided by Waste Management of Carolinas, Inc. and Randolph County were used to estimate remaining landfill lifetime. The comparison of soil demand to soil supply was evaluated by reducing the bank cubic yards excavated volume by 20 percent to account for soil shrinkage. ASSUMPTIONS: Operations soil and intermediate cover needs = 10% net capacity Shrinkage factor = 20% (Ref. 1) Protective cover = 2 ft Final cover = 2 ft Airspace utilization factor = 762,667 cy/yr (AUF = (2,000 tons/day x 286 operating days per year)/0.75 tons/cy) CALCULATIONS: Step 1: Estimate landfill airspace and lifetime. The approximate landfill airspace and lifetime was estimated by creating three-dimensional surfaces of the proposed cover grade, the proposed subgrade, and the existing grade in AutoCAD Civil 3D 2015. The gross airspace volume was estimated for each cell and phase by comparing the proposed protective cover and the proposed intermediate cover grade. The usable waste volume was estimated by deducting 10 percent of the net capacity due to operational and intermediate soil cover. The estimated lifetime was evaluated by dividing the net volume by an assumed airspace utilization factor of 762,667 cubic yards per year. The Phase 1 landfill airspace and lifetime was estimated as shown in the following table: * * * Daily disposal rate increased from 2,000 tons per day to 4,000 tons per day. This calculation was updated by SCS Engineers, PC (April 2019) 1,525,333 4,000 1,525,333 PROJECT NO. 7235-14-001 SHEET NO. 3 / 5 DATE 02/13/15 JOB NAME Great Oak Landfill COMPUTED BY IKB SUBJECT Landfill Capacity and Borrow Soil CHECKED BY JAM Cell Footprint Area (acres) Net Airspace Volume1 (cy) Protective Soil Cover (2-feet) (cy) Final Soil Cover (2-feet) (cy) Operational & Intermediate Soil Cover 2 (cy) Usable Volume (cy) Airspace Utilization3 (cy/year) Estimated Lifetime4 (years) Cell 1 15.5 1,305,256 50,013 50,013 130,526 1,174,731 762,667 1.7 Cell 2 10 727,625 32,267 32,267 72,763 654,863 762,667 1.0 Cell 3 11.6 994,612 37,429 37,429 99,461 895,151 762,667 1.3 Cell 4 4.8 786,784 15,488 15,488 78,678 708,105 762,667 1.0 Cell 5 4.6 1,144,835 14,843 14,843 114,484 1,030,352 762,667 1.5 Cell 6 5.0 769,484 16,133 16,133 76,948 692,536 762,667 1.0 Cell 7 4.8 1,250,364 15,488 15,488 125,036 1,125,328 762,667 1.6 TOTAL 56.3 6,978,961 181,661 181,661 697,896 6,281,065 -9.2 TABLE 1: PHASE 1 AIRSPACE AND LIFETIME 1. Estimated by comparing top of protective cover to top of intermediate cover. 2. 10% of Net Airspace Volume 3. Equal 2,000 tons/day*286 operating days/year/0.75 tons/CY 4. Net Airspace Volume divided by airspace utilization. The estimated landfill lifetime for Phase 1 is 9.2 years. The total landfill airspace and lifetime was estimated as shown in the following table: Phase Footprint Area (acres) Net Airspace Volume1 (cy) Protective Soil Cover (2-feet) (cy) Final Soil Cover (2-feet) (cy) Operational & Intermediate Soil Cover 2 (cy) Usable Volume (cy) Airspace Utilization3 (cy/year) Estimated Lifetime4 (years) Phase 1 56.3 6,978,961 181,661 181,661 697,896 6,281,065 762,667 9.2 Phase 2 21.8 6,161,656 70,341 70,341 616,166 5,545,491 762,667 8.1 Phase 3 27.1 4,216,559 87,443 87,443 421,656 3,794,903 762,667 5.5 Phase 4 10.4 1,378,226 33,557 33,557 137,823 1,240,404 762,667 1.8 Phase 5 23.0 5,032,069 74,213 74,213 503,207 4,528,862 762,667 6.6 Phase 6 11.4 1,828,832 36,784 36,784 182,883 1,645,948 762,667 2.4 Phase 7 15.9 3,530,065 51,304 51,304 353,007 3,177,059 762,667 4.6 Phase 8 11.0 4,282,475 35,493 35,493 428,247 3,854,227 762,667 5.6 Phase 9 13.2 4,392,158 42,592 42,592 439,216 3,952,942 762,667 5.8 TOTAL 190.1 37,801,000 613,389 613,389 3,780,100 34,020,900 -49.6 TABLE 2: LANDFILL AIRSPACE AND LIFETIME 1. Estimated by comparing top of protective cover to top of intermediate cover. 2. 10% of Net Airspace Volume 3. Equal 2,000 tons/day*286 operating days/year/0.75 tons/CY 4. Net Airspace Volume divided by airspace utilization. The total estimated landfill lifetime for Phases 1 through 9 is 49.6 years. Step 2: Evaluate borrow soil supply versus anticipated soil demand. Generally, excess soil will be generated and stockpiled during the construction phase, and then utilized during construction, operation, and closure of the landfill. The available amount of stockpiled soil will change during the lifetime of the landfill as phases are constructed (generating soil), and operated and closed (requiring soil). The soil supply and demand for assumed landfill events (such as phase construction, phase operation, phase closure, etc.) were evaluated. PROJECT NO. 7235-14-001 SHEET NO. 4 / 5 DATE 02/13/15 JOB NAME Great Oak Landfill COMPUTED BY IKB SUBJECT Landfill Capacity and Borrow Soil CHECKED BY JAM The approximate total cut and fill earthwork volumes were estimated by comparing three-dimensional surfaces of existing grade with the proposed subgrade in AutoCAD Civil 3D 2015. Unadjusted Total Cut (cy) Shrinkage Factor (percent) Adjusted Total Cut (cy) Total Fill (cy) Adjusted Net (cy) Phase 1 56.3 1,234,013 20%987,210 173,511 813,700 Phase 2 21.8 517,213 20%413,770 20,852 392,918 Phase 3 27.1 367,210 20%293,768 60,414 233,354 Phase 4 10.4 389,919 20%311,935 15,349 296,586 Phase 5 23.0 1,036,188 20%828,951 25,684 803,266 Phase 6 11.4 171,774 20%137,420 32,791 104,628 Phase 7 15.9 130,981 20% 104,785 83,873 20,911 Phase 8 11.0 160,024 20% 128,019 13,533 114,487 Phase 9 13.2 261,816 20% 209,453 72,604 136,849 Borrow Area 1 13.2 575,000 20%460,000 n/a 460,000 Borrow Area 2 2.9 125,000 20%100,000 n/a 100,000 Borrow Area 3 1.7 75,000 20%60,000 n/a 60,000 TOTAL 207.9 5,044,138 4,035,311 498,611 3,536,700 TABLE 3: SOIL GENERATION - BANK CUBIC YARDS Phase Phase Footprint Area (acres) Total Earthworks Step 3: Borrow soil supply versus anticipated soil demand. Anticipated soil demand assuming that protective cover consists of soil is described as follows: Construction Operations & Intermediate Soil Cover Volume (cy) Average Depth (ft) Volume (cy) Volume (cy) Fill Average Depth (ft) Volume (cy) Phase 1 56.3 173,511 2 181,661 697,896 2.0 181,661 1,234,730 Phase 2 21.8 20,852 2 70,341 616,166 2.0 70,341 777,700 Phase 3 27.1 60,414 2 87,443 421,656 2.0 87,443 656,955 Phase 4 10.4 15,349 2 33,557 137,823 2.0 33,557 220,286 Phase 5 23.0 25,684 2 74,213 503,207 2.0 74,213 677,318 Phase 6 11.4 32,791 2 36,784 182,883 2.0 36,784 289,242 Phase 7 15.9 83,873 2 51,304 353,007 2.0 51,304 539,488 Phase 8 11.0 13,533 2 35,493 428,247 2.0 35,493 512,767 Phase 9 13.2 72,604 2 42,592 439,216 2.0 42,592 597,004 TOTAL 190.1 498,611 -613,389 3,780,100 -613,389 5,505,490 TABLE 4: UNADJUSTED SOIL DEMAND TOTALPhase Phase Footprint Area (acres) Protective Cover Final Cover Soil The unadjusted soil demand is shown in Table 3. The landfill grading phase operations were evaluated by dividing the landfill operations for Phases 1 through 9 into 19 events (Events 1-19) as shown on Attachment 1. Soil excess or deficit was estimated throughout the life of landfill Phases 1 through 9. There is a net deficit of soils during all events. The peak deficit of approximately 1,470,179 cubic yards is during Event 19, final closure. PROJECT NO. 7235-14-001 SHEET NO. 5 / 5 DATE 02/13/15 JOB NAME Great Oak Landfill COMPUTED BY IKB SUBJECT Landfill Capacity and Borrow Soil CHECKED BY JAM Note that there is anticipated to be a deficit of total stockpiled soil after Event 1, Phase 1 operations of approximately 65,858 cubic yards. It is anticipated that during this event, additional soil will be obtained from on-site borrow sources. DISCUSSION: Based on soil material generation and demand estimates from S&ME’s experience, excess soil will be generated during the Phase 1 construction (Event 1) which may be used during Phase 1 operations (Event 2). For the Phase 1 operations condition where protective cover consists of soil, the volume of soil material demand exceeds the volume of available stockpile material by as much as 65,858 cubic yards, and the total soil deficit after the final closure is approximately 1,470,179 cubic yards. The net soil deficit will be obtained by excavating in on-site borrow sources, such as in the vicinity of the borrow areas 1 through 3. The estimated soil supply volume for the condition where protective cover consists of soil is presented in Attachment 1. It should be noted that the actual material volumes will vary from the estimated quantities presented based on conditions encountered in the field and actual landfill operations requirements. REFERENCE: 1. North Carolina Department of Transportation Roadway Design Manual, NCDOT, November 2007. Great Oak Landfill S&ME Project No. 7235-14-001 Stockpiled Soil Volume Start (cy) Soil Created (cy) Soil Used (cy) Stockpiled Soil Volume End (cy) Assumptions 1 Phase 1 Construction 0 987,210 355,172 632,038 2 Phase 1 Operations 632,038 0 697,896 -65,858 3 Phase 2 Construction -65,858 413,770 91,194 256,719 4 Phase 2 Operations 256,719 0 616,166 -359,447 5 Phase 3 Construction -359,447 293,768 147,857 -213,535 6 Phase 3 Operations -213,535 0 421,656 -635,191 7 Phase 4 Construction -635,191 311,935 48,906 -372,162 8 Phase 4 Operations -372,162 0 137,823 -509,985 9 Phase 5 Construction -509,985 828,951 99,897 219,068 10 Phase 5 Operations 219,068 0 503,207 -284,139 11 Phase 6 Construction -284,139 137,420 69,575 -216,294 12 Phase 6 Operations -216,294 0 182,883 -399,177 13 Phase 7 Construction -399,177 104,785 135,177 -429,570 14 Phase 7 Operations -429,570 0 353,007 -782,577 15 Phase 8 Construction -782,577 128,019 49,026 -703,583 16 Phase 8 Operations -703,583 0 428,247 -1,131,831 17 Phase 9 Construction -1,131,831 209,453 115,196 -1,037,574 18 Phase 9 Operations -1,037,574 0 439,216 -1,476,790 19 Final Closure -1,476,790 0 613,389 -2,090,179 - Borrow Area -2,090,179 620,000 0 -1,470,179 Total Total 4,035,311 5,505,490 -1,470,179 ATTACHMENT 1: SOIL STOCKPILE VOLUMES Event No. Event Description Total Earthwork 1 Chao, Ming-tai From:Lamb, Steve <SLamb@scsengineers.com> Sent:Friday, May 31, 2019 2:26 PM To:Chao, Ming-tai; Harrison, Susan Cc:paxton.arthurs@randolphcountync.gov Subject:[External] Request for Tonnage Increase - Great Oak Landfill Attachments:tonnage increase ltr to Ming.pdf CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to  report.spam@nc.gov    Ming:    I hope all is well.  Please find attached the tonnage increase request for Great Oak Landfill.    After your review, please give me a call if you have any questions or require any additional information.    Enjoy the weekend.    Steve Lamb, PE  Vice President  SCS Engineers  2520 Whitehall Park Drive, Suite 450  Charlotte, NC 28273  704‐504‐3107 (W)  704‐576‐4731 (C)    Driven by Client Success  www.scsengineers.com