19860240 Ver 1_COMPLETE FILE_19860504

Permit Class'
New STATE OF NORTH CAROLINA
Department of Natural Community Development
FQ .
® Mal N 1 ?r
Conc
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® Fxcavatio )%
Issued to
to NCGS 113-229
Permit Number
224-86
authorizing development in Beaufort County at South Creek (travercet frpPk hetween
Sandy Landing & TG clay pond) as requested in the permittee's application dated 6/11186 including
attached plats, 3- w/sheet, DOG-029-011 dated 5/26/86, AOG-030-143 dated 418186 and AOG-
030-145 dated 4/22/86
This permit, issued on 11/2 /V g , is subject to compliance with the application (where consistent
with the permit), all applicable regulations, special conditions and notes set forth below. Any violation of these terms may subject
permittee to a fine, imprisonment or civil action; or may cause the permit to be null and void.
Construction
(1) In order.to protect juvenile shrimp and finfish populations, no excavation
or filling will be-- permitted between 1 February and 30 November of any
year without the prior approval of the Division of Coastal Management.
(2) No marsh grass will be excavated and/or filled.
(3) If excavation is conducted by a dragline on a barge, all spoil materials will
be retained on the barge, until unloaded at a site approved by a
representative of the Division of Coastal Management-
(4) If excavation is conducted by a hydraulic dredge, all spoil materials will
be pumped into one of the existing clay ponds. The DCM will be notified
as to which pond will be used. The DCM will subsequently decide if a given
(See attached sheet for Additional Conditions)
This permit action may be appealed by the permittee
or other qualified persons within twenty (20) days of the
issuing date. An appeal requires resolution prior to work
initiation or continuance, as the case may be.
This permit must be accessible on-site to Department
personnel when the project is inspected for compliance.
Any maintenance work or project modification
not covered hereunder requires further Departmental
approval.
All work must cease when the permit expires on
December 31, 1989
In issuing this permit, the State of North Carolina
agrees that your project is consistent with the North
Carolina Coastal Management Program.

Signed by the authority of the Secretary of DNRCD and
the Chairman of the Coastal Resources Commission.
f David W. Owens, Director
Division of Coastal Management
This permit and its conditions are hereby accepted.
Signature of Permittee

, L,

Texasgulf Chemicals Company
ADDITIONAL CONDITIONS
site is in keeping with this permit.
Permit #
Page 2 of 3
(5) All excavated materials will be confined above mean high water and landward
of regularly or irregularly flooded marsh behind adequate dikes or other
retaining structures to prevent spill-over of solids into any marsh or
surrounding waters.
(6) The disposal area effluent will be contained by pipe, trough or-similar device
to a point at or below the normal water level to prevent gully erosion and
unnecessary siltation.
(7) The terminal end of the pipeline will be positioned at or greater than fifty
(50) feet from any part of the dike and a maximum distance from spillways to
allow settlement of suspended solids.
(8) A water control structure will be installed at the intake end of the effluent
pipe to assure compliance with water quality standards.
(9) Maximum excavation that will occur on the west bank of South Creek is 1000'
in length,14' in width,and 8' in depth at normal water.
_(10) Maximum excavation that will occur on the east bank of South Creek is 400' in
length,14' in width,and 8' in depth at normal water.
(11) Only clean washed sand may be used to cover the pipeline once installed at
the shore approaches.
(12) The monitoring system on the casing pipe will be installed and operable prior
to the pumping of any clays through the pipeline.
NOTE: An Easement is required for this project. Such Easement must be approved by
the Council of State through the Dept. of Administration's State Property
Office prior to pipe installation.
NOTE: In the event that any excavation must be performed on any portion of the
clay pond dike, the activity must be performed in accordance with the
provisions of the Dam Safety Act.
Monitoring
(13) Every six months after the pipeline is in place, a survey similar to DOG-029-010
dated 6-19-86 which was conducted for the 18" pipeline project, will be
conducted for the project authorized herein. This survey will continue
indefinitely until the Division of Coastal Management is satisfied that the
pipeline is settled permanently and no movement is occurring. If the data
shows a shift in the pipe, all pumping activities will cease immediately, and
will not begin again until approval is given by the Division of Coastal Manage-
ment.
NOTE: The Division of Environmental Management, on October 10, 1986, issued an
,?-4

State of North Carolina
Department of Natural Resources and Community Development
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor R. Paul Wilms
S. Thomas Rhodes, Secretary Director
October 10, 1986
Mr. Douglas G. Mercer, Superintendent
Safety and Environmental Department
Texasgulf Chemicals Company
Post Office Box 48
Aurora, North Carolina 27806
SUBJECT: Authorization to Construct
Proposed 30-inch Clay Transfer Line
Texasgulf Chemicals Company
Beaufort County
Dear Mr. Mercer:
A letter of request for Authorization to Construct was received September
23, 1986, by the Division and final plans and specifications for the subject
project have been reviewed and found to be satisfactory. Authorization is
hereby granted for the construction of approximately 4000 feet of 30-inch OD
steel pipe with a 26-inch OD.high density polyethylene liner, concrete anchor
weights, 2-inch blow-off line for determining leaks, and all associated piping,
valves and appurtenances including necessary equipment for testing, to trans-
port clay slurry beneath South Creek subject to the following conditions:
1. Prior to operating the transfer line, a hydrostatic test at
150% of the maximum operating pressure must be conducted on
both the steel pipe and the polyethylene liner. Mr. Jim
Mulligan, Washington Regional Office Supervisor, shall be
notified at least 48 hours prior to conducting this test so
that a staff member can be made available to observe the test
and confirm its completion. This test shall be repeated once
per quarterly with the results submitted to the Washington
Regional Office within the month following the test.
Pollution Pfrutntion Pays
AD Banc 27687, Kaki North caohm 276117667 TdVhow 919-7337015

Mr. Douglas G. Mercer
October 10, 1986
Page 2
2. Daily visual inspections of the blow-off line shall be made
to determine if the 26-inch polyethylene line is leaking.
If a leak is detected, the use of this transfer line shall
be terminated immediately and Mr. Jim Mulligan shall be
notified.
Upon satisfactory completion of the on-site inspections listed in Item 1
above, Mr. Mulligan will provide written authorization to proceed with the
operation of the line.
This Authorization to Construct is issued in accordance with Part III,
Paragraph C of NPDES Permit No. N00003255 issued December 16, 1981, and shall
be subject to revocation unless the facilities are constructed and operated
in accordance with the conditions and limitations specified in Permit No.
N00003255.
In the event the facilities fail to perform satisfactorily, the permittee
shall take such immediate corrective action as may be required by this Division,
including the elimination of the use of this line.
One set of approved plans are being forwarded to you. If you have any
questions or need additional information, please contact Mr. Jim Mulligan,
Washington Regional Office Supervisor, at [phone].
Sincerely,
R. Paul Wilms
Director
cc: Jim Mulligan
Arthur Mouberry

DIVISION OF ENVIRONMENTAL MANAGEMENT
Water Quality Section
September 26, 1986
M E M O R A N D U M
TO: John Parker
Bill Mills )Qj-?
FROM:
SUBJECT: Application for CAMA Permit
Texasgulf Chemicals, Inc. - New Pipe
Beaufort County
The Subject application has been reviewed for water
quality impacts and the following comments are offered:
1. The project will require a 401 Certification but
does meet the requirements for general
certification No. 1273 for effluent discharges
from upland diked disposal areas.
2. The transfer pipeline will require approval from
this Division in the form of an Authorization to
Construct under the current NPDES permit. Such
authorization will be based on submission and
review of detailed plans and specifications for
the transfer facilities since they are part of the
Company's wastewater collection and treatment
facilities.
3. It is recommended that final action on the CAMA
permit be held pending the issuance of the
Authorization to Construct.
BM/dkb
cc: Jim Mulligan
Vla '
NKDA'T'A DF/CAMA/401 REV DATE 07/22/86
ACTION > ADD FILE > DFCAMA401 PSWD > FORMAT > NRD1=LAMA NEXT RCD > 00084
ACTION = ADD. ENTER THE DATA TO BE STORED FRD DATA
PROJ0 00083 PROJ : TEXAS GULF COUNTY: BEAUFORT REGION: 07
ASSIGNED TO: WJM oJ11P JOINT NOTICE: N
TYPE CERTIFICATION RECOMMENDATION DATES YYMMDD
404 PN : 401 REQ : ISSUE: RECEIVED: 860701:1
CAMA ONLY: GC: UPLAND DIKE DENY: INITIAL REPORT: 86072
DF/CAMA : Y GC: HOLD: Y•. FINAL REPORT:
RECEIVING STREAM: SOUTH CREEK CLASS: SA BASIN: TAR
COMMENTS:
TG PROPOSES TO PLACE A NEW CLAY TRANSFER PIPELINE ACROSS SOUTH CREEK
THE PROPOSAL INVOLVES THE PLACEMENT OF A 30--INCH STEEL CASING ALONG 'T'HE. BOTTOM
OF SOUTH CREEK APPROX. 100 F'T' DOWNSTREAM OF THE EXISTING SAND TAILINGS LINE
THE 30-INCH LINE WILL BE ANCHORED WITH CONCRETE ANCHORS; THE ACTUAL_ TRANSFER
LINE WELL BE A 26-INCH POLYETHYLENE F'IF'E ENCASED WITHIN THE 30--INCH LINE.
THE PLACEMENT OF THE NEW LINE WILL REQUIRE THE EXCAVATION OF A TRENCH ON TIME
WEST SIDE 1000 X 14 X 8 FT DEEP AND ON THE EAS'T' SIDE 400 X 14 X 8 F'T' DEEP
ALL. SPOIL.. WILL. ICE PLACED ON HIGH GROUND OR IN A DIKED AREA AS REQUIRED BY
CAMA PERMIT CONDITIONS--ADDITIONAL COMMENTS PENDING
COPIES: WARO°-CENTRAL-MILLS•-GOSSETT
RE CEI. ED
I'll- 2 3 1986
1Mklhi QUhL f Y ?kCfl0t4
OPERATIONS BRANCH
OFFICE OF COASTAL MANAGEMENT
FIELD INVESTIGATION REPORT
1. Applicant's name Texasgulf Chemicals Company
2. Location of project site Beaufort Count,, South Creek, at site of existing clay pumps,
photo number 12-19-84, 70-100 1-19, J-19
3. Investigation type: Dredge & Fill X CAMA X
4. Investigative procedure: (A) Dates of site visit 6-13-86
(B) Was applicant present es
5. Processing procedure: Application received 6-26-86 Office Washington
6. Site description: (A) Local Land Use Plan Beaufort County
Land classification from LUP Conservation
Development constraints identified in LUP None
(B) AEC(s) involved: Ocean Hazard Estuarine shoreline X
Coastal wetlands Public trust waters
Estuarine waters X Other
(C) Water dependent: Yes No X Other
(D) Intended use: Public Private X Commercial
(E) Type of waste water treatment: Existing N/A
Planned N/A
(F) Type of structures: Existing N/A
Planned N/A
(G) Estimated annual rate of erosion N/A Source N/A
7. Habitat description: AREA
(A) Vegetated wetlands: Dtedged Filled Other
None N/A N/A
(B) Non=vegetated wetlands:
(C) Other:
Open water ± 19,600 sq.ft.
Pipeline (width, length) + 112,500 sq.ft.
(D) Total area disturbed:. + 19,600 sq.ft. + 112,500 sq.ft.
8. -Project summary The applicant is proposing to place a 30" clay transport pipeline
underneath South Creek from Sandy Landing to the existing clay pond system.

Environmental setting
A part of Texasgulf's phosphate
clay material from the mill to
South Creek. The transporting
pipeline underneath South Creek
in this pipeline was discovered
inoperable. This pipeline went
Project proposal
operations in Beaufort County is the transportation of
the existing clay disposal ponds on the south side of
of these materials has been through a 30" sub-aqueous
since the mid 1960's. On 16 February 1986 a rupture
which resulted in the transporting system being
from the existing pumping station to clay pond no. 1.
The applicant is proposing to abandon the ruptured pipeline and replace it with a new
30" pipeline. This new pipeline will be a sub-aqueous line and will extend underneath
South Creek from the existing pumping station to clay pond no. 5, a distance of
+ 3,570 feet. The proposed pipeline will be placed + 100' downstream of an existing
T8" sandtailings pipe which exists underneath South Creek.
The company reviewed several alternatives in regards to the type of pipe to be used
and in regards to construction methods.
The chosen pipe alternative consists of a 26 inch polyethylene pipe inside of a 30 inch
steel casing. The pipeline will be buried the entire length of the crossing. It is
felt that heavy ballasting of the pipeline will result in its sinking, except at the
east and west banks of the creek where the bottom consists of hard sand. At these
locations excavation will be needed. On the west bank a trench will be excavated 1000'
in length by 14' in width and to a depth of -8' at normal water level. On the east
bank a trench will be excavated 400' in length, by 14' in width and also to a depth of
-8' at normal water level. This excavation will be conducted either by a dragline
on a barge or by a hydraulic dredge.
Also proposed is the pressure testing of the pipeline prior to its use and a monitoring
system will be implemented to signal a failure in the pipe system.
Environmental impact
The project as proposed should have a minimal environmental impact. Impacts will
occur if the new line becomes ruptured resulting in a clay spill into South Creek.
David U. Gossett - Washington Office - 8 July 1986
® Texasgulf Chemicals Co. A Division of Texasgulf Inc.
P.O. Box 48 Aurora, North Carolina 27806
Phosphate Operations
[phone]
June 10,, 1986
Mr. David Gossett
Division of Coastal Management
Post Office Box 1507
Washington, North Carolina 27889
Dear Mr. Gossett:
As you know, on February 16, 1986, Texasgulf had a
failure in the sub-aqueous pipeline used to transport clay
material from the Mill area to the clay disposal pond
system located near the confluence of South and Bond Creeks.
Since that time, a number of options have been evaluated
which would allow continued pumping of clays to the disposal
area. These options have included repairs to the existing
pipe, lining the existing pipe, use of an existing 18" line,
or installation of a new line.
After careful consideration, the installation of a new
30" lined pipe has been determined to provide maximum long
range protection to the environment while having minimum
impact during installation. Our evaluations have been
carefully reviewed by Henry Von Oesen and Associates of
Wilmington and they agree with our evaluations. Attached
is a letter from Paul Denison of Von Oesen providing this
concurrence.
The proposed line will extend from the existing pumping
facility (Sandy Landing) parallel to the existing sand
tailings line to the No. 5 Clay Pond area. Some excavation
in the shallow water near each shore will be necessary to
allow the pipe to be placed below the creek bottom. The
method of excavation will be determined by the contractor,
but the method will be restricted to a dredge or a barge
mounted clamshell or similar equipment. If a dredge is used,
the spoils will be placed in the existing clay pond system.
If•a clamshell is used, we plan to place the spoil adjacent to
the cut for return after the pipe is in place.
(ATg Mr. vossett - 2 - June 10, 1986
As indicated in Mr. DenisonIs letter and the geotechnical
report by Soils and Material Engineers, Inc. (page 5), the
pipeline is expected to immediately settle several feet into
the bottom silts once the pipeline is away from the narrow
strip of firm bottom at each shoreline. The pipe will also be
weighted to promote additional settling.
If you have any further questions about this application,
please contact me.
Sincerely,
V??eA-
Douglas G. Mercer, Superintendent
Safety & Environmental Department
DGM:ec
cc: Mr. D. F. DeLong
Mr. G. W. Whitaker
Mr. F. H. Robinson
Mr. L. W. Pullen
Mr. R. B. Catlett
00-04-000
12-03-001-20
11-02-001-24
l

APPLICATION
FOR
PERMIT TO EXCAVATE AND/OR FILL
WATER QUALITY CERTIFICATION
EASEMENT IN LANDS COVERED BY WATER CAMA PERMIT FOR MAJOR DEVELOPMENT
Department of Administration State of North Carolina Department of the Army
(GS 146-12) Department of Natural Resources and Community Development CorpsW,Engineers, Wilmington Dist
(GS 113-229, 143-215.3(a)(1), 143-215.3(c), 113A-118 (33 CFk?09 320-329)
i? ?,rc
Please type or print and fill in all blanks. If information is not applicable, so indicate by placing KtA in bk#nk.
1. Applicant Information
A Texasgulf Chemicals Company
A. Name
Post OH1ice Box 48 First Middle
B. Address
Street, P. 0. Box or Route
Aurora, North Carolina 27806 (919) 322-411
City or Town State Zip Code Phone
11. Location of Proposed Project:
A. County Beaufort
B. 1. City, town, community or landmark Sandy Landing To Clay Pond
2. Is proposed work within city limits? Yes No X
C Creek, river, sound or bay upon which project is located or nearest named body of water to project
South Creek
Description of Project
A. 1. Maintenance of existing project 2. New work _ Install Subaqueous Pipe
B. Purpose of excavation or fill
1. Access channel N. A. length width depth
2. Boat basin N. A. length width de
th
-
- p
3. Fill area N - A length width depth
*4. Other Vest Bank length 1000' width 14' depth 8
C 1. Bulkhead length N • A. Average distance waterward of MHW (shoreline) N - A .
2. Type of bulkhead construction (material)
D. Excavated material (total for project)
1. Cubic yards approx. 5000 cu. v . 2. Type of material
E. Fill material to be placed below MHW (see also V1. A)
Sandy Silts
-; 1. Cubic yards approx. cAA-IJ Cu. vds 2. Type of material Sandy Silts
IV. Land Type, Disposal Area, and Construction Equipment:
A. Does the area to be excavated include any marshland, swamps or other wetland? Yes No X
B. Does the disposal area include any marshland, swamps or other wetland? Yes No X
C Disposal Area Existing clay pond system, if dredge is used
1. Location
2. Do you claim title to disposal area? yes
D. Fill material source if fill is to be trucked in Mine sand tails, if needed
E. How'will excavated material be entrapped and erosion controlled? will be placed on high ground
will necessary erosion or sediment control
F. Type of equipment to be used Dragline and trucks or dredge, 1 necessary
G. Will marshland be trussed in transporting equipment to project site? If yes, explain No
* East bank length 400 width 14' depth 8'
V. Intended Use of Project Area (Describe)
A. 1. Private N. A.
2. Commercial
3. Housing 0evelopmentor Industrial Sub-aqueous pipe line to transport clay t rial
4. Other -N . A.
B. 1. Lot size(s) N. A.
2. Elevation of lot(s) above mean high water N A
3. Soil type and texture N. A.
4. Type of building facilities or structures N. A.
S. Sewage disposal and/or waste water treatment A. Existing N -A. Planned
8. Describe
6. 'Land Classification (circle one) DEVELOPED TRANSITIONAL COMMUNITY RURAL
CONSERVATION THER (See CAMA Local Land. Use Plan Synopsis)
VI. Pertaining to fill and Water Quality:
A. Doe's the proposed project involve the placement of fill materials below mean high water? Yes X No
8. 1. Will any runoff or discharge enter adjacent waters as a result of project activity or planned use of the
area following project completion? Yes %No
2. Type of discharge Clarified water
3. Location of discharge South or Bond Creek (tributaries)
VIL Present rate of shoreline erosion (if known): Not Known
Vill. List permit numbers and issue dates of previous Department of Army Corps of Engineers or State permits for
work in project area, if applicable: CAMA Minor 81-0032
IX Length of time required to complete project: 120-150 days
X In addition to the completed application form, the following items must be provided:
A. Attach a copy of the deed (with State application only) or other instrument under which applicant
claims title to the affected property. OR if applicant is not claiming to be the owner of said property,
then forward a copy of the deed or other instrument under which the owner claims title plus written
permission from the owner to carry out the project on his land.
B. Attach an accurate work plat drawn to scale on 8% X 11" white paper (see instruction booklet for
details). Note: Original drawings preferred - only high quality copies accepted.
C. A copy of the application and plat must be served upon adjacent riparian landowners by registered or
certified mail or by publication (G.S. 113-229 (d))Enter date served June 11, 1986
D. Litt names and complete addresses of the riparian landowners with property adjoining applicant's.
Such owners have 30 days in which to submit comments to agencies listed below.
Mr. W. E. Miller Hboker & Hollowell Oil Company
Rte. 2. Box 216 Post Office Box 278
Aurora, N. C. 27806 Aurora, North Carolina 27806
XI. Certification requirement: I certify that to the best of my knowledge, the proposed activity complies
with the State of North Carolinals approved coastal management program and will be conducted in a
manner consistent with such program.
X11. Any. permit issued pursuant to this application will allow only the development described in this appli-
cation and plat. Applicants should therefore describe in the application and plat all anticipated devel-
opment activities, including construction. excavation, filling, and land clearing.
11 -
DATE 1 i fly, lti r • .Xr c7m, t r?
Applicant's Signature
F%@ C 01 - .. .-• •.-..?? I- --- u a is mor" 1aICTn11/"TI^K1C
SANDY CANTING EXISTING 30°/ CLAY SLURRY PIPELINE
PUMPING STATION (TO BE ABANDONED)
l
NEW 30"0
LINED\
SLURRY PIPELINE CLAY POND I
EXIST. 180 SAND--.,A CROSSING CREEK
TAILINGS LINE
(TO BE REMOVED) )
GQ.? CLAY POND 2
NEW 30"# CLAY SLURRY
' SHORE PIPELINE
CLAY POND 3
CLAY POND 5A ` " \
4f k 1+ 00•1
??? CLAY POND 4A
r ? CLAY POND 5B
L mom ow =a ON

STATE ROAD 1912

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CHECKED
2G' O.D. POLYETHYLENE PIPE ENCASED IN
3G" O.D. STEEL CASING
DRAW114 TITLE I ENGINEERING DATE
JOB NO.
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HENRY VON OESEN AND ASSOCIATES
CONSULTING ENGINEERS
AND P L A N N E R S Telephone [phone]
611 PRINCESS STREET P.O. DRAWER 2087 WILMINGTON, NORTH CAROLINA 28402
June 2, 1986
Mr. Robert M. Thomas, Senior Engineer
Texasgulf Chemicals Co.
P. O. Box 48
Aurora, NC 27806
Re: South Creek Pipeline Replacement
Dear Mr. Thomas:
In accordance with your recent request and our numerous
meetings and discussions on the subject, this is to advise of
our recommendations concerning replacement of the Texasgulf
Chemicals Co. subaqueous pipeline across South Creek adjacent
to your plant. The recommendations herein are also consistent
with our discussions and presentation to representatives of the
North Carolina Department of Natural Resources and Community
Development in Washington, North Carolina on 28 May 1986.
After analysis of numerous options, we have selected the
alternative of encasing a high density, thick wall, 26-inch
polyethylene pipe inside of a 30-inch steel casing
with burial of the pipeline in the river bottom for the entire
length of the crossing. Analysis of numerous options, including
deep trench dredging, shallow trench dredging with bent supports
for the pipeline and even an elevated pipeline crossing led us
to the conclusion that heavy ballasting and simple sinking of
the casement pipe would be the preferred option.
We feel that this is possible based on the results of test borings
performed by Soil & Material Engineers, which indicates that the
overburden bottom materials (above hard or dense sand) was comprised
of extremely soft unconsolidated silty type materials which would
-allow the ballasted pipeline to sink through these materials to
approach the hard bottom. Technical design details relative to
this proposed method of installation will. be included in our
project design package which will be furnished to you within a
few days.-
We feel that this selected option provides the best technical
solution to the problem and is also by far the least environmentally
disturbing of the numerous options considere oo In this case only
a small amount of materials (approximately cubic yards) would
have to be dredged from the shorelines to insure sufficient burial
of the pipeline on the hard bottom in these areas. There would
be a minimum of three to four feet of cover on the pipe sections
at the shore approaches, with increasing coverage of the buried
Mr. Robert M. Thomas
June 2, 1986
Page 2
pipeline in the natural bottom materials up to depths of 17 to
18 feet near the center of the crossing. Comparatively speaking,
we estimate that approximately 180,000 to 200,000 cubic yards
of material would have to be dredged from the river bottom to
allow open trench burial of the pipeline. Similarly, 40,000 to
50,000 cubic yards of material would have to be dredged from a
shallow trench. to allow installation of the bent-supported pipeline
system mentioned above.
Finally, we propose to insure the integrity of both the
inside and outside (casing) pipes by pressure testing prior to
commencement of operations. Additionally, a monitoring system
will be installed on the casing pipe which will immediately detect
and signal any failure of the materials pipe by allowing any materials
that escape into the encasing pipe to overflow into a sump and/or
tailings pit where they will be detected during any of the numerous
daily inspections of the materials pumping station at the river's
edge. Arrangements will also be made periodically-to pressure
test the encasing pipe to constantly insure its integrity.
I hope this information is satisfactory to your immediate
needs. We look forward to meeting with you again in the very
near future to review final technical details of the proposed
project. Please call if you have any questions or if we may
assist further in any way.
Sincerely yours,
HENRY VON OESEN AND ASSOCIATES, INC.
Paul S. Denison, P. E.
PS D /-i.-GB