07-01_12_Redacted

JAMES B. HUNTJR. _ ml
GOVERNOR
WAYNE MCDEVITT
SECRETARY ',.•,
GHARLE9 H. GARONER
P.G., P.E. DIRECTOR
AND STATE GEOLOGIST
I
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF LANo RESOURCES
September 24, 1998
Mr. Stephen R. Phillips
Manager, Environmental Affairs
PCS Phosphate - Aurora Division
P.O. Box 48
Aurora, North Carolina 27806
RE: Mining Permit No. 07-01
Aurora Phosphate Mine
Beaufort County
Tar -Pamlico River Basin
Dear Mr. Phillips:
This office has reviewed your July 31, 1998 letter and its
enclosures requesting several modifications to the above mining permit.
These include changes in the final reclamation of the headwaters of
Whitehurst Creek, changes in the mine refuse disposal area, and
approval to remove overburden by hydraulic dredging.
Your modification request is hereby approved, with the following
stipulations:
1 } The final reclamation of the headwaters of Whitehurst
Creek shall conducted in accordance with all current and
future conditions of the Division of Water Quality's 401
Certification (No. 2748);
2} The previous approval to move the mine refuse disposal
area shall be rescinded, the existing disposal area shall be
used by extending its western boundary approximately 250
feet as shown on the Mining Refuse Area map dated May
29, 1998, and the materials to be disposed shall remain
the same as indicated in your company's previously
approved list; and
3) The temporary reinstitution of dredging for the removal of
the top approximately 35 feet of overburden ahead of the
draglines shall be conducted in two separate blocks, each
approximately 120 acres, as indicated on the "1 100 Acre
Mine Plan Map - Dredge Schematic" dated May 20, 1998.
This activity shall occur over the next 2 - 3 years and be
restricted to the northwest corner of the recently permitted
LAND QUALITY SECTION [phone] FAX [phone]
GEOLOGICAL SURVEY SECTION (91 91 733-2423 FAX [phone]
P.O. 9o7t 27687. RA4EIG H, NORTH CAROLINA 2761 17687 TELEPHONE [phone] FAX 1919, 71 5-6801
AN EQUAL OPPORTUNITY I AFFIRMATIVE ACTION EMPLOYER - 50 o RECYCLED/10 o PCST-CONSUMER PAPER

Mr. Stephen R. Phillips
September 24, 1998
Page 2
1 ,100 acre area on the west side of the current mining operation. All
water from the dredge blocks shall ultimately be discharged through a
NPDES-permitted outfall. It is understood that dredging these blocks will
assist in the timing of the movement of bucket wheel equipment to the
NCPC Tract.
Please attach a copy of this modification approval letter to your existing mining
Qermit for future reference. As a reminder, the total permitted acreage at this site is
11, 51 2 acres.
This office has received and is currently evaluating your subsequent
modification request pertaining to the future development of a portion of the NCPC
Tract. We will contact you in the near future if additional information is needed.
Please contact Mr. Tracy Davis, P.E., State Mining Specialist, at (919) 733-
4574 should you have any questions concerning this matter.
Sincerely,
Charles H. Gardner, P,G., P.E.
CHG/td
9/98mod.pcs
cc: Mr. Tracy Davis, P.E,
Mr. Floyd Williams, P.G.
Mr. Bradley Bennett - DWQ
Ms. Barbara Rote - WRC

Department of Environment
,--:" Natural Resources
Division of Land Resources
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
Charles H. Gardner, P.G., P.E.
Director and State Geologist
November 19, 1997
Mr. Stephen R. Phillips
Manager, Environmental Affairs
PCS Phosphate - Aurora Division
P.O. Box 48
Aurora, North Carolina 27806
RE: Mining Permit No. 07-01
Aurora Phosphate Mine
Beaufort County
Tar -Pamlico River Basin
Dear Mr. Phillips:
1�•
NORTH C.RouxA DE4rrmmNT or
ENv1RoNmExT wxn NATuRIJ_ REaouRcs-s
This office has reviewed your October 6, 1997 letter and its
enclosures requesting a modification to the mining permit to
activate 450 acres already under permit and to add/mine 650 acres
to the west of the existing mining operation. This will result in
a 1,100 acre mine block. In addition, on October 15, 1997, you
requested approval of a new mining refuse disposal area in Mine
Block 24, including clarification of the items to be disposed in
said area.
Your requests for modification of Mining Permit No. 07-01 as
indicated above are hereby approved provided that a) the Erosion
and Sedimentation Control Plan dated September 24, 1997, the 1100
Acre Mine Plan Map and Final Reclamation Plan - Southern Permit
Area, both dated September 29, 1997, and the contents of the
modification application dated October 8, 1997 are strictly adhered
to for the mine expansion and b) the new mining refuse disposal
area is restricted to the items listed in Attachment I of your
October 15, 1997 letter and to the boundaries indicated on the
Mining Refuse Area map dated September 11, 1997. PleaQQ attach a
copy of this modification approval letter to your ,existing mining
Permit for future reference.
As a reminder, the total permitted acreage at this site is now
11,512 acres.
Gcolopcal Survey Section
Land Quality Section
[phone]
[phone]
FAX: [phone]
FAX [phone]
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone]
Y� An Equal Opportunity Affirmative Action Employer 50% Recycled / 10% Post --Cons ntex Papa
IV

Mr. Phillips
Page 2
Please contact Mr. Tracy Davis, P.E., State Mining Specialist,
at [phone] should you have any questions concerning this
matter.
Sincerely,
Charles H. Gardner, P.G., P.E.
CHG/td
1100mod.pcs
cc, Mr. Tracy Davis, P.E.
Mr. Floyd Williams, P.G.
Mr. Bradley Bennett - DWQ
Ms. Barbara Rote - WRC

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Land Resources
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
Charles H. Gardner, P.G., P.E.
Director and State Geologist
April 10, 1997
Mr. Jeffrey C. Furness
PCS Phosphate
Aurora Division
P.O. Box 48
Aurora, North Carolina 27805
RE; Modification Request
Mining Permit No. 07-01
Beaufort County
Dear Mr. Furness:
ffl�KWA
A&V
E)EHNR
Your recent request to have the above referenced mining
permit modified has been approved. The modification is to allow
blasting to facilitate the current and future removal of well
casings Located around the perimeter of the mine site. The
approval is contingent upon PCS Phosphate following the
"Procedures for Explosives on PCS Phosphate Property", which was
attached to your April 3, 1997 letter to Mr. Tracy Davis of this
office. In addition, you should contact Mr. Floyd Williams,
Washington Land Quality Section Regional Engineer, at (919) 946-
6481 at least 48 hours prior to any future blasting of well
casings as proposed in your letter.
Please attach this approval letter to your mining permit
document for future reference.
Please contact Mr. Davis if you should have any further
questions regarding this matter. He may be reached at {919) 733-
4574.
Sincerely,
�� Qom*------
Charles H. Ga ner, P.G., P.E.
CHG/td
CC: Mr. Floyd Williams, P.G.
Mr. Tracy Davis, F.E.
Geologicd Survey Section Land Quality Section Geodetic Survey Section
[phone] [phone] [phone]
FAX: [phone] FAX: [phone] FAX: [phone]
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50%recycled/ 10%post-consumer paper

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Land Resources
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
Charles H. Gardner, P.G., P.E.
Director and State Geologist
June 10, 1996
Mr. Jeff Furness
PCS Phosphate Company, Inc.
P.O. Box 48
Aurora, North Carolina 27806
RE: Permit No. 07-01
Aurora Phosphate Mine
Beaufort County
Dear Mr. Furness:
FTWA
DEHNR
This office has reviewed your May 23, 1996 letter requesting
a modification to the approved plan for the relocation of Bailey
Creek. Your company proposes to construct a temporary diversion
channel west and north of the existing Bailey Creek channel to
reroute the water flow. The diversion channel would include two
rock check dams and a settling basin before it reconnects with
the Bailey Creek channel. You also propose to fill in a section
of the existing channel to allow spoil placement as indicated on
the Sketch Plan -- Temporary Water Diversion for Bailey Creek
Relocation dated May 22, 1996.
Your request for modification of Mining Permit No. 07-01 as
outlined above is hereby approved with the following stipulation:
Appropriate approvals must be obtained from the Division of
Environmental Management, Water Quality Section, and the U.S.
Army Corps of Engineers prior to implementation of the above
modifications to the relocation of Bailey Creek. Please forward
two (2) copies of such approvals, when obtained, to Mr. Tracy
Davis of this office.
Please attach a copy of this modification approval letter to
your existing mining permit for future reference.
As a reminder, the total permitted acreage at this site is
10,862 acres.
Geological Survey Section Land Quality Section Geodetic Survey Section
[phone] [phone] [phone]
FAX: [phone] FAX: [phone] FAX: [phone]
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone] FAX [phone]
An Equal Opportunity Airirmaiive Action Employer 50% recycled/ 10% post -consumer paper

Mr. Furness
June 10, 1996
Page 2
Please contact Mr. Davis at [phone] should you have
any questions concerning this matter.
Sincerely,
harles H. Gardner, P.G., P.E.
CHG/td
bailey.mod
cc: Mr. Tracy Davis, P.E.
Mr. Floyd Williams, P.G.
Mr. John Dorney _ DEM
Mr. Hugh Heine - USCOE

State of North Carolina
Department of Envlronment,
Health and Natural Resources
Division of Land Resources
James B, Hunt, Jr., Governor
Jonathan B. Howes, Secretary
Charles H. Gardner, P.G., P.E,
Director and State Geologist
April 4,
Mr. B. A. Peacock
PCS Phosphate Company, Inc.
P.O. Box 48
Aurora, North Carolina 27806
RE: Permit No. 07-01
Aurora Phosphate Mine
Beaufort County
Dear Mr. Peacock:
1996
Your application for modification of Permit No. 07-01 for
the Lee Creek Mine in Beaufort County has been approved. The
modification allows a) the addition and mining of the 770 acre
mine block south of the existing mine area, b) the relocation and
restoration of Bailey Creek, and c) a change in the name of the
company and mine name on the permit as indicated by your December
8, 1995 letter and supporting documentation. A copy of the
modified permit is enclosed.
The conditions in the permit modification were based
primarily upon the initial application. Modifications were made
as indicated by the modification request and as required to
insure compliance with The Mining Act of 1971. The permit number
and expiration date shall remain the same as the prior permit. I
would like to draw your particular attention to Operating
Conditions Nos. 4.L., 4.M., 5.D. and 9.B. of the enclosed permit.
As a reminder, the total permitted acreage at this site has
changed from 10,092 acres to 10,862 acres in light of this
modification.
In addition, please note that the enclosed
includes the contents of the September 15, 1995
signed by Mr. Charles Gardner allowing blasting
facilitate the removal of five deep well casings
the perimeter of the mine site.
Geological Survey Section
[phone]
FAX: [phone]
Land Quality Section
[phone]
FAX; 733-2876
modified permit
approval letter
operations to
located around
Geodetic Survey Section
[phone]
FAX; 733-4407
P.O, Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

Mr. Peacock
April 4, 1996
Page 2
Please review the modified permit and advise this office at
[phone] should you have any questions concerning this
matter.
Sincerely,
Tracy Davis, P.E.
State Mining Specialist
Land Quality Section
TED/td
07-01pcs.mod
Enclosure
cc: Mr. Floyd Williams, P.G.
Ms. Barbara Rote - WRC, w/enclosures
Mr. John Dorney - DEM, w/enclosures

D E PAR`TMENT O F ENV = RONME1�7r1-
H'� A T ."I'H ASTD NA
]RUE SOiTRCYES
D=V=SIGN OF T.ASTD RESOZTRCES
T-A�� QUAL2"TY SECT'2ON
P E R M = 'T
for the operation of a mining activity
In accordance with the provisions of G.S. 74-46 through
68, "The Mining Act of 1971," Mining Permit Rule 15A
NCAC 5 B, and other applicable laws, rules and
regulations
Permission is hereby granted to:
PCS Phosphate Company, Inc.
Aurora Phosphate Mine
Beaufort County - Permit No. 07-01
for the operation of a
Phosphate Mine
which shall provide that the usefulness, productivity
and scenic values of all lands and waters affected by
this mining operation will receive the greatest
practical degree of protection and restoration.
MINING PERMIT EXPIRATION DATE: Januqly 4 200

Page 2 of 18
In accordance with the application for this mining permit, which
is hereby approved by the Department of Environment, Health and
Natural Resources hereinafter referred to as the Department, and
in conformity with the approved Reclamation Plan attached to and
incorporated as part of this permit, provisions must be made for
the protection of the surrounding environment and for reclamation
of the land and water affected by the permitted mining operation.
This permit is expressly conditioned upon compliance with all the
requirements of the approved Reclamation Plan. However,
completed performance of the approved Reclamation Plan is a
separable obligation, secured by the bond or other security on
file with the Department, and may survive the expiration,
revocation or suspension of this permit.
This permit is not transferable by the permittee with the
following exception: If another operator succeeds to the
interest of the permittee in the permitted mining operation, by
virtue of a sale, lease, assignment or otherwise, the Department
may release the permittee from the duties imposed upon him by the
conditions of his permit and by the Mining Act with reference to
the permitted operation, and transfer the permit to the successor
operator, provided that bbth operators have complied with the
requirements of the Mining Act and that the successor operator
agrees to assume the duties of the permittee with reference to
reclamation of the affected land and posts a suitable bond or
other security.
In the event that the Department determines that the permittee or
permittee's successor is not complying with the Reclamation Plan
or other terms and conditions of this permit, or is failing to
achieve the purposes and requirements of the Mining Act, the
Department may give the operator written notice of its intent to
modify, revoke or suspend the permit, or its intent to modify the
Reclamation Plan as incorporated in the permit. The operator
shall have right to a hearing at a designated time and place on
any proposed modification, revocation or suspension by the
Department. Alternatively and in addition to the above, the
Department may institute other enforcement procedures authorized
by law.
Definitions
Wherever used or referred to in this permit, unless the context
clearly indicates otherwise, terms shall have the same meaning as
supplied by the Mining Act, N.C.G.S. 74-49.

Page 3 of 18
Modifications
Aiari�l 1, 1985: This permit has been modified to change the
projected mining and reclamation schedule as well as incorporate
changes to the reclamation plan to allow backfilling of the mine
areas with a blend of gypsum and clay tailings.
April 8, 1988: This permit has been modified to add
approximately 550 acres of adjacent land to make the Texasgulf,
Inc. and NCPC permit areas contiguous. The modification also
includes a change in the mine advance direction and a change in
the pre -strip method (i.e., use of a bucket wheel excavator in
lieu of a hydraulic dredge).
February 8, 1990: This permit has been modified to include and
allow mining activities on an adjacent 160 acres of land with
several stipulations.
November 29, 1990: This permit has been modified to remove the
last sentence of Operating Condition No. 7.B.4. which requires
Texasgulf, Inc. to develop and submit a plan by 1992 to blend all
new clays and gypsum directly at the plant for permanent waste
disposal/reclamation. This modification has been approved
provided that no new gypsum stacks are constructed.
June 13, 1991: This permit has been modified to include and
allow mining activities on an adjacent 250 acres of land with
several stipulations.
September 6, 1921- This permit has been modified to include the
construction of a new sulfur rail unloading system adjacent to
the current sulfur tracks at the plant site with several
stipulations.
October 31, 1991: This permit has been modified to allow the
second trial capping of approximately 35 acres (10%) of the R-2
blend area with a 4:1 sand to clay cap ratio.
0=2ber_31.-_ 1991: This permit has been modified to allow the
reactivation of Gypsum Pile 3/4 with several stipulations.
February 28, 1222: This permit has been modified to include the
700 acre mine advance south of the current permit area with
several stipulations.
Tune 2. 1992: This permit has been modified to allow capping of
the R-2 blend area with a clay cap, 18 to 24 inches thick,
provided that this capping process does not result in impoundment
of water against the dikes.

Page 4 of 18
June 4,1992:_ This permit has been modified to allow borrow pit
activities in the 700 acre modification area (upstream of SR
1937) prior to implementing the hydrology modeling and monitoring
requirements as required by the February 28, 1992 modification
with several stipulations.
July 6. 1992_: This permit has been modified, with stipulations,
to allow the development of the mine utility corridor around the
700 acre modification area. This will be accomplished by leaving
four gaps in the perimeter canal system to permit water to
continue to flow through the existing lead ditches into the
headwaters of Whitehurst Creek.
July 27. 1992: This permit has been modified to allow the
placement of a 30 inch culvert in each of the uncut lead ditches
and for the subsequent placement of coarse granular washer reject
material over said culverts to allow equipment access to the mine
utility corridor area along the perimeter of the 700 acre mine
expansion.
July 28, 1992: This permit has been modified to extend the
previous reclamation deadlines specified in this mining permit to
those provided in the July 22, 1992 letter from Texasgulf, Inc.
to the Department.
January 4_, 1993_; This permit has been modified to include the
approval of the "Mitigation Plan for Replacement of 5,000 Feet of
Channelized Whitehurst Creek" dated May 14, 1992 and the
"Whitehurst Drainage Channel Restoration Plan" dated December 7,
1992.
March 17, 1994: This permit has been modified to allow the
addition and mining of the 360 acre mine block south of the
existing mine area as indicated in Mr. William Schimming's
January 25, 1994 letter and supporting documentation.
line 20, 1994: This permit has been modified to allow capping of
the 900 acre R-3 blend area with a clay cap as indicated in Mr.
William Schimming's May 26, 1994 letter to the Department.
January 5, 1995: This permit has been modified to allow the
addition and mining of the 290 acre mine block east of the
existing mine area as indicated in Mr. William Schimming's
November 18, 1994 letter and supporting documentation.
September 15. 1995: This permit has been modified to allow
blasting operations to facilitate the removal of five deep well
casings located around the perimeter of the mine site.

Page 5 of 18
Alpril_ 4, _1!296-- This permit has been modified to allow a) the
addition and mining of the 770 acre mine block south of the
existing mine area, b) the relocation and restoration of Bailey
Creek, and c) a change in the name of the company and mine name
on the permit as indicated by Mr. B. A. Peacock's December 8,
1995 letter and supporting documentation.
Expiration Date
This permit shall be effective from the date of its issuance
until January_ 4, 2_00.
Conditions
This Permit shall be subject to the provisions of the Mining Act,
N.C.G.S. 74-46, et. seq., and to the following conditions and
limitations:
OPERATING CONDITIONS:
1. Wastewater and__ Pit _Dewatering
A. Any wastewater processing or mine dewatering shall be
in accordance with the requirements and rules
promulgated by the N.C_ Environmental Management
Commission.
B. Any stormwater runoff from the affected areas at the
site shall be in accordance with any applicable permit
requirements and regulations promulgated by the
Environmental Protection Agency and enforced by the
N.C. Environmental Management Commission. It shall be
the permittee's responsibility to contact the Water
Quality Section, Division of Environmental Management,
to secure any necessary stormwater permits or other
approval documents.
2. Air Ouality and Dust Control
A. Any mining related process producing air contaminant
emissions including fugitive dust shall be subject to
the requirements and rules promulgated by the N.C.
Environmental Management Commission.
B. All mine access roads shall be appropriately stabilized
to reduce dust and prevent erosion and offsite
sedimentation. During mining operations, water trucks
or other means that may be necessary shall be utilized
to prevent dust from leaving the permitted area.

Page 6 of 18
3. Buffer zones
A. Any mining activity affecting waters or wetlands shall
be in accordance with the requirements and regulations
promulgated and enforced by the Environmental
Management Commission, the Coastal Resources Commission
and the U.S. Army Corps of Engineers. Any areas under
the jurisdiction of these agencies shall be visibly
marked at the site and the appropriate approval
documents obtained prior to any land disturbing
activities in said areas.
B. Sufficient buffer shall be maintained between any
affected land and any adjoining waterway to prevent
sedimentation of that waterway from erosion of the
affected land and to preserve the integrity of the
natural watercourse.
C. The width of the buffer adjacent to any watercourses at
the site, most specifically Porter Creek, Durham Creek,
Whitehurst Creek and South Creek, shall be determined
by and subject to any federal and state regulations
concerning navigable waters and wetland areas.
D. Sufficient buffer (minimum of 25 feet) shall be
maintained between any excavation and any adjoining
property line to prevent caving of that property and to
allow grading of the sideslopes to the required angle.
E. Overburden removal for ore extraction shall not occur
within 300 feet of any neighboring dwelling house,
church, school, hospital, commercial or industrial
building, public road or other public property until a
formal modification request has been submitted to and
approved by the Department. The request shall clearly
describe how a physical hazard to the above features
will be prevented.
F. The buffer zones shown on the Mine/Plantsite Location
map (Attachment 8) dated October 19, 1992 shall be
maintained to prevent caving of any adjoining property
and to allow grading of the side slopes to the required
angle. These buffer zones, with the exception of the
installation of required sediment control measures and
earthen berms, shall remain undisturbed.

Page 7 of 18
4. Erosion and Sediment Control
A. Adequate mechanical barriers including, but not limited
to diversions, earthen dikes, brush barriers, silt
check dams, silt retarding structures, rip rap pits, or
ditches shall be provided in the initial stages of any
land disturbance and maintained to prevent sediment
from discharging onto adjacent surface areas or into
any lake or natural watercourse in proximity to the
affected land.
B. The construction and maintenance of the new sulfur rail
unloading system adjacent to the pre-existing sulfur
tracks at the plant site shall be in accordance with
the Erosion Control Plan AFE N-605 Sulfur Unloading
Facility prepared by Texasgulf, Inc. dated August 27,
1991.
C. The reactivation of Gypsum Pile 3/4 shall be in
accordance with the report by Ardaman & Associates,
Inc. entitled "Support Document - Permit Application to
Reactivate Gypsum Pile 3/4 - Texasgulf Phosphate
Operations, Aurora, North Carolina" dated August 26,
1991 with the following stipulations:
1) that all necessary permits be obtained from the
Division of Environmental Management in order to
conduct this activity.
2) that all clay material to be utilized for the
underlines be obtained only from: (a) an area
south of the existing mine activity, as close to
the mine activity as possible, (b) an area agreed
to by the Corps of Engineers as a
nonjurisdictional wetland area and (c) an area
within the approved mining --permit area covered by
this permit.
D. The 700 acre mine expansion shall be conducted in
accordance with the permit modification application
dated October 11, 1991 and the supplemental information
dated December 23, 1991 as well as the following
stipulations:

Page 8 of 18
1) that the predisturbance flow levels of Whitehurst
Creek be maintained by pumping groundwater into
the uppermost portion of the creek at a rate to
attempt to match the pre -mined, undisturbed
hydrology of the creek. This requirement should
maintain the aquatic life in the creek and
maintain the natural salinity levels at the mouth
of Whitehurst Creek at South Creek. In order to
assure flow into the mitigation channel during low
runoff flow, a water source shall be constructed
adjacent to the sediment pond and shall discharge
directly into the sediment pond near the upstream
end. The water source shall be controlled by a
float switch located within the sediment pond and
set to maintain the water level so that any runoff
flow into the sediment pond will create an
immediate discharge into the mitigation channel.
2) that all land disturbing activities within the 700
acre expansion area shall be in accordance with
the Mitigation Plan for Replacement of 5,000 Feet
of Channelized Whitehurst Creek dated May 14, 1992
and the 401 Water Quality Certification (Number
2748) issued by the Division of Environmental
Management on June 30, 1992.
3) that any mining related activities in the 700 acre
expansion area shall be in accordance with all
applicable state and federal water quality rules
and permit requirements (i.e., Division of
Environmental Management, Division of Coastal
Management, U.S. Army Corps of Engineers, etc.).
4) that the construction of the mine utility corridor
around the 700 acre expansion area shall be in
accordance with the above approved plans and
corresponding permits. Furthermore, adequate
erosion and sedimentation control measures shall
be installed and maintained downstream of any land
disturbing activity related to the construction of
the mine utility corridor, most specifically in
those areas where water may flow directly into the
headwaters of Whitehurst Creek.
5) that restoration of the headwaters of Whitehurst
Creek shall be in accordance with the Whitehurst
Drainage Channel Restoration Plan dated December
7, 1992 and any supplemental information approved
by the Department detailing said restoration.

Page 9 Of 18
E. The 360 acre mine expansion (south of the 700 acre mine
block) shall be conducted in accordance with the permit
modification application dated January 18, 1994 and the
"Sedimentation and Erosion Control Plan - Mine Permit
7-1 Modification - 360 Acre Block for Texasgulf, Inc."
booklet and corresponding maps dated December 15, 1993.
F. The capping of the R-2 blend area with a clay cap, 18
to 24 inches thick, shall be in accordance with
Texasgulf, Inc.'s letter to the Department dated May
14, 1992 and the memorandum to Texasgulf, Inc. from Dr.
Stephen Broome and Mr. Don Millman dated May 7, 1992
and May 11, 1992, respectively. Said capping process
shall be conducted in such a manner so as not to result
in the impoundment of water against the dikes.
G. The borrow activities in the 700 acre expansion area
(upstream of SR 1937) to obtain clays for use in
reconstructing liners for gypsum piles 3 and 4 shall be
conducted in accordance with the Proposed Borrow Pit
Area Map dated April 30, 1992 with the following
stipulation: that appropriate erosion and
sedimentation control measures, such as a horseshoe
gravel filter at the upstream end of the culvert under
SR 1937 or other acceptable alternative, shall be
utilized and maintained to prevent offsite
sedimentation into the headwaters of Whitehurst Creek.
H. All mining permit boundaries, major features of the
active mining operation and final reclamation
elevations/contours shall be in accordance with the
Mine/Plantsite Location map (Attachment 8) dated
October 19, 1992, the Final Reclamation Contours - Mine
and Plantsite map (Attachment 10) dated October 21,
1992 and the Final Reclamation Estimated Contours -
Charles Tract map (Attachment 11) dated October 21,
1992.
I. An erosion and sediment control plan(s) shall be
submitted to the Department for approval prior to any
land disturbing activities at the site not previously
indicated on an erosion control plan or mine map
submitted to and approved by the Department.
J. The capping of the 900 acre R-3 blend area with a clay
cap shall be in accordance with Texasgulf, Inc.'s
letter to the Department dated May 26, 1994. The clay
cap shall consist of settled clay being placed at an
average thickness of 18 inches. A five (5) foot
freeboard shall be maintained between the water surface
and the top of the dike along the exterior dike
portions of the R-3 area. Lastly, said capping process
shall be conducted in such a manner so as not to result
in the impoundment of water against the dikes.

Page 10 of 18
K. The 290 acre mine expansion (east of the 360 acre mine
block) shall be conducted in accordance with the permit
modification application dated November 16, 1994, the
"Sedimentation and Erosion Control Plan for Mine Permit
7-1 Modification - 290 Acre Mine Block for Texasgulf,
Inc." booklet dated October 11, 1994 and the
"Relocation of a Portion of Whitehurst Creek Mitigation
Channel" report dated October 11, 1994, with the
following stipulation:
A "plug" or appropriately designed sediment control
measure shall be maintained at the downstream end of
the new mitigation channel, until the upper portions of
said channel have been constructed and stabilized, to
prevent offsite sedimentation at the connection of the
new channel with the existing channel. Once the new
channel has been stabilized and the downstream "plug"
has been removed, the "plug" at the upstream end of the
new channel shall then be removed to allow flow through
the new stabilized channel, into the existing channel,
then into Whitehurst Creek.
L. The 770 acre mine expansion (south of the existing
mining operation) shall be conducted in accordance with
the permit modification application dated December 7,
1995, the "Sedimentation and Erosion Control Plan for
Mine Permit 7-1 Modification - 770 Acre Block for PCS
Phosphate Company, Inc." booklet dated November 30,
1995, the supplemental information/letter dated March
26, 1996, and the following revised maps:
1) 770 Acre Mine Plan Map, Mine Permit Modification
dated March 12, 1996;
2) Construction Plan, Relocated Channel for 770 Acre
Mine Block dated November 30, 1995;
3) Plan & Details, Relocated Channel for 770 Acre
Mine Block dated February 12, 1996;
4) Final Reclamation Map, Mine Permit 7-1
Modification, 700/360/290/770 Acre Blocks dated
March 12, 1996.
M. The relocation and subsequent restoration of Bailey
Creek (associated with the 770 acre mine expansion)
shall be conducted in accordance with all terms and
requirements contained in the 11401 Water Quality
Certification and ADDITIONAL CONDITIONS" (DEM Project #
951281) dated March 6, 1996 and any approved revisions
to it.

Page 11 of 18
5. Groundwater_Protection
A. Observation wells shall be installed and monitored as
deemed necessary by the Department.
B. The observation wells shall be secured against
unauthorized entry with a lockable cap. Any necessary
permits or approvals to construct these wells shall be
obtained from the N.C. Division of Environmental
Management, Groundwater Section.
C. water from the observation wells shall be analyzed, and
corresponding results reported, as required by the
Groundwater Section.
D. If nearby potable wells are impacted by the mine
dewatering activities, the permittee shall mitigate
such impacts through bearing the costs for replacement
or modifications to the wells or pumps to maintain the
potable water supply to local residences.
6. Graded Slopes and Fills
A. The angle for graded slopes and fills shall be no
greater than the angle which can be retained by
vegetative cover or other adequate erosion control
measure, structure, or device. In any event, exposed
slopes or any excavated channels, the erosion of which
may cause offsite damage because of siltation, shall be
planted or otherwise provided with groundcover, devices
or structures sufficient to restrain such erosion.
B. Up to the first fifty (50) feet of overburden shall be
removed by a bucket wheel excavator system and conveyed
to previously mined areas for reclamation. The
remaining overburden shall be removed by draglines and
cast into previously mined areas in windrows.
C. Oversized phosphate pebbles and gangue materials
(rejects) in the ore matrix shall be stockpiled in the
vicinity of the mill area or returned to a previously
mined area. This material may be utilized for internal
road construction and maintenance. It may also be made
available to the general public as well as state and
local governments.
D. The quartz sand (sand tailings) from the ore matrix
shall be pumped to previously mined areas for backfill
either alone or in a blend with gypsum and clay. It
shall also be utilized for dike and roadway
construction.

Page 12 of 18
E. The clay material from the ore matrix shall be pumped
to the previously mined areas for backfill, either
alone or in a blend with gypsum. Clay only discharges
shall not exceed 25% of the total time of any waste
discharges into previously mined areas. Records
documenting the amount of time of clay vs. clay/gypsum
blend discharges into mined areas shall be maintained
at the mine office and be available for review by
Department personnel upon request.
F. The gypsum byproduct used in the clay/gypsum blend
shall be stockpiled next to the processing plant in no
more than a three stockpile rotation. Solids from
cleaning the cooling ponds or associated ditches may be
pumped to either the Number 1 or Number 2 gypsum stack.
G. Any dikes/embankments at the mine site shall be
constructed, stabilized and maintained in accordance
with the Dam Safety Law of 1967 and corresponding
regulations promulgated by the N.C. Environmental
Management Commission. Such requirements and
regulations shall be enforced by the Land Quality
Section.
7. S.urf e Drainage
The affected land shall be graded so as to prevent
collection of pools of water that are, or likely to become,
noxious or foul. Necessary structures such as drainage
ditches or conduits shall be constructed or installed when
required to prevent such conditions.
8. High Wall Barrier
A physical barrier shall be maintained at all times around
the perimeter of any highwall to prevent inadvertent public
access. Examples of such barriers could include vegetated
earthen berms, canals or gates.
9. Visual Screening
A. Existing vegetation shall be maintained between the
mine and public thoroughfares to screen the operation
from the public. Additional screening methods, such as
constructing earthen berms or additional tree
plantings, shall be employed as deemed appropriate by
the Department.
B. Screening of the 770 acre mine expansion from nearby
residences and public roads shall be conducted in
accordance with the measures outlined in the March 26,
1996 letter and associated revised maps.

4
Page 13 of 18
10. Plan Modific ti n
The operator shall notify the Department in writing of the
desire to delete, modify or otherwise change any part of the
mining, reclamation, or erosion/sediment control plan
contained in the approved application for this mining permit
and any approved revisions to it. Approval to implement
such changes must be obtained from the Department prior to
on -site implementation of the revisions.
11. Refuse Disposal
A. No on -site disposal of refuse or other solid waste that
are generated outside of the mining permit area shall
be allowed within the boundaries of the mining permit
area unless authorization to conduct said disposal has
first been obtained from both the Division of Solid
Waste Management and the Land Quality Section,
Department of Environment, Health and Natural
Resources. The method of disposal shall be consistent
with the approved reclamation plan.
B. Mining refuse as defined by G.S. 74-49 (14) of The
Mining Act of 1971 generated on -site and directly
associated with the mining activity may be disposed of
in a designated refuse area. All other waste products
must be disposed of in a disposal facility approved by
the Division of Solid waste Management. No petroleum
products, acids, solvents or their storage containers
or any other material that may be considered hazardous
shall be disposed of within the permitted area.
12. Annual Reclamation Report
An Annual Reclamation Report shall be submitted on a form
supplied by the Department by February 1 of each year until
reclamation is completed and approved.
13. Bonding
The security which was posted pursuant to N.C.G.S. 74-54 in
the form of a $500,000.00 surety bond meets the current
Departmental requirements. This security shall remain in
force for this permit to be valid. The total affected land
shall not exceed the bonded acreage.
14. Archaeological Resources
Authorized representatives of the Division of Archives and
History shall be granted access to the site to determine the
presence of significant archaeological resources.

Page 14 of 18
APPROVED RECLAMATION PLAN
The Mining Permit incorporates this Reclamation Plan, the
performance of which is a condition on the continuing validity of
that Mining Permit. Additionally, the Reclamation Plan is a
separable obligation of the permittee, which continues beyond the
terms of the Mining Permit.
The approved plan provides:
Minimum StangsIrds As Provided By G.S. 74-53
1. The final slopes in all excavations in soil, sand, gravel
and other unconsolidated materials shall be at such an angle
as to minimize the possibility of slides and be consistent
with the future use of the land.
2. Provisions for safety to persons and to adjoining property
must be provided in all excavations in rock.
3. All overburden and spoil shall be left in a configuration
which is in accordance with accepted conservation practices
and which is suitable for the proposed subsequent use of the
land.
4. No small pools of water shall be allowed to collect or
remain on the mined area that are, likely to become noxious,
odious or foul.
5. The revegetation plan shall conform to accepted and
recommended agronomic and reforestation practices as
established by the North Carolina Agricultural Experiment
Station and the North Carolina Forest Service.
6. Permittee shall conduct reclamation activities pursuant to
the Reclamation Plan herein incorporated. These activities
shall be conducted according to the time schedule included
in the plan, which shall to the extent feasible provide
reclamation simultaneous with mining operations and in any
event, provide reclamation at the earliest practicable time
after completion or termination of mining on any segment of
the permit area and shall be completed within two years
after completion or termination of mining except for the
s1jrfaceQ_Qf clay and gypsum wastes, for which reclamation
shall follow the sc,hedule._.snQQi,£,i.ed by this -permit,

Page 15 of 18
RECLAMATION CONDITIONS:
1. Provided further, and subject to the Reclamation Schedule,
the planned reclamation for the 1993-2003 permit period
shall be: 1) backfill the mine excavations to original
elevation or higher except in those areas where approved
wetlands mitigation projects are required (the final
elevations may be below original surface elevations), 2)
stabilize all waste disposal areas and settling ponds, and
3) regrade and revegetate any areas in unconsolidated
material.
2. The specifications for surface gradient restoration to a
surface suitable for the planned future use are as follows:
A. Reclamation of mined land and settling ponds shall be
accomplished in two phases: 1) physical restoration
and 2) revegetation. Physical restoration shall be
accomplished by 1) backfilling with bucket wheel
excavator (overburden) material and dragline cast
material, 2) backfilling with sand tailings from the
flotation section of the mill, 3) backfilling with
clay/gypsum blend, and 4) may include capping the top
surface with a clay cap to enhance the establishment of
vegetation.
B. Upon completion of the backfilling activity noted in
2.A. above, the surface shall be graded to the desired
final contours as indicated on the Final Reclamation
Contours - Mine and Plantsite map dated October 21,
1992.
C. Rehabilitation of the clay settling ponds at or
associated with Texasgulf, Inc.'s mining operation
shall include the desiccation of water from the surface
of the ponds by the installation of drainage ditch
systems. Such drainage systems, in addition to
establishing vegetation including tree plantings,
should aid in the consolidation of the clays in the
ponds. Reclaimed clay ponds 1 thru 4B may be utilized
as wildlife habitats, forestry areas, or agricultural
areas. Clay ponds 5A and 5B may be utilized as wetland
habitats, as well as other wildlife habitats. Tn any
event, the final contours of the surface of the clay
ponds shall be in accordance with the Final Reclamation
Estimated Contours - Charles Tract map dated October
21, 1992.

Page 16 of 18
D. Every six (6) months Texasgulf, Inc. shall submit to
the Department detailed reports of reclamation
activities and reclamation research for each of the
following areas:
1) Charles Tract clay waste areas
2) Clay -gypsum blend areas
3) Gypsum stockpile areas
4) Sand tailings areas
5) Other areas
Each report shall include a specific plan and schedule
for future reclamation and reclamation research.
E. All settling ponds and sediment control basins used for
sedimentation control shall be backfilled, graded, and
stabilized or cleaned out and made into acceptable lake
areas after such ponds and basins are no longer needed
for sedimentation control.
F. The processing,,stockpile, and other disturbed areas
neighboring the mine excavations shall be graded to
slopes no steeper than a 4 horizontal to 1 vertical.
G. Compacted surfaces shall be disced, subsoiled or
otherwise prepared before revegetation.
H. On -site disposal of waste shall be in accordance with
Operating Conditions Nos. 11.A. and B. of this permit.
I. The affected land shall be graded to prevent the
collection of noxious or foul water.
3. Rev_egetation Plan:
Disturbed areas at the site shall be permanently revegetated
according to the following Revegetation Plan approved in the
renewal application by Mr. L. Gaylon Ambrose, Agricultural
Extension Service, on June 9, 1992:
Seeding recommendations:
1. Dike slope 3:1 or 4:1 - Spring/Summer Seeding
O.
Rate (Pounds/Acre)
Hulled bermudagrass 50
Common sudangrass 50
Japanese millet 50

Page 17 of 18
2. Dike slope 3:1 or 4:1 - Fall Seeding
Rate (Pounds/Acre)
Kentucky 31 Tall fescue 50
Crimson clover 25
3. Reclaimed Area, Flat or Gently Rolling - Fall Seeding
TV Rate (Pounds/Acre)
Alfalfa and other 20
soil improving legumes
Fertilizer shall be applied to any area as recommended by
soil test results.
Interspersed with legumes areas, various types of adapted
tree species shall be planted for wildlife habitat. Species
such as green ash, bald cypress, sweetgum, sycamore, and red
maple are commonly planted.
Currently, there is an active research program to determine
additional ground cover species that are adapted to the
reclaimed areas, such as various legumes.
Also, a variety of agricultural crops shall be planted to
determine their suitability for future land use at the site.
4. Reclamation Plan:
A. Reclamation shall be conducted simultaneously with
mining to the extent feasible. In any event,
reclamation shall be initiated as soon as feasible
after completion or termination of mining of any mine
segment under permit.
B. Specific reclamation areas and schedules shall be as
described in the following table taken from the "Mine
Permit 7-1 Renewal - Reclamation Schedule" dated July
21, 1992:

Page 18 of 18
A) R-Areas Final Reclamation
R-Area Acres Reclaim Date (Year)
R-1 476 1994
R-2 425 1997
R-3 945 2003
R-4 (N) 420 2002
R-4 (S) 260 2004
R-5* 520 2005
*R-5 includes Whitehurst Creek channelized
drainage which will be re-established and
reclaimed four (4) years after mining through the
area. Estimated date for final reclamation of
channelized drainage is December 1997.
B) Charles Tract
Pon
Acres
Reclaim Date (Year)
1
700
1993
2
156
1994
3
186
1995
4A
255
1994
4B
233
1995
5A
212
5B
323
*Pond Nos. 5A and 5B are potential areas for
wetland mitigation.
This permit, issued July 20, 1972, renewed July 20, 1982,
modified April 1, 1985, April 8, 1988, February 8, 1990,
November 29, 1990, June 13, 1991, September 6, 1991, October
31, 1991, February 28, 1992, June 2, 1992, June 4, 1992,
July 6, 1992, July 27, 1992, July 28, 1992 and January 4,
1993, renewed January 4, 1993, and modified March 17, 1994,
June 20, 1994, January 5, 1995 and September 15, 1995, is
hereby subsequently modified this 4th day of April, 1996
pursuant to G.S. 74-52.
00
By:
Charles H. Gardner, Director
Division of Land Resources
By Authority of the Secretary
Of the Department of Environment, Health and Natural Resources

JAME6 B. HUNTJR. ^.•.Tt
GOVERNOR
WAYNE MCDEVITT
SECRETARY
CHARLES H. GARDNER
P.G., P.E. DIRECTOR
AND STATE GEOLOGIST
-L
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF LAND RESOURCES
September 24, 1998
Mr. Stephen R. Phillips
Manager, Environmental Affairs
PCS Phosphate - Aurora Division
P.O. Box 48
Aurora, North Carolina 27806
RE: Mining Permit No. 07-01
Aurora Phosphate Mine
Beaufort County
Tar -Pamlico River Basin
Dear Mr. Phillips:
This office has reviewed your July 31, 1998 letter and its
enclosures requesting several modifications to the above mining permit.
These include changes in the final reclamation of the headwaters of
Whitehurst Creek, changes in the mine refuse disposal area, and
approval to remove overburden by hydraulic dredging.
Your modification request is hereby approved, with the following
stipulations:
1) The final reclamation of the headwaters of Whitehurst
Creek shall conducted in accordance with all current and
future conditions of the Division of Water Quality's 401
Certification (No. 2748);
2) The previous approval to move the mine refuse disposal
area shall be rescinded, the existing disposal area shall be
used by extending its western boundary approximately 250
feet as shown on the Mining Refuse Area map dated May
29, 1998, and the materials to be disposed shall remain
the same as indicated in your company's previously
approved list; and
3? The temporary reinstitution of dredging for the removal of
the top approximately 35 feet of overburden ahead of the
draglines shall be conducted in two separate blocks, each
approximately 120 acres, as indicated on the "1100 Acre
Mine Plan Map - Dredge Schematic" dated May 20, 1998.
This activity shall occur over the next 2 - 3 years and be
restricted to the northwest corner of the recently permitted
LAND QUALITY SECTION 1919} 733-4S74 FAX [phone]
GEOLOGICAL SURVEY SECTION 1919) 733-2423 FAX [phone],0900
P.O. Box 27687, RALEIGH. NORTH CAROLINA 2761 1 -7687 TELEPHONE , 91 91 733-3833 F4,X , 91 91 71 S-8801
AN EQUAL OPPORTUNITY l AFFIRMATIVE ACTION EMPLOYER - 50', RECYC4EV 10% PCST-CONSLIMER as Pr

Mr. Stephen R. Phillips
September 24, 1998
Page 2
1 ,100 acre area on the west side of the current mining operation. All
water from the dredge blocks shall ultimately be discharged through a
NPDES-permitted outfall. It is understood that dredging these blocks will
assist in the timing of the movement of bucket wheel equipment to the
NCPC Tract.
Please attach a coav of this modification approval letter to your existing -mining
permit for future reference. As a reminder, the total permitted acreage at this site is
11 , 512 acres.
This office has received and is currently evaluating your subsequent
modification request pertaining to the future development of a portion of the NCPC
Tract. We will contact you in the near future if additional information is needed.
Please contact Mr. Tracy Davis, P.E., State Mining Specialist, at (919) 733-
4574 should you have any questions concerning this matter.
Sincerely,
Charles H. Gardner, P.G., P.E.
CHG/td
9/98mod.pcs
cc: Mr. Tracy Davis, P.E.
Mr. Floyd Williams, P.G.
Mr. Bradley Bennett - DWQ
Ms, Barbara Rote - WRC

PCsy
Phosphate V AURORA 01 i ION_
RO. BOX 48, AURORA, NC 27806 DIRECT: [phone] FAX: [phone]
Stephen R. Phillips
Manager
Environmental Affairs
June 30, 1998
Mr, Charles Gardner, Director
Division of Land Resources
North Carolina Department of ENR
P. 0. Box 27687
Raleigh, North Carolina 27611-7687
Dear Mr. Gardner:
JUL 0 71998
u!i
As required by our Mining Permit No. 7-1, enclosed are the descriptions of
reclamation activities for the first half of 1998, and the reclamation plans for
the Last half of 1998. Attached to the descriptions are support maps No. 1H98RPSA
and 2H98RPSP.
If you have any questions, please do not hesitate to call me at the above number
or Jeff Furness at (919) 22-8249.
0"I'lic er A I y,
Stephen R. Phillips
SRP:JCF/pwo
Attachments
PC: T. J.
Regan
(w/attch)
W. T.
Cooper
(w/attch)
Floyd
Williams - DLR, WaRO
(w/attch)
W. A.
Schimming
(w/attch)
J. C.
Furness
(w/o attch)
M. T.
Harris/D. J. Millman
(w/attch)
I. K.
Gilmore
(w/attch)
W. R.
Walker
(w/o attch)
12-04-002-02
(w/attch)
00-20-000
(w/o attch)

Mine Site Reclamation
Actual Reclamation Development for the first half of 1998, (January -June).
For details, see the attached drawing 1H98RPSP,
R-1
At the recommendations of Mr. Henry Riddick, retired Beaufort County Extension Director, there
will no longer be any farm test plots on this area. Mr. Riddick feels that the previous years of
testing have been successful and conclusive to the point of establishing the facts that the R-1 area
is suitable for row crop farming. The 20 approximate acres that have been used for farm testing
will be planted in the fall with a wildlife cover crop.
Tree growth monitoring is continuing under Dr. Steve Broome and Dr. Ted Shear. Dr. Broome
has several small test plots are being compared with the small grain plots on R-2. Dr. Broome
also planted several different species of hardwood tree seedlings, as well as pine seedlings. The
growth and survival of this planting will be compared to a similar plot on R-2.
A 9.3 acre plot of pine tree seedlings and a 1,0 acre plot of mined hardwood tree seedlings were
planted on the leveled portion of the separator dike between R-1 and R-3.
Imi
Approximately 120 acres have been disk plowed and prepared for the spraying of a herbicide that
will control the phragmite growth. A contract high flotation backhoe was employed to construct
a network of cross surface drainage ditches. These ditches were constructed on 500 foot centers
and crossed the area, concentrating on the low center portion. After the cross ditches were
completed, a connector ditch was constructed along the center of the low area, connecting all of
the cross ditches and discharging to the decant structure. This drainage network will allow
surface vegetation to become established and assist in the development of the interior area.
Due to excessive spring rains, no agricultural test areas were planted; however, the wheat/vetch
test plot that was planted in the fall of 1997 has been successful. This plot was planted at the
recommendations of Mr. Gaylon Ambrose, Beaufort County Farm Agent.
In Marclr 1998, Dr. Steve Broome planted a large test plot (approximately 3 acres) of a variety of
hardwood and pine tree seedlings. The growth and survival rate of this plot will be compared
with the plot on R-1.
R-3
A contract high flotation backhoe was employed to construct a network of new surface drainage
throughout the area. Most of the ditches were constructed in a north -south direction and
approximately 350 feet apart. Most all of the ponded areas in the northern 75 percent of the area
were intercepted and drained. Surface drainage ditches were constructed through the ponded
areas near the south end, however, due to the consistency of the material, the ditches were not cut
very deep. With the completion of these ditches, vegetation should cover the area and assist in
the dewatering of the surface.

Actgal Reclamation Development Report for the first half of 1998
i June 11, 1998
Page 2
Approximately 60 acres along the north end have been chopped and disk plowed in preparation
for herbicide spraying to control the vegetation.
By-pass Mill Clays area being discharged on the eastern portion of the area to complete the
capping of R-3. This will continue throughout the year.
R-4
This area is continuing to dry and vegetation is beginning to cover the eastern half. A permanent
dewatering pump is being installed at the West End. When operational, this pump will control
the water Ievel in the lake to a minimum level, allowing the majority of the surface area to
become vegetated and stabilized for future development as a bottomland/upland hardwood
habitat.
R-S
Blend discharge into the area ceased in December 1997. The area is being allowed to dry and
consolidate before further filling takes place.
R-6
Blend discharge into the area began in December 1997 and will continue through the middle of
1999. The separator dike between R-6 and the future R-7 was completed in February 1998. A
mine access/utility corridor is being constructed from sandtailings, along the West Side. Bucket
Wheel spoil was placed into the area through mid -March, 1998.
Whitehurst Creek
In March 1998, a contract tree planter planted several different species of hardwood tree
seedlings along the bottom flat area of the constructed creek. This completes the reclamation of
the west prong until the tie-in is made at a later date.
G-1
A portion of the base of this torn down gypsum stack was graded. Vegetation is covering the area
and drying of the surface is near the point of allowing access with reclamation equipment.
Tree Planting on Bucket Wheel Spoil
A 60 acre area of bucket wheel spoil area was planted with pine tree seedlings. This area is on
the East Side of R-5 and was filled in 1993. This area will be monitored for growth and survival
rate of the seedlings.

Actual Reclamation Development Report for the first half of 1998.
June 11, 1998
Page 3
Charles Tract Activities
A large stormwater spillway is being constructed near the No. 2 Pond decant structure. This
spillway, when complete, will handle all surface water from Pond No. 1, Pond No. 2, and Pond
No. 4B, and will allow for the decertification of three (3) permitted impoundments.

Z
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RECLAIM AREA 1
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AGRDmTURAL TEST PLOTS W
..-.,...,. •-R'4, - -.-. ®PLANTED PINE TREE SEEDLINGS Z Z
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.... _ .. .. R-2 Qr• AREA PLwED IN PREPARATION FOR MERBD m SPRAYING J A
Q- AREA DRYING FOR FUTURE DEVELOPMENT I M
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...:.:.:.:.:.:.:.:.:.:... :,�- AGRICULTURAL TEST PLOT 0
- -- SURFACE DRADVAE DITCHES CONSTRUCTED 1-4
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Q- AREA DRYING IN PREPARATION FOR DEVELOPMENT W W J
R-q -AREA DRYING IN PREPARATION FOR DEVELOPMENT
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R-6 O- ACTIVE BLEND sTORAGE AREA V
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R-T �- SANDTAILINGS DISCHARGE AREAS
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- DUCIET VNEEL SPOIL ADVANCE
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PLANTED NARDVm TREE SEEDLINGS IN
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Q-PLANED PINE TREE SEEDLINGS
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Mine Site Reclamation
Planned Reclamation Development for the second half of 1998,_L)uly-December .
For details, see the attached drawing 2H98RPSP.
R-1
The 20-acre farm test area will be sprayed with a herbicide to control the vegetation. The area
will be plowed and planted with a wildlife cover crop.
Tree growth monitoring will continue under the direction of Dr. Broome and Dr.
Shear. Dr. Broome will continue to monitor growth and yield of the small grain test plots.
R-2
Approximately 120 acres of the area will be sprayed with a herbicide to control the vegetation.
After the herbicide has had its effect on the vegetation, the area will be disk plowed and prepared
for fall planting. In October, several species of clover and alfalfa will be planted as a wildlife
cover crop.
As the surface allows, improvements will be made by deepening the surface drainage ditch
network.
Tree growth on the small test plots, as well as the small grain yield on the farm test plots; will
continue to be monitored by Dr. Broome.
R-3
Approximately 60 acres along the north end will be sprayed with herbicide, plowed, and planted
with a wildlife cover crop. Plans call for several species of clover and alfalfa to be planted in
October.
Plans call for approximately 150 acres of the area to be chopped to stomp down the standing
vegetation and plowed to allow the upper one -foot of surface to dry. If time allows, this area will
be sprayed with a herbicide and planted with a cover crop.
Clay capping will continue on the northeastern area through the period.
As the surface allows, improvements will be made to the surface drainage ditch network.
R-4
With the installation of a permanent dewatering pump completed, the surface waters will be
pumped out of the area, allowing more of the surface to dry and become vegetated. This will be a
period of drying and consolidation of the surface.
R-5
This area will continue to dry, consolidate, and settle.

Planned Reclamation Development Report for the second half of 1998
June 15, 1998
Page 2
R-6
Blend will continue to be discharged into the area throughout the period. Sandtailings will
continue to be used to construct the access corridor on the West Side of the area.
R-7
Bucket Wheel spoils will continue to be discharged into this area throughout the period. Spoil
will be placed in such a manner so as to cell off the eastern half from the active mine area.
The base of gypsum stack number one will be sprayed with a herbicide to control the vegetation.
The surface will be plowed and planted with cover crop.
Charles Tract Activities
Plans call for the No. 2 Pond spillway to be completed by mid summer. When completed, all
surface rainwater from Pond No. 1, Pond No. 2, and Pond No. 4B will exit through this spillway,
follow by request to de -certify the associated permitted structures.

It
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DQ BY'WRW RECLAMATION—FLANTSITE DN. NOJeHmRS
PLANNED RECLAMATION DEVELOPMENT FOR
DATE;«-m-98 SECOND HALF OF 1998 (JULY—DECEMBER) SCALE; AS SHOWN

(lam' QGS �1�-656�f� Lo. �.rdpl�lLAsR�N glRS

JAMES S. HUNT JR.}
GOVERNOR
b�
WAYNE McDEv)Tr.�'
SECRETARY
GHARLES K
PG., P.E. DIRECTOR
AND STATE GEOLOGIST
cc; p4gp r
NqNwe 4
NORTH CAROLINA DEPARTMENT OF rU
ENVIRONMENT AND NATURAL RESOURCES G�
DIVISION OF LAND RESOURCES V
August 7,199A8
MEMORANDUM 866L 6 D d 3 S
TO: Mr. William Wescott a U ll u ga Q
Habitat Conservation Program Coordina 1,
Wildlife Resources Commission
FROM: Susan B. Edwards �&
Mining Program Secretary
Land Quality Section
SUBJECT: Mining Permit Modification Request for PCS Phosphate
Aurora Phosphate Mine - Permit No. 07-01
Beaufort County
Please find attached for your review a copy of the mining permit modification
request for the above referenced project.
Please review this information and advise as to the probability of this operation
having unduly adverse effect on wildlife and freshwater fisheries (G. S. 74-51 (2)).
Please respond by September 4._1991 so that we may complete our review of this
request within our statutory time limits.
As is the case in our review of all mining permit applications, renewals and
modifications, this office will carefully review all proposed erosion and sediment
control measures to ensure that they are sufficient to restrain erosion and off site
sedimentation. However, any comments your agency can provide regarding effects on
wildlife and freshwater fisheries would be greatly appreciated. If your staff wishes to
perform a site inspection, it is recommended that they contact the person submitting
this request to set up a convenient date and time. Also, please send a copy of your
comments to the person noted in the application. REJURN ALL APPLICAIIQN
MATERIALS AND MAPS WITH YOUR REVIEW COMMENTS TO THIS
FI E
Your continued cooperation in the review of these type requests is greatly
appreciated. Please contact Mr. Tracy Davis at [phone] if you have any
questions.
/SBE
Attachments
cc: Mr. Floyd Williams
LAND QUALITY SECTION [phone] FAX [phone]
GEOLOGICAL SURVEY SECTION [phone] FAX [phone]
P.O. BOX 27687, RALEIGH, NORTH CAROLINA 2761 I-76B7 TELEPHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/10% POST -CONSUMER PAPER

PCs
Phosphate AURORA DIVISION
P.O. BOX 48, AURORA, NC 27806
August 13, 1998
AUG 17 1998 �jL
Ms. Judy Wehner
Division of Land Resources
North Carolina Dept. of ENR
P. O. Box 27687
Raleigh, North Carolina 27611-7687
Dear Ms. Wehner:
Per your request, enclosed please find one additional set of maps and a check for $450.00
to be added to our Mine Permit 7-1 modification submittal dated July 31, 1998. My
understanding of the reason for your request is that this modification is deemed to be a
major modification, instead of a minor.
If you have any further questions, please call nee at [phone].
Sincerely,
Je ey Furness
Senior Environmental Scientist
Enclosures
PC: W. A. Schimming w/o encl.
S. R. Phillips/00-14-000 w/o encl.
M. T. Harris w/o encl.
1. K. Gilmore w/o encl.
12-04-001-47 w/o encl.

PCS
Phos atev AURORA
P.O. BOX 48, AURORA, NC 278DB
PAY TO THE ORDER OF
NC Dept, of ENR
P. 0. Box 27687
Raleigh, IBC 27611
Ohhank Psiaware
Dna Penns way
New Castae, DE 19720
62-20 CHECK NUMBER
311
CONTROL r
August 10, 1998 NUMBER J��.�978
AMOUNT
$450.00**
i' l
.
�I 4 •

NCDE `R
JAMES B. HUNT JR, -
GOVERNOR
WAYNE MCDEVITT
SECRETARY
CHIARLE9 H. GARDNER
P.G., P.E. DIRECTOR
AND STATE GEOLOGIST
NORTH CAROL.INA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIV[SION OF LAND RESOURCES
Mr, Jeffrey C. Furness
PCS Phosphate
P.Q. Box 48
Aurora, North Carolina 27806
Re: Permit No. 07-01
Application Received
Beaufort County
Tar River Basin
Dear Applicant:
August 7, 1998
August 5, 1998
A cursory review has been completed on the information you submitted
for the above referenced mine site. The information noted on the attached
checklist is required to complete your application. If the information has not
been received by this office by the indicated deadline, your application may be
disapproved.
PLEASE BE ADVISED THAT YOUR APPLICATION IS NOT COMPLETE
UNTIL ALL OF THE ITEMS LISTED ON THE ATTACHED CHECKLIST HAVE
BEEN FULLY ADDRESSED.
In order to complete the processing of your application, please forward
two (2) copies of the requested information to my attention at the following
address:
Land Quality Section
P. 0. Box 27687
Raleigh, N. C. 27611
Please contact me at [phone] if you have any questions.
Sincerely,
�Y
Jhn4eudith A.1 Wer
Assistant State Mining Specialist
Land Quality Section
TEDIjw
cc: Mr. Floyd Williams, P.G.
Mr. Charles Gardner, P.G., P.E.
LAND QUALITY SECTION 1919) 733-4574 FAX [phone](176
."M.OWN
.' GEOLOGICAL SURVEY SECTION (9191 733.2423 FAX [phone]
- Y _ P.O. BOX 27697, RALEIGH, NORTH CAROLINA 2761 [-7687 TELEPHONE [phone] FAX [phone]•8801
AN EQUAL OPPORTUNITY /AFFIRMATIVE ACTION EMPLOYER - 50 o RECYCLEDl1 Ora POST -CONSUMER PAPER

a
CHECKLIST FOR REQUIRED INFORMATION
The following information is required by 15A NCAC 5B .0004 and .0012 in
order for the al2plication to be deemed complete. If the information is not received
within 21 days of the date of this chenklist,__the review will cease and the
application file will be closed or your application may be disapproved.
Applicant: PCS Phosphate___ Date: 8�. 17/98
Project:_._ Aurora_ Phosphate Mine Time called: 10:30 am
Application/Permit No: 07-01 County: Beaufort Initials: JW
Date Received: 8 5 98
Mining permit boundary missing or confusing on map.
Buffer zones missing from map.
_: Access road and appropriate sediment and erosion control devices missing.
_: Location map sufficient to allow on -site inspection was not provided.
_: Stockpile and processing areas not indicated on the mine map.
Land entry agreement not provided (for leased land_).
Affidavit of Notification not completed and notarized.
Notification of all adjoining landowners not complete. Copies of the return
receipt cards not submitted.
X : Appropriate application fee not submitted.
X : Other:
Another set of maps is required for routing purposes. A fee of $50.00 was
received. The modification request requires a fee of $500.00. A balance of
$450.00 is needed to complete the review.

JAMES S. HUNTJR.
GOVERNOR
WAYNE MCDEVITT
SECRETARY
CHARLES_ H. GArtDNER
M, P.E. DIRECTOR
AND STATE GEOLOGIST
}' NORTH CAROLINA DEPARTMENT 0jr
ENVIRONMENT AND NATURAL RESOURCUS
DIVISION OF LAND RESOURCIxg
August 7, 1998
id UT LaiA !ice
TO: Mr. William Wescott
Habitat Conservation Program Coordinator
Wildlife Resources Commission
FROM: Susan B. Edwards
Mining Program Secretary
Land Quality Section
SUBJECT: Mining Permit Modification Request for PCS Phosphate
Aurora Phosphate Mine - Permit No. 07-01
Beaufort County
Please find attached for your review a copy of the mining permit modification
request for the above referenced project.
PIease review this information and advise as to the probability of this operation
having unduly adverse effect on wildlife and freshwater fisheries (G.S. 74-51 (2)).
Please respond by September 4. 1998 so that we may complete our review of this
request within our statutory time limits.
As is the case in our review of all mining permit applications, renewals and
modifications, this office will carefully review all proposed erosion and sediment
control measures to ensure that they are sufficient to restrain erosion and off -site
sedimentation. However, any comments your agency can provide regarding effects on
wildlife and freshwater fisheries would be greatly appreciated. If your staff wishes to
perform a site inspection, it is recommended that they contact the person submitting
this request to set up a convenient date and time. Also, please send a copy of your
comments to the person noted in the application. RETURN ALL APPLLCATLj)N
MATERIAL AND WITH YOUR REVIEW CDMMErT5 TO THIS
FFI
Your continued cooperation in the review of these type requests is greatly
appreciated. Please contact Mr. Tracy Davis at [phone] if you have any
questions.
/SBE
Attachments
cc: Mr. Floyd Williams
LAND QUALITY SECTION (9191 733-4574 FAX [phone]
GEOLOGICAL SURVEY SECTION 19191 733-2423 FAX (919) 733.O9Op
P.D. BOX 27687, RALEIGH. NORTH CAROLINA 27611.7687 TELEPHONE [phone] FaX [phone]p 1
AN EQUAL OPPORTUNITY IAFFI RMATIVE ACTION EMPLOYER - 50% RECYCLED/10% PO5--00%SU MER PAPER

DATE TO ASSISTANT �"� DATE TO SUSAN
LOGGED IN
MIIVING CHECKLIST FOR ROUTING
r _
Company Project Name
bLPermit No. County Date Received 5
Reviewer
Please make copies of check to include with Central Office and
Field Office files and log in checks.
* ❑ New ❑ Renewal ❑ Modification ❑ Transfer ❑ Release
❑ Additional Information Fee Needed
Fee Received: Amount -10 4v
Please route to:
Wr U�J Field Office
01"'Wiidlife Resources Commission
* ❑ Archives and History
Other: b A
Date Routed
�?--7-95
Date Routed
Date Routed
Date Routed
Suspense Date for Comments: (Date received +30 days,
not on weekend)
.33Please note the following:
Lry
*SUSAN: Please make file and return Checklist and file to Reviewer
White Copy to Field Office Yellow and Pink Copies to File Goldenrod Copy to Susan

DATE TO ASSISTANT + DATE TO SUSAN
LOGGED IN
M q, NG CHECKLIST FOR ROUTING
Company hr� C (' ._ i 1 Project Name izz
Permit No. County �� Date Received
Reviewer
^;
Please make copies of check to include with Central Office and
Field Office files and log in checks.
* ❑ New ❑ Renewal ❑ Modification ❑ Transfer ❑ Release
❑ Additional Information EJ Fee Needed 0
Fee Received: Amount '�o 00
Please route to:
'2 c�tl T,,%7 on Field Office
0 Wildlife Resources Commission
* ❑ Archives and History
' Other :
Date Routed
5?--7-9 5
Date Routed (Y
Nr
Date Routed
Date Routed
Suspense Date for comments: �C (Date received +30 days,
not on weekend)
.lJ Please note the following:
*SUSAN: Please make file and return Checklist and file to Reviewer
White Copy to Field Office Yellow and Pink Copies to File Goldenrod Copy to Susan

PCS
Phosphate AURORA
P.O. BOX 48, AURORA, NC 27808
PAY TO THE ORDER OF
North Carolina Dept, of ENR
P. 0. Box 27687
Raleigh, NC 27611
CAbank Dekwara
One Punn's way
New Cas7s, DE 19720
62.20 CHECK NUMBER
311
CONTROL
July 30, 1998 NUMBER 535170
AMOUNT
$50.00**

PCs
Phosphate AURORA DIVISION
P.O. BOX 48, AURORA, NC 27806
July 31, 1998
Mr. Tracy Davis, P.E.
Division of Land Resources
North Carolina Dept. of ENR
P. O. Box 27687
Raleigh, North Carolina 27611-7687
Ref: Minor Modification to Mine Permit 7-1
Dear Mr. Davis:
PCS Phosphate requests that several minor modifications be made to Mine Permit 7-1.
These modifications involve Whitehurst Creek, the mine refuse disposal area, and
dredging overburden.
Enclosed for additions to your files are the final agreements (correspondence and
drawings) between PCS Phosphate and the North Carolina Division of Water Quality
regarding the issuance of the revised 401 Certification for Whitehurst Creek. This should
make your files complete on this subject.
In an October 15, 1997 letter to DLR, PCS Phosphate requested approval of a new
location for our mine refuse disposal area, and stated that the current disposal area would
be closed. After further analysis, we have determined that the current area is still usable
for some period of time. Therefore we would Iike to rescind our request to move the
disposal area, continue to use the currently permitted area by moving the western
boundary 250 feet, with the same materials disposed in it as our previously approved list.
A map showing this new western boundary is enclosed.
The final modification is the temporary reinstitution of dredging for the removal of the
top f 35 feet of overburden ahead of the draglines. Two separate blocks, each
+' approximately 120 acres, will be dredged over the next 2 - 3 years in the northwest corner
of the recently permitted 1,100-acre parcel on the west side of the current mining
operation. Dredging these blocks will assist in the timing of the movement of
bucketwheeI equipment to the NCPC Tract. Two enclosed figures show the location of
the dredge blocks. Water from the dredge blocks will ultimately be discharged through a
NPDES-permitted outfall.

Enclosed is a check for $50.00 to cover the cost of a minor modification. Should you
have any question on any of these three issues, please give me a call at [phone].
Sincerely,
07,,,,
Je ey C.Furness
Environmental Scientist
Enclosures
PC: Floyd Williams - DLR, WaRO
W. A. Schimming
W. T. Cooper
S. R. Phillips / 00-14-000
A T. Harris
1. K. Gilmore
D. A. Jacoby
12-04-001-47

PCS
Phosphate AURORA DIVISION
?,O. BOX 48, AURORA, NC 27606
May 28, 1998
Mr. John Dorney
Division of Water Quality
North Carolina DENR
4401 Reedy Creek Road
Raleigh, North Carolina 27607
Re: Modification of 401 Water Quality Certification
Relocation of Upper Portion of Whitehurst Creek
DEM #92039
Certification 2748 (originally issued 30 June 1992)
Beaufort County
Dear Mr. Dorney:
The referenced revised Water Quality Certification, issued on 12 December 1996,
requires that grading and planting of the upper portion of Whitehurst Creek be completed
by 7 June 1998 (except for final tie-in, which is to be complete by 7 June 2003). This
letter is official notice that the excavation and grading of the upper Whitehurst Creek
channel through reclaimed land is complete, along with the grading of a 5-acre area
adjacent to the sediment pond at the head of the east prong of Whitehurst Creek. Tree
planting (both balled and burlapped and bare root trees) was complete on 6 March 1998.
We would be happy to take DWQ staff on a tour of this project if the opportunity arises.
Please call me at [phone] if you have any questions.
Sincerely,
*r nctir
!!��
JLvffrey C. Furness
Senior Environmental Scientist
JCF/pwo
PC: W. A. Schimming D. J. Millman
W. T. Cooper W. R. Walker
S. R. Phillips / 00-14-000 P. J. Moffett
12-01-004-26

State of North Carolina
Department of Environment,
Health and Natural Resources r
ia
Division of Water Quality
James B. Hunt, Jr., Governor MOM
Wayne McDevitt, Secretary p E H NJA. Preston Howard, Jr., P.E., Director
November 19, 1997
pQnc�,r�a la -al- o04- atn
Mr. Jeffrey Furness _ o u 4 S
PCS Phosphate 3, 7
Post Office Box 48
Aurora, NC 27806 BY �3w3
Dear Mr. Furness:
Re: N itigadon plan approval
Whitehurst Creek relocation
Beaufort County
DWQ 92039
On December 12, 1996, DWQ issued a revised Certification for the relocation of the
upper portion of ''Whitehurst Creek. A condition of that Certification was that additional
written approval was required for the mitigation plan. That plan (dated February 10, 1997)
was received. by DWQ. This plan is acceptable to DWQ to meet the additional condition of
Certification Number 2748. All other conditions of that Certification are still applicable.
Please call Mr. John Dorney at [phone] if you have any questions.
Sin ly,
'i
ston oward, Jr.
cc: Washington DWQ Regional Office
Central Files
Tracey Davis; Division of Land Resources
Division of Water Quality - Non -Discharge Branch
4401 Reedy Creek Rd., Raleigh, NC 27607 Telephone [phone] FAX * 733-9959
An Equal Opportunity Affirmative Action Employer • 50% recycled/10% post consumer paper

PCS
Phosphate VAURORA DIVISION
P.O. BOX 48. AURORA. NC 27806
February 10. 1997
Mr. John Dorney
Division of Water Quality
North Carolina Dept. of EHNR
4401 Reedy Creek Road
Raleigh, NC 27626-0535
Dear Mr. Dorney:
A modification to the 401 Water Quality Certification for Whitehurst Creek was issued by the
Division of Water Quality on December 12, 1996. A stipulation of the modification was that a
final mitigation plan for all wetland and stream mitigation must be submitted within two months.
Enclosed please find two copies of the mitigation plan. The plan consists of a narrative portion
and a set of five large drawings. The narrative describes the tree planting specifications,
monitoring plans and success criteria, and the drawings (labeled figures 1-5) show the plans for
different parts of the project.
1f you have any questions on this plan, please call me at 919/322-8249. When you indicate your
approval of this plan, it will be submitted to the Division of Land Resources for incorporation
into the reclamation portion of our mining permit.
Sincerely,
y tit�ui,
frey C. Furness
JCF/re
Enclosures
PC: Tracey Davis - DLR, Raleigh (w/o encl)
W. A. Schimming (w/encl)
P. J. Moffett (w/encl)
D. J. Millman (w/encl)
S. . s/12-01-004-26 (w/encl)
B. W. Bolick - CZR (w/encl)
00-14-000 (w/o encl)

Mitigation Plan for the
Whitehurst Creek Channel
Beaufort County, North Carolina
PCS Phosphate Company, Inc.
February I997

1.0 INTRODUCTION
On April 24, 1992 PCS Phosphate Company, Inc. (PCS Phosphate)
submitted an application for a 401 Water Quality Certification to the North
Carolina Division of Water Quality (DWQ) to impact a portion of the
channelized drainage of Whitehurst Creek. Approval of the 401 was issued
on June 30, 1992, and a mitigation channel was constructed. A
modification to the 401. to relocate a portion of the mitigation channel, was
requested on December 15, 1994 and approved on May 30, 1995. A second
modification was requested on May 28, 1996, which. involved leaving the
current Whitehurst Creek mitigation channel in place, construction of a new
channel through reclaimed land, and a change in the date for the whole
channel system to be tied together and complete. This request was approved
by DWQ and resulted in the issuance of a modified 401 on December 12,
1996. This 401 Certification required that a mitigation plan for Whitehurst
Creek be submitted to DWQ for approval within two months of the date of
the modification approval.
. This document is the proposed mitigation plan as specified in the 401
Certification conditions. The Whitehurst Creek mitigation project consists
of three distinct but integrated areas, shown in the large drawing labeled
Figure 1. The first is the 10-foot wide stream channel itself, which consists
of an east prong, (Figure 2), which was completed in August 1995, and a
west prong (Figures 3 and 4). The second is the flat floodplain areas
adjacent to the west prong and at the confluence of the east and west prongs
(Figures 3 and 4). Third is a headwater area located at the extreme upper
end of the east prong (Figure 5 ).
2.0 STREAM CHANNEL MONITORING
2.1 Water Ouality. The parameters to be monitored include dissolved
oxygen, temperature, pH, conductivity, fluoride and total phosphorus.
Water quality monitoring has been done on a monthly basis in the east
prong for several years. Monitoring water quality in the west prong will
begin one month after it is tied -in to lower Whitehurst Creek, which must be
done by June 4, 2003. Samples will be collected from two locations in each
prong, one near the upper ends and one nearer the lower ends.

2.2 Fish. Fish sampling will be conducted during winter (,February) and
summer (July) using a backpack electroshocker at an upstream and a
downstream location in each prong. This sampling is presently occurring in
the eastern prong, and will begin in the western prong following tie-in.
Samples will be taken over two 600-foot segments at each site, with
upstream and downstream blocknets used when needed. Fish collected will
be identified, measured, and either kept as vouchers or released. Voucher
specimens will be preserved in 10 percent formalin and transferred to 95
percent denatured ethanol after 48 hours. The created stream channels will
be considered successful when there is no greater than 25 percent reduction
in the total number of species found before mining.
21.3 Benthic Macro i nverte brates. Qualitative macro invertebrate sampling
will be conducted during winter and summer at an upstream and a
downstream location in each prong. Nine standing sweep net samples will
be taken at each site for each seasonal survey. These samples will be hand -
sorted in the field and all macro invertebrates collected preserved in 10
percent formalin. Additional macro invertebrates will be collected from log
washes and rubs as well as by incidental captures made during visual
searches. All specimens will be transferred to 95 percent denatured ethanol
in the lab. Macro invertebrates will be identified to lowest reasonable taxa
within each group. Taxa identification for specimens collected in the
surveys will rely primarily on Brigham et al (1982), and will be based on
the level of effort established by DWQ during their sampling of Whitehurst
Creek in February 1992. The created stream channels will be considered
successful when there is no greater than 25 percent reduction in the total
number of genera (or species where identification is feasible) found before
mining. Monitoring will continue until this success criterion is met or until
the DWQ concurs that the benthic macro invertebrate community has
successfully recolonized, whichever is sooner.
3.0 BOTTOMLAND HARDWOOD WETLAND MONITORING
The monitoring of the floodpiain wetland that will be created adjacent
to the stream channel will be based on the Compensatory Hardwood
Mitigation Guidelines published by the Wilmington District of the U. S.
Army Corps of Engineers.

3.1 Planting Specifications. Hardwood trees will be planted at a density
of at least 400 trees per acre. The initial planting goal is 20 percent
containerized and 80 percent bare root seedlings, but may be modified
depending on ability to install the larger trees. Tree species on the lowest
floodplain areas may include bald cypress, green ash, water tupelo and
overcup oak. Tree species on the higher floodplain areas will include, but
not be limited to, willow oak, laurel oak, swamp chestnut oak, water oak,
cherrybark oak, river birch and blackgum. Trees will be planted in the west
prong floodplain in February 1998, and in the floodplain area at the
confluence of the east and west prongs by February 2003.
3.2 Tree Monitoring and Success Criteria. Tree success will be
monitored with tree transects scattered throughout the floodplain area.
Success is measured by tree survival and species composition. Average tree
density will be at least 320 planted trees/acre at the end of the third growing
season. At least six species of planted hardwood trees will be present at the
end of the third growing season (with bald cypress considered hardwood).
3.3 . Hydrology Monitorinjg and Success Criteria. The hydrology of the
bottomland hardwood floodplain areas will be monitored with 24-inch wells
spaced within the floodplain and checked periodically throughout the
growing season. On most areas, the hydrology should meet or exceed the
level of 12.5 percent of the growing season as specified in the Corps of
Engineers Compensatory Hardwood Mitigation Guidelines. Wetland
restoration sites that are inundated or saturated to the surface for a
consecutive number of days greater than 12.5 percent of any one growing
season under normal conditions are hydrologically successful. Portions of
this site which after three years of monitoring are inundated or saturated to
the surface between 5 and 12.5 percent of the growing season in most years
will be considered successful on a case by case basis. Standing water within
12 inches of the surface will be considered a positive indicator of wetland
hydrology.
4.0 HEADWATER AREA.
The monitoring of the headwater area that will be developed at the
upper end of the east prong will be based on the Compensatory Hardwood
Mitigation Guidelines published by the Wilmington District of the U. S.
Army Corps of Engineers.
3

4.1 Planting Specifications. Bare root hardwood tree seedlings will be
planted at a density of at least 400 trees per acre. Tree species may include
bald cypress, green ash, water tupelo, overcup oak, willow oak, water oak,
laurel oak, swamp chestnut oak, cherrybark oak, blackgum, and river birch.
Trees will be planted in February 1998.
4.2 Tree Monitoring and Success Criteria. Tree success will be
monitored with tree transects scattered throughout the headwater area.
Success is measured by tree survival and species composition. Average tree
density will be at least 320 planted trees per acre at the end of the third
growing season. At least six species of planted hardwood trees will be
present at the end of the third growing season (with bald cypress considered
a hardwood).
4.3 Hydrology Monitoring and Success Criteria. The hydrology of the
headwater area will be monitored with 24-inch wells checked periodically
throughout the growing season. The hydrology of the bottomland hardwood
floodplain areas will be monitored with 24-inch wells spaced within the
floodplain and checked periodically throughout the growing season. On
most areas, the hydrology should meet or exceed the level of 12.5 percent of
the growing season as specified in the Corps of Engineers Compensatory
Hardwood Mitigation Guidelines. Wetland restoration sites that are
inundated or saturated to the surface for a consecutive number of days
greater than 12.5 percent of any one growing season under normal
conditions are hydrologically successful. Portions of this site which after
three years of monitoring are inundated or saturated to the surface between
5 and 12.5 percent of the growing season in most years will be considered
successful on a case by case basis. Standing water within 12 inches of the
surface will be considered a positive indicator of wetland hydrology.
5.0 REPORTS
An annual monitoring report will be submitted to DWQ by April 1 of
the following year. Upon meeting the stated success criteria, the wetland
areas within the scope of the Whitehurst Creek project would be expected to
count as mitigation credits for future wetland impacts.
H

6.0 LITERATURE CITED
Brigham, A.R., W. U. Brigham, and A Gnilka, eds. 1982. Aquatic insects
and oligochaetes of North and South Carolina. Midwest Aquatic
Enterprises, Mahomet, Illinois. 837 pp.

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
Mr. Jeffrey Furnes!ENVM0NMFWAL AFFAIRS DEFT.
PCS Phosphate
P.O. Box 48 JIB I -) 1996
Aurora, NC 27806
Dear Mr, Furness:
ALinSKMA,
0 ma ikk
C)EHNR
December 12, 1996
Re: Modification of 401 Water Quality Certification
Relocation of upper portion of Whitehurst Creek
DEM #92039
Certification 2748 (originally issued 30 June 1992)
Beaufort County
Oa -a)- Of
AS
W,C
3 R P /oa- ry-0oo
N MT3 /raRw
�,1 M
bJ r+n
ia- o/ - Qoy
Jccl - Cc si
The Certification issued on 30 June 1992 to Texasgulf, Inc. (now PCS Phosphate) is
hereby modified to read as follows:
Reconstruction of the upper portion of Whitehurst Creek shall be completed by 7 June
2003 as described in your letter of 29 August 1996 which shall include grading, tree
planting and establishment of a permanent continuous hydrologic connection to the
remaining portion of Whitehurst Creek. Grading and planting shall be done and completed
by 7 June 1998 with the final tie-in to the new channel by 7 June 2003. If these dates are
not met, a $1,000.00 per day penalty will be imposed by DWQ until the creek is
reestablished to assure compliance. In addition an additional 0.4 acre mitigation area shall
be created where the two channels come together. A final mitigation plan for all wetland
and stream mitigation shall be submitted within two months of the date of this letter.
All other conditions of this Certification are still applicable. Please call Mr. John
Dorney of my staff at 919-733-1786 if you have any questions.
cc: Jim Mulligan, DWQ Washington Regional
Kristen Rowles, Pamlico -Tar River Found
Central Files
Wilmington District Corps of Engineers
Tracey Davis, Division of Land Resources
Sincerely
rstop Howar
mice
ati
Division of Water Quality - Environmental Sciences Branch
4401 Reedy Creek Rd., Raleigh, NC 27626-0535 - Telephone [phone] - FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

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RICHLANDS TOWNSHIP BEAUFORT COUNTY NORTH CAROLINA N
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VEGETATION IN THE FORM OF GRASS SHOULD BE ESTABLISHED IN SUCH A MANNER
THAT SMALL GRAINS WILL STABILIZE THE SOIL UNTIL NATIVE PLANTS E'ECOME
REESTABLISHED. PREFERABLE GRASS INCLUDES: ANNUAL RYE GRAFTS, RYE,
WHEAT, OATS, SORGHUM, or ANNUAL LESPEDEZA.
TREES SHOULD BE PLANTED AT A DENSITY OF 400 TREES PER ACRE WITH A GOAL
OF 320 TREES PER ACRE AFTER 5 YEARS, TREES MORE TOLERANT OF FLOODING
CONDITIONS (SUCH AS BALD CYPRESS) SHOULD BE PLANTED AT THE LOWEST
AREAS WITHIN THE FLOOD PLAIN AREA.
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Phosphate AURORA DIVISION
RICHLANDS TOWNSHIP BEAUFORT COUNTY NORTH CAROLINA
DATI;:_08-114-96-- ROBERT M. CHILES, P.E_
J+OB NO. — ysCf74— ENGINEERS AND CONSULTANTS
SCALE: _ �_. __ 1(70' NEW KERN. NCRTH CAROLINA

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Division of Land Resources Quarterly Meeting
June 9, 1998
10:00 a.m. @ Mine Office
Proposed Agenda
Discussion Topics (10:00 a.m. - 11:45 a.m.)
• Status Update of Mining and Reclamation Activities
• Future Plans/Permitting Needs
• Prestripping Assistance via Dredging
• NCPC Tract Area
• Relocation of 306
• Mine Permit for Alternative E plus
Ancillary Acres
• Mining Refuse Area
• Reclamation Presentation
• September 1998 (IMCC)
• October 1998 (NASLR)
Lunch (11:45 a.m. - 12:30 p.m.)
Tour (12:30 p.m. - 2:30 p.m.)
• Reclamation Areas - Plantsite
• Charles Tract - Clay Pond No. 2 Dike Breach

Division of Land Resources Quarterly Meeting
June 9, 1998
10:00 a.m. @ Mine Office
Proposed Agenda
Discussion Topics (10:00 a.m. - 11:45 a.m.)
• Status Update of Mining and Reclamation Activities
• Future Plans/Permitting Needs
• Prestripping Assistance via Dredging
• NCPC Tract Area
• Relocation of 306
• Mine Permit for Alternative E plus
Ancillary Acres
• Mining Refuse Area
• Reclamation Presentation
• September 1998 (IMCC)
• October 1998 (NASLR)
Lunch (11:45 a.m. - 12:30 p.m.)
Tour (12:30 p.m. - 2:30 p.m.)
• Reclamation Areas - Plantsite
• Charles Tract - Clay Pond No. 2 Dike Breach

Author: Tracy Davis at NROLROIP
Hate: 5/8/98 12:26 PM
Priority: Normal
TO: [e-mail] at Internet
TO: Jim Simons
CC: Tracy Davis
Subject: Re[2]: PCS Phosphate
------------------------------------- Message Contents ---_----_----------------------------
yes, leave Raleigh around 7:00 am and return to Raleigh around 5:00
pm.
Reply Separator
Subject: Re: PCS Phosphate
Author: Jim Simons at NROLROIP -pS
Date: 5/8/98 10:23 AM
vv.)
Mining, mining, mining. I can go as far as I know. with Mell gone /jp 6l1a
a,
and the GA in town, I am subject to call at the last minute. Is this + It fjW
a one day trip? Jim
Reply Separator TiA�
Subject: PCS Phosphate
Author: Tracy Davis at NROLR0IP R�� $�
Date: 5/8/98 9:59 AM
As Charles wanted only 3 of us to go, and Mell and Jim Leumas will be
out of the State on Tuesday, 6/9, are you two still a go for meeting
with PCS? CHG said he can't make it.
I need to let Jeff Furness know soon. We'll meet at the mine offic
as usual, around 10: 00 am.
Please confirm your attendence.
Thanks! r
JJJ
Tracypk
�"

Author: Tracy Davis at NROLROlP
Date: 5/8/98 9:59 AM
Priority: Normal
TO: [e-mail] at Internet
TO: Jim Simons
CC: Tracy Davis
Subject: PCS Phosphate
------------------------------------ Message Contents ---------------- --------------------
As Charles wanted only 3 of us to go, and Mell and Jim Leumas will be
out of the State on Tuesday, 6/9, are you two still a go for meeting
with PCS? CHG said he can't make it.
I need to let Jeff Furness know soon. We'll meet at the mine office,
as usual, around 10:00 am.
Please confirm your attendence.
Thanks?
Tracy

Author: Charles Gardner at NROLR0IP
Date: 5/4/98 5:48 PM
Priority: Normal
Receipt Requested
TO: Nell Nevils
TO: Tracy Davis
Subject: PCS Phosphate Meeting
------------------------------------- Message Contents----------------------------------
Mell and Tracy, please arrange this to keep the number of attendees from being
outlandish. I'd say 3 from LQS (including Floyd) would be plenty. One mining,
one dams, and Floyd. You or Jim could go if need be. I doubt that I can make
it this time.
Forward Header
Subject: PCS Phosphate Meeting
Author: Tracy Davis at NROLROiP
Date: 5/4/98 10:01 AM
Charles,
Jeff Furness called me late last week to see when we could meet with
PCS staff. He wants to update us on PCS' current activities as well
as brief us on PCS' future plans, especially the NCPC Tract. Then, we
can take the usual tour of the site.
Here are the dates that Jeff and I are available:
June 8, 9, 10, 11
I would prefer Tuesday, June 9th.
Everyone, please let me know if you are interested in attending, so I
can advise Jeff as soon as possible.
Thanks!!
Tracy

Author: Rick Moore at NROLR0IP
Date: 5/4/98 10:07 AM
Priority: Normal
TO: Tracy Davis
Subject: Re: PCs Phosphate Meeting
------------------------------------ Message Contents ------------------------------------
I have been told that I will probably be in Hot Springs with Jim and
Mell. If I don't go to Hot Springs, I would like to go with you. I
am available for all of those dates, if not in Ark.
Thanks for the invite!
Rick
Reply Separator
Subject: PCS Phosphate Meeting
Author: Tracy Davis at NROLROIP
Date: 5/4/98 10:01 AM
Charles,
Jeff Furness called me late last week to see when we could meet with
PCs staff. He wants to update us on PCS' current activities as well
as brief us on PCs' future plans, especially the NCPC Tract. Then, we
can take the usual tour of the site.
Here are the dates that Jeff and I are available:
June 8, 9, 10, 11
I would prefer Tuesday, June 9th.
Everyone, please let me know if you are interested in attending, so I
can advise Jeff as soon as possible.
Thanks!!
Tracy

Author: Jim Simons at NROLR0IP
Date: 5/4/98 10:04 AM
Priority: Normal
TO: Charles Gardner
TO: Jim Leumas
TO: Rick Moore
TO: Mell Nevils
TO: Tony Sample
TO: Judy Wehner
TO: [e-mail] at Internet
TO: Tracy Davis
Subject: Re: PCS Phosphate Meeting
------------------------------------ Message Contents
Mell and JKL will be in Hot Springs, AK at a dam conference for all of
those days. I can go to PCS either of those days. Jim
Reply Separator
Subject: PCS Phosphate Meeting
Author: Tracy Davis at NROLR0IP
Date: 5/4/98 10:01 AM
Charles,
Jeff Furness called me late last week to see when we could meet with
PCS staff. He wants to update us on PCS' current activities as well
as brief us on PCS' future plans, especially the NCPC Tract. Then, we
can take the usual tour of the site.
Here are the dates that Jeff and I are available:
June 8, 9, 10, 11
I would prefer Tuesday, June 9th.
Everyone, please let me know if you are interested in attending, so I
can advise Jeff as soon as possible.
Thanks!!
Tracy

k . 104
Author: Tracy Davis at NROLR0IP
Date: 5/4/98 10:01 AM
Priority: Normal
TO: Charles Gardner
TO: Jim Leumas
TO: Rick Moore
TO: Mell Nevils
TO: Tony Sample
TO: Jim Simons
TO: Judy Wehner
BCC: Tracy Davis
TO: [e-mail] at Internet
Subject: PCS Phosphate Meeting
------------------------------------ Message Contents ----____-____-_---------_--_--_-----
Charles,
Jeff Furness called me late last week to see when we could meet with
PCS staff. He wants to update us on PCS' current activities as well
as brief us on PCS' future plans, especially the NCPC Tract. Then, we
can take the usual tour of the site.
Here are the dates that Jeff and I are available:
June 8, 9, 10, 11
I would prefer Tuesday, June 9th.
Everyone, please let me know if you are interested in attending, so I
can advise Jeff as soon as possible.
Thanks!!
Tracy

Author: Joan Bolick at NROLR01P
Date: 4/30/98 9:18 AM
Priority: Normal
TO: Tracy Davis
Subject: call
------------------------------------ Message Contents _-__---------_---__--_____-____-----
Jeff Furness of PCS Phosphate wants you to call him at 919-322-B249.

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
Mr, Jeffrey Furness
PCS Phosphate
Post Office Box 48
Aurora, NC 27806
Dear Mr. Furness:
Re: Mitigation plan approval
Whitehurst Creek relocation
Beaufort County
DWQ 92039
1 `�
r�
�EHNR
C�3
DEC z o 7997
On December 12, 1996, DWQ issued a revised Certification for the relocation of the
Lipper portion of Whitehurst Creek. A condition of that Certification was that additional
written approval was required for the mitigation plan. That plan (dated February 10, 1997)
was received by DWQ. This plan is acceptable to DWQ to meet the additional condition of
Certification Number 2748. All other conditions of that Certification are still applicable.
Please call Mr. John Dorney at [phone] if you have any questions.
Sinpftly,
ston l4oward, Jr., P. .
cc: Washington DWQ Regional Office
Central Files
Tracey Davis; Division of Land Resources
Division of Water Quality • Non -Discharge Branch
4401 Reedy Creek Rd., Raleigh, NC 27607 Telephone [phone] FAX # [phone]
An Equal Opportunity Affirmative Action Employer • 50% recycled/10% post consumer paper

PCS
Phos tev AURORA DIVISION
P.O. BOX 48, AURORA, NC 27806
February 10, 1997
Mr. John Dorney
Division of Water Quality
North Carolina Dept. of EHNR
4401 Reedy Creek Road
Raleigh, NC 27626-0535
Dear Mr. Dorney:
F E g 1. 21997
lay
A modification to the 401 Water Quality Certification for Whitehurst Creek was issued by the
Division of Water Quality on December 12, 1996. A stipulation of the modification was that a
final mitigation plan for all wetland and stream mitigation must be submitted within two months.
Enclosed please find two copies of the mitigation plan. The plan consists of a narrative portion
and a set of five large drawings. The narrative describes the tree planting specifications,
monitoring plans and success criteria, and the drawings (labeled figures 1-5) show the plans for
different parts of the project.
If you have any questions on this plan, please call me at 919/322-8249. When you indicate your
approval of this plan, it will be submitted to the Division of land Resources for incorporation
into the reclamation portion of our mining permit.
Sincerely,
Frey C. Furness
JC F/re
Enclosures
PC: Tracey Davis - DLR, Raleigh (w/o encl)
W. A. Schimming (w/encl)
P. J. Moffett (wlencl)
D. J. Millman (w/encl)
S. R. Phillips/12-01-004-26 (wlencl)
B. W. Bolick - CZR (wlencl)
00-14-000 (w/o encl)

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
Mr. Jeffrey Furness
PCS Phosphate
P.O. Box 48
Aurora, NC 27806
Dear Mr. Furness:
LT!;VA
A&O
�EHNR
December 12,
/ .
AFC N�
�I /V1
Re: Modification of 401 Water Quality Certification QG
) /
Relocation of upper portion of Whitehurst Crd6 ,Q,l
DEM #92039 ���
Certification 2748 (originally issued 30 June 1992)
Beaufort County 1/0i.-
The Certification issued on 30 June 1992 to Texasgulf, Inc. (now PCS Phosphate) is
hereby modified to read as follows:
Reconstruction of the upper portion of Whitehurst Creels shall be completed by 7 June
2003 as described in your letter of 29 August 19966which shall include grading, tree
planting and establishment of a permanent continuous hydrologic connection to the
remaining portion of Whitchurst Creels. Grading and planting shall be done and completed
by 7 June 1998 with the final tie-in to the new channel by 7 June 2003. If these dates are
not met, a $1,000.00 per day penalty will be imposed by DWQ until the creek is
reestablished to assure compliance. In addition an additional 0.4 acre mitigation area shall
be created where the two channels come together. A final mitigation plan for allmetland
and stream mitigation shall be submitted within two months of the date of this letter.
All other conditions of this Certification are still applicable. Please call Nfr:?`olin`'
Dorney of my staff at 919-733-1786 if you have any questions. I DEC 2
cc: Jim Mulligan, DWQ Washington Regional
Kristen Rowles, Pamlico -Tar River Found,
Central Files
Wilmington District Corps of Engineers
Tracey Davis, Division of Land Resources
Division of Water Quality • Environmental Sciences Branch
4401 Reed Creek Rd. Raleigh, NC 27626-0535 • Telephone [phone] • FAX [phone]
0 y � 9 P
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

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W I YOU ERE OUT
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TELEPHONED
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CALLED TO SEE YOU
WILL CALL AGAIN
WANTS TO SEE YOU
URGENT
RETURNED YOUR CALL
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PCS
PhosphateVA U R JRA.QLVISION
P.O. BOX 48, AURORA, NC 27808
October 31, 1996
Mr. John Dorney
Division of Water Quality
N. C. Dept. of EHNR
4401 Reedy Creek Road
Raleigh, North Carolina 27626-0535
Dear Mr. Dorney:
f F?ECEIVED
DEHNR
IAND OLIALIT, r
We have reviewed the draft modification of the 401 Water Quality Certification for
Whitehurst Creek dated October 17, 1996, which included the attached map depicting
two additional created wetland areas consisting of 2.5 acres and 0.4 acres. We
appreciate the opportunity to comment on it before it becomes final.
We believe that the 2.5 acre wetland is not practical from several standpoints. First, the
proposed southern half of the 2.5 acre area peaks in elevation at just under 19 feet msl.
This is where the stilling basin spoil was placed. A copy of the elevation survey of that
area is attached. The channel bottom through there is at 2 feet msl, therefore
approximately 16 feet of earth would need to be excavated to create a bottomiand
wetland.
Second, the north area currently has several large pecan trees on it that we intentionally
saved during channel design and construction. Finally, excavating this proposed 2.5
acre area would essentially eliminate one of the few meanders constructed in this
channel. Therefore we request that reference to the 2.5 acre area be eliminated from
the draft 401.
We would agree to widening the area where the east prong would meet the west prong
to include an additional 0.4 acres of bottomland floodplain wetland. This would need
to be done when the west prong tie-in is complete by June 7, 2003. We feel that this
0.4-acre area along with our proposed 5-acre headwater area is a reasonable amount of
acreage added to that involved in the east prong channel itself.

� P.

Mr. John Domey
October 31, 1996
Page 2 of 2
To make sure all the requirements are clear, we would propose that the Iast two
sentences in the main paragraph in your draft 401 be revised to read: "In addition, an
additional 0.4 acre floodplain wetland area shall be created at the end of the east prong
where it ties in to the west prong. Grading and planting of this 0.4 acre area should
also be complete by 7 June 2003. A final plan for all stream mitigation and wetland
creation shall be submitted within two months of the date of this Ietter."
We appreciate the Division's willingness to work toward agreeing to a modified 401,
and look forward to receiving a final version in the near future. If you have any
questions please call me at 919/322-8249.
Sincerely,
L,!� �� Furness
JCF/re
Attachment
pc: W. A. Schimming (w/attach)
W. T. Cooper (w/attach)
S. R. Phillips/00-14-000 (w/attach)
H. M. Breza/D. J. Millman (w/attach)
P. J. Moffett (w/attach)
Tracy Davis, DLR, Raleigh (w/attach)
12-01-004-26 (wlattach)

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SPOIL , 9.7
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PCS
Phosphate VAURORA DIVISION
P.O. BOX 48. AURORA. NC 27806
August 29, 1996
Mr. Jimmie Overton
Division of Water Quality
North Carolina Department of EHNR
4401 Reedy Creek Road
Raleigh, North Carolina 27626-0535
Re: Modification of 401 Water Quality Certificati
Relocation of Upper Whitehurst Creek
DEM #92039
Certification 2748 (originally issued 30 June
Beaufort County
Dear Mr. Overton:
RECEIVED
DEHNR
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,,.NND QUALITY SECTION
RECEIVED
n DEHNR
�FP 19 1996
1992)
LAND QUALITY SECTI&
In a letter to Steve Tedder dated December 15, 1995 submitting the 401
application for Bailey Creek, PCS Phosphate proposed some changes in the
restoration plans for Whitehurst Creek and in the associated 401 certification for
Whitehurst Creek. At the time, PCS Phosphate requested that the Bailey Creek
401 application was the priority issue for the agency to work on. Once the
Bailey Creek 401 certification was issued, the focus was shifted to the
Whitehurst Creek request. Several drawings and figures were packaged with a
cover letter to John Dorney dated May 28, 1996, and a meeting was held at your
offices in Raleigh on May 28 to address the changes requested for the
Whitehurst Creek restoration.
The proposed modifications to the plans for the restoration of Whitehurst
Creek involved two main areas. These areas were the west prong through
reclaimed land and the east prong, which would be the existing Whitehurst
Creek mitigation channel. In the meeting, drawings were reviewed for the
redesign of the western prong. The project would be done in two stages, with
the final tie-in complete by June 7, 2003. This prong would then be
approximately 3200 feet long and contain approximately 7 acres of floodplain
wetland adjacent to the channel, which did not previously exist. You and your
staff seemed receptive to this part of the package, with the one exception being
a request to add more meanders to the western prong to match the design for
Bailey Creek. A draft letter dated June 17, 1996 setting forth new conditions for
the 401 certification was faxed to PCS Phosphate on June 20 from your agency,

I-Vi4ij U i
onvruA
I

Mr. Jimmie Overton
August 29, 1996
Page 2 of 3
however we requested a delay in issuing a final version until all of the issues
were resolved.
The other area of discussion involved leaving the existing Whitehurst
Creek mitigation channel in place permanently as the eastern prong. You
expressed some reservations regarding this plan because of the lack of wetlands
adjacent to the stream channel and the associated water quality benefits that
wetlands would provide before this water reaches lower Whitehurst Creek. This
was reiterated by you during a field visit to the site on June 17. This portion of
Whitehurst was previously highly channelized with no adjacent wetlands,
however you stated that this proposal would be enhanced if the water entering
the head of this eastern prong could go through a wetland area first, thereby
potentially improving the quality of it before it flowed through the channel.
The five large drawings enclosed with this letter depict modifications we
have made in the design of the project since the plan submittal and meeting on
May 28. The first two drawings are the design for Phase I and Phase 11 of the
western prong. These drawings are similar to the ones submitted on May 28,
except that more meanders have been added. Again, Phase I would be
complete by June 7, 1998, and Phase II (final tie-in) would be complete by June
7, 2003.
The next two drawings (plan view and cross -sections) depict a proposed
new Whitehurst Creek headwater area. This flat, unmined area of approximately
five (5) acres would be the receiving area for stormwater coming off of the future
blend reclamation area to the west. Stormwater would sheet flow through this
area, out through an open spillway, into an existing water diversion canal and
into the pond currently in place at the upper end of the Whitehurst Creek
mitigation channel. This headwater area would be seeded with legumes and
grasses (no fescue) and planted with a variety of bare root hardwood tree
seedlings before June 7, 1998. Until the final reclamation of the blend area to
the west, a culvert will be used to discharge stormwater from this 5-acre area
instead of the open spillway. The culvert will serve to restrict the water flow off
of this area which should keep the area as wet as possible.
The fifth and final drawing shows the overall plan for the ultimate
restoration of Whitehurst Creek. It can be seen how the blend reclamation

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VEGETATION IN THE FORM OF GRASS SHOULD BE ESTABLISHED IN SUCH A MANNER
THAT SMALL GRAINS WILL STABILIZE THE SOIL UNTIL NATIVE PLANTS BECOME
REESTABLISHED. PREFERABLE GRASS INCLUDES: ANNUAL RYE GRASS, RYE,
WHEAT, OATS, SORGHUM, or ANNUAL LESPEDEZA,
TREES SHOULD BE PLANTED AT A DENSITY OF 400 TREES PER ACRE WITH A GOAL
OF 320 TREES PER ACRE AFTER 5 YEARS, AT LEAST TWO ROWS OF TREES SHALL
BE PLANTED IN ALTERNATING PATTERNS (RATHER THAN DIRECTLY OPPOSITE EACH
OTHER) ON THE BANK TO PROVIDE CANOPY SHADING. TREES MORE TOLERANT OF
FLOODING CONDITIONS (SUCH AS BALD CYPRESS) SHOULD BE PLANTED AT THE
TOE OF THE SLOPE AND/OR WITHIN THE FLOOD PLAIN AREA.
20% BALLED and BURLAPPED
80% BARE ROOT SEEDLINGS
FLOOD PLAIN SPECIES LRANS I T I OU SLOPE SPECIES
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RICHLANDS TOWNSHIP BEAUFORT COUNTY NORTH CAROLINA
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DATE: _08-14_96-� ROBERT M. CHILES, P.E.
JOB NO, _96074_-_ ENGINEERS AND CONSULTANTS
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THAT SMALL GRAINS WILL STABILIZE THE SOIL UNTIL NATIVE PLANTS BECOME
REESTABLISHED. PREFERABLE GRASS INCLUDES: ANNUAL RYE GRASS, RYE,
WHEAT, OATS. SORGHUM, or ANNUAL LESPEDEZA.
TREES SHOULD BE PLANTED AT A DENSITY OF 400 TREES PER ACRE WITH A GOAL
OF 320 TREES PER ACRE AFTER 5 YEARS. AT LEAST TWO ROWS OF TREES SHALL
BE PLANTED IN ALTERNATING PATTERNS (RATHER THAN DIRECTLY OPPOSITE EACH
OTHER) ON THE BANK TO PROVIDE CANOPY SHADING. TREES MORE TOLERANT OF
FLOODING CONDITIONS (SUCH AS BALD CYPRESS) SHOULD BE PLANTED AT THE
TOE OF THE SLOPE AND/OR WITHIN THE FLOOD PLAIN AREA-
20% BALLED and BURLAPPED
80% BARE ROOT SEEDLINGS
FLOOD PLAIN SPECIES
CYPRESS
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KIC;HLANUS 1UWN5HIN BEAUFORT COUNTY NORTH CAROLINA i
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DATE: 08_14s6__ ROBERT M. CHILES, P.E. N
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WHITEHURST CREEK
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Phosphate AURORA DIVISION
TOWNSHIP BEAUFORT COUNTY NORTf
DATE: _ 08, 23-96
JOB NO, _ 96074�T_
SCALE: _� _= 50'
ROBERT M. CHILES, P.E.
ENGINEERS AND CONSULTANTS
NEW BERN, NORTH CAROLINA

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RICHLANDS TOWNSHIP BEAUFORT COUNTY NORTH CAROLINA
DATE: ROBERT M. CHILES, P.E-
JOB NO. 56074
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Mr. Jimmie Overton
August 29, 1996
Page 3 of 3
areas, the headwater wetland area and the east prong, portions of the mine
perimeter canal system, and the west prong, are all tied together to form a
Whitehurst Creek headwater system that should serve well in water quality and
aquatic life functions.
We respectfully request that the 401 Water Quality Certification for
Whitehurst Creek (No. 2748, DEM #92039) be modified to reflect the drawings
included in this package and the time schedules as reflected in this letter and
your agency's draft letter of June 17, 1996. We would be happy to meet with
you and any member of your staff to discuss this issue. If you have any
questions, please call me at [phone].
Sincerely,
Je rey C. Furness
Environmental Scientist
JCF/re
Enclosures
pc: Tracy Davis - DLR, Raleigh (wlencl)
W. A. Schimming (wlencl)
S. R. Phillips112-01-004-26 (wlencl)
H. M. Breza/D. J. Millman (wlencl)
P. J. Moffett (wlencl)
00-14-000 (w/o encl)

PCS
Phos ate-v AURORA DIVISION
P.O. BOX 48. AURORA. NC 27806
May 28, 1996
Mr. John Dorney
Water Quality Section
Division of Environmental Management
North Carolina Department of EHNR
4401 Reedy Creek Road
Raleigh, North Carolina 27607
Dear Mr. Dorney:
p
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On December 15, 1995, PCS Phosphate applied for a 401 Water Quality Certification for
impacts to the upper channelized drainage to Bailey Creek. In the cover letter for that
application, we also requested that certain conditions in the 401 Certification for Whitehurst
Creek (dated June 30, 1992) be deleted. These conditions involved the requirement for
reclamation of Whitehurst Creek within 4 years from the date of mining the fork of the two
drainage prongs and a $1,000 per day penalty if it was not reclaimed by then. We also
outlined a modified reclamation plan for the whole southern mining area encompassing the
Whitehurst and Bailey Creek drainages, and a map of this plan was provided. We agreed at
the time that the Bailey Creek 401 would be the issue of priority for DEM to focus on. Now
that the 401 Certification for Bailey Creek has been approved, the Whitehurst Creek issue
needs to be addressed.
At the time of the issuance of the initial 401 Certification for Whitehurst Creek (June 1992),
it was believed that the restoration of the upper channelized drainage to Whitehurst Creek
could be accomplished within the 4-year time frame stipulated in the permit. We believed that
we were close to completing the EIS process that had begun in 1988. However, the EIS
process is still not completed, which has caused PCS Phosphate to request three additional
modifications to our mining permit to continue mining in upland areas in the southern portion
of our property. As long as mining activities continue in this southern area, the mine utility
corridor (2 canals, pipelines and road) needs to remain in place near the old S. R. 1941 bridge,
which precludes tieing -in a reclaimed channel to the main Whitehurst Creek channel. We
project that this corridor will need to remain much longer than anticipated when the Whitehurst
Creek 401 Certification was agreed to (Figure 1).
In the December 15, 1995 letter, a proposal was put forth to create one channel for Whitehurst
Creek through reclaimed land and to also let the current Whitehurst Creek mitigation channel
remain in place permanently. This makes the most ecological sense based on the direction that
stormwater would flow off the reclaimed land, and would result in approximately 8,200 feet
of restored channel compared to a currently required 5,000 feet. We believe that there is no
reason to not use the mitigation channel that is already in place and is functioning better than
the original channel for part of the permanent reclamation of this area..

i
Mr. John Dorney
May 28, 1996
Page 2 of 2
We still are proposing that scenario, however we propose to modify the design of the channel
constructed through reclaimed land to be similar to the design recently approved for the
relocation of Bailey Creek. That is, there will be an approximately 50-foot wide floodplain
slightly elevated along each side of a 10-foot wide channel. This will result in approximately
7 acres of bottomland hardwood wetland, which did not originally exist. Enclosed are large
drawings which show the design of the reclaimed channel and the overall reclamation plans
for the area. The construction of the channel through reclaimed land would be accomplished
in two phases. The first phase of constructing the main portion of the channel would be done
by April 1998. The second phase would be tieing -in the new channel to the original channel,
which would be done by April 2003. This timing is outlined in Figure 2. Notice that the total
delay in the restoration of Whitehurst Creek is 5 years, which equals the amount of time that
we will have mined in this area over what we originally believed we would. For this reason,
we request that the condition in the original 401 Certification that the restoration of upper
channelized drainage to Whitehurst Creek be completed within the 4-year time frame (by June
1998) be modified to reflect the 5-year delay and specify restoration by June 2003, In
addition, we request that the $1,000 per day penalty condition be dropped since the existing
Whitehurst Creek mitigation channel equals the total length of the original channelized drainage
and is functioning better than the original channel.
A table highlighting the benefits of the new plans for Whitehurst Creek is also enclosed. If
you have any questions on this request, please call me at 919/322-8249.
Sincerely,
, k' C ".
Je frey C. Furness
JCF/re
Enclosures
PC: lTracy Davis - DLR, Raleigh (w/encl)
W. A. Schimming (w/encl)
W. T. Cooper (w/o encl)
S. R. Phillips/12-01-004-26 (w/encl)
H. M. Breza/D. J. Millman (w/encl)
P. J. Moffett (w/encl)
00-14-000 (w/o encl)
ll:AWC401chg.

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
Mr. Thomas J. Regan, Jr.
PCS Phosphate Company, Inc.
P.O. Box 48
Aurora, NC 27806
Dear Mr. Regan:
E H N FRCEIVED
August 6, 1997
" G 11 1997
Re: Modification of Water Quality Certification N
Proposed PCS mine expansion
DWQ Project #961120, COE #198800449
Beaufort County
AUG 6 '97
Dl V LAND RE&
DWQ issued Certification No. 3092 on 6 May 1997 to the PCS Company to allow
the fill of 1,268 acres of wetlands for a mine expansion in Beaufort County. Condition
Number Two of that Certification is hereby rescinders since it may result in permit
processing difficulties for the U.S. Army Corps of Engineers. All other conditions are still
applicable.
Please call Mr. John Dorney of my staff at 919-733-1786 if you have any questions.
Sincerely,
Pstorni Howard,?Jr.E.
cc: Wilmington District Corps of Engineers
Corps of Engineers Washington Field Office
Washington DWQ Regional Office
Mr. John Dorney
Mr. John Parker; DCM
Central Files
Kristin Rowles, Tar -Pamlico River Foundation
Derb Carter, Southern Environmental Law Center
Melba McGee, EHNR
Frank McBride, WRC
Charles Gardner, DLR
Bruce Bolick, CZR
Roger Schecter, DCM
Katy West, DMF
ruKo r-qc�
0
Division of Water Quality - Environmental Sciences Branch
Environmental Sciences Branch, 4401 Reedy Creek Rd., Raleigh, NC 27607 Telephone [phone]
An Equal Opportunity Affirmative Action Employer • 50% recycled/100% post consumer paper
i i114h ,�
-�i4p III
FAX # [phone]

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Wafer Quality
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A, Preston Howard, Jr„ P.E., Director
Mr. Thomas J. Regan, Jr.
PCS Phosphate Company, Inc.
P.O. Box 48
Aurora, NC 27806
Dear Mr. Regan,
�EHNF1
RECEIVED
May 6, 1997
_ MAY s `97
ErgMir+
MAY Q 9 1997
i
Re: Certification Pursuant to Section 401 of the Federal Clean Water Act,
Proposed expansion of PCS Phosphate mine
WQC Project #961120, COE #198800449
Beaufort County
Wit) RE&
Attached hereto is a copy of Certification No. 3092 issued to PCS Phosphate Company dated
6 May 1997.
If we can be of further assistance, do not hesitate to contact us.
Sincerely,
1
A. Preston Howard, Jr. P�E.
Attachments
961120.wgc
cc: Wilmington District Corps of Engineers
Corps of Engineers Washington Field Office
Washington DWQ Regional Office
Mr. John Dorney
Mr. John Parker, Division of Coastal Management
Central Files
Kristin Rowles, Tar -Pamlico River Foundation
Derb Carter, Southern Environmental Law Center
Melba McGee, EHNR
Frank McBride, WRC
Charles Gardner, DLR
Bruce Bolick, CZR
Roger Schecter, DCM
Katy West, DMF
Division of Water Quality • Environmental Sciences Branch
Enviro. Sciences Branch. 4401 Reedv Creek Rd., Raleiah. NC 27607 Teleohone 919-733-1786 FAX # [phone]

i a.
NORTH CAROLINA 401 WATER QUALITY CERTIFICATION
THIS CERTIFICATION is issued in conformity with the requirements of Section 401
Public Laws 92-500 and 95-217 of the United States and subject to the North Carolina Division of
Water Quality (DWQ) Regulations in 15 NCAC 2H, Section .0500 to PCS Phosphate Company
resulting in 1,268 acres of wetland impact in Beaufort County pursuant to a revised application
filed on the 5th day of December of 1996 to expand an existing open pit phosphate mine following
the alignment of Alternative E as outlined in the Environmental Impact Statement except as
modified below.
The application provides adequate assurance that the discharge of fill material into the waters
of South Creels and its tributaries in conjunction with the proposed development will not result in
a violation of applicable Water Quality Standards and discharge guidelines. Therefore, the State
of North Carolina certifies that this activity will not violate the applicable portions of Sections 301,
302, 303, 306, 307 of PL 92-500 and PL 95-217 if conducted in accordance with the application
and conditions hereinafter set forth.
This approval is only valid for the purpose and design that you submitted in your application,
as described in the Public Notice or as modified below. If you change your project, you must
notify us and you may be required to submit a revised application. If additional wetland fills for
this project (now or in the future) are proposed, additional compensatory mitigation will be
required as described in 15A NCAC 2H .0506 (h) (6) and (7). For this approval to be valid, you
must follow the conditions listed below. In addition, you should get any other federal, state or
local permits before you go ahead with your project including (but not limited to) Sediment and
Erosion control, Coastal Stormwater, Non -discharge and Water Supply watershed regulations.
Condition(s) of Certification:
1. That appropriate sediment and erosion control practices which equal or exceed those
outlined in the most recent version of the "North Carolina Sediment and Erosion Control
Planning and Design Manual" or the "North Carolina Surface Mining Manual" (available
from the Division of Land Resources in the DEHNR Regional or Central Offices) are
utilized to prevent exceedances of the appropriate turbidity water quality standard (50
NTUs in all freshwater streams and rivers and 25 NTUs in all saltwater classes);
2. Since an environmental impact statement is required, this Certification is not valid until a
Record of Decision is issued by the US Army Corps of Engineers;
3. Measures shall be taken to prevent live or fresh concrete from coming into contact with
waters of the state until the concrete has hardened;
4. This certification shall expire on 5 May 2007 unless PCS demonstrates to the
satisfaction of the Director of the Division of Water Quality that no mining methodology
is available and economically feasible which would reduce impacts to wetlands and
waters. Should this demonstration be accepted by the Director of DWQ, then this
Certification shall expire on 5 May 2017.
5. Mitigation is required as described in the 5 December 1996 Public Notice from the U.S.
Army corps of Engineers. DWQ shall be sent two copies of all annual monitoring reports
for the wetland mitigation effort. If mitigation is not successful, additional mitigation will
be required.
6. A water management and stream monitoring plan for water quality, water quantity, and
biology (macrobenthos and fish) shall be developed by PCS Phosphate and submitted to
DWQ for written approval. This plan shall include monitoring for Huddles Cut

(which is a tributary of the Pamlico River) and Jacks Creek and Tooleys Creek (which are
tributaries of South Creek) or other streams with Primary Nursery Area functions. This
plan shall be designed to assure the protection of downstream water quality standards,
including downstream Primary Nursery Area functions, in all tribuitaries to South Creek
and Pamlico River adjacent to the mining site. This plan shall identify any deleterious
effect on riparian wetland function including but not limited to water storage, pollutant
removal, streambank stabilization, as well as resident wetland -dependent aquatic life and
resident wetland -dependent wildlife habitat and aquatic life in streams tributary to the
Pamlico River and South Creek on the Durham -South Creek peninsula. This plan shall
also provide mechanisms for written approval from DWQ to remedy these effects if any
are identified. If necessary, management activities to protect these uses will be required
for all of the tributaries to South Creek and Pamlico River. This plan shall be submitted
to DWQ within six months of the date of issuance of the 404 Permit. Seven copies of the
draft plan shall be submitted to DWQ for circulation and review by the public and other
agencies.
7. This Certification is for wetland impacts in Alternative E as described in the final
Environmental Impact Statement. It does not provide Certification for additional wetland
impacts along South Creek, it's tributaries and wetlands in those watersheds. Additional
wetland impact may not be allowed elsewhere on the peninsula unless agreed upon in
writing by the N.C. Division of Water Quality in the future. Compensatory mitigation
will be required for any additional wetland fill.
Violations of any condition herein set forth shall result in revocation of this Certification and
may result in criminal and/or civil penalties. This Certification shall become null and void unless
the above conditions are made conditions of the Federal 404 Permit.
If this Certification is unacceptable, you have the right to an adjudicatory hearing upon
written request within sixty (60) days following receipt of this Certification. This request must be
in the form of a written petition conforming to Chapter 150B of the North Carolina General
Statutes and filed with the Office of Administrative Hearings, P.O. Box 27447, Raleigh, N.C.
27611-7447. If modifications are made to an original Certification, you have the right to an
adjudicatory hearing on the modifications upon written request within sixty (60) days following
receipt of the Certification. Unless such demands are made, this Certification shall be final and
binding.
This the 6th day of May, 1997
DIVISION OF WA QUALITY
A. Preston Howard, Jr P.E.
WQC #3092

0.

REC x, q1
MAR 1 1 '08
tW t-AU40 RE&
February 26, 1998
PCs
Phosphatev AURORA ❑
P.O. BOX 48, AURORA, NC 27806
Mr. John Dorney
Division of Water Quality
North Carolina Department of Environment and Natural Resources
4401 Reedy Creek Road
Raleigh, North Carolina 27607
'/
MAR 0 31998
He: Certification Pursuant to Section 401 of the Federal Clean Water Act, Proposed expansion of
PCS Phosphate mine WQC Project #961120, COE #198800449, Certification No. 3092,
Beaufort County
Dear Mr. Dorney:
The subject 401 Water Quality Certification issued to PCS Phosphate on May 6, 1997 requires
that a water management and stream monitoring plan for water quality, water quantity, and biology
(macrobenthos and fish) be developed by PCS Phosphate and submitted to DWQ for written approval
within six months of the date of issuance of the Corps of Engineers 404 Permit. Enclosed are seven
copies of the plan, entitled "NCPC Tract Stream Monitoring Program for PCS Phosphate Company, Inc.,"
for your use and review. We are also sending three copies to the Corps of Engineers' Wilmington office,
at the request of David Franklin.
We are willing to meet with you and other DWQ staff to discuss this plan at your earliest
convenience. The sooner that an agreement can be reached on the plan, the sooner we can initiate the
monitoring program. in the meantime, if you have any questions, please call me (919/322-8242) or Jeff
Furness (919/322-8249).
Sincerely,
"'� R. P1+0
S,R. Phillips
Manager, Environmental Affairs
Enclosures
PC: David Franklin - Corps, Wilmington (3 copies)
Charles Gardner - Di_R
T.J. Regan
W.A. Schimming
T.C. Younger
W.T. Cooper
M.T. Harris
P.J. Moffett
J.C. Furness
G.W. House
J.M. Hudgens
B.W. Bolick
Wayne Skaggs - N.C. State University
1 2-01-004-27
00-20-000
3

NCPC TRACT STREAM MONITORING PROGRAM FOR
PCS PHOSPHATE COMPANY, INC.
MAR 03199g
Prepared by:
CZR Incorporated, Wilmington, North Carolina
Dr. Wayne Skaggs, P.E.
Prepared for:
PCS Phosphate Company, Inc.
Aurora, North Carolina
Prepared for review by:
U.S. Army Corps of Engineers
North Carolina Division of Water Quality
North Carolina Division of Land Resources
�I�0
26 February 1998 Z R
INCORPORATED
ENVIRONMENTAL CONSULTANTS

TABLE OF CONVENTS
Rag-e
COVERSHEET ................ ..................................... i
TABLE OF CONTENTS ................................ ............ .... ii
LIST OF FIGURES ..................................................
INTRODUCTION . . ............................... . .............. . 1
REVIEW OF ON -SITE DATA AND APPLICABLE LITERATURE ............ 4
OBJECTIVES AND INFORMATION NEEDS ........................... 6
PROPOSED METHODOLOGY AND TIMING ........................... 8
I. SELECTION AND COORDINATION OF SPECIFIC SAMPLES SITES; DESCRIPTION
OF EXISTING CONDITIONS; ESTABLISHMENT OF MONITORING PROCEDURES,
AND PURCHASE, INSTALLATION, AND CALIBRATION OF EQUIPMENT .......... , . 8
A. In-depth Reconnaissance of Jacks Creek, Tooley Creek, and Huddles Cut Drainage
Areas and Selection of Specific Monitoring Sites .................. . ....
8
B. Description of Existing Conditions ........................... . .....
8
C. Establishment of Monitoring Procedures, and Purchase, Installation, and
Calibration of Equipment ..................... . ..................
8
1. Installation of Shallow Monitoring Wells and Continuous Water
Level Recording Devices ........ . ..........................
9
2. Installation and Calibration of Flow Monitoring Stations .......... ...
9
3. Establishment of Vegetation Monitoring Plots ....................
9
4. Installation of Rain Gauges ........ . ........................
14
5. Installation of Continuous Monitors at Salinity Monitoring Sites ........
14
6. Establishment of Water Quality Monitoring Sites ..................
14
7. Establishment and Marking of Fish and Benthos Monitoring Sites ......
16
D. Graphics Preparation ...........................................
16
E. Reporting..................................................16
II. MONITORING PROTOCOL............................................16
A. Groundwater Monitoring . ....................................... 17
B. Flow Monitoring and Modeling .................................... 17
C. Water Quality Monitoring ....................................... 17
D. Salinity Monitoring ............................................ 18
E. Vegetation Monitoring .......................................... 18
F. Fish and Benthos Monitoring ..................................... 18
G. Photo Documentation of Monitoring Sites and Conditions ................. 19
H. Soil Property Measurements ..................................... 19
I. Preparation of Annual Report ........................... . ...... . .. 19
Ili. FOLLOW-UP MONITORING . . . ......................... I ............... 20
REFERENCES

LIST OF FIGURES
Figaar_e
m
1 Alternative ..................................................... 2
2 WL-80 and Shallow Monitoring Well Locations, Flow Monitoring Stations, and Water
Quality Monitoring Stations in the Jacks Creek Drainage .. .. . . ..... .. . ... . ....
10
3 WL-80 and Shallow Monitoring Well Locations, Flow Monitoring Stations, and Water
Quality Monitoring Stations in the Tooley Creek Drainage .....................
11
4 WL-80 and Shallow Monitoring Well Locations, Flow Monitoring Stations, and Water
Quality Monitoring Stations in the Main Prong of Huddles Cut ..................
12
5 WL-80 and Shallow Monitoring Well Locations, Flow Monitoring Stations, and Water
Quality Monitoring Stations in the Western Wrong of Huddles Cut ...............
13
6 Salinity Monitoring Sites ............................................
15

NCPC TRACT STREAM MONITORING PROGRAM FOR
PCS PHOSPHATE COMPANY, INC.
I101i:181019I01to] I,
CZR Incorporated (CZR), assisted by Dr. Wayne Skaggs and his group (Skaggs), have been
requested by PCS Phosphate Company, Inc. (PCS Phosphate) to prepare a stream monitoring plan to
respond to Section 404 permit conditions and to 401 Water Quality Certification conditions related to
Alternative E {Figure 1). Condition #6 of the 401 Water Quality Certification No. 3092 issued 6 May
1997 by the N.C. Division of Water Quality (DWQ) reads as follows:
6. A water management and stream monitoring plan for water quality, water quantity,
and biology Imacrobenthos and fish) shall be developed by PCS Phosphate and
submitted to DWQ for written approval. This plan shall include monitoring for Huddles
Cut (which is a tributary of the Pamlico River) and Jacks Creek and Tooleys Creek
(which are tributaries of South Creek) or other streams with Primary Nursery Area
functions. This plan shall be designed to assure the protection of downstream water
quality standards, including downstream Primary Nursery Area functions, in all
tributaries to South Creek and Pamlico River adjacent to the mining site. This plan shall
identify any deleterious effect on riparian wetland function including but not limited to
water storage, pollutant removal, streambank stabilization, as well as resident wetland -
dependent aquatic life and resident wetland -dependent wildlife habitat and aquatic life
in streams tributary to the Pamlico River and South Creek on the Durham -South Creek
peninsula. This plan shall also provide mechanisms for written approval from DWQ to
remedy these effects if any are identified. If necessary, management activities to
protect these uses will be required for all of the tributaries to South Creek and Pamlico
River. This plan shall be submitted to DWQ within six months of the date of issuance
of the 404 Permit. Seven copies of the draft plan shall be submitted to DWQ for
circulation and review by the public and other agencies.
In addition, Conditions #3 and 5 of the 404 Permit No. 198800449 state the following:
3. The Permittee must perform appropriate studies developed in coordination with the
USACE and the State to assess whether there are water quality impacts or hydrologic
impacts on the tributaries of South Creek and the Pamlico River due to the removal of
drainage area from these tributaries. The NCDWQ condition addressing this issue
should satisfy this requirement. If adverse effects are identified within the tributaries
identified in the NCDWQ condition, the USACE may require that additional tributaries
of the Pamlico River and South Creek be included in the scope of the study. If
unacceptable impacts are identified, appropriate remedial action must be developed and
implemented by PCS to rectify the impact. This may include the addition of
supplemental flows to the tributaries by pumping water from the aquifer decompression
canal into the drainage of these systems.
5. The Permittee must comply with all 401 Water Quality Certification conditions
specified above and in Water Quality Certification #3092.
CZR has worked extensively on the NCPC Tract since 1988, conducting a wide range of
environmental studies including wetland delineations, plant community mapping and descriptions,
wildlife studies, water quality sampling, aquatic sampling, and other related activities. PCS Phosphate
requested CZR to use this on -site experience to evaluate and respond to the DWQ and USACE
conditions and to enlist Skaggs to assist in modeling and monitoring the water quantity for these stream
systems.

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ALTERNATIVE E
PCS PHOSPHATE COMPANY, INC.
SCALE: AS SHOWN APPROVED BY: DRAWN BY: BFG
DATE: 1 /28/98 FILE: 1745ALTE
CP# 1745.1 6
4709 COLLEGE ACRES DRIVE
SUM 2
$IRapR►p RwT Ep wILUIFtGTON, mC9 00/ 2S FIGURE 1
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The DWQ selected three stream drainages (Jacks Creek, Tooley Creek, and Huddles Cut) to be
monitored (Figure 1). Huddles Cut is a tributary to the Pamlico River and has a drainage area of 872
acres. Jacks Creek, with a drainage area of 528 acres, and Tooley Creek, with a drainage area of 498
acres, are tributaries to South Creek. As shown in Table 5-3 of the Final Environmental Impact
Statement for the Texasgulf Inc. Mine Continuation (USACE 1996), the temporary drainage area
reductions to these three streams due to mining under Alternative E would be as follows:
Jacks Creek 197 acres, or 37.3 percent, of the present 528 acres
Tooley Creek 67 acres, or 13.5 percent, of the present 498 acres
Huddles Cut 221 acres, or 25.3 percent, of the present 872 acres
From 1) on -site experience in the NCPC Tract over recent years, 2) literature dealing with the
NCPC creeks and similar systems, and 3) meetings between PCS Phosphate personnel, CZR
Incorporated biologists, and Skaggs, the study team determined that the monitoring will be directed
primarily at the stream sections and forested riparian wetlands just above (upstream of) the CAMA
markers on each stream. These are the areas where freshwater flow from the drainages 1) can be most
readily measured and 2) is likely to have the greatest impact on plant and animal life. The time frame
for the monitoring was set to begin in 1998, with early 1998 being used to finalize plans and purchase,
install, and calibrate equipment.
The DWQ designated that the water management and stream monitoring plan be for 1) water
quality, 2) water quantity, and 3) biology (fish and benthos). CZR has proposed the tasks outlined
below to accomplish the required monitoring. Monitoring of flow, groundwater, rainfall, and salinity in
all three creeks will begin in 1998. Water quality monitoring, vegetation sampling, and fish and benthos
sampling will begin in 1998 on Jacks Creek, but will not begin on Tooley Creek or Huddles Cut until
closer to the time that land clearing activities are expected to reach those drainage basins. The pre -
mining monitoring results from each creek will be compared with results from future similar sampling
during the period that drainage basins are reduced due to mining to determine any deleterious effects
to riparian wetland functions.
3

REVIEW OF ON -SITE DATA AND APPLICABLE LITERATURE
Much information has been collected on the fisheries, salinity, and water quality of the creeks
in the PCS Phosphate vicinity. CZR collected extensive benthic, fisheries, and water quality data during
the 1988-89 EIS sampling work (CZR Incorporated 1990). The North Carolina Division of Marine
Fisheries (NCDMF) has collected extensive fisheries data and associated salinity data periodically since
the late 1970s. During the 1980s, East Carolina University scientists researched the fisheries and
salinity of the creeks near the Charles Tract clay ponds; on the NCPC Project Area II (a man-made creek
with essentially no drainage basin); and on Jacks, Jacobs, and Drinkwater Creeks (Lawson 1981,
Lawson 1982, West 1988, West 1990, Rulifson 1990). Additionally, North Carolina State University
researchers have conducted intensive studies of the salinity dynamics and fisheries of similar creeks
near the mouth of the Pamlico River and on the western shore of Pamlico Sound (Pietrafesa 1985,
Moser 1987, Overton and Fisher 1988, Pietrafesa et al. 1988, Moser and Gerry 1989). Some limited
data have also been collected on salinity -induced changes in the bottomland hardwood wetlands in the
headwaters of these creeks (Brinson et al. 1985).
Salinity in the creeks near PCS Phosphate varies greatly, both on an annual and a short-term
basis. Salinity can range from fresh (0 ppt) to mesohaline (up to 17 ppt) (CZR Incorporated 1990).
Annual variability in salinity tends to follow the same pattern throughout the South Creek -Pamlico River
estuarine system. Control over this pattern has been attributed to freshwater input from the Tar River
(Stanley 1988, Nixon 1989). Available evidence suggests that short-term variation in salinity is
controlled largely by system -wide tidal fluctuations, which are controlled by changes in wind speed and
direction (CZR Incorporated 1994). For most of the small creeks near PCS Phosphate, the gradient in
surface salinity from the upper end of the estuarine portion of the creek to the mouth averages less than
2 ppt. This suggests that the influence of local freshwater input is minimal. However, local freshwater
input does seem to affect salinity near the upper end of tidal influence, especially for the creeks with
large drainage basins, such as Bailey, Whitehurst, and Porter Creeks. Unfortunately, the continuous
salinity, water level, and runoff data necessary to conclusively evaluate short-term salinity fluctuations
in these creeks do not exist. However, studies of continuous data on similar creeks near the mouth of
the Pamlico River and on the western shore of Pamlico Sound concluded that short-term salinity
fluctuations were caused primarily by wind tides, with local freshwater input being important only at
the uppermost ends of the creeks (Pietrafesa 1985, Pietrafesa et al. 1988, Overton and Fisher 1988).
Thus the available evidence suggests that any changes in salinity due to drainage basin reductions
would be minor and would be limited to the upper ends of the creeks.
Extensive trawl data collected over the years by various researchers show that these creeks are
nursery areas for juvenile finfish and crustaceans. The catch tends to be dominated by a few common
species, but numbers and species composition vary greatly from month to month, from year to year,
and from creek to creek (Lawson 1981, Lawson 1982, West 1988, CZR Incorporated 1990, Rulifson
1990, NCDMF unpublished data). Trawl samples are usually dominated by spot (Leiostomus xanthurus)
and/or bay anchovy (Anchoa mitchillr). Atlantic croaker (Micropogonias undulatus) is common in some
years, but nearly absent in others. Southern flounder (Paralichthys lethostigma), common blue crab
(Callmectes sapidus), and brown shrimp (Penaeus aztecus) are occasionally encountered in low numbers.
Trawl -to -trawl variability in numbers and species composition is so high that it is generally not possible
to make statistically meaningful comparisons based on standard monthly trawl samples. Evidence
suggests that the high variability in the catch is driven by recruitment pulses of the dominant fish (CZR
Incorporated 1990) and by erratic, system -wide hydrographic fluctuations that drive juvenile fish into
and out of the small nursery creeks (Miller et al. 1988).
Several laboratory and field studies have investigated the effects of short-term salinity
fluctuations on the metabolism and distribution of common estuarine fish such as spot, Atlantic croaker,
and Atlantic menhaden tBrevoortia tyrannus) (Hettler 1976, Engel et al. 1987, Moser 1987, Moser and
Gerry 1989, Moser and Miller 1994), The studies found that these common fish are highly tolerant of
4

rapid, large magnitude salinity changes. The fish in these studies were exposed to salinity changes that
were much larger and much more rapid than any that occur naturally in the area's tidal creeks. The
general conclusion reached in these studies is that the fish commonly encountered in the Pamlico
River/Pamlico Sound estuarine system can easily tolerate and adapt to short-term salinity fluctuations.
Based on the results of these studies, it seems unlikely that any salinity fluctuations caused by drainage
Basin reductions would have an appreciable effect on the nursery functions of the creeks. Studies on
NCPC Project Area 11 by Rulif son (1990) and West 11990) support this conclusion. NCPC Project Area
II, which has essentially no drainage basin, was found to function as a nursery area for common finfish.
Brinson et al. (1985) studied the hydrology and vegetation of the bottomland hardwood forests
at the upper ends of Jacks and Jacobs Creeks. During a period of record high salinities in the Pamlico
River system, they found that high salinity groundwater intruded into the forests. There was evidence
that the intrusions stressed the trees in these forests. The hydrology aspect of the Brinson et al. (1985)
study investigated flood levels and hydroperiods and it documented wind tide influence on the hydrology
of Jacks Creek up to the S.R. 1942 crossing. However, the study did not fully evaluate the relative
effects of wind tide flooding and drainage basin input on the hydrology of these wetlands.

OBJECTIVES AND INFORMATION NEEDS
The existing data on the PCS Phosphate creeks and similar creeks in the region provide valuable
information on the potential effects of drainage basin reduction. However, the studies to date were not
specifically aimed at answering the drainage basin reduction question. Therefore, for Jacks Creek,
Tooley Creek, and Huddles Cut, several data gaps need to be filled to allow this question to be
answered.
EIQ-w ajonitQ[in_g. Drainage or outflow from each watershed should be measured to determine
hydrology conditions of the watershed. Water table depths should also be measured in the drainage
basin to relate water table fluctuations to surface outflow. Because both drainage and water table
depths are dependent on rainfall, precipitation should be recorded on each site. Flow data and on -site
rainfall data should also be collected during the years of drainage basin reduction to both provide a
direct assessment of the effects and to provide verification of the prediction of the effects. Flow data
and modeling of drainage basin inputs (covered below) are essential pieces of information for evaluating
the effects of drainage basin reduction on salinity of the creeks and hydrology of the bottomland
hardwood wetlands.
Flow modelina. A simulation model will be used to describe the hydrology of each of the
watersheds. The model will be based on DRAINMOD (Skaggs 1978, 1991), with modifications to route
surface runoff to ditches and natural channels, and to route both surface and subsurface flows through
the drainage network. Except for a few site specific modifications, the model exists and has been
described by Konyha and Skaggs (1992) and Amatya et al. (1997). The model uses input data to
describe soil properties, site parameters (e.g., drain depths and locations, surface roughness, etc.),
vegetation, and channel characteristics, together with measured rainfall and other meteorological data
to predict subsurface drainage and surface runoff rates. Once the model has been tested and calibrated
using measured hydrologic data for each monitoring site, it can be used to conduct long term
simulations to quantify, in a statistically reliable fashion, the existing hydrology of the sites. Then the
model can be used to predict the probable effects of drainage basin reduction on outflow from the basin
or watershed. This could be done for any stage as the mining progresses. If necessary to mitigate
water quantity or water quality impacts, the model could be used, during and after mining, in a real time
application to determine the quantity and timing of pumped additions of water to represent existing
conditions.
Salinity artdSn[Sev�Qt7iSQring. To evaluate the effects of drainage basin input on salinity,
water level and salinity data must be collected from the estuarine portions of the creeks. Because
available evidence suggests that drainage basin effects on salinity are limited to the upper ends of the
creeks, salinity monitoring should be concentrated there. However, salinity should be monitored at a
station near the mouth of each creek to confirm that no local drainage basin effects are present near
the mouth. Salinity data should be interpreted in light of the rainfall, flow, and water level data to allow
evaluation of the effects of drainage basin input and wind tides on salinity. Salinity and water level
should also be monitored at control stations in South Creek and the Pamlico River so that system -wide
wind tide effects on salinity can be identified. Once the effects of local drainage basin input on salinity
have been fully evaluated, predictions of the likely effects of drainage basin reduction can be made.
Salinity and water level monitoring should continue during the years of drainage basin reduction to allow
confirmation of the predictions.
Water. quality monitoriag. Water quality data should be collected on the waters originating in the
drainage basins of the three creeks. These data can be compared to data collected during the mining
years to determine whether mining activities have any adverse impact on the quality of the drainage
basin runoff.
Fish and benthos monitorkg, Data on the abundance and species composition of fish and
benthos in the creeks should be collected. These data can be compared to data collected during the
A

years of drainage basin reduction to identify changes in the fish and benthic communities. However,
caution must be exercised to avoid attributing natural variation in fish and benthic communities to
drainage basin reduction. Fish and benthos monitoring should be restricted to the upper ends of the
estuarine portions of the creeks for the following reasons:
1) Variability in trawl data collected nearer to the mouths of these creeks is so high that it would
be very difficult to make statistically meaningful comparisons between pre -reduction and post -reduction
data.
2) Trawl data are strongly affected by erratic, natural fluctuations in juvenile fish abundance.
Therefore, if a significant difference in abundance was detected, it would be very difficult to determine
whether drainage basin reduction contributed to the difference.
3] Any effects due to drainage basin reduction would be most pronounced at the upper ends
of the creeks, thus sampling at the upper ends of the creeks would be more likely to detect any effects
that occur.
�C�CeSland veaetaii9nsrl�1it41i�g. Abundance, health, and species composition of the vegetation
should be monitored in the bottomland hardwood forests at the heads of these creeks. Data should be
collected before drainage basin reduction and compared to data collected after drainage basin reduction
to identify any vegetation changes due to changes in salinity or wetland hydrology. However, care must
be taken not to confuse natural vegetation changes with vegetation changes due to drainage basin
reduction.
WetlandJ].ydrolooy monitoring. Monitoring of the hydrology of the bottomland hardwood
wetlands should be conducted to determine the relative influences of wind tides and drainage basin
input. Water level data collected for the salinity monitoring and flow data collected for the flow
modeling can be used to assist in the wetland hydrology analysis. The hydrology data can then be used
to make qualitative predictions of the potential effects of drainage basin reduction on the hydrology of
the bottomland hardwood wetlands. Hydrology data should also be collected during the years of
drainage basin reduction to confirm the predictions.
7

PROPOSED METHODOLOGY AND TIMING
The following section outlines and describes the proposed tasks. Monitoring on each creek will
begin before any impacts to the drainage basins occur. This initial monitoring will allow characterization
of pre -mining conditions and will provide a basis for comparison with data collected after the drainage
basins have been reduced. The selection and coordination of specific sample sites, description of
existing conditions, and establishment of monitoring procedures will be done in early 1998. The flow,
groundwater, rainfall, and salinity monitoring equipment will be purchased, installed, and calibrated on
all three creeks in early 1998. Full-scale monitoring, including vegetation, water quality, and fish and
benthos monitoring on Jacks Creek will begin as soon as possible in 1998. For Tooley Creek and
Huddles Cut, flow, groundwater, rainfall, and salinity monitoring will begin as soon as possible in 1998,
but monitoring of vegetation, water quality, and fish and benthos will not begin until closer to the time
that land clearing activities are expected to reach those drainage basins.
The monitoring steps established and carried out in the initial monitoring on each creek will be
repeated at the same locations in future years when the mine reaches portions of the Jacks Creek,
Tooley Creek, and Huddles Cut drainage basins. The purpose of future sampling in these drainages will
be to determine if any deleterious effects to riparian wetland functions have occurred due to mine
expansion into portions of the drainage basins. CZR will document the sampling in an end -of -year report
each sampling year.
I. SELECTION AND COORDINATION OF SPECIFIC SAMPLE SITES; DESCRIPTION OF EXISTING
CONDITIONS; ESTABLISHMENT OF MONITORING PROCEDURES, AND PURCHASE, INSTALLATION,
AND CALIBRATION OF EQUIPMENT
• ! - • a - • • . rmaw M__ WMAN1111111915prolr - . • • • - •
Initial reconnaissance of the drainage areas has been done by CZR, Skaggs, and PCS Phosphate
personnel; and tentative monitoring sites have been selected. A more in-depth reconnaissance, along
with the use of the most recent aerial photo coverage and topographic information, will be used to
complete specific on -the -ground selection of the monitoring sites for flow measurements, water quality
sampling, salinity monitoring, wetlands monitoring, and sampling of fish and benthos. Final selection
of sites will be coordinated with PCS Phosphate, the DWQ, and the USACE.
r •E . a• •o• .�
CZR will describe existing conditions within the three stream drainages. The existing drainages
and established monitoring sites will be identified on maps and/or aerial photographs. Descriptions of
the vegetation, soils, topography, natural and constructed drainage channels, and other features will
be included with photo documentation of the sites. Some fixed-point photo stations will be established
to document potential future vegetation changes or other potential impacts in the riparian wetlands and
stream monitoring zones.
When the sampling sites and procedures have been approved by PCS Phosphate, DWQ, and the
USACE, CZR and Skaggs will obtain, install, and calibrate the required equipment. This is to be begun
as soon as possible in early 1998.
0

1. In;; t a l I a tion-of_Sha l l o w__M-Qr i_toring-N-eI l s-ansi_ C o n ib u o u ,-,,-10Later Levei_fie cording
Devices
Groundwater and wetland hydrology will be monitored with a combination of shallow
monitoring wells and continuous water level recording devices. A total of 39 monitoring wells will be
installed in the bottomland hardwood wetlands in the three creek drainages. The continuous monitoring
devices will be WL-80 well monitors from Remote Data Systems, Inc. The units, which will record
water levels over an 80-inch range, will be installed with 60 inches in the ground to record groundwater
and 20 inches above ground to record intermittent surface waters. The continuous recorders will be
supplemented with shallow monitoring wells constructed of 1 .25-inch PVC well screen. Sixty inches
of well screen will be installed underground, and a 12-inch piece of PVC pipe will extend above -ground
and be capped, numbered, and marked for location and identification. The WL-80s will be bear -proofed
with a system of larger PVC pipe and barbed wire. This system has proven effective in nearby well
monitoring on PCS Phosphate wetland mitigation lands,
The approximate locations of WL-80 and shallow monitoring wells in riparian wetlands
relative to flow monitoring stations are shown in Figures 2 through 5. Five WL-80s supplemented with
five shallow monitoring wells will be installed in the Jacks Creek drainage (Figure 2l. Three WL-80s and
three wells will be installed in Tooley Creek (Figure 3). In Huddles Cut, seven WL-80s and five wells
will be located on the main prong (Figure 4), and five WL-80s and six wells will be installed on the
western prong (Figure 5). During the installation of each WL-80 or well, the soil horizon depths and
colors will be recorded on wetland data forms. In addition to the wells shown for the riparian wetlands
on Figures 2 through 5, approximately an additional 15 WL-80s and 20 monitoring wells will be located
in areas of higher elevations upstream of the flow measuring stations. These wells are not shown on
the figures, as their actual locations have not yet been determined by Skaggs. Data from these wells
will be used to describe the hydrology and calibrate the model for each drainage basin. The WL-80s
and shallow monitoring wells for all three stream drainages will be installed in early 1998. All WL-80
and shallow monitoring well locations will be surveyed by PCS Phosphate for location and elevation
relative to sea level.
The flow monitoring stations will include dual systems for measuring flow rates. Under
low and moderate flow conditions, flows will be determined by measuring the stage on the upstream
side of a triangular weir. Flow velocities in the outlet pipe system will also be continuously measured
with a recording Marsh McBirney flow meter. For high flow events and during very wet periods,
backwater conditions might submerge the weir for periods of time. During those periods, flow rates will
be determined from the Marsh McBirney flow meter alone. Where possible, flow stations will be located
at road crossings where the flow is concentrated and exits the watershed (or sub -watershed) through
a culvert. Flow stations not located at road crossings will need to have weirs and culverts installed to
facilitate flow measurement. A total of eight stations (two on Jacks Creek, two on Tooley Creek, and
four on Huddles Cut) will be located on the drainages which feed into the main creeks (Figures 2, 3, 4,
5). These intermittent drainages are dry much of the year. The proposed monitoring locations were
selected based on a combination of factors including accessibility for installation and monitoring, the
presence of a constriction (channel or culvert) to facilitate measurement, and location near the lower
end of the free -flowing portion of each stream. All flow stations will be installed and calibrated in early
1998.
In the lower portions of the intermittent drainages just above the CAMA markers on each
creek, riparian wetlands (normally narrow bands of bottomland hardwoods) occur. If there is any impact
by reducing the freshwater flow due to reduction of the creeks' drainage areas, these wetlands would
appear to be the ones most likely to be impacted. Vegetation monitoring sites will be located in the

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r
WL-80 AND SHALLOW MONITORING WELL LOCATIONS,
FLOW MONITORING STATIONS, AND WATER QUALITY MONITORING STATIONS
IN THE TOOLEY CREEK DRAINAGE
PCS PHOSPHATE COMPANY, INC.,
NCPC TRACT STREAM MONITORING
4
S
SCALE: 1' = 200' APPROVED BY: FILE:
Q DATE: JANUARY 1998 DRAWN SY;
' Photo Date:
r 2 APAIL 1989
R 4709 COLLEGE ACRES DRIVE, SUITE 2
. ,�. WILKNGTON. NORTH CAROLINA 29903
=6 TEL [phone]
INCORPORATED
FAX [phone]
* UMPONMedW CONRATANR �[w;I @am.�°m FIGURE 3

LEGEND
WL-80 monitoring well
OShallow
monitoring well
®
Flow monitoring station
Water quality monitoring station
�.®
Upper limits of CAMA jurisdiction
WL-80 AND SHALLOW MONITORING WELL LOCATIONS,
FLOW MONITORING STATIONS, AND WATER QUALITY MONITORING STATIONS
IN THE MAIN PRONG OF HUDDLES CUT
PCS PHOSPHATE COMPANY, INC.,
NCPC TRACT STREAM MONITORING
SCALE: 1 " = 200' APPROVED BY: FILE:
DATE: JANUARY 1996 DRAWN BY:
Photo Date:
AA2
APRIL 1989
D IVE.OLM SUITE 2
CQLN,
ZR
N RTHACRC
WkLMINGTpN, NORTH CARg4iNA 29403
ILMI
0E-
TEL 91W392-9253
NCORPORATED FAX [phone]
UIVIRONIVIENTAL CONSULTANTS [e-mail]
FIGURE 4
12
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16
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vicinity of each of the 20 WL-80 continuous monitors located in the riparian wetlands. Thus, the 20
vegetation monitoring sites will include five in Jacks Creek, three in Tooley Creek, and twelve in
Huddles Cut (see WL-80 locations in Figures 2 through 5).
Vegetation sampling will focus on the shrub and herb layer. Compared to trees, shrubs
and herbs respond more quickly to changes in salinity and hydrology and therefore will provide a better
way to monitor changes in the vegetation. At each site, ten permanent random sample plots will be
selected within a 100-foot radius of the WL-80 location. Each sample plot will include a 1-square meter
herb plot and a 4-by-4 meter woody vegetation plot selected on random compass bearings and
distances from the WL-80 location. These plots will be used to measure density, coverage, and species
composition of the herb and shrub layers. Vegetation plots will be established on Jacks Creek in 1998.
Vegetation plots on Tooley Creek and Huddles Cut will be established closer to the time that land
clearing activities are expected to reach the drainage basins of those creeks.
4. Install atiQ n_oLR a i n S_au= .
Rain gauges will be installed in each of the three creek drainages lone each in the Jacks
Creek, Tooley Creek, and Huddles Cut drainages) in early 1998. The rain gauges will be the TE-125
TELOG Tipping Bucket Rain Gauge.
1 .� . •i rRMFLAreraff roMMUM, MW A lel @11 ceiM I �i -
Proposed salinity monitoring sites are shown in Figure 6. The precise salinity monitoring
sites will be established and marked, and continuous monitors will be installed. Two monitors will be
installed in Jacks Creek, one near the upper end of the CAMA jurisdiction in the permanent open water
of the creek and one at the mouth of the creek. Two monitors will be installed on Tooley Creek, one
near the junction of the two main prongs and one at the mouth of the creek. On Huddles Cut, three
monitors will be installed, one each near the CAMA marker on the main drainage and the CAMA marker
on the western prong, and one at the creek mouth. Two additional monitors, one in South Creek and
one in the Pamlico River (Figure 6) will provide comparison salinity values. The type of salinity monitor
used will probably be the YSI 600 XLM, which allows measurement of salinity and water level. The
salinity monitors will be installed in early 1998.
as follows:
6. EstabLLshmentQf Water Quality Monitoring Sites.
CZR will establish and mark water quality monitoring sites on each of the creek systems
Jacks Creek (Figure 2): At two locations, one just below the flow
monitoring station on the main prong, and one
at the salinity monitor near the junction of the
prongs of Jacks Creek.
Tooley Creek (Figure 3): At three locations, one each just above the
CAMA marker on the two main prongs, and one
at the salinity monitor near the junction of the
two main prongs.
Huddles Cut (Figures 4 and 5): At four locations, one each above the CAMA
marker on the main prong and on the western
prong, and one each at the salinity monitor just
below the CAMA marker on each prong.
14

Y
-
S
IZ
C.,. �: •
0

Water quality stations will be established on Jacks Creek in 1998, but stations on Tooley Creek
and Huddles Cut will not be established and monitored until closer to the time that land clearing
activities are expected to reach those drainage basins.
UtM
Fish and benthos monitoring stations will be located in the vicinity of (just above and just below)
the CAMA markers on the main prong of Jacks Creek, on each of the two main prongs of Tooley Creek,
and on the main prong and western prong of Huddles Cut. The stations will be sampled in winter
(February) and summer (July) of each sample year, using the sampling protocol established by DWQ for
the ongoing sampling on Whitehurst and Bailey Creeks. Sample site establishment will occur in 1998
on Jacks Creek, but will be deferred on Tooley Creek and Huddles Cut until closer to the time that land
clearing activities are expected to reach those drainage basins.
Areas upstream of the CAMA markers (which likely will be freshwater) will be sampled by
electrofishing; whereas areas downstream may have salinity (and thus conductivity) levels too high to
use the back -pack electroshocker. These areas will be sampled with nets or seines. Stream
configurations and habitat conditions in these streams may warrant variations from DWQ's normal 600-
foot standard sample station length. For example, the upstream station in the main prong of Huddles
Cut will be located in a wide, swampy area with no defined channel. Therefore, the sampling station
at this location likely will be shorter and wider than the DWQ standard. Once established, sample
stations will remain constant throughout the duration of the monitoring.
Sampling above and below the CAMA marker will give a sample in fresh water above the CAMA
marker, and a sample in the upper estuarine portion of the creek below the CAMA marker. Based on
past work in these areas, there should be permanent water in which to sample both in winter and
summer below the CAMA marker. For the intermittent areas above the CAMA marker, there likely will
be water present in the winter but the areas may be dry in summer.
Final graphics depicting sampling site locations, monitoring figures, and/or data presentation
figures will be prepared by CZR personnel. Some of the graphical presentations of hydrologic data and
modeling results will be supplied by Skaggs.
ANUME—romm
Detailed information on monitoring equipment and procedures will be included in the Year One
(1998) end -of -year report.
II. MONITORING PROTOCOL
This section presents the monitoring protocol for the parameters to be monitored in Jacks Creek,
Tooley Creek, and Huddles Cut. As stated previously, flow, groundwater, rainfall, and salinity
monitoring will begin on all three creeks as soon as possible in 1998, Monitoring of water quality,
vegetation and fish and benthos on Jacks Creek will begin as soon as possible in 1998, but will not
begin on Tooley Creek and Huddles Cut until closer to the time that land clearing activities are expected
to reach those 'drainage basins. The protocol presented in this section describes the full range
monitoring.
The early months of 1998 will involve coordination of the creek monitoring study with State and
Federal agencies and preparation for monitoring. We assume full-scale monitoring on Jacks Creek as
16

well as flow, groundwater, rainfall, and salinity monitoring on Tooley Creek and Huddles Cut will begin
around June 1998.
The well sites will be monitored every two weeks during the trips to download flow and salinity
data from the continuous monitors, The WL-80 data will be downloaded on a HP48GX calculatoridata
recorder, and the water level in the wells will be read visually and recorded on well data sheets {or in
field notebooks to be transferred to well data sheetsl.
Data from the wells and WL-80s in headwater areas above the flow monitoring stations will be
used by Skaggs for the drainage hydrology modeling. Data from the wells and WL-80s in the riparian
wetlands will be used primarily to construct a general characterization of the hydrology of the riparian
bottomland hardwood wetlands, but will also be used by Skaggs in the flow modeling. Groundwater
data will be presented in tabular and graphic format, and wetland hydroperiod durations will be
calculated. Standard well data will be correiated with WL-80 data to allow estimation of the water table
depth at the well locations between monitoring visits. Additionally, on -site flow data and estuarine
water level data will be displayed graphically with WL-80 water level data so that the relative effects
of flow and estuarine water level fluctuations on groundwater levels can be evaluated.
In addition to the on -site rainfall data collected to facilitate the flow modeling, rainfall data will
also be collected at the weather station on the PCS Phosphate plant site. There is a 28-year record of
rainfall data for the plant site, so current data from the plant site can be compared to historical data to
assess the relative wetness or dryness of a particular year.
S1111111111110 57M ►!.0. �1 M MT1•• �.
The data from the eight continuous flow monitors will be downloaded every two weeks. Copies
of the data will be supplied to Skaggs for subsequent analysis and for use in describing the hydrology
and modeling the flows in the three creek drainages. Beginning in 1999, Skaggs will analyze the flow
data and produce tabular and graphical flow rate and cumulative outflow graphs for each monitored
drainage area. Water balance calculations will be conducted and reported. These data, together with
water table data from the watersheds, will be used to test and calibrate the model. Using recorded
rainfall data, the model will predict flow rates and cumulative volumes on a day-by-day basis for the
period of monitoring. Once calibrated, the model will be used to simulate the hydrology for a long
period of hydrologic record at this location. This will enable us to define a statistically reliable baseline
condition for the drainage areas considered. Then the model can be applied to predict the effect of
basin reduction due to mining on the outflows to the creeks. This can be done for any stage of the
mining process. The predicted flows can then be used to assess potential impacts to the other
parameters being studied. In the event that it is necessary to supplement outflows during the mining
process because of reduction in the drainage area, the model could be run in "real time" to determine
the amount of drainage, and its distribution in time, that would have occurred under normal or
undisturbed conditions.
[�VMTVTMIM. KULVI.e .•.
Every two weeks, during the trip to download data from the continuous flow monitors, salinity
monitors, and WL-80 groundwater monitors, physical water quality data and water samples for
chlorophyll a and nutrient analyses will be collected from all nine water quality locations. The
parameters measured will include:
17

• Temperature
• Dissolved oxygen
• Salinity
• pH
• Secchi depth
• Turbidity
• Chlorophyll a
• Phosphorus
— Dissolved orthophosphate phosphorus
— Total dissolved phosphorus
— Particulate phosphorus
• Nitrogen
— Nitrate nitrogen
— Ammonia nitrogen
— Particulate nitrogen
— Dissolved Kjeldahl nitrogen
The chlorophyll a and nutrient analyses will be done under Dr. Donald W. Stanley's direction at the
laboratories of East Carolina University. Dr. Stanley will assist CZR with water quality data analyses
and reporting.
Data from the salinity monitors will. be downloaded every two weeks in conjunction with the
downloading of data from the flow monitors. The data will be retrieved using the HP48GX calculators
used to download the WL-80s. Maintenance (e.g., changing batteries, cleaning probes) will be
performed on the salinity monitors as needed during the data retrieval visits.
The salinity data will be displayed graphically with the flow data, estuarine water level data, and
USGS stream gauge data from the Tar River. This will allow analysis of the relative influence of these
factors on salinity in the creeks. This analysis will be used to make qualitative predictions of the effects
of drainage basin reduction on salinity.
E. Y ge.tation Monitoring.
Vegetation monitoring will be conducted during July and/or August of each monitoring year.
Shrubs, defined as woody plants greater than 3.2 feet in height but less than 3 inches in diameter at
breast height (DBHi, will be inventoried in each of the ten 4-by-4 meter plots located in the vicinity of
each WL-80 in the riparian wetlands. For each species, the number of stems present will be counted
and percent cover will be estimated. Herbs, defined as all vascular plants less than 3.2 feet in height,
will be inventoried in each of the 1-square meter plots nested within the 4-by-4 meter plots. For each
species, the number of stems present will be counted and percent cover will be estimated. For shrubs
and herbs, the cover data, density data, and importance values calculated will be used to assess
changes in vegetation structure and composition over time.
F. Fish -and benthos MoniUgmg.
Because of the timing of the beginning of the study, fish and benthos sampling on .tacks Creek
in 1998 will be limited to the summer (July) sampling period. In other monitoring years, fish and
benthos sampling will be conducted in winter and summer.
18

In the areas upstream of the CAMA markers, fish sampling likely will be conducted using a
backpack electroshocker. Upstream and downstream block nets will be used when needed. back of
water during the July sampling period on these intermittent streams may necessitate the elimination of
sampling at some or all of the upstream sampling locations. In the area downstream of the CAMA
markers on each stream, high conductivity likely will prevent electrofishing. Therefore, these areas will
be sampled using seines and/or hoop nets as dictated by habitat conditions in the individual sample
areas. Fish collected will be identified, measured, and either kept as vouchers or released. Data on
species richness and abundance will be tabulated for inclusion in the annual report. The data will be
used to track changes in species richness and abundance over time.
Benthic macro invertebrates will be collected using nine standing sweep net samples at each
sample station. Lack of water during the July sampling period may necessitate reduction or elimination
of sampling at some or all of the upstream sampling locations. Samples will be hand -sorted in the field
and all macroinvertebrates collected will be preserved in 10 percent formakn. Additional
macroinvertebrates will be collected from log washes and rubs as well as by incidental captures made
during visual searches. All specimens will be transferred to 95 percent denatured ethanol in the lab,
and will be identified to the lowest reasonable taxa within each group. Data on taxa richness and
abundance will be tabulated for inclusion in the annual report. The data will be used to track changes
in taxa richness and abundance over time.
During the vegetation sampling, two photographs will be taken at each WL-80 location in the
riparian wetlands. Each photograph will feature a 10-foot range pole located at a fixed distance from
the camera. The camera will be situated at the WL-80 location, and a picture will be taken facing
upstream and downstream. Camera and range pole locations will remain constant throughout the
duration of the monitoring program. The photographs will be included in the annual report, and will be
used to provide visual documentation of changes over time.
During the fish and benthos sampling, a representative photograph will be taken of each sample
station. The photograph locations will remain constant throughout the duration of the monitoring
program. The photographs will be included in the annual report, and will be used to provide visual
documentation of changes over time.
H. S_c 1[ P__roperty_Mea,swrorn_a=.
Measurements of the soil properties, the soil water characteristics, and the saturated hydraulic
conductivity in each of the three study drainages will be done by Skaggs in 1998. These data will be
used in the hydrologic modeling of the three drainage areas. Measurements will be made at an
estimated 12 locations (with three depths and three replications at each location). Hydraulic
conductivity tests will be conducted at 75 to 100 locations. Soil property, site parameter, and
vegetation data will be assembled into data sets for modeling the hydrology of the watersheds.
Preliminary model simulations will be conducted in 1998 to make sure that all needed data are being
collected.
IM S .. ,! f I I l:. l
An annual report, which will include an analysis and discussion of the data collected in items
A. through H., will be submitted to the USACE, DWQ, and the North Carolina Division of Land
Resources (DLR) by 15 March following each monitoring year.
19

Ill. FOLLOW-UP MONITORING
During the years when the mine reaches portions of the Jacks Creek, Tooley Creek, and Huddles
Cut drainage basins, the monitoring protocol established above will be repeated. The results of the
follow-up monitoring will be compared with the initial monitoring data. Annual reports of the monitoring
will be submitted to the DWQ, the USACE, and the DLR in mid -March of the year following the
sampling. If any deleterious effects to riparian wetland functions are suggested by the data, PCS
Phosphate and CZR will report and discuss such effects in the annual report and will suggest a plan of
remedial action. If no deleterious effects are identified on a particular creek for a period of two years
following drainage basin reduction, monitoring on that creek will be discontinued.
20

REFERENCES
Amatya, D.M., R.W. Skaggs, and J.D. Gregory. 1997. Evaluation of a watershed scale forest
hydrologic model. Ag Water Management, 32:239-258.
Brinson, M.M., W.D. Bradshaw, and M.N. Jones. 1985. Transitions in forested wetlands along
gradients of salinity and hydroperiod. J. Elisha Mitchell Sci. Soc. 101.76-94,
CZR Incorporated. 1990. Report on 1988-1989 hydrography, sediment, benthic, fisheries, and
xooplankton/ichthyoplankton surveys in support of the Environmental impact Statement for the
Texasgulf Inc. mine continuation. 78 pp.
CZR Incorporated. 1994. Compilation and analyses of drainage area, salinity, rainfall, and fisheries
data to address potential impacts to the tidal estuarine creeks in the NCPC Tract due to
drainage basin reductions involved with Texasgulf's proposed Alternative B.
Engel, D.W., W.F. Hettler, L. Coston-Clements, and D.E. Hoss. 1987. The effect of abrupt salinity
changes on the osmoregulatory abilities of the Atlantic menhaden Brevoortia tyrannus. Comp.
Biochem. Physiol. 86:723-727.
Hettler, W.F. 1976. Influence of temperature and salinity on routine metabolic rate and growth of
young Atlantic menhaden. J. Fish. Biol. 8:55-65.
Konyha, K.D, and Skaggs, R.W. 1992. A coupled field hydrology -open channel flow model:theory.
Trans of the ASAE, 35(5):1431-1440.
Lawson, T.J. 1981. Nursery area assessment of Bond, Long, and Short creeks, Beaufort County,
North Carolina. Annual report to Texasgulf Inc. 134 pp.
Lawson, T.J. 1982. Nursery area assessment of Bond, Long, and Short creeks, Beaufort County,
North Carolina. Annual report to Texasgulf Inc. 192 pp.
Miller, J.M., B.M. Currin, and M.L. Moser. 1988. Broad Creek report - faunal studies. Pp. 213-422
in Freshwater inflow and Broad Creek estuary, North Carolina. Special Report: UNC Sea Grant
College Program, Submitted to N.C. Div. of Sail and Water, Dept. of Nat. Resour. and Comm.
Devel. 422 pp.
Moser, M.L. 1987, Effects of salinity fluctuation on juvenile fish. Unpubl. Ph.D. thesis, N.C. State
Univ., Raleigh, N.C. 150 pp.
Moser, M.L. and L.R. Gerry. 1989. Differential effects of salinity changes on two estuarine fishes,
Leiostomus xanthurus and Micropogonias undulatus. Estuaries 12:35-41.
Moser, M.L. and J.M. Miller. 1994. Effects of salinity fluctuation on routine metabolism of juvenile
spot, Leiostomus xanthurus. J. Fish. Biol. 45:335-340.
Nixon, S.W. 1989. Water quality in the Pamlico River estuary -- with special attention to the possible
impact of nutrient discharges from Texasgulf Inc. A report prepared for Texasgulf Inc. 147
PP.
Overton, M.F. and J.S. Fisher. 1988. Broad Creek salinity study: Final Report. Pp. 1-61 jIl
Freshwater inflow and Broad Creek estuary, North Carolina. Special Report: UNC Sea Grant
College Program. Submitted to N.C. Div. of Soil and Water, Dept. of Nat. Resour. and Comm.
Devel. 422 pp.

Pietrafesa, L.J. 1985. Response of Rose Bay to freshwater inputs. Pp. 21-61 in W. Gilliam, J.M.
Miller, L. Pietrafesa, and W. Skaggs (eds.). Water management and estuarine nurseries. UNC
Sea Grant Publ. UNC-SG-WP-85-2. 84 pp.
Pietrafesa, L.J., F. Askari, and C. Gabriel. 1988. On salinity fluctuations in Broad Creek. Pp. 62-212
L Freshwater inflow and Broad Creek estuary, North Carolina. Special Report: UNC Sea Grant
College Program. Submitted to N.C. Div. of Soil and Water, Dept. of Nat. Resour. and Comm.
Devel. 422 pp.
Rulifson, R.A. 1990. Finfish utilization of man -initiated and adjacent natural creeks of South Creek
estuary, North Carolina, 1984-1988. ICMR Technical Report No. 90-01. ICMR-ECU,
Greenville, N.C. 45 pp.
Skaggs, R.W. 1980. A water management model for shallow water table soils. Technical Bulletin No.
276, North Carolina Agricultural Research Service, N.C. State Unvieristy, Raleigh, 54 pages.
Skaggs, R.W. 1991. Drainage. In J. Hanks and J. Ritchie (eds), Modeling Plant and Soil Systems,
Agronomy Monograph No. 31, American Society of Agronomy, Madison, W1:205-243.
Stanley, D.W. 1988. Water quality in the Pamlico River estuary 1987. A report to Texasgulf
Chemicals, Inc. ICMR Technical Report No. 88-02. ICMR-ECU, Greenville, N.C. 82 pp.
U.S. Army Corps of Engineers. 1996. Final Environmental Impact Statement for the Texasgulf Inc.
mine continuation, Aurora, North Carolina.
West, T.L. 1988. Effects of claypond freshwater discharge on finfish and shellfish utilization of
nursery areas. Summary of preliminary findings. Submitted to Texasgulf, Inc. Dept. of
Biology, East Carolina University, Greenville, N.C. Pages unnumbered.
West, T.L. 1990. Growth and survival of Lerostomus xanthurus (spot) in man-made and natural
wetlands. Report to Texasgulf Chemicals, Incorporated. Dept. of Biology, East Carolina
University, Greenville, N.C. 30 pp.

iJ 7
James B. Hunt Jr., Governor By Jonathan B. Howes, Secretary
IDEHNFI
North Carolina
Department of
Release: 'Immediate
t, Health, and Natural Resources
Contact: Ernie Seneca 919/733-7015
ext.208
Date5// .g Distribution: Statewide
State Approves PCS PhosphaWs__20-Year ining Expansion Into Wetlands
RALEIGH --- The Potash Corporation of Saskatchewan (PCS) Phosphate Co.,
formerly Texasgulf, has been given conditional state approval to expand phosphate mining
operations onto 1,268 acres of Beaufort County wetlands over the next 20 years.
Today the North Carolina Division of Water Quality issued a 401 certification as
prescribed by the federal CIean Water Act to allow wetland fill on the company -owned tract
bordered by the Pamlico River and South Creek near Aurora. The U.S. Army Corps of
Engineers will review the certification and decide whether to issue its own permit before
PCS can begin training the area, which is about three miles northeast of current operations.
Preston Howard, director of the Division of Water Quality, said the state
certification requires the company to "come back in 10 years and show us whether. it should
be allowed to continue as planned." PCS must demonstrate that no mining methodology is
available or economically feasible that would reduce impacts to wetlands and water.
"Even though we'll be monitoring the project continuously, the 10-year review
provision will really help us ascertain if more changes can be made to better protect the
environment," Howard said. "Technology may have advanced to the point where further
reduction of wetlands impacts is attainable and cost-effective."
The 404 permit that PCS now needs from the Corps of Engineers can either be
equal to or more stringent than the state certification. Also needed before the company can
proceed is consistency approval from DEHNR's Division of Coastal Management, as
required by the federal Coastal Zone Management Act, and modification of its mining
permit from the department's Division of Land Resources.
John Dorney, supervisor of the Water Quality Certification Program for the
Division of Water Quality, said government and company officials have held lengthy
negotiations since expansion plans were unveiled in 1993. PCS originally proposed to
mine phosphate on 3,069 wetland acres. "These discussions led to PCS agreeing to nine
substantially less acreage and with much fewer wetland impacts," he said.
"This is obviously an environmentally sensitive area of the state, with marshes,
primary nurseries for fish and bottomland hardwoods," Dorney said. "We took whatever
Public Affairs Office Debbie Crane
PO Box 27687, Raleigh, N. C. 2761.1 Director, Office of Public Affairs
.(9,19) 715-4112 =FAX # [phone] ,
An Equal opportunity / Affirmative Action Employer

steps were feasible and allowed by the rules to protect the watershed and aquatic life. The
most sensitive areas will be protected, and PCS will reclaim affected mining areas.
"We looked at downstream and cumulative effects along with the mitigation plans,"
he added. "Nitrogen and phosphorous discharges from the company's treatment plant into
the Pamlico River have been dramatically reduced over the years. PCS has already restored
about 2,400 acres of wetlands on nearby Iand as part of this mitigation effort."
PCS is the first company in North Carolina to mitigate wetlands prior to impacting a
site. Beginning in early 1995, the company blocked drainage ditches and started planting
hardwoods on the tract formerly known as Parker Farm which is located between
Vandemere Creek on the Bay River and South Creek on the Pamlico. Plans call for
restoring an additional 600 acres at that farm.
The 401 certification for expansion requires PCS to develop a water management
and stream monitoring plan for water quality and quantity as well as biology for Huddles
Cut and Jacks Creek, tributaries of the Pamlico River and South Creek, respectively.
Division of Water Quality approval is required for the plan to be implemented.
Both the company and third party interests have 60 days to appeal either the
certification or portions contained within the document.
* Contact: Ernie Seneca, public information officer, N.C. Division of Water Quality, (919)
733-7015, extension 208; John Dorney, supervisor of the Water Quality Certification
Program, DWQ, [phone].

DRAFT RELEASE
Cry
rft/g ;L
State Approves PCS Phosphate's 20- Year Mining Expansi Into Wetlands
RALEIGH --- The Potash Corporation of Saskatchewan (PCS) Phosphate Co.,
formerly Texasgulf, has been given conditional state approval to expand phosphate mining
operations onto 1,268 acres of Beaufort County wetlands over the next 20 years.
Today the North Carolina Division of Water Quality issued a 401 certification as
prescribed by the federal Clean Water Act to allow wetland fill on the company -owned tract
bordered by the Pamlico River and South Creek near Aurora. The C.S. Army Corps of
Engineers will review the certification and decide whether to issue its own permit before
PCS can begin mining the area, which is about three miles northeast of current operations.
Preston Howard, director of the Division of Water Quality, said the state
certification requires the company to "come back in 10 years and show us whether it should
be allowed to continue as planned." PCS must demonstrate that no mining methodology is
available or economically feasible that would reduce impacts to wetlands and water.
"Even though we'll be monitoring the project continuously, the 10-year review
provision will really help us ascertain if more changes can be made to better protect the
environment," Howard said. "Technology may have advanced to the point where further
reduction of wetlands impacts is attainable and cost-effective."
The 404 permit that PCS now needs from the Corps of Engineers can either be
equal to or more stringent than the state certification. Also needed before the company can
proceed is a coastal zone consistency determination from DEHNR's Division of Coastal
Management, as required by the state Coastal Area Management Act, and modification of
its mining permit from the department's Division of Land Resources.
John Dorney, supervisor of the Water Quality Certification Program for the
Division of Water Quality, said government and company officials have held lengthy
negotiations since expansion plans were unveiled in 1993. PCS originally proposed to
mine phosphate on 3,069 wetland acres. "These discussions led to PCS agreeing to mine
substantially less acreage and with much fewer wetland impacts," he said.
"This is obviously an environmentally sensitive area of the state, with marshes,
primary nurseries for fish and bottomland hardwoods," Dorney said. "We took whatever

steps were feasible and allowed by the rules to protect the watershed and aquatic life. The
most sensitive areas will be protected, and PCS will reclaim affected mining areas.
"We looked at downstream and cumulative effects along with the mitigation plans,"
he added. "Nitrogen and phosphorous discharges from the company's treatment plant into
the Pamlico River have been dramatically reduced over the years. PCS has already restored
about 2,400 acres of wetlands on nearby land as part of this mitigation effort."
PCS is the first company in North Carolina to mitigate wetlands prior to impacting a
site. Beginning in early 1995, the company blocked drainage ditches and started planting
hardwoods on the tract formerly known as Parker Farm which is located between
Vandemere Creek on the Bay River and South Creek on the Pamlico. Plans call for
restoring an additional 600 acres at that farm.
The 401 certification for expansion requires PCS to develop a water management
and stream monitoring plan for water quality and quantity as well as biology for Huddles
Cut and Jacks Creek, tributaries of the Pamlico River and South Creek, respectively.
Division of Water Quality approval is required for the plan to be implemented.
Both the company and third party interests have 60 days to appeal either the
certification or portions contained within the document.
### #### M
* Contact: Ernie Seneca, public information officer, N.C. Division of Water Quality, (919)
733-7015, extension 208; John Dorney, supervisor of the Water Quality Certification
Program, DWQ, (9I9) 733-1786.

MOP
•
Author: Charles Gardner at NROLROIP
Date: 4/11/97 11:01 AM
Priority: Normal
Receipt Requested
TO: Preston Howard at Internet
TO: Roger Schecter at nroba03p
TO: Melba McGee at NRDCSOIP
CC: Linda Rimer at NRDCS01P
CC: Mell Nevils
CC: Tracy Davis
CC: [e-mail] at Internet
Subject: Re[2]: PCS Meeting/Action Items
-------------------------------------- Message Contents --------------------------------------
This is simply to let you know the expiration dates of the existing
PCS Mining Permits (see following message). Permit 907-05 covers the
area east of SR-306, and was transferred from NCPC to Tg (PCS).
Before PCS may begin mining east of SR-306, permit #07-05 will be
consolidated into #07-01, and #07-01 will be modified to incorporate
the "401" conditions along with other conditions for environmental
protection, as provided under the broad authority of the N.C. Mining
Act. Input from DWQ, DCM, Wildlife, Marine Fisheries, and others will
be solicited by DLR as part of the permit consolidation/modification
process.
Charles
Forward Header
Subject: Re[2]: PCS Meeting/Action Items
Author: Tracy Davis at NROLR0IP
Date: 4/11/97 8:46 AM
Charles,
07-01 (Lee Creek Mine) expires 1/4/2003; 07-05 (NCPC Mine/EIS Tract)
expires 1/31/2005.
However, as you know, 07-05 was renewed as an ".inactive
renewal"...thus, it is my understanding from our past discussions that
PCS will have to submit a major modification to "activate" the permit.
This would include a comprehensive mining, S&E, and reclamation plan,
along with any required studies.
Tracy
Reply Separator
Subject: Re: PCS Meeting/Action Items
Author: Charles Gardner at NROLR0IP
Date: 4/10/97 1:54 PM
FYI, This brings you pretty well up to date on this. I've
clear that the Mining Permit will address some issues that
currently unresolved, particularly the detailed reclamation
the cadmium issue. The latter is related to the former, of
could be a tough issue (apparent lack of good science and a
concern by WRC at this point).
made it
are
plan and
course, and
lot of

:_lease remind me (again) of the current mining permits expiration
' dates.
Charles
Forward Header
Subject: Re: PCS Meeting/Action Items
Author: Henry Lancaster at NRDCSOIP
Date: 4/10/97 1:15 PM
Phone notification and mail followup is ok.
Reply Separator
Subject: PCS Meeting/Action Items
Author: Melba McGee at NRDCSOIP
Date: 4/9/97 3:05 PM
I thought the meeting with EHNR divisions and the Corps was very
productive. The purpose of the meeting was to discuss the issues
identified with the preferred Alternative (E) but also see if we could
reach a comfort level where EHNR divisions could accept the
department's decision. I think we accomplished this by agreeing on
what conditions would be included in the 401/consistency/404. This
also allowed other EHNR divisions the opportunity to critique and be
involved in these decisions. There are still concerns but I do think
everyone feels more at ease that measures will be in place to protect
us down the road. Divisions agreed that the Secretary's letter to PCS
requesting further coordination would allow us to discuss some of the
unresolved long term issues. Sequence of events that are expected to
take place in the next couple of weeks:
Tom Reagan with PCS has been asked to identify a corridor within
Alternative E for removing mining equipment. Charles Gardner asked
Tom to send the letter acknowledging the corridor to the Corps. Rann
Carpenter of PCS is aware that the 401/Consistency Determination will
not be issued until EHNR has received copies of that letter.
Issue 401/Consistency simultaneously. Depending on when PCS' letter is
received and what it contains, this process could take a few days to a
week.
Corps' Record of Decision Issued, then 404. The Corps thinks this will
take a couple of months.
Notify Special Interest Groups by phone and mail copies of the News
Release.
Release Secretary Howes' letter to PCS requesting additional
coordination to discuss future minable areas. Letter being drafted by
Water Quality.
Preston, Roger, Charles please add to this if I have left anything
out.
Secretary Howes, Henry, Linda any feedback on notifying the Special
Interest Groups by phone then mailing them the news release?

0
AGENDA
PC S MEETING
April 9,1997
I. Opening Remarks
II. Charles Gardner
Corridor for Recovering Mining Machines
IIT. David Franklin - Corps Update
IV. John Domey - 401 Water Quality Certification
New Rules verses Old Rules
V. Group Discussion
VI. Overview ofFinal Action
Wt r PC s
41)
U

PCS
Phosphate
3101 GLENWOOD AVE.. P.O. BOX 30321. RALEIGH, NC 27622.0321 TEL: [phone]U FAX: [phone],7
`4t March 26, 1997
Colonel Terry Youngbluth
District Engineer
U.S. Army Corps of Engineers
Post Office Box 1890
Wilmington, North Carolina 28402
��✓ I99
9�
Thomas J. Regan, Jr.��
Executive Vice President
RE: PCS Phosphate Company, Inc. (Texasgulf Inc.) Mine Advance Permit
Dear Colonel Youngbluth:
PCS Phosphate Company, Inc. (PCS) received a copy of the letters to you from the Pamlico -
Tar River Foundation (PTRF) and the Southern Environmental Law Center (SELL) dated January
20, 1997 regarding the PCS Permit Application. PCS believes the PTRF and SELC have attempted
to add certain facts to the administrative record which are inaccurate. These facts are related to: (1)
the availability and suitability of certain PCS land holdings south of the Project Area for phosphate
mining, and (2) the current practicability of mining those land holdings.
PTRF contends, and SELC relies upon, "an initial survey" that shows that PCS "owns
approximately 11,000 acres overlying the phosphate deposit south of the project area." PTRF and
SELC then assert that this "southern reserve area consists mostly of uplands." PTRF and SELC
conclude that the Corps' Final Environmental Impact Statement (FEIS) did not demonstrate that an
alternative based upon continued mining in this area southwest of Aurora (characterized as a "no
action" alternative) was impractical. The Corps clearly considered such an alternative in Section
3.2.2 of the FEIS. Therefore, the complaint of PTRF and SELC is really a factual disagreement with
the Corps' opinion. However, the "facts" PTRF and SELC rely upon to discredit the Corps' opinion
are inaccurate and distort the true situation.
PCS actually owns 9,984 acres south of the Project Area (PTRF's calculation included some
acreage within the Project Area), but only 4,786 of those acres are realistically available for mining
because: (1) 122 acres he within the City limits of the Town of Aurora, (2) 812 acres are isolated to
the west of Durham Creek, (3) 723 acres consist of parcels isolated by ownership and wetlands along
the east side of Durham Creek with no parcel larger than 165 acres, (4) 1,842 acres are isolated to
the east of or are in the upper reaches of South Creek, and (5) 1,699 acres consist of parcels isolated
by ownership and wetlands along the west side of South Creek with no parcel larger than 225 acres.
Even the 4,786 acre area described as available is interspersed with 465 acres of uncontrolled
property which would have to be acquired to allow for the development of an effective nine plan.
Furthermore, the remaining 4,786 acres contain the upper reaches of two tributaries of South
Creek (Bloomfield Swamp Creek and Cypress Run) and one-third of this area is woodlands.
Although two-thirds of the area is in productive farmland use, at least 95% of the soils in this area

Colonel Terry Youngbluth
March 26, 1997
Page Two of Two
are hydric. Although PTRF and SELC reference the National Wetlands Inventory maps, they well
know that these same maps drastically underestimated the wetlands actually delineated in the.Project
Area. Based upon our observations and conversations with our wetlands consultants, PCS believes
that approximately 1,600 acres of the 4,786 could be delineated as wetlands under current Corps
guidance and the remainder iS'probably prior converted cropland.
PTRF and SELC also suggest consideration be given to mining a tract of land owned by
Reserveco, an Elf Aquitaine subsidiary, which is located south of the 4,786 acres. However, even
a cursory look at the Reserveco tract indicates that it is almost totally wetlands.
Even if one were to assume the Corps would issue a permit to mine the 4,786 acre block
(Aurora Southwest Area) and that PTRF would actually acquiesce to such a permit, the direct
operational costs of mining this tract represent a staggering increase over the already economically
distressed Alternative E. There are four major reasons for this cost increase: (1) poorer ore quality,
(2) thinner ore thickness, (3) doubled ore transport distances, and (4) the need to open a new mine
pit because of the intervening homes, businesses, highway, rail lines and power lines. Our Mining
Planning Department compared the operational cost differential between Alternative E, the second
ten years of Alternative E, and the new mine- See enclosed Tables I and R which were prepared
using the same mineral resource parameters, mining cost factors, and 1991 dollars as are used in the
FEIS. Since PCS would mine the uplands in Alternative E first in either scenario, consideration of
the first ten years is really irrelevant. Even under the Wilmington District's expansive view of
economic practicability, an operational increase for the second ten years of $354.4 Mullion is
unreasonable. In addition to the direct economic detriment to PCS, the Corps needs to consider the
socioeconomic distress which seven farming families face by the loss of cropland they have been
farming for decades.
The other arguments raised by PTRF and SELC repeat earlier arguments which have already
been addressed in the FEIS.
Enclosures
Iad:032597,O6
pc: Derb Carter, Esquire (SELC)
Kristin Rowle6 (PTRF)
Stephen D. Benton
John Dorney
A. Preston Howard, Jr.
Brooke Lamson
Sincerely,
_PCS PNOSPFHLA,1,7COMPANY,INC.
`j_'home r.
Executive Vice t
T. J. Wright
W. T. Cooper
W. A. Schimming
P. J. Moffett
G. W. House
J. Hudgens
B. BoJick

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
A'K
74
0�1&
�EHNR
April 14, 1997
Mr. Thomas J. Regan, Jr.
Potash Corp. of Saskatchewan (PCS) Phosphate Co.
P.O. Box 48
Aurora, NC 27806
Dear Mr. Regan,
Re: Certification Pursuant to Section 401 of the Federal Clean Water Act,
Proposed expansion of PCS Phosphate mine
WQC Project #961120, COE #198800449
Beaufort County
Attached hereto is a copy of Certification No. 3092 issued to PCS Phosphate Company dated
14 April 1997.
If we can be of further assistance, do not hesitate to contact us.
Sincerely,
A. Preston Howard, Jr. P.E.
Attachments
961120.wgc
cc: Wilmington District Corps of Engineers
Corps of Engineers Washington Field Office
Washington DWQ Regional Office
Mr. John Domey
Mr. John Parker, Division of Coastal Management
Central Files
Kristin RowIes, Tar -Pamlico River Foundation
Derb Carter, Southern Environmental Law Center
Melba McGee, EHNR
Frank McBride, WRC
Charles Gardner, DLR
Bruce Bolick, CZR
Roger Schecter, DCM
Katy West, DMF
Division of Water Quality • Environmental Sciences Branch
Enviro. Sciences Branch. 4401 Reedv Creek Rd.. Raleigh. NC 27607 Teleohone 919-733-1786 FAX # [phone]

NORTH CAROLINA 401 WATER QUALITY CERTIFICATION
.THIS CERTIFICATION is issued in conformity with the requirements of Section 401
Public Laws 92-500 and 95-217 of the United States and subject to the North Carolina Division of
Water Quality (DWQ) Regulations in 15 NCAC 2H, Section .0500 to Potash Corp. of
Saskatchewan (PCS) Phosphate Co. resulting in 1,268 acres of wetland impact in Beaufort
County pursuant to a revised application filed on the 5th day of December of 1996 to expand an
existing open pit phosphate mine following the alignment of Alternative E as outlined in the
Environmental Impact Statement except as modified below.
The application provides adequate assurance that the discharge of fill material into the waters
of South Creek and its tributaries in conjunction with the proposed development will not result in
a violation of applicable Water Quality Standards and discharge guidelines. Therefore, the State
of North Carolina certifies that this activity will not violate the applicable portions of Sections 301,
302, 303, 306, 307 of PL 92=500 and PL 95-217 if conducted in accordance with the application
and conditions hereinafter set forth.
This approval is only valid for the purpose and design that you submitted in your application,
as described in the Public Notice or as modified below. If you change your project, you must
notify us and you may be required to submit a revised application. If total wetland fills for this
project (now or in the future) exceed one acre, compensatory mitigation may be required as
described in 15A NCAC 2H .0506 (h) (6) and (7). For this approval to be valid, you must follow
the conditions listed below. In addition, you should get any other federal, state or local permits
before you go ahead with your project including (but not limited to) Sediment and Erosion
control, Coastal Stormwater, Non -discharge and Water Supply watershed regulations.
Condition(s) of Certification:
1. That appropriate sediment and erosion control practices which equal or exceed those
outlined in the most recent version of the "North Carolina Sediment and Erosion Control
Planning and Design Manual" or the "North Carolina Surface Mining Manual' (available
from the Division of Land Resources in the DEHNR Regional or Central Offices) are
utilized to prevent exceedances of the appropriate turbidity water quality standard (50
NTUs in- all freshwater streams and rivers and 25 NTUs in all saltwater classes);
2. Since an environmental document is required, this Certification is not valid until a Record
of Decision is issued by the US Army Corps of Engineers;
3. Measures shall be taken to prevent live or fresh concrete from coming into contact with
waters of the state until the concrete has hardened;
4. This certification shall expire on 14 April 2007 unless PCS demonstrates to the
satisfaction of the Director of the Division of Water Quality that no mining methodology
is available and economically feasible which would reduce impacts to wetlands and
waters. Should this demonstration be accepted by the Director of DWQ, then this
Certification shall expire on 14 April 2017.
5. Mitigation is required as described in the 5 December 1996 Public Notice from the U.S.
Army corps of Engineers. DWQ shall be sent two copies of all annual monitoring reports
for the wetland mitigation effort. If mitigation is not successful, additional mitigation will
be required.
6. A water management and stream monitoring plan for water quality, water quantity, and
biology (macrobenthos and fish) shall be developed by PCS Phosphate and submitted to
DWQ for written approval for Huddles Cut which is a tributary of the Pamlico River and

Jacks Creek which is a tributary of South Creek. This plan shall be designed to assure
the protection of downstream water quality standards by identifying any deleterious effect
on riparian wetland function as well as aquatic life in streams tributary the Pamlico River
and South Creek on the Durham -South Creek peninsula. This plan shall also shall
provide mechanisms for written approval to remedy these effects if any are identified.
This plan shall be submitted to DWQ within six months of the date of issuance of the 404
Permit. Seven copies of the draft plan shall be submited to DWQ for circulation and
review by the public and other agencies.
7. This Certification is for wetland impacts in Alternative E as described in the final
Environmental Impact Statement. It does not provide Certification for additional wetland
impacts along South Creek, it's tributaries and wetlands in those watersheds. Additional
wetland impact may not be allowed elsewhere on the peninsula unless agreed upon in
writing by the N.C. Division of Water Quality in the future. Compensatory mitigation
will be required for any additional wetland fill.
Violations of any condition herein set forth shall result in revocation of this Certification and
may result in criminal and/or civil penalties. This Certification shall become null and void unless
the above conditions are made conditions of the Federal 404 and/or coastal Area Management Act
Permit.
If this Certification is unacceptable to you have the right to an adjudicatory hearing upon
written request within sixty (60) days following receipt of this Certification. This request must be
in the form of a written petition conforming to Chapter 150B of the North Carolina General
Statutes and filed with the Office of Administrative Hearings, P.O. Box 27447, Raleigh, N.C.
27611.7447. If modifications are made to an original Certification, you have the right to an
adjudicatory hearing on the modifications upon written request within sixty (60) days following
receipt of the Certification. Unless such demands are made, this Certification shall be final and
binding.
This the 14 of April, 1997
DIVISION OF WATER QUALITY
A. Preston Howard, Jr. P.E.
WQC #3092

DRAFT
April 9, 1997
Mr. Thomas Regan
Potash Corp. of Saskatchewan (PCS) Phosphate
P.O. Box 48
Aurora, NC 27806
Dear Mr. Regan:
RE: Future mine advance
PCS Phosphate mine -. Aurora, NC
Beaufort County
As you are aware, staff from several agencies in the
Department of Environment, Health and Natural Resources, the U.S.
Army Corps of Engineers, the Pamlico -Tar River Foundation and PCS
Phosphate have been working over the past several years to
determine future minable areas (including a mining exclusion
zone) and associated wetland mitigation for the South Creek -
Pamlico River peninsula. These discussions have now been put on
hold by the company pending resolution of the 404 Permit action
for a portion of the peninsula. I understand that as of 14 April
1997, the 401 Certification and the Coastal Consistency
Determination were issued by the Divisions of Water Quality and
Coastal Management, respectively for alternative E.
Once the 404.Permit is issued for this project, I urge PCS
Phosphate to restart the earlier discussions to determine the
ultimate mining plan and wetland mitigation plan for the South
Creek -Pamlico River peninsula. The various Division of DEHNR are
very willing to assist you in this endeavor.
Please contact Ms. Melba McGee of my staff at 919-715-4194
who will be glad to coordinate efforts at our end.
Sincerely yours,
Jonathan B. Howes
pcs.ltr
CC: Melba McGee
Wayne Wright, US Army Corps of Engineers
Kristen Rowles, Pamlico -Tar River Foundation
Preston Howard
Roger Schecter
Frank McBride, WRC
Derb Carter, Southern Environmental Law Center
Charles Gardner

To:
�.c�r2 r C�.cl�c�s s 7rF2
Z.,AAl"
OF
Subjed /Dc s
KC.E4ED ,
RED... _ ..
tes
o.✓ V6,1/<Ico 4. "
A. Preston Howard, Jr., P.&, Director
AL
f5p—HNR
North Cantina OgIftenl of EoTbvameat, deWlb ead 19mm] Rueurces
PO BOX 29535, Raleigh, North Carolina 27620-0535 / Phone: [phone], E'I: 203 / &-Mall, PRIMNOEMMUMMUS

14
Phosphatse \�\
3101 GLENWOOD AVE., P.O. BOX 30321. RALEIGH, NC 27622.0321 TEL: [phone] FAX: [phone]
Thomas J. Regan, Jr.
, Executive Vice President
` March 26� 1997
Y [jam ii yy
Colonel Terry Youngbluth
District Engineer
U.S. Army Corps of Engineers L: ,^,R, - 7_L1,: ,ti �•._; .
Post Office Box 1890
Wilmington, North Carolina 28402
RE: PCS Phosphate Company, Inc. (Texasgulf Inc.) Mine Advance Permit
Dear Colonel Youngbluth;
PCS Phosphate Company, Inc. (PCS) received a copy of the letters to you from the Pamlico -
Tar River'Foundation (PTRF) and the Southern Environmental Law Center (SELL) dated January
20, 1997 regarding the PCS Permit Application. PCS believes the PTRF and SELC have attempted
to add certain facts to the administrative record which are inaccurate. These facts are related to: (1)
the availability and suitability of certain PCS land holdings south of the. Project Area for phosphate
mining, and (2) the current practicability of mining those land holdings.
PTRF contends, and SELC relies upon, "an initial survey" that shows that PCS "owns
approximately 11,000 acres overlying the phosphate deposit south of the project area." PTRF and
SELC then assert that this "southern reserve area consists mostly of uplands." PTRF and SELC
conclude that the Corps' Final Environmental Impact Statement (FEIS) did not demonstrate that an
alternative based upon continued miring in this area southwest of Aurora (characterized as a "no
action" alternative) was impractical. The Corps clearly considered such an alternative in Section
3.2.2 of the FEIS. Therefore, the complaint of PTRF and SELC is really a factual disagreement with
the Corps' opinion. However, the `faacts" PTRF and SELC rely upon to discredit the Corps' opinion
are inaccurate and distort the true situation.
PCS actually owns 9,984 acres south of the Project Area (PTRF's calculation included some
acreage within the Project Area), but only 4,786 of those acres are realistically available for miming
because: (1)122 acres lie within the City limits of the Town of Aurora, (2) 812 acres are isolated to
the west of Durham Creek, (3) 723 acres consist'of parcels isolated by ownership and wetlands along
the east side of Durham Creek with no parcel larger than 165 acres, (4) 1,842 acres are isolated to
the east of or are in the upper reaches of South Creek, and (5) 1,699 acres consist of parcels isolated
by ownership and wetlands along the west side of South Creek with no parcel larger than 225 acres.
Even the 4,786 acre area described as available is interspersed with 465 acres of uncontrolled
property which would have to be acquired to allow for the development of an effective nine plan.
Furthermore, the remaining 4,786 acres contain the upper reaches of two tributaries of South
Creek (Bloomfield Swamp Creek and Cypress Run) and one-third of this area is woodlands.
Although two-thirds of the area is in productive farmland use, at least 95% of the soils in this area

Colonel Terry Youngbluth
March 26, 1997
Page Two of Two
are hydric. Although PTRF and SELC reference the National Wetlands Inventory maps, they well
know that these same maps drastically underestimated the wetlands actually delineated in the Project
Area. Based upon our observations ind conversations with our wetlands consultants, PCS believes
that approximately 1,600 acres of the 4,786 could be delineated as wetlands under current Corps
guidance and the remainder ig'probably prior converted cropland.
PTRF and SELC also suggest consideration be given to mining a tract of land owned by
Reserveco, an Elf Aquitaine subsidiary, which is located south of the 4,786 acres. However, even
a cursory look at the Reserveco tract indicates that it is almost totally wetlands.
Even if one were to assume the Corps would issue a permit to mine the 4,786 acre block
(Aurora Southwest Area) and that PTRF would actually acquiesce to such a permit, the direct.
operational costs of mining this tract represent a staggering increase over the already economically
distressed Alternative E. There are four major reasons for this cost 'increase: (1) poorer ore quality,
(2) thinner ore thickness, (3) doubled ore transport distances, and (4) the need to open a new mine
pit because of the intervening homes, businesses, highway, rail lines and power lines. Our Mining
Planning Department compared the operational cost differential between Alternative E, the second
ten years of Alternative E, and the new mine. See enclosed Tables I and II which were prepared
using the same mineral resource parameters, mining cost factors, and 1991 dollars as are used in the
FEIS. Since PCS would mine the uplands in Alternative E first in either scenario, consideration of
the first ten years is really irrelevant. Even under the Wilmington District's expansive view of
economic practicability, an operational increase for the second ten years of $354.4 Million is
unreasonable. In addition to the direct economic detriment to PCS, the Corps needs to consider the
socioeconomic distress which seven farming families face by the loss of cropland they have been
farming for decades.
The other arguments raised by PTRF and SELC repeat earlier arguments which have already
been addressed in the FEIS.
Enclosures
1Ad;032597.06
pc: Derb Carter, Esquire (SELC)
4 tin Rowles (PTRF)
Stephen D. Benton
John Dorney
A. Preston Howard, Jr.
Brooke Lamson
Sincerely,
-PCS P OSPHA COMPANY, INC.
Thomas J. a Jr.
Executive Vice t
T. J. Wright
W. T. Cooper
W.-A. Schimming
P. J. Moffett
G. W. House
J. Hudgens
B. Bolick

TABLE I
Mineral Resource Parameters and Mining/Operational Factors
for Alternative E and Aurora Southwest Area
NCPC Tract
Parameter _ Alt. E _ (Alt. E 2nd_10 yrs. Z Aurora SW
Overburden depth 109 116 105
Ore grade (% P205) 14.8 15.2 12.0
Ore thickness (feet) 36 39 i 33.5
Area mined (acres) 4640 2050 3340
Tonnage per acre minedb 23.5 24.5 16.4
(thousand tons)
Overburden removed per year 40.0 38.4 58.4'2
(million BCY)
Ore transport distance 5.24 3.42 9.4
(average miles per year)
Years of Mining 20 10 10
Aurora Southwest Area averages (except years of mining); no defined mine plan
b Metric tons of phosphate concentrate (67 BPL phosphate rock) based on recovery rate
Includes 18,295,000 LCY rehandle of new pit development prestrip stockpiled
overburden (averaged over 10 years)
Attachment to letter from T. J. Regan, Jr. to Colonel Terry R. Youngbiuth (USAGE)
dated March 26, 1997

CfNrl®fN7'IAL
TABLE II
A summary of the increased costs of mining for 10 years in the
area southwest of Aurora versus the NCPC Tract (second 10 years
of Alternative E) is outlined below:
• Development Costs
• Additional Equipment (3rd BWE System, $ 30.5
Pumps, and Pipeline)
• Initial Pit Opening 13.5
• Major Utilities (Crossings or Relocations) ( 6.7)
and Property Acquisition
• Wetland Mitigation* --
• Major Equipment Moves 2.0
Sub -Total = $ 39.3
• operating Costs
• Overburden Removal $102.4
• Ore Mining 23.3
• Ore Pumping 115.4
• Sand Tailings Pumping 34.2
• Gypsum/Clay Blend Pumping 32-8
Sub -Total =
Total = $354.4
* Wetland mitigation costs for the area southwest of Aurora
have been estimated to be equivalent to those.mitigation
costs associated with Alternative E (NCPC Tract).
O _Indicates that overall costs for this line item are greater
for Alternative E (2nd 10 years) than for southwest of
Aurora.
Attachment to letter from T. J. Regan, Jr. to Colonel Terry R.
Youngbluth dated March 26, 1997.

Author: Charles Gardner at NROLROIP �~
Date: 2/23/97 7:37 PM LBY
Priority: Normal 241997Receipt RequestedTo: Preston Howard at Internet
CC: Melba McGee at NRDCS0IP
CC: Linda Rimer at NRDCSO1P
CC: Mell Nevils
CC: Tracy Davis
CC: [e-mail] at Internet
Subject: PCS Phosphate, Draft 401 Water Quality Certification
------------------------------------ Message Contents ------------_-----------_--------------
Preston, please pass this on to John Dorney as I do not have an e-mail
address for him.
The Division of Land Resources has reviewed the draft 401 Water
Quality Certification attached to John Dorney's memorandum of January
31, 1997. It is requested that the following change be made: Page 1,
paragraph 3, last sentence, delete "Sediment and Erosion control" and
replace with "Mining". (As the project is covered under the Mining
Act, it is exempt from the Sedimentation Pollution Control Act.) This
is really more of an editorial change than a substantive change.
We have no other comments. It will be our position, when the Mining
Permit is issued or revised, to make the conditions of the Mining
Permit that relate to water quality consistent with the requirements
of your division.
Thank you for the opportunity to review this draft. We would
appreciate your providing us with a signed copy of the certification
for our files when it is issued. Please let me know if you have any
questions.
Charles Gardner

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C� F F�
NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT,
HF1AL7'S, AND NATURAL RESOURCES
DIVISION OF LAND RESOURCES
LAND Q UALITY SECTION
P.O. BOX 27687
RALEIGH, NORTH CAROLINA 27611
TELEPHONE: [phone] FAX: (919.) 733 2876
FACSIMME MESSAGE
TO:
COWANY/DEPARMEA .-
PHONE NO.:
FAX No.:QRi9 _
FROM:
DATE:
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DATEr"
— — — —NUMBER=OFPAGES BEING SENT—.(INCLUDING_THIS PAGE):. o.6.
COMMENTS:
' •_ems'+�:i�'�.L:+��%'�.� -s„

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.. pECEWE
FEB 101997
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, M E M 0 RA. -=DLL
HEALTH, AND NATURAL RESOURCES
DIVISION OF LAND RESOURCES
TO:
`7
�7
4� � �
CHARLES H. GARDNER
I DIRECTOR
AND
STATE GEOLOGIST
DATE: Zj9r/f 7--
SUBJECT:
d, al..., q2_1 17 &4

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
Ja mes B. Hunt, Jr., G ove mor
Jonathan & Howes, Secretary
A. Preston Howard, Jr., P.f., Director
January
MEMO
A [4 J LOA
ICF1
31, 1997 RECEIVED
TO: Bill Schimming, PCS Phosphate
David Franklin, Corps of Engineers
Lee Pelej, US Environmental Protection Agency
Kristin Rowles, Pamlico -Tar River Foundation
Kevin Mooney, US Fish and Wildlife Service
Frank McBride, NC Wildlife Resources Commission
Steve Benton, Division of Coastal Management
Mike Street, NC Division of Marine Fisheries
Larry Hardy, National Marine Fisheries Service
Charles Gardner, Division of Land Resources
Melba McGee
FROM: John Dorn
RE: Draft 401 Water Quality ertification
WQC # 961120
Beaufort County
'FEB ; 37
DIV. LAINT ""-
Attached for your review is the draft 401 Water Quality
Certification for the PCS Phosphate mine expansion near Aurora.
Preston Howard has asked that this draft be sent to various
interested parties for their review and input before a final
decision is made regarding issuance. Please send any comments to
me by 17 February 1997. The dates on the Certification will have
to be adjusted to reflect this review time.
Thank you in.advance for your help. I can be reached at
919-733--1786 if you have any questions.
cc:- Jim Mulligan, DWQ Washington Regional Office
Deborah Sawyer, DWQ Washington Regional Office
Preston Howard
Steve Tedder
Jimmie Overton
pcs401.mem
P.O. Box 29535, Raleigh, North Carolina 27626-0535
Telephone [phone] FAX # [phone]
An Equal Opportunity Affirmwlve Aedon Employer 50% reeyeled110% pose consumer paper

State of North Carolina µ
Department of Environment,
Health and Natural Resources 4 •
Division of Water Quality a
James B. Hunt, Governor p � H N �
JaJonathan B. Howes,
s, Secretary
A. Preston Howard, Jr., P.S., Director
January 19, 1997
Mr. Thomas J. Regan, Jr. Book
Potash Corp. of Saskatchewan (PCS) Phosphate Co. F-I
P.O. Box 48
Aurora, NC 27806
Dear Mr. Regan, r
Re. Certification Pursuant to Section 401 of the Federal Clean Water Act,
Proposed expansion of PCS Phosphate mine
WQC Project #961120, COE #198800449
Beaufort County
Attached hereto is a copy of Certification No. 3092 issued to PCS Phosphate Company dated
15 January 1997.
If we can be of further assistance, do not hesitate to contact us.
Sincerely,
A. Preston Howard, Jr. P.E.
Attachments
961120.wgc
cc: Wilmington District Corps of Engineers
Corps of Engineers Washington Field Office
Washington DWQ Regional Office
Mr. John Dorney
Mr. John Parker, Division of Coastal Management
Central Files
David McNaught, Tar -Pamlico River Foundation
Melba McGee, EHNR
Frank McBride, WRC
Charles Gardner, DLR
Bruce Bolick, CZR
Roger Schecter, DCM
Division of Water Quality - Environmental Sciences Branch
Enviro. Sciences Branch. 4401 Reedv Creek Rd.. Raleiah. NC 27607 Telsohone 919-733-1786 FAX # [phone]

NORTH CAROLINA 401 WATER QUALITY CERTIFICATION
THIS CERTIFICATION is issued in conformity with the requirements of Section 401
Public Laws 92-500 and 95-217 of the United States and subject to the North Carolina Division of
Water Quality (DWQ) Regulations in 15 NCAC 2H, Section.0500 to Potash'Corp. of
Saskatchewan (PCS) Phosphate Co. resulting in 1,268 acres of wetland impact in Beaufort
County pursuant to a revised application filed on the 5th day of December of 1996 to expand an
existing open pit phosphate mine following the alignment of Alternative E as outlined in the
Environmental Impact Statement except as modified below.
The application provides adequate assurance that the discharge of fill material into the waters
of South Greek and its tributaries in conjunction with the proposed development will not result in
a violation of applicable- Water Quality Standards and discharge guidelines. Therefore, the State
of North Carolina certifies that this activity will not violate the applicable portions of Sections 301,
302, 303, 306, 307 of PL 92-500 and PL 95-217 if conducted in accordance with the application
and conditions hereinafter set forth.
This approval is only valid for the purpose and design that you submitted in your application,
as described in the Public Notice or as modified below. If you change your project, you must
notify us and you may be required to submit a revised application. If total wetland fills for this
project (now or in the future) exceed one acre, compensatory mitigation may be required as
described in 15A NCAC 2H .0506 (h) (6) and (7). For this approval to be valid, you must follow
the conditions listed below. In addition, you should get any other federal, state or local permits
before you go ahead with your project including (but not limited to) Sediment and Erosion
control, Coastal Stormwater, Non -discharge and Water Supply watershed regulations.
Condition(s) of Certification:
1. That the activity be conducted in such a manner as to prevent significant increase in
turbidity outside the area of construction or construction related discharge (50
NTUs in streams and rivers not designated as trout waters by DWQ; 25 NTUs in
all saltwater classes.
2. This certification shall expire on 14 January 2007 unless-PCS demonstrates to the
satisfaction of the Director of the Division of Water Quality that no mining
methodology is available and economically feasible which would reduce wetland
impacts. Should this demonstration be accepted by the Director of DWQ, then this
Certification shall expire on 14 January 201T.
3. Mining limits in blocks 19 and 20 shall be modified to the written satisfaction of
DWQ to further minimize disturbance of bottomland hardwood forests. This
proposed modification shall be submitted to DWQ before any wetland areas are.
cleared or filled within the boundaries of Alternative E.
4. DWQ shall be sent two copies of all annual monitoring reports for the mitigation
effort. If mitigation is not successful, additional mitigation will be required.
5. A stream monitoring plan for water quality, water quantity, and biology shall be
developed by PCS Phosphate and submitted to DWQ for written approval for
Huddles Cut which is a tributary of the Pamlico River and either Jacks Creek or.
Tooley's Creek which are tributaries of South Creek. This plan shall be designed
to identify any deleterious effect on riparian wetland function and aquatic life in
these streams and shall provide mechanisms to remedy these effects if any are
identified. This plan shall be submitted to DWQ before wetland areas are impacted
on this property.

violations -of any condition herein -set forth shall result in revocation of this Certification and
may result in criminal and/or civil penalties. This Certification shall become null and void unless
the above conditions are made conditions of the Federal 404 and/or coastal Area Management Act
Permit.
If this Certification is unacceptable to you have the right to an adjudicatory hearing upon
written request within sixty (60) days following receipt of this Certification. This request must be
in the forth of a written petition conforming to Chapter 150E of the North Carolina General
Statutes and filed with the Office of Administrative Hearings, P.O. Box 27447, Raleigh, N.C.
27611-7447. If modifications are made to an original Certification, you have the right to an
adjudicatory hearing on the modifications upon written request within sixty (60) days following
receipt of the Certification. Unless such demands are made, this Certification shall be final and
binding. `
This the 19th day of January; 1997
DIVISION OF WATER QUALITY
A. Preston Howard, Jr. P.E.
WQC #3092

Q
C�E.HNR
NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT,
HEALTH, AND NATURAL RESOURCES
DIVISION OF LAND RESOURCES
LAND QUALITY SECTION
P.O. BOX 27687
RALEIGH, NORTH CAROLINA 27611
TELEPHONE: (9I9) 733-4574 FAX: (9I9.) 733 2876
FACSIMILE MESSAGE
TO: 1r-
COMPANYIDEPARTMENT.• IC/ Q l5 406WR G� ,
PHONE NO.: _ q 11 _ _ 7i7i 0
FAX NO.: 6t11
FROM:
DATE.-'­"1 77ME. [ �d
NUMBER OF PAGES BEING SENT {INCLUDING THIS PAGE):
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1 City
INNIH

Explore two rooms of fossilized bones, teeth, shells,
and coral on display, Discover how geologic forces over
millions of years have created a large bed of fossils. See
the artist's image of life 5 and 15 million years ago
when vertebrates, shelled creatures, and marine life
swam in the Atlantic Ocean, which then covered what is
now Aurora. Smile as you have your picture taken in the
model of a giant shark'sjaw. Search for your own fossils
across the street from the museum. Answers to where,
when, how, and why are revealed in the' 2-minute
video presentation. Learn more about North Carolina's
history and resources. Create your own collections and
display of fossils (sharks' teeth and shells, etc.).
Will Aurora
be under
water again
in 1,000 years?

sing fossils from the PCS Phosphate
mining operation, the Aurora Fossil
Museum tells the story of the formation
of the Coastal Plain from the birth of
the Atlantic Ocean to the present,
In one of the museum's three
roams, visitors may observe
geological formations as
seen from the bottom of
a mine. Another of the
roams provides a view of
life in the ocean five and
fifteen miliion years ago, while _
r1
R
the third houses an exhibit of prehistoric man in
eastern North Carolina. A 12-minute video,
presented during tours of the museum, traces
the geological and paleontological history of the
area, beginning 22 million years ago, and
w looks at predictions that this region will
again be underwater 1,000 years
}., from now, After completing their
tour of the museum, visitors are
invited to sift through course
phosphate material and search
for fossils. Prehistoric sharks'teeth
are one of the favorite finds.

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Mining giant Strikes opposition (7/27/97, The N&O)
http://cgi.nando.net/plweb-csi/fastweb?ge..%20AM]%2019970725°1o3C%3Ddate%3C%3D 19970728
'A"EA MONSIEUR
Sunday
July 27, 1997
N.C. I NEXT STORY
RELATED: Mining,
prQessing of phosphate
Lock
Mining giant strikes opposition
Phosphate company's expansion bid raises concern for
wetlands
BY TERRY ALLEGOOD, staff writer
AURORA -- When a
rich lode of phosphate
ore was discovered deep
beneath the lowlands of
eastern Beaufort County
40 years ago, the rush
was on.
The discovery
spurred a land boom.
Mining companies F" Staff Photo by Chris Seward
bought up thousands of
acres of farm fields and A worker, lower left, is dwarfed by draglines
forests for the right to as high as multistory buildings at PCS
g Phosphate Co. in Aurora.
mine the grainy black
rock, highly prized for
making fertilizer. State and local governments, eager for jobs in a
poor fishing and farming region, welcomed construction of an open
pit mine and fertilizer -processing plant on the south shore of the
Pamlico River.
The reaction is different these days, as PCS Phosphate Co.
prepares to move its huge mining machines into 4,900 acres of
untapped lands over the next 20 years. The company, which bought
the mining and processing plants from Texasgulf Inc, in 1995,
would destroy 1,200 acres of wetlands to get the phosphate out of
the ground.
In the last 32 years, the companies have mined about 5,500
acres and developed a complex near Aurora that has become one of
the world's largest phosphate operations. By itself, the site makes
North Carolina the country's second-largest producer, behind
Florida.
Unlike those in Florida; where the phosphate is 3 to 12 feet
below the surface, the Beaufort County bed lies flat and deep -- at
least 100 feet down -- and some of the richest ore is found under
streams, marshes and lowlands. That's why PCS, which owns about
36,000 acres, wants to go right through the most environmentally
sensitive areas.
Environmental groups are fighting the proposal.
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"Our view is that the company should mine the areas that have
the least wetlands and least environmental impact first," said Derb
Carter, a lawyer for the Southern Environmental Law Center in
Chapel Hill. "The company wants to mine some of the most
sensitive wetlands that will have the most impact first."
Wetlands were generally considered wastelands in the past, and
they weren't even an issue when mining began. Protected by law
since 1974, wetlands are now described by scientists as critical
habitat for plants and animals and areas that improve water quality
by filtering out nutrients and sediment.
The dispute over future mining began nine years ago, when the
company began outlining to the Army Corps of Engineers the areas
it wanted to mine over the next 20 years. After six years of
reviewing various mining options, the corps has said it will
announce its decision on a permit soon, perhaps this week.
Carter said the law center will consider a legal challenge to a
permit if it is issued.
"It's a critically important decision," he said. "This project
would involve the largest single legally permitted wetland
destruction in the state."
Despite the lengthy review, Carter said, the corps and company
have not adequately addressed two key concerns:
❑ That mining wetlands shouldn't even be an option because the
company has reserves in at least 10,000 acres on higher ground;
❑ And that by heading north toward the Pamlico instead of south
to the higher ground, the company will want to mine even more
wetlands after the land covered in the permit is mined.
The company dismisses upland mining as too expensive and
impractical because the ore is deeper underground and farther from
the processing plant. As for future mining, PCS executive vice
president Tom Regan Jr. makes it clear the preferred route is
through the streams and marshes along South Creek.
He said the company's wetlands mitigation projects, which now
involve about 2,420 acres, can offset the loss of natural areas.
Giant operation
The scope of the PCS complex, located 120 miles east of
Raleigh, is massive. Draglines with booms that reach 21 stories
rumble, claw and dump tons of soil from a pit that resembles a
moonscape. The company's electric bill alone totals $2.5 mullion a
month, making it Carolina Power and Light Co.'s largest customer.
Potash Corporation of Saskatchewan Phosphate Co. bought the
place from the French company Elf Aquitaine for $820 million in
1995.
Considering the stringent laws protecting wetlands, only a giant
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such as PCS would consider wiping out whole chunks of them. It
originally proposed a route that would destroy about 3,200 acres of
wetlands, but modified its request to the corps after encountering
stringent opposition.
Regan said the company would have enough phosphate reserves
in upland areas to mine for about six years if it doesn't receive the
corps permit.
"During that five- or six -year period, we would continue our
efforts to secure permits in order to continue our mining
operation," he said. "Without our mining operation, there is a
serious question as to the viability of the rest of the facility."
In addition to surface lands, the company has Ieases with the
state for mineral rights to 10,000 acres under the Pamlico River
and Durham Creek. Regan said the company has no plans to mine
the waterways but it is still holding on to the rights.
"Fifty or 75 years from now, when the phosphate reserves in
North America are depleted, with the continued advancement of
technology it may be possible to recover those reserves," he said.
"But obviously that's going to be decided by a regulatory and
permitting process that will occur way into the future."
There were few restraints when Texasgulf Inc., the developer of
the mining complex, began operating in the early 1960s.
To reach ore below ground, the company was allowed to
strip-mine the surface with dredges, huge bucketwheel excavators
and draglines with scoops as big as a dump truck. Because
groundwater is only a few feet below the surface, the company
must pump out an average of 57 million gallons a day to keep the
pit dry.
Fresh water loaded with nutrients was simply discharged into
the brackish water of the Pamlico River until 1992, when the
company began a wastewater recycling system. On -site streams
were obliterated or rechanneled around the pit.
Changes in terrain
Mining gave the flat, featureless terrain new highs and lows -- a
200-acre crater more than 140 feet deep and gray mounds of
gypsum 125 feet tall, a byproduct of ore processing. The plant site
-- a series of milling and chemical processing plants that include
two of the world's largest sulfuric acid plants -- looks like
something that might be more at home in northern New Jersey than
on the banks of the wide, flat Pamlico River.
It may riot be pretty, but it is a phosphate industry powerhouse.
The single site produces about 5.5 million tons of phosphate
concentrate a year; its products sold for $431 million in 1996.
PCS is an economic power at home, too. With 600 employees
in the mine and 1,159 overall, the company is one of the largest
employers in the area, and its yearly tax bill of $2.7 million
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accounts for about a third of Beaufort County's property taxes.
Workers commute by state ferry across the Pamlico River and from
surrounding communities up to 40 or 50 miles away for jobs that in
many cases pay more than $40,000 a year.
Aurora native Dalton Bennett, 38, said phosphate mining
allowed him to stay in his hometown rather than moving away for a
decent job. He started working for Texasgulf 13 years ago after
working in construction and, now works in a PCS sulfuric acid
plant.
"It would be hard to find a job here," he said. "Farming is
basically about gone."
Bennett said any harm to the environment from mining has been
more than offset by the boost to the economy and by the company's
land reclamation projects. He said there is no reason for the Corps
of Engineers to deny the company a permit to keep going.
Frank B. "Bo" Lewis, executive director of the Greater
Washington Chamber of Commerce, said that the company has
been a good neighbor and that the environmental problems related
to air and water discharges had been corrected. Saying the
phosphate operation was "a clean industry," he said the water now
discharged into the Pamlico was pure enough to drink.
"It would be a travesty if that permit is denied," he said.
Not everyone agrees. Environmentalists and commercial
fishermen blame the phosphate plant for pollution that has led to
fish kills and water -quality problems in the river.
Kristin Rowles, executive director of the Pamlico -Tar River
Foundation, a conservation organization in Washington, N.C., said
the company and Corps of Engineers arbitrarily selected areas for
future mining that left out substantial upland sites. As a result, she
said, the foundation's concerns are the same as when the review
started.
"What it comes down to is the whole process has not looked at
the cumulative impacts of mining," she said.
Checkered past
Carter of the Southern Environmental Law Center said the
company's history with environmental regulations is one reason for
concern about the scope of the proposed mining. The company has
been fined and criticized for violations of state air and water
regulations, including a civil assessment of $5.7 million in 1986 for
air -quality violations. The company eventually paid about $1
million in a settlement.
"It's a major project occurring on the banks of one of the most
environmentally stressed rivers in the state," he said. "The Pamlico
River, along with the Neuse, has been experiencing significant
water -quality problems related to land -use and runoff and this
project is occurring on.the banks of the river, involving its
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tributaries."
Longtime critic Etles Henries, operator of a crab processing
business on South Creek, also said nothing has happened to change
his mind that phosphate mining contributed to the decline of
commercial fishing on the river. Permitting further destruction of
wetlands, he said, "would be the worst thing that could happen to
the seafood industry."
Henries, who was sorting baskets of blue crabs in his creekside
plant, said he has observed firsthand the way natural marshes filter
runoff and how they serve as nursery areas for tiny fish and crabs.
He expressed doubt that artificial systems would work as well.
"Are they going to replace active marsh or are they going to
close up a ditch in a field and say that's wetlands?" he asked.
Henries said water -quality problems in the Pamlico haven't gone
away, but attention has shifted to other places, including the Neuse
River. Further, he said, the public attention has been on pollution
from the hog industry instead of the phosphate industry.
"I think the best thing that happened to PCS is hog farms," he
said.
The phosphate plant dominates the geographic and
environmental landscape in Aurora, which itself sits atop the
phosphate deposit. The tall draglines loom behind homes along
N.C. 33 just out of town, and many of the town's 700 residents
work at the plant or in businesses that benefit from the $120 million
it spends each year for goods and services.
Theresa Cavanaugh, a clerk at a convenience store in town, was
waiting for the plant's afternoon shift change to bring a stream of
customers. She said she didn't know who was right about the
company's environmental impact, but the plant's economic effect is
clear.
"If that place was to shut down, this town would dry up," she
said.
Jerry Allegood can be reached at [phone] or
jeMaP,,nando.com
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TM
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July 27, 1997
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MAIN STORY: Minine
giant strikes opposition
RELATED: Mining,
processing of phosphate
rock
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Mining, processing of phosphate rock
Phosphate rock is a source for phosphorous, an essential
element for plants and animals. Plants obtain phosphorous from the
soil and animals obtain it from plants or other animals. Deposits of
phosphate rock were formed on ancient sea beds as minerals drifted
to the bottom and were covered by clay and sand.
Beaufort County lies atop a bed of phosphate an average of 53
feet deep, ranging from 6 to 7 feet in the western part of the county
to 140 feet in the southeast corner. However, the thicker deposits
are buried deeper.
Here is how PCS mines and processes the mineral:
In PCS' reserves, the ore lies nearly 100 feet below the surface,
A bucketwheel excavator takes off 40 feet of soil on top, called
overburden, and electrical draglines remove the remaining 60 feet
of overburden and mine the 35 to 40 feet of ore.
The ore is dumped into a sump. There it is hosed down to form
a slurry of sand and water that is pumped to a mill to be washed
and screened. Quartz sand is then separated from the
phosphate -rich ore by floating or by burning in a process called
calcining. Calcined phosphate rock is used by PCS or its customers
to produce phosphoric acid.
The production of fertilizer begins by converting liquid sulfur
into sulfuric acid. Liquid sulfur is shipped to Aurora by rail or
barges and made into sulfuric acid on site. It is combined with
processed phosphate rock and forms phosphoric acid and gypsum
as a byproduct. Phosphoric acid is used to produce dry fertilizer.
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' .,
no-P�r 2United States Department of the Interior
5-
FISH AND WILDLIFE SERVICE
Raleigh Field Office
Post Office Box 33726
Raleigh, North Carolina 27636.3726
N 0 U 10 1997
October 29, 1997
Colonel Terry. R. Youngbluth
District Engineer, Wilmington District
U.S. Army Corps of Engineers
Post Office Box 1890
Wilmington, North Carolina 28402-1890
Attention: David Franklin
Dear Colonel Youngbluth:--
IEC1E!1 V E
Nov 0 5 1997
CENED
4i�v 3 '97
The U.S. Fish and Wildlife Service (Service) has reviewed the Scope
of Work (SOW) for a study of cadmium (Cd) and other metals proposed
by permittee Potash Corporation of Saskatchewan (PCS) Phosphate,
Incorporated, at their Aurora, North Carolina, processing plant.
The SOW was submitted to address a condition in Clean Water Act
section 404 permit, Action I.D. No. 198800449, issued by the
District Engineer and a section 401 permit issued by the North
Carolina Division of Water Quality. The Cd study was requested by
several agencies due to concerns over demonstrated bioaccumulation
and the potential for adverse biological effects.
The Service has concerns which have not been relieved by the SOW.
The SOW has been circulated for review along with a status report
indicating that much of the proposed work has already been
conducted. 'Yet the results of the presumably already completed
work were not supplied for evaluation. Furthermore, the SOW
appears to have been developed without clear objectives or goals,
and without supporting documentation for the protocols used.
Additionally, it appears that the study was implemented prior to
conducting literature reviews to determine the most appropriate
methodologies or the current state of knowledge about the subject.
The Cd exposure/bioaccumulation studies are reasonable and prudent
resource protection measures. The SOW, potentially being a stand-
alone document, ought to provide readers with that rationale. So
that the. studies and results are kept in perspective, a more
thorough and explanatory rationale provided by the agencies should
be included in the SOW and any subsequent reports or summaries.
W��Sr7�g7

2'
We are very concerned that implementation of the SOW predated
development of a comprehensive literature review. In general,
scientifically sound studies are based on the existing record of
accumulated evidence and replicable sampling and analyses
protocols. The SOW contains many references to as yet incomplete
literature reviews. Literature reviews should constitute the
intellectual foundation and prerequisite for hypothesis formation,
study design, and methodology selection.
A thorough review of Cd environmental fates and affects, agency
reports, sampling protocols, and analysis techniques must be
conducted and reported independently of the already implemented
study components. The review should be focused in a manner that
guides reviewers to select the most effective and appropriate
sample sites, indicator organisms and tissues, and analyses. The
review should formulate questions and hypotheses, data collection
objectives, and criteria or thresholds for additional or more
detailed studies. Such an approach minimizes costs, time and
effort. It prioritizes study components that offer the maximum
information and decision -making, criteria at the earliest stages of
an investigation. We recommend that the literature review be
conducted and used as the foundation for a modified SOW.
The SOW does not clearly state the issues to be addressed. it
generally references previous agency comments on Cd concerns, but
a scope should specify what particular issues it aims to address
(e.g., Cd enrichment; bioaccumulation; adverse effects from
bioaccumulated cadmium, etc) and should preferably specify what
hypotheses are going to be tested to address the concerns (e.g., is
Cd enriched in local soils, sediment and biota; is Cd accumulating
at levels deleterious to small mammals or migratory birds; are Cd-
associated adverse effects apparent at the site?). The approach to
answering these questions would differ markedly, so in general,
SOWS intended to address concerns of several agencies should
specify intended objectives. The Study Team referenced in the SOW
may have done this, but if so, no supporting evidence has been
presented by the permittee. An effective review of the scope is
not possible until the targets of the assessment are specified.
The SOW lacks specificity on'several key components:
o The analytical methods are not specified in any section. A
SOW should include this information, particularly the sample
digestion protocols (for example, a complete strong acid
digestion would yield significantly different results from
analyses employing weak acid digestion -- the SOW does not
address the issue), lower limits of quantitation for each
medium, and the quality assurance and 'control (QA/QC) measures.
_..
,employed(numberot_ blanks, spikes, duplicates, and
analyses of standard reference material along with pre -defined

w
3
levels of tolerance for method precision and accuracy). A
description of the analytical methods and QA/QC performance
will be essential in assessing the utility of data already
collected. If these details are in a separate sampling and
analysis plan, that plan should be circulated for review
along with the SOW and any results available thus far.
o An additional concern for the surface water analyses (Section
II. B.) is the lack of specificity for whether total or
dissolved metals will be assessed. Both measures are
important and should be included in the assessment.
o An additional concern for sediment sampling (Section III. B.
1.) is absence of reference to supporting information on the
sample sites and actual samples. The greatest sediment
contamination will occur in depositional areas adjacent and
down -gradient of the source. Depositional areas should be
targeted for sediment collection. Interpretation of sediment
chemistry data is hindered if information on physical
parameters of the collected samples, particularly particle
size, total organic carbon (TOC) content, and acid volatile
sulfide content (AVS) are absent. Sediments are
heterogeneous, and factors such as particle size and TOC
greatly influence contaminant accumulation. The physical
parameters mentioned here should be analyzed for all collected
sediments.
Section IV. discusses plant collection and analyses. Substantial
data on Cd accumulation in local vegetation already exists. A
summary of the existing information may indicate that additional
analyses are unnecessary. The Service is not seeking additional
analyses of plant material at this time.
All sections on biota sampling lack detail on the ages of organisms
to be targeted (or size ranges). Since Cd bioaccumulates, age
should be a component of study design for.comparable results among
stations and to have knowledge of the duration of exposure at the
sites.
The utility of the planned fish sampling (Section V.A.) is
questionable. First, the species selected are highly migratory
(i.e., they do not lend themselves to sampling aimed at delineating
extent of local contamination / accumulation). Second, whole -
fish analyses may mask accumulation in target organs, such as Jiver
and kidney (i.e., whole -fish sampling will not yield significant
information on Cd effects to the fish). Without the study
objective defined, it is not possible to suggest the preferred
species or analytical approach.

4
Inter -species composites of aquatic invertebrates (Section V.B.)
should be avoided; samples composited in this fashion do not allow
among -site comparisons. Adequate reconnaissance of the sites
should identify organisms present in suitable abundance to complete
the assessment without resorting to composites. Rangia clams
should be considered in the benthic macroinvertebrate monitoring.
They are relatively abundant in the area and there are a lot of
comparison data available for this species.
The species of turtles and their target organs for analyses are not
specified (Section V.C.); this information is important given the
dietary differences among species. If the turtle data are deemed
necessary, more than one individual should be collected at each
site to ensure representative samples.
Terrestrial invertebrates are not a part of
they should be (Section VI.). The Service's
assessment indicated that terrestrial
earthworms) may be a significant route of
mammals and migratory birds. The SOW should
terrestrial invertebrate sample collection
spanning the gradient of soil Cd levels.
site -specific bioaccumulation potential to
the current SOW, but
preliminary draft risk
invertebrates (e.g.,
Cd exposure to small
be amended to include
and analyses at sites
Such data would allow
ie assessed as well as
lend support to terrestrial risk assessments.
The terrestrial vertebrate sampling (Section V.B.) should include
insectivorous or vermivorous birds (e.g., American robin or
woodcock). The Service's preliminary draft risk assessment
indicated that these biota may be at risk from site contaminants.
The birds currently listed are predominantly herbivorous to
omnivorous and do not have a significant, long-term reliance on
terrestrial invertebrates as forage.
Sampling of terrestrial vertebrates would benefit by adding a
component to address Cd's adverse effects on these organisms.
Ultrastructural damage to the liver and kidney have been
demonstrated from Cd in experimental exposure of small mammals and
birds. Properly preserved tissues from the small mammal and avian
sampling could be processed for histopathological examination so
that Cd levels measured -in kidney and liver could be evaluated with
the ancillary knowledge as to whether the predicted adverse impacts
were in fact present. Since the logicists of specimen collection
are the major component of vertebrate sampling, the additional
information gained by the histopathology would be a good
investment.
A more focused SOW is possible to address concerns raised by the
Service at equal.or lesser level of effort than that proposed here.,
More attention to problem formulation, review of existing
literature (to guide selection of key species; define toxicological-• _

5
endpoints and define concentrations which would trigger additional
actions), and development of assessment endpoints should have
proceeded the measurement endpoints presented in the scope.
We appreciate this opportunity to comment on the SOW. 1t is not
fully satisfactory to the Service, and needs revision. Please call
Kevin Moody or Tom Augspurger of my staff at [phone]
extensions 19 and 21, respectively; with any questions or comments.
Sincerely,
ah n M. He ner
Field Supervisor
cc:
Pamlico -Tar River Foundation, Washington, NC (Kristen Rowles)
DCM, Raleigh, NC (John Parker)
DEH, Raleigh, NC (Linda Sewall)
DLR, Raleigh, NC (Charles Gardner)
DMF, Washington, NC (Mike Street)
DWQ, Raleigh, NC (John Dorney)
WRC, Raleigh, NC (Frank McBride)
EPA, Wetlands Regulatory Branch, Atlanta, GA (Thomas Welborn)
NMFS, Beaufort, NC (Larry Hardy)
FWS/R4:KMoody:KM:10/24/97:919/856-4520 extension 19:\pcscdsow.wpd

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
October 13, 1997
Chi
001 10
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I D FE N! F=1
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William A. Schimming 22 �
Director, Environmental Affairs
PCS Phosphate
3101 Glenwood Ave.
Raleigh, NC 27622-0321 f��`
Re: PCS Phosphate Company, Inc.
Department of the Army Permit No. 198800449
Cadmium Study Program
Dear Mr. Schimming:
Per your request, my staff have reviewed the scope of work for the Cadmium and
Other Metals Study dated September 23, 1997. As you know, we have made comments on
the need for a cadmium study in the past, specifically noting that our research indicates that
Southeastern estuaries are high in cadmium. We support the study if the data collected will
be used to characterize whether PCS is adding cadmium and other metals to the system in a
way that is detrimental to the ecosystem.
We have the following comments:
• Surface water samples should be taken at all aquatic organism sampling sites.
• No details were provided on the actual analytical methodologies to be used. We
recommend the use of EPA approved methods and, for surface water samples, the use
of clean techniques for sampling and analyzing metals. These clean techniques may be
as simple as metal -free sampling equipment and reagents. These techniques are
necessary to reach the lower detection levels required for ambient water sampling.
• The review of existing surface water quality data should take into consideration the
possibility of contamination especially for metals such as copper and zinc which are
ubiquitous. Historic data, for the most part, was not collected using clean
methodologies.
• We recommend that literature pertinent to vegetative sampling be reviewed to determine
if separating the seeds from the vegetative portions of the plants is necessary. Due to
their lipid and protein content, seeds may accumulate more metals than other portions of
the vegetation. This information may be useful in determining if the animals tested are
truly representative of potentially impacted species.
• We recommend that a control/comparison site well away from the study area, perhaps
in the Pungo or Neuse River systems be added to the study. Such a site would give a
better idea of metal concentrations outside the area of PCS influence.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

� � 1
William Schimming
PCs P1josphate Cadmitan Study
October 13, 1997
Page 2
• As I noted earlier, DWQ has pointed out that high cadmium sediment concentrations
have been documented in -southeastern estuaries. A review of more recent literature
should be conducted.
If you have any questions regarding our comments, then please contact Dianne Reid at
[phone] extension 568..
Sincerely,
A. Preston Howard, Jr., P.E.
cc: Greg Thorpe
John Dorney
tCharles Gardner, Division of Land Resources
David Franklin, Wilmington District Corps of Engineers

RECEIVED
DEPARTMENT OF THE ARMY OCT b '97
WILMINGTON DISTRICT, CORPS OF ENGINEERS
P.O. BOX
wiLMiruGrnrv, rvoRrH c r a �c�r �4 n /] CKY LARD RES.
IN REPLY REFER TO October 2,
o�T 0 71997
Regulatory Branch
Action ID. 198800449 PCS Cadmium Study
Ms. Melba McGee
Department of Environment, and
Natural Resources
14th Floor --Archdale Building
512 N. Salisbury Street
Raleigh, North Carolina 27611-7687
Dear Ms. McGee:
di��.�.�
r�_; I<
7
On September 29, 1997, we received the Scope of Work for a study of cadmium and other
metals proposed to be performed at the PCS Phosphate, Inc. reclamation areas, Aurora, North
Carolina. This submittal was also provided to Mr. Preston Howard, North Carolina Division of
Water Quality (DWQ) and Mr. Charles Gardner, North Carolina Division of Land Resources
(DLR). The study is intended to satisfy a special condition requirement of the Section 404
permit recently issued by the Corps of Engineers' to PCS Phosphate, a condition of the DWQ
401 water quality certificate, and requirements yet to be established by the DLR.
The scope of work is initially being coordinated through this office with Federal and State
resource agencies that have an interest in this issue. All comments provided to us will be
coordinated with DWQ and DLR to consolidate a response to PCS. We would appreciate
receiving any comments you may have on the proposed scope of work by October 27, 1997.
If you have questions regarding this matter, contact Mr. David Franklin at telephone
[phone].
•,
Sincerely,
G. Wayne Wright
Chief, Regulatory Branch
Enclosure

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-2-
Copy furnished with enclosure:
Ms, Kristen Rowles
Pamlico -Tar River Foundation
Post Office Box 1854
Washington, North Carolina 27889
Copy furnished without enclosure:
Mr. John Dorney
Division of Water Quality
DENR
4401 Reedy Creek Road
Raleigh, North Carolina 27607
Mr. A. Preston Howard, Jr.
Division of Water Quality
DENR
9th Floor --Archdale Building
512 N, Salisbury Street
Raleigh, North Carolina 27626-0535
Mr. Charles H. Gardner
Division of Land Resources
DENR
th Floor --Archdale Building
512 N. Salisbury Street
Raleigh, North Carolina 27611-7687
Mr. William A. Schimming
PCS Phosphate
Post Office Box 30321
Raleigh, North Carolina 27622-0321

-3-
Same letter sent with enclosure:
Mr. Frank McBride
North Carolina Wildlife Resources
Commission
1142 I-85 Service Road
Creedmoor, North Carolina 27522
Mr. William Wescott
North Carolina Wildlife Resources
Commission
146 Chesterfield Drive
Washington, North Carolina 27889
Mr. Lee Pelej
Wetlands Section -Region 4
U.S. Environmental Protection Agency
61 Forsyth Street
Atlanta, Georgia 30303
Mr. John Hefner
U.S Fish and Wildlife Service
Post Office Box 33726
Raleigh, North Carolina 27636-3726
Mr. Larry Hardy
National Marine Fisheries Service
Pivers Island
Beaufort, North Carolina 28516
Mr. Stevc Benton
N.C. Division of Coastal Management
2728 Capital Blvd.
Parker Lincoln Building
Raleigh, North Carolina 27604
Ms. Linda Sewall
Environmental Health
2728 Capital Blvd.
Parker Lincoln Building
Raleigh, North Carolina 27604
Mr. Jim Mulligan
Washington Regional Office
Box 2188
Washington, North Carolina 27609
Ms. Melba McGee
Department of Environment, and
Natural Resources
14th Floor --Archdale Building
512 N. Salisbury Street
Raleigh, North Carolina 27611-7687

i
PCs
Phosphate
3101 GLENWOOD AVE., P,O. BOX 30321. RALEIGH, NG 27622.0321 TEL: [phone] FAX: [phone]
September 23, 1997
Mr. David Franklin
Regulatory Branch
Department of the Army
Wilmington District Corps of Engineers
P. O. Box 1890
Wilmington, N.C. 28402-1890
Mr, Charles H. Gardner, P.G., P.E.
Director and State Geologist
Division of Land Resources
DEHNR
P. O. Box 27687
Raleigh, N.C. 27611-7687
Mr. A. Preston Howard, Jr., P.E.
Director
Division of Water Quality
DEHNR
P. O. Box 29535
Raleigh, N.C. 27626-0535
Re: PCS Phosphate Company, Inc.
Department of the Army Permit No. 198800449
Cadmium Study Program
Gentlemen:
BSI 5 '97
Special Condition No. 2 of the captioned Permit requires that PCS Phosphate Company, Inc.
(PCS Phosphate) within six months of issuance, "develop and implement cadmium
contamination studies and monitoring, subject to approval by the USACE, in consultation with
the North Carolina Division of Water Quality, and USEPA with regard to water quality issues,
and in consultation with the North Carolina Wildlife Resources Commission, and USFWS with
regard to issues related to uptake by plant species, and ultimate consumption by foraging
wildlife".
PCS engaged CZR, Incorporated earlier this year to develop a cadmium study program.
Preliminary work has begun under this program (See Attachment 1 - September 10, 1997 Status
Report by CZR, Inc.).
As we have discussed by telephone during the past week, PCS Phosphate would appreciate your
review of its Cadmium Study Program (four copies to each enclosed) in connection with the
previously stated Permit requirement. It is my understanding from our conversations that David
Franklin will provide copies to all interested regulatory agencies, state and federal, except for
DWQ and DLR. If additional copies are required, please advise.

PCS Phosphate Company, Inc.
Department of the Army Permit No. 198800449
Cadmium Study Program
Page 2
September 23, 1997
PCS Phosphate appreciates your willingness to review and comment on its Cadmium Study
Program. Please advise if I can assist you further.
Sincerely,
William A. Schimming
Director, Environmental Affairs
WAS/jss
Encs.

ATTACHMENT 1
STATUS REPORT ON THE CADMIUM AND OTHER METALS STUDY
ON AND ADJACENT TO PCS PHOSPHATE RECLAMATION AREAS
10 September 1997
• In late May 1997, CZR Incorporated (CZR) and PCS Phosphate Company (PCS) personnel
collected three samples each of potential sources of metals including clays, gypsum, sand
tailings, bucket wheel spoil, and blend. Dr. John Trefry of the Florida Institute of
Technology (FIT) analyzed the samples for a wide range of metals.
• In July 1997, CZR biologists and Dr. Terry Logan of Ohio State University (OSUI) collected
soil samples from R-1, R-2, Porter Creek -North wetland reclamation site, Charles Tract clay
pond 1, Charles Tract clay pond 4B, and the Archbell/Kugler Tract control site. The samples
are being analyzed by Dr. Logan at OSU for a wide range of metals.
• In August 1997, Dr. Trefry's field personnel from FIT and CZR biologists collected water
and sediment samples from 18 locations (six on or adjacent to the reclamation areas, six on
or adjacent to the Charles Tract clay pond complex, and six control or comparison sites).
These samples are being analyzed (water samples for four metals and sediment samples for
six metals) at FIT.
• In mid -August 1997, Dr. Trefry and PCS personnel sampled groundwater from two wells at
the reclamation areas. In late August, three additional wells were installed (two on the
Charles Tract and one on the Archbell/Kugler Tract) and were sampled by PCS personnel
in September. The groundwater samples are being analyzed by FIT for four metals.
• CZR biologists conducted a reconnaissance in July 1997 of areas to be sampled for plants.
The plant samples were collected from six sites in early September and sent to Ohio State
University for analysis of cadmium.
• CZR biologists will begin sampling of aquatic and terrestrial animals (including
invertebrates) in mid -September and into October.
CPI! 1745,46

SCOPE -OF -WORTS FOR THE CADMIUM AND OTHER METALS STUDY
ON AND ADJACENT TO PCS PHOSPHATE RECLAMATION AREAS
(R-1, R-2, R-3, AND THE CHARLES TRACT)
by
CZR Incorporated, Wilmington, North Carolina
Dr. Terry Logan, Columbus, Ohio
Dr. John Trefry, Melbourne, Florida
The following scope of work outlines the study procedures to gather data to answer the comments,
questions, or concerns (regarding cadmium and other potential metal contaminants) posed by various
agencies and environmental groups commenting on the EIS and permit application. The pertinent
comments were summarized previously by CZR and distributed to the study team. This scope of work
outlines specifically what will be done, where, and by whom. It follows the input from general
discussions from the study team's on -site meeting in Aurora on 21 March 1997 and from subsequent
telephone conversations and comments from study team members. A schedule and a cost estimate
have also been prepared.
I. SOURCES OF METALS
The first step in the cadmium and other heavy metals study on and adjacent to the PCS Phosphate
reclamation areas will be to evaluate the potential sources of metal contaminants from PCS Phosphate
reclamation areas. This will include scans for a wide range of metals for the following PCS source
materials: t
1) Clays
2) Gypsum
3) Sand tailings
4) Bucket wheel spoil
5) Blend
Three separate samples of each material type will be collected by CZR and PCS environmental and
reclamation personnel in late May 1997, and will be shipped to Dr. Trefry at the Florida Institute of
Technology (FIT) for analysis. The analyses will be completed in June 1997, and presented in a brief
study team report.
II. WATER
A. Review of Existing[?ata
The study team will review and summarize existing metals data for receiving surface waters
at outlet sources and directly adjacent areas. For R-1 through R-3 (Figure 1), this would be primarily
in the Pamlico River and also in Porter Creek and Durham Creek. For the Charles Tract (Figure 2), this
would involve Short Creek, Long Creek, South Creek, Flannigan Gut, and Bond Creek. The team will
also review metals data for the Charles Tract clay ponds and for the Porter Creek Wetland Reclamation
Area ponds. CZR, with assistance from PCS environmental personnel, will be responsible for collecting
and organizing the available on -site data and forwarding it to Dr. Trefry. Dr. Trefry will review pertinent
supporting literature material along with the on -site data, and will prepare a brief summary of the
information. Dr. Logan will provide review and analysis assistance.

Q 3000 6000
SCALE IN :ECT
FIGURE 1. PCS PHOSPHATE COMPANY, INC.
RECLAMATION! AREAS R-1 THRU R-5

DRAWN
S.C. PASCNALL
CHECKED
APPROVED
APPROVED
PCS iR�
Phosphate AURORA DIVISION
DRAWINC TITLE
CHARLES TRACT CLAY PONDS AND NPOES•PERMITTEO
OUTFALL LOCATIONS I
S
'rrES
ppfranL
�INEERING DATE;
JOB No. r0/J/95
SCALE:
. J' 2.500'
ORAWNC No.
AOC- 000- 070
M. l Mr. n

• M.
'Ilan � •l ;I 311M MIMMMIAA•
Dr. Trefry's field personnel, assisted by CZR personnel, will collect the surface water samples
from selected areas on or adjacent to the PCS reclamation areas (Figure 3). Samples will be collected
in August 1997. Analyses will be done by Dr. Trefry's laboratory at FIT. The samples will be analyzed
for 1) cadmium, 2) arsenic, 31 total chromium, and 41 zinc. Based on the scans done on the source
materials under Section I above and on the review of existing data, other metals may be included in
the analyses.
The areas to be sampled are as follows:
i
• Below the spillway draining from R-1
• In the canal draining from R-1 to outfall 007
+ Durham Creek at EIS sample station 42
• Porter Creek (adjacent to R-1) at EIS sample station 47
• In the pond at Porter Creek North wetland reclamation site
• In the 101 outfall canal below the R-2 discharge point
Sites On or Adiacent to the Charles Tract
• At EIS sample station 16 in Short Creek
• At EIS sample station 18 in bong Creek
• In Flannigan Gut near outfall 021 -
+ At EIS sample station 19 in Bond Creek
• Inside clay pond 5A
• At EIS sample station 23 in South Creek
• At EIS sample station 21 in Bond Creek
• Pamlico River about 1 mile downstream from Indian Island
• Brickyard pond on Archbell/Kugler Tract
+ Bath Creek adjacent to Archbell/Kugler Tract
• Pamlico River adjacent to Archbell/Kugler Tract
• Duck Creek adjacent to Archbell/Kugler Tract
.� ,.• .A• ..A.,11 : :IA•
Dr. Trefry's field personnel, assisted by CZR andlor PCS personnel, will collect groundwater
samples from selected existing well sites on or adjacent to the PCS reclamation areas (Figure 4).
Samples will be collected in August 1997. Analyses will be done by Dr. Trefry's laboratory at FIT. The
samples will be analyzed for 11 cadmium, 21 arsenic, 3) total chromium, and 4? zinc. Based on the
scans done under I. above and on the review of existing metals data, other metals may be included in
the analyses.
4

DUCK
CREEK
BATH
• • CREEK
PAMLICO RIVER
u' DURHAM • •
CREEK
•
PORTER •
CREEK
1NOIAN
ISLAND
5OUTH
CREEK •
LONG •
* CREEK
SHORT
CREEK MUDDY
0 9000 18000
• BOND CREEK
CREEK
SCALE IN FM
• SAMPLE SITE
FIGURE 3. WATER AND SEDIMENT SAMPLING SITES

DUCK
CREEK
� BATH
CREEK
PAMLICO RIVER
ct DURHAM ® GWM-2B
CREEK
PORTER
CREEK ® GWM—aB
INDIAN
ISLAND
SOUTH
CREEK
- LONG
CREEK
SHORT
CREEK ® BOND CREEK ® MUDDY
0 9000 18000 '
LITTLE CREEK
SCALE M iE[T CREEK
® SAMPLE SrrE
FIGURE 4. GROUNDWATER SAMPLING SITES

The following well sites will be sampled:
• GWM-2B
• GWM-4B
No existing surficial aquifer wells are known on the Charles Tract. To sample groundwater,
two wells will be installed. One on the east side and one on the west side of the Charles Tract.
No existing surficial aquifer wells are known on the Archbell{Kugler control site or other suitable
area. To sample groundwater, one well will be installed in a suitable control site.
III. SOILS/SEDIMENTS
The study team will review and summarize existing metals data for the RCS reclamation sites
and adjacent areas and for pertinent comparison sites. This will be coordinated by CZR with input and
assistance from Dr, Logan, Dr. Trefry, and PCS Phosphate environmental and reclamation personnel.
s l e A s 11. . -. 0=11 WhTf W on u s
-. u-r •ire
Dr. Trefry's field personnel, assisted by CZR and PCS personnel, will collect sediment
samples from the locations listed below during August 1997 (Figure 3). At present, we anticipate only
sampling one time (in August 1997); however, some sites could be resampled in'January 1998 if the
data warrant. Analyses will be done by Dr. Trefry's laboratory at FIT. The samples will be analyzed
for 1) cadmium, 2) arsenic, 3) total chromium, 4) zinc, 5) iron, and 6) aluminum. Based on the scans
done on the source materials under Section I. above and on the review of existing data, other metals
may be included in the analyses.
The areas from which sediment samples will be taken from pond, creek, river, or canal
bottoms include:
• Below the spillway draining from R-1
• In the canal draining from R-1 to outfali 007
• Durham Creek at EIS sample station 42
• Porter Creek (adjacent to R-1) at EIS sample station 47
• In the pond at Porter Creek North wetland reclamation site
• In.the 101 outfall canal below the R-2 discharge point
7

Sites On or Adjacent to the —Charles Tract
• At EIS sample station 15 in Short Creek
• At EIS sample station 18 in long Creek
• In Flannigan Gut near outfall 021
• At EIS sample station 19 in Bond Creek
• Inside clay pond 5A
• At EIS sample station 23 in South Creek
Control/Comparison Sites
• At EIS sample station 21 in Bond Creek
• Pamlico River about 1 mile downstream from Indian Island
• Brickyard pond on Archbell/Kugler Tract
• Bath Creek adjacent to Archbell/Kugler Tract
• Pamlico River adjacent to Archboll/Kugler Tract
• Huck Creek adjacent to Archbe111Kugler Tract
2. Soil Samples
Soil samples will be taken from the reclamation areas and control site and will be analyzed
by ❑r. Logan's laboratory at Ohio State University. The samples will be analyzed for 1) cadmium, 2)
arsenic, 3) total chromium, and 4) zinc. Based on the scans in Section I above, other metals may be
included as well.
Three separate soil samples will be taken by Dr. Logan and CZR personnel from each sample
area listed below. Each sample will be comprised of 10 subsamples taken at random in about a 10 foot
diameter circle. Samples will be from the 0-6 inch depth of the surface soil, and plant debris, roots,
etc. will be excluded. The subsamples will be mixed by hand in the field in a plastic bucket and a 1
pound sample placed in a plastic bag for shipment to Dr. Logan's laboratory.
On or Adiacent to R-1 , R-2. and R-3
• R-1
• R-2
• On Porter Creek -forth wetland reclamation site
'-n_the Charles Tract
• Clay pond 1
• Clay pond 48
Control Site
• Site on the Archbell/Kugler Tract
8

1V. PLANTS
CZR wildlife biologist and botanist personnel will conduct a reconnaissance of the Charles Tract clay
ponds, the Porter Creek -North wetland reclamation site, R-1, R-2, and the Archbell-Kugler control site
in June and July 1997 to identify the plant species occurring and to determine which species are likely
to be consumed by wildlife and which species to sample. The reconnaissance will also serve to help
pick potential mammal trapping and collection sites for sampling in the Fall. After the reconnaissance,
CZR will coordinate the final list of plant species and sample numbers with PCS before proceeding with
plant collection. Plants will be collected primarily in August or September 1997. CZR biologists will
take three separate plant tissue samples of each selected plant species from each sample area. Total
above ground plant material will be taken for smaller plants by clipping the plant just above the ground
surface. Care will be taken to avoid soil contamination and dead plant material. For larger shrubs and
trees, the youngest, fully developed leaves will be harvested by hand. Each sample will comprise tissue
from 10 separate plants. Subsamples will be placed in a plastic bucket and mixed by hand; a
composite sample of about 0.5 pound wet weight will be placed in a zip -lock bag. The sample bags
will be marked with the sample site, number, species, and date; and the samples will be shipped to Dr.
Logan's laboratory for analyses for cadmium levels.
At the present time, the plant species and numbers for each area are not known. Thus, for planning
and initial costing purposes, we have assumed that we will collect three composite samples of an
average of four plant species from each of the following areas:
• Charles Tract clay pond 1
• Charles Tract clay pond 4B
• R-1
• R-2
• Porter Creek -North wetland reclamation site
• Site on the Archbell/Kugler Tract
V. AQUATIC ORGANISMS
Aquatic organisms from waters on or adjacent to the PCS reclamation areas will be sampled by CZR
biologists primarily in August, September, and October 1997. Supplementary collections may be made,
if needed, in other months. The aquatic organisms (except for turtles) collected will be frozen whole,
packaged in marked containers, and shipped to Dr. Trefry's laboratory for analyses for cadmium levels.
Depending on size, the turtles collected will either be shipped whole or will be dissected and packaged
in sample parts in marked containers, The samples will be frozen and shipped to Dr. Logan's laboratory
at Ohio State University for cadmium analyses.
A. ELsh
CZR biologists will collect fish samples as available from the areas listed below (Figure 5). At
the river and creek sites, the fish will likely be seasonal migratory species such as spot, croaker, and
bay anchovy. In the ponds (such as Porter Creek -North), carp, largemouth bass, and sunfish are likely
target species. CZR will use a variety of methods, as required. This may include seines, trawls, gill
nets, electroshocker, or other gear.
E

DUCK
CREEK
BATH
A IL CREEK
n
PAMLICO RIVER
DURHAM
CREEK
PORTER • A
CREEK
INDIAN
ISLAND
SOUTH
CREEK
LONG
CREEK
- SHORT
CREEK MUDDY
o s000 1$000
BOND CREEK
CREEK
SCALE IN FEET
SAMPLE SITE
FIGURE 5. AQUATIC ORGANISM SAMPLING SITES

• At the mouth of the outfall 007
• Durham Creek in the vicinity of Station 42
• Porter Creek in the vicinity of Station 47
• Pond in the Porter Creek -North wetland reclamation site
• In the 101 outfall canal below the R-2 discharge point
• Short Creek
• Long Creek
• Flannigan Gut and Bond Creek (near Station 19)
• In clay pond 5A
• In Brickyard pond on Archbell/Kugler Tract
• In Bath Creek adjacent to ArchbelllKugler Tract
• In Duck Creek adjacent to Archbell/Kugler Tract
• Bond Creek in the vicinity of Station 21
B. loy@rtebrates
At each of the sites listed above for fish collections, three invertebrate samples will also be
collected for cadmium analyses. At the creeks and river stations, likely species will include the mollusc
Macoma (M. balth/ca and M. phenaxi. Samples of shrimp and crabs will be taken where available. At
the pond and canal stations, a composite of available invertebrates (for example - crayfish, dragonfly
nymphs, oligochaetes, and snails) will be taken. At stations where a specific group of invertebrates
is readily available, composites will be comprised of that one group. However, if one group is not
adequately available, a composite of several different species/groups will be collected.
C. Turtles
At each of the sites listed above for fish collections, CZR biologists will collect mature turtles
for cadmium analyses by use of traps, baited hooks, or incidental to fish collections in seines, trawls,
or gill nets. One sample will be analyzed per site.
VI. TERRESTRIAL ANIMALS
A. Review of Literature
Dr. Logan will review and summarize pertinent literature relating to cadmium in terrestrial
animals. This may include information from the U.S. Fish and Wildlife Service's Patuxent Wildlife
Research Center and the U.S. Environmental Protection Agency's office in Corvallis, Oregon, both of
which have done work on the effects of cadmium in animals.
11

CZR biologists, under existing collecting permits and with any special permission or permits
required, will collect representative mammals and birds to sample cadmium in tissues. The Charles
Tract is the best established reclamation area with a diverse and abundant terrestrial animal population.
Some likely mammal species to use include the white-tailed deer, nutria for muskrat), eastern cottontail
(or marsh rabbit), cotton rat, shrews, raccoon, and gray fox. The Porter Creek wetland reclamation
sites and R-1 may yield some of the above species. The sample animals and numbers will be
determined by availability to some extent, but the target list and numbers by area, including a control
site, are listed below. At least three specimens of each will be collected and analyses for cadmium will
be done for the storage organs (kidneys and liver). For the game species (white-tailed deer, rabbit,
bobwhite, morning dove, and Canada goose), a sample of the muscle tissue will also he analyzed. CZR
will dissect the specimens, prepare sample portions (as per Dr. Logan's instructions) in separate marked
zip -lock bags, freeze the samples, and ship to Dr. Logan's laboratory at Ohio State University. For
smaller specimens (such as shrews, cotton rats, or bobwhites), CZR will freeze the specimens whole
and ship to Dr. Logan.
On the Qharles Tract
• White-tailed deer
• Gray fox
• Nutria
• Rabbit (eastern cottontail or marsh rabbit}
• Raccoon
• Cotton rat
• Shrews (or rice rat)
• Bobwhite
• Mourning dove
The early successional stage of R-1 and the Porter Creek Wetland Reclamation Areas (Porter
Creek -North and Porter Creek -South! and their isolation from surrounding habitats (due to the
creek and river, the plant site, and other adjacent reclamation sites) allows a very limited animal
population from which to sample. However, CZR biologists will collect small mammals and
birds as available from these sites. From these areas CZR will attempt to collect three
specimens each of the following;
• White-tailed deer
• Rabbit
• Cotton rat
• Shrews (or rice rat)
• Bobwhite
• Mourning dove
• Canada goose
12

On the Archbell/Kugler Tract control site, CZR biologists will collect specimens for comparison
with those on the reclamation sites. This will include three specimens for composite sample
where necessary) each of the following available target species:
• White-tailed deer
• Gray fox
• Nutria
• Rabbit
• Raccoon
• Cotton rat
• Shrews for rice rat)
• Bobwhite
• Mourning dove
CZR biologists will collect one composite sample each, as available, of 1) earthworms and 2)
available insects {grasshoppers, beetles, etc.} and spiders from the following. sites:
• R-1
• R-2
• Porter Creek -North wetland reclamation site
• Charles Tract clay pond 1
• Charles Tract clay pond 4B
• Charles Tract clay pond 5A
• Site on the ArchbelllKugler Tract control site
VII. REPORTING
A. Bi-mo
The CZR Project Manager will keep PCS Phosphate personnel updated bi-monthly on the
progress of the study.
B. Draft Reoort
The study team will prepare a draft report in the early months of 1998, and will submit the
draft report for PCS review by 1 May 1998.
C. Einal Regort
After receipt of review comments from PCS Phosphate, the study team will prepare the final
report for submission to PCS by 31 July 1998.
13

TENTATIVE SCHEDULE FOR THE CADMIUM AND OTHER METALS STUDY ON AND ADJACENT TO PCS PHOSPHATE RECLAMATION AREAS
1997 1998
MAY JUN JUL AUG Sip OCT NOV DEC JAN FEB MAR APR MAY JUN JUL AUG
I. SOURCESOFMJGTALS
Collection Anayses
11. WATER
I C1ata reviewlsummary
Ill. SOILSISEAIMENTS
Data reviewlsummary �I
Sediments
Soils
IV- PLANTS
V. AQUATIC ORGANISMS
VI. TERRESTRIAL ANIMALS
1/7I. REPORTING
Craft Report
Final Report
Colletlipn Analyses
Colleclion Analysts
Collection Ana"ccS
Co9eGion Analyses I
Reconnaissance CaUeGion Analyses
Collection Analyses
Collection
Analyses 1
14
Preparation �•Submftl:1 MAY 98
PCs n view
Finalize report I'Submiaal: 91 JUl.9e
CPl1 1745-48, 9115W
t

By
PCS
Phosphate
APR 151997 --- - - -
3101 GLENWCIII VE., P.O. BOX 30321, RALEIGH, NO 27622-0321 TEL: [phone] FAX: [phone]
Thomas J. Regan, Jr.
April 14, 1997 Executive Vice President
Colonel Terry Youngbluth
District Engineer
U.S. Army Corps of Engineers
Post Office Box 1890
Wilmington, North Carolina 28402
RE; PCS Phosphate Company, Inc. (Texasgulf Inc.)
Mine Advance Permit
Dear Colonel Youngbluth:
A question has been raised regarding the ability of PCS Phosphate
Company, Inc. (PCS Phosphate) to withdraw its mining equipment at the end of
the mining plan (Alternative E) requested in the PCS Phosphate permit
application.
As: previously and openly- -stated;.PC--S Phosphate -intends to--file--a -permit - - -
application prior to completing the mine plan contemplated by Alternative E
which would allow PCS Phosphate to continue mining the ore reserves east of
Alternative E on the NCPC Tract. However, in the event such further permit is
not granted, PCS Phosphate can, at the conclusion of mining under Alternative
E, relocate its mining equipment to another location or otherwise dispose of the
equipment without impacting any additional wetland acres on the NCPC Tract.
Sincerely,
PCS PHOSPHAT COMPANY, INC.
Thomas J. e n,
Executive Vice iden
TIRJ[c M NIM-o3

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Land Resources
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
Charles H. Gardner, P.G., P.E.,
Director and State Geologist
December 19, 1996
Mr. Tom Augspurger, Ecologist
U. S. Fish and Wildlife Service
Post Office Box 33726
Raleigh, North Carolina 27636-3726
Dear Mr. Augspurger:
A4
[DEHNR
This is to acknowledge receipt of your letter of December 18, 1996 and the draft
preliminary risk evaluation concerning cadmium at PCS Phosphate's mine reclamation
sites. My staff and I look forward to reviewing this report and to having further contact
with you. Thank you for your cooperation.
cc: Mr. Mell Nevils/Tracy Davis
Geological Survey Section
[phone]
FAX: [phone]
Sincerely,
Charles H. Gardner, P. G., P. E.
Land Quality Section
[phone]
FAX: [phone]
P.O. Box 27687. Raleigh. North Carolina 27611-7687 - Telephone [phone] , • FAX [phone]
An Equal Opportunity/ Altlrmative Action Employer • 50% recycled/ 10% post -consumer paper

z
cited motes Department of the
SO 01 FISH AND WILDLIFE SERVICE
Raleigh Field office
Post office sox 33726
Raleigh, North Carolina 27636.3726
Mr. Charles Gardner, Director
North Carolina Division Of Land
Post Office Box 27687
Raleigh, North Carolina 27611
Dear Mr. Gardner:
esfarr
Interior
:ember 18 996�1 ti Dec
DEHNR iti 996
.- N
:s 5 I997
LAND QUALITY
E
I enjoyed talking with you about the U.S. Fish and Wildlife Service's (Service) ecological risk
evaluation activities associated with cadmium at the PCS Phosphate facility. Enclosed is a
December 1996 version of the Draft Preliminary Risk Evaluation of Cadmium in PCS
Phosphate Reclamation Lands and Adjacent Areas for your agency's review.
Although comments and questions are welcome on any part of the evaluation, our intent in
circulating it at this stage is to get feedback on: 1) the proposed methodology; 2) selection of
ecological receptors modeled; and, 3) the completeness of existing analytical data. These are the
same questions posed to the North Carolina Wildlife Resources Commission, U.S. Army Corps
of Engineers, NCSU Soil Science Department, and PCS Phosphate when we circulated the draft
in August; the only substantive changes in this version are corrected typographical errors. The
responses from the previous reviewers, which you requested, are summarized below:
o NCWRC - see attached comments;
o NCSU - correct two typos regarding plant cadmium data (which have been corrected);
o PCS - agree with methodology, data complete and data gaps are correctly identified,
recommended another bird more suited to old field habitats be used instead of woodcock,
recommended adding definitions and page numbers.
O USACOE - no comments other than the recommendation to forward a copy of the document
to the Division of Land Resources.
The goal of the final evaluation is to investigate the potential for adverse ecological effects, to
provide a foundation for discussion of any risks, and to identify important information gaps
which might limit a more robust evaluation. As I mentioned, a more complete draft will be

A developed and circulated once we receive input on the methods, data sources and indicator
species. I look forward to hearing from you. Please give me a call if you have any questions
about this request of the subject document. I can be reached at 856-4520 x. 21.
Sincerely,
Tom Augspurg
Ecologist
Attachment
FWS/R4:TAugspurger:ta:12-12-96:919-856-4520 ext.21:wp511dlr

RECEIVED
DEC 19 '96
United States Department of the Interior DtV LAND RED
FISH AND WILDLIFE SERVICE
Raleigh Field Office
Post Office Box 33726
Raleigh, North Carolina 27636.3726
December 18, 1996
Mr. Charles Gardner, Director
North Carolina Division Of Land Resources
Post Office Box 27687
Raleigh, North Carolina 27611
Dear Mr. Gardner:
I enjoyed talking with you about the U.S. Fish and Wildlife Service's (Service) ecological risk
evaluation activities associated with cadmium at the PCS Phosphate facility. Enclosed is a
December 1996 version of the Draft Preliminary Risk Evaluation of Cadmium in PCS
Phosphate Reclamation Lands and Adjacent Areas for your agency's review.
Although comments and questions are welcome on any part of the evaluation, our intent in
circulating it at this stage is to get feedback on: 1) the proposed methodology; 2) selection of
ecological receptors modeled; and, 3) the completeness of existing analytical data. These are the
same questions posed to the North Carolina Wildlife Resources Commission, U.S. Army Corps
of Engineers, NCSU Soil Science Department, and PCS Phosphate when we circulated the draft
in August; the only substantive changes in this version are corrected typographical errors. The
responses from the previous reviewers, which you requested, are summarized below:
o NCWRC - see attached comments;
o NCSU - correct two typos regarding plant cadmium data (which have been corrected);
o PCS - agree with methodology, data complete and data gaps are correctly identified,
recommended another bird more suited to old field habitats be used instead of woodcock,
recommended adding definitions and page numbers.
O USACOE - no comments other than the recommendation to forward a copy of the document
to the Division of Land Resources.
The goal of the final evaluation is to investigate the potential for adverse ecological effects, to
provide a foundation for discussion of any risks, and to identify important information gaps
which might limit a more robust evaluation. As I mentioned, a more complete draft will be

4.
developed and circulated once we receive input on the methods, data sources and indicator
E; species. I look forward to hearing from you. Please give me a call if you have any questions
about this request of the subject document. I can be reached at 856-4520 x. 21.
Sincerely,
/A
Tom Augspurg
Ecologist
Attachment
FWS/R4:TAugspurger:ta:12-12-96:919-856-4520 ext.21:wp511dlr

Page
COPY FOR YOVA
MEMORANDUM IMFORMA710II
TO: Tom Augspurger
U.S. Fish and Wildlife Service
FROM: William Wescott
N.C. Wildlife Resources Commission
DATE: August 27, 1996
SUBJECT: Draft Preliminary Risk Evaluation of Cadmium in PCS Phosphate
Reclamation Lands and Adjacent Areas.
The draft risk evaluation to investigate potential effects of cadmium at PCS
Phosphate Inc., in Aurora, appears to have been developed from the most applicable
data available in the literature. We are providing the following comments for your
consideration.
Methodology
We agree with the assumptions and methodology used in this risk
assessment.
Ecological Receptors
The receptors used in this draft risk assessment appear adequate to
determine the existence of possible/potential ecological problems.
Existing Analytical Data
Based on the average input parameters, three of the four species have
hazard quotients >1. These three hazard quotients ranged from 3.6 to 14.8.
A full scale detailed risk assessment appears justified based on the results of
this draft evaluation, existing cadmium concentrations, and the thousands of
acres to be directly impacted in the future.
We recommend that the USFWS collect or oversee the collection of the data
needed to develop Hazard Quotients for aquatic, terrestrial, and avian
species. Hunting and fishing are very popular recreational activities in this
area; therefore, we recommend the following species be included in a risk
assessment: whitetail deer, resident Canada geese, herons, aquatic
invertebrates, crabs, bullhead catfish, pumpkinseed sunfish, largemouth
bass, and bowfin.
Thank you for the opportunity to comment on this draft risk evaluation. if you
have questions regarding these comments, please contact me at [phone],

7
DRAFT
Draft Preliminary Risk Evaluation of Cadmium
in PCS Phosphate Reclamation Lands
and Adjacent Areas
U. S. Fish and Wildlife Service
Raleigh Field Office
December 1996 Draft
(a:\cdra.rvl)
The Service requests that no part of this draft be cited or reproduced outside the agencies
receiving it (USFWS, USACOE, NCWRC, NCDLR, NSCU-Soil Science, and PCS). Please
direct any questions or suggestions to:
Tom Augspurger
USFWS
Ecological Services
P.O. Box 33726
Raleigh, North Carolina 27636-3726
Phone: [phone] ext. 21
Fax: [phone]
E-mail: [e-mail]

DRAFT
TABLE OF CONTENTS
1.0 Background
1.1 Introduction
1.2 Site Description
2.0 Problem Formulation
2.1 Cadmium Toxicity Assessment
2.1.1 Birds
2.1.2 Mammals
2.2 Exposure Assessment
2.3 Ecological Receptors with Dietary Exposure Profiles
2.3.1 Terrestrial Resources
2.3.1.1 Short -Tailed Shrew
2.3.1.2 Eastern Cottontail
2.3.1.3 American Woodcock
2.3.1.4 Northern Bobwhite
2.3.2 Aquatic Resources
2.3.2.1 Muskrat
2.3.2.2 Raccoon
2.3.2.3 Mallard
2.3.2.4 Lesser Scaup
2.3.3 Human -Use Resources
2.3.3.1 White-tailed Deer
2.4 Evaluation Endpoints
3.0 ASSUMPTIONS
3.1 Life History Assumptions
3.2 Dietary Exposure Assumptions
3.3 Toxicity Assumptions
4.0 CONTAMINANTS OF CONCERN
4.1 Cadmium in the Terrestrial Environment at PCS
4.1.1 Cadmium Data for Site Soils and Plants
4.1.2 Bioaccumulation Factors and Predicted Cadmium
Concentrations in Terrestrial Invertebrates
4.2 Cadmium in the Aquatic Environment at PCS
4.2.1 Cadmium Data for Site Sediments and Surface Water
4.2.2 Cadmium Data, Bioaccumulation Factors, and
Predicted Cadmium Concentrations in Aquatic
Invertebrates

DRAFT
5.0 RISK CHARACTERIZATION
8.1 Exposure Concentration Calculation
8.2 Hazard Quotient Calculation
6.0 SOURCES OF UNCERTAINTY
7.0 CONCLUSIONS and RECOMMENDATIONS
8.0 REFERENCES

MI
1.0 Background
1.1 introduction
Concern has been expressed by environmental review and permitting
agencies over the potential for ecological effects of elevated
cadmium associated with the operations of the PCS Phosphate mine
in Aurora, North Carolina. Cadmium is enriched in the process
residuals and reclaimed lands associated with the facility. At
the request of the North Carolina Wildlife Resources Commission,
the U.S. Fish and Wildlife Service conducted an elementary risk
evaluation. This draft of the risk evaluation may be finalized
upon review of involved parties; it could also be expanded into a
full scale risk assessment with more advanced bioaccumulation
modeling and more rigorous statistical treatments. Our intent in
the risk evaluation is to investigate the potential for
ecological effects, to provide a foundation for discussion of any
risks by interested parties, and to identify important
information gaps which might limit a more robust evaluation.
The evaluation uses existing cadmium analytical chemistry data
for site soils and plants and predicts concentrations in other
media at the site to develop dietary cadmium burdens for site
ecological receptors. These dietary concentrations are compared
to toxicological affects levels for cadmium in the published
literature via a hazard quotient approach. Sources of model
uncertainty are discussed as are the implications of the risk
evaluation findings and recommendations for additional field data
collection.
1.2 Site Description
PCS Phosphate's Aurora facility mines phosphate -containing
deposits on the south side of the Pamlico River in Beaufort
County. Carbonate -apatite is strip mined at a rate of about 13
million tons per year; mining and processing operations result in
byproducts including sand tailings, 2.5 million tons of clay
tailings and 6 million tons of phosphogypsum annually (Markland
1996). Cadmium is enriched in these materials; analyses by TVA
indicate cadmium concentrations of 21.0, 14.0, and 6.0 mg/kg dry
weight, in the clay, phosphogypsum, and sand tailings
respectively (Dr. Steve Broome, pers. comm. 1996).
Historically, clay tailings were de -watered in large settling
ponds. Part of the reclamation process now includes the mixing
of clay tailings with phosphogypsum at varying ratios with the
slurry then utilized to replace mined substrate. The PCs
Phosphate reclamation site designated as R-1 received a blend of
4

DRAFT
2:1 phosphogypsum to clay tailings. It is currently dominated by
phragmites, tali fescue, broomsedge, and wax myrtle (Dr. Steve
Broome, pers. comm. 1996). Reclamation site R-2 received blended
residuals at a ratio of 4:1 phosphogypsum to clay tailings and is
currently dominated by phragmites (Dr. Steve Broome, pers. comm.
1996) .
2.0 Problem Formulation
This risk evaluation is designed to evaluate the potential
threats to ecological receptors from exposure to cadmium at
reclaimed lands, clay settling ponds, and adjacent areas
associated with the PCS Phosphate facility. Based on the
habitats present on site, exposure is likely to result from
direct contact with soil, direct ingestion of vegetation, direct
ingestion of soil invertebrates, and direct ingestion of surface
waters. Terrestrial and aquatic receptors may accumulate site
contaminants through contact with these site media. These
receptors may then be consumed by higher trophic level receptors,
transferring the contaminants through the food chain.
A simple approach to evaluating ecological risks is the use of
hazard quotients. The hazard quotient method (Suter 1993)
compares exposure concentrations to contaminant concentrations
associated with ecological endpoints such as reproductive failure
or reduced growth. The comparisons are expressed as ratios of
potential intake values (i.e., dietary cadmium concentrations in
this case) to effect levels:
Hazard Quotient = Dietary Exposure Concentration
Lowest Observed Adverse Effect
Level (LOAEL)
A hazard quotient Z 1 when the LOAEL is used in the denominator
indicates that exposure to the contaminant may cause adverse
effects in the organism. A hazard quotient < 1 does not indicate
a lack of risk, but should be interpreted based on the severity
of the effect reported and the magnitude of the calculated
quotient.
The values to be used in the hazard quotient denominator are
derived from a review of the pertinent literature on cadmium
toxicity (see section 2.1). A Lowest Observed Adverse Effect
Level (LOAEL) is defined here as the lowest dietary concentration
of cadmium utilized in a toxicity test that caused an adverse
5

DRAFT
effect which was statistically significantly different from a
control group in that test. A No Observed Adverse Effect Level
(NOAEL) is defined here as the highest dietary concentration of
cadmium utilized in a toxicity test that caused effects which
were not statistically significantly different from the control
group in that test. By definition, LOAEL and NOAEL values are
limited to doses actually utilized in experimental treatments; a
LOAEL may not be the actual threshold for initiation of adverse
effects (it is simply the lowest dose at which adverse effects
have currently been demonstrated) and a NOAEL may not be the
upper safe limit beyond which adverse effects are predicted (it
is simply the highest dose yet tested at which adverse effects
have been unapparent).
The values to be used in the hazard quotient numerator, or the
dietary exposure concentrations, are a combination of measured
values of cadmium in soils and vegetation at the PCS Phosphate
site and predicted values in other site media (see sections 2.3
and 2.4). For a set of aquatic and terrestrial birds and mammals,
the dietary hazard quotients are calculated and discussed. The
selection of the species utilized in this evaluation is discussed
in detail in section 2.2)
2.1 Cadmium Toxicity Assessment
Cadmium is a naturally -occurring metal which can become enriched
in certain areas as a result of anthropogenic activities. The
main sources of cadmium as a pollutant are cadmium refining,
copper and nickel smelting, and fuel combustion (Wren et al.
1995). The metal has no known biological function (Cooke and
Johnson 1996) and has been associated with subtle to severe
biological effects, the latter including mutagenicity,
teteratogenicty, and suspected carcinogenicity (Eisler 1985).
Cadmium is known to bioaccumulate. Tissue levels of cadmium
increase with the age of the vertebrate organism, are largely
accumulated in the liver and kidney, and eventually act as a
cumulative poison. Because cadmium is known not to biomagnify,
the risk evaluation will focus on the lower trophic levels where
bioaccumulated cadmium concentrations are expected to be highest.
2.1.1 Birds
No studies on the dietary toxicity of cadmium to woodcock,
Northern bobwhite, or scaup (the avian species evaluated in this
assessment; see section 2.3) were found. Therefore, literature
pertaining to the dietary toxicity of cadmium to the mallard,
N.

DRAFT
Japanese quail, and chickens are used. A synopsis of available
information is offered here along with avian cadmium NOAEL and
LOAEL values which we will use as toxicity screening values for
all avian receptors in this evaluation.
Juvenile mallard drakes were fed diets containing 0, 50, 150, or
450 mg/kg of cadmium for six weeks (Di Giulio and Scanlon 1.984).
The most significant metabolic effects were seen only in the 450
mg/kg treatment group. These specimens exhibited a 20.3%;
decrease in body weight, a 26% decrease in liver weight, a 15k
increase in kidney weight, a 21% decrease in liver aldolase
activity, a 46% increase in plasma uric acid concentrations, a
74% decrease in plasma triiodothyronine concentrations, a 28k
increase in adrenal weights, and a 31% increase in adrenal
cortisone concentrations. Ducks in the 150 mg/kg treatment group
also exhibited a 12W increase in kidney weight and a 23k increase
in adrenal weight. No adverse effects were observed at a dietary
concentration of 50 mg/kg.
Adult (1 year old) male and female mallard ducks were fed a diet
containing 0.08, 1.6, 15.2, and 210 mg/kg, wet weight of cadmium
ad libitum for 90 days (White and Finley 1978). There were no
mortalities in any treatments, and hematocrit and hemoglobin
levels were normal in all treatments. Male testis weight, male
kidney weights, and egg production by females were significantly
less in the 210 mg/kg treatment when compared to the controls.
No adverse effects were observed at a dietary concentration of
15.2 mg/kg.
Mallard ducklings were fed dietary cadmium at 0, 5, 10, or 20
mg/kg from day 1 of age to 12 weeks of age (Cain et al. 1983).
Ducklings receiving 20 mg/kg exhibited an 8 percent decrease in
packed cell volume, a 6 percent reduction in hemoglobin
concentration, and a 52 percent increase in serum glutamic
pyruvic transaminase activity, all of which were statistically
significant at the 0.05 level. Upon necropsy, these specimens
revealed mild to severe kidney lesions. No significant adverse
effects were noted at dietary cadmium levels of 5 mg/kg or 10
mg/kg.
Juvenile (2-week old) male Leghorn chickens were fed a diet ad
libitum containing various concentrations of Cd in two separate
experiments (Prizl et al. 1974). Experiment 1 utilized Cd
concentrations of 0, 400, 600, 800, and 1,000 mg/kg for 20 days.
Experiment 2 utilized Cd concentrations of 0 and 700 mg/kg for 20
days. A significant reduction in growth rate and feed
consumption was noted at a dietary concentration of 400 mg/kg.
An LDso of 565 mg/kg was calculated. Chickens fed diets of 12
7

DRAFT
mg/kg and 48 mg/kg of cadmium exhibited significant reductions in
egg production (Leach et al 1979, as cited in Furness 1996).
Male Japanese quail fed a diet containing 75 mg/kg of Cd as CdC12
for 4 weeks exhibited a 62 percent decrease in testis size, a
lack of spermatogenesis, damage to small intestine mucosa, and
severe anemia (Richardson et al. 1974). These responses were
associated with a mean liver cadmium concentration of 42t2.6
mg/kg.
In his review of cadmium toxicity data, Eisler (1985) indicated
that wildlife dietary Levels exceeding 0.1 mg/kg should be viewed
with caution. In a recent review of most of the cadmium studies
cited here, as well as additional toxicity data for birds,
Furness (1996) concludes that dietary cadmium concentrations in
excess of 2 mg/kg induced increased synthesis of metallothionein,
accumulation of cadmium and zinc, and possible alteration of
iron, zinc, and calcium metabolism. Although these physiological
changes are attributable to low level dietary cadmium, they
probably should not be considered adverse responses; rather, they
appears to be adaptive physiological responses that are
potentially reversible and not harmful. Toxic effects of cadmium
(altered behavioral responses, suppression of egg production, egg
shell thinning, kidney damage, testicular damage, duodenal
epithelium damage, altered energy metabolism, anemia, bone marrow
hyperplasia, and cardiac and adrenal hypertrophy) have been
reported in laboratory studies with ducks, chickens, quail, and
starlings (Furness 1996) at levels as low as 12 mg/kg (decreased
egg production) and 20 mg/kg (kidney and testicular lesions). For
avian receptors in this risk evaluation, a dietary level of 12
mg/kg, dry weight, of cadmium will be used as a LOAEL with a
NOAEL of 10 mg/kg, dry weight.
2.1.2 Mammals
No studies were retrieved pertaining to the dietary toxicity of
cadmium to any of the mammals chosen as ecological receptors (see
section 2.3). Eisler (1985) summarized data from mice exposed to
dietary cadmium at 1.8 mg/kg for 28 days. This exposure resulted
in reduced hematocrit and hemoglobin values (Siewicki et al.
1983, as cited in Eisler 1985). Male and female weanling brown
rats fed a diet containing 5 mg/kg of cadmium for 10 weeks
exhibited no adverse effects on growth (Pribble and Weswig 1973).
Offspring of white-footed mice exposed to 10 mg/kg dietary
cadmium for 10 weeks exhibited increased testes weights (Yocum et
al. 1987). In his review of cadmium toxicity data, Eisler (1985)
indicated that wildlife dietary levels exceeding 0.1 mg/kg should
be viewed with caution.
K,

DRAFT
In a more recent review of cadmium residue data in target organs
of mammalian receptors, Cooke and Johnson (1996) report that
diets containing cadmium at about 10 mg/kg, dry weight, could be
expected to produce mild symptoms of kidney dysfunction and
reduced bone calcification with more severe kidney damage evident
at 50 mg/kg. The equivalent NOAEL to LOAEL range, in terms of
dose, is estimated at 1 to 7 mg of cadmium per kg of body weight
per day (Cooke and Johnson 1996). The kidney concentrations
associated with damage are estimated at 100 mg/kg, wet weight
(350 mg/kg, dry weight) on a whole organ basis (Cooke and Johnson
1996). For mammalian receptors in this risk evaluation, a
dietary cadmium level of 10 mg/kg, dry weight, will be used for
a LOAEL with a NOAEL of 5 mg/kg, dry weight.
2.2 Exposure Assessment
Based on the mix of aquatic and terrestrial habitat at the sites
and the availability of existing toxicity information, two groups
of receptors (aquatic and terrestrial) will be evaluated.
Because existing reviews of cadmium toxicity indicate that
insectivorous species are likely at greatest risk in the wild
(Cooke and Johnson 1996), we have chosen to construct the hazard
quotients with aquatic and terrestrial species of bird and mammal
that forage on invertebrates. To provide a lower range of risk
estimation, hazard quotients are also calculated for aquatic and
terrestrial species which are largely herbivorous. All of the
selected species are common in eastern North Carolina (Potter et
al. 1980, Webster et al. 1985) which adds environmental realism
to the ecological risk evaluation.
2.3 Ecological Receptors
Key life history information from the Wildlife Exposures Factors
Handbook (USEPA 1993) is summarized below for the indicator
species chosen for this evaluation. Incidental soil ingestion
data are taken from Beyer et al. (1994).
4

2.3.1 Terrestrial Resources
2.3.1.1 Short -Tailed Shrew (Blari.na brevicauda)
Body weight:
Food ingestion rate:
Soil ingestion rate:
Home range:
Dietary composition:
f
13 to 22 g
0.49 to 0.52 g / g * d
not available, but probably
significant
<0.1 to 1.8 ha
80 to 95%- invertebrates
including insects, worms, and
snails; 10% vegetation; and
10% other, including mice
voles, and other vertebrates;
for this evaluation, assume
90% invertebrates and 10 t
vegetation
2.3.1.2 Eastern Cottontail (Sylvlagus floridanus)
Body weight.
Food ingestion rate:
Soil ingestion rate:
Home range:
Dietary composition:
700 to 1800 g
not available
not available, but probably
negligible
1 to 8 ha
100 percent vegetation,
including trees, shrubs,
vines, grasses, and (orbs
2.3.1.3 American Woodcock (Scolopax minor)
Body weight:
Food ingestion rate:
Soil ingestion rate:
Home range:
Dietary composition:
10
120 to 220 g
0.11 to 1.43 g/g * d
10.4 %;
0.3 to 171 ha
approximately 100 k
invertebrates, including
earthworms, beetle larvae,
coleoptera; some grit and
plant material; Assume 100k
terrestrial invertebrates for
this evaluation

2.3.1.4 Northern Bobwhite (Colinas virginianus)
Body weight:
Food ingestion rate:
Soil ingestion rate:
Home range:
Dietary composition:
2.3.2 Aquatic Resources
2.3.2.1 Muskrat - to be
2.3.2.2 Raccoon - to be
2.3.2.3 Mallard - to be
2.3.2.4 Lesser Scaup -
2.3.3 Human -Use Resources
150 to 200 g
0.072 to 0.093
not available,
negligible
4 to 16 ha
DRAFT
g/g * d
but presumed
75-90% vegetation, including
seeds and grasses; 10-25%
invertebrates, including
grasshoppers and beetles;
assume 75% vegetation and 25%
invertebrates for this
evaluation
developed
developed
developed
to be developed
2.3.3.1 White-tailed Deer - to be developed
2.4 Assessment Endpoints
The assessment endpoints selected for insectivorous and
herbivorous mammals are population viability and impaired
reproductive fitness due to cadmium exposure. The mechanism
whereby impaired fitness can occur are discussed in section 2.1.2
(Cadmium Toxicity Assessment - Mammals) and includes affects on
individuals such as physiological effects and ultrastructural
injury to the kidney. The assessment endpoint selected for birds
is the overall fitness of the population due to cadmium exposure.
The mechanism by which impairment can occur are discussed in
section 2.1.1 (Cadmium Toxicity Assessment - Birds) and include
physiological effects, reduced egg production, and
ultrastructural injury to the livers and kidneys of individual
birds.
Based on the characteristics of the contaminants of concern and
the assessment endpoints identified for this site, the following
hypotheses were developed for evaluation in this risk evaluation:
11

DRAFT
1) Levels of cadmium in site soils are sufficient to reduce
reproductive output and cause adverse physiological changes
to the livers and kidneys of birds.
2) Levels of cadmium in site soils are sufficient to cause
adverse developmental and physiological effects in small
mammals.
3.0 Assumptions
2.1 Life History Assumptions
Food ingestion rates, sediment/soil ingestion rates, and body
weights of receptor species were obtained from the literature,
primarily the U.S. Environmental Protection Agency's Wildlife
Exposure Factors Handbook (USEPA 1993). For this initial risk
evaluation, none of these factors are critical since we are
relying on concentration in the diet rather than dose per unit
body weight.
Area use factors (AUFs) were not calculated to weigh the
estimated exposure according to the proportion of time the
organism would be expected to use the contaminated site and its
food resources relative to its home range. They could be
calculated according to the following equation:
AUF = Contaminated Area a)
Home Range or Foraging Range (ha)
Although home ranges were available for receptor species (see
section 2.3), the size of the reclamation areas indicates that
all AUFs would likely have exceeded 1. Also, estimated exposure
calculations do not account for differential habitat use over the
site and hence, provide a conservative estimate of risk.
3.2 Dietary Exposure Assumptions
Dietary composition information was also obtained from the
Wildlife Exposure Factors Handbook (USEPA 1993) for the receptor
species. Although we attempted to chose species that would
maximize likely exposure (i.e., the insectivorous small mammals
and birds), few species are rigid in their feeding strategies.
For the shrew and woodcock, we used maximum reported dietary
percentage of invertebrates, as a worst case scenario, since the
cadmium toxicity review predicts this forage to have the highest
cadmium burden. Many species rely predominantly on a diet of
12

DRAFT
invertebrates early in life (e.g., young bobwhite quail, Canada
geese, mallards)for the high protein requirements of building
muscle mass. Hence, the conservative approach to approximating
forage composition has merit beyond its utility in developing a
conservative estimate of the risk. This is particularly
important given the data of Cain et al. (1983), as cited in
section 2.1.1, which indicates that 12 week exposure to 20 mg/kg
dietary cadmium in mallard ducklings produced adverse effects;
this level only slightly exceeds the cadmium LOAEL in birds for
this evaluation.
To estimate exposure to contaminants via ingestion, it was
assumed that levels of cadmium in site soils and forage were 100
percent available for bioaccumulation by the ecological receptors
we evaluated (i.e., total cadmium concentrations used instead of
some fraction to represent that which the gut could assimilate).
Because we used dietary concentrations of forage and dietary
toxicity data in the risk evaluation, depuration is only
indirectly addressed. As indicated in the introduction, more
comprehensive modeling can be conducted including use of actual
feeding rates, depuration rates, body weights, and time.
3.3 Toxicity Assumptions
A literature search was conducted to determine the chronic or
sub -acute toxicity of the contaminants of concern when ingested
by the indicator species. If no toxicity values could be located
for the receptor species, values reported for a closely related
species were used. All studies were critically reviewed to
determine whether study design and methods were appropriate. No
toxicological data were available for the species we evaluated;
it is assumed that the LOAEL and NOAELs derived from a review of
avian and mammalian studies are reflective of the target species'
sensitivity.
4.0 Contaminants of Concern
4.1 Cadmium in the Terrestrial Environment at PCS
Terrestrial fauna may be exposed to cadmium via consumption of
forage, ingestion of surface water and the incidental ingestion
of sediment or soil. Data are available for the cadmium content
of site soils and vegetation, a potential dietary component.
13

DRAFT
Data for cadmium content of terrestrial invertebrates at this
site are not available but can be predicted.
4.1.1 Cadmium Data for Site Soils and Plants
Data for the risk evaluation has been provided by Jeff Furness of
PCS Phosphate and Dr. Steve Broome of the North Carolina State
University (NCSU) Department of Soil Science. Available data
include cadmium residues in soils and vegetation from the
reclamation sites, experimental plots, and reference sites.
Analyses were performed by the Analytical Service Laboratory at
NCSU via ICP and AA under their standard operating procedures.
Residuals from the phosphate extraction process include clay
tailings, phosphogypsum, and sand tailings; analyses by TVA
indicate total cadmium concentrations in these media of 21.0,
14.0, and 6.0 mg/kg dry weight, respectively (Dr. Steve Broome,
Pere. comm. 1996). Average plant available cadmium (a fraction
of total cadmium resulting from a DPTA extraction process) in the
top 110 cm of blend from reclamation site R-1 was measured at
5.12 mg/kg dry weight (n=200; sd=1.07) (William Wescott, pens.
comm. 1996). A 95% upper confidence limit from these data is
5.27 mg/kg dry weight. Soils of the southeastern United States
on average contain about 0.15 mg/kg cadmium with a range of 0.03
to 0.44 mg/kg based on analyses of over 1200 samples (Page et al.
1987). Since the only cadmium concentrations for site soils are
plant -available cadmium, rather than total, we will use an
estimate of soil cadmium at the PCS Phosphate reclamation sites
of 15 mg/kg, dry weight. It is assumed that site soils contain
at least this amount of total cadmium given the cadmium content
of the blended materials. For a worst case scenario, a value of
21 mg/kg, dry weight is used in the conservative risk
calculations.
Vegetation sampling conducted at reclamation site R1, R2, and the
former clay settling ponds indicates that cadmium is accumulated
in the tissues of biota planted at, or colonizing, these sites.
Analytical cadmium data for trees in the former clay settling
ponds is.available for eight species. Cadmium was above the 0.8
mg/kg detection level in only 8 0£ 48 leaf samples at the former
settling pond and averaged 3 mg/kg (using a value of 1/2 the
detection limit for samples reported as less than detection) with
a maximum of 31.4 mg/kg (in Carolina poplar). On site R1, leaves
from 268 whole trees were analyzed, comprising a variety of
species. Cadmium was below the detection limit in most samples
and averaged about 3 mg/kg with a maximum of 24.6 mg/kg (in
southern red oak).
14

DRAFT
Cover crop experiments at R1 included cadmium analyses in a
variety of species. Analyses of nearly 500 plant samples (all
above ground biomass) indicate about 50t of the plants with
levels of cadmium above the detection limit, an average of about
2 mg/kg, and a maximum of 21 mg/kg (in subterranean clover).
Cadmium content of agricultural crops were assayed at R1.
Cadmium was above the detection limit in all 19 samples and
averaged about 2 mg/kg with a maximum of 5.4 mg/kg (in corn
leaves) .
Native vegetation colonizing Rl and R2 includes cattail,
phragmites, goldenrod, lambsquarter, and groundsel tree.
Analyses of these indicate most of the 38 samples had cadmium
above the detection limit with an average of 9.9 mg/kg and a
maximum of 93.6 mg/kg (in lambsquarter).
For the purposes of the risk evaluation, an average concentration
of 3 mg/kg is utilized based on the biggest data set, the
experimental plots of ground covers and trees. Two additional
values are used in the conservative risk calculation, a natural
vegetation average of 9.9 mg/kg and the maximum of 93.6 mg/kg for
the most conservative assessment.
4.1.2 Bioaccumulation Factors and Predicted Cadmium
Concentrations in Terrestrial Invertebrates
Terrestrial invertebrates are known to accumulate cadmium from
contaminated soils (Cooke and Johnson 1996). Although no residue
data are available for invertebrates associated with the PCS
reclamation sites, this pathway is important to consider in the
risk evaluation. Therefore, potential cadmium concentrations in
terrestrial invertebrates, such as earthworms will be predicted.
Published literature was used to obtain bioaccumulation factors
(BAFs) for terrestrial invertebrates. If a RAF was not presented
in the study being reviewed, a RAF was calculated by dividing the
concentration reported in the tissue by the ambient
concentrations reported in soil collected at the same location:
RAF = Contaminant Concentration irr Tissue
Contaminant Concentration in Soil
Table 1 lists the bioaccumulation factors from literature
reviewed as part of this study. Those data produce an average
RAF of 20 with a maximum of 126. We discounted the two highest
15

DRAFT
BAF9 (which were derived for very acidic soils) and recalculated
the average BAF at 11 with a maximum of 48 for use in this
evaluation. These BAFs are used to predict the contaminant
concentration in terrestrial invertebrates for the evaluation by
multiplying by the BAF and the site soil cadmium concentration of
15 mg/kg (see section 4.1.1). Consequently, estimates of
terrestrial invertebrate cadmium content range from 165 mg/kg
(with the average BAF of 11) to 720 mg/kg (with the maximum BAF
of 48). The highest BAF is included to predict the contaminant
concentrations in the receptor species, food items as a
conservative estimate of risk. Both the mean and maximum
predicted terrestrial invertebrate cadmium concentrations will be
used in the risk calculations.
4.2 Cadmium in the Aquatic Environment at PCS _ to be
developed
4.2.1 Cadmium Data for Site Sediments and Surface Water
4.2.2 Cadmium Data, Bioaccumulation Factors, and Predicted
Cadmium Concentrations in Aquatic Invertebrates
16

DRAFT
Table 1. Cadmium Bioaccumulation Factors (BAFs) - All residue data are on a dry weight basis
Organism Ambient Cd Exposure Exposure Period Cd Concentration BAF Ref.
Concentration pH in Tissue
Earthworm
0.8 mg/kg
NA
collected
from
wild
4.1 mg/kg
5.1
(1)
Earthworm
6.9 mg/kg
NA
collected
from
wild
34.0 mg/kg
4.9
(1)
Earthworm
15.4 mg/kg
NA
collected
from
wild
107 mg/kg
6.9
(1)
Pillbugs
0.8 mg/kg
NA
collected
from
wild
14.7 mg/kg
18.4
(1)
Pillbugs
6.9 mg/kg
NA
collected
from
wild
130 mg/kg
18.8
(1)
Pillbugs
15.4 mg/kg
NA
collected
from
wild
231 mg/kg
15.0
(1)
Ants
0.8 mg/kg
NA
collected
from
wild
1.2 mg/kg
1.5
(1)
Ants
6.9 mg/kg
NA
collected
from
wild
5.4 mg/kg
0.6
(1)
Ants
15.4 mg/kg
NA
collected
from
wild
37.5 mg/kg
2.4
(1)
Spiders
0.8 mg/kg
NA
collected
from
wild
2.6 mg/kg
3.25
(1)
Spiders
6.9 mg/kg
NA
collected
from
wild
34.5 mg/kg
5.0
(1)
Spiders
15.4 mg/kg
NA
collected
from
wild
102 mg/kg
6.6
(1)
Beetles
0.8 mg/kg
NA
collected
from
wild
0.7 mg/kg
0.9
(1)
Beetles
6.9 mg/kg
NA
collected
from
wild
5.6 mg/kg
0.8
(1)
Beetles
15.4 mg/kg
NA
collected
from
wild
15.1 mg/kg
1.0
(1)
Earthworm
2.9-5.5 mg/kg
6.1
collected
from
wild
62-109 mg/kg
11 to 38
(2)
Spiders
2.9-5.5 mg/kg
6.1
collected
from
wild
16-74 mg/kg
3 to 25
(2)
Earthworm
0.3-1.2 mg/kg
3.5
collected
from
wild
13-38 mg/kg
11 to 126
(2)
Spiders
0.3-1.2 mg/kg
3.5
collected
from
wild
8.8-17 mg/kg
7 to 57
(2)
Earthworm
0.1 mg/kg
5-6
collected
from
wild
4.8 mg/kg
48
(3)
Earthworm
2.7 mg/kg
5-6
collected
from
wild
57 mg/kg
21
(3)
Earthworm
1.14 mg/kg
6.96
collected
from
wild
10.8 mg/kg
9.5
(4)
Earthworm
0.64 mg/kg
6.98
collected
from
wild
7.8 mg/kg
12.2
(4)
Earthworm
0.62 mg/kg
6.88
collected
from
wild
7.2 mg/kg
11.6
(4)
Earthworm
0.88 mg/kg
6.96
collected
from
wild
8.7 mg/kg
9.9
(4)
Earthworm
0.66 mg/kg
6.86
collected
from
wild
3.0 mg/kg
4.5
(4)
References:
1 Hunter et al. 1987a, 1987b 2 Ma et al. (1991)
3 Beyer et al. (1982) 4 Gish and Christensen (1973)

DRAFT
5.0 Risk Characterization
5.1 Exposure Concentration Calculation
Exposure concentrations (dietary and incidental intake of soil)
were calculated for each target receptor species based on: 1) the
documented levels of cadmium in site soils and vegetation; 2) the
predicted levels of contaminants in whole body tissue of forage
species based on bioaccumulation factors; and 3) the receptor
daily food and sediment intake rates as reported in the
literature.
The exposure concentrations were calculated for the receptor
species with following equations:
Dietshrew { ( [soil] x BAF x p:terr. invert) + ( [veg] x p:veg)
+ ( [soil] x p:soil) )
Dletrabbit = { ( [veg] x p:veg) + ( [soil] x p:soil) )
Dietwooacack = { ( [soil] x BAF x p:terr. invert) + ( [soil] x
p:soil)}
Dietq,,ail = ( ( [soil] x BAF x p:terr. invert) + ([veg] x p:veg)
+ ( [soil] x p: soil) j
Where: Diet = Dietary cadmium content (mg/kg)
[ ] = contaminant concentration in a
particular matrix (mg/kg)
BAF = bioaccumulation factor for soils to
invertebrates
p: = proportion of the specified component
of the diet (from section 2.3.1)
invert = terrestrial invertebrates
veg = vegetation
soil = site soils
Calculation for dietary concentrations are detailed below. Three
sets of dietary concentrations are calculated: 1) input
parameters for soil cadmium (15 mg/kg), vegetation cadmium (3
mg/kg) and BAF (11) based on best professional judgement to be
the "average" case; 2) input parameters for soil cadmium (15
mg/kg), vegetation cadmium (9.9 mg/kg) and BAF (48) based on best
professional judgement to be the maximum exposure scenario for
the PCS Phosphate site; and, 3) input parameters for soil cadmium
(21 mg/kg), vegetation cadmium (93.6 mg/kg) and BAF (126) based
18

DRAFT
on the maximum values measured or calculated for each parameter
and defined as the model worst case scenario.
Dietary Calculations with Average Input Parameters (final units
are mg/kg)
Dietahrew = { ( [soil] x BAF x p:terr. invert) + ( [veg] x p:veg)
= (15 * 11 * 0.9) + (3 * 0.1) = 149
note: no incidental soil ingestion rate was available
Dietrabbit = { ( [veg] x p:veg)
(3 * 1.0) = 3
note: no incidental
+ ( [soil] x prsoil) )
soil ingestion rate was available
Dietwoodcock = { ( [soil] x BAF x p:terr. invert) + ( [soil) x p:soil) }
(15 * 11 * 0.9) + (15 * 0.1) = 150
note: 10% incidental soil ingestion rate caused
invertebrate component of diet to be reduced by 10°s
Dietqugiz = { ( [soil] x BAF x p:terr. invert) + ([veg] x p:veg)
= (15 * 11 * 0.25) + (3 * 0.75) = 43.5
note: no incidental soil ingestion rate was available
Dietary Calculations with High Input Parameters (final units are
mg/kg)
Diets,,r�w = { ( [soil] x BAF x p:terr. invert) + ( [veg] x p:veg)
= (IS * 48 * 0.9) + (9.9 * 0.1) = 649
note: no incidental soil ingestion rate was available
Dletrabbit = { ( [veg] x p:veg)
= (9.9 * 1.0) = 9.9
note: no incidental
+ ( [soil] x p: soil) )
soil ingestion rate was available
Dietwoodcack = { ( [Soil] x BAF x p:terr. invert) + ( [soil] x p:soil) )
(15 * 48 * 0.9) + (15 * 0.1) = 650
note: 10% incidental soil ingestion rate caused
invertebrate component of diet to be reduced by lot
Dietq„aii = {( [soil] x BAF x p:terr. invert) + ( [vegl x p:veg)
= (15 * 48 * 0.25) + (9.9 * 0.75) = 187
note: no incidental soil ingestion rate was available
19

DRAFT
Dietary Calculations with Maximum Input Parameters (final units
are mg/kg)
Diet.,.. = (([soil] x BAF x p:terr. invert) + ([veg] x p:veg)
= (21 * 1.26 * 0.9) + (93.6 * 0.1) = 2390
note: no incidental soil ingestion rate was available
Dletwoodcock - ( ( [soil] x BAF x p:terr. invert) + ( [soil] x p:soil) }
= (21 * 126 * 0.9) + (21 * 0.1) = 2380
note: lot incidental soil ingestion rate caused
invertebrate component of diet to be reduced by lot
5.2 Hazard Quotient Calculation
Hazard Quotient = Dietary Exposure Concentration
Lowest Observed Adverse Effect
Level (LOAEL)
A hazard quotient Z 1 when the LOAEL is used in the denominator
indicates that exposure to the contaminant may cause adverse
effects in the organism. A hazard quotient < 1 does not indicate
a lack of risk, but should be interpreted based on the severity
of the effect reported and the magnitude of the calculated
quotient.
HQs based on Average Input Parameters (final value is unitless)
Shrew = 149 / 10 = 14.9
Rabbit = 3 / 10 = 0.3
Woodcock = 1.50 / 12 = 12.5
Quail = 43.5 / 12 = 3.6
20

DRAFT
HQs based on High Input Parameters (final value is unitless)
Shrew = 649 / 10 = 64.9
Rabbit = 9.9 / 10 = 0.99
Woodcock = 650 / 12 = 54.2
Quail = 187 / 12 = 15.6
HQs based on Maximum Input Parameters (final value is unitless)
Shrew = 2390 / 10 = 239
Woodcock = 2380 / 12 = 198
6.0 Sources of Uncertainty
There are various factors which introduce uncertainty into this
evaluation. Wherever possible, an attempt has been made to
acknowledge the uncertainty and to explain the assumptions and
methods employed to manage it. We attempted to provide risk
estimates based on average, high, and absolute maximum model
input parameters. The average and high cases are a best estimate
of the likely risk; the maximum -based risk calculations were made
to drive this risk evaluation towards a conservative, or likely
over -estimation, of risk. These issues need to be considered
when interpreting the results.
Natural variability in the analytical data is expected. There is
not a robust dataset available for total cadmium levels in site
soils, a key parameter in the risk evaluation. The available
data for site soils (Wakefield's TVA dataset) was utilized, but
no statistical confidence limits can be assigned to the estimates
of 21 mg/kg cadmium in clay and 14 mg/kg cadmium in
phosphogypsum.
The variability and incompleteness of the analytical data may
have introduced additional uncertainty into this risk evaluation
when the BAF's were used to project contaminant levels in
terrestrial invertebrates at the site from site soil cadmium
data. It is important to note that these bioaccumulation factors
range over 4 orders of magnitude and are derived from a variety
of soils types and cadmium concentrations. While a robust
21

DRAFT
dataset exists from which to calculate BAFs (Table 1), this
approach is clearly not as favorable as: 1) having cadmium data
directly available for PCS site terrestrial invertebrates; or, 2)
having PCS site -specific BAFs. This is an important source of
uncertainty because the BAF drives the risk evaluation
conclusions in most scenarios (along with the soil cadmium
concentration). Also, BAFs for cadmium availability to
invertebrates will vary among sites as influenced by a soil's pH,
texture, organic matter content, oxidation status (Alloway 1995),
and the concentrations of other elements, particularly zinc and
selenium (Beyer et al. 1982).
Exposure via the ingestion of water and via direct contact with
water was not evaluated due to the absence of relevant analytical
data. Consequently, the bioaccumulation of contaminants via
these pathways was not evaluated. Incidental soil ingestion
rates were not available for all species.
Due to inter -species variability, exposure profile values (i.e.,
receptor life history information) and toxicity values obtained
from the literature may over- or underestimate actual values for
species addressed in this risk evaluation. In addition, toxicity
values reported in the literature are often derived in single -
species, single contaminant laboratory studies. Prediction of
ecosystem effects from laboratory studies is difficult, as
environmental factors and interactions between contaminants can
influence toxic effects. In addition, the use of invalid
assumptions in the conceptual model may also introduce
uncertainty due to error. Therefore, conservative assumptions
were made in light of the this uncertainty, so that any threat
posed by site -related contamination was not underestimated. '
Hence, one set of risk calculations were based on values that
would drive the risk evaluation towards an overestimation of risk
(e.g., highest BAFs, greatest proportion of terrestrial
invertebrates in the diet, and LOAELs).
7.0 Conclusions and Recommendations - to be further developed
o All hazard quotients calculated in the preliminary risk
evaluation based on comparison of projected dietary cadmium
concentrations to LOAELs exceeded 1, with the exception of
average and high parameters estimate -based calculations for
the eastern cottontail.
o Soil cadmium concentrations and a literature -derived
bioaccumulation factor appear to drive the magnitude of the
risk; it would be advisable to develop a more robust dataset
22

DRAFT
for each of these input parameters to establish greater
confidence in the model predictions.
0
IR
8.0 References
Alloway, B.J. 1995. Cadmium. Pages 122-151 IM: B.J. Alloway
(ed.). Heave McMetaIg in --Soils (Second Edition). Blackie Academic
and Professional, New York.
Beyer, W.N., R.L. Chaney and B. Mulhern. 1982. Heavy metal
concentrations in earthworms from soil amended with sewage
sludge. J. Environ. Qual. 11: 381-385.
E.E. Connor and S. Gerould. 1994. Estimates of soil
ingestion by wildlife. J. Wildl. Manage. 58: 375-382.
Cain, H.W., L. Sileo, J.C. Franson and J. Moore. 1983. Effects
of dietary cadmium on mallard ducklings. Environ. Res. 32: 286-
297.
Cooke, J.A. and M.S. Johnson. 1996. Cadmium in small mammals.
Pages 377-388 In W.N. Beyer, G.H. Heinz and A.W. Redmon-Norwood
(eds .) . En r-.ronmenta] .Contaminantg.,,,ia-Wildlife :— Interprptina
Tissue Concentrations. Lewis Publishers, Boca Raton, FL.
Di Giulio, R.T. and P.F. Scanlon. 1984. Sublethal effects of
cadmium ingestion on mallard ducks. Arch. Environ. Contam.
Toxicol. 13: 765-771.
Eisler, R. 1985. Cadmium hazards to fish, wildlife, and
invertebrates: A synoptic review. U.S Fish Wildl. Serv. Biol.
Rep. 85(1.2). 46 pp.
Furness, R.W. 1996. Cadmium in birds. Pages 389-404 IM W.N.
Beyer, G.H. Heinz and A.W. Redmon-Norwood (eds.). Environ ental
Contaminants in Wildlife:__Interpreting Tissue Concentrations,
Lewis Publishers, Boca Raton, FL.
Gish, C.D. and R.E.
zinc in earthworms
1060-1062.
Christensen. 1973. Cadmium, nickel, lead, and
from roadside soil. Environm. Sci. Tech. 7:
23

DRAFT
Hunter, B.A., M.S. Johnson and D.J. Thompson. 1987a.
Ecotoxicology of copper and cadmium in a contaminated grassland
ecosystem: Z. soil and vegetation contamination. J. Appl. Ecol.
24: 573-586.
1987b. Ecotoxicology of copper and cadmium in a
contaminated grassland ecosystem: ii. invertebrates. J. Appl.
Ecol. 24: 573-586.
Leach, R.M., Jr., K.W. Wang and D.E. Baker. 1979. Cadmium and
the food chain: the effect of dietary cadmium on tissue
composition in chicks and laying hens. J. Nutr. 109: 437-443.
Ma, W., W. Denneman and J. Faber. 1991. Hazardous exposure of
ground -living small mammals to cadmium and lead in contaminated
terrestrial ecosystems. Arch. Environ. Contam. Toxicol. 20: 266-
270,
Markland, K.R. 1996. Phosphate mining: past problems and PCS
Phosphate's progeressive solution using the phosphogypsum and
clay tailings blend. Masters Thesis, North Carolina State
University. 137 pp.
Morgan, J.E. and A.J. Morgan. 1988. Earthworms as biological
monitors of cadmium, copper, lead and zinc in metalliferous
soils. Environ. Poll. 54: 123-138.
Page, A.L., A.C. Chang and M. El-Amamy. 1987. Cadmium levels in
soils and crops in the United States. Pages 119-146 In: T.C.
Hutchinson and K.M. Mema (eds.). Lead. Mercury. Cadmium and
Arsenic in the Environment. John Wiley and Sons, New York.
Potter, E.F., J.F. Parnell and R.F. Teulings. 1980. Birdg of the
Carolinas. University of North Carolina Press, Chapel Hill.
Pribble, H.J. and P.H. Weswig. 1973. Effects of aqueous and
dietary cadmium on rat growth and tissue uptake. Bull. Environ.
Contam. Toxicol. 9: 271-275.
Pritzl, M.C., Y.H. Lie, E.W. Kienholz and C.E. Whiteman. 1974.
The effect of dietary cadmium on development of young chickens.
Poultry Sci. 53: 2026-2029.
Richardson, M.E., M.R.S. Fox and B.E. Fry, Jr. 1974.
Pathological changes produced in Japanese quail by ingestion of
cadmium. J. Nutr. 104: 323-338.
24

DRAFT
Suter, G. 1993. Retrospective risk assessment. Pages 311-354 In
G.W. Suter, II (ed.). Ecolog Cal Risk Assessment. Lewis
Publishers, Boca Raton, FL.
United States Environmental Protection Agency. 1993. Wildlife
exposure factors handbook, Volume I of II. Office of Research
and Development, Washington, D.C. EPA/600/R-93/187a. various
page numbering.
Webster, W.D, J.F. Parnell and W.C. Briggs, Jr. 1985. Mammals of
the_Carolinas, Virginia, and Maryland. University of Nort
Carolina Press, Chapel Hill.
White, D.H. and M.T. Finley. 1978. Uptake and retention of
dietary cadmium in mallard ducks. Environ. Res. 17: 53-59.
Wren, C.D., S. Harris and N. Harttrup. 1995. Ecotoxicology of
mercury and cadmium. Pages 392-423 IM D.J. Hoffman, B.A.
Rattner, G.A. Burton, Jr. and J. Cairns, Jr. (eds.). Handbook of
RcQLQxicology. Lewis Publishers, Ann Arbor, MI.
Yocum, S.M., P.C. Darby and P.F. Scanlon. 1987. Effects of
ingested cadmium and lead on ,reproduction of peromyscus leucopus.
Va. J. Sci. 38: 90.
25

Table 1
Soil Test Summary for Beaufort County and Texasgulf
(8521 samples
NCDA-Soil Test
Lab)
LOW
MEDIUM
HIGH VERY HIGH
V. HIGH PLUS
P
0-12.0
13.2-30.0
31.2-60.0 61.2-120.0
>120.0
mg/cdm
1.09%
11.72%
39.76% 30.60%
16.85%
K
0-0.05
0.06-0.13
0.13-0.25 0.26-0.50
>0.50
mq/100 ccrn
0.56%
2.99%
23.50% 59.14%
13.83%
Ca
0-34.9
35.0-44.9
45.0-54.9 55.0-64.9
>65.0
meq/100 ccrn
6.35%
23.46%
34.57% 27.05%
8.56%
Mg
0-4.9
5.0-9.9
10.0-14.9 15.0-19.9
>20.0
meq/100 ccrn
0.95%
11.37%
28.57% 33.58%
25.52%
Mn
0-1.60
1.764.00
4.16-8.00 8.16-16.00
>16.00
-mg/odm
3.29%
60.11%
31.23% 4.30%
1.07%
_.- Zn
0-0.40
0.44-1.00
1.04-2.00 2.04-4.00
>4.00
mg/cdm
0.17%
3.70%
33.77% 37.80%
24.55%
Cu
0-0.20
0.22-0.50
0.52-1.00 1.02-2.00
>2.00
mg/cdm
0.80%
6.94%
45A5% 38.09%
8.71%
Cd
Plant Available Cadmium in Blend
PPm
(Wescott, W.G., 1994)
Total Cadmium conc. in:
Clay
Gypsum
Sand
(Tennesee Valley Authority, Bulletin Y-159)
U.S. Average for Uncontaminated Agricultural
Soil
'
(Holm9ren, G.S., et al., 1986)
L1
NCDA analysis for NCSU
(40 samples at each cfttance X 5 destaaces = 200 samples)
TEXASGULF
1429.4
"+/-" 234.9
1.12
0.23
61.54
"+1--" 10.46
2.84
"+/-" 1.42
4.11
0.78
16.85
"+/-" 2.43
0.92
"+/-" 0.14
5.12
+/-" 1.07
21.0
14.0
6.0
0.27

t ROSERT MIKKELSEN
r
ROBERT MIKKELSEN
METAL IONS IN
BIOLOGICAL SYSTEMS
Edited by
Helmut Sigel
Insfifufe of Inorganic Chemistry
University of Basel
Basel, Switzerland
with the assistance of Astrid Sigel
VOLUME 20
Concepts on Metal Ion Toxicity
• i
' I
r
MARCEL DEKKER, INC. New York and Basel
Copyright ® 1986 by Marcel Dekker, Inc.
J
Metal Toxicity to Agricultural Crops
Frank,T. Bingham, Frank J. Peryea,* and Wesley 14. Jarrell
Department of Soil and Environmental Sciences
University of California
Riverside, California 92521
1. INTRODUCTION
120
2. CADMIUM
121
2.1. Introduction
121
2.2. Forms in Soil
121
2.3. Availability
122
2.4. Cd Toxicity Relative to Cu, Ni, and Zn
132
2.5. Corrective Measures
133
3. COPPER
134
3.1. Forms in Soil
134
3,2. Availability to Plants
.135
3.3. Symptomology and Diagnosis
138
3.4. Corrective Measures
138
4. ZINC
139
4.1. Forms in Soil
139
4.2. Availability to Plants
-141
4.3. Symptomology and Diagnosis
143
4.4. Corrective Measures
144
S. MANGANESE
144
5.1. Forms in Soil
144
5,2. Availability to Plants
145
*Present affiliation: Tree Fruit Research Centex,
Washington State
University, Wenatchee, Washington 99163
'` 119

120• i
BINGHAM, PERYEA, AND JARRELL
5.3.
Symptomology and diagnosis
146
5.4.
Corrective Measures
146
6. NICKEL
147
6.1.
Forms in Soil
147
6.2.
Availability to Plants
147
6.3.
Symptomology and Diagnosis
149
6.4.
Corrective Measures
149
REFERENICES
149
ti I. INTRODUCTION
Trace metals in the geochemical environment may all be toxic if
present at elevated bioavailable concentrations. A number of these
metals are essential for the growth of plants. Obviously, in a
chapter of the length permitted we cannot address all trace metals,
We have therefore elected to discuss five metals —three of�which are
essential for the growth of crops —namely, copper, manganese, and zinc,
and,two that are not considered to be essential, cadmium and nickel.
Copper, manganese, nickel, and zinc toxicities to crops occur
under natural conditions in the form of reduced yields. Although
phytotoxic effects of Cd have been frequently observed in greenhouse
studies, no documented case exists where Cd in soil has reduced the
yields of field -grown commercial crops. Phytotoxicities commonly occur
on crops grown on acid soils and are rare on neutral and alkaline soils.
Industrial uses of the -metals are many and widespread. There-
fore phytotoxicities and excessive accumulation in soils are commonly
observed near point sources. Much of the information on effects of
trace metals in soils on crop growth and composition has been accumu-
lated from soils contaminated by point sources, particularly mining
and smelting operations, as well as the disposal or recycling of
municipal sewage sludges on land.
The following discussion centers on factors influencing the
concentration of available metals in soils for a wide variety of
crop species. Metal uptake and accumulation by plants are dependent
METAL TOXICITY TO AGRICULTURAL CROPS 121
not only upon the concentration of available metals in soil but also
upon the plant species. Phytotoxic concentrations in soils and
plants derived from greenhouse experiments are also discussed,
2. CADMIUM
2.1. Introduction
Cadmium (Cd) is a trace metal that is toxic to both animals and
plants when present at excessive bioavailable concentrations in the
environment. Cadmium also has a tendency to persist in the soil.
Although there are no observations of Cd toxicity (reduced crop
yields) to crop species in the field, Cd is accumulated in plants.
rhus factors influencing Cd availability to food crops are under
intensive study because of the potential hazard to humans consuming
plant food products containing elevated levels of Cd.
2.2. Forms in Soil
"The Cd content of unpolluted soil is closely related to that of the
parent material. The Cd content of the earth's crust averages 0.15 ,
mg/kg. Cadmium concentrations in igneous, metamorphic, and sedimen-
tary rocks range from 0.001 to 1.9, 0.04 to 1.0, and 0.1 to 11,,0 "
mg/kg, respectively. Soils derived from such parent materials con-
tain 0.1-0.3, 0.1-1.0, and 3.0-11.0 mg/kg cadmium [1,2]. Recently
Holmgren et al. [3] summarized the Cd content of 3202 surface soils.'''
(excluding organic soils) collected from the major crop -producing
regions in the United States. They found soil Cd to range from V
0.03 to 0.9 mg/kg, with an average of 0.27 mg/kg.
- The species in soil solutions of acid and cilcireous soils,
respectively, are Cd2% CdCl+, and CdSO40; and Cd2% CdCf`,"CdS040,
and CdHCQ3+. Cadmium does not complex with organic ligands to any
`extent in cultivated soils [4-6). The adsorbed Cd of Cd-treated

12Z , BINGHAM, PERYEA, AND JARRELL
soils varies from 90 to 99% of the Cd added at relatively low rates
,(<20 mg Cd per kg soil) (7).
2.3. Availability
2.3.1. Substrate Concentration and Plant Species
Response to substrate Cd is highly dependent upon the plant species
as well as the concentration of available Cd. Page et al. (8] re-
ported the effect of Cd levels in nutrient solutions on Cd uptake
and growth for a variety of common crop species, rest plants were
established in aerated solution culture tanks containing 100 liters
of a complete nutrient solution. Cadmium, as Cd504, was then added
to the solutions, producing Cd levels ranging from•0.1 to 10.0 mg/
liter. The plants were grown for 3 weeks in the presence of Cd,
harvested, and analyzed for Ieaf Cd content. Table I summarizes the
results. The data demonstrate a strong plant species effect with
respect to threshold concentrations of Cd in solution and uptake as
judged by leaf Cd levels. For example, concentrations '-0.10 mg/liter
reduced growth 25$ for beet' (Beta vulgaris L.), field bean (Phaseo3us
vulgaris L.), and turnip (Brassica raps L.). In marked contrast, a
level of 4.00 mg Cd per liter was required for similar growth reduc-
tion in cabbage (Brassica oleracea L.). These data also show that
no general relationship exists between leaf Cd content and tolerance
to Cd.
Bingham et al. (9) grew a number of agricultural crops in
potted soils using a pH 7.5 sandy loam treated with municipal sewage
sludge enriched with various amounts of CdSO4. The sludge was in-
corporated into the soil at a rate of 10 g/kg soil and the test plants
were grown to the commercial harvest stage. This experiment led to
the ranking of the plants according to their tolerance to Cd, as
judged by yield and leaf Cd levels (Table 2). The addition of 10 mg
Cd per kg soil at pH 7.5 was sufficient to reduce yields of spinach
(Spinacia oleracea L.), soybean (Glycine max L.), and curly cress ,
I
METAL TOXICITY TO AGRICULTURAL CROPS
123
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BINGHAM, PERYEA, AND JARRELL
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METAL TOXICITY TO AGRICULTURAL CROPS
125
(r.epidium sativum L.) by 25% or more. In contrast to these rela-
tively low threshold concentrations, concentrations of �160 mg Cd
per kg soil were required for similar yield reductions in tomato
(Lycopersicon esculentum L.), squash (Cucurbita bepo L.), cabbage
(Br. oleracea L.), Swiss chard (8. vulgaris L.), and wetland rice
(oryza sativa L.). Rice grown in the greenhouse under upland con-
ditions was much more sensitive to soil Cd, with a concentration of
17 mg Cd per kg soil reducing yields by 25% [101.
The effect of soil type on Cd uptake and threshold leaf and
soil Cd levels is shown for eight soils in Table 3 [11). Leaf Cd
data are reported for soil addition rates of 0, 5, 10, and 20 mg
Cd per kg for each soil. Also included are the threshold concen-
trations associated with a 25% decrement in shoot weight_ These
t
TABLE 3
._ —Cadmium Accumulation
by Lettuce
(Lactuca sativa var.
longifolia)
in Relation to Cd
Treatment Rate of Acid and Calcareous Soils
and Threshold
Leaf and
Soil
Cd Concentrations
(25% Yield
Decrement)
Leaf Cd
contenta (mg/kg)
Threshold
Cd
for Cd
rate
(mg/kg) of
level (mg/kg)
Soil series
Soil
pH
0
5
10 20
Leafa Soil
Altamont
4.7
0.6
21
42 64
ISO
60
Hanford
5.0
0.8
19
32 48
200
30
°i
Redding
S.4
0.9
21
40 77
200
100
4.
San Miguel
5.7
0.8
29
50 71
220
160
CL
Arizo
7.4
1.3
42
42 71
90
10
s i
Domino
7.5
0.9
88
88 111
120
50
�, 4a
"
Simona
7.7
0.5
52
52 71
85•
30
Holtville
7.7
3.0
62
62 99
65
10
„
..
aDry weight
basis.
Source. Adapted from
Ref. 11.
h 7
m h
1

126 BINGHAM, PERYEA, AND JARRELL
METAL TOXICITY TO AGRICULTURAL CROPS 127
data show leaf Cd.values for the 10 mg Cd per kg soil treatment,
ranging from 32 for the Hanford soil to 88 for the Domino soil.
Threshold leaf Cd values ranged from 65 to 220 mg/kg, with the
higher values being observed for plants grown in the acid soils.
The threshold soil Cd rates (associated with a 25% yield depression)
were also quite variable, with values varying from 10 to 160 mg/kg
soil. These data clearly demonstrate that diagnostic criteria for
Cd toxicity are highly dependent upon the crop species as well as
upon soil type.
The experience with Cd availability under field conditions
indicates that for a given application rate, Cd uptake by the test
plant is not as great as that observed with pot tests [12]. With
potted soils, the plant extends its root system throughout the soil
volume treated with Cd. In the field, root systems probably extend
beyond the depth of soil treated with Cd; consequently, the field -
grown plants absorb less Cd. The long-term field experiment con-
ducted by Chang et al. [13) showed that the Cd content of barley
(Hordeum vulgare L.) increased according to the annual addition rate
of Cd added as sewage sludge, but not according to the cumulative
rate.' Over the 6-year period of sewage sludge additions, a total of
50 kg Cd per hectare was applied, yet the Cd uptake was minimal
(<O.l mg Cd per kg grain on a dry weight basis) and, as expected, no
yield depression occurred. In the midwestern part of the United
States Jones et al. [14] followed Cd uptake by corn (Zea mays L.)
grown in small plots treated with different amounts of sewage sludge
each year for several years. The highest leaf Cd value was 28 mg/kg
leaf material (dry weight basis); however, no reduction in yields
occurred. They found leaf Cd concentrations to parallel the annual
Cd addition rates but not the cumulative rates. Additional details
on Cd availability in these plots were published by Hinesly et al.
1151. Additional information on the availability of sludge -borne
Cd under field conditions is presented in the review paper by Soirmers
[16].
Observations of the availability of native Cd in soils to vege-
table crops are limited. Lund et al. (17] assessed Cd availability
in seven uncultivated soils using several crop species. The 4 Y HNO3
extractable Cd varied from 0.02 to 22 mg/kg soil and leaf Cd values
for Swiss chard (B. vulgaris var. ciela) varied from 0.6 to 82 mg/kg
leaf material (dry weight basis). The correlation between leaf Cd
and soil Cd (r = 0.92) was highly significant.
Cadmium in soil solution of acid soils exists as Cd2+, CdCI+
and CdSO40, and in alkaline soils as Cd2«, CdCl+, CdSO40, and, to a
lesser degree, CdHCO3+. The Cd2' species accounts for 80-90% of the
total Cd in solution, except in soils which have been salinized with
C1 and SO42 salts. Under saline conditions the CdCI+ and CdSO40
,,,species a count for p o 50% of the total Cd [5,6].= The Cd avail-
able to Swiss chard (B. vulgaris var. cicla) correlated better with
the Cd2+ activity in soil solutions than with total soluble Cd or
free -ion and•ion-pair concentrations [5,6]. Thus assessment of the
availability of Cd, and undoubtedly other metals, could be refined
by chemically speciating trace metals In solution_ We have found
the GECCHEM computer program [18] to be satisfactory for speciating
....Cd, with the calculated Cd2+ concentrations corresponding to concen-
trations measured with the Cd-specific ion electrode [19].
2.3.2. Soil ,pH
In general, Cd uptake by plants is greatly reduced upon liming an
acid soil. The resulting increase in soil pH reduces the solubility
of Cd in the soil solution, as well as the bioavailability of soil
Cd [6]. Liming a Cd-amended Redding sandy loam increased the pH from
4.0 to approximately 7.0 and.reduced soluble Cd in the soil from 0.15
to 0.0035 mg/liter. Leaf Cd contents of Swiss chard (B. vulgikis var:
cicia) grown in the unlimed and limed soil treated at equivalent Cd
rates were, respectively, 74 and 8.5 jig Cd per g soil. Similarly,
rice (o. sativa L.) under "flooded" management (paddy) showed' reduc-
tions in Cd uptake with increasing pH (20]. Figure 1 illustrates the
relationship between Cd treatment rate for the Redding sandy soil at
various pH levels and the Cd contents of rice grain_ Wheat (Triticum
aestivum L_) also demonstrated less Cd uptake upon liming of the Red-
ding sandy loam [21]. Reduction in Cd availability Sue to liming

128 BINGHAM, PERYEA, AND JARRELL METAL TOXICITY TO AGRICULTURAL CROPS 129
2.0 4.0 6.0 9.0 10.0 120 14.0 16JD
Cd ADDED -mg Cd kg"
FIG. i_ Predicted content of Cd in rice grain in relation to soil pH
and soil Cd of plants grown in the Redding sandy loam treated with
Cd ± lime and maintained under flooded conditions. (Adapted from Ref.
20, by permission of the Williams and Wilkins Co., Baltimore, Maryland
under field conditions has been discussed by Chaney et al. [221,
the Council on Agricultural Science and Technology [23], and Hyde
et al. [24] for soybean (G. max L.), Swiss chard (B. vulgaris), oats
(Avena sativa), wheat (T. aestivum), and corn (Z. mays).
The negative effect of increased pH on Cd availability is due
-in part to reduction of Cd solubility in the soil solution phase.;•
Mahler et al. [251 compared Cd uptake by lettuce, corn, tomato,
sweet corn, and Swiss chard grown on four acid and four calcareous
soils according to the concentration of Cd in soil solution (Fig. 2).
Cadmium uptake as a function of the Cd concentration in soil solution
was decidedly higher for plants grown in the acid soils. Root acfiv-
ity influencing Cd absorption may have been stimulated by the lower
pH conditions. The greater uptake rate could not be explained upon
the basis of the chemical speciation [251. Additional details of
the negative effect of increased pH on Cd availability are contained
in recent reviews [1,2,16,26,27].
LETTUCE
7
�b
CHARD
i
i
P
CORN
o ACID SOILS
• CALCAREOUS SOILS
0 2 4 6 e 10 0 2 4 6 a IQ
SATURATION EXTRACT CADMIUM CONCENTRATION mg Cd 1-'
FIG. 2. Cd concentration in shoots in relation to Cd concentration
of saturation extracts of 4 acid and 4 calcareous soils. (Adapted
from Ref. 25, by permission of the Am. Soc. of Agronomy, Crop. Sci.
Sac. of America, and Soil Sci. Sac. of America).
2.3.3. Cation Exchange Capacity
The U.S. Environmental Protection Agency recommends disposal rates
for sewage sludge containing more than 2 mg Cd per kg on soils with
PH values above 6.5 according to the cation exchange capacity (CEC)
of the receiving soil [28]. For soils with CEC values of <5, 5-15,
and >15 m£q per 100 g the corresponding limits are 5, 10, and 20 kg
Cd per hectare. John et al. [29) compared the bioavailability of
Cd in 30 different potted soils treated at a rate of 10 mg Cd per
kg, using radish (Raphanus sativa L.) and lettuce (Lactuca sativa L.)
as indicator plants. They found the ability of soil to adsorb Cd to
be the most effective parameter reducing Cd availability as judged
by Cd uptake of the test plants. Haghiri [30] removed organic matter
from a single test soil and then added different amounts of muck to
produce a range of CEC values for the soil -muck mixtures. The pH -
r,

130
BINGHAM, PERYEA, AND JARRELL
values of the mixtures were held constant at 6.5. The availability
of Cd added as CdCl2 was determined by a short-term pot experiment
using oats (A. sativa L.) as the test plant. The concentration of
Cd in the shoot was negatively, correlated with the CEC at a given
Cd treatment rate. Miller et al. [31] found that the availability
of Cd to soybeans (G. max L.) decreased with increasing CEC in nine
soils amended with equivalent rates of CdC12. In contrast to the
above findings, Mahler et al. (11) did not detect a consistent CEC
effect on Cd availability using Swiss chard (B. vulgaris) or Romaine
lettuce (L. sativa) as test plants for eight acid and calcareous
soils treated with sludge pretreated with CdC12. Hinesly et al.
[32] carried out a pot experiment with nine soil mixtures having a
range of CEC values (5-15 mEq per 100 g) and treated with sewage
sludge at a rate equal to 10 mg Cd per kg or with CdClz at the same
Cd rate. Corn (Z. mays L.) was used as the indicator plant, with
Cd uptake taken as the index of Cd availability.' Cadmium uptake was
inversely related to the CEC with soil mixtures receiving CdC12.
However, Cd uptake was not influenced by the CEC with soil mixtures
treated with sewage sludge containing Cd. The conflicting observa-
tions of CEC affecting Cd availability point to the need for further
research.
1.3.4. Redox Potential
Increased availability of soil Cd to rice plants growing in paddies
was directly related to the number of days that the paddies were
drained prior to harvesting the crop (33,341. This observation
,suggested that, Cd solubility, and hence availability, was strongly
dependent upon the redox potential of the soili Reddy and Patrick
[3S] conducted a Short-term experiment with rice seedlings growing
in soil suspensions having controlled levels of redox potential and
PH to demonstrate their combined effect on Cd solubility and avail-
ability. Decreasing the redox potential from 400 to -200 mV greatly
decreased the solubility and availability of Cd in soil suspensions
.adjusted to different pH levels Fig. 3).
METAL TOXICITY TO AGRICULTURAL CROPS
rl,
n:
r
iQ
A pH 5
0 pH 6
2.5
• pH 7
Zp
w PH B
I.5
1.0
a5
REDOX POTENTIAL. mV
FIG. 3. Effect of redox potential and pH on Cd uptake by rice
plants and an the Cd concentration of the soil -water suspension.
(Adapted from Ref. 3S, by permission of the Am. Sac. of Agronomy,
Crop Sci. Sac. of America, and Soil Sci. Sac. of America).
131
Bingham et al. [10] also demonstrated the marked effect of
redox potential on Cd solubility and availability to rice plants by
growing rice in flooded (paddy) and nonflooded (upland) soil treated
with low to excessive amounts of Cd. A 25% decrement in grain pro-
duction was associated with soil Cd treatments of 17 and 320 mig/kg
soil, respectively, for the nonflooded and flooded management sys-
tems (Fig. 4)f The concentrations of Cd in the soil water phase
(saturation extracts of soil with water) of soil treated at the 17 mg
Cd per kg soil rate were, respectively, 0.003 and 2.01 mg Cd per liter
for the flooded and nonflooded systems. both leaf and grain contained
lower concentrations when rice was grown under flooded conditions. s

132
BINGHAM, PERYEA, AND JARRELL
METAL TOXICITY TO AGRICULTURAL CROPS
133
c �
B0- - - - - - - - - - - - - - - - -
o60 �� I
• FLOOD
} • NON FLOOD
a 40 ! \ 1
0 I \ ! -
t
2I �\\
0 I
I \ I
1
0
10 20 40 80 160 320 640 .
SOIL Cd — mq k9-1
FIG. 4. Grain yield of rice grown under flooded and nonflooded
conditions in relation to soil Cd concentration. (Adapted from
Ref. 10, by permission of the Am. Soc, of Agronomy, Crop 5ci. Soc.
of America, and Soil Sci. Soc. of America).
Chemical analysis of soil water collected at harvest time from
the flooded and nonflooded soil pots showed SO42- to be at a nonde-
tectable range (<i.0 mg/liter) under flooded conditions and ranging
up to 14.2 mg/liter under nonflooded conditions. The lack of SO42
,under low redox conditions suggests that Cd precipitated as CdS and
was thus less available to rice. However, the increased Mn2+ and
.Fe2+ concentrations associated with flooded soils may have also
` curtailed uptake of Cd by the plant [35].
2.4. Cd Toxicity Relative to Cu, Ni, and Zn
Our laboratory group has tested the phytotoxicity of Cd, Cu, Ni, and
Zn alone and in combination with acid.and calcareous soils. For
example, Mitchell et al. [36] investigated the phytotoxicity of
these metals individually by incorporating a sewage sludge (lit addi-
tion rate) enriched with low to phytotoxic,amounts of CdSO4, CUSO41
NiSO4, or ZnSO4 in an acid soil as well as a calcareous soil and
growing lettuce (L. sativa L.) and wheat (T. aestivum L.) to matu-
rity. Depending on the soil and plant species, they found Cd to be
2-20 times more toxic than the other metals. In general, the order
of toxicity was found to be Cd > Ni > Cu > Zn.
Interactive effects of these metals were evaluated in pot
tests with wheat as the test plant for an acid soil with factorial
treatments of metals with and without liming [37]. Wheat grain
yield (Y in g/plant) for the acid soil was found to be related to
metal additions (mg/kg soil) as follows;
Y = 3.71 - 0.0036(Zn + 1.4 Cu + 2.1 Ni + 4.0 Cd)
This shows Cd to be approximately four times more toxic than Zn.
Under limed conditions only Cd and Cu were phytotoxic at the levels
tested (up to 80 mg Cd per kg, 200 mg Cu per kg, 80 mg Ni per kg,
and 200 mg Zn per kg). Under these conditions Cd was 4.5 times more
toxic than Cu.
. -Relative toxicity coefficients are used to estimate the "zinc _
equivalent" [37-41] or the potential toxicity of metals to agricul-
tural crops cultivated on soils with pH values of at least 6.5.
Accordingly, toxicity is probable when the sum of Zn + 2Cu + 8 Ni
(mg/kg soil) exceeds 250 mg/kg for soils with pH values of at least
6.5. Cadmium could be incorporated into the Zn equivalent expres- .
sion provided that its toxicity coefficient was established. How-
ever, metal toxicities vary according to certain soil properties,
pH, for example, and plant species. Consequently, the zinc equiva-
lent, or.metal toxicity coefficient for that matter, should be used
judiciously. The toxicity of these metals added to soil would
increase under acid soil conditions.
2.5. Corrective Measures
Cadmium is quite immobile in soil and when materials. containing. Cd
are applied to the soil surface, essentially all of the Cd applied.

13 BiNGHAM, PERYEA, AND JARRELL
METAL TOXICITY TO AGRICULTURAL CROPS - 135
remains in the depth of incorporation. Means to decontaminate this
layer include removal of the contaminated layer, removal of tha Cd.
from the layer, or covering the contaminated layer. Cadmium can be
complexed with commercially available cheiate — for example, ethylene-
diaminetetraacetic acid (hDTA)--and leached below the root zone.
Although this procedure has been used successfully'in Japan, it is
expensive and may lead to contamination of the goundwater. Removal
of the contaminated layer or covering the layer with noncontaminated
soil is also effective, but the costs may be prohibitive.
Techniques to minimize the amount of Cd which may enter the
human food chain from contaminated soils include growth of nonfood
chain crops, growth of crops used exclusively as animal feed and
that absorb relatively small amounts of Cd, and growth of crops
.which make up only a small percent of the human diet. In general,
crops grown on acid soils absorb more Cd than crops grown on neutral
or calcareous soil. Therefore, liming acid soils to increase the
soil pH is an effective means to reduce the amount of Cd absorbed.
3. COPPER
3.1. Forms in Soil
Naturally occurring copper minerals in soils include oxysulfates,
carbonates, phosphates, oxides, and hydroxides. Copper sulfides may
form in poorly drained or submerged soils where reducing conditions
exist. Copper minerals are normally too soluble to persist in freely
drained agricultural soils [421. In metal -contaminated soils, how-
ever, the chemical environment may be controlled by nonequilibrium
processes that lead to the accumulation of metastable solid phases'.
Recent evidence suggests that covellite (CuS) or chalcopyrite
(CuFeS2) may exist as thermodynamically stable minerals in both
oxidized and reduced Cu-contaminated soils (43).
Trace amounts of Cu occur as discrete sulfide inclusions in
silicates and isomorphously substitute fof structural cations in
phyllosilicates [441. Charge -unbalanced clay minerals nonspecif-
ically adsorb Cu while oxides and hydroxides of Fe and Mn demonstrate
high specific Cu affinity [45). High molecular weight organic com-
ponents act as solid adsorbents; low molecular weight organic mate-
rials tend to form readily soluble Cu complexes [46].
The compositional complexity of soils limits the ability to
quantitatively partition total soil Cu into unambiguous chemical
forms. Sequential extraction procedures indicate that the bulk of
nonstructural Cu resides in organic matter and in Mn and Fe oxides. .
Readily soluble and exchangeable Cu, considered the forms that are
available for plant uptake, typically comprise less than 5e of total
soil Cu [47,49]. Application of Cu-containing sewage sludge or
inorganic Cu salts enhances the concentrations of soil Cu that are
extractable by milder reagents (49,501, suggesting that Cu may exist
in more labile chemical forms in Cu-polluted soils.
Uncertainties in thermodynamic equilibrium constants and lack
of experimental techniques have restricted precise determination of
Cu speciation in soil solutions- In the system Cu-0O2-H2O the pre-
dominant soluble species shifts from free ionic Cut+ to CuCO3D to
Cu(OH)20 with increasing pH. Free ionic Cu occurs as the hydrated
ion [Cu(H20)612+ and commonly forais coordination complexes by ligand
substitution of the aquo groups (511. The preponderance of soluble
Cu in soil solutions occurs in organic complexes [52,53], although
free ionic Cut+ may be significant at low soil pH values [45]-.
Copper solubility is enhanced under acid conditions and normally
decreases under reducing conditions [54]. The solution species and
oxidation states are largely determined by the stabilizing effects
of complexing ligands [511.
3.2. Availability to Plants
Root absorption of soil solution Cu is the primary means by which
Cu enters plants. Hydroponic experiments demonstrate that plant
tissue concentrations, total uptake, and toxicity symptoms of Cu
}a

24 '
t
a covalent non -polar substance. When X is SO4- or NO3, the substance is ionic in char
ter._Dialkyls and diaryls are non polar, volatile, toxic, colorless liquids. Biological methyl I
ation of mercury or its compounds gives highly toxic (CH3)2fl9 or CH31-19+.
Practically all the organometalbe compounds of germanium, fin and lead are form i
in the oxidation. state +4. Of toxicological interest are only lead and tin compound
particularly (CH3)4Pb and (C2H5)4Pb and dialkyl and Walkyltins wluch have a vatic
of industrial and other uses.
Examples of the third category of organometallic compounds are rls-cyclopentadien +++'
such as (C,H5)2Fe_ (fits indicates that five carbon atoms are bound to the metal, and ;+�}
pronounced 'pentahapto'.) This type of compound is shown below:
1
Fe Mt1n
C Co
� p
Ferrocene qs-Cyclopentad ienyl-Mn-tricarbonyl
Of potential toxicological importance are the cyelopentadienyl-manganese-tricarbon
(t25-05l-ls)N1n(C0)3 and its methylated analog, methylcyclopentadienyl•manganes
tricarbonyl (MMT), which has been considered as a replacement for lead tetraethyl as l
antiknock agent.
4 Solubility
The solubility of metal compounds in water and in. lipids is of great toxicological i
portance because it is one of the major factors influencing the biological availability a
absorption of metals. The solubibty of metal compounds in water depends on 1
presence of other chemical species, particularly H* ions (pH), and so it may be quite, c
feient depending on whether the solvent is 'pure' water or a biological fluid. Mologi
fluids are slightly alkaline in mammals (pH 7.4), with the exception of the fluids in 1
gastrointestinal tract which are acid (pll 2-6) in the stomach and almost neutral (pH 6
in the intestines. In addition, biological fluids may also contain a variety of orga.
ligands which exert a further influence on the solubility. Experimental data on the so
bjhty of metal compounds in biological fluids are very limited.
In spite of the mentioned differences, there are some simple rules governing the so.
bitty of metal compounds in water which may be a useful indicator for the solubility
these compounds in biological fluids.%A simple rule, used in chemistry, divides vario
substances into 'soluble' and 'insoluble'. 'Soluble' substances are those which have a so]

DR- or NO3, (lie substance is ionic in chat
e, toxic, colorless liquids. Biological metl
dghly toxic (Cli3)2iig or CIi3Flgi.
rids of germanium:, tin and lead are four
interest are only lead and tin compour
iatkyl and trialkyltins which have a vari
metallic cnrnpounds are Ti'-cyclopentadien
rbon atoms are bound to the metal, anc
z)und is shown below:
s
r
Mn
C CO
O
yelopen t sd i ertyl-ht n-t rica rbo riyf
ie cyclopentadienyl-manganese-tricarboi
ralog, methylcyclopentadienyl-mangane
d as a replacement for lead tetraethyl as
and in lipids is of great toxicological I
rs influencing the biological availability a
tat compounds ,in water depends on I
ly H+ ions (pl i), and so it may be quite c
)ure' water or a biological fluid. Biologi
4), with the exception of the fluids in t
in the stomach and almost neutral (pH 6
'ids may also contain a variety of organ
solubility, Experimental data on the sot
ire very limited,
s are some simple rules governing the sol
y be a useful indicator for the solubility
le rule, used in chemistry, divides vario
)le' substances are those which have a sol
2s
water >1 g/100 ml; `insoluble' are those which have a solubility C0.1 g/100 mi.
'1':,,, .I:;linction may not be meaningful if a substance is highly toxic. Within each group
r�eriodic system the solubility of metal compounds generally decreases with
atomic numbers.
11;'My'soluble,metal compounds,are nitrates, acetates and all.chlorides,bromides and
rodi+t i,ept those of silver, mercury(I) and lead.'Allrsulfates,lexcept those of barium,
and lead are also soluble. All salts of sodium, potassium and ammonium are
_-:ccpt sodium antimonate, potassium hexachlnroplatinate and potassium cobalto.'
� 5
Imtl'i: �
}' "rtrhsoluble' are all hydroxides (except those of alkali metals, ammonium and
";ld - ;ill normal carbonates and phosphates (except those of alkali metals and am•
and sulfides (except those of alkali metals, ammonium and the alkaline earth
i.: , ,iition to the factors mentioned above, such as pH, the presence of other ions,
�t•: `::rkibty may depend on the oxidation state of a metal, and on the rate of oxida-
iit':� conversions(see Section 5.2).
s' �,; lubihty of sparingly soluble substances will also depend on their particle size
tin Si'diled material is usually more soluble.
4 i'r! tjl,rties of metal ions
`• I r ,-;rmation of metal ions
SlciA i)r;s are formed by the removal of one or more outer electrons from the neutral
-tunm. The energy required for the ion formation depends on the environment in which
!Iris process takes place. The formation of ions in the gas phase requires a considerable
aII"ount of energy. The same process requires much less energy if it takes place in water
``ecause a part of the ionization energy is provided by the energy of hydration, i.e. the
energy that is gained when a positively charged metal ion binds dipolar water molecules.
I'llc number of water molecules that are bound directly to the metal ion (first hydration
",•here) depends on the size and the charge of the metal ion, and varies from 4 for Li+ to
about 10 for Ra'*. Because there is further polarization of water molecules contained in
tine first hydration sphere, additional water molecules will be attracted to form a second
hydration sphere. This association can, of course, continue but its extent decreases
rapidly with distance from the ion. The size of the hydration sphere will obviously
depend on the polarizing power of the ion which in turn depends on the charge/radius
111i0, Tire hydrated ion Is a dynamic system in which water molecules in the hydration
sphere rapidly exchange with those in the bulk phase of the solution.
5•= Rerlox potentials
111e removal of electrons from metal atoms is an oxidation process. The reverse process is
called reduction. Oxidation and reduction processes are always coupled, Le. when one

40
graph which has a monochromator that separates the emitted radiation according to wave.
lengths (i.e. tire energy of photons). A spectrum is obtained and a very wide range of
metals can be more or less quantitatively determined. Atomic emission spectrometry Is
especially useful for multi -element analysis, e.g. for soil analysis, geological surveys, ett;
It was used by Tipton and coworkers (1963) in extensive investigations on the metal con.
tent In different' organs of the human body, but accurate data could not always be ob.'
twined. Atomic emission spectroscopy is also used in the metal industry for the quail "
control of products. In many industries spectroscopic equipment is also used for monitort
ing the exposure of workers to such metals as lead and cadmium. Emission spectrometric
methods are not suited to the determination of easily volatile substances like selenium;
arsenic or mercury.
The standards and the samples to be analyzed must have matrices of the same comp;;
sition, since the intensity of the emissions can be affected by the matrix. The electrical
discharge sources may vary. For example, the DC arc source does not give a better preci-
sion than about 20%. The DC arc enables, however, a low detection limit. Other spark
sources may give a better reproducibility, but a higher detection limit. For the best type:
of equipment, the cost is very high.
Atomic absorption spectrometry The basic principle behind atomic absorption spectrom-':
etry is that metals in the ground state will absorb radiation from a light beam with dial
same spectral composition as the light emitted by the element under consideration. Cad"
x
mium atoms thus absorb radiation from light emitted by a cadmium lamp. The decrease7�
In intensity as compared to a blank corresponds to the concentration of the metal. Theret
are two main methods for atomization of a sample, the flame method and lire furnace
method, the latter also being called electrothermal atomic absorption. The flame methods
use different mixtures of gases for creating a high -temperature atomization flame, e.g.
air —acetylene. Different types of flames may be used for different metals. Flame methods
are generally used for liquid samples which can be aspirated directly into the flame. An..
Important modification is the technique developed by Delves (1970) where a small
amount of a liquid sample, e.g. blood, is put into a microcrucible made of nickel and then
inserted in the flame. During the last years, the Ilanietess methods have rindergone a rapid
development. Most common Is the graphite tube furnace. The principle is that after:
drying in the furnace, the temperature is raised to atomize the sample whicli then passes.
through the light path. Several milliliters of solution must be used in the conventional
flame method, while only 1-100 µl need be applied to the furnace. The standard solu-
tion, preferably In a similar matrix, is treated in the same way. Atomic absorption spec-11
trometry has found a number of applications and has been especially useful for the
determination of lead, cadmium and mercury In biological materials aad in exposure.
media as well as for the determination of many essential elements, e.g. copper and An
Recently methods have also been developed for nickel and arsenic In different media.
Special modifications are required for highly volatile metals such as mercury and arsenic.
One limitation is that atomic absorption is not suited for multi -element analysis. Also,
'i
some non-specific absorption may occur due to the presence of other atoms and mole-
cules; in the flame. Salts such as sodium chloride and phosphates are especially apt to

357
itions in air around 50-100 pg/m3 has I
;.possible (Harvey et al., 1975) to demonstrate elevated liver levels of cadmium. The sensi-
•rs. In the general population the main
tivily has been increased and at present about 16pg Cd/g wet weight in kidney and 1.8
imated that long-term exposures with
po Cd/g wet weight in liver can be detected (Vartsky et al., 1978). The radiation dose
vsfunction. This estimate was based on
From one measurement, is low (gonad dose <40 mrem; Vartsky et al., 1978). Further
al excretion of cadmium were used, a
development of this method has brought about portable equipment for field use.
:is is in accord with estimations based
The usefulness of newly developed electrochemical methods, such as anodic stripping
concentration in sensitive individuals i;
v,3ltammetry, for determination of cadmium in biological material is difficult to evaluate
mal cortex. WHO (1977) has recently
as present.
and 300 mg/kg with 200 mg/kg being _
Atomic absorption spectrophotometry is the most common method for the determina-
3 '
tnn of cadmium to date. By flameiess AAS methods, about 5 pg/kg can be accurately
n early stage, clectrophoretic examina-
6,Jermined in foodstuffs (Kjellstrbm et al., 1974) and even lower levels can be deter -
ow -molecular -weight proteins must be
Mined in urine (Elinder et al., 1978) and blood (L lander and Axelsson, 1974)' �lowevei
n does not regress, even if exposure ]
ii:tcrference of salts (e.g. Na salts), may cause inaccuracies if appropriate precautions artk'
is no specific therapy for chronic cad- t#
r• d taken (Pulido et al., 1966),'In blood, values well below 1 pg/I have been accurately,
kinst the metabolic disturbances. i,
determined (Stoeppler and Brad*dt, 1978).
avironmental aspects of cadmium has '�
in the past and even into the present, a substantial amount of published data has been
1975), CEC (1978), Fulkerson et al.
based on inadequate methods. Errors, with values 10-100 times too high, have been
J
seen with regard to both emission spectroscopy and atomic absorption specirophoto-
1
nnctry (Fulkerson et al., 1973; Fribcrg et al., 1974; WHO, 1979).
4 Production and uses
nber 48; density 8.6; melting point
xagonal, silver -white malleable metal; _
4.1 Production
mentioned are cadmium acetate, cad-
_
,crate, cadmium oxide, cadmium car-
N
0tdmium displays chemical similarity to zinc and occurs together with zinc, the cad-
)f the •man y inorganic cadmium com- ,
mium :zinc ratio in minerals and soils being 1 : 100 to 1 : 1000. Cadmium is obtained as
cetate, chloride and sulfate. Cadmium jy.;:
a by-product from the refining of zinc and other metals, particularly copper and lead.
easily complexed with some organic 'y,
11iere is no specific cadmium ore worth mining solely for its cadmium content. The world
fishing the basis for several analytical
production of the metal in 1970 was 16 000 tons. It had increased yearly by 14% during `s '
compounds, but these have not been -�
the preceding five years. C7nly a very minor part of this world production is recycled, thus
dly decomposed. iT,
cadmium has been named 'the dissipated element' (Fulkerson et al., 1973).
Although cadmium has been recognized for only a relatively short period of time, '
environmental pollution has taken place for several thousand years, ever since man started
If
to produce metals from ores which happened to contain cadmium. '
,ly for the analysis of cadmium and '
4.2 Uses
irately (Smith et al., 1955). Emission 4
y and accuracy for cadmium. Modern .` i'
Cadmium is used in a number of industrial processes. Because of its ability to protect Iron
it 50 ng (Imbus et al., 1963). ' ' --i
items from rusting, it is used for coating such items by electroplating. Cadmium -plated
;d as an accurate method, but has not
parts for automobiles and the like are more resistant to rust than zinc -coated (galvanized)
bstrand. 1960; Unnman et al., 1973).
objects. Cadmium sulfide and cadmium sulfoselenide are used as color pigments In plas-
,ls in liquids such as urine with this_ ..
tics and in various types of paint. Cadmium stearate is used as a stabilizer in plastics.
atfon of cadmium in liver by neutron
Because of its ability to stiffen copper and increase its mechanical resistance at Increased
In cadmium -exposed workers it was '
temperatures, cadmium is used in copper —cadmium alloys, which are used for such items
t5
i€r�Js

Reclamation of Heavy Metal —Contaminated Soils: T'ielo Studies and
Germination Experiments
Gabriella Geiger, P, Federer, and H. Sticher*
ABSTRACT
Field studies and germination experiments have been performed to
assess the fertility restoration by different reclamation procedures on
heavy metal —polluted lolls. In a contaminated area In Switzerland we
have investigated the metal accumulation or lettuce ILacruca sadva i..,
'Apollo') tin four different experimental plots: Fl was untouched, 1172
was plowed, on F3 the highly contaminated litter was removed, and
on F4 the surface layer was removed and replaced with uncontami-
nated soil. The metal content in plant tissue decreased from F1 over
F2 and F3 to F4. The lecture grown on F4 had normal metal tissue
concentrations (Cd, 0.92 mg/kg; Cu, 28 mg/kg; Zn, 87 mg/kg) whereas
tissue concentrations on the unfilled plot FI were strongly elevated
(Cd, 6.1 mg/kg; Cu, 57 mgjkg; Zn, 864 mg/kg). Growth chamber
experiments served to test the suitability of different soil substrata for
plant development. We have studied the germination and growth of
cress (1.opidium salivu,n L.) and lettuce on different heavy metal —
polluted media and observed that the structure of the litter is the main.,,
.reason for poor development of the seedlings We conclude thal'fromil' '
the reclamation procedures considered; only therreplacemea of the
highly contaminated topsoil will lead to good-germinatl4h, norms)
plant development, and heavy metal contents essentially bcluw all
toxicity limits.
�+
SEVERr- anthropogenic pollution of surface soils can
originate from heavy emitters of airborne particles.
Major problems result from old smelters and foundries
that emitted heavy metals over several decades. The pol-
Iution may present immediate danger to people living in
the neighborhood of such plants. Nowadays, air regu-
Iations in most countries have been tightened to eliminate
the primary risks. However, the regulations fall short of
resolving the problems associated with the large amounts
of heavy metals accumulated on the soil surface and in
the near subsurface zone (Slrojan, 1978). Serious prob-
lems arise for agriculture and gardening near polluted
sites. Growing plants may accumulate heavy metal in
their tissue in such concentrations that their use as food
for humans or animals becomes questionable:'
Because of such problems with heavy metal —polluted
sites, different decontamination or reclamation proce-
dures have been suggested to minimize the danger of
slow poisoning of the inhabitants and to restore the soil
fertility for agricultural plants. One method consists in
immobilizing accumulated heavy metals through addi-
tion of a nontoxic compound such as lime, iron sulphate,
cation exchangers; organic matter, or clays such as ben-
tonite (Czupyrna et al., 1989). A second method at
tempts to dilute the contaminants in the uppermost soil
layer by a deep plow down to 80 cm (KOster and Merkel,
1985). A third method suggests the replacement of the
upper soil layer.with unpolluted soil (Asami, 1984). Fi-
nally, other methods propose washing of the soil with
complexing solutions or cultivating metal -accumulating
plants (Kosler and Merkel, 1985). All treatments have
All authors, Inst. of Terrestrial Ecology, Swiss Federal Ins(. of
Technol., Grahenstrasse 3, 8952 Schlieren, Switzerland. Received
2 Mar. 1992. `Corresponding author.
Published in J. Environ. Qual. 22:201-207 (1993).
their merits and specific problems, such as costs, deg-,
radation of the soil structure, 'decrease of soil fertility,
and unknown longlime'effects.
Since decontaminating a particular s�e is usually an
expensive task, it should be possible to Auate its suc-
cess beforehand. Depending on the use of the land, soil
type, and the occurring heavy metals, different proce-
dures might be appropriate. `.�
Consider the common heavy metals that show quite
different behavior in soils and may have produced dif-
ferent physiological effects. The main toxic effects are
disturbances in photosynthesis, functions of the stomata,
respiration, and biomass production (Larcher, 1984;
Fouroughi et al., 1982), which may lead to substantial
growth inhibition. Dry tissue concentrations of 40 mg/
kg Cu, 400 mglkg Zn, and 5 mg/kg Cd have been re-
ported as toxicity limits (Amberger, 1979; Sauerbeck,
1985). The amount of metal taken up by the plants de-
pends on the metal content of the soil, but is strongly
influenced by other factors'such as plant species, soil
parameters (pH in particular), and the kind of metal itself
(Friichtenicht and Vetter, 1982). Copper tends to be very
strongly bound to soil organic matter and is mainly non- .�
toxic to plants. However, Cu is accumulated in plant
roots, where it hinders the uptake of essential nutrients
and thus retards plant growth (Brams and Fiskell, 1971).
Zinc and Cd are more mobile in soils and taken up by
plants more readily. Because Cd is much more toxic for
humans than for plants, already levels of 0.5 mg/kg Cd,
which are not yet toxic for plants, must be considered
as critical when the plants are used as nutriment or fodder
(Sauerbeck, 1985). Finally, it is essential to realize that
numerous heavy metals such as Mn, Mo, Co, but also
Cu and Zn are essential micronutrienis for plants. De-
ficiencics may disturb plant-rlletabolism. For example,
Artlberger (1979) has reported tissue concentrations for
Cu below 4 mg/kg and Zn 20 mg/kg as the bottom crit-
ical limit.
In this study we attempt to judge different reclamation
procedures on one particular site with high levels of heavy
metal contamination from a brass foundry. This site chows
a pronounced heavy metal pollution of the topsoil, which
causes much concern among the practitioners of agri-
culture and gardening nearby. In our view, a good re-
clamation procedure should be affordable, reasonably
simple, and should fully restore soil fertility and plant
quality. We consider four reclamation methods as real-
istic for this.sitc: addition of cation exchanger, liming,
dilution and replacement with unpolluted soil. We have
performed growth chamber experiments and small-scale
field studies in order to judge the possible impact of each
particular restoration procedure. We have focused on heavvyy
metal uptake by the plants and on germination on pol-
luted substrata.
EXPERIMENTAL SITE
Since 1895, non -Fe metals have been tasted to mainly brass
(Cu,Zn) and argentine (Cu,Zn,Ni) in a factory al Dornach
(Switzerland). The pollution of this region was first described
in an internal report issued by "Kantonales labor Sole ;urn"
i
201 '
I

202
J. ENVIRON. OUAL., VOL. 2Z JANUARY-MARCH t993
Table 1. Typical soil parameters of the experimental site as a function of depth: pH, carbonate content (CaCO,), organic C content
(Co,,,), cation exchange capacity (CEC), and content of Cd, Cu, and Zn (HNO3 extraction).t '
Depth
pH
COCO,
C".
CEC#
Cadmium
Copper
Zinc
cm
%
mmol,tkg
mg/kg
0-M
6.3
6
26
12.0
16 000
9 000
3-5
6.8
10
4.6
330
4.6
1 280
2 750
5-10
7.2
11
2.8
340
3A
630
1490
10-15
7.3
12
2.3
320
1.9
350
810
15-20
7.4
22
1.6
280
0.91
125
280
20-25
7.5
13
1.5
230
0.50
50
100
25-30
7.6
20
1.3
280
0.35
25
56
30-35
7.6
17
0.9
270
0.40
16
44
35-40
7.7
30
1.0
240
0.29
12
35
40-45
7.7
38
0.4
220
0.29
t0
43
t i=ederer and Slither. 1991
t CEC with BaC1, (mmoijkS).
I Undecomposed titter layer.
in 1987. During the smelting process of alloying and founding
of slug, oxidic aerosols (mainly Zn0 and Cu0) are produced.
In the past,. this led to airborne emissions of approximately 75
tlyr. Following the Swiss emission regulations of 1973, the
company installed filter equipment, which reduced the emis-
sions to less than 0.7 t/yr (approximately 0.3 kg/yr Cd, 24 kg/
yr Pb, 138 kg/yr Cu, and 500 kg/yr Zn). Nowadays the com-
pany recycles 200 to 300 t/yr filter powder, which is sold as
zinc ore.
The highly heavy metal polluted area is approximately 1 km
in diam. and is elongated in the direction of the main winds.
The soil of the site is a calcic fluvisol (Calcifluvent) (Federer
and Sticher, 1991). The bedrock contains alluvial rubble ma-
terial with clay (25%) and carbonates uniformly distributed in
the profile. The surface layer has a pH=6.3, whereas in the
45-cm depth, the pH value is raised to 7.7 (Table 1). The
thickness of the root zone varies typically between 40 cm and
i m, On the experimental site it amounts to 45 cm. The soil
Fable 2. The six different growth media used in the germination
experiments with lettuce and cress.
Medium Modeled reclamation,
no. Composition of medium action
1 Litter
0-3 cm
No action
2 Mineral soil
Removal of the most
3-5 cm
contaminated layer
3 Litter 0-3 cm
Addition of
Immobilization of
cation
heavy metals by
exchangert
cation exchanger
4 Mineral soil
Addition of
Removal of the most
3-5 cm
cation
contaminated layer
exchangert
and immobilization
of heavy metals
by cation exchanger
5 Mineral soil
Addition of
Reference for
3-5 cm
filter
assessment of the
powdert
influence of soil
structure
6 Uncontaminated Reference and
soil replacement of the
contaminated layer
with unpolluted soil
t Exchanger capacity SS or 110% needed to bind the heavy metals in
medium I or 2.
Cation exchanger: Lewatit TP 207, Bayer.
The preparation has been described by Heller (1979).
t Mixing ratio in order to obtain the heavy metal concentrations of
medium 1.
surface is covered with an unusually thick, mostly undecom-
posed litter layer. This top layer is sharply separated from the
mineral soil, which indicates an almost complete absence of
earthworm (Lumbricus lerms(Hs) activity. The accumulation
of litter is mainly due to the absence of decomposing micro-
organisms in the polluted soil (Strojan, 1978). Similar accu-
mulations of undecomposed litter near a mining -smelting
complex have been reported by Watson et al. (1976).
Table 1 shows the extremely high Cd, Cu. and Zn cuncen-
tralions (Federer and 5ticher, 1991) in the soil on the site.
These concentrations should be compared with the typical ranges
of metal concentrations in mineral soils: Cd, 0.01-1 mg/kg;
Cu, 2-100 mg/kg; and Zn, 10-300 mg/kg (Tyler, 1981). The
metal concentrations decrease rapidly with increasing depth in
the profile. Such pronounced accumulation of heavy metals in
the surface layer is typical for anthropological airborne pol-
lution (Filipinski, 1989, Strojan, 1978).
MATERIALS AND METHODS
To examine the influence of metals on germination, growth
chamber experiments were performed. All experiments were
carried out using lettuce (Lacruca saliva L., Apollo) and cress
(Lepidiurn sativurn L.). Each growth experiment was per-
formed with 50 seeds placed uniformly in 10 petri dishes (60
mm diam., 34 mm height) filled with six different growth
media (see Table 2). The necessary moisture of the seedlings
was maintained with water. The experiments were conducted
in a growth chamber having a 16-h day with the following
environmental conditions. During day -time illumination was
25 000 Lux and temperature 20 °C. During the night it was
dark with a temperature of 10 °C and 1.5 h twilight in between.
Air moisture in the growth chamber was at 80%. The root
length of the seedlings was measured from the junction of the
hypocotyl to the root tip 13 d after incubation.
To carry out the field experiments, we chose four plols (1.5
m by 1.6 m). The vegetation was removed and the plots were
prepared in four ways (see Table 3). 1n spring 13, 3-wk old
lettuce saplings were planted at uniform distances on each plot
and collected after 6 wk. In order to perform the soil analysis,
we used five cores obtained from the 0 to 10-cm surface layer
on each plot, which were dried at 105 °C and ground to pass
a 2-mm sieve. The soil pH was measured in' 0.01 M CaC12
suspension (0.4 g soil/mL). The total C content was deter-
mined with the CHN-Rapid-analyzer (Heracus). The carbonate
content was measured gxavimetrically using adsorption on a
Nesbilt bulb (Page et al., 1982),
For the heavy metal analysis. we used DTPA and nitric acid
extractions. The DTPA extraction (0.5 g soil/mL) was per-
formed in a solution of 0.005 M DTPA (diethylenctriamine
pentaacetic acid, Fluka, p.a.), 0,01 M CaCl2 (Fluka, puriss.),
and 0.1 M TEA (triethanolamine, Fluka puriss.) adjusted to

•3,
GEIGE:R ET AL.: RECLAMATION OF HEAVY MEI'AIL-CONTAMINATED SOILS
203
Table 3. Summary of the conditions ln'the field experiments.
Site Site conditions Decontamination procedure
F1 Untreated Reference
FZ Plowed to a depth of 10 cm Dilution of the metals In the root
zone
F3 Litter layer removed (upper Removal of the most contarninated
5 cm) and the mineral soil layer
loosened
F4 Topsoil removed (upper 10 Replacement of the contaminated
cm) and replaced with layer with unpolluted soil
alien soil (surface layer
and composted garden
debris)
pit 7.3 with hydrochloric acid (Fluka puriss.) and shaken for
2 It (Page ct al., 1982). Separate soil samples were extracted
for 2 h with 2 M nitric acid (Fluka, puriss. p.a.) at 95 °C (0.1
g soil/mL). The metal analysis was performed on filtered
(Schleicher & Schucil 5891) samples using atomic absorption
spectroscopy (AAS) (Varian, Spec(rAA 400). Capper and zinc
were analyzed by flame AAS, Cd by flameless AAS.
In order to analyze the heavy metal content of the plants,
lettuce leaves were rinsed with doubly distilled water, dried at
105 °C, and powdered with a vibratory disc (tungsten carbide)
mill type RS1 (Retsch). Resulting lissue samples (200 mg)
were digested in a high-pressure microwave system (MLS-
1200 with HPV 80, pressure digestion vessels AGW, Leut-
kirch, Germany). The digestion acid mixture was composed
of 2 mL hydrofluoric acid (40%, Merck, suprapur), 2 mL nitric
acid (657D, Fluka, puriss. p.a.), and 1 mL chloric acid (20%,
Merck, p.a.). The digestion was performed in three steps; 10
min with 300-W power, 1 min pause, and finally 8 min with
600 W power. The transparent solutions were quantitatively
transferred into polypropylene standard flasks and diluted to
25 mL. Cadmium, Cu, and Zn in the plant tissue digest were
analyzed by AAS.
RESULTS AND DISCUSSION
Natural Vegetation on the Site
The heavy metal pollution has a dramatic effect on
the vegetation of the site. The soil is covered only with
loose patches of meadovy. Nevertheless, the heavy metal '
content of the plants growing on the site (Cd, 0.2-0.6
mg/kg; Cu, 7-30 mg/kg; Zn, 90-180 mglkg) are signif-
icantly below the phytotoxic limits (Amberger, 1979).
Most of the plants are typical for nutrient -rich sites (al-
falfa, Medicago sativa L.; white deadnettle Lamium al-
bum L.; sorrel, Rumex acelosa L.; dandelion, Tarawcum
ofcinale Weber)(Landolt, 1977). Leguminous plants
(especially alfalfa) are dominating. Furthermore, the ex-
istence of meadow dary (Salvia pralensis L.) on this site
is quite remarkable. Usually it can only compete on sites
poor in nutrients. We suspect that its successful stand is
due to an induced metal resistance and since the site is
regularly ferlilized. The dominance of alfalfa is not ac-
cidental. It is known that this species can often carry
vesicular-arbuscular mycorrhiza and rhizobia. The infec-
tion of the roots with these fungi is favored by high pH.
El-Kherbawy et al. (1989) have demonstrated that such
fungi regulate metal uptake of alfalfa, which explains
the dominance of the leguminous plants on the experi-
mental site. Comparable plant communities were found
on derelict mine sites in Cu, Ph, or Zn mining regions
in North America (McGavock, 1962). McGavock de-
scribes a vegetation cover sparser than on surrounding
sites, with barren patches of soil occurring and reduced
vegetation structure and xeromorphic growth forms its
well as species typical for somehow disturbed, circum-
neutral, and nutrient -poor sites (as in our case meadow -
dary). He observed the frequent adaptation to exposed
conditions and strongly reduced diversity, which was also
observed on our site.
Growth Chamber Experiments
The germination experiments were performed on dif-
ferent substrata to model the soils resulting from the dif-
ferent reclamation procedures (see Table 2). For these
experiments we used cress and lettuce seeds. In spite of
the heavy metal content, seeds germinated on all six
media. The 2 wk old cress seedlings are shown in Fig.
1. The seedlings grown on mineral soil are long and
healthy; whereas the seedlings grown on litter are very
small and thickened. Since the heavy metal concentra-
Fig. 1. Pictorial representation or cress grown on heavy metal --polluted litter (Medium 1, right) and mineral soil (Medium 2, left).

244 J. ENVIRON. QUA(.., VOL. 22. JANUARY-MARCII 1993
a) 9 b)
too
a
50
E 2p E 6
r O .E 5
c 10
m m 4 O
8 5 O $ 3
2 O 2 e e
• I
1 0
111tar mineral control 0 55 110
Boil Boll copoclly [°/.]
Fig. 2. Root length of plants alter germination. (a) Cress (filled circle) and lettuce (open circle) grown on heavy metal -polluted
litter (Medium 1), mineral soil (Medium 2), and unpolluted control soil (Medium 6). W Cress grown on litter (Medium 3,
triangles) and mineral soil (Medium 4, squares) as a function of the exchanger capacity.
lions in the litter are very high, we suspect that prefer-
ential accumulation of Cu in the roots leads to decreased
root length and to suppressed formation of lateral roots
(Grams and Fiskell, 1971). In addition to that, the sur-
face organs of the seedlings on litter were in a poor
condition and chlorosis was observed. Such effects are
often induced by high metal concentrations in soils
(Chernen'kova and Sizov, 1986).
Figure 2a shows the length of the principal roots after
2 wk. The roots of the plants grown on litter were clearly
shorter than of those grown on mineral soil (by a factor
of 5.7 in the case of cress and 1.6 in the case of lettuce).
The roots in the control soil were the longest in spite of
the relatively high Cd content of 0.94 mg/kg (Cu, 26
mg/kg; Zn, 102 mg/kg). Therefore, such high Cd con- .
ctintrations seemed to have no no'.Zle effects on the,
early stages of plant development' Root length of the
cress seedlings strongly decreased %tith increasing cation
exchanger resin content of the mineral soil (Fig. 2b).
This is just the contrary effect of the one expected from
a soil reclamation procedure. In the case of cress on
litter, addition of a small amount of exchanger rosin did
somewhat enhance growth of the seedlings; further ex-
changer addition, however, led to growth inhibition. Mohr.
(1982) explains this behavior as complexation of the nu-
trients by the exchanger. The surface organs of the seed-
lings grown on the exchanger medium were small but
appeared healthy. However, with increasing amount of
exchanger the roots became thicker and more brittle with
a tendency of inhibition of lateral root formation. Re-
duction in root length and in the number of lateral roots
of plants deficient in nutrients was also described by
Hackett (1968). The seedlings grown on soil mixed with
filter powder (Medium 5) were long and appeared fairly
healthy, but formed roots above the soil surface as de-
scribed by Russell (1977).
In the present experiment, optimum conditions granted
quick germination and rapid development. Such condi-
tions seldom exist in nature. Factors such as dryness,
parasite infection, and temperature fluctuations may
impede plant growth and development. Nevertheless, such
optimum conditions allow conclusions on the germina-
tion process of soils involved in different reclamation
procedures.
Cadmium Copper Zinc
mg/kg g/kg g/kg
6.0 2.5 3.5
16 e e e
5.0 e 0 e 2.0 3.0
4.0 2.5
1.5 e '� -
2.0
3.0
1.0 1.5
2.0 O O
p 1.0
1.0
e
O � O O O e 0.5 � O O
0 0 0
FI F2 F3 F4 FI F2 F3 F4 FI F2 F3 F4
'Fig. 3. Concentrations of Cd, Cu, and Zn in the soil on the four experimental plots, Fl, F2, F3, and F4. Triangles (A) correspond
to the nitric acid extraction procedure, circles (0) to DTPA.
t

GEIGER ET AL: RECLAMATION OF HEAVY METAL -CONTAMINATED SOILS
Cadmium Copper zinc
mg/kg mg / kg g / kg
7.0 0 60 0 1.0 O Q
6.0 50 0 0 0.8
5.0
O 40 0.6 p
4.0 O O
30
3.0 0.4
2.0 20
205
to--�----- 0
I.o-------- �- o
0 0 0
FI F2 F3 F4 FI F2 F3 F4 FI F2 F3 F4
Fig. 4. Concentration of Cd, Cu, and Zn in lettuce (dry wt. basis) on the four different experimental plots, Ft. n, F3, and F4.
The dashed line indicates is normal tissue concentration of plhnls (Sauerbeck, 1985).
Since the polluted upper litter layer strongly inhibits
the root development because of its high heavy metal
content and its structure, we propose that in any feasible
reclamation procedure the litter layer should be removed
to ensure proper germination of the plants.
Field Experiments
'The content of HNO3-extractable metals in the surface
soil (Fig. 3) layer of plots Fl, F2, and F3 were more or
less identical on a very high level (Cd, 4.5 mg/kg; Cu,
2000 mg/kg; Zn, 3100 mg/kg). Only plot F4, to which
uncontaminated soil material had been added, showed a
significantly lower content (Cd, 1.6 mg/kg; Cu, 230 mg/
kg; Zn, 710 mg/kg). A similar trend in the metal con-
tents, though on a lower level, was found with the DTPA-
extraction method (Fig.3)(Cd, 1,7 mg/kg; Cu, 380 mg/
kg; Zn, 151 mg/kg for plot FI, F2, F3; and Cd, 0.6 mgl
kg; Cu, 44 mg/kg; Zn, 86 mg/kg for plot F4).
The metal content of the plant tissue differed (Cd,
0.94; Cu, 0.92; Zn, 0.75) between the four experimental,
plots. It was extremely high on plots F1, F2, and F3
(Fl: Cd, 6.1 mg/kg; Cu, 57 mg/kg; Zn, 860 mglkg; F2:
Cd, 4.4 mg/kg; Cu, 50 mg/kg; Zn, 860 mg/kg; F3: Cd,
4.3 m�g; Cu, 50 mg/kg; Zn, 565 mg/kg). Copper con-
tent o the plants in F1, F2, and F3 was about the same,
while Cd and Zn decreased when going from Fl to F3
On plot F4 heavy metal content was quite low (Cd, 0.95
mg/kg; Cu, 28 mg/kg; Zn, 87 mVkg), As can be seen
from Fig. 4, Cd and Zn concentrations on F4 were some-
what below normal tissue concentration; only Cu con
centration was slightly higher..
On the four different plots, the uptake of heavy metal
by -plants decreased from Fl, F2, and F3 to R. Zinc,
Cu;•and Cd in F1, F2, and F3 were within the phytotoxic
range for lettuce: However, in F4 all metals considered
.were below or (as in the case of Cu) slightly above the
gghytotoxic limit (Amberger, 1979). Not surprisingly, the
biomass' production on this plot is large (140 g/plant)
(Fig. 5), although the metal concentrations in the plants
Fig. 5. Pictorial representation of the lettuce grown for 6 wk on the four different experimental plots (rmm left to right) F1, F2,
F3, and F4.
9

1
206 1. ENVIRON. QUAL., VOL. 22. JAWARY-MARCH 1993
'an F1 and F2 are nearly equal, the biomass of the plants
on F1 (21 g/plant) is only about half of the biomass on
F2 (51 g/plant). The poor state of the plants on-.F.1 is
_mainly caused by chlorosis and by compact; nontreated
soil structure..•'_'omparcd with dicotyledones from an
equally contaminated control plot nearby with native
vegetation, the metal uptake by lettuce from plots F1,
F2, and F3 was strongly elevated. Beside the well-known
accumulation of heavy metals by lettuce (Adrian, 1986)
a different root length and distribution of the native veg-
ctation may be a reason for the different metal content.
In Fig. 5, typical lettuce plants grown on the four
experimental plots are traced. Remarkable differences
exist between the plots regarding the biomass above-
ground (F1, 21 g; F2, 51 g; F3, 44 g; F4, 140 g) and
extent of the root zone. There is an obvious correlation
between the development of the roots and of the surface
biomass. The trend of decreasing biomass production of
the single plants is enhanced by increasing mortality of
the plants on the different plots (F1, 39%; F2, 46%; F3,
9%; F4, 9%). Furthermore, the plants in F1 showed
chlorosis effects. In Fig. 5 we have also indicated the
appearance of gaffs on the roots of plants grown on sites
Fl and F2, which have made the root morphology ab-
normal. The roots in F2 showed the most severe infec-
tion with galls of almost 1 cm in diam. In F4 the roots
had no galls down to the 10-cm depth, although below
(in the native soil) small galls were found. These galls
are caused by root knot nematodes (Meloidogyne hapla
ssp.).
The high infection of the lettuce root with nematodes
can be explained by low microbiological activity. This
root knot nematode (Meloidogyne hapla ssp.) prefers
neutral to weakly basic soils poor in clay (Taylor et al.,
1982). Nematodes build very resistant cysts, which would
normally be digested by litter decomposing microorgan-
isms (Ebregi and Boldewijn, 1977). On our site, how-
ever, nematode infection developed because of
exceptionally low activity of microorganisms. This lack
of activity is indicated by the pronounced accumulation
of litter on the soil surface. A similar observation was
also reported by Ebregt and Boldewijn (1977). In the
present case, the lower soil layers are poorly penetrable
and the nematodes seem, therefore, to inhabit the soil
surface layer. Mixing the surface layer with the mineral
soil on plot F2 (plowed) allows the nematode infection
to inhabit the entire root zone. This leads to root damage,
reduction of the biomass, and, in extreme cases, to the
death of the plant. In summary, only plot F4 (replaced)
shows good growth conditions for lettuce and low heavy
metal concentrations ill the plants.
CONCLUSION
- In this study we have attempted to assess the fertility
restoration of contaminated soils after different recla-
mation procedures. We focused on contamination by Cd,
�—Cu, and Zn. Our work.i[ncluded field studies and ger-
mination experiments. I''n a calcareous, highly eontami-
rnated region in Switzerland, we have investigated the
" '-heavy metals accumulated in lettuce on four different
..-plots, which were used to model different reclamatition
-methods, such as dilution by plowing, immobilization
' r :by the addition of an exchanger resin and reducing of
the heavy metals by elimination, or replacement of the
highly polluted soil. The same soils have been used -for.
germination experiments with lettuce and cress. Results,
showed that only the replacement of the highly contam-
inated top soil leads to good germination, normal•plant,�.
development, and plant heavy metal contents essentially- -
below toxicity limits for Cd, Cu, and Zn.
The other three reclamation procedures tested are'hot
suitable for the site. The reasons are as follows: -First,
plowing the site distributes the highly contaminated sur-
face -layers into the soil and the metals could., be mobi-
lized in the future. Decomposition of the contaminated
organic matter will lead to a decrease of the'availabfe
binding sites and thus lead to a heavy metal release. The
low molecular weight dissolved organic matter -may act .
as an active carrier, for Cu in particular (BrOmmer•et
al., 1986). Therefore, neither was reduction of the metal .
uptake achieved, nor was fertility restored by this -method.
. Second, elimination of the litter layer leads to -some re-
duction in the heavy metal concentrations of the plants
— though not enough to gel below the toxicity'limit.
Elimination of the entire contaminated layer would result
in a substantial heavy metal reduction, but at the'sime
time lead to the loss of the topsoil. Third, the*addition
of an exchanger resin may reduce the heavy metal•avail-
ability, but the exchanger adsorbs also essential cations. -
This reduced cation availability can lead to nutrient de-
ficiencies for the plants (Mohr, 1982). Leaving.the Con-
taminated area unchanged leads — due to impeded
germination of seeds — to an increasing incompleteness
of the plant coverage and thus to enhanced wind erosion. .
An alternative would be to cultivate heavy metal —tolerant
species, either leguminous plants.associated-with'spe-
cific mycorrhizae (Visser, 1985) or plants•physiologi-',
cally adapted to high tissue concentrations.
The methods used in this investigation do not require
large investments and may easily be adapted to other
heavy mela'-'Conlaminated sites. The results of such studies
may provide substantial help in selecting a reclamation
method, and lead to definitive conclusions about the pos-
sible success of a particular treatment,
ACKNOWLEDGMENTS
We thank K. Barmettler, L. Birch, M. Borkovec, A. Hun-
ziker, and Metall Werke Dornach for their cooperation.
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Amberger, A. 1979. Pflanzenerntihrung. Oekologische and_p hy-
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Asami, T, 1994. Pollution of soils by cadmium, p. 95-111. In
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Brams, E.A., and J.G.A. Fiskell, 1971. Copper accumulation in
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Br0mmer, G., J. Gerth, and U. Herms. 1986. Heavy metal sppee-
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Chernen'kova, T.V., and 1. Sizov. 1986. Germinating capacity
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Czupyrna, G., A.I. Mac Lean, R.D. Levy, and la. Gold. 19139
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Ebregt, A., and J.M.A.M. Boldewijn. 1977. Influences of heavy
metals in spruce forest soil on amylase activity, CO, evolution
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SHORT COMMUNICATIONS
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Soil pii, rhizobia and vesicular-arbuscuiar mycorrhizae inocu-
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and Cadmium in einem stark belasteten Kalkboden. Chimia
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Filipinski, M. 1989. Pflanzenaufnahme and Losborkeit von
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niger Schwermetalle auf Gcmusepflanzen. Gegendhersteltungg
der Erggehnisse aus Wasserkuitur- and Substratversuchen. Land-
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Frdchtenichl, K., and 11. Vetter. 1982. Charakierisierung der
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Landoll, E. 1977. Oekologische Zeigerwerte zur schweizer Flora.
Verbffentlichung des geobot. Inst.. Satflung Rdbel.
Larcher, W. 1984. Ockotogie der Pflanzen auf physioiogischer
Grundlage. Ulmer, Stuttgart.
207
McCavoek, E.H. 1962. An evaluation of biogeochemical pros-
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Mohr, H.D. 1982. Eintluss von Kai ionenaustauscherharz auf die
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Russell, S.R. 1977. Plant root systems: Their function and inter-
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R.L. Tate and D.A. Klein (ed.) Soil reclamation processes:
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SHORT COMMUNICATIONS
A Zero -Tension Sampler for the Collection of Soil Water in Macropore Systems
K. E. Simmons' and D. E. Baker
ABSTRACT
A zomtension sampler was designed for the collection of soil leach -
ate at 1.2 m in the soil profile to determine the effects of dairy manure
and N11,N0, applications on water quality In soils possessing a ma•
cropore structure. Nitrate-N concentrations In soil water collectsrt from
these samplers were compared with eonceatratfons lit soil water col-
lected from conventional ceramic porous -cup samplers. The xeraten-
sion samplers were constructed from 5-cm polyvinyl chloride (PVC)
pipe and Installed at a 45' angle In The loll profile. This design min.
imized the amount of field excavation and the interruption of routine
cultivation. On average, approximately 50% of the samplers con-
tained solution after rainfall and the data were effective at deman-
orating the effect of macropore flow an NO,.N concentrations in the
leachale. Nilrate-N concentrations in soil water collected from porous -
cup samplers were consistently higher than those collected from zero.
tension samplers. Mean NO,-N concentrations In soil water from po.
roue -cup and zero -tension samplers ranged from approximately 5 to
60 mg L-r and 0 to 20 nag L-r, respectively. '
K.G. Simmons, Agric. Res. Dep., National Fertilizer and Envi-
ron. Res. Center, TVA, Muscle Shoals, AL 35660; and D.E.
Baker, Dep. of Agronomy The Pennsylvania Slate Univ., Uni-
versity Park, PA 16802. This research was partially supported by
the Pennsylvania Dep. of Environ. Resources, Bureau of Soil and
Water Conservation and the Chesapeake Bay Program- Received
11 Feb. 1992. 'Corresponding author.
Published in J. Environ, Quai. 22:207-212 (1993).
MANY sAMPL NG DEv CEs have been used to collect
soil water from the profile for environmental as-
sessment, including both zero -Tension (Jordan, 1968) and
tension (Linden, 1977) samplers. The advantages and
disadvantages associated with soil -water samplers have
been reviewed (Lilaor, 1988; Grossmann and Udluft,
1991); particularly those related to the porous -cup sam-
pler (Alberts et al., 1977; Anderson, 1986; Morrison and
Lowery, 1990a,b; Nagpal, 1982; Warrick and Am-
moozegar-Fard, 1977). These methodologies can be time-
consuming and expensive and may yield discrepant and
inconclusive results, especially in the presence of a ma-
cropore structure where bypass flow occurs. Bypass flow
creates large variations in water and solute movement
through the root zone and renders the measurement of
some soil properties (hydraulic conductivity) and the pre-
diction of solute transport difficult by conventional meth-
ods.
The effect of macropores on solute transport depends
on the water content of the soil and the location of the
solute. Under saturated conditions, when the solute is
dissolved in the flowing solution (i.e., NO, in irrigation
water) interaction between water in the soil matrix with
the solute in the flowing solution may be minimal, and
solute transport across the root zone may be quite rapid.
During a slow wetting process, when the soil is not sat-
urated, however, the solution is transported into the mi-

r
Distribution of Cadmium and Selected Heavy
Metals In Phosphate Fertilizer Processing
Cd
Cd
Cd
col
Cd
cd
Cd
Cd

DISTRIBUTION OF CADMIUM AND SELECTED HEAVY
''. METALS"IN'PHOSPHATE .FERTILIZER PROCESSING
•
ti
� �
F
� . _ i
Phosphate rocks, and fertilizers produced
from them, have long been known to contain
varying amounts of cadmium and other heavy
metals; but contents vary over a very wide
range depending upon rock source and method
of processing. High -temperature calcination is
the only known technology to decrease the
amount of cadmium that carries through the
acidulation process to wet -process phosphoric
acid and final fertilizer products.
The harmful health effects of cadmium intake
at high levels of concentration have long been
recognized in the cadmium metal industry, but
protective measures have been adopted. More
recently, interest has developed in the many
areas of long-term exposure to low levels of
potential health hazards such as radiation, food
additives for preservation or improved appear-
ance, cosmetics, sugar substitutes, and many
others. Because of the possibility that high
levels of cadmium intake may be harmful to
human health, study of the various avenues of
cadmium entry into the human food chain has
increased in recent years.
Several studies have been made to investigate
the quantities and distribution of possibly.,
harmful heavy metals, including cadmium, in
the several basic sequences of the phosphate
fertilizer processes (1.7). In recognition of the
need for a more detailed knowledge of the occur-
rence and distribution of cadmium and 'other
heavy metals in phosphate fertilizer processing,
the Division of Chemical Development, Ten-
nessee Valley Authority (TVA), in cooperation
with The Fertilizer Institute (TFI), undertook a
relatively broad -based sampling and analysis
program to provide more specific data on the
distribution of heavy metals during phosphate
processing from matrix to the finished fertilizer
products used in agricultural production.
This study was restricted to an attempt to
determine redistribution pathways of cadmium
and other selected heavy metals in commercial
phosphate fertilizer processing and to deter-
mine if any of the several processing steps
result in a significant concentration or dilution
effect in either final products or waste
materials. Thermal (furnace) phosphoric acid
and waste materials such as sewage sludge were
not included in the study.
Ideally such a study should provide a com-
plete material balance for each element from tho
matrix to the final products, including distribu-
tions in products and waste streams in the
intermediate steps of beneficiation and acidula-
tion. When consideration is given to the
variable inputs and outputs because of changes
that occur in all of these steps resulting from
compositional changes and rock cbncentrate
blending operations, the sampling problem
takes on unmanageable proportions. Judgment
was applied to identify key steps in the overall
processing sequence, and restrictions were
placed on the number of ore types and sampling
points that were studied. Because of short-term
variation, sampling from the key points of the
selected ore types was repeated to adequately
generalize the representative metals distribu-
tions on a sustained term basis.
The use of byproduct sulfuric acid from
smelter operations constitutes a special case in
which the cadmium content of the fertilizer
product is the sum of the content of the sulfuric
acid and that of the phosphate rock. While this
is a relatively smell contribution to total
phosphate fertilizer pr'bduction, the possibility
of localized above-averag6•levels of cadmium ap-
plication should be determuted. A small number
of byproduct sulfuric acid samples from a lead
smelter and a zinc smelter contained only trace
amounts of cadmium. -
A second special case is that of triple super-
phosphate (TSP—about lb% of U.S. phosphate
fertilizer consumption). A first assumption is
that all the cadmium in the feed rock and that in
the acid would remain with the finished product,

but the possibility of volatilization or other
changes during production needed to be
evaluated.
MECHODS
Representative member firms of The Fer-
tilizer Institute cooperated in the survey by con-
tributing samples at the selected points during
fertilizer production. These cooperating pro-
ducers represent the major geographic regions
of phosphate production: central Florida, north
Florida, North Carolina, and the western region.
Together, these companies represent about 45%
of U.S. phosphate fertilizer production. The
distribution of sampling points over the major
processing steps is summarized in figures 1.3.
Samples at the designated points in processing
were taken at two -week intervals for a total of 6
samples over a 12-week period to approximate
representative approaches to long-term opera-
tions.
The sampling program was subdivided into
three major areas:
1. Conversion of the mined total matrix to
acid plant concentrate and the associated
wastes.
2. Conversion of the concentrate to
merchant -grade wet -process acid (WPA)
and the associated wastes.
3. Conversion of merchant -grade WPA to
liquid and solid finished products.
2
TOTAL
MATRIX
ILB
I -I
WASTE SLIMES SAND
WATER TAILINGS
IOT 10T ILB
I-2 I-3 I-•
The waste -materials sampling was required as
a contribution toward establishing a material
balance for cadmium and for an indication of
possible adverse environmental effects.
Metal contents of the samples were deter-
mined by direct current argon plasma spec-
trometry (DCAPS). Twenty frequency channels
were available for simultaneous use. The metals
were determined in two groups: iron, aluminum,
magnesium, and calcium were determined
simultaneously and the results used in matrix
matching of the second group consisting of cad-
mium, zinc, copper, manganese, chromium,
vanadium, and nickel. Uranium and lead re-
quired individual determination. Phosphorus
was determined by the spectrophotometric
molybdovanadate method and reported as the
pentoxide (P20.). A summary of analytical pro-
cedures is given in Appendix A.
RESULTS
Summaries of analytical results for cadmium,
other selected metals, and for P20, at the
various sampling points are shown in tables 1-4
for each region. These tables comprise the
essence of this report, but do not totally reflect
the idealized sets of samples requested that are
shown in figures 1-3. Variations exist in phos-
phate fertilizer processing among regions and
among individual producers within a region. A
few errors were observed in the taking of
PEBBLE CONCENTRATE
I-S. I LB
COARSE FLOTATION CONCENTRATE
I-B, 1 LB
FINE FLOTATION CONCENTRATE
I-7. ILB
OR
ONE GALLON COMPOSITE AS SENT TO
STORAGE --SEPARATIONS AT TVA
I —Conversion of total matrix as mined to rock concentrate and associated waste
Figure 1. Sampling program for the major
subdivisions of phosphate processing --I
4
.I
� ➢i'
4'. �.

samples and in the labeling of samples taken.
These virtually unavoidable deviations necessi-
tated some use of subjective judgment in the
compilation of tables of regional averages.
Variation in concentration of all elements of cor-
responding points among the 6 sets of samples
over the 12-week period was small, except in a
few isolated cases. Cadmium contents showed
no major concentration effects in either prod-
ucts or waste streams.
Estimated distributions and material
balances are given only as examples and are
subject to modifications to reflect the opera-
tions of individual; producers. An estimated
material balance based on several assumptions
of "typical" phosphate processing (8) and data
from the central Florida region indicates the
following:
1. In beneficiation, cadmium distribution is
about evenly divided between useful frac-
tions and waste materials, as shown in the
following tabulation and in figure 4.
MAKEiIP
WAlN H
IOT
II -A -a
VIRGIN
"ISC4
SCRUBBER
NO SAMPLE
LIQUOR
REgb
i Or
d-A-4
OYPSUY CAME WASH
CAKE
WATER
pIRAOE
ACID
CONCENTRATOR
y_A
I LB
1t-A-8
I Or
II-A-S
I OT
a -A -a
SAILWPA
_
ROGK GONG.
I OT
FEED
I -LB
-J
4-,I-T
3L-A-I
044LLON COMPOSITE.
on
SEPARATION AT TVA
a-B-I
a-B
MAKEUP
WAlY M=
1 OT
J.
BYPRODUCT
N=90a
lCRUBBER
IOT
LIQUOR
it a-
I Or
arnuY
cAKEwAlN
GRAD[
u-°-"
CAME
WATER
AC10
CONCENTRATOR
ILA
E-8-2
IOT
a-B-3
ZL :a
547.WPA
1 OT
OR
II-S-r
I OALLON COMPOSITE,
SEPARATION AT TVA
li-A or I I-B—Conversion of rock concentrate to 54°% WPA and associated wastes
Figure 2. Sampling prbgram for the major subdivisions
of phosphate processing —I I -A or 11-13
FILTER
NH3 N-P
30% WPA
No
GRADES
1 9T
SAMPL£
I LB
PAIn
.2
R£O'O
M -3
:214
OT-I
GRANULAR
ROCK
CSP
come.
I LB
1 ' LB
m-}
M-A
CSP-ROP
SA%
i"AD
'
I -LB
WPA
ESPL3
PROT'8
m -°
IOT
IOT
17.1
tY-x
'r '
I I I —Conversion of 64% WPA to
solid finished products IV —Conversion of 54% WPA to fluid products
Figure 3. Sampling program for the major
1'
subdivisions of phosphate processing —III and IV
.• t, ,, A
3
• 1, r,

A
Table 1. - Analysis of samples from phosphate fertilizer processing, central Florida region
%
PPM
%
I-05
Ca
_
Cd
U
_
Cu
Zn
Mn
_
Ni
Pb y
Cr
V
Al
Mg
Fe
(1, Beneficiation)
Matrix
13.4
15.4
3
82
17
49
90
16
12
70
112
1.9
0.30
0.70
Wash Water
<0.01
<0.01
<1
<1
<1
<1
<1
<1
<1
Q
<1
<0.01
<0.01
<0.01
Slimes (Dry Solids)
6.6
6.8
4
46
29
80
157
41
20
177
155
6.7
1.6
2,8
Slimes (Filtrate)
<0.01
<0_01
<1
<1
<1
<1
<1
<1
<1
<1
<1
<0.01
<0.01
<0.01
Slimes (Slurry)
0.34
0.32
<1
2
3
7
<1
3
<1
7
17
0.18
0.04
0.04
Sand Tailings
2.8
2.7
<1
8
11
16
34
4
2
8
10
0.19
0.04
0.16
Pebble Conc
30.5
35.0
3 '.
166
17
55
203
29
10
47
133
0.79
0.32
0.90
Coarse Float
28.4
31.1
4
128
15
52
170
21
14
42
99
0.59
0.27
0.72
Fine Float
31.2
32.9
5
106
21
70
254
25
14
58
•112
0.60
0.27
0.85
Float Concentrate
32.5
35.9
5
152•
16
115
390
32
14
60
94
1.21
0.24
1.30
(11,
Acidulation)
Rock Feed
30.1
32.8
5
156
9
61
208
30
9
52
119
0.64
0.25
0.72
Gypsum
1.5
25.1
1
34
14
19
20
15
6
1
1
0.09
0.02
0.16
Gypsum Wash Water
2,7
0.14
<1
20
<1
7
18
2
1
5
11
0.05
0.06
0.07
Make -Up Water
1.2
0.13
<1
11
<1
7
22
2
<1
2
6
0:03
0.03
0.02
WPA, 282 P,O5
27.2
0.34
3
123
7
39
178
21
2
'47
100
0.51
0.29
0.82
Scrubber Liquor
0.83
0.10
<1
4
<1
2
7
1
<1
2
3
0.04
0.02
0.02
WPA, 54% P201
52.6
0.19
5
230
9
75
349
36
4
85
181
0.79
0.46
1.13
(III, Products)
WPA,
54% P205
51.6
0.39
6
227
12
70
346
36
5
86
212
0.80
0.47
1.59
WPA,
28% PROS
28.1
0.26
3
138
6
31
175
24
3
45
107
0.55
0.30
0.86
N-P
Product (DAP)
46.4
0.32
8
185
12
66
344
23
4
78
154
0.80
0.42
1.32
N-P
Product (MAP)
52.1
0.62
3
237
14
54
233
28
3
98
206
0.74
0.56
1.59
Rock
Feed
33.3
35.7
12
140
8
87
195
21
11
55
104
0.58
0.19
0.73
CSP
(Granular)
47.1
16.0
8
189
16
89
310
29
7
84
165
0.75
0.39
1.40
WPA.
40% P,o5
40.1
0.17
7
150
5
77
298
22
2
72
122
0.64
0.36
1.36
CSP
(ROP)
45.3
15.7
4
202
8
60
332
24
7
68
173
0.78
0.34
1.60

Table 2. Analysis of samples from phosphate fertilizer processing, north
Florida regiona
%
2pm
P205'
Ca
Cd
U
Cu
Zn
Mn
Ni
Pb
Cr
V
Al
Mg
Fe
(I, beneficiation)
Matrix
8.01
6.40
4
29
22
15
76
13
10
49
56
1.57
0.07
0.21
Wash Water
0.01
0.01
<1
<1
<1
<1
<1
Q
<1
<1
<1
<0.01
<0.01
<0.01
Fri Slimes
(Dry Solids)
14.6
9.98
8
69
40
75
124
48
29
165
212
9.59
0.46
1.47
Pri. Slimes
(Filtrate)
<0.01
0.01
<1
<1
<1
<1
<1
<1
<1
<1
<1
<0.01
<0.01
<0.01
Sec Slimes
(Dry Solids)
15.6
12.4
7
64
33
67
145
43
16
150
240
6.34
0.56
1.44
Sec Slimes
(Filtrate)
<O:OI
0.01.
<1
<1
<1
<1
<1
<1
<1
<1
<1
<0.01
<0.01
<0.01
Sand Tailings
4.15
4.24
<1
12
8
2
32
3
4
7
8
0.26
0.04
0.11
Pebble Conc
28.1
27.6
5
86
20
53
199
7
10
64
99
0.85
0.24
0.50
Coarse Float
32.4
32.2
6
63•
25
53
188
7
12
72
109
0.60
0.19
0.53
Fine Float
32.0
32.4
6
62
22
55
173
7
13
73
98
0.59
0.19
0.31
(II,
Acidulation)
Rack Feed
31.1
30.8
8
66
25
50
187
9
13
68
98
0.67
0.21
0.39
Gypsum
1.89
27.3
2
16
1
6
23
3
13
6
11 '
0.14
0.08
0.06
Gypsum Wash Water
1.37
0.13
1
4
1
3
15
1
<1
3
3
0.04
0.02
0.03
Make -Up Water
1.35
0.14
1
4
1
3
14
1
<1
3
3
0.04
0.02
0.03 '
VPA, 28% P205
24.3
0.77
4
46
12
47
193
7
1
45
62
0.48
0.22
0.50
Scrubber liquor
1.27
0.13
<1
4
1
2
14
1
<1
3
3
0.04
0.02
0.03
WPA. 54% P205-
44.5
0.66
7
73
17
86
350
13
2
84
118
0.84
0.37
0.86
_
(III, Products)
WPA, 54% P205
47.8
0.31
8
75
15
98
371
13
1
82
112
0.80
0.36
0.89
N-P Product
46.5
0.35
6
73
39
86
334
13
1
78
106
0.79
0.34
0.89
Rock Feed
32.7
31.2
10
69
10
64
248
9
12
62
109
0.63
0.20
0.58
CSP (Granular)
48.5
12.6
9
79
22
99
394
16
8
.103
127
0.90
0.39
0.94
WPA, 54% P205
51.2
0.02
8
77
15
104
413
16
<1
90
118
0.62
0.21
0.83
Super Acid
69.3
0.04
11
104
19
149
610
25
<1
126
161
0.43
0.14
0.57
'Samples were submitted as composites of sac samples taken at intervals
of two weeks,

rn
Table 3. Analysis of samples from phosphate fertilizer processing, North Carolina region
Rpm
%
P205
Ca
Cd
U
Cu
^Zn�
Mn
_
Ni
Pb
Cr
V
Al
Mpz
Fe
(I, Beneficiation)
Matrix
15.1
17.0
_21.
81
19
172
21
21
<1
133
39
0.66
0.63
0.56
Wash Water
<0.01
0.01
<1
<1
<1
<1
<1
<1
<1
<1
<1
<0.01
<0.01
<0.01
Slimes (Dry Solids)
2.44
9.5
21
32
40
167
60
53
6
243
69
1.99
2.41
1.80
Slimes (Filtrate)
<0.01
0.04
<1
<1
<1
<1
<1
<1
<1
<1
<1
0.01
<0.01
<0.01
Sand Tailings
2.12
2.09
6
9
12
42
2
<1
<1
15
<1
0.08
0.09
0.17
Washer Rejects
16.0
28.5
5
71
2
66
24
10
<1
57
27
0.33
0.84
0.49
Rock Conc
26.2
27.3
39
93
22
287
18
16
<1
142
23
0.21
0.30
0.43
Calciner Feed
26.2
26.8
39
94
12
290
18
16
<1
143
24
0.22
0.29
0.44
Calciner Product
28.9
29.5*
38
100
21
308
25
20
12
157
35
0.23
0.31
0.47
(II, Acidulation)
Rock Feed
28.1
29.6
38
62
25
303
26
18
11
150
32
0.23
0.32
0.47
Gypsum
1.35
21.8
14
22
11
45
5
8
17
26
26
0.03
0.02
0.05
Gypsum Wash Water
1.67
0.20
6
5
3
25
3
2
<1
8
2
0.01
0.03
0.03
Make -Up Water
<0.01
0.01
<1
<1
<1
<1
<1
<1
<1
<1
<1
<0.01
<0.01
<0.01
WPA, 28% P205
26.6
0.31
25
53
<1
257
45
18
<1
130
29
0.19
0.32
0.50
Scrubber Liquor
1.43
0.17
4
4
1
19
3
2
<1
7
2
0.01
0.02
0:03
WPA, 54% P205
51.9
0.31
46
96
2
513
87
35
2
254
54
0.33
0.63
1.00
(III, Products)
WPA, 54% PaOs
51.2
0.67
49
102
2
500
88
37
<1
256
55
0.33
0.62
0.95
WPA, 28% P205
27.4
0.25
28
57
<1
310
55
29
<1
133
29
0.23
0.44
0.61.
N-P Product
46.4
0.95
54
94
5
492
68
30
<1
219
35
0.30
0.59
0.89
Rock Feed
29.9
31.5
43
58
10
313
14
19
9
156
32
0.22
0.31
0.44
CSP (Granular)
47.2
14.3
66
97
12
603
92
71
<1
228
57
0.28
1.01
1.11
Super Acid
68.8
0.12
59
119
<1
700
123
51
<1
345
72
0.46
0.89
1.40
r'.•

Table 4. Analysis of samples from phosphate fertilizer processing, western region
ppm _ %
P205 Ca Cd U Cu Zn• Mn Ni Pb Cr V Al Mg Fe
(I, Beneficiation)
Matrix 25.5 24.8 125 114 .117 1195 100 157 17 1028 1178 1.24 0.33 0.87
Rock Conc 31.3 30.2 120 138 92 760 69 79 12 390 537 0.51 0.21 0.33
(II, Acidulation)
Byproduct H2SO4
(Pb Smelter)
<0.01
<0.01
<1
<1
<1
<1
4
17
<1
24
<1
<0.01
<0.01
0.02
Byproduct H2S0„
(Zn Smelter)
<0.01
<0.01
<1
<1
<1
<1
<1
<1
<1
<1
<1
<0.01
<0.01
<0.01
Rock Feed
32.7
31.7
122
135
80
871
75
85
16
465
660
0.59
0.22
0.39
Gypsum (Dry Solids)
0.92
22.9
12
18
18
48
<1
6
12
53
32
0.09
0.01
0.02
Gypsum (Filtrate)
0.85
0.11
9
6
13
41
5
3
1
9
18
0.01
0.01
0.01
WPA, 28% P205
26.2
0.38
65
83
19
621
60
63
2
313
492
0.42
0.18
0.30.
WPA, 54% P205
53.4
0.13
128
178
55
1202
119
107
1
632
876
0.83
0.26
0.58
(III,
Products)
Feed Acid, CSP
46.6
1.55
103
89
6
1192
114
151
7
545
980
0.74
0.47
0.47
+.
CSP Product
43.9
15.3
83
92
21
973
99
128
4
475
953
0.69
0.60
0.49
N-P Feed Acid
42.5
0.31
98
103
11
1131
88
124
9
532
894
0.66
0.34
0.46
N-P Product
47.7
0.43
105
113
11
1223
116
136
5
604
989
0.87
0.40
0.55
w
Feed Acid, Super
Acid
54.3
0.07
92
114
<1
1314
115
164
6
623
1188
0.78
0.48
0.52
Super•Acid
68.7
0.06
113
138
<1
1651
145
194
7
780
1474
0.97
0.58
0.64

% of P205 % of Cd
Pebble + float concentrate 75 47
Slimes' + sand tailings 25 53
2. In acidulation, the distribution of cad-
mium is about one-third to gypsum and
two-thirds to filter -grade acid in central
Florida processing. Moderately higher
proportions go to gypsum in the other
regions, as shown in the following tabula-
tion and in table 5 (details of the calcula-
tions are shown in figure 5).
Source lb Cd/2000 lb rock
Rock feed 0.0100
Filter -grade acid 0.0063
Gypsum 0.0031
3_ The cadmium contents of the final prod-
ucts are approximately the sum of those
in the starting materials, as shown in the
following tabulations.
MATRIX
2000 LB
3 PPM Cd
0.0060 LB Cd
a
WASHER
40% P20b acid + NH3 -s diammonium phosphate (DAP)
4988 lb acid
4310 lb DAP
40.1% P205
46.4% P205
2000 lb P205
NH3 2000 lb P20r,
7 ppm Cd
8 ppm Cd
0.0349 lb Cd
0.0345 lb Cd
Similar results were found for concentrated
superphosphate:
Rock feed TSP. granular
Pounds•1587 1000 2446
P2069 % 61.6 33.3 47.1
P 06, lb 819 + 333 —11, 1152
C, ppm 6 12 8
Cd, lb 0.0096 0.0120 0.0196
0.0095 + 0.0120 = 0.0215 = 0.0196
The acidulation step is regarded to be of the
most interest in this study. Beneficiation proce-
dures are well established and not likely to
PEBBLE
332 LB
3 PPM Cd
0.0010 LB
FLOAT
264 LB
5 PPM Cd
FLOTATION
FEED 0.0013 LB
1104 LB
—16 MESH TAILS
$40 LB
DESLIMER L
1668 LB 0.3 PPM Cd
0.0003 LB Cd
Figure 4. Cadmium distribution in beneficiation, central Florida region
SLIMES
564 LB
4 PPM Cd
0.0023 LS Cd

Im
change significantly in the near future. The data
indicate that acid contents carry through to
finished products.
On this premise, a simple computer program
was used to calculate approximate acidulation
step material balances. The results are given in
tables 6-8, with footnotes to indicate the
ROCK CONC.
FEED +
H
30.1 % P2 QS
1 ppm Cd
2000 LB ROCK
602 LS P205
0.0100 LB Cd
MAKE-UP
WASH H2O
1,21i P205
assumptions that were used. It is evident that
the assumptions were biased toward high levels
for output, relative to input, and vary with
region; but the approximate balances for the
metals of primary interest lend support to the
conclusion that no major point of distribution
was overlooked.
SCRUBBER
` LIOUDR
0_e'I1. P205
.
�ppn+Cd
GYPSUM
CAKE
FILTER
CAKE
WASH WATER
ACID
1.5 % Play
2.7 % P205
27,21E P205
j_ ppm
CAI _ppm Cd
1'1_ ppm S�d
3146 LB GYP
2103 LB ACID
54 %
4T LB Ploy
S72 LB P205
ACID
0.0031 LB Cd
0.0063 LB Cd
52.6 % P205
_L ppm Cd
1081 LB ACID
572 LB P205
0,0054 L8 Cd
Figure 5. Cadmium distribution in acidulation, central Florida region
Table 5. Distributions in acidulation, central Florida region
lb/2000 1b rock
feed
C_omZ2nent
28% WPAa
gueumb
Rock
input
_Output
A
P,0a
571.8999
47.1817
602.0000
619.0815
17.082
CA
7.1487
789.5078
656.0000
796.6565
140.656
Cd
0.0063
0.0031
0.0100
0.0095
-0.001
u
0.2586
0.1069
0.3120
0.3656
0.054
Cu
0.0147
0.0440
0.0180
0.0588
0.041
Zn
0.0820
0.0598
0.1220
0.1418
0.020
Mn
0.3743
0.0629
0.4160
0.4372
0.021
Ni
0.0442
0.0472
0.0600
0.0913
0.031
Pb
0.0042
0.0189
0.0180
0.0231
0.005
Cr
0.09BB
0,0031
0.1040
0.1020
-0.002
V
0.2103
0,0031
0..2380
0.2134
-0.025
Al
10.7231
2.8309
12.8000
13.5540
0.754
Mg
6.0975
0.6291
5.0000
6.7266
1.727
Fe
17.2411
5.0327
14.4000
22.2738
7.874
°Assumed fitter -grade acid to contain 9S% of input P205,
bAssumed 5.5 tons of gypsum/ton of P20S in filter -grade acid.
cAsuumed output to be the sum of acid content plus gypsum content.
9
ti

Table 6. Distributions in acidulation, north Florida region
lb/2000 lb rock
feed
Rock
om Cponenr-
28% WPAa
Gx2sumb
in2ut
Outputc
A
P20,
590.8999
61.7490
622.0000
652.6487
30.649
Ca
18.7240
887.2361
616.0000
905.9600
289.960
Cd
0.0097
0.0065
0.0160
0.0162
0.000
U
0.1119
0.0520
0.1320
0.1639
0.032
Cu
0.0292
0.0032
0.0500
0.0324
-0.018
Zn
0.1143
0.0195
0.1000
0.1338
0.034
Mn
0.4693
0.0747
0.3740
0.5441
0.170
Ni
0.0170
0.0097
0.0180
0.0268
0.009
Pb
0.0024
0.0422
0.0260
0.0447
0.019
Cr
0.1094
0.0195
0.1360
0.1289
-0.007
V
0.1508
0.0357
0.1960
0.1865
-0.009
Al
11.6721
4.5G99
13.4000
16.2220
2.822
Mg
5.3497
2.6000
4.2000
7.9497
3.750
Fe
12.1584
1.9500
7.8000
14.1084
6.308
aAssumed filter -grade acid to contain 95% of input P20s.
bAssumed 5.5 tons of gypsum/ton of P20s in filter -grade acid.
cAssumed output to be the sum of acid content plus gypsum content.
Table 7. Distributions in acidulation, Borth Carolina region
1b/2000 1b rock
feed
Component,
28% WPAa
Gy2sumb
Rock
-input
0utputc
6
P205
533.8999
41.1103
562.0000
575.0100
13.010
Ca
6.2221
640.1458
592.0000
646.3677
54.368
Cd
0.0502
0.0411
0.0760
0.0913
0.015
U
0.1064
0.0646
0.1240
0.1710
0.047
Cu
0.0020
0.0323
0.0500
0.0343
-0.016
Zn
0.5158
0.1321
0.6060
0.6480
0.042
Mn
0.0903
0.0147
0.0520
0.1050
0.053
Ni
0.0361
0.0235
0.0360
0.0596
0.024
Pb
0.0020
0.0499
0.0220
0.0519
0.030
Cr
0.2609
0.0763
0.3000
0.3373
0.037
V
0.0582
0.0763
0.0640
0.1346
0.071
Al
3.8136
t 0.8809
4.6000
4.6945
0.095
Mg
6.4229
0.5873
6.4000
7.0101
0.610
Fe
10.0357
1.4682
9.4000
11.5039
2.104
aAssumed filter -grade acid to contain 9S% of input P205.
bAssumed 5.5 tons of gypsum/ton of P2O5 in filter -grade acid.
cAssumed output to be the sum of acid content plus gypsum content.
10

Table 8. Distributions in acidulation, western region
_ Ib/2000 lb rock feed
Rock
Ct?mponent 28% WPAa Gypsum input input OutpuCd
P,0,
621.2996
89.50
653.9998
710.7996
56.780
Ca
9.0112
789.77
633.9998
798.7812
164.781
Cd
0.1541
0.1025
0.2440
0.2566
0.013
U
0.1968
0.1025
0.2700
0.2993
0.029
Ctj
0.0451
0.1503
0.1600
0.1954
0.035
7.n
1.4726
0.4441
1.7420
1.9167
0.175
Mn
0,1423
0.0376
0.1500
0.1799
0,030
Ni.
0.1494
0.0410
0.1700
0.1904
0.020
Pb
0.0047
0.0478
0.0320
0.0525
0.020
Cr
0.7422
0.2425
0.9300
0.9847
0.055
V
1,1667
0.2323
1:3200
1.3990
0.079
Al
9.9598
3.7576
11.8000
13.7174
1.917
Mg
4,2685
1.0248
4.4000
5.2933
0.893
Fe
7.1141
1.3664
7.8000
8.4805
0.680
'Assumed filter -grade acid to contain 95% of input P205.
bAssumed 5.5 tons of gypsum/ton of P10s In filter -grade acid.
rGypsum samples were submitted as slurries estimated to contain 33% solids. Solid and liquid fractions were
analyzed separately.
dAssumed output to be the sum of acid content plus gypsum content.
REFERENCES
I. "Cadmium in the Phosphate Industry," Submitted to EPA
by Versar, Inc., August 1979.
2. Cadmium Seminar, The Fertilizer Institute, University of
California Davis, October 1978.
�3, "A Preliminary Assessment of Cadmium Additions to Agri-
cultural Lands via Commercial Phosphate Fertilizers," (Draft
report) SW-718, EPA, Office of Soil and Waste, SCS
Engineers, Inc., August 1978.
4. Auer, C., Project Officer, "Chemical Technology and Econo-
mics in Environmental Perspective," Task VI -Cadmium -in
Phosphate Fertilizer Production,' EPA 66012-77-006,
November 1977.
6. Reuss, J., Dooley, H. L., and Griffis. W., "Plant Uptake of
Cadmium From Phosphate Fertilizer," EPA 60013.76-053,
May 1976.
6. "Technical and .Economic Analysis of Cadmium and Its Com-
pounds," EPA 56013-76-005 (PB 244 625), March 1975,
7. Hodley, W. H., Metha, S. M.. and Sherman, P. L., "Determi-
nation of Hazardous Elements in Smelter -Produced Sulfuric
Acid," EPA 65012-74-13, December 1974.
8. Redistribution of Accessary Elements in Mining and Mineral
Processing, Part IL Uranium, Phosphate, and Alumina,
Committee on Accessory Elements, Board on Mineral and
Energy Resources, Commission on Natural Resources, Na-
tional Research Council, National Academy of Sciences,
Washington, DC,1979.
I

v
HEAVY METALS IN FERTILIZERS
.., DO THEY CAUSE ENVIRONMENTAL AND
HEALTH PROBLEMS?
O. GUNNARSSON ('),
Supra AB. Sweden
k
Man is mining geological deposits and making use of their contents of
}
different elements, #"e and other metals are very important for our material
welfare. P. K. Ca, Mg and many other elements are of fundamental impor-
t
l
lance for agriculture and food production. As we all know the mining and
using of elements have increased very fast during the last century. From eco-
logical point of view the natural hiogeochemical cycles have speeded up and
this has caused some environmental problems.
The fertilizer industry, serving agriculture and food production, is among
others using minerals containing P. K and S. But these minerals are not
i
a clean ). They contain more or less of many 'other elements and with our
present technology parts of the i, impurities -� are transferred to the marketed
fertilizer products and further on to the soils and plants. As far as is known
today K minerals do not cause any significant problems. Impurities of P and
S minerals on the other hand may cause some concern. The problem is their
i
content of so called heavy metals. The paper will be confined mainly to the
i
heavy metals originating from phosphate rock. Problems related to cadmium
(Cd) will be discussed more in detail.
Heavv metals include elements with a density of more than 4 g/cm2.
Their content in minerals is as a rule very low. The usual measure unit is
;
ppm (parts per million) or sometimes ppb (parts per billion). Many of them
are essential for life in low doses but toxic in higher doses. Cu, Zn, Mn, Co
and perhaps also,Cr are examples of essential heavy metals. The biological
function of heavy metals is often as cofactors in enzymatic systems. For some
of the heavy metals the essentiality for life is not yet proved. Examples are
Pb, Hg, Ni and Cd. About Cd there are some litterature references advoca-
ting its essentiality for shell -fish.
J
V) Paper presented at the IFA Agricultural Committee meeting, Paris. March 1983.
27
Fertilizers and Agriculture. W 85. September 1983.
t

}
O. GUNNARSSON
Content of heavy metals in phosphate rock and fertilizers
As the issue of heavy metals and particularly Cd is concerning public
opinion, massmedia and politicians very much in Sweden, the problem was
studied somewhat in detail.
Table I gives some typical analyses of various phosphate rocks. They are
not necessarily representative. The same grade can vary from load to load.
Anyhow, about Cd the difference between sedimentary rocks and apatites
(magmatic rocks) should be noticed. The content of Hg is generally very low.
Also Pb content is comparatively low:-Ni is -an element we know fairly little
about but the content may be of some importance. The content of Zn is high
in sedimentary rocks. in the Swedish apatites there are high amounts of As
and W. As is a classical poison. A study on possible problems related to As
content of fertilizers is going on at the Agricultural University, Uppsala. So
far, As is not considered to cause any serious problems. At Supra W was
studied using a radio -active isotope of the element. The uptake was very low,!,,
and we do not think W will cause any problems.
Table I.
T)pical content of heavy metals in some rock phosphates
analysed by supra in the early seventies.
Mg/Kg (ppm)
Rock phosptra".
Cd Fig Pb Ni Zn As W
Khouribga (Morocco)
18
0.04
2
30
270
10
30
Pebble (Florida) 4 Sedimentary
:`'S 0.09
12
13
80
5
30
Garsa (Tunisia) Rocks
34
0.03
2
16
290
2.1
—
Taiba (Senegal)
71
0.33
4
53
500
2.3
30
Kola (USSR)
0.2
0.01
4
0.5
20
<,
110
Grsnges (Sweden) Apatites
1A
0.04
3
15
21
235
270
l.kab (Sweden)
0.3
0.15
6
20
—
220
110
Table 11 gives figures for heavy metal content in some marketed ferti-
lizers 1975. Cd is mainly coming from phosphate rock. When producing
single superphosphate (the main source of P in P 9 and PK 7-13) all Cd is
transferred to the end product. The P content of the other products is based
on phosphoric acid to which 80-90 % of the Cd in the phosphate rock is
transferred. Ni, Zn, Cu, Cr and Co is also mainly originating from phosphate
rock. Some may come from sulphuric acid and some from corrosion.
28
I
I

Heavy metals in Fertilizers and Environment
.► r
Table H.
Content of
heavy metals in some Supra produced fertilisers
'
in the early seventies.
Content Mg/Kg (ppm)
Fertilizer - Products
Cd
Hg
Pb Ni
Zn
Gu
Cr
Co
P 9
t0
0.3
2 24
I50
59
t35
0.6
PK 7-13
6
0.2
4 18
129
22
110
0.2
N P 26-6
<0.02
<0.01
19 6
7
10
12
0.5
NPK 16-7.13
6
0.1
128 12
276
22
72
0.8
NPK 20-5-9
0,1
<0.01
10 12
22
4
.22
0.8
NPK 20-6-6
0.4
<0.01
10 9
30
11
20
2.3
NPK 12.9-16
10
0.1
130 20
300
34
NPK 14-6-17
5
0.06
138 17
350
38
What are the effects of heavy metals in fertilizers?
Zn, Cu and probably also Cr are important micronutrients for plants,
animals and man. Co in very small quantities is essential for animals and
man. By using fertilizers with a impurities )r of these elements the reserves in
the soils are at least partly maintained. So the o impurities a have to some
extent made possible good yields of satisfactory quality as regards micronu-
trient content. That is the positive side of the heavy metal content of fertili-
zers seldom recognized.
Cd, fig. Pb and Ni in'the amounts given as fertilizers according to table
2 are far below the toxic level for plants. The very Iow content of Fig cannot
possibly cause any problems. Pb is strongly fixed in the soil and considerable
doses are necessary in order to influence the plant uptake significantly. So
the amounts of Pb applied as fertilizers can reasonably be neglected. As
mentioned before very little is known about Ni, but, no serious problem is
expected.
Cadmium and human health
Cd is currently given much concern because of its possible effects on
human health and its wide distribution in the environment.
Although Cd is a toxic substance if ingested or inhaled in sufficient
quantity acute poisoning is very rare. Instead the health problems related to
Cd depend mainly on its long term accumulation in the human organism,
Cd is estimated to have a half-life of 20-30 years in the human body. That
means high concentrations are built up if individuals are exposed to Cd for a
long -time. Cd is particularly concentrated in liver and kidney. The highest
concentration is found in kidney cortex. When. the concentration of Cd in
29
y.
t

0
d
Yi
fix^
O. GUNNARSSON
a certain' level a"sq ecial- rotein ''micro lobWin r_
ktdney 'cortex reachesp_ p , a: • g
-will be'excreted..Thus the first detectable symptom will k e'piotein urea.#
By heavy Cd intoxication the result may be reduced kidney function and
later on a bone disease called osteomalacia. Such symptoms are known from
workers occupationally exposed to Cd for a long time. Also the ltai-Itai
disease occurring among the population of a 'district in Japan is showing
these symptoms. In this district they used heavily Cd contaminated water
from a metal industry for irrigating rice which was used as the main food
source. The heavy Cd intake combined with low intake of protein is conside-
red to be the main cause of the Itai-Itai disease.
According to L. Friberg (Quotation from 5) : Cd
e There is no definite evidence that exposure outside industry has given rise
to medical effects in other parts of the world. s
Off and on hypertension and also some cancer forms are related to Cd
exposure but there does not seem to be any reliable evidence and the hypo-,
theses are rejected.
--''Gdnerally the concentration of Cd in the kidney cortex is used as some
-r; sort.of.index of Cd exposure, Table III gives some medical data on Cd.
Table III,
Some medical data on Cd.
y
Critical level in ki4nev cortex
200 pg/g wet weight
giving detectable protein erea
(range 150-400) (5)
Daily intake over a 50-year
period estimated to give the critical
200 pg/clay
level in kidney cortex
1 4001eg/week) (19)
hlaK-intake recommended by who
400-500 pg/week
i Estimated average daily intake in some
countries.
jig/day
µg1week
reference
United States
39
(273)
compitance prog.
evaluation 1974
Canada
52
(364)
Kirkpatrick and
coffin 1977
West Germany
48
(336)
EPA - 600/6-75-003
Rumania
3"
(266.449)
EPA - 600/6-75-003
Czechoslovakia
60
(460)
EPA - 600/6-75-003
Japan (Unpolluted area)
59
(392)
EPA- 600/6-75-003
Sweden
17
(119)
Kjellslram 1978
30
e

Heavy metals in Fertilizers and Environment
— The critical level in kidney cortex is estimated to be of the order 150-
400 µg/g wet weight. The figure 200 is usually given in literature.
i — The daily intake over a 50-year period estimated to give the critical level
is calculated to be round 200 µg/day or 1'400 µg/week.`" w
i -- The maximum intake recommended by WHO is 400-500 µg/week. Thus
there is a safety factor of about 3.
Table also gives estimated intake via food in some countries. As can be
! noticed they are of the order recommended as maximum intake or lower.
Thus at present there does not seem to be any serious problems. Still the
situation concerns the medical science. From autopsied kidneys there is
found a considerable variation of Cd content. The distribution is found to be
' lognormal and even if the mean is about 20-30 µ/g wet weight there is a
theoretical probability of finding some individuals in a very large population
having reached the critical level 200. If the Cd exposure will increase still
more the a tail » of the distribution curve beyond the critical level will also
increase (figure 1), Because of this the standpoint of Sx-edish medical and
FREQUENCY %
C34]
28
6
i
i 1 2 10 20 100 200 PG CD/G
from Elinder of al, 1976
r — — ~ — — — hypothetical Curve with a geometric mean of 50 µg Cd/g
3
Fig. 1. — Frequency distribution of Cd concentrations in kidney cortex in Sweden 1974
j (black line) and hypothetical curve at a geometric mean value of 5o µg Cd/8 (dotted line). From
Elinder, e1 al, 1978,
I
31
0
I

111
S
O. GUNNARSSON
environmental authorities is that all reasonable measures should be taken to
reduce Cd intake.
Cadmium in food
Food is considered to be the main input source under normal conditions.
Consequently the background of the Cd content of food is subject to much
interest. Phosphate fertilizers are apparently an easily identifiable source.
The input from them to soils can easily be quantified. Other sources are not
so easy to identify and quantify.
But what is the real importance of fertilizer Cd 7
Table IV gives a schematic description of the route of fertilizer Cd in the
food chain. As is seen there are many interfering factors and conditions.
Here some of them will be discussed.
Aw
Table IV.
The route of fertilizer = Cd in the food chain.
Interfering factors and conditions
Fertilizers
Content of Cd and its solubility
i
Content of other elements
Influence on pH in soils ,
Soil
Natural content of Cd and its availability, pH. CEC, clay
content, organic matter
Input from the'air and "via precipitation
Leaching and losses by suspended particles
Recirculation via non harvested biomass and stable manure
Accumulation in the soil
Plants
Genetic variation. differences among plant parts, direct
}
uptake from air and precipitation, content in harvested parts
Husbandry Animals
Retention, accumulation in certain tissues,
i
Transfer to meat and milk
Food processing and
cooking Separation of different parts
IBreakdown
of structure, changing of biochemical properties
Intake by man
Retention : 2-5 % of ingestion
Other inputs . breathing. smoking, water, drinks, occupational
}
exposure
Influences on health
Total daily retention - long term exposure
Accumulation
Dietary properties: proteins, vitamins, other elements
Genetic variation among individuals
General physical condition
32
0
{

Heavy metals in Fertilizers and Environment
Variation of Cd concentration among and within
different plant products entering the food chain
Basic for the discussion of Cd in the food chain is the' concentration of
Cd in vegetable products and the amounts of them that are consumed, Table
V gives Cd analyses and ranges for different plant products entering the food
chain. The table is based on a study on a Mineral element composition of
Finnish foods n (13),
As is quite obvious there is a very wide variation among different pro-
ducts — of the order 100 or more. leafy products and roots are generally
higher in Cd than fruits and grains but the main part of the variation among
different products mast be attributed to genetic factors. Thus there is a wide
variation in the capacities of plants to take up and concentrate Cd in their
different tissues. It is also known from several research reports (Is.t61 that
there are important differences among cuitivars of the same species. The
ranges indicated in table V may to some extent reflect genetic variation
Table V.
Cd concentration. of cereals and vegetables based
on a Finnish surve'i.
P. VARo, M. NUURTAsto, E. SAARt A P. KotvtsTUttiEN: Mineral element composition of Finnish folds.
111, Annual variations in the mineral element composition of cereal grains. 4rta 4gric. Sound. Suppl. 22.
1980. pp. 27.35.
P. VARo• O. LAoELMA, M. NUURTAmo, E, SAAM & P. KolvtsToINE4: Mineral element composition of
Finnish foods,
Vll. Potato, vegetables, fruits, berries and mushrooms. 4cra Agrir. Sound. Suppl. 23, 1990. pp. 99.113.
(PP13)
Product No, of samples Nanogram cadmium/gram dry matter
Averages Range
Grain of winter wheat(')
(34)
74
20- 99
Grain of spring wheat(')
(51)
48
29- 79
Grain of rye (')
(50)
16
5- 43
Grain or barley (')
(47)
24
5- 43
Grain or oats (')
(36)
48
5- 79
Potato
(20)
50
20. 100
Potato. fresh
( 3)
150
100- 300
Carrot
( 5)
273
183- 364
Red beet
( 5)
250
83- 333
Cabbage, white
( 5)
63
63- 125
Cauliflower
( 5)
123
37- 250
Lettuce
( 6)
1000
400.2000
Spinach
( 4)
2143
714-5000
Onion, yellow
( 5)
231
39- 385
Pease
( 3)
125
4. 292
(') Average or rive years (1972-76).
33 F
I

O. GUNNARSSON
among cultivars but the main cause is considered to be variation in environ-
mental factors. The range is of the order 10.
From table V it is clear that the Cd concentration of cereals is compara-
tively low. However, they- particularly wheat — play an important role in
our food.
Is the Cd content of Swedish crops Increasing ?
A group at the Karolinska Institutet 02) has studied the Cd concentra-
tion of winter wheat and spring wheat collected at the plant breeding station
of Svalof/UItuna over the period 1916-72. The same varieties were grown on
the same field over all the period. Thus variation caused by genetic and
geological factors is eliminated. The analyses are plotted in figure 2 and
linear regression of time on Cd concentration is calculated. The seasonal
variation is striking -- of the order 5-10. For winter wheat there is a statisti,
tally significant trend indicating doubling of the Cd concentration over the
period 1916-72. But only 15 % of the variation is explained by the trend. For
spring wheat there is no statistically significant trend.
This study has played an important role in the discussion on Cd in Swe-
den. The results are more or less generalized to all crops. The extrapolation
of Cd burden in kidney cortex indicated in figure 1 is partly based on this
study. Increased Cd-application via fertilizers is supposed to be one of the
causes. In order to get a background Cd input via phospate fertilizers has
been estimated over the period 1900-80. The result is shown in figure 3.
Up to 1946 the input was low. less than I g/ha/y. and practically cons-
tant. From 1946 and forward P fertilization increased considerably and so
also Cd input up to 3.5 g/ha/y 1972. In the early seventies we became cons-
cious of the Cd problem and started to reduce Cd input by selecting Cd low
rocks. Today the Cd input is as an average 1.5 g/ha/y.
Trends for Cd-analyses of wheat grain have also been calculated for the
period 1946-72 in figure 2. These trends are indicated with dotted lines.
There were no significant trends neither for winter wheat nor (or spring
wheat. For spring wheat the trend happened to be negative.
So over the period when Cd application via fertilizerts increased in
Swedish agriculture there does not seem to be any significant. increase in Cd
content of wheat.
When considering the analyses given in figure 2 one should know that
the experimental field is located about 5 km from the centre of the city Upp-
sala. In 1916 Uppsala was a small non -industrialized city and the experimen-
tal field located in a rural area. Over the period considered Uppsala has
grown and developed to an industrialized city. Urban buildings are now
surrounding the experimental field. This of course means increased pollution
and inflow of Cd from the atmosphere to soils and plants.
In conclusion the study is a very weak base for the conclusion that Cd
contents of Swedish crops have increased over the last decades.
I
34 i

O. GUNNARSSON
Atmospheric input of Cd
The main part of Cd in the atmosphere is considered to have its origin
from industrial activities, burning of fossil fuels and garbage incineration.
Because of this the amount deposited on the soil is decreasing from the
southern industrial area in Sweden close to the european continent to the
northern less industrialized and populated area. Analyses of samples of moss
clearly show this distribution (tab. VI). Analyses of old moss samples indi-
cate an increase during the 20th century but as is shown in table VI there is
Table VI.
Cd in Swedish moss 1973 and 1980.
Area
Mg/Kg t
1975 (')
1950 (')
SW
Sweden
0.81
O.S6
SE
Sweden
0.74
0.55
W central
Sweden
0.67
0.43
E central
Sweden
0.62
0,49
NW
Sweden
0.39
0.29
NE
Sweden
0.64
0.49
Average
0.65
0.47
Decrease
—
28 %
M The samples are representing the three last year production
of moss biomass.
Reference: Rilhling, A: Tungmetaller I mossa. monitor 1982.
Statens naturvardsverk,
Cd OIMA
4
s
i
t
] _
- LT I
1000 1906Isla 1016102010261@so 1070104010431Goo 196610/0 f09619I0107S 111a0 '
Fig. 3. -- Estimated Cd input via P fertilizers in Sweden g/ha and year. 5 y:ars averages.
36
1

Heavy metals in Fertilizers and Environment
now a definite decrease from 1975 to 1980. This is in agreement with the
trends for atmospheric deposition of Cd in Denmark over the period 1973-
78 (20)• This decrease is of course a consequence of intensified cleaning of
fumes and other aerial emissions not only in Scandinavia, but all over
Europe.
The atmospheric deposition of Cd on the soil in rural areas of Europe
seems to be in the range 1-5 g/ha/yr with 3 as a likely average. However. the
plants can also pick up Cd direct from the atmosphere. According to a
Danish study (") where radioactive isotope dilution technique was used the
crops picked up 10-60 % of their Cd content direct from the atmosphere. As
uptake from the atmosphere probably is independent of uptake from soil the
atmospheric Cd is probably a very important cause of variation of Cd
content of the crops.
Cd in soil and its availability to plants
The ct natural » content of Cd in agricultural soils is varying from less
than 0.1 to more than I ppm. Considering the surface soil 0-25 cm and a
�--
density of 1.2 this means from less than 300 g to more than 3 000 g/ha. Soilsoar.-t
with •more'than•3 ppm-- may be,considered polluted.," 10 ppm'is usually'•-tdxic
to plants but this of course depends on availability. Some of the Cd content
is exchangeable as Cd2+ and may be considered immediately available to
plants. Not very much is known about the less available forms but some Cd
may be bound to the organic substance.
As indicated in table IV the plant availability is influenced by many
factors. Most important is pH. It is well documented in many reports that
the solubility and the availability of Cd increase as pH decreases. As
examples two diagrams have been taken from a Danish report("). They are
shown in figure 4. The first diagram shows in principle absorption isotherms
for two soils at different pH. The effect of pH is dramatic. Also the diffe-
rence between loamy sand and sandy loam is quite obvious. The loamy sand
with low clay content and low CEC produces higher concentration of Cd in
solution than the sandy loam at the same total content of Cd in the soils.
The second diagram shows Cd content in rye-grass at different pH and dif-
ferent amounts of Cd in the soil (0.15, 0.5 and I ppm). Even here the effect
of pH is dramatic.'[ncreasing pH from 6.0 to 7.0 reduces Cd content of rye-
grass about 60 %.
The diagram shows an almost linear response of Cd content of rye-grass
to Cd content of the soil. Linear relationships between Cd content of the
soils and uptake by the plants seems to be general.
Cd-uptake is also influenced by nitrogen fertilization 0). For winter
wheat a correlation was found between content of Cd and content of N in
wheat grain.
I
37
�i

' 1
' 1
i
O. GUN NARSSON
Relations between the Concentrations of Cd in soil solution
in 2 Danish subsoils, at Ca" — 10-3 M and varying PH.
Cd In sell j
M0rK0 TO
—'--toan,Y sand
.PHs7.Y ;
20 04a4y tears
i'
! • PHUT i
1 e ' •-
ilp
j
r
10 i
+� H—
s ,w
P HF S
�'• PMe
0
. i _��� H
SISI; 0 Cd
10 20 30 40 30 In lost solution ue11
Cd uptake in italien rye grass, as influenced by PH and Cd concentrations
in sandy loam (Askov). Pot experiment.
Cd'In +y.e+aa&
'"91ko Ts off (CAC12)
o s.s
e
0.75
6.s
I. 0.50
1
/ 7
j' 0.23 / 0
0.2s 0.e0 0.7e t TortO Te
Sour" Tje1! J. C. rr o1. 19fi8 (2!). Cd In soil
Fig. 4.
38
i
,

Heavy metals in Fertilizers and Environment
.Input of Cd via fertilizers
The average input of Cd via fertilizers seems to be of the order 3-
4 g/ha/yr for european agricultural soils. The probable range is 0-10 depen-
ding on Cd content of fertilizers and phosphate fertilizing intensity.
Assuming 0.3 ppm to be the Cd content in the surface soil
is 1 000 g/ha) the yearly average input is 0.3 % of the soil content. Thus the
change of the Cd content of the soil is very small.
Some authors argue that fertilizer Cd is more available than soil Cd and
will be so for many years. Analyses from long-term Swedish Meld experi-
ments indicate that newly applied fertilizer Cd is more soluble than the soil
Cd extracted with 2 N HCI, but they also indicate that fertilizer Cd gradually
goes to equilibrium with the less soluble Cd reserves in the soil. Table IX is
showing results of analyses and calculations. The soils are analysed after 17
years of P fertilization and Cd application. The Cd accumulation is estima-
ted. Conventional Swedish soil testing methods according to Egn6r are used.
2N HCl is supposed to extract practically all inorganic Cd. Ammonium lac-
tate/acetate is supposed to measure the immediate plant available Cd. The
a total �) Cd content of these soils is about 1 000 g/ha and of this 25 % is
easily soluble. The estimated Cd accumulation is very well accounted for by
in the amounts extracted with 2 N HCI. But only about half of the estimated
Cd accumulation is found in easily soluble form. The other half is found in
Tableau V11.
Cadmium accumulation and rr fixation s in soils due to superphosphate
application in 'long term field experiments.
Averages based on analYses from 6 field experiments.
Treatments
A B C D
P-Fertilization, kg/ha/year
0
15
30
45
Estimated Cd-application, g/ha/year (1)
0
— t.65
— 3.3
— 4.95
Estimated Cd-Accumulation over 17 years, g/ha
0
— 28
— 56
— 84
Cd extracted from the surface soil ajier 1 i years (1)
II By 2 N HCI (= total?), g/ha
9t3
933
967
1000
Increase due to Cd-Application, g/ha
—
+ 20
+ 54
+ 87
2) By ammonium lactate/acetate (Egner), g/ha
221
229
250
262
Increase due to Cd-Application, g/ha
—
+ 8
+ 29
+ 41
1) ./. 2) (Sparingly soluble Cd), g/ha 692 708 717 738
Increase due to Cd-Application, g/ha — + 16 + 25 + 46
Cd-Content of wheat grain harvested after 15 years,
PPB 107 106 109 ill
(t) Estimated Cd content of used phosphates : 110 mg Cd/kg P.
(3) Calculations based on the assumption that the surface soil of a hectare is 2.5 x IV kg.
39 i
r

O. GUNNARSSON '
the sparingly soluble form. Considering the continuous application and some
time needed to reach equilibrium it is reasonable to believe that the fertilizer
Cd will distribute itself like the other soil Cd.
I Grain of winter wheat grown after 15 years of continuous application
are also analysed for Cd-and accounted for in the last line of the table.
There are no significant differences but possibly a small increase for the
highest application.
To conclude the estimated application of Cd is quantitively accounted
for in the soil but part of it is transferred to sparingly soluble forms and
there are reasons to believe that only 25 % will stay in easily soluble form.
The influence of the increased Cd content of the soil on the Cd content of
wheat grain is not significant.
�j From these experiments it can be concluded that a yearly application of
up to 5 g over 15-20 years will have no practical influence on the Cd content
of the crops. ;
1 Compared to other sources of variation accounted for above (differences i
among plants. pH of soils, atmospheric input and so on) the Cd application
via fertilizers is negligible on a medium term basis.
Taking a very long term perspective — 100 years or more — it can be
argued that Cd will accumulate in the soil and give considerable increased
plant uptake. The degree of Cd accumulation depends upon the difference
'i between total inflow and total outtlow in the soil system. If inflow and out -
now equal there will be a steady state and no accumulation. As outflow
(plant uptake and leaching) normally will increase with increased accumula-
tion a steady state may be reached sooner or later if inflow is constant and
not extremely high. In a simplified mathematical model the level at steady
state is defined by
1Icd
CdS„ ii — id
there Cd�it is the amount of Cd in soil Y-lcd is the total inflow per year and
jCd is the relative fraction of Cd soil lost per year.
Today our knowledge on the total inflow and the total fractional losses
of Cd from a plant available pool in the soil is unsatisfactory. But we do
know that the Cd balance will vary a great deal from local to local and from
case to case. Also the knowledge on the long and complex chain from Cd in
the soil to health: effects on man is unsatisfactory. Having this in mind it is a
little doubtful about generalized conclusions based on mathematical model-
ling and simulations where future Cd exposure due to Cd application by
fertilizers is predicted. But such calculations may be of value for indicating
qualitative trends.
Recently several such calculations are reported (t' 1t}. They indicate that
some soils may reach critical Cd levels 100 years or more ahead.
Against this may be put Cd analysis from very long term field experi-
ments published by Isermann (10). They show Cd enrichment in some cases
but Cd depletion in other cases. Generally the changes are within the margin
of error.
911

Heavy metals in Fertilizers and Environment
The general conclusion about Cd in fertilizers is that application of up to
5-g/ha/yr as an average does not have any detectable effect on human
health at present or in the near future. On a very long-term basis (100 years
or more) there is a possibility of a significant accumulation of Cd in the soils.
But about that our knowledge is unsatisfactory. y
If it is considered desirable from the viewpoint of human health to
reduce Cd input via fertilizers and the society is ready to pay for it, it is
possible. There is plenty of time.
About the Cd content of crops the atmospheric input -'direct or via the
soil - plays an important role.' As emissions are reduced this input will also
be reduced. This is already documented in moss analyses from Sweden 1975
and 1980 (table V1). So it is likely that the Cd content of the crops also will
decrease.
LITERATURE
Ill ANDERSSON. A. Heavy metals in the soil environment on their retention, distribution and
amounts, on the influence of fertilization measures and on methods of analysis. Swedish
J. Agric. Res. 5, 125-135. 1975; 6. 19.25, 1976; 6. 27-36, 1976: 6, 145-150, 1976: 7. 7-20,
1977; 6. 151-159. 1976: 7. 1-5. 1977.
(21 ANDERSsoN. A. & NtLssoN, K. O. Enrichment of Trace Elements from sewage sludge
fertilizer in soils and plants. Ambio, vol. 1, no. 5.
131 COREY. R. B.. 1980. Management and other practices available to food producers. TFI Cad-
mium Seminar. Rosslyn, Virginia, USA, Nov 20-21.
141 DIEHL.. J.-F., 1981. Cadmium and Umwelt. Schriftcnrcihe Chemie + Fortschritt, Heft 3.
Verband der Chemischen Industrie e.V, Frankfurt am Main.
151 FmtPERT. L.. 1980. Cadmium in the industrial and general envirottinment - a toxilogical
appraisal, TFI Cadmium Seminar, Rosslyn, Virginia. USA, Nov. 20-21.
161 GUNNARSSON. O.. 1980. The relative role of fertilisers for the cadmium levels in the food
chain under swedish circumstances. TFI Cadmium Seminar, Rosslyn, Virginia. USA, Nov.
20.21.
171 HuTToN. M.. 1983. The environmental implications of cadmium in phosphate fertilizers.
Phosphorus d Potassium, No. 123. Jan/Feb.
181 HANSEN. J. A. A TJELL. J. C.. 1982. Slammerr jordbrugsanbendelse. ! Overblik. Laboratories
for Ieknisk Hygiejne. Danmarks Tekniske Hjskole.
(91 ISERMANN. K.. Influences of Cd containing fertilizer phosphates on the Cd content of agricul-
tural and horticultural soils. BASF AG, Limburgerhof. West -Germany.
(101 ISERMANN, K. Cadmium in agricultural ecosystems. BASF AG, Limburgerhof. W-Germany.
(Ill JANSSON, S. L., 1975, Bdrdighetsstudier fir markvard. KSLA-T Suppl. 10. 1-60.
1121 KJELLSTRbm. T.. LIND. B., LiNNMAN. L.. ELINDER, C. G.. 1975. Variation of cadmium
concentration in swedish wheat and barley. Arch. Environ. Health- vol 30, July.
1131 KOIVISTONEN, P. (editor), 1980. mineral Element Composition of Finnish Foods. Act. Agric.
Scand. Supp1. 22.
(141 MORTVEDT, J. J.. 1980. Cadmium levels in soils and plant tissues from long-term soil fertility
plots. TFi Cadmium Seminar, Rosslyn, Virginia, USA. Nov 20-21.
(151 PAGE. A. L.. 1980• Information gained on the issue of cadmium in the food chain through the
case study. TFI Cadmium Seminar, Rosslyn, Virginia, USA, Nov 20-21.
(161 PUERSON t ALLOWAY, B. J., 1979. Cadmium in soils and vegetation. The Chemistry, bioche-
mistry and biology of cadmium. Editor: Webb. Elsevier/North Holland.
(171 PrmRssoN, O., 1977. Differences in cadmium uptake between plant species. Swed J.
Agrie. Res. 7.
41

r
I
f
i
O. GUNNARSSON
1181 RUHI.ING. A., SKARBY, L.. 1979. Landromfaaande karrering, ay reglonala rungmetallhalter 1
mosso. SNV PM 1191.
(191 RYAN. J. A.. 1980. Analysis of the cadmium Issue. TFI Cadmium Seminar, Romlyn. Virgi-
nia. USA, Nov 20-21.
1201 T1ELL JENS CHR.. 1980. Armosfaerisk tillforsel til lantbruksomrader ay spormetallerna bly,
cadmium og :ink med nrderbord og stov. Lab. for Iek. Hygiejne, DTH.
1211 TJELL J. C.. HANSEN. J. Aa.. CHRISTENSEN. T. H.. HGvMANts. M. F. 1"0. Predirrian of
cadmium concentrations in danish soils. The Second European Symposium on Characteri-sation. Treatment and Usa of Sewage Sludge. Vienna, 20-24 Oct.
1221 TIELL J. C.. el al. 1980. Planleoptag av bly, kvicksoly og cadmium frq atmosfaerrn. Lab for
lek. Hygiejne. DTH,
1231 Waa. M. (editor), 1979. The chemistry, blorhemistry and blolagy+ of cadmium. Else-
vier/North Holland,
1241 WEIGEL, H. J. h JAGER, H. J.. 1980. Subcellular distribution and chemical form of cadmium
in bean plants. Plant Physiol., vol 65, 480492.
1251 Principal results of the Cadmium Hearing in Berlin. Nov 2-4. 1981.
}•;'
42
i
.
i
i

0
Cadmium and Health:
A
Toxicological
and
Epidemiological
Appraisal
Volume I
Exposure, Dose,
and Metabolism
Editors
Lars Friberg, M.D.
Carl -Gustaf Clinder, M.U.
Professor
Associate Professor
Department of Environmental
Department of Occupational
Hygiene
Medicine
Karolinska Institute
National Board of Occupational
Stockholm, Sweden
Safety and Health
Solna, Sweden"
Tord Kjellstrom, Ph.D. (Med. Dr.)
Gunnar F. Nordberg, M.D.
Senior Lecturer
Professor
Department of Community Hcalth
Department of Environmental
and General Practice
Medicine
Univesity of Auckland
Ume& University
Auckland, New Zealand
Umea, Sweden
CRC Press, Inc.
Boca Raton, Florida
I

IN
transportable
T9.
It. A., Trace
3. 1974. ,
I mnnitorinp.
n by National
Carolinska In-
1xic metals in
ixic metals in
tic absorption
11. 555-559.
amace atomic
it monitoring.
World Health
Vol, 47. John
0
n
Volvine l: &r osure, Dose, gird Mefalx4isrn 23
Chapter 3
CADMIUM: USES, OCCURRENCE, AND INTAKE
Carl -Gustaf Elinder
TABLE'OF CONTENTS
1, General Chemistry................................................................ 24
IL Production and Uses............................................................. 24
Ili. Occurrence....................................................................... 25
'A. Global Emissions and Changes in Human Exposure. . . ................... 26
B. Cadmium in Air .............. ....................................... 29
I, Ambient Air ...................................................... 29
2. Workroom Air .................................................... 30
3. D uslfall........................................................... 30
4. Indirect Mclhods for Measurement of Cadmium Deposition and
Cadmium in Air ...................... ........................ 33
C. Cadmium in Water and Fresh Water Sediments .......................... 34
D. Cadmium in Soil and Uplake by Plants ..................................
35
1. Contauninalion of Soil Caused by Emission from
Industries........................................................ 35
2. Contamination of Soil by Sewage Sludge.........................36
3. Contamination of Sail by Phosphate Fertilizers ................... 38
4. Uptake of Cadmium in Plants ..................................... 40
5. Measures to Decrease Cadmium Uptake -in Plants ................41
E. Cadmium in Food ....................................................... 41
1. Nonpolluted Areas ................................................ 4 l
2. Polluted Areas....................................................4 3
F. Cadmium in Cigarettes...................................................46
IV. Daily Intake of Cadmium........................................................ 47
A. Via Food and Water......................................................47
I. Nonpolluted Areas ................................................ 47
2. Polluted Areas ..................................................... 48
B. Vitt Ambient Air and Smoking ............................................ 50
C. Via Occupational Exposure Routes.......................................50
D. Via Other Sources of Exposure ..................................... , ..... 51
V. Summary and Conclusions........................................................ 52
References............................ :.................................................. 53
N

34 Cadndron and Health: A 7o.ricologicul and Epidemiological Appraisal
Cadmium in moss (mg/kg)
1970
Ml a 1.0
0.8 — 1.0
0,5 0,8
0.3 0.5
t 0.s
1980
z10
0.6 — 0 8
..... 0.4 — 0 6
K 04
FIGURE S. Concentration of cadmium in carpets of moss (hylocomium
splendens) in Sweden in 1970 and 1980,'"•="
cadmium pollution. Increased levels of cadmium in moss can be detected at distances
exceeding 100 km from the sources of emission.212
There are other biological materials which may be used for the screening of cadmium
pollution: e.g., Kobayashi12' measured cadmium in mulberry leaves and noticed a decrease
in cadmium concentration with increasing distance from a cadmium-emilling factory in
Annaka City, Japan. Similarly, Gale and Wixson" and Hemphill et al." reported increased
levels of cadmium in white oak and blueberry leaves in an area cibse to pollution sources
of cadmium in Missouri. Elevated levels of cadmium were also found in decomposing leaf
litter on the forest floor at distances 10 to 20 km from the smelter. Organs obtained from
wild or domestic animals may also be used in order to identify environmental pollution with
cadmium.6 1-1
C. Cadmium in Water And Fresh Water Sediments
The normal cadmium concentration in sea water is about 0.01 to 0.10 µg/f.1-1-150j34-2 .Z2$
Values approximately S to 10 times higher, i.e., about 0.2 to 0.4 p,glf, have been reported
from coastal areas such as the Oslofjord. Norway, and Liverpool Bay, U. K.'("11

Volume 1: E.rposure. Dose, and Melabolisur 35
In rain water collected at areas without•poinrsources of cadmium pollutiow!the chditiiubl{J
concentration has been found to range from O:QI to 0:07 µg/t'.'' "'
IFNresh surface and'ground'waters: tlic-cadiiiiutr"i`coiicerit�sitian is iisualty less t#ianrl"k`g7z'
C. In 49 water samples collected from different local wells throughout Sweden, the cadmium
concentration was below the detection limit of I µg/f in all samples except one which had
a cadmium concentration of 3 µgle,' wranger et al.'"' reported on cadmium concentrations
in raw, treated, and distributed water from the main water supply of 71 municipalities in
Canada. The mean cadmium concentration was C0.02 µg/e with a range between <0.02
to 0.9 µglC. Increased concentration of cadmium in drinking water may occur as a result
of contamination either from industrial discharges or from the use of metal pipes in the
distribution of the drinking water.Z1N Sharrett et al.22' measured cadmium in standing and
running tap water from 130 houses in Seattle, Washington, which had copper or galvanized
pipes. Median levels of cadmium in water were more than ten times higher in water obtained
from galvanized pipes. The median cadmium concentration in standing and running water
from galvanized pipes was 0.63 and 0.25 µgiC and from copper pipes 0.06 and 0.01 µgl
e, respectively.
Natural waters occasionally contain cadmium concentrations higher than I µglt. In areas
where there are zinc -bearing mineral formations, concentrations may reach 10 µg/V
It is important to recognize that in natural, noncontaminated water. as well as in contam-
inated water systems, cadmium is'mainly found in the bottom'sedimenrand'in suspended '-
particles. Yamagata and Shigematsu27" pointed out that in rivers, polluted by cadmittin,, then
metal is often undetectable in'the-water' phase;'rwhile-large'cohceniraiions are found id
suspended -particles and in bottom sediments; This is especially true in water of a neutral
or alkaline pH. A similar Finding was obtained in Sweden, where 0.5 km downstream from
a cadmium -emitting factory, 4 µglC of cadmium was found in water, while 80 mg/kg (dry
weight) was found in mud."' To avoid errors when determining the degree of contamination
in water, cadmium in suspended particles or in sediments must be determined. The contam-
ination of rice fields surrounding the Jintsu River, the area in Japan where the Itai-itai disease
occurred, was probably, due to the transportation to the paddy soil of cadmium -containing
suspended particles when river water was used for irrigation."
D. Cadmium in Soil and Uptake by Plants
Soil is a heterogeneous material. Cadmium concentration in soil is, therefore, highly
variable, depending on the material from which it is derived as well as the types of secondary
t distances
material and organic substances present in the sample. Generally, the -concentration - of
cadmium in soil, with no known cadmium pollution; is less than I mg/kg (dry weight)."' 142
I' cadmium
However, as much as 30 mg/kg has been observed in nonpolluted soil samples derived from
a decrease
shale (see Lund, 1981, cited in Page).19' Figure 6 presents the log normal frequency dis-
tribution of cadmiuii concentration inr361-Swedish"soil'samples analyzed by Andersson.'.
factory in
l increased
The median cadmium concentration in soil vi+dsT0:22* mg/kg. Similar results have been
obtained elsewhere. A large national survey in -Japan has shown that the median cadmium
an sources
posing leaf
concentration in nonpolluted soils is about 0.3 to 0.4 rtigikg.2�0
tined from
1. Conrarninarion of Soil Caused by Emission from Industries
lotion with
The contamination of soil by cadmium can take place in different ways. Deposition of
cadmium from air and water used for irrigation has already been mentioned. Concentrations
in soil near cadmium -emitting industries have also been reported to be highly elevated,
V0.1�4.204.225
ranging from a few to more than 50 mg/kg."•67.'a.152.+83.20" The highest values are normally
n
seen very close to the pollution source. Figure 7 shows cadmium concentrations in surface
{reported
soil with increasing distance downwind from a cadmium production smelter which has been
operating since 1929 in Avonmouth, U.K.12 Thus, emission of cadmium causes local

36 Coebidu t and Health: A Toxicological and Epidemiological Appraisal
so
40
30
20
10
0
M
at
Q1
C1
Gf
d1
O
O
O
I
1
A
V
I
I
to
O
t'7
tt'>
N
to
t0
N
:-
O
O
O
O
O
mg C d/kg
FIGURE h. Frequency disiribution of cadmium in Swedish soils.
(From Andersson, A., Sued. J. Agric. Res.. 7, 7-20, 1977. With
permission.)
problems in many cases. However, long distance transport of air -polluting cadmium may
also occur, although it may be difficult to pinpoint any specific source of cadmium pollution
in areas far removed from the cadmium -emitting industries.
"Mining and refining of metals -such as zinc, copper, lead, and cadmium from ore have
given rise to substantial cadmium pollution in several areas of the world. In Japan, cadmium
emission into water from mines situated upstream of farming areas and atmospheric emissions
from zinc smelters have resulted in cadmium pollution of soils in at least 13 different areas.='°
A good review on cadmium pollution of soils in Japan has been provided by Kitagishi and
Yamane. "' Another heavily contaminated area has been recognized in the village of Shipham,
U.K. Surface soil samples taken from gardens were found to have cadmium concentrations
ranging up to 800 mg/kg, with a median concentration of about 80 mg/kg.."-' In addition to
cadmium, the soil was also rich in zinc, median of about $000 mg/kg, and lead, median of
about 2000 mg/kg. The village was actually built on slag heaps from an old zinc mine which
was operating in the I81h and 19th centurics.'4 Considerable pollution with cadmium has
also been recognized in certain areas of Central Europe,134.142•198
2. Contamination of Soil by Sewage Sludge
Application of municipal sewage sludge to soils may be an important source of cadmium
contamination. The cadmium concentration in sewage sludge has been reported to range
from 2 to 1500 mg/kg dry material, with medians in the order of 5 to 20 mg/kg. J8.&B.187•2"
Regular use of sludge as a nitrogen fertilizer can cause substantial cadmium enrichment in
surface soil. Yearly application of 5 tons/ha (10.000 m2) of sludge containing 10 mg Cd ,
per kilogram, which is not an extraordinary amount, would result in an annual deposition

Volume 1: E posure, Dose, and Metabolism
40
�' 0- 15cm
• • 30-45cm
35
.ar
30
0
N
ZO 25
C
c
a
— 20 .p
N
CL
O
r
c 15
}
l
O 10I
sl
V
4
5
,4
0 5 10 15
Distance from smelter
37
FIGURE 7. Cadmium in surface (0 to 15 cm) and
subsoils (30 to 45 cm) with increased distance from a
cadmium -producing smeherin Avonmouth, U.K. (From
Marples, A. E. and Thornton, I., CmIndum 74. Proc.
2nd Int. Cadmium Coaf., Cannes, Metal bulletin Ltd..
London. 1980, 74--79. With permision.)
of 50 g Cd per hectare. Andersson' has estimated that for a silt loam soil with a bulk density
of 1.33 glcm-', the amount of cadmium in the surface 20 cm of soil with a Cd concentration
of 0.22 mg/kg will be about 0.6 kg/ha. Thus, addition of the above mentioned volume of
sewage sludge would give rise to an increase of about 10% in the surface cadmium content.
Therefore, if sewage sludge is regularly added to the soil on an annual basis, cadmium
content may increase considerably. The amount of cadmium deposited on arable land from
dustfall is less, around 300 µg/m' or 3 g/ha (See Section 111.$.3).
Several investigations have shown that cadmium from sewage sludge is in fact plant
avai table. "" For example, Gutenmann et al." found 20 times higher cadmium con-
centrations in tobacco grown on soil amended excessively with sludge compared to tobacco
grown on control soil. Figure 8 shows a typical pattern of results obtained when plants
.(Swiss chard) were grown on sludge -amended soil. The figure also shows that plants grown

Cadinium and Health; A Toxicological and Epidetniological Appraisal
10.0 1 0 1
9.0
pt a.0 greenhousel y - 0.79 +1.91x
X
�
E T.o
Y
0 8.(} •
i+ so a
a 0
C
s 4.0
3.0 , °o a •
v
U •
2.0 0 • •
ad = M • fleld: 1'• 0.t+4+04IX
1.0 • r .
0 1.0 2.0 3.0 4A
Cd applied to soil In form of sludge (mg/kg)
FIGURE 11_ Relationship between conceniration of cadmium in plants
(Swiss Chard) grown on sewage sludge -amended soils. (Redrawn from
Page, A. L., Bingham, F. T.. and Shang, A. C.. Effer•t of Heat;• Metal
Pollution on Plants, Vol. I. Lepp, W., Ed., Applied Science Publishers,
Barking, Essex. 1981, 77--109. With permission.)
in greenhouses take up cadmium from soil more effectively than plants grown in open fields.
It has not yet been ascertained to what extent the cadmium content in crops is related to the
annual amounts of cadmium added to soil via sewage sludge or to the accumulated amount
added over a period of years. Available experimental results indicate that the annual loading -
is of greater importance than the cumulative amount, but the cadmium previously applied
to soil remains available to plants for extended periods of tin -it. 142
In Sweden, a maximum average of I ton of sludge (dry weight) per hectare (containing.
at most 15 mg Cd per kilogram is permitted. This corresponds to 15 g Cd per hectare. In
Sweden, sludge containing more than 15 mglkg dry weight should not be applied to soil
used for food crops.=" Similar regulations, although somewhat less strict, on maximum
permissible quantity of cadmium addition to soil from sewage sludge have been enforced
in several other countries in Western Europe.1•26=• " In the U.S., an annual application
limit of cadmium from sewage sludge to fields used for the production of crops which
accumulate cadmium has been set at 500 g/ha. "' There are considerable differences in the
maximal amounts of cadmium added to soil from sludge in different countries.'"
Comprehensive reviews covering the effects of sewage sludge on the content of cadmium
in crops are available, e.g., by Pahren et al,."' Sommers,'" U.S. Council for Agricultural
Science and Technology,'" Ryan et al."s and in the proceedings from a recent seminar.1e
3. Contamihation of Soil by Phosphate Fertilizers
Another possible source of contamination is the use of phosphate fertilizers. The con-
centration of cadmium in phosphate fertilizers varies greatly. depending on the origin of the
raw phosphate. Generally, sedimentary rock phosphate has a high cadmium content (Table
i

Volu to l: E:rposure, Dose, and Metabolbm 39
Table 4
CADMIUM CONCENTRATIONS IN NATURALLY
OCCURRING RAW PHOSPHATE OBTAINED FROM
DIFFERENT COUNTRIEiS"••'
Cadmium concentration
in
Cad mlum•concentration relation to the
In phosphate rock phosphate (PIO,)
Country (mg/kg) content (mg/kg)
U.S. (Florida) 5.5-16 IA-52
Morocco 5--30 24-96
Senegal 70-90 225-290
Togo 50 161
U.S.S.R. (Kola) 0.1-0.4 0.3---1.3
Tunisia/Algeria — 60
tsraeWordan — 35
4). The average cadmium concentration in phosphate fertilizers used in the member states
of the European Economic Community during 1979/1980 ranged from 48 to 101 mg/kg
phosphate (PZOS)." Based on the average annual use of fertilizers in the member states of
the EEC (a range from 30 to 144 kg/ha), Hutton" calculated that arable land of the member
states received an annual input of 5.1 g of cadmium per hectare, which corresponds to about
1% of the total cadmium content in surface soil (20 cm in depth).
Commercial fertilizers contain from a few to 200 mg/kg,16' with typical cadmium con-
centrations ranging from 2 to 20 mg/kg.' The corresponding concentrations expressed in
milligrams Cd per kilogram phosphate are about 4 to 5 times higher, i.e., 10 to 100 mg/kg
phosphate. Long-term use of such fertilizers has been shown to increase the cadmium content
in SoilS.4.1MI".269
Williams and David 261-?69,reported that topsoil which hhd bi eWfertiliicd with phosphates
for, more, than 20 years- c"Ontained "significantly "more -cadmium,! 0.1 -mg/kg compared to
similar -unfertilized,soils; -0.05 -mg/kg. Mulla •et al.=66 reported that -soil.-fertilized-with
approximately 175 kg of phosphate per hectare and year, for 36 years had an average cadmiuhl
-concentration of I mg/kg'which was more than 10 times the concentration in unfertilized
control soils. Andersson and Hahlin" investigated the relationship between variable amounts
of cadmium -containing phosphate fertilizers applied between 1963 and 1978, and the cad-
mium concentration in soil. They were able to show that there was a significant linear
increase of cadmium in the soil with increasing amount -of -applied phosphate fertilizers.
From the regression line it was possible to estimate that an annual fertilization with 25 kg
of phosphorus (P) per hectare, a normal amount for Swedish conditions, wilt increase the
cadmium content in soil by 0.3 to 1.1 %. The average cadmium concentration in the phosphate
fertilizer used during the experiment was estimated at about 23 mg/kg (110 mg Cd per
kilogram P)."
NXlt-5 Cadmium from phosphate fertilizers applied to soils is available to plants in a way similar
to that of cadmium from sewage sludge. Williams and David26" showed that cadmium in
superphosphate was as available to plants as cadmium chlorid6 in a later study, the saint:
authors"" revealed a close relationship between accumulated amount of superphosphale
added to soil, and the cadmium concentration in wheat. In agreement with this study,
Andersson and Hahlin" found a similar increase in the cadmium content of barley grown on
experimental fields to which varying amounts of phosphate fertilizer were applied. The
average increase in barley Fertilized with an annual amount of 25 kg phosphorus (P) per
hectare was found to be 0.6 and 1.1% in grain and in straw, respectively, which is close

40 Cadmium and Health: A Toxicological and Epidemiological Appraisal
:11% 0.8
M
CM
i
0.6
CD
m 0.4
w
0
0.2
•- c
M
U 0.0
.. AIM
0 100 200 300 400 500 600 700
gram Cd/hectare
FIGURE 9. The inliuence of p)i on the uptake of cadmium in fodder rape from
soils amended with cadmium -containing sewage sludge. (Derived from Anderson.
A. and Nilsson, K, 0.. Annbio. 3, 198---210, 1974.)
to the increase in soil. Further, the average annual increase of cadmium.in wheat harvested
from the same fields in central Sweden from 1916 to 1972111 was about M/year (Figure 1).
4. Uptake of Cadmium in Plants
The uptake of cadmium by plants is not entirely dependent on the concentration of cadmium
in soil. Other highly important factors are, e.g., soil type, organic matter content, oxidation
reduction potentials, concentration of other trace elements in soil, etc. Plant uptake of
cadmium is considerably more efficient in noncalcareous soils when compared to calcareous
soils.24" The most important factor, apart from the concentration of cadmium, appears to be
the pH of the soil.19' A decrease in pH of soil results in a marked increase in plant uptake
of cadmium. This was first established in the case of wheat grown on sewage sludge -
amended soil,1e but has subsequently been found to apply generally.19I There was a marked
effect of soil pH on the uptake in fodder rape when cadmium was applied to soil in the form
of sewage sludge (Figure 9). Consequently, liming of 'soil may be an effective method of
minimizing the cadmium uptake by plants. Chaney et al." were able to reduce the cadmium
content in soybeans from 33 to 5 mg/kg dry weight by increasing the pH in soil from 5.3
to 7. For a discussion of other soil factors which may.influence the uptake of cadmium by
plants, reference is made to a review by Page et al.1 '
Besides the above -mentioned factors present in the soil and plant environment, there are
other important differences in the capability of various plants to take up cadmium. Kobayashi
et al.127 added cadmium oxide to soil pots and noticed that wheat grain accumulated con-
siderably more cadmium than rice. Bingham et al.," in soil tests using sewage sludge as
an additive, found high levels of cadmium in spinach and lettuce, median levels in radish
and soybeans, and low levels in corn and rice. Similarly, Lonst619 using radioactive cad-
mium, observed a high uptake of cadmium in spinach and lettuce, median uptake in carrot,
tomato, and rapeseed, and low uptake in beans, peas, and wheat. Thus, it may be concluded
that leafy vegetables, such as spinach, lettuce, and Swiss chard, may contain the highest
concentrations of cadmium. Root crops, such as carrot, potato, and radish, will contain
intermediate concentrations, whereas grains and fruits generally contain lower concentra-
tions. In addition to species differences in the uptake of cadmium, it should also be mentioned

Vokaue 1: Evhosure, Dose. and Metabolism 41
that significant differences have been found between different cultivars, or genotypes of the
same species.""I"' For example, Hinesley and co-workers"" showed that certain hybrids
of corn do not accumulate cadmium even if it is grown on soil heavily amended with
cadmium -rich sewage sludge.
5. Measures to Decrease Cwhirium Uptake in Plants
As mentioned earlier (Section IILCA), one way to minimize cadmium uptake in plants
is to increase pli of the soil to above G.S.' Another alternative would be to grow brains
such as barley and corn. or fruits, which have a comparably low uptake of cadmium from
the soil, or to use certain plant genotypes which are known not to accumulate cadmium
from soil."" Sometimes the pH of the soil is already close to neutral or even alkaline, and
is not suitable for growing plants with a low uptake of cadmium. In such cases it may be
necessary to remove the surface soil, since measures to remove cadmium from soil by acids
or complexing agents have so far been ineffective.J9 In Toyama, as well as in other cadmium -
polluted areas of Japan, the local farmers have successfully demanded that the cadmium -
polluted soil should be replaced by nonpolluted soil. " The surface soil down to a depth of
about 30 cm was replaced at considerable expense. Contaminated soil can, without health
hazards, be used for growing flowers or Irces or be used for housing or nonagricullural
industry. This has in fact happened to a great extent in the most polluted areas of Japan,
but not all farmers want to stop growing rice and vegetables on their scarce land.
E. Cadmium in Food
rvested
1. Nonpolluted Arens
ure I }.
In the last 20 years, especially during the 1970s, a large number of reports dealing with
t
Cadmium concentrations in various foodstuffs has been published. There is a substantial
variation in the reported results which most likely reflects, not only true differences in
dmium
_
concentration, but to a great extent analytical variations. Certain early data on cadmium
idation
x
concentrations in different types of food submitted by, e.g., Schroeder et al."' using atomic
ake of
absorption spectrophotometry without previous extraction or background correction, and by
:areous
,
Kropf and Geldmacher-v. Mallinckrodt"` using emission spectrophotonictry, are occasion-
s to be
ally several magnitudes higher than those found at a later date. Unfortunately, old and
uptake
incorrect data are still being referred to as correct in certain scientific publications. For
;Judge-
example, Ryan et al.."' in their extensive review on cadmium in the human food chain,
narkcd
cited Pinkerton et al.19 2"" who reported unrealistically high levels for cadmium in normal
Ee form
human and bovine milk, 9 to 134 and 20 to 34 µgM, respectively. The actual concentration
hod of
of cadmium in milk is most likely below I µgI (Table 5).106..219
dmitmn
Table 5 presents data on cadmium in a number of selected foodstuffs derived from 40
am 5.3
publications. As discussed previously (Section 111.), we have no guarantee that the data
ium by
given in Table 5 are correct. The table should not be considered to provide true concentrations,
but rather to give the reader an idea about the tentative range of cadmium concentrations in
ere are
various types of foodstuffs. The data have been arranged in two groups according to year
)ayashi
of publication. It should be noted that there is a tendency towards obtaining lower values
A con-
in the more recent studies. In view of the improved analytical facilities developed in later
edge as
years, it is reasonable to assume that the recently published analytical results are more
radish
accurate,
ie cad-
A more extensive compilation of published data on the cadmium content in various
carrot,
foodstuffs is given in a document from the Commission of European Communities and
eluded
�t
elsewhere.'`-""`° Measurements of cadmium in various types of foodstuffs made by labo-
sigh t
ralories in different countries have also been compiled by the Food and Agriculture Organ-'
:o
:ontain
ntai
ization within the United Nations and the World Health Organization." Unfortunately, no
:entra-
itioned
;

52 Cacbid utt and Health: A Toxicological and Epidemiological Appraisal
V. SUMMARY AND CONCLUSIONS
Cadmium occurs in nature in conjunction with zinc and is similar to zinc in its physical
and chemical properties. Cadmium is obtained as a by-product during the refining of zinc -
bearing ores, usually at the ratio of 3 tons of cadmium per 1000 tons of zinc. Cadmium is
mainly used in the plating industry, but also in the preparation of various alloys. It is used
in one type of alkaline batteries. Sonic cadmium compounds, primarily cadmium stearate,
are used as stabilizers in plastics, particularly in PVC. Cadmium sulfide and cadmium
sulfoselenide are used as yellow and red pigments in paints and plastics.
Consumption and production of cadmium have increased considerably during the 20th
century. At the beginning of the century, only quantities of the order of tens of tons were
produced annually; by 1980 world production had reached a0proximately 17,000 tons/year.
Only a minor proportion of all refined cadmium is recycled. There is a risk that the
cadmium which is not recycled is distributed, giving rise to pollution of the general envi-
ronment. Certain data indicate that the environmental levels of cadmium, and human ex-
posure, have increased during the last century.
Cadmium -contaminated soil and water may occur naturally or as the result of emissions
from industries, the use of cadmium -rich fertilizers and/or sewage sludge, or in the form of
deposited air pollution. Crops grown on contaminated soils and/or irrigated by cadmium -
contaminated water take up cadmium efficiently. Uptake is strongly enhanced by a low pH
level.
Humans are exposed to cadmium via food, water, air, and dust. For people not occu-
pationally exposed to cadmium, food is the most important source of exposure. In noncon-
laminated areas, most foodstuffs will contain less than 0.05 mg Cd pet• kilogram wet weight.
Cadmium concentrations are generally low in milk, meal, fish, and fruits. Intermediate
concentrations are found in leafy vegetables and in grains such as rice and wheat. High
concentrations of cadmium are found in kidney and liver from adult animals, certain seafoods
such as mussels, oysters, and crabs, and in certain species of wild -growing white mushrooms.
The average daily intake of cadmium in the U.S. and Europe is about 10 to 25 µg with
large individual variations. In Japan, the cadmium intake in nonpolluted areas is 35 to 50
µg/day.
There is a lack of knowledge about the chcmicai species and bioavailability of cadmium
in different types of foodstuffs. If cadmium in certain foodstuffs is less available to gas-
trointestinal absorption than in others, or vice versa, this would obviously have important
practical consequences for the evaluation of the possible harmful effects. More data on the
binding of cadmium in different types of foodstuffs are urgently needed.
The normal concentration of cadmium in water is less than I µgle. At cadmium concen-
trations exceeding 5 to 10 µgIC, drinking water may contribute significantly to the daily
intake of cadmium.
"Normal" concentrations of cadmium in air, about 5 ng/m' or less, do not contribute
much to the daily intake of cadmium, but concentrations of 0.1 to 0.5 µg/m' (weekly or
monthly means) have been recorded in areas close to cadmium -emitting factories. Such high
levels may result in inhalation of I to 7.5 µg Cd per day, which is a significant amount
since the absorption rate in the respiratory tract is greater than in the gastrointestinal tract.
During occupational exposure, inhalation as a rule is the dominating exposure route. Work-
room concentrations of cadmium in the order of 20 µg/m' will result in an inhalation of
more than 150 µg/8 working hours.
Smoking also contributes to daily intake. Smoking 20 cigarettes per slay will probably
cause inhalation of 2 to 4 µg Cd per day. In cadmium industries, cigarettes often become
contaminated by cadmium -containing dust and this will further increase the importance of
this exposure route.

Draft Review: CADMIUM RELATIVE to PLANTS and ANIMALS
A. L. Hatfield, M. R. Tucker, A. Mehlich, and J. M. Hickey
Agronomic Div,, North Carolina Dept. of Agriculture, Raleigh, NC
Cadmium the Metal
Cadmium (Cd) is a soft, silvery -white metallic element. In its natural
state it occurs as the sulfide greenockite which is almost always associated
with zinc sulfide ores and to a smaller extent with zinc containing ores of
lead and copper. The element is never found in the free state in nature,
nor is there an ore of cadmium, so the entire 8 million lbs of primary cadmium
produced in the U.S. is dependent on its recovery as a by-product from the
treatment of other ores containing it. Zinc ores, ZnS, usually run highest
in cadmium, varying up to 0.5 percent. Since cadmium in the environment is
associated with zinc, and the chemical properties of the two metals are very
similar, it is found in the by-products of most zinc mining operations. Other
sources of cadmium include fertilizer impurities, particularly natural phosphate
deposits, gasoline, oil, coal, tires, and many organic waste products.
Cadmium is a constituent of easily fusible alloys such as solder, electro-
plating (major use), deoxidizing agent in nickel plating, process engraving,
electrodes for cadmium vapor lamps, photoelectric cells, electric fuses, auto-
matic fire sprinkling systems, Ni-Cd storage batteries, and as a protective
coating on iron and steel for corrosion resistance. The powder of cadmium is
also used as an amalgam (1 Cd: 4 Hg) in dentistry. Many cadmium salts are ,used
as anthelmititice (worm treatment) in swine and poultry. Consequently, the food
chain is not the only source of Cd contamination in the human environment.
Cd in the Food Chain
Increasing concern over cadmium in the agricultural environment has been
prompted because it has been linked to !t.ypertension, emphysema and other health
problems in animals and man. The hazard to human health from elevated levels of
,Cd in the food chain is magnified because of the cumulative nature of Cd in the

1
tissue of meat animals and subsequent accumulation in the tissue of humans
consuming both animal and plant products. In all the animal feeding trials
reviewed, the Cd content of all tissue analyzed increased in proportion to
the Cd content of the diet, usually in the order kidney > liver > muscle >
fat.
In Japan, contamination of rice paddy soil with 0.9 and 3.0 ppm Cd
resulted in Cd concentrations in rice grain from 0.003 to 1.02 ppm, which
was implicated as a primary factor in a fatal disease of humans, translated
as ouch -ouch. Cadmium is also carcinogenic In animals and is epidemiologi-
cally implicated in human prostate cancer.
Much work can be found in the literature but, as with all biological
research, few nondisputable conclusions can be drawn. The possibility that Cd
is a causative agent in human hypertension has been proposed by Schroeder and
Vinton. However, epidemiological studies of people industrially exposed to Cd
do not support this thesis. Feeding trials with rats indicate the time required
to develop hypertension was related to the level of Cd in the diet. Cadmium -
induced hypertension may be produced in humans at specific levels in the diet but
recent evidence indicates that' the level of Zn in the diet exerts a great in-
fluence on the level of Cd required to develop hypertension.
The level of Cd normally found in human foods range from 0.05 to 0.20 ppm.
Normal Cd concentratione in domestic animal foods are relatively high but seldom
exceed 0.5 ppm. The Cd concentration in uncontaminated grasses range from 0.03
to 0.3 ppm; alfalfa from 0.02 to 0.2 ppm; wheat and oats from 0.1 to 0.5 ppm.
Water consumed by livestock seldom contains more than 0.001 ppm Cd. However when
experimental animals were fed low levels of dietary Cd, significant quantities of
Cd accumulated not only in the kidneys and livers but also in the small intestines
and spleens.
I

s
_3-
The significance of the accumulation of some varying amounts of Cd in
1
specific tissues of animals is unknown. However, Cd induces the production of
a metal -binding protein called metallothionein in the liver. Injected and
dietary Cd causes hypertension and interactions with essential metals in some
tissues, ie,-reduction of Cu, Zn, Fe and Se in tissues such as liver, spleen,
duodenum, testicles and in the blood. In addition, some tissue enzymes are
adversely affected and some histological damage has been reported. We can infer
that, in some unknown way, Cd accumulation in the tissue causes these effects.
Chemistry of Cadmium in Soil
Ceochemically Cd is a chalcophile element which tends to form covalent
bonds with sulfide. Basicly this group of elements includes nickel (Ni), Copper
(Cu), Zinc (Zn), and lead (Pb). In view of the tendency of the Cd atom to have
its' excess charge neutralized by an accompanying exchangeable anion, notably
hydroxyl (OH), it is generally adsorbed on the soil as CdOH+. Only in acid sail
will it be found as the Cd2+ ion. Therefore, the solubility and plant availa-
bility of Cd can be reduced by liming the soil to reduce the harmful effects of
unbuffered -salt -exchangeable hydrogen (11+) and aluminum (Al 3+). The solubility
of Cd is also reduced through chelation or organic matter complexes in the
general order Cu > Pb > Zn > Cd. Cadmium as well as Cu is extractable from
organic soils in measureable quantities only with strong acids in combination
with a chelating agent such as EDTA or DT'PA.
The behavior of Cd in soil is much the saftte as Zn. The amount in circula-
tion has been postulated to be about 1/100 of that of Zn but it accompanies Zn
in roughly proportional amounts through adsorption and downward penetration in
the soil. Consequently, we may be able to follow the movement of Cd by moni-
toring the movement of Zn.

• y
-4-
�T:
The eeneral range of Cd found in soils is usually between 0.01 and 7.0
Vic= ug/g. A. contaminated soil would be considered low at 0.4 ug/g but appreciable
�;
amounts may accumulate from many soil amendments.
The common sources of Cd that would be of concern in North Carolina agri-
culture are by-product lime from Zn ore and flue dust,by-product gypsum or other
materials from phosphate fertilizer production, swine and poultry waste, muni-
cipal waste and phosphate fertilizers. Air pollutants from industrial sites and
auto traffic also may be factors.
Management of Soils
Cadmium content of plants is influenced by rate of application to the soil,
soil pH, soil organic matter, crop species and variety, N and P fertilization
and additions of other metals such as Zn and Cu. Cation exchange capacity is
also influential.
First and foremost, limit or exclude from use all known abnormally high Cd
bearing material,as soil additives or amendments. The effect of application of
high Cd-bearing materials on the Cd content of plants may be evident many years,
perhaps 25, after application.
Since the Cd and many heavy metals is more soluble and therefore more avail-
able for plant uptake in acid soil, the control of soil acidity offers the best
hope to cut down on Cd uptake by plants. Rowever, control of pll probably wi.11
not reduce the Cd content of plants to the same level as that from uncontaminated
soil. Since high Cd levels are usually associated with high Zn levels no plant
deficiencies of Zn would be expected. However, high pll on the Coastal Plain
soils, because of inherently low Mn levels, would probably create many problems
with Mn deficiency.
Some crop or enterprise shifting may be required if localized fields or
whole farms are contaminated with Cd beyond acceptable levels. Different plant

-5-
i_
species, varieties and plant parts contain different levels of Cd wher, grown
on similar soils and at similar rates or levels of Cd. Low accumulaters of Cd
yy. .
would be corn grain, irish potatoes and carrots. high accumulaters would be
most leafy vegetables, most legumes and most of the small grains. Additional
crop choices would be the fiber or non-food crops. Tobacco is a high accumulater
in the leaf tissue. What crop can replace it in N. C. agriculture?
Any practice that would increase the OM level in soil would help immobilize
Cd through increased organo-metal complexing. Other ammendments found to lower
uptake of Cd are low Cd P fertilizers and, to some extent competitive cations
such as Cu and Zn. Any acid form N fertilizer, I►owever, has been shown to in-
crease Cd uptake -
As a last resort or'reclamati.on'effort, deep plowing to bury the Cd or to
mix it with a large volume of soil could be tried. This is not desirable be-
cause of,the host of physical and chemical problems it creates.
The cation exchange capacity (CEC) and amount of metal oxides will prove
to be a controlling factor in the Cd loading capacity of soils and hence the
availability to plants. Consequently, less serious contamination levels would be
expected in the Piedmont and Mountain soils where C,EC's of 8-15 meq/100 dm3 will
be found. The sandy Coastal Plain soils with CEC}s of 2-3 meq may prove to be the
area where most management problems could arise. The organic Tidewater soils
may prove to be troublesome because of the high level of acidity at optimum
pH levels; this may, however, be counteracted by the ability of organic matter
to complex Cd and lower availability to plants. a

TECHNICAL REPORTS
Distribulion of Cadfnium, Zinc, Copper, and Lead in Soils of Industrial Northwestern Indiana'
W. P. MILLER AND W. W. MC FEE'
ABSTRACT
Dive undisturbed locations of sandy Oakville and Plalnfield soils
tinder (eak forest in the heavily industrialized region of northwestern
Indiana were sampled al four depths, to assess the nature and extent
of Cd, Zn, Cu, and Ph contamination. The litter layer and lop 2.5 cm
of soil al a site -Ailhin 5 km or the center of the industrial complex
"rw hluhiy conlantinalcd with Cd, -l_n, Cu, and Ph. t.evels or Cd and
Za decreased rapidly with distance to the south and cast, while Cu and
Ph decreased more erratically, with all metals reaching nearly back-
cruund levels al 18 km. Samples taken deeper in the profiles (30 to 36
end did not show elevated metal levels compared with a rural site 67
kin Its the soulb.'Sequenliai extraction methods applied to the top 2,5-
em soil samples showed large amounts of relatively labile metals as-
,odaled wilh exchange siles (KNO,-extractable: 23, 10, 1, and 8016 of
lutal Cd, Zn, Cu, and Ph, respectively), bound by soil organic mailer
INa,P,O,-extractable: 21, 33, 24, and 4117a of the total Cd, Zn, Cu,
and Pb), and associaled with carbonates and/or noncrystalline Fe
nxidek (EnTA-e,elracrabte: 12, 8, 26, and 28074 of the total Cd, Zn,
('n. and l'b). Minimal amounts of the metals were within the small
amount of crystalline Fe and Mn oxides present In these soils. Non-
r%lrtclable (residual) metals amounted to 26, 32, 23, and 4% of the
tidal Cd, Zn, Cu, and Ph.
Additional Index Words: soil contamination, pollution, metal ex-
lrarlion,
hiller. W. P,, and W. W. McFee. 1983. Distribution of cadmium,
'Inc. copper, and lead in soils of industrial northwestern Indiana. J.
linviron. Qual. 12,29-33.
Contamination of soils by heavy metals has been dis-
covered in urban areas (Klein, 1972), near metal
smellers (Buchauer, 1973), and along roadsides (Lager-
st'erff and Specht, 1970). The source of these metals is,
presumably, deposition in wet and dry fall of metal-
bcarind particulates originating largely from the com-
buslion of fossil fuels and smelting of metals. A recent
survey of forest litter samples has shown widespread
ntclal contamination in northeastern United States from
Virginia to Massachusetts (Andresen et al., 1980).
The high density of population and heavy industry in
t1w Chicago -northwestern Indiana region has prompted
several studies of metal contamination in this area. Air
'amples in this urban region contain two to four times
as much Cd and Pb as rural areas, and orders of mag-
nilude more Cu (Harrison and Winchester, 1971). Sam-
pling of Ap horizons on transacts east of this region
Contribution from the Purdue University Agric. Exp, Sin. Journal
I'�Iper no, 8738. Received 10 July 1982.
'Assist
4ant Professor, Agronomy Dep., University of Georgia, and
1907. or, Agronomy Dep., Purdue University, W. Lafayette, IN
1yp7.
showed no widespread contamination of agricultural
soils with Cd or Zn outside of the Gary -East Chicago
area (Dietz et al., 1978). However, the'study by Parker
et al. (1978) showed severe Cd, Zn, Cu, and Pb con-
tamination of an undisturbed site located in East
Chicago, Indiana. Litter layer and top 2.5-cm soil
samples contained an average of 10 to 100 tithes more
metal than a rural site in central Indiana, and native
plants on the site had metal levels 2 to 10 times greater
than plants at the rural site.
Elevated levels of heavy metals in soils may lead to
uptake by native and agronomic plants (and subse-
quently, animals and humans) and leaching to ground
and surface waters. Movement to plants or groundwater
is dependent on chemical form of metals in -contami-
nated soils. Sequential extraction procedures have been
used to assess the forms of trace metals in polluted sedi-
ments (Gupta and Chen, 1975), sewage sludge (Stover et
al,, 1976), and urban sediments and street sweepings
(Wilber and Hunter, 1979). The ultimate goal of identi-
fying forms of metals retained in soils is to estimate the
potential mobility of heavy metals to food and water
sources.
This research was conducted to characterize the dis-
tribution of Cd, Zn, Cu, and Pb on several relatively
undisturbed sites within the urban area of northwestern
Indiana, particularly with respect to distance from
pollution source, depth in the soil profile, and chemical
form of metal in the soil.
MATERIALS AND METHODS
Potenlial sampling locations were selected by examining topograph-
ic maps and soil surveys of northern Lake County, Indiana. Five lo-
cations with undisturbed profiles and occupying at least several hec-
lares were sampled. The soils were either the Oakville or Plainfield,
series, both mixed, mesic, typic Udipsamments, derived from cal-
careous acolian beach sands and acidic outwash sands, respectively.
All the sites were in mature oak (Quercus velutina L.) forest, with a
heavy accumulation of partially decomposed and fresh leaf litter.
Sample locations are shown in Fig. 1.
At each location, two to four composite samples were taken, de-
pending on the complexity of the topography. Composite samples
were obtained by walking over an area determined to be fairly
homogenous, and extracting 10 to 15 soil cores with a 13-cm diameter
snit probe. Each core was immediately divided into the top L5-cm, 5-
to 10-cm, and 30- to 36-cm segments and bagged separately. Litter
samples (02 horizon, excluding fresh leaves) were composiled from
four to six approximately0.01-mil plots al each site. A total of 15 sites,
at five local ions, were sampled.
In the laboratory the soil samples were air-dried and seived to <2
mm. Moist littler samples were also lightly sieved to remove some of
the sand contaminant. Subsamples of the litter were dried al 105°C
For moisture determination. Total Cd, Zn, Cu, and Pb were solu-
bilized from soil and litter samples by digesting duplicate Subsamples
J. Environ, Qual., Vol. 12, no. 1, 1983 29

(0.5-2 g) in 250-mL flasks with 15 mL or concentrated HNO, on a hot
plate (100*Q overnight. Reflux funnels were used to reduce evapora-
tion. After the overnight digestion five to eight 1-mL aliquots of 30010
H2O, weft added to oxidize resistant organic matter. After H2O, treat-
ment, solutions were transferred to 50-mL volumetric flasks and
diluted to voiume with distilled FI,O. This method gave values com-
parable to HNO,/HCIO„ HF, and dry-ashing (450"C, 24 h) tech-
niques on selected samples (W. P. Miller. 1979. Mobili+y and re-
Icntion of Cd, Zn, Cu, and Pb in sandy soils of northwestern Indiana,
M.S. Thesis, Purdue Univ., West Lafayette, Indiana). Metals were de-
termined by atomic absorption spectrophotometry (AAS) on a Varian
AA6 unit, equipped with hydrogen tamp background correction.
The sequential Fractionation procedure employed for metals was
adapted from Stover et aL (1976). McLaren and Crawford (1973a),
and Chao (1972). Only the 0- to 2,5-cm soil samples were used, One
gram of air-dried soil was mixed on an end -aver -end shaker for the
prescribed time period with a given amount of reagent, centrifuged,
the solution decanted, and the soil residue washed with 10 mL of dis-
tilled H2O. The wash water was discarded after centrifugation, and
the next reagent added. Reagents and extraction times used for in.
dividual metal forms in the soil were;
Ifrr,ersoluble: 10 in H2O, 30 min;
Exchangeable; 10 ml- INK NO., 16 h;
Organically bound: 15 mL I Na,P,O,, 16 h;
Carbonare/rtoncryslalline Fe occluded: 10 mL 0.1 Al EDTA, 16 h;
Nfnoride-occluded; 10mL0,1MNH2O H-HC1 +0.01NIINO,,
30 min;
Crystalline Te oxide occluded. 10 mL 0.271V Na-cif rate + O.I N
Nal ICO,, + 0.25 g Na,S,O,, 80°C, 15 min;
Sulfides: 10mL INHNO., 16 h;
Residual: reflux coned HNO, + H2O,, 12 h.
The 0- to 2.5-cm soil samples were analyzed for particle -size dis-
Iribulion (pipette method), organic matter (Walkley-RWck), free Fe
(dithionite and AAS for Fc), and pH in water (20) (Jackson, 1974)•
RESULTS AND DISCUSSION
Of the five locations sampled, three were Oakville
soils and two were Plainfield soils, In both series, clay
content and free Fe were low (1.6 to 3.0010 clay, 0.3 to
0.7% Fe) and organic matter was relatively high (7 to
16%) in the 0- to 2.5-cm layer. The only property that
differed significantly between series (Table 1) was pH.
The Oakville locations were closer to the industrial com-
plex, which is built on the dune sands of the southern
end of Lake Michigan, while the Plainfield locations are
in the outwash area south and east of the industrial zone
(Fig. 1).
Mean metal contents of the 0- to 2.5-cm soil samples
decreased rapidly with distance from the major indus-
Lake M1chl9an N
Ease
CHICAW
HAMMOND2�1 G A R Y
.3
LW
Fig. 1-Sampling localions in the urban area of northwestern Indiana
Table 1-Selected soil properties of aeries sampled at five
locations for heavy metal analysis.
Distance
from 0. to 2.5•cm soil properties
Loea- whiting- No. of
Lion Series Gary sites Clay Silt Sand OMT Fel pit
ktn
%s
1
Oakville
4.8
4
2.2
12.0
86
8.2
0.60
7.3
2
Oakville
6.7
2
3.0
12.7
84
15.9
0.63
7.0
3
Oakville
7.0
2
2.1
11.5
87
9.6
0.38
7,0
4
Plainfield
16.7
4
1.6
8.4
90
7.0
0.67
6.3
5
Plainfield
17.9
3
2.5
8.1
89
7.9
0.33
5.8
t OM = organic rneller.
# Fe = dithionileextraction.
trial center located on the lake in Whiting and Gary
(Fig. 2). For Cd and Zn, the relationship with distance
appears to be nearly exponential, similar to the findings
of Pietz et aI. (1978) for Cd on a southeast transect
through this area. The concentration decrease for Pb
and Cu was less pronounced to a distance of 7 km, and
Cu actually exhibited a maximum at this distance (loca-
tion 3). Harrison and Winchester (1971) noted localized
regions of elevated levels of airborne Cu in northwest-
ern Indiana due to unidentified industrial activity, in
contrast with fairly uniform distributions of Cd and Zn.
Lead contamination tends to be associated with motor
vehicle density; thus, it may be quite localized (Lager-
werff and Specht, 1970). This possibly accoullts for ele-
vated soil Pb levels at sites 2 and 3 (Fig. 2).
Mean metal distribution at four depths in these urban
soils is presented in Table 2, along with data from a
rural site 67 km south of Lake Michigan (Parker et al.,
1978). Metal concentrations in the litter were similar to
those reported by Andresen et al. (1980) for Pb, Cu, and
Zn, although they were lower than levels found ne r
metal-smclters (13uchauer, 1973). At location 5, (17.9
km) concentrations were still considerably higher than
the rural site (except for Cd), indicating significant de-
position has occurred at this distance. The same trend
was apparent in 0- to 2.5-cm samples. The relationship
between metal concentrations (µg/g) in the litter (ML)
and 0- to 2.5-cm soil (M,-,) was determined by linear re-
gression analysis of data from the original 15 sites plus
the rural site, giving the equations:
12[24 1Cd o
?o 1 125 6
o
6 �1 u� 100 4
1
'at x r100 1 �'Pb 'C Pb M."
100
12 1 e \. 75 3
Q
9 �I �'•� 50 2
`tee
4 6B 10 12 14 16 ih
Km barn Gary -Whiting Area
Fig. 2-Concentrafions of Cd, 7,n, Cu, Pb in the lop 2.5-cm soil sam-
ples as a function of distance from Gary -Whiting Industrial center.
30 J. Fnviron. Qual., Vol. 11, no, 1, 1983

WI M
Cd M,,, = 0.68 MI + 0.03 (r' = 0.95),
Zn M,,, = 0.72ML - 86.5 (r' = 0.95),
Cu M,,, = 0.38 ML -- 3.5 (r' = 0.96), and
Pb W, = 0.58 AIL - 31.4 (r' = 0.91).
The metal concentrations in the surface layer of the
inincral soils were highly correlated with the litter con-
centration, as expected. The lower slope coefficients for
Cu and Pb indicate a greater affinity in the litter layer
for these metals and more restricted leaching.
Metal concentrations in 5- to 10-cm soil samples
(Table 2) reflected the concentrations in upper soil
Myers, but also appeared to be affected by the depth. of
the Al horizon, which was quite variable between and
within locations (range, 7 to 12 cm). Biological mixing
within the Al horizon and organic matter sorption of
any soluble metals may tend to homogenize metals
within the Al, but prevent movement out of this
horizon. Concentrations of 30- to 36-cm soil samples,
,dearly devoid of organic matter, are near background
levels for all metals and show little relation to the metal
loading of the surface horizons (Table 2). Although
the exchange complex of this B horizon material is
limited (4% clay, 0.6% Fe, pH 6.5 for Oakville),
oric would expect some increase in metal concentra-
Table 2-Total Cd, Zn, Cu. and Ph contents of solla at five urban
locations and a rural site at four depths.
Location in Fig. 1
Depth 1 2 3 4 6 Ruralt
cal ng g. -
Litter
17.6
5.3
4.5
2.7
0.6
1.2
0-2.6
12.2
4.2
2.4
1.7
0.9
0.2
5-10
1.3
0.3
0.6
0.1
0.2
0.1
30-36
0.1
0.2
0. i
0.1
0.2
0.1
Zinc
Litter
2977
1504
1161
523
476
96
0-2.6
2300
1044
620
304
142
29
5-10
212
70
98
21
35
13
30-36
11
16
18
8
27
10
Copper
Litter
212.0
247.0
427.0
91.0
75A
9.9
0-2.6
96.3
87.0
150.0
69.0
10.0
3.9
6-10
14.6
8.9
IRA
4.6
4.4
2.2
30-36
1.5
IS
3.0
1.9
3.7
1.9
Lead
Litter
755.0
677.0
677.0
270.0
163.0
71.8
0-2.5
401.0
371.0
314.0
144.0
64.0
20.5
5-10
46.7
29.1
65.0
6.8
8.9
5.9
30-36
0.2
0.6
0.6
0.2
0.9
3.5
t From Parker et al. 11978); actual depths sampled were litter, 0- to 2.5-cm,
2.5- to 14-cm, and 14• to 25-cm.
Table 3-Sequentially extracted Cd, Zn, Cu, and Ph from five locations in northwestern Indiana.
Extractantt
11,0
-KNO.
P,O,
KDTA
N11,011
Na.S,O.
HNO,
I.ocotio„
lsol.)
lexeh.)
lorg.l
tFe ace[.)
(win occl.)
icrys Pet
taut#.)
fleaidue
Total
% of total
Cadmium
l
0.15
24.8
14.8
11.0
6.0
3.3
12.0
22.3
9.82
2
0.35
19.6
16.5
22.0
6.0
4.5
10.0
23.0
3.88
3
0.43
26.0
26.0
10.6
2.0
2.5
9.5
24.0
2.66
4
0.05
25A
23.8
6.0
2,8
1.5
11.8
28.2
1.57
5
0.05
19.0
26.0
3.3
1.7
4.7
12.1
34.7
1.07
LSD (0.06)
0.98
17.8
23.7
1319
8.6
9.1
9.7
19.3
6.96
',lean
0.21
23.0
21.0
11.8
3.7
3.3
11.1
26.4
Zinc
1
0.10
11.0
28.1
14.0
i s's
4.3
8.8
17.8
2490
2
0.10
9.0
37.0
8.0
8.5
3.5
2.5
29.5
921
3
0.16
10.5
36.0
7.6
4.0
7.2
3.0
33.0
497
4
0.15
10.0
29.6
6.1
4.0
10.3
1.0
42.3
234
5
0.47
9.3
32.1
4.0
2.7
12.3
I.0
38.7
136
LSD (0.051
0.01
9.1
24.4
7.7
17.0
10.1
4.9
22.6
1890
Mean
0.19
L0.0
32.5
7.9
7.2
7.6
3.3
32.3
Copper"
1
0.33
0.9
22.6
24.8
7.6
2.6
13.3
28.0
90.8
2
0.25
1.0
22.0
25.0
10.0
6.5
9.5
27.2
71.5
3
0.35
1.1
37.0
33.0
7.2
2.6
9.5
9.6
145.5
4
0.85
1.3
19.0
26.3
7.3
3.0
15.5
27.3
28.0
5
0.77
2.1
1817
24.0
9.1
4.0
20.8
21.0
10.7
ISD10.051
1.16
1.6
36.4
20.4
10.0
4.6
13.1
39.7
185.0
Wean
0.61
1.3
23.8
26.4
8.2
16
13.7
22.6
Lead
1
-
7.0
26.6
30.11
12.5
3.0
14.8
4.6
364
2
-
6.5
37.0
3110
11.1
3A
6.5
6.2
323
3
-
8.0
49.0
26.6
6.6
2.0
6.6
3.0
355
4
-
8.3
42.3
29.3
7.0
2.8
7,0
3.8
115.5
5
-
9.3
61.0
25,3
6.0
2.0
4.3
3.3
63.7
Lsi)(0,05)
8.3
34.4
22.9
16.3
6.4
7.4
4.0
434.0
klean
-
7.6
41.2
28.4
8.2
2.7
7.8
4.0
1 See Materials and Methods for metal forma extracted by specific reagents
J. F.nviron. Qual., Vol. 12, no. 1, 1983 31

lions through adsorption, if metals were moving into
this region. Other studies by these authors (to be pub-
lished) detected no movement of metals out of l-m
intact cores of Oakville soils after application of 10
years simulated rainfall.
The apparent immobility of heavy metals in this soil
was further explored by using a sequential fractionation
procedure to estimate the type of metal bonding in the
0- to 2.5-cm samples. While the specificity of extracting
reagents for given forms of metals in soils is open to
question, the procedure provides an indication of
general types of metal -soil associations (Jenne
and Luoma, 1975). Another problem is that the large
number of determinations performed on one sample
tends to introduce additive analytical error. Regression
analysis of dig/g metal in HNO, digests (Mi)ic,) vs. the
SLIM of the t,g/g metal in the eight fractions (MsuM) gave
the equations:
Cd MDEG = 1.29 Msuhl — 0.6 (r' = 0.99)
Zn MDio = 0.86 MsuM + 94 (r' 0.98)
Cu MDIG = 1.07 Msuh, + 3.3 (r' = 0.99)
Pb Moir = 1.04 Msum + 5.9 (r' = 097)
Although the sums of the fractions are closely related to
total metal in the digests, the deviation of slope from
one for Cd and Zn, as well as the non -zero intercepts,
indicate some systematic analytical error.
The fractionation data presented in Table 3 are means
of metal concentrations in each fraction, expressed as a
percentage of the sum of the eight fractions. Also given,
is an overall mean for the rive locations and an approxi-
mate LSD value calculated as an average of LSD's for
two, three, and four repliations, which were determined
using the method given by Steel and Torric (1960), Gen-
erally, the variation within locations (due to natural
variability and experimental error) was as great as be-
tween locations.
An average of nearly 7D% of the total Cd in these
soils was present in exchangeable, organically bound,
and residual form (Table 3). A high percentage of salt -
exchangeable Cd occurred at all five sites, irrespective
of the level of total Cd. Studies of exchangeable metals
in sludges (Stover et al., 1976) and polluted sediments
(Gupta and Chen, 1975) showed only small amounts of
exchangeable Cd, with most of the metal associated
with organic matter, carbonates, and Fe oxides. Soluble
Cd (Ii O-ext rac table) was related to total Cd levels and
reached quite high levels (0.05 µg/g, dry soil basis) in the
more contaminated Oakville soils. The organic
(Na.P,O,-extractable) Cd fraction in these soils was sig-
nificantly smaller at sites I and 2, the most highly con-
taminated Oakville sites, with a concomitant increase in
the EDTA-extractable fraction. Stover et al. (1976) used
EDTA to extract metal carbonate precipitates from
sludges, finding nearly 50% of the total Cd in this form.
In these high -pH Oakville soils, CdCO, may be precipi-
tating, although there is also evidence that EDTA solu-
bilizes poorly crystalline Fe oxides and associated trace
elements (Borggaard, .1979). The Cd associated with
crystalline Mn (NH,OH•HCI-extractable) and Fe
32 J. Environ. Quat., Vol, 12, no. I, 1983
(citrate- Na,S,O,-ex(ractable) oxides was very low in .
these sails, in contrast to the data of Jenne (1968), who
hypothesized that these oxides are major trace metal .
sinks. Cadmium, extractable with 1N HNO,, attributed
to CdS precipitates by Stover et al. (1976), was also a
small fraction (I I % avg) of the total Cd. There is some 3
doubt as to the presence of sulfides in these aerobic .
soils, and this reagent may actually extract a range of
acid -soluble Cd species. '(he residual Cd is also likely to
be composed of a range of bonding types, although the
large amounts of residual Cd in these soils (average
26%) and the small amount of clay make Hodgson's
(1963) hypothesis of incorporation into mineral lattices t
seem inappropriate for these soils. This fraction may in-
clude resistant Cd oxide minerals, originally deposited
on the soil from aerial sources.
The distribution of Zn (Table 3) was similar to Cd.
but with a reduced amount of exchangeable melal (10%
avg.), and increased organically bound and residual i
fractions (both avg. 32%). Studies of Zn Fractions in
Georgia (Schuman, 1979) and Virginia (lyengar et al.,
1981) soils have found up to 7001a of the Zn in agricul-
tural soils in the residual fraction, and nearly all the re-
mainder associated with Fe oxides. The high organic
content and low amounts of"Fe and Mn appear to de-
termine the Zn distribution found in the soils studied
here. Percent carbonate (EDTA-extractable) and Mn-
associated (NH,OH•HCI-extractable) Zu increased
somewhat in the most contaminated soil (location 1)
relative to the other soils, perhaps indicating saturation
of organic sites and subsequent ZnCO, precipitation
and/or sorption by Mn minerals.
Organically bound (Na,P,O,-extractable), carbonate/ "
poorly crystalline Fe (EDTA-extractable), and residual
fractions were nearly equal in accounting for most of
the Cu in these soils (Table 3). Location 3 soils were the
only samples deviating from (lie mean values to any
degree, with increased organically bond and carbonate/
Fe fractions, and less residual Cu. This may partially ex-
plain its much higher total Cu (Fig. 2). Exchangeable Cu
was quite low (1.3% avg.) probably due to the strong
specific (covalent) interaction of Cu with organic matter
and other surfaces (McLaren and Crawford, 1973b). A
similar fractionation of 24 English soils found an avg.
of 50% residual, 30% organic, and 15% Fe oxide Cu
(McLaren and Crawford, 1973a). The presence of an
avg. of 0.501D of the Cu in water soluble forms may be
an indication of the presence of soluble organic com-
plexes (Hodgson et al., 1966). The drying of soil
samples prior to analysis may have increased solubiliza-
tion of organic matter (Bartlett and James, 1980).
The organic and carbonate/poorly crystalline Fe frac-
tions of soil Pb contained 70% of the total amount of
this metal (Table 3), agreeing with studies relating Pb
sorption parameters to soil organic matter and carbon-
ate levels (Zimdahl and Skogerboe, 1977). Wilber and
Hunter (1979) found higher amounts of Pb in soluble,
exchangeable, Mn oxide, and residual fractions of
several sediments, compared with the soils of this study. t
Such differences may be caused by variation in soil
properties, and by differences in methodology and
interpretation. EDTA was not employed by Wilber and
Hunter (1979) nor by most other workers, and its ability .
p
tl

tb extract carbonates, poorly crystalline Fe compounds,
and possibly other metal forms makes comparison of
procedures employing it with other methods difficult. In
these soils, however, consistently high amounts of
metal, particularly Pb, are extractable with this reagent.
CONCLUSIONS
The data presented here indicated not only that the
soils of the industrial region of northwestern Indiana
are highly polluted with Cd, Zn, Cu, and Pb, but also
that the extent of contamination is limited to the im-
rnediate industrialized region (within roughly 20 km of
Lake Michigan, in agreement with Pietz et A., 1978).
Movement of metals in soil profiles since the time of de-
position also appeared to be minimal, as the litter layer
and top 2.5 cm of soil provide effective retention sites
for the pollutants (Parker et al., 1978).
A sequential extraction technique used to characterize
bo1_ding of metals to the soils showed that organic
matter (Na.P,O, extraction),' carbonates and poorly
crystalline Fe oxides (EDTA extraction), and tightly
bound residual (coned HNO, extraction) fractions con-
tained >70% of the total Cd, Zn, Cu, and Pb. Ex-
changeable Cd and Zn were also significant fractions,
averaging 10-2507D of the total present. Although
alllauntS of organic matter and Fe oxides, and the rela-
tivciy high pH levels of these soils were of obvious im-
portance in influencing this distribution, there was little
variation in fractions between Plainfield and Oakville
series, or with changes in total metal levels. Correlation
and regression analyses of data for metal fractions and
soil parameters similar to those of McLaren and Craw-
ford (1973a) and Iyengar et al. (1981), did not detect
statistical relationships explaining metal distribution.
The specificity of reagents used in these procedures is
largely unknown, and the situation may be further com-
phcated in these highly contaminated soils by the pres-
ence of a variety of insoluble metal precipitates de-
posited on soil. Lead sulfate, separated by density gradi-
ent methods and identified by x-ray diffraction, was
found to account for up to 7001a of the total Pb in'urban
soil samples (Olsen and Skogerboc, 1975). Other pre-
cipitates may form in the soil after the initial deposition
(e.g., Santillian-Medrano and Jurinak, 1975). These
fractionation methods do not resolve solid phases from
metals adsorbed or occluded by soil surfaces. Solubility
determinations have shown that EDTA, but not KNO,
or Na,P,O,, substantially dissolves Cu oxides and hy-
droxycarbonates. Thus, the large amounts of heavy
metals in KNO,- and Na.P,O,-extractable fractions may
accurately represent exchangeable and organically
bound metals, forms which are potentially subject to
leaching (Hodgson, 1963) and plant uptake (Iyengar ct
al., 1981).
LITERATURE CITED
I. Andresen, A. M., A. H. Johnson, and T. G. Siccama. 1980.
Levels of lead, copper, and zinc in the forest floor in the north-
eastern United States. J. Environ. Qua]. 9:293-296,
2. Bartlett, R., and B. James. t980. Studying dried, stored soil
samples -some pitfalls. Soil Sci. Sac. Am. J, 44.721-724,
3. Borggaard, D. K. 1979. Selective extraction of amorphous iron
oxides by EDTA from a Danish sandy loam. 1. Soil Sci. 30:727-
734,
4. Buchauer, M. 1973. Contamination of soil and vegetation near a
zinc smelter by zinc, cadmium, copper, and lead. Environ. Sci.
Technol. 7:13l-135.
5, Chao, T. T. 1972, Selective dissolution of manganese oxides from
soils and sediments with acidified hydroxylamine hydrochloride.
Soil Sci. Sac. Am. Proc. 36:764-768.
6. Gupta, S. K., and K. Y. Chen, 1975. Partitioning of trace metals
in selective chemical fractions of near shore sediments. Environ.
Lett, 10:129-158,
7. Harrison, P, R.. and J. W. Winchester. 1971. Area -wide dis-
Iribution of lead, copper and cadmium in air particulates from
Chicago and northwest Indiana. Almos. Environ. 5:863-880.
8. Hodgson, J. F. 1%3. Chemistry of the micronutrient elements in
soils, Adv.'Agron. 15:119-159.
9, Hodgson, J, F., W. L. Lindsay, and J. F. Trierweiler. 1966,
Micronutrient cation complexing in soil solution: 11. Complexing
of zinc and copper in displaced solution from calcareous soils.
Soil Sci. Sac. Am. Proc. 30:723-726.
10. Iyengar, S. S., D. C. Martens, and W. P. Miller, 1991. Distribu-
tion and plant availability of soil Zn fractions. Soil Sci. Sac.
Am. J. 45:735-739.
11. Jackson, M. L. 1974. Sol] chemical analysis -advanced course.
2nd ed. M. L. Jackson. Dep. of Soil Sci.. University of Wiscon-
sin, Madison.
12. Jenne, E. A. 1968. Controls on Mn, Fe, Co, Ni, Cu, and Zn con-
centrations in soils and water: the significant role ofhydrous Mn
and Fe oxides, In Trace inorganic in water. Adv. Chem. Series
73:337-387.
13. Jenne, E. A., and S. N. Luoma. 1975. Forms of trace elements in
soils, sediments, and associated waters: An overview oftheir de-
termination and biological availability. p. 110-143. In Biological
implications of metals in the environment. Proc. 151h Hanford
Life Sci. Sym., Tech. Info. Center, U.S. ERDA, Washington,
D.C.
14, Klein, D. H. 1972. Mercury and other metals in urban soils.
Environ. Sci. Technol. 6:560-562.
15. Lagerwerff, J. V., and A. W. Specht, 1970. Contamination or
roadside soil and vegetation with cadmium, nickel, lead, and
zinc. Environ. Sci, Technol. 4:583-585.
16, McLaren, R. G., and D. V. Crawford. 1973a. Studies an soil
copper. t. The fractionation of copper in soils. J. Soil Sci. 24:
172-181.
17. McLaren, R. G.. and D. V. Crawford. 1973b. Studies on soil
copper. It. The specific adsorption of copper by soils. J. Soil Sci.
24:443-452.
18. Parker, G. R., W. W. Mcree, and 1. M. Kelly. 1978. Metal dis•
tribution in forested ecosystems in urban and rural northwestern
Indiana. J. Environ. Qual, 7:337-342.
19. Pietz, R. I., R. J. Vetter, D. Masarik, and W. W. McFee. 1978.
Zinc and cadmium contents of agricultural soils and corn in
northwestern Indiana. J. Environ. Qual. 7:381-385.
20. Santillian-Medrano, J., and J. J. Jurinak. 1975. The chemistry of
lead and cadmium in soil: solid phase formation. Soil Sci. Sac.
Am. Proc. 39:851-856.
21. Schuman, L. M. 1979. Zinc, manganese, and copper in soil frac-
tions. Soil Sci. 127:10-17.
22, Steel, R. G.. and J. Ff. Torrie, 1960. Principles and procedures
of statistics. McGraw Hill Book Co., New York.
23, Stover, R. C., L, E. Sommers, and D. J. Silvicra. 1976. Evalua-
tion of metals in wastewater sludges. J. Water Pollut. Control
red, 48:2165-2 175.
24. Wilber, W. G., and J. V. Hunter, 1979. Distribution of metals in
street sweepings, stormwater solids, and urban aquatic sedi-
ments. J. Water. Pollut, Control Fed. 51:2810-2822.
25. Zimdahl, R. L., and R. K. Skogerboe. 1977. Behavior of lead In
soil. Environ. Sci. Technol. 11:1202-1206.
J. Enviren, Qual., Vol. 12, no. 1, 1983 33

Lotus cc:Mail For: Tracy Davis
Author: Charles Gardner at NROLROIP
Date: 6/13/96 1:39 PM
Priority: Normal
Receipt Requested
TO: Mell Nevils
CC: Tracy Davis
CC: Melba McGee at NRDCSOIP
Subject: PC5 FEIS
------------------------------------ Message Contents
David Franklin called me this afternoon to ask if DLR would have
authority to require minimum standards for water quality, including
monitoring, for runoff from reclaimed areas in the PCS FEIS area, I
told him yes, under the broad povisions of the Mining Act, and that we
would do so, if needed, through permit conditions and in consultation
with DEM and other agencies. I told him we would hold on release of
reclaimed areas from the Mining Act until quality of runoff is
assured, by whatever means of assurance is reasonably required.
(He ,indicated the COE is moving quickly now toward release of the
FEIS.)
i

Lotus cc:Mail For: Tracy Davis
Author: Mell Nevils at NROLROIP
Date: 6/11/96 8:02 AM
Priority: Normal
TO: Tracy Davis
Subject: Cadmium
-----------------------------------
Forwarded w/Changes
Author: Charles Gardner at NROLR0IP 6/10/96 5:01 PM
TO: Linda Rimer at NRDCS01P
TO: Preston Howard at Internet
CC: Mell Nevils
CC: Melba McGee at NRDCS01P
Subject: Cadmium
-----------------------------------
Forwarded w/Changes
Author: Melba McGee at NRDCS01F
6/10/96 4:20 PM
TO: Charles Gardner at NROLR0IP
Subject: Cadmium
------------------------------------
Message Contents -
FYI
Forward Header
Subject: Cadmium
Author: Charles Gardner at NROLR0IP
Date: 6/10/96 5:01 PM
The question of possibly excessive cadmimum intake by animals eating
plants growing on PCS gypsum/clay reclamation areas will be in the 20
year mine plan FEIS. David Franklin called me last week to ask if we
have authority under the NC Mining Act to deal with that potential
problem. I told him yes, we do, and will work with DEM, WRC, and the
company to establish any conditions that may be needed in their
detailed reclamation plan (which is part of the Mining Permit).
Franklin indicated he will .refer to the broad authority of the Mining
Act in the FEIS, regarding this potential issue.
Forward Header
Subject: Cadmium
Author: Melba McGee at NRDCS01P
Date: 6/10/96 4:20 PM
I spoke with William Wescott, Wildlife Resources Commission concerning
the information he and the U.S. Fish and Wildlife people were
gathering on cadmium. He said the information being gathered will be
the most up-to-date and complete package of material on cadmium. I ask
him to be sure you received a copy of the information. If the
Reclamation Plan arrives and you have not heard from William please
let me know.
n

DEHNR Fax:[phone] Apr 29 '96 11:43 F.01f15
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�EWNR
North Carolina
Department of
Environment, Health
Natural Resources
WASHINGTON REGIONAL OFFICE
1424 Carolina Avenue
Washington, N. C. 27889
Phone: [phone],91
TO: &0"Z;'
FAX: [phone]
FAX NUMBER:
FROM:
DATE:
Number of pages (including cover page)
i

96 11:43
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DEHNR Fax:[phone] Apr 29 '96 11:46 P-05115
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DEHNR Fax:[phone] Apr 29 '96 11:54 P.14115
/A

Lotus cc:Mail For: Tracy Davis
Author: Charles Gardner at NROLR01P
Date: 4/26/96 4:03 PM
Priority: Normal
Receipt Requested
TO: [e-mail] at Internet
TO: Mell Nevils
TO: Tracy Davis
TO: Jim Simons
Subject: PCS
Forwarded w/Changes ----------------------------------
Author: Melba McGee at NRDCS01P 4/26/96 3:44 PM
TO: Charles Gardner at NROLR0IP
Subject: PCS
------------------------------------ Message Contents --------------------------_----------
Floyd, please send me a copy of your notes or a summary of the
meeting. How did it go? Do you have any reading on when the FEIS
will be released by the COE?
Thanks,
Charles
Forward Header
Subject: PCS
Author: Melba McGee at NRDCS0IP
Date: 4/26/96 3:44 PM
I talked to John Dorney he said the meeting was a brainstorming
session that went well. He said that Doug mentioned another meeting
in May or June. John and Jim Mulligan are suppose to send me their
notes. John mentioned to Doug that the Corps should be invited. Will
keep you posted and send you what they send me.

Il
1-1
U
1
1
1
1
1
1
SUPPORTING INFORMATION FOR
THE SUCCESS CRITERIA IN THE
PCS PHOSPHATE COMPANY, INC.
COMPENSATORY WETLANDS
MITIGATION PLAN
Prepared for:
PCS PHOSPHATE COMPANY, INC.
Environmental Affairs Department
Aurora, North Carolina
Prepared by:
CZR INCORPORATED
Wilmington, North Carolina
August 1995

1
1
1
1
1
1
1
1
I
TABLE OF CONTENTS
page
TITLEPAGE ........................................................ ....i
TABLE OF CONTENTS
LIST OF TABLES ...
LIST OF FIGURES .... ................................................... iii
LIST OF APPENDICES.................................................... id
I. SUPPORTING INFORMATION FOR THE VEGETATION SUCCESS CRITERIA .......... 1
11, SUPPORTING INFORMATION FOR THE HYDROLOGY SUCCESS CRITERIA ......... 12
A. Summary of NCPC Tract Well Data ............................... 12
B. Evapotranspiration Information .................................. 13
C. Rationale for the Revised Hydrology Success Criteria ................... 14
LITERATURE CITED .......... ......... ............ ..................... 16
11

1
1
1
1
1
1
1
Ul
LIST OF TABLES
Table Pane
l Planned seedling distribution for Sections E, F, and G of the Parker Farm ............ 2
2 Actual species composition of planted trees within monitoring transacts on Sections E,
F, and G of the Parker Farm .......................................... 4
3 Species composition of selected naturally vegetated hardwood stands on hydric soils
in the PCS Phosphate Company, Inc. vicinity ............................... 5
LIST OF FIGURES
Figure Page
1 Planned total percentages of seedling species planted on the Parker Farm Sections E,
F, and G........................................................ 3
LIST OF APPENDICES
APPENDIX A ANALYSIS OF WETLAND HYDROLOGY ON THE PARKER FARM:
BLOCKS E, F AND G
APPENDIX B EFFECTS OF TREE GROWTH ON HYDROLOGY AND WETLAND
HYDROLOGIC STATUS
APPENDIX C EVAPOTRANSPIRATION IN NORTHEASTERN NORTH CAROLINA

I. SUPPORTING INFORMATION FOR THE VEGETATION SUCCESS CRITERIA
tIn the Compensatory Hardwood Mitigation Guidelines (8 December 1993), the Wilmington
District of the Corps of Engineers (Corps) specified two major criteria to be applied to determine the
vegetative success of hardwood wetland restoration and creation projects. The density criterion
requires a minimum of 320 trees per acre surviving for three years. The species composition criterion
requires a minimum of six hardwood species with no more than 20 percent of any one species. The
density criterion is based on consultations with foresters experienced in establishing hardwood
' plantations, and it is a reasonable minimum establishment density that ensures a well -stocked stand
when the trees mature. The species composition criterion is intended to ensure a diverse stand at
maturity. However, it often requires an unnatural species composition that is impractical to meet on
many large-scale restoration sites in eastern North Carolina.
While the species composition criterion required by the Corps is an appropriate goal to use when
planning a hardwood wetland restoration or creation project, it may not be appropriate to apply it as
a specific success criterion for the following reasons:
1) It may not be practical to implement during planting.
2) It does not allow a reasonable safety margin for different rates of establishment mortality
' among planted species.
3) It does not allow the natural process of succession to occur. The inevitable natural
regeneration of wind -dispersed volunteer trees is part of succession.
1 4) Most importantly, it does not reflect the species composition of natural wetland hardwood
forests in the PCS Phosphate vicinity.
Table 1 and Figure 1 show the planned species compositions for Sections E,F, and G of the
Parker Farm. The 20 percent rule was used as a general guideline for each section and for the three
sections as a whole. However, because of constraints related to species availability and the planting
zones required for the site, three species (bald cypress [Taxodium distichumj, green ash [Fraxinus
pennsylvanical, and red maple [Acerrubruml) were close to the 20 percent limit. Monitoring transacts
placed in Sections E,F, and G after planting show that even when the 20 percent rule is used as a
guide, it may not be feasible to implement during planting (Table 2). Although overall percentages were
below 20 percent, bald cypress and green ash exceeded 20 percent in the Section E monitoring
transects. In addition, the 20 percent rule allows virtually no margin of safety for high establishment
mortality for a particular species, Heavy mortality of one of the common species could result in the
other common species exceeding the 20 percent limit. The 20 percent rule also does not allow enough
' latitude for the natural regeneration of wind -dispersed species such as sweet -gum (Liquidambar
stryaciflua) and red maple, which can be quite prolific. It is unreasonable to expect that these species
be excluded from early successional stands, especially on such a large scale.
The most important concern with the 20 percent rule is that it does not approximate natural
conditions in the PCS Phosphate vicinity. Table 3 presents the overstory composition of 17 natural
stands near PCS Phosphate. Some of these natural stands are within the area to be impacted by
Alternative B, some are on or near the Parker Farm, some are part of the proposed South Creek Riparian
Corridor, and some are on Weyerhaeuser property in the Gum Swamp. he
of these stands meets
the 20 percent rule, and only a few come close. The average high single species percentage for these
17 stands was 37 percent, and the median high percentage was 47 percent. It is more reasonable to
allow PCS Phosphate to restore a tree species mix that occurs naturally. A more realistic single species
percentage limit that reflects natural conditions would be roughly twice the 20 percent limit.
' The proposed revised species composition component of the vegetation success criteria was
designed to more closely approximate the composition of natural forests in the PCS Phosphate vicinity.
The revised criterion states that no species will comprise more than 40 percent of the total number of
1
1

r
Table 1. Planned seedling distribution for Sections E, F, and G of the Parker Farm.
Zone 1
Zone 2
Zone 3
Zone 4
Zone 5
Totals
Bald cypress
38 %
6 %
6 %
16 %
—
13 %
Green ash
38 %
6 %
6 %
24 %
—
17 %
Overcup oak
6 %
35 %
6 %
—
—
8 %
Black gum
6 %
40 %
6 %
3 %
—
11 %
'
Red Maple
6 %
6.5 %
38 %
24 %
12.5 %
18 %
Water oak
6 %
6.5 %
38 %
5 %
12.5 %
9 %
'
Willow oak
—
—
—
12 %
25 %
9 %
Tulip poplar
—
—
—
4 %
25 %
6 %
'
Cherrybark oak
—
—
—
12 %
25 %
9 %
Totals
100 %
100 %
100 %
100 %
100 %
100 %
1
1
1
1
1
1
1
1

Figure 1.
Planned total percentages of seedling species planted on the Parker Farm
Sections E, F, and G
too
so
C
(d
Q
o 40
20
a
Bald cypress Green ash Overcup oak Black gum Red maple Water oak Wlilowoak Tulip poplar Cherrybark oak
Seedling Species

M M M M M M M M M M M M M M M M r M M
Table 2. 'Actual species composition of planted trees within monitoring transects on Sections E, F, and G of the Parker Farm'.
Section E Section F Section G Total
Tree species Number Percentage Number Percentage Number Percentage Number Percentage
tagged of total tagged of total tagged of total tagged of total
Bald cypress
331
23.0
521
18.0
521
17.8
1,373
18.9
Black gum
90
6.2
330
11.4
144
4.9
564
7.8
Cherrybark oak
39
2.7
185
6.4
333
11.4
557
7.7
Green ash
301
20.9
409
14.1
526
18.0
1,236
17.0
Overcup oak
22
1.5
67
2.3
59
2.0
148
2.0
Red maple
283
19.6
500
17.3
419
14.3
1,202
16.5
Tulip poplar
34
2.4
120
4.1
255
8.7
409
5.6
� Water oak
57
4.0
127
4.4
39
1.3
223
3.1
Water tupelo
81
5.6
114
4.0
46
1.6
241
3.3
Willow oak
115
8.0
275
9.5
410
14.0
800
11.0
Unknown oak
88
6.1
246
8.5
172
5.9
506
7.0
Sweet -gum
1
0.1
0
0.0
0
0.0
1
0.0
River birch
0
0.0
1
0.0
3
0.1
4
0.1
Unknown
0
0.0
3
0.1
1
0.0
4
0.1
Total
1,442
100.1
2,898
100.1
2,928
100.0
7,268
100.1
' Based on 7,268 tree seedlings tagged in seventy 0.2-acre transects.

0
Table 3. Species composition of selected naturally vegetated hardwood stands on hydric soils in the PCS Phosphate Company, Inc. vicinity.
Site
Parker Farm
Section J
Parker Farm
Section FI
Number of
data points Soil series
13 Belhaven muck
13 Ponzer muck,
Dare muck
Community type
hardwood forest
hardwood forest
Dominant tree species
red maple
black gum
sweet -gum
bald cypress
loblolly pine
red bay
laurel oak
black gum
red maple
red bay
tulip poplar
sweet -gum
sweet bay
water oak
American holly
Atlantic white cedar
Average approximate
percentage of total canopy
composition
30
25
22
8
8
3
2
27
26
16
15
5
4
2
1
1
King[Taylor 8 Belhaven muck, hardwood forest red maple 73
Property Wasda muck sweet -gum 9
pond pine 5
American holly 5
tulip poplar 3
black gum 2
sweet bay 2

Table 3 (continued).
Average approximate
Number of percentage of total canopy
Site data points Soil series Community type Dominant tree species composition
Parker Farm 12 Ponzer muck, hardwood forest red maple 57
Section D Dare muck sweet -gum 18
wooded red bay 14
subsections pond pine 10
sweet bay 2
Parker Farm
27 Belhaven muck hardwood shrub -scrub
sweet -gum
38
Section I
red maple
31
red bay
14
tulip poplar
11
loblolly pine
3
a)
American holly
1
sweet bay
1
NCPC tract
4 Muckalee loam, hardwood forest
sweet -gum
49
Section 8
Wahee fine sandy
red maple
15
loam, Augusta
water oak
16
fine sandy loam
white oak
8

IM M M M M M M M M M M IM M_
V
Table 3 (continued).
Average approximate
Number of percentage of total canopy
Site data points Soil series Community type Dominant tree species composition
NCPC Tract
Section 41
NCPC Tract
Section 44
5 Roanoke fine
sandy loam
10 Roanoke fine
sandy loam,
Wahee fine sandy
loam
hardwood forest water oak
30
willow oak
30
loblolly pine
10
red maple
8
swamp chestnut oak
4
blackjack oak
4
hardwood forest red maple
21
water oak
14
southern red oak
12
tulip poplar
11
post oak
9
loblolly pine
8
white oak
6
sweet -gum
2
swamp chestnut oak
1
South Creek 4 Arapahoe fine hardwood forest
tulip poplar
45
corridor sandy loam,
loblolly pine
15
Parcel P-23 Tomotley fine
sweet -gum
13
sandy loam,
bald cypress
8
Dragston loamy
red bay
8
sand
red maple
5
water oak
3
ironwood
3

I= M M M M M M M M M IM r� M M ■r M M M
Table 3 (continued),
Average approximate
Number of percentage of total canopy
Site data points Soil series Community type Dominant tree species composition
South Creek 3 Tomotley fine hardwood forest water oak 33
corridor Parcel sandy loam sweet -gum 27
P-33 red maple 10
tulip poplar 10
laurel oak 10
swamp chestnut oak 7
green ash 3
South Creek 2 Ponzer muck hardwood forest
sweet -gum
40
corridor
red maple
25
Parcel P-41
water oak
15
CO (part)
tulip poplar
15
laurel oak
5
Gum Run 10 Tomotley fine hardwood forest
sweet -gum
25
Reference sandy loam
red maple
18
Forest
tulip poplar
13
red bay
13
swamp chestnut oak
10
water oak
8
ironwood
a
ioblolly pine
5
black gum
3

M M M M M M r ■. M M M M M M M r M M=
Table 3 {continued).
Average approximate
Number of percentage of total canopy
Site data points Soil series Community type Dominant tree species composition
NCSU Gum 18 Cape Fear fine hardwood forest red maple 36
Swamp block 11 sandy loam black gum 18
swamp chestnut oak 16
laurel oak 11
sweet -gum • 10
tulip poplar 8
water oak 2
NCSU Gum 1$ Cape Fear fine hardwood forest sweet -gum 22
Swamp block 28 sandy loam red maple 22
laurel oak 19
swamp chestnut oak 15
black gum 13
tulip poplar 6
loblolly pine 3
American holly 2
NCSU Gum 18 Cape Fear fine hardwood forest sweet -gum 23
Swamp block 3a sandy loam red maple 21
swamp chestnut oak 17
laurel oak 16
black gum 12
tulip poplar 9
water oak 1
sweet bay 1

rr rr rr r rr r rr rr r r r r■r rr r� r �r r r r
Table 3 (concluded),
Average approximate
Number of percentage of total canopy
Site data points Soil series Community type Dominant tree species composition
NCSU Gum 18 Cape Fear fine hardwood forest red maple 37
Swamp block 4' sandy loam sweet -gum 20
black guru 17
laurel oak 10
tulip poplar 7
swamp chestnut oak 5
American beech 3
water oak 1
Western Gum 6 Ponzer muck hardwood forest red maple 54
Swamp sweet -gum 44
0
willow oak 2
a ❑ata from these sites collected as part of the Regionwide 35 Harvesting Study, Hardwood Research Cooperative, N.C. State University
(unpublished).

Imes present on a section of restored hardwood wetlands on prior -converted cropland. This upper limit
1 is aimed at the middle of the range of natural variation in forests in the area. It is apparent, however,
that the natural forests used as the model for the revised criterion have been subject to past cutting
that has allowed ruderal species like sweet -gum and red maple to become more dominant than they
' would be under pristine conditions. Because it is not the intent of the restoration projects to imitate
this disturbed condition, an additional requirement of the revised species composition criterion is that
sweet -gum and red maple in combination cannot comprise more than 40 percent of the total species
composition. While this requirement recognizes that sweet -gum and red maple cannot be excluded
from young hardwood plantations, it prevents the restored wetlands from being dominated by these
two species. For mitigation sites planted prior to August 1995, sweet -gum and red maple in
combination cannot comprise more than 50 percent of the total species composition. This slightly
higher percentage is allowed for these sites because red maple was planted on all mitigation sites
constructed prior to August 1995.
' In light of the above information, the vegetation success criteria have been revised as follows:
The PCS Phosphate prior -converted cropland hardwood wetland restoration
' areas are planted with a diversity of hardwood species (usually nine species).
Vegetation success is monitored with vegetation transects scattered throughout the
restoration areas. Success is measured by tree survival and species composition,
Average tree density on each section of restored prior -converted cropland will be at
least 320 trees/acre at the end of the third growing season. This will include all
surviving planted trees and all naturally regenerated trees that have attained a minimum
height of 24 inches. As an additional quality assurance/quality control measure, at the
' end of the fifth growing season, 10 percent of the vegetation transects will be
resampled, and if the trees/acre criterion is not met then remedial action will be taken.
At least six species of hardwood trees will be present on each section of
' restored prior -converted cropland at the end of the third growing season. This will
include all surviving trees and all naturally regenerated trees that have attained a
minimum height of 24 inches, Bald cypress and pond cypress will be considered
hardwoods. For areas planted prior to August 1995, no one species will comprise more
than 40 percent of the total number of trees present in any section, and if the total
number of sweet -gum and red maple is more than 50 percent of the total number of
trees present in any section, then remedial action will be taken. For areas planted after
August 1995, no one species will comprise more than 40 percent of the total number
of trees present in any section, and if the total number of sweet gum and red maple is
more than 40 percent of the total number of trees present in any section, then remedial
action will be taken. Also, if more than 10 percent of the trees in any section are
lobiolly pine then remedial action will be taken,
17

P
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II. SUPPORTING INFORMATION FOR THE HYDROLOGY SUCCESS CRITERIA
The hydrology success criterion given by the Corps in the Compensatory Hardwood Mitigation
Guidelines specifies that wetland restoration and creation sites must exhibit continuous saturation to
the surface or inundation for at least 12.5 percent of the growing season under reasonably average
climatic conditions. This requirement is more stringent than the hydrology criterion used by the Corps
for delineating wetlands for regulatory purposes. Within the EIS project area, the Corps has exercised
regulatory jurisdiction over wetlands with hydroperiods as short as 5,0 percent of the growing season.
If wetlands are delineated with hydroperiods less than 12.5 percent of the growing season, it is
reasonable to allow wetland mitigation projects to meet a hydrology success criterion of less than 12.5
percent of the growing season. In past meetings, the Corps and other agencies have justified applying
the 12.5 percent standard to mitigation sites as a safety factor to account for increased
evapotranspiration (ET) when the vegetation matures. The thought is that sites with hydroperiods
shorter than 12.5 percent of the growing season at the end of a three-year monitoring period will have
hydroperiods shorter than 5.0 percent when the trees mature. Assuming this thought is valid, applying
the 12.5 percent mitigation site standard is still unreasonable to applicants who have had early
successional project area wetlands delineated at less than 12.5 percent. The following information
demonstrates that application of the 12.5 percent hydrology standard to PCS Phosphate wetlands
mitigation sites is unreasonable, and that there is no need for a safety factor to account for increased
ET over time.
' A. Summary of NCPC Tract Well Data
From 1991 to 1993, CZR collected shaliow monitoring well data from over 378 sites in the
' NCPC Tract. Wells were located in 61 sections throughout the NCPC Tract. Sections were identified
by CZR as areas of relatively similar habitat. The wells were installed to facilitate jurisdictional wetland
delineations in interstream divide areas where field indicators of wetland hydrology were questionable.
fl
Jurisdictional areas of the sections where the wells were located comprise approximately 1,640
acres. Of these 1,640 acres, approximately 176 acres (10.7 percent) are estimated from the well data
to have been delineated as wetlands with hydroperiods longer than 12.5 percent of the growing season.
The remaining 1,464 acres (69.3 percent) were delineated as wetlands with hydroperiods between 5
and 12.5 percent of the growing season. Therefore, at least 1,464 acres of the 3,069 acres of
wetlands delineated in Alternative S (47.7 percent) would have hydroperiods between 5 and 12.5
percent of the growing season.
A crude maximum estimate of the area of wetlands in Alternative B with hydroperiods shorter
than 12.5 percent can be obtained by extrapolating the 89.3 percent Figure derived above to all of the
interstream divide wetlands in Alternative B, There are approximately 2,909 acres of interstream divide
wetlands in Alternative B. The remaining 160 acres of wetlands in Alternative B are bottomland
hardwoods, ponds, and freshwater marshes. Although no wells were installed in these communities,
it is assumed that they are wet for more than 12.5 percent of the growing season. Applying the 89.3
percent figure to the 2,909 acres of interstream divide wetlands, it is estimated that approximately
2,596 acres of wetlands delineated in Alternative B (84.7 percent) would have hydroperiods between
5 and 12.5 percent of the growing season. Clearly this is an overestimate, because wells were not
installed in areas where the presence of wetland hydrology was apparent. However, it does serve to
establish an upper limit to the range of acreage in Alternative B that is estimated to have. been
delineated between 5 and 12.5 percent.
Within the areas estimated to have been delineated as jurisdictional wetlands with hydroperiods
shorter than 12.5 percent of the growing season, there were at least 108 wells that exhibited upland
hydrology (hydroperiod shorter than 5.0 percent of the growing season) during one or more of the years
12

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I
1991 to 1993. At least 33 wells within this area exhibited upland hydrology for two of the three years.
Although there was considerable variability in rainfall from year to year, rainfall during the early part
of the growing season of each year was within the normal range.
The NCPC Tract well data indicate that between 47.7 percent and 64.7 percent of the
jurisdictional wetlands in Alternative 8 were delineated with hydroperiods between 5 and 12.5 percent
of the growing season. Furthermore, some of the marginal areas delineated as jurisdictional wetlands
had upland hydrology for one or two of the three years that wells were monitored. PCS Phosphate is
being required to provide compensatory mitigation for impacts to all of the jurisdictional wetlands in
Alternative B, regardless of length of hydroperiod. It is unfair to require PCS Phosphate to provide
mitigation sites that all have hydroperiods longer than 12.5 percent of the growing season when half
or more of the wetlands proposed to be impacted have hydroperiods between 5 and 12,5 percent of,
the growing season.
B. Evapotranspiration Information
To answer the question of whether increases in ET with vegetation maturity can remove
jurisdiction from mitigation sites that start out with hydroperiods between 5.0 and 12.5 percent of the
growing season, CZR gathered information on ET in wetlands from three primary sources.
Richardson and McCarthy (1994) conducted DRAINMOD computer model simulations of
hydrology for organic soil sites in eastern North Carolina that were in various stages of vegetation
development. Their simulations predicted that peatlands with the vegetation recently removed should
lose 59 percent of their total annual rainfall to ET. Agricultural peatlands were predicted to lose 61
percent of their total annual rainfall to ET, and naturally vegetated peat -based pocosins were predicted
to lose 66 percent of their total annual rainfall to ET. Thus the difference in total annual losses to ET
between essentially bare soil and mature pocosin vegetation is only 7 percent. The difference shrinks
to 5 percent when mature vegetation is compared to agricultural vegetation, which could be considered
roughly equivalent to a first -year hardwood plantation dominated by herbaceous vegetation. If the
percentages are applied to the average annual rainfall of 49.85 inches at PCS Phosphate, it is estimated
that total annual ET in first year hardwood plantations averages 30.41 inches, whereas for mature
vegetation it averages 32.90 inches, a difference of only 2.51 inches. The estimate for mature
vegetation probably overestimates ET for mature hardwood plantations because it is based on data from
pocosins. Pocosins are largely dominated by evergreen vegetation and are likely to have higher total
annual ET than deciduous forests. It is also important to note that these are estimates of total annual
ET. Differences in ET between vegetation stages during the critical early growing season months of
March, April, and May will be much smaller.
Drs. R. W. Skaggs and G. M. Chescheir of N. C. State University used DRAINMOD and a 40-
year record of rainfall data to simulate the water table on Sections E, F, and G of the Parker Farm, after
blockage of the drainage system (see Appendix A). Their initial simulations used a root depth of 6
inches. When it became apparent that potential vegetation -induced changes in ET over time would be
an issue affecting the formulation of the hydrology success criteria, Dr. Skaggs ran additional
simulations using root depths of 2.4 inches and 11.8 inches. These depths were intended to represent
a hardwood plantation at establishment and a mature hardwood plantation, respectively. These
simulations showed that for areas with high surface storage, the 12.5 percent hydrology criterion
should be met in 34 to 38 years out of 40, regardless of root depth. More importantly, in areas with
low surface storage where the 12.5 percent criterion should only be met 16 or 17 years out of 40 when
the root depth is shallow, increasing the root depth only reduced the proportion to 13 years out of 40,
This is important because it illustrates that in areas with marginal wetland hydrology, increases in root
depth resulted in only small decreases in the frequency of wetland hydroperiods. Dr. Skaggs wrote a
short report to accompany the simulations (included here as Appendix B). In this report Dr. Skaggs
13

1
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stated that differences in ET between different stages of succession occur mainly during dry periods.
During wet periods when the water tablets close to the surface, ET is limited on4y by the atmosphere's
ability to evaporate water. During such times, ET will be essentially equal to potential
evapotranspiration (PETi, which is not affected by the vegetation.
CZR also contacted Dr. Robert Evans of N. C. State University, Dr. Evans provided ET data
from a site near Plymouth, N. C., and he wrote a short memorandum expressing his professional
opinion on the effects of vegetation stage on ET (Appendix C). Dr. Evans concurred with Dr. Skaggs'
opinion that vegetation stage has little effect on ET during wet periods. The data he sent compared
actual ET for an undrained hardwood forest wetland, a drained hardwood forest wetland, a drained
mature pine plantation, a drained fescue pasture, and drained bare soil. All of the sites were on
Portsmouth loam. Total annual ET ranged from 29.5 inches for the bare soil to 37.2 inches for the
undrained hardwood forest wetland, a difference of 7.7 inches. The most important comparison,
however, is between the drained hardwood forest wetland and the drained fescue pasture. Any
difference in ET between these two stages should be due to the effect of the hardwood forest
vegetation. Total annual ET in the drained hardwood forest wetland was 35.8 inches versus 34,3
inches for the drained fescue pasture, a difference of 1.5 inches. When the comparison is limited to
the critical early growing season months of March, April, and May, ET was 11 .1 inches for the drained
hardwood forest wetland versus 10.6 inches for the drained fescue pasture, a difference of only 0.5
inches. Thus the data provided by Dr. Evans confirm the expert opinion that vegetation stage has little
effect on ET during wet periods.
C. Rationale for the Revised Hydrology Success Criteria
The available evidence on the effect of vegetation stage on ET indicates that there is no need
for an ET safety factor in the hydrology success criteria. Therefore, proposed revisions to the
hydrology success criteria are focused on making them reflect the hydrology criteria that the Corps uses
when claiming regulatory jurisdiction over wetlands.
In a 6 March 1992 clarification and interpretation memorandum for the 1987 USACE Wetlands
Delineation Manual, the Corps describes wetland hydrology in the following terms:
"Areas which are seasonally inundated and/or saturated to the surface for a
consecutive number of days for more than 12.5 percent of the growing season are
wetlands, provided the soil and vegetation parameters are met. Areas wet between 5
percent and 12.5 percent of the growing season in most years (see Table 5, page 36
of the 1987 Manual) may or may not be wetlands. Areas saturated to the surface for
less than 5 percent of the growing season are non -wetlands. Wetland hydrology exists
if field indicators are present as described herein and in the enclosed data sheet."
The memorandum then provides a list of primary and secondary field indicators to be used to determine
whether wetland hydrology exists. These indicators are less reliable than recorded water table data and
therefore are not relevant for mitigation sites where the water table is intensively monitored.
In light of the above information, the proposed hydrology success criteria have been revised to
allow credit for sites that are inundated or saturated to the surface between 5 and 12.5 percent of the
growing season in most years. Organic soil sites, however, will only receive partial mitigation credit
if the hydrology is in the marginal range, because it is unlikely that organic soils can persist over the
long term with such a short hydroperiod,
14

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1
The revised hydrology success criteria read as follows:
Wetland restoration sites on organic soils (e.g. Dare muck, Ponzer muck) that
are inundated or saturated to the surface for a consecutive number of days greater than
12.5 percent of the growing season are hydrologically successful and will receive full
restoration credit. Organic soil sites that are inundated or saturated to the surface
between 5 and 12.5 percent of the growing season in most years are successful but
will be credited at a lesser rate. Wetland restoration or creation sites on mineral soils
(e.g. Roanoke fine sandy loam, Tomotley fine sandy loam), or mineral soils with histic
epipedons (Wasda muck} that are inundated or saturated to the surface for a
consecutive number of days greater than 12.5 percent of the growing season are
hydrologicalfy successful and will receive full credit. It such mineral soils are inundated
or saturated to the surface between 5 and 12.5 percent of the growing season in most
years they are also hydrologically successful and will receive full credit, Standing water
within 12 inches of the surface will be considered a positive indicator of wetland
hydrology (i.e. saturation to the surface).
15

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LITERATURE CITED
Richardson, C. J., and E. J. McCarthy. 1994. Effect of land development and forest management on
1 hydrologic response in southeastern coastal wetlands: a review. Wetlands 14:56-71.
1
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F,
APPENDIX A
' ANALYSIS OF HYDROLOGY
ON THE PARKER FARM: BLOCKS E,F AND G
[.1
1

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1
1
1
1
ANALYSIS OF WETLAND HYDROLOGY ON THE PARKER FARM:
BLOCKS E,l~ AND G
Prepared by:
Dr_ R.W. Skaggs and Dr. G.M. Chescheir
DRAINMOD
2824 Sandia Drive
Raleigh, North Carolina
Prepared for:
CZR Incorporated
4709 College Acres Drive, Suite 2
Wilmington, North Carolina 28403
December, 1994
1

ANALYSIS OF WETLAND HYDROLOGY ON T14E PARKER FARNI:
BLOCKS E,F, and G
By
' Dr. R. W_ Skaggs and Dr. G.M. Cheschelr
EXECUTIVE SUMMARY
' The objective of this project was to analyze the hydrology of Blocks E, F, and G of the
Parker farm to deternune if proposed modifications in the drainage system will result in water
table conditions that will satisfy wetland hydrologic criteria. Alternatives to the proposed
plan that would require less earth work at a reduced cost were also analyzed.
We spent one day on the site to make soil property measurements and determine site
parameters. The DRAINMOD computer model was used to simulate the hydrology for a 40-
year period of record for all modifications considered.
Results showed that modifications currently planned by CZR Incorporated (consisting of
filling and plugging the field ditches, plugging the collector canals, leveling the fields and
placing a berm to block the shallow swale that will exist at the current ditch location) will
result in the restoration of wetland hydrology. Except for local high places where the surface
' is relatively smooth and depressional storage is low, the modified site will satisfy the 12.5%
hydrologic criterion in at least 35 out of 40 years, on average. Even where surface
depressional storage (on localized high places that may exist), the 8% hydrologic criterion
' will be satisfied in 28 of 40 years and the 6% criterion in 36 of 40 years.
Omitting the berm from the planned modifications would still result in wetland hydrology in
' that it would satisfy the 6% criterion in more than one-half of the years for all conditions
examined. However, it would not satisfy the 12.5% criterion for areas with hydraulic
conductivities on the higher end of the range, nor for areas with low surface storage,
regardless of the conductivity.
Blocking or filling the field ditches without leveling the fields would only result in
' establishing wetland hydrology for areas with low hydraulic conductivity. Since these areas
tend to be randomly distributed in the tract, these alternatives are not recommended without
special measures to increase surface storage.
' It is obvious that required earth work could be substantially reduced if leveling the fields was
not necessary. Wetland hydrology could be created by constructing a berm at the field ditch
' outlet, and at other locations in the ditch as necessary to overcome effects of land slope. The
bean would need to be continuous and at the same elevation as the top of the crown or turtle
back at the center of the fields.
1

ANALYSIS OF WETLAND HYDROLOGY ON TI-[L- PARKER FARM:
BLOCKS E, F, and G
By
1 Dr. R. W Skaggs and Dr. G. M. Chescheir
The objective of the work reported herein was to analyze the hydrology of blocks E,F, and G
of the Parker farm to determine if proposed modifications in the drainage system will result in
water table conditions that will satisfy wetland hydrologic criteria. The Parker farm is located
' in Beaufort and Pamlico counties, North Carolina, with the fields to be considered in
Beaufort. The hydric soils and vegetation in the surrounding areas indicate that the fields
were wetlands prior to being drained and converted to agricultural cropland in the 1970s or
' 1980s. The drainage system consists of parellel open ditches that outlet into collector canals
oriented perpendicular to the field ditches. It is proposed to modify the drainage system by
blocking the field ditches and canals and leveling the surface as necessary to re-establish
' wetland hydrologic conditions. We simulated the day-by-day water table response to long
term rainfall and evapotranspiration (ET) data to determine if various methods of blocking the
drainage ditches and leveling the field surfaces would result in wetland hydrology.
' SITE DESCRIPTION
' The site layout is shown in Figure 1 (CZR plot). The drainage system consists of open field
ditches spaced 90 m (300 ft.) apart and about 90 cm (3 ft,) deep. (The depth actually varies
from approximately 2 ft. at the upper end of the ditch to 4 ft. at the lower end.) The
tcollector canals are about 0.25 mile (1320 ft.) apart for field E and 3200 ft. apart in fields F
and G. The collector canals empty into the main canal which is adjacent to the Old Railroad
' Bed road. The field surfaces were shaped during development for agriculture to provide good
surface drainage. Soil was pushed from the ditch area toward the center of the fields forming
the "turtle back" shape typical of drained agricultural soils in this region. An example is
' shown in Figure 2 (CZR plot). 'Ground surface elevation at the center of the field between
the two ditches is normally I to 1.5 ft. higher than the field surface next to the ditch.
' The shape of the fields causes difficulty in reversing the effects of drainage. I,f not for the
artifical slope that was created when the land was developed for fanning, effects of drainage
could be reversed by simply blocking the drainage ditches. However, blocking the drainage
ditches to the surface in their present condition will still leave a Swale that is 1 to 1.5 ft.
lower than the field surface between the drains. This will provide for some subsurface
drainage, albeit reduced as compared to the existing drainage intensity, and an outlet for
' surface runoff. One of our objectives was to determine if blocking the drainage ditches,
without leveling the field surface, would reduce drainage rates sufficiently to re-establish
wetland hydrology.
Soils on the site are classified primarily as Wasda and Portzer Muck, Wasda Muck is a
mineral soil with a histic surface horizon (Histic Humaquepts). Ponzer Muck is an organic

I
V iglll-e I . I )lagram of Parker farm sections F, F, and G
i
c(x.ti PA1LAOAD OCO)
v +
TEXASGULF INC. PARKER FARM
SECTIONS E, F, AND G TO BE RESTORED
IN EARLY 1995
TEXASGULF MINE EIS
SCAt[: HIS
FIGURE I

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soil (Terris Medisaprisrs). Wasda Muck is located on the western side of Mocks E.); and G
while the eastern side (approximately 65`/o) is classified as Ponzer Muck. Both soils are
classified as very poorly drained, but both are underlain by sandy lenses that will allow
relatively rapid subsurface drainage to the ditches and canals.
FIELD MEASUREMENTS
The proposed wetland site was visited on November 30, 1994, to inspect the site and to
' measure the soil hydraulic conductivity. The saturated hydraulic conductivity of the soil was
measured using the auger hole method (van Beers, 1970) in borings at ten locations (Figure
3). Three borings were located along the road bordering the northwest edge of each of the
' three blocks. The borings were located at the quarter point between two ditches and
approximately 50 m southeast of the roads. One additional boring was located in the southern
corner of Block G. Borings were to depths of approximately 1.2 m. The boring at G 10 was
' augered to a depth of 3.2 m after the auger test was performed.
The observed soil profiles generally consisted of a surface layer of organic material to depths
' of 30 to 60 cm (Table 1). Under the organic layer, mineral layers of sandy loam or sandy
clay loam graded to loamy sand or sand at depths of 65 to 90 cm. The loamy sand or sand
extended to the bottom of the boring at approximately 120 cm. In the deeper boring at G 10,
' loamy sand was observed to 210 cm then sand with shells and some clay was observed to
320 cm.
The measured hydraulic conductivities of the soils ranged from 2.4 to 32 cm/hr. Low
conductivity values (3.9 and 2.4 cm/hr) were measured in the western section of Block E
' where a sandy clay loam layer to depths of 81 to 86 cm was observed (Table 1). Higher
conductivities ranging from 20 to 32 cm/hr were observed in Block F and in the northeastern
corner of Block E. In these borings sandy loam instead of sandy clay loam was observed to
' depths of 65 to 81 cm. The hydraulic conductivities measured in Block G ranged from 3.7 to
12 cm/hr. Some sandy clay loam was observed in these borings.
' The measured hydraulic conductivity values were influenced by the depth and texture of the
top two layers of the soil. Hydraulic conductivity deceased as the clay content in the middle
layer increased and thickness of the top two layers increased. The conductivity of the sand
underlying the top Iayers is most likely in the range (22 to 32 cm/hr) measured in Block F.
Therefore, for design purposes it would be conservative to use conductivity values in this
range.
1
I
4

m m
� rm r r r err �r r rr r r r r� r r
CK I SOVr"
G �.
rc
k'
K = G , _`�''�i,
tk
K =. 30.3
1�
K = ;0 . u `,-A ►- 0
R
��� \7/-jr/ X-/•'��/'N/ �%/ !-fi/ C i:', 1•N! _f il' A'N f'X/ 1-N� !N
I
Vigme 3. I.ocation of soil borings on Parker Farm sections G, F, G. I-lyclN11111c conductivities calculated by auger hole tests
are also shown.

1 Table I
I.]
11,
1
Soil profile description and hydraulic conductivity of burings on Mocks E. F, and G Of the
Parker Farm in Beaufort County, NC.
E2
Water Table Depth = 54 cm
Boring Depth = 120 cm
E6
Water Table Depth = 37 cm
Boring Depth = 120 cm
E9
Water Table Depth = 47 cm
Boring Depth = 120 cm
0
- 33
cm
ORG
0
- 33
cm
ORG
0
- 63
cm
ORG
33
- 60
cm
SL
33
- 55
cm
SL
63
- 83
cm
SL to LS
60
- 61
cm
SL to SCL
55
- 86
cm
SCL
83
-114
cm
LS
81
-100
cm
CS to S
86
-120
cm
LS to S
114
-120
cm
S
100
-120
cm
S
Soil
K =
3.9
cm/h
Soil
K =
2.4
cm/h
Soil
K =
19.7
cm1h
F
Water Table Depth = 54 cm
Boring Depth = 120 cm
0 - 35 cm ORG
35 - 81 cm SL
81 -120 cm SL to S
Water Table Depth = 35 cm
Boring Depth = 120 cm
0 - 53 cm ORG
53 - 66 cm SL to LS
66 - 96 cm LS
96 -120 cm S
Water Table Depth = 29 cm
Boring Depth = 120 cm
0 - 55 cm ORG
55 - 66 cm, SL to LS
83 -120 cm LS
ISoil K = 30.3 cm/h Soil K = 22.0 cm/h Soil K = 31,9 cm/h
. G 2 G-5 G 10
' Water Table Depth = 60 cm Water Table Depth = 45 cm Water Table Depth = 40 cm
Boring Depth = 120 cm Boring Depth = 120 'cm Boring Depth = 320 cm
'
0 - 33 cm
ORG
0
- 45
cm
ORG
0
- 55
cm ORG
33 - 57 cm
SL to
SCL
45
- 60
cm
SiL
55
-- 91
cm SL to LS
57 - 91 cm
SCL
60
- 81
cm
SCL
91
-210
cm LS
'
91 -120 cm
S
81
96
- 96
-120
cm
cm
SL
LS to S
210
-320
cm S with shell
& some clay
Soil K = 8.5
cm/h
Soil
K =
6.8 cm/h
Soil
K =
3.7 cm/h
Gl South
Water Table Depth
= 60 cm
S
-
Sand
Boring Depth
= 120
cm
LS
-
Loamy Sand
CS
-
Clayey Sand
0 - 58 cm
ORG
SL
-
Sandy Loam
58 - 81 cm
SL to
LS
SiL
-
Silty Loam
'
81 -120 cm
LS
SCL
ORG
-
-
Sandy Clay Loam
Organic
Soil K = 11.7
cm/h
6

' MODEL, DESCRIPTION
' The soil water conditions on the drainage area were simulated using the water management
model, DRALNMOD. DRAINMOD performs water balances in the soil -water regime at the
midpoint between two drains of equal elevation. The water balances in DRAINMOD involve
' two basic equations. The first equation is a water balance in the soil profile:
AVO=D+ET -F {l)
' where AV, is the change in air volume, D is the drainage from the profile, ET is the actual
evapotranspiration from the profile, and F is infiltration into the profile.
' The second equation is a water balance at the soil surface,
AS=P -F -RO (2)
' where AS is the change in water volume stored at the soil surface, P is precipitation, F is the
infiltration volume, and RO is the surface runoff. Methods for evaluating equation variables
are discussed in detail in Skaggs (1980).
The model is capable of calculating hourly values for water table depth, surface runoff,
subsurface drainage, infiltration, and actual evapotranspiration over long periods of
climatological data. DRAINMOD has been modified to evaluate wetland hydrology by
calculating the number of years that the water table depth is less than a specified depth for a
specified number of consecutive days during a specified growing season. For example, the
' model will calculate the number of years out of 40 years that the water table depth is less
than 30 cm for 14 consecutive days during a growing season from March 21 to November 15.
The reliability of DRAINMOD has been tested for a wide range of soil, crop, and
climatological conditions. Results of tests in North Carolina (Skaggs, 1982), Ohio (Skaggs et
al., 1981), Louisiana (Gayle et al., 1985; Fouss et al., 1987), Florida (Rogers, 1985),
Michigan (Belcher and Merva, I987) and Belgium (Susanto et al., 1987) indicate that the
model can be used to reliably predict water table elevations and drain flow rates. The
' reliability of the model for simulating the hydrology of pocosins was tested directly by
Broadhead and Skaggs (1989). Predicted water table depth, monthly drainage volumes, and
runoff hydrographs compared very well to experimental data collected for a 25-month period
on both natural and drained pocosin sites in eastern North Carolina. DRAINMOD has been
used to evaluate pocosin hydrology (Skaggs et al., 1993) and wetland definition criteria
(Skaggs et al., 1994)
' CASES CONSIDERED
' There are a number of ways that the drainage system could be modified to reduce drainage
rates and create wetter conditions. We simulated four different field treatments. All of them
involve blockage of the collector canals so there is no potential for seepage from the fields or
1
7
1

1
' field ditches to these canals. The field treatments included the current proposed treatment
plus three cost cutting alternatives. The treatments considered were as follow~:
1. Plug and fill the ditches and level the surface as planned in CZR plans dated 12-7-94.
The field ditches will be filled leaving a 15 cm (6 in.) deep swale. A clay plug
' blocking the ditch and swale will be installed at the ditch midpoint and outlet. A
berm 15 cm above land surface will be constructed the length of the field at either end
of the ditches and at the middle of the ditch. We will refer to this treatment as
' PLANNED.
2. Same as 1 above except that the berm and plug blocking the swale is not constructed.
That is the 15 cm deep swale is allowed to drain freely. This treatment will be called
PLAN-NOBERM.
3. The surface is not leveled but is left in its current turtle -backed configuration. The
ditches are blocked to the current land surface at either end and in the middle. Since
' the current surface between the drains is 30 to 45 cm above the surface at the ditches,
this treatment would provide for some subsurface and surface drainage when the water
table is close to the surface. It is assumed that, after the ditch is blocked, water could
' drain from the ditch when the ditch water elevation is greater than the elevation of the
land surface at the ditch. This treatment will be referred to as BLOCKDITCH.
4. Same as 3 above except that the field ditches are filled so that there is no storage of
water in the ditch. The lower land surface elevation at the ditch would allow drainage
with an effective ditch depth of 30 to 45 cm, depending on the height of the crown in
' the individual fields. This treatment will be referred to as FILLDITCH in the
discussion of results.
Analyses were made for both soil types, the Wasda and Ponzer. In addition to the drainage
system and soil type, other factors affect the rate that water is removed from the field and
whether or not wetland hydrology will exist after modifications. One factor is the hydraulic
' conductivity of the profile, K. While K is dependent on the soil type, the effective value for
the profile is often more dependent on the layers of sandy materials below 4 to 5 ft. deep.
This is particularly true for the lower coastal plains where this site is located. Field
' measurements at I0 locations indicated that the effective K for this site varied from about 4
to over 25 cmJTr. Therefore we conducted simulations for both of these values. It is likely
that the actual field effective value lies somewhere between these extremes, but we can't
t discount the possibility that the higher or lower values may represent the effective K for a
portion of a field, or for one or more of the areas between adjacent drainage ditches. Results
for both extremes can be analyzed to assist in making a choice that will be on the "safe side"
' for the modifications to be constructed.
' Another factor that could have a significant effect on whether the modified site will have
wetland hydrology, or will satisfy criteria for wetland hydrology, is surface depressional
storage. During periods of heavy rainfall, the water table rises to the surface on these poorly
1 drained soils and excess water is stored in surface depressions. Once the depressions are

�1
n
J
I
filled additional rainfall runs off the Surface and is conveyed from the: field tllrau11lZ the
drainage network. When rainfall ceases the water stored in surface depressions remains there
until it is either evapotranspired or moves through the profile to the drains or to some other
sink. Thus the depth of surface storage may have a big effect on how much water is stored
on the surface and the length of time that the water table is at or near the surface as the
ponded water is being removed. The amount of surface storage depends heavily on surface
roughness and how it is treated in the modification process. Since the objective is to make
the site wetter, it would be desireable to increase the roughness. We estimate that the
depressional storage could vary from about I cm for the current "turtle -backed" shape of the
fields if they are not further bedded so that the surface is relatively smooth to 4 cm or more.
The higher value could result from bedding the fields as would normally be done for crop
production, but not connecting the low spots to the field ditches with "hoe drains", as is
typically done. Such a high value could also result if the field is leveled and berms are
placed in such a way that water must be ponded to a'4 cm average depth before runoff can
occur. Simulations were conducted for depression storage values of both I cm and 4 cm.
For the PLANNED case, a depression storage value of 8 cm was also used to simulate the
effective surface storage of the 15 cm berm. A value lower than 15 cm was used to account
for surface gradient parallel to the ditches.
The DRAINMOD simulations were conducted for the time periods from 1951 to 1990 using
the climatological record from New Bern, NC. Daily rainfall and maximum and minimum
temperature data were obtained from the Southeast Regional Climate Center and converted to
DRAINMOD weather format files. Daily rainfall was converted to hourly rainfall by evenly
distributing the daily values over the four hour period from 1700 to 2100. The wetland
criteria used for the simulations were that the water table was within 30 cm (1 ft.) of the
surface for a continuous period of at least 30, 19, and 14 days (12.517o, 8%n and 6% of the
growing season) during the growing season. The growing season for the simulations was
from March 21 to November 16. Summaries of the soil and drainage system design input
variables for the DRAENMOD simulations are shown in Tables 2 and 3.
The new soil survey for Beaufort County has been completed but not yet released. The
average dates of 28 F temperature in the spring and fall as given in the new soil survey are
March 13 to November 25 giving a growing season of 257 days. Simulations were also
conducted for this growing season with appropriate thresholds for 12.5%, 8%, and 6%.
Results were nearly identical to those for the March 21 to November 16 growing season so
they are not presented here.
RESULTS
The Planned Design.
Results for both soil types for the planned modifications (PLANNED) are presented in Table
4. These results show clearly that the PLANNED treatment will result in conditions that will
satisfy wetland hydrologic criteria. For a surface storage of 4 cm the water table was within
30 cm of the surface for 30 or more consecutive days during the growing season in 35 out of
P
E

1
'
Table 2. Summary of DRAiNMOD input variables used for the four cases
simulated
Variable PLANNED PLAN-NOBERM BLOCKD[TCH
FILLDITCH
'
Ditch Depth' (cm) 15 15 120
30
Wier Depth' (cm) 1 15 30
30
'
Ditch Spacing (m) 90 90 90
90
Surface Storage (cm) I, 4, and 8 1 and 4 1 and 4
1 and 4
Sol] K (cniAu) 4 and 25 4 and 25 4 and 25
Root Depth (cm) 15 15 15
4 and 25
15
Water elevation in the ditch is controlled by Wier Depth. Therefore, the
Wier Depth
'
simulates the depth from the highest soil surface elevation in the field to
the elevation at
top of the plug blocking the ditch.
�
10

Table 3. Volume drained, upflux, and Green-Ampt values used to simulate the soils on
' Blocks E, F, and G of the Parker farm in Beaufort county, NC.
' Ponzer Wasda
Muck Muck
'
Water
Table
Vol
Upflux
Vol
Upflux
Depth
Drn
Drn
'
cm
cm
cm/hr
cm
cmlhr
0.0
0.00
0.1000
0.00
1.0000
10.0
0.32
0.0850
0.30
0.7500
'
20.0
0.64
0.0700
0,60
0.5000
30.0
1.08
0.0150
1.20
0.2567
40.0
1.60
0.0090
1.80
0.0133
'
50.0
2.20
0.0067
2.40
0.0108
60.0
2.80
0.0045
3.00
0.0083
'
80.0
4.00
0.0026
4,30
0.0042
100.0
5.30
0.0016
5.20
0.0004
120.0
6.74
0,0012
5.70
0.0003
'
140.6
8.18
0.0009
6.20
0.0002
160.0
9.66
0.0006
7.00
0.0001
200.0
12.70
0.0000
8.60
0.0000
'
250.0
18.16
0.0000
10,60
0.0000
300.0
23.61
0.0000
12.60
0,0000
'
Water
Green Arnpt Parameters
Table
Depth
A
; B
A
B
'
cm
0.0
0.000
1
25.0
0.117
50.0
0.180
80.0
0.250
'
120.0
0.330
250.0
0.390
1
1
1
1
0.00
0.000
0.00
2.00
0.500
7,40
2.00
0.500
5.20
2.00
0.530
4.70
2.00
0.570,
4.10
2.00
0,700
2.00
11

1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
Table 4. Number of years out of 40 that the simulated water table was within 30 cm (1 ft.)
of the surface for a continuous period of at least 30, 19, and 14 days during the
growing season for the planned modifications (PLANNED) on blocks E, F, and
G of the Parker Farm in Beaufort County, NC. The 30, 19 and 14 days represent
12.5%, 8% and 6% of the growing season.
Percent of Growine Season
Soil
Soil
12.5% 8%
6%
Type
K
30 days 19 days
14 days
c m/hr
Surface Storage = 8 cm
Ponzer
25
39 40
40
Wasda
25
39 40
40
Ponzer
4
39 40
40
Wasda
4
39 40
40
Surface Storage 4 cm
Ponzer
25
35 38
40
Wasda
25
36 40
40
Panzer
4
35 38
40
Wasda
4
36 39
40
Surface Storage, 1 cm
T
Panzer
25
12 28
36
Wasda
25
12 30
36
Ponzer
4
12 28
36
Wasda
4
12 29
36
12

40 years for the Ponzer Muck soil and 36 out of 40 years for the Wasda Muck. The 8% (19
consecutive days) water table criterion was satisfied in 38 out of 40 years and the 6%
' criterion (14 consecutive days) in 40 of 40 years for the Ponzer. For a surface storage of 8
cm the PLANNED design met the 6%, 8%, and 12.5% criteria for at least 39 out of 40 years,
Note that results are very similar for the two soils with the Wasda slightly wetter than the
' Ponzer.
Results were essentially the same for the two hydraulic conductivity values. This is because
the berms placed in the swale were at or above the soil surface, so there was no hydraulic
gradient for drainage.
' Surface storage did make a difference. When surface storage was reduced to 1 cm the
number of years that the 12.5% criterion was satisfied was only 12 out of 40. However the
8% criterion was satisfied in at least 26 out of 40 years and the 617o criterion in 36 out of 40
' years. The design calls for a berm around the field of at least 15 cm above land surface.
Therefore it is very unlikely that the surface depressional storage will be less than 4 cm for
' this design. The exception will be on'relatively smooth local high places where the
depressional storage could be as low as 1 cm. We would expect such areas to make up a
very small percentage of the total. If such areas are present and are a problem (which we
' don't expect), the surface storage could be increased by plowing or bedding in the locations
affected.
Planned Design Without Berm.
Results for the planned design without the berm (PLAN-NOBERM)are summarized in Table
5. This simulates conditions where drainage water can flow out of the 15 cm deep Swale.
Such conditions could exist if, for some reason the berms and plugs are not installed or are
broken, or if they are not effective because of elevation differences. Results in Table 5 for
surface depressional storage of 4 cm show that the 6%, 8%, and 12.5% criterion would be
satisfied in respectively 34, 25, and 13 of 40 years for the high K (25 cm/hr) and in 40, 37,
and 34 of 40 years for the low K (4 cm/hr). The K value makes a difference in this case
' because the absence of berms and plugs allows some subsurface drainage. For low surface
storage of only 1.0 cm, the water table would not satisfy the 12.5% or 8% criteria in over
half of the years for the high K; and would only satisfy the 12.5% criterion in 10 of 40 years
for the low K. Thus this treatment would satisfy the hydrologic criteria where the surface
storage is 4 cm or greater, but will only marginally satisfy the criteria on relatively high,
smooth place where the depressional storage may be I cm or less. This effect could be
' counteracted by bedding or taking other measures to increase roughness in the high areas.
Blocking -or Filling the Ditches Without Leveling the Fields.
Results for the BLOCKDITCH and FILLDITCH treatments are given in Tables 6 and 7,
respectively. In both cases it is assumed that the fields are not leveled, but that the field
ditches are either blocked or completely filled to the current surface elevation at the ditch.
These treatments allow for some subsurface drainage as the "turtle -backed" shape result in
most of the field being 30 to 45 cm higher than the blocked or filled ditch. Comparing
1 13

Table 5.
Number of years out of 40 that the simulated water table was within
30 cm (1 ft.)
of the surface for a continuous period of at least 30, 19, and 14 days
during the
growing season for the planned modifications without berms (PLAN-NOBERM)
on blocks E, F, and G of the Parker Farm in Beaufort County, NC.
The 30, 19
and 14 days represent 12.5%, 8% and 6% of the growing season.
Percent of Growing Season
Soil
Soil 12.5% 8%
6%
'
Type
K 30 days 19 days
14 days
c rr/hr
'
Surface Storage = 4 cm
Ponzer
25 11 29
36
'
Wasda
25 13 29
37
Ponzer
4 36 39
40
'
Wasda
4 37 39
40
Surface Storage = 1 cm
Ponzer
25 2 10
21
'
Wasda
25 2 14
24
Ponzer 4 12 23 36
Wasda 4 14 24 37
1
1
1
14

1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
Table 6. Number of years out of 40 that the sirtuilated water table was within 30 cm (1 ft.)
of the surface for a continuous period of at least 30, 19, and 14 days during the
growing season for the existing land contours and with ditches plugged
(BLOCKDfTCH) on Blocks E, F, and G of the Parker Farm in Beaufort County,
NC. The 30, 19 and 14 days represent 12.5%, 8% and 6% of the growing
season.
Soil
Type
Soil
K
ctrtfhr
12.5%
30 days
Percent of GrowinEz Season
8%
19 days
6%
14 days
Surface Storaize = 4 cm
Ponzer
25
1
4
16
Wasda
25
1
6
20
Ponzer
4
29
37
39
Wasda
4
32
37
39
Surface Storage = I cm
Ponzer
25
0
0
2
Wasda
25
0
1
8
Panzer
4
3
18
30
Wasda
4
4
22
32
15

1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
Table 7. Number of years out of 40 that the simulaeed water table was within 30 cm (1 ft.)
of the surface for a continuous period of at feast 30, 19, and 14 days during the
growing season for existing land contours with ditches filled (FILLDITCH) on
blocks E, F, and G of the Parker Farm in Beaufort County, INC. The 30, 19 and
14 days represent 12.5%, 8% and 6% of the growing season.
Percent of Growing Season
Soil
Soil
12.5% 8%
6%
Type
K
30 days 19 days
14 days
c m/hr
Surface Storage = 4 cm
Ponzer
25
1 4
16
Wasda
25
1 6
18
Ponzer
4
29 37
39
Wasda
4
31 37
39
Surface Storage = I cm
Panzer
25
0 0
1
Wasda
25
0 l
8
Ponzer
4
3 18
30
Wasda
4
4 22
32
16

1
1
1
I
1
I
results in Tables 6 and 7 show that there is very little difference between the two treatments.
The hydrologic criteria are satisfied in most years for only the fields with low K (4 cm/hr)
and high depressional storage (4 cm). The 6% and 8% criteria are marginally satisfied for the
low K and low surface storage. However, it is clear that there will be some fields that do not
satisfy the hydrologic criteria under these treatments.
An Alternative that Would not Require Leveling the Fields.
Results in Tables 6 and 7 notwithstanding, it should not be necessary to level the fields to
create wetland hydrology. As discussed above, the reason the hydrologic criteria were not
satisfied in most cases for the BLOCKDITCH and FILLDITCH treatments was that the lower
surface elevation at the ditch location provided a subsurface drainage outlet. By filling or
simply blocking the field ditches and constructing berms at the outlets that are at the elevation
of the field midpoints (the top of the "turtle back", see Figure 4), subsurface drainage would
be nearly eliminated and the results would be as given in Table 4. If the berm is 15 cm
below the field midpoint, results in Table 5 would apply. The big advantage to using this
alternative is a dramatic reduction in required earth work. Another potential advantage is that
there would be a considerable variation in wetness from the ditch location to the center of the
fields. This could also be a disadvantage for regeneration of some tree species. It would still
be necessary to block the collector canals as presently planned to reduce seepage.
Seepage to the Main Canal.
We have not considered seepage to the main canal which will be open although there is
potential for some control of its water level. The main canal is separated from blocks E,F,
and G by a road which will reduce seepage due to compaction. Still seepage will occur.
Experience with similar situations on similar soils indicates to us that such seepage will only
affect the field immediately adjacent to the road and canal. Even there we don't expect it to
prevent the establishment of wetland hydrologic conditions.
1
17

1
1
1
1
1
1
1
1
1
1
Canal plug
Plan view
Berm
Ditch plugs
Elevation view
Figure 4. Diagram of an alternative that would not require leveling the fields.
18

REFERENCES
Belcher, H. W. and G. E. Merva. 1987. Results of DRAI]NMOD verification study for
Zeigenfuss soil and Michigan climate. ASAE Paper No. 87-2554. ASAE, St. Joseph,
MI 49085.
Broadhead, R.G. and R.W. Skaggs. 1989. A hydrologic model for artificially drained North
Carolina padands. p. 61-70. In: V.A. Dodd and P.M. Grace (eds.) Agricultural
Engineering, Proc. of the 1 Ith International Congress, Dublin, Sept. 4-8.
' Fouss, J. L., R. L. Bengtson and C. E. Carter. 1987. Simulating subsurface drainage in the
lower Mississippi Valley with DRAINMOD. Transactions of the ASAE 30(6):1679-
1688.
' Gayle, G., R. W. Skaggs and C. E. Carter. 1985. Evaluation of a water management model
for a Louisiana sugar cane field. J. of Am. Soc. of Sugar Cane Technologists, 4:18-
28.
' Rogers, J. S. 1985. Water management model evaluation for shallow sandy soils.
Transactions of the ASAE 28(3):785-790.
' Skaggs, R. W. 1980. A water management model for artificially drained soils. Tech. But.
No. 267, North Carolina Agricultural Research Service, N. C. State University,
Raleigh. 54 pp.
' Skaggs, R. W., N. R. Fausey and B. H. Nolte. 1981. Water management evaluation for
North Central Ohio. Transactions of the ASAE 24(4):922-928.
' Skaggs, R. W. 1982. Field evaluation of a water management simulation model.
Transactions of the ASAE 25(3):666-674.
' Skaggs, R. W., J. W. Gilliam, and R. O. Evans. 199I. A computer simulation study of
pocosin hydrology. Wetlands (I 1):399-416.
Skaggs, R.W., D. Amatya, R.O. Evans, and J.E. Parsons. 1994. Characterization and
evaluation of proposed hydrologic criteria for wetlands. Journal of Soil and Water
' Conservation 49(5):501-510.
Susanto, R. H., J. Feyen, W. Diericicx and G. Wyseure. 1987..The use of simulation models
' to evaluate the performance of subsurface drainage systems. Proc. of Third
International Drainage Workshop, Ohio State Univ., pp. A67-A76.
1
' 19

APPENDIX B
' EFFECTS OF TREE GROWTH ON HYDROLOGY AND WETLAND
HYDROLOGIC STATUS
I

Effects of Stage of Tree Growth on Hydrology and Wedand Hydrologic Status
g Y gY
Prepared by: R. Wayne Skaggs
July 31, 1995
The stage of growth or age of vegetation (trees) could affect the hydrology in two ways.
1. Tree roots and, to a lesser extent the roots of annuals, tend to loosen the soil and promote
soil structure that increases hydraulic conductivity in the surface layers. This increases lateral
drainage where drainage ditches and canals are present.
2. The deeper rooting systems and increased leaf area that develop as the trees get older
increase evapotranspiration (ET), especially during dry periods when soil water supplies limit ET
for shallow rooted seedlings.
' How do these factors affect the results presented in our report concerning wetland hydrologic
status for the planned modifications in the drainage system on the Parker Farm?
Since the drainage ditches and canals will be filled and/or plugged, there will be only small
potential for subsurface drainage, regardless of the hydraulic conductivity of the profile. Thus
' the first effect listed above is not relevant for this case. That is, an increase in hydraulic
conductivity in the surface horizon due to root activity as the trees age will not have a great
effect on the hydrology or the wetland hydrologic status. This is demonstrated by the results in
Tabfe 4 in our December, 1994 report. The number of years satisfying the wetland hydrologic
criterion is the same for the high (25 cmThr) and low (4 cm/hx) conductivity values.
The major hydrologic effect of the age or maturity of the trees is due to its effect on ET. ET
is affected by the age of the trees in two ways. The root depth increases with age to some
maximum effective depth that is limited by the shallow water table conditions. This depth is
normally assumed to be a maximum of 30 cm or so, depending on the drainage intensity of the
field. The effective root depth during the first year when the trees are planted may be 5 cm or
less. Normally the effective root depth increases with time, reaching its maximum within 4 to
7 years depending on species and site conditions. We used an average root depth of 15 cm for
the analyses presented in our this report. The root depth is important and affects ET mostly
during dry periods. During the time that the water table is close to or at the surface, ET is not
Limited by soil water availability and may be assumed equal to the Potential evapotranspiration
(PET), which is the capacity of the atmosphere to evaporate water. PET depends on such factors
as air temperature, relative humidity, net radiation, wind speed, etc. When the soil dries out at
the surface, ET may be limited by the availability of soil water to supply PET. The deeper the
rooting depth, the more soil water available to meet ET demands. Thus plants with deeper roots
will increase ET during these "dry" periods. This increases storage available for infiltrating water
and may increase water table depths, even for subsequent rainfall events.
Increased leaf area of the more mature vegetation also increases ET. Again this increase occurs
mostly during relatively dry periods when most of the water lost by ET is removed by
transpiration through the trees as opposed to evaporation from the plant and soil surfaces.
1

ET is quantified in the DRAINMOD model as a two step process. First PET is determined. it
may be read in directly or calculated internally by the Thornthwaite method using daily
maximum and minimum temperatures. A correction factor is .used to remove bias in the
Thomthwaite method that causes it to underpredict PET during the winter months in eastern NC.
Once the PET is calculated, DRAINMOD determines whether there is sufficient soil water
available in the root zone to satisfy the PET. This depends on the root depth. Lf sufficient soil
water is available, the ET is set equal to the PET. Thus this method considers the effect of root
depth on ET but not the effect of increased leaf area, at least directly. We have conducted
considerable research on this subject and have found that the methods used in DRARVMOD
satisfactorily describe the ET process. Detailed comparisons using several more sophisticated
methods of predicting ET (with considerably more complex and expensive inputs) has shown that
results predicted for long-term analyses with the standard methods in DRANMOD are as reliable
as the use of the more sophisticated methods (which can't be used in most cases because required
input data are not available). A paper on comparison of various methods for predicting ET is
attached.
What does all this mean with respect to the results presented in our report for the Parker Farm?
We ran additional simulations for the planned modifications (PLANNED in Table 4of our
December, 1994 report) using root depths that characterize conditions during planting and
establishment (root depth of 6 cm) and for mature vegetation with a root depth of 30 cm. These
results were compared with those presented in the original report, which were done for a root
depth of 15 cm. Results are presented in Table Al. These results show that the frequency that
' the wetland hydrologic criterion(water table within the top 30 cm of the profile for 30 or more
consecutive days during the growing season) is satisfied is not affected by the age of the
vegetation for surface depressional storage of 4 cm. These systems are very wet and ET is
essentially equal to PET most of the time. That is, the water table is close enough to the surface,
at least during wet periods, such that the PET demand is satisfied by evaporation and
transpiration, even for newly established vegetation with a small (6 cm) rooting depth.
' The age of the vegetation (and root depth) did make a difference for the drier sites that had
surface depressional storage of: only I cm. In this case drier periods when ET was limited by
soil water availability were more frequent. The older trees with deeper root depths had access
to a greater supply of soil water. Thus predicted ET was greater for the older vegetation, the
water table was deeper and the frequency that the wetland hydrologic criterion was satisfied was
reduced, compared to the younger vegetation with shallower root depths.
Planned modifications for the site call for increasing the surface roughness and constructing
' berms to increase depressional storage. These actions should cause surface storage to be at least
4 cm, probably greater. The result will be a very wet site on which PET demands of the
atmosphere will be satisfied most of the time. Results given in Table Al indicate that the
wetland hydrologic criterion will continue to be satisfied on the site as the trees mature. ET will
no doubt be increased during dry periods for the older trees, but this effect will not significantly
affect the frequency that the wetland hydrologic criterion is satisfied.

1
i
1
i
1
1
1
1
1
1
1
1
1
f
1
1
1
1
1
Tabic Al. Effect of root depth on number of years out of 40 that the simulated grater table was
within 30 cm (l I't.) of the surface for a continuous period of at least 30 drys (12.5% of
Growing season) during the growing season for the planned modifications (PLANNED) on
blocks E, F, and G of the Parker Farm in Beaufort County, NC.
Rooms
Soil Soil 6 cm 15 cm 30 cm
K, cmlh
Surface Storaze = 4 cm
Ponzer 25 35 35 34
Wasda 25 36 36 35
Ponzer
4
38 35
35
Wasda
4
38 36
35
Surface Storage = 1 cm
Ponzer
25
16 16
13
Wasda
25
17 16
13
Ponzer
4
17 16
13
Wasda
4
17 16
13

Ll
I
I
u
1
L
I
APPENDIX C
EVAPOTRANSPIRATION IN NORTHEASTERN NORTH CAROLINA
1

I
1
North Carolina
Cooperative Extension Service
NOR1I.1 CAROLINA SI'Al'E UNIVERS11N
COLLEGt: OF AGKICULTURE & LIFL SCIENCLS
' Department of Biological and Agricultural Engineering. Sox 7625. Raleigh, NC 27695.7625 . Tel: [phone] . FAX [phone]
July 29, 1995
MEMO t�
TO: Elizabeth Perkinson
FROM: Robert Evans
SUBJECT: Evapotranspiration in northeastern North Carolina
Enclosed you will find several tables showing monthly evapotranspiration variability as
influenced by natural climatic conditions (rainfall and temperature), land use and vegetative
cover in the Washington/Beaufort county area.
Under ideal conditions (well watered, moist soil with complete vegetative cover) ET would
average about 40 inches per year. Evaporation from the same soil with all vegetation
removed would be nearly 30 inches. Thus, the average vegetative influence can be up to 10
inches per year: You will note that there is not much difference between a drained hardwood
forested wetland, pine plantation, and fescue pasture. This is because on average we have a
wet system - rainfall exceeds PET in most months - particularly Ianuary to March,
November, and December. During these months, PET is relatively low, so the soil is moist
enough to met the atmospheric demand regardless of vegetative cover. During some summer
months, particularly those months when rainfall is below average, vegetation can result in up
to twice as much ET as from a bare soil. But, once the water table drops to about 2 meters,
ET drops dramatically, regardless of vegetation present. On average, the difference between
perennial vegetative types is rather small, usually not more than 1-2 inches per year.
As we discussed on the phone, I think the biggest ET influence on a young, restored wetland
site will be how annuals are managed. If annual vegetation is managed/destroyed, then ET
during the first 3-4 years of seedling establishment will be closer to that of a bare site. With
good ground cover of annuals, I think ET will be about the same as from a fescue pasture.
' Soil type and other factors can also influence ET. For example, ET from a well drained,
sandy soil in the same area could be up to 25 percent less than values shown for the
Portsmouth soil. However, most sites suitable for restoration would have soil -water
properties that are similar to the example site,
I hope this information will be of help in your water balance calculations. Give me a call if
you have further questions.
enc
Employmeni and program opportunities are offered to all people regardless of race, color, national origin, sex, age or handicap.
North Carolina Slate University, North Carolina A&T State University, U.S. Department of Aericulture, and local yovemments cooperating.

1
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Rainfall at Plymouth for the 30 year period 1957 to 1986. All values are in
centimeters.
RANKING OF MONTHLY TOTAL RAINFALL
RANK JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC
1 22.9 19.4 23.6 14.2 28.2 33.2 38.0 29.2 29.1 29.3 16.9 19.8
2 20.9 17.3 16.8 13.7 23.2 23.9 35.8 28.9 21.4 26.2 16.8 13.7
3 17.1 16.3 15.2 13.7 20.8 22.3 28.8 27.8 20.6 20.0 16.3 12.8
4 16.8 15.3 15.0 13.6 19.0 19.7 28.5 27.4 19.2 14.6 15.6 12.2
5 16.5 15.0 14.2 12.2 17.8 17.2 27.3 20.4 18.2 14.1 13.9 12.0
6 15.4 14.4 13.9 12.0 17.3 16.9 22.3 20.1 17.6 12.6 13.2 11.8
7 15.3 13.1 13.5 11.4 16.8 14.8 21.6 19.7 17.4 11.7 11.8 11.6
8 13.1 12.2 13.3 11.2 15.5 14.7 20.6 19.5 17.4 10.6 11.8 11.6
9 13.0 12.1 13.1 11.0 15.5 13.1 18.4 17.2 15.5 10.2 11.8 11.4
10 12.6 11.6 12.9 10.8 15.5 12.3 18.3 17.0 14.5 10.2 10.1 11.0
11 11.8 11.5 12.4 10.8 15.0 12.1 17.0 15.8 13.8 10.0 9.5 10.2
12 11.8 11.0 12.3 10.4 13.2 12.0 16.5 15.7 13.3 8.6 7.6 9.6
13 11.6 10.6 12.1 9.0 13.1 11.4 16.3 13.2 12.3 8.0 7.4 9.2
14 11.0 10.4 11.3 8.9 12.7 9.6 15.2 13.1 12.1 7.4 6.7 9.0
15 10.8 10.3 11.2 8.2 12.5 9.3 14.3 11.5 11.6 7.3 6.7 8.9
16 10.6 10.1 10.5 8.2 10.5 9.1 14.0 10.7 11.4 5.9 6.7 8.7
17 9.8 10.1 10.0 7.8 10.1 8.7 12.9 10.5 10.6 5.8 5.6 8.5
18 9.1 9.9 9.4 6.3 9.2 8.6 12.8 10.3 9.3 5.3 5.4 8.1
19 9.0 9.9 9.4 5.7 7.6 8.1 12.5 10.2 8.7 5.1 5.4 8.1
20 9.0 9.6 9.3 5.3 6.9 8.0 12.5 9.1 8.5 4.9 5.1 7.8
21 8.3 8.2 8.8 5.2 6.9 7.9 11.6 8.8 7.0 4.8 4.9 7.3
22 8.1 7.7 8.5 5.1 6.0 7.8 11.6 7.5 6.2 4.4 4.5 6.6
23 7.2 7.6 8.2 5.0 5.0 7.1 10.9 7.5 6.1 3.9 4.1 6.1
24 6.9 7.5 8.1 4.5 4.7 6.3 9.9 7.3 5.5 3.8 4.0 5.3
25 6.0 7.5 7.2 4.3 4.6 6.1 9.5 6.7 5.2 3.4 3.5 5.2
26 5.7 5.5 5.9 4.0 4.6 6.0 9.3 5.5 4.5 3.0 3.3 5.1
27 4.0 4.7 5.6 3.7 4.0 4.5 5.5 5.1 4.2 2.6 2.6 2.9
28 3.9 4.6 4.6 2.8 3.5 4.4 5.4 4.7 3.6 2.0 1.9 2.8
29 3.9 4.5 4.6 2.2 2.8 4.4 4.1 3.6 3.3 1.6 1.6 1.4
30 3.7 2.8 2.2 1.7 2.2 3.8 2.0 .8 1.6 .8 1.6 1.4
AVERAGE 10.9 10.4 10.6 8.1 11.5 11.4 16.1 13.5 11.7 8.6 7.9 8.7
1

POTENTIAL EVAPOTRANSPIRATION
PLYMOUTH AS LIMITED
BY ATMOSPHERIC
FROM A WELL WATERED
CONDITIONS. (1957-1986).
(ALWAYS MOIST)
ASSUMES
SOIL AT
COMPLETE
,
CANOPY COVER
AND AN
EFFECTIVE
ROOT DEPTH OF
45 CM
ALL YEAR.
RANKING
OF MONTHLY
EVAPOTRANSPIRATION
RANK
,TAN
FEB
MAR
APR
MAY
SUN
JUL
AUG
SEP
OCT
NOV
DEC `
1
7.8
10.0
11.2
13.1
15.0
15.9
15.5
13.7
11.4
9.2
7.2
6.1
2
4.6
7.2
10.9
12.4
14.9
14.8
15.4
13.7
11.0
9.2
6.2
5.9
3
4.0
6.9
10.6
12.4
14.6
14.4
15.0
13.6
10.4
9.1
5.7
5.0
4
4.0
6.1
10.0
12.2
14.6
14.4
14.5
13.2
10.4
8.5
5.4
4.2
5
3.8
5.8
10.0
11.6
14.3
13.9
14.4
13.0
10.4
8.5
5.3
4.1
6
3.5
5.6
9.7
11.5
14.3
13.8
14.4
12.7
10.4
S.1
5.1
4.0
7
3.2
5.6
9.3
11.2
14.1
13.7
14.3
12.7
10.3
7.8
5.0
3.8
8
3.1
5.5
9.3
11.2
14.0
13.7
14,3
12.7
10.2
7.7
5.0
3.8
9
3.0
5.4
9.2
10.9
13.9
13.6
14.2
12.6
10.1
7.7
4.9
3.3
10
2.9
5.1
9.0
10.9
13.4
13.5
14.2
12.5
9.9
7.6
4.9
3.2
11
2.8
5.1
8.9
10.7
13.3
13.4
13.9
12.4
9.8
7.4
4.8
3.2
12
13
2.8
2.7
4.9
4.8
8.8
8.6
10.6
10.5
13.1
12.8
13.4
13.2
13.8
13.6
12.4
12.2
9.7
9.7
7.3
7.3
4.7
4.3
3.1
3.1
14
2.3
4.7
7.6
10.1
12.7
13.1
13.6
12.2
9.6
7.0
4.3
2.9
15
2.2
4.5
7.2
10.0
12.7
13.1
13.5
12.0
9.5
6.9
4.3
2.8
1
16
2.2
4.2
6.9
10.0
12.4
12.8
13.4
12.0
9.5
6.5
4.2
2.7
17
2.1
4.1
6.8
9.8
12.2
12.6
13.4
12.0
9.4
6.4
4.2
2.7
18
2.1
3.9
6.8
9.5
12.1
12.4
13.3
12.0
9.4
6.4
4.1
2.7
19
2.0
3.6
6.8
9.5
11.9
12.2
13.3
11.8
9.3
6.3
4.1
2.6
20
1.9
3.6
6.4
9.4
11.9
12.0
13.3
11.8
9.0
6.3
4.1
2.5
21
1.8
3.1
6.4
9.3
11.6
12.0
13.3
11.5
8.9
6.3
4.1
2.5
22
1.7
2.9
6.2
9.0
11.5
12.0
13.2
11.4
8.9
6.3
4.1
2.4
23
1.6
2.8
5.7
8.9
11.4
11.9
13.1
11.4
8.8
6.2
3.9
2.4
24
1.6
2.5
5.2
8.6
11.2
11.7
12.8
11.4
8.8
6.1
3.9
2.1
25
1.4
2.3
5.1
8.4
11.2
11.6
12.8
11.3
8.8
5.9
3.8
2.0
26
1.4
2.3
5.0
8.4
10,8
11.5
12.7
11.3
8.6
5.8
3.7
1.9
27
1.2
2.2
4.9
8.3
10.8
11.5
12.7
11.2
8.4
5.4
3.4
1.9
28
1.1
1.9
4.5
7.9
10.6
11.5
12.7
11.1
8.1
5.4
3,0
1.4
29
1.1
1.7
4.3
7.9
10.3
11.3
12.5
11.1
7.8
5.1
2.8
1.1
30
.4
.7
3.1
7.8
10.3
11.1
12.3
10.8
7.3
5.1
2.6
1.0
AVERAGE
2.5
4.3
7.5
10.1
12.6
12.9
13.6
12.1
9.5
7.0
4.4
3.0
i-o /, /
F
/'F• S
C V+�
1
1

1
ACTUAL
EVAPOTRANSPIRATION
(AET)
FROM A
TYPICAL
UNDRAINED
FORESTED, HARDWOOD
WETLAND
NEAR PLYMOUTH, NC.
(1957-1986).
(MAXIMUM
SURFACE
STORAGE (PONDING)
2.5
CM). EFFECTIVE
ROOTING DEPTH IS
ASSUMED TO
BE 40
CM DURING THE
GROWING
SEASON
AND 5 CM
DURING
THE
DORMANT
PERIOD.
RANKING
OF
MONTHLY
EVAPOTRANSPIRATION
RANK
JAN
FEB
MAR
APR
MAY
JUN
JUL
AUG
SEP
OCT
NOV
DEC
1
7.8
10.0
11.2
12.4
15.0
14.7
15.5
13.7
10.4
9.2
7.2
6.1
2
4.6
7.2
10.6
12.4
14.9
14.4
15.4
13.6
10.4
9.2
5.7
5.5
3
4.0
6.9
10.0
12.2
14.8
13.7
15.0
13.0
10.3
8,5
5.3
5.0
4
4.0
6.1
10.0
11.6
14.1
13.7
14.4
12.7
10.3
8.5
5.1
4.2
5
3.8
5.8
9.7
11.5
14.0
13.6
14.3
12.7
10.2
8.1
5.0
4.1
6
3.5
5.6
9.3
11.2
13.9
13.4
14.2
12.7
10.1
7.8
5.0
3.8
7
3.2
5.6
9.3
10.9
13.4
13.2
13.9
12.6
9.9
7.8
4.9
3.8
8
3.1
5.5
9.2
10.7
13.3
13.1
13.8
12.5
9.8
7.7
4.9
3.6
9
3.0
5.4
9.2
10.6
13.1
12.8
13.5
12.4
9.7
7.4
4.8
3.3
10
2.9
5.1
9.0
10.5
12.8
12.6
13.4
12.4
9.7
7.3
4.7
3.2
11
2.8
5.1
8.9
10.1
12.7
12.4
13.4
12.2
9.6
7.3
4.3
2.9
12
2.8
4.9
8.8
10.0
12.7
12.2
13.3
12.2
9.5
7.0
4.3
2.9
13
2.7
4.8
8.6
10.0
12.4
12.0
13.3
12.2
9.5
6.9
4.3
2.8
14
2.3
4.7
7.6
10.0
12.2
12.0
13.3
12.0
9.4
6.5
4.2
2.8
15
2.2
4.5
7.2
9.8
12.1
12.0
13.3
12.0
9.3
6.4
4.2
2.7
16
2.2
4.2
6.9
9.5
12.0
11.9
13.2
12.0
9.0
6.4
4.1
2.7
17
2•.1
4.1
6.8
9.5
11.9
11.6
12.8
11.8
8.9
6.3
4.1
2.6
18
2.0
3.9
6.8
9.4
11.9
11.5
12.8
11.8
8.8
6,3
3.9
2.5
'
19
1.9
3.6
6.8
9.3
11.6
11.5
12.7
11.5
8.8
6.3
3.9
2.5
20
1.8
3.6
6.4
9.3
11.5
11.5
12.7
11.4
8.8
6.2
3.8
2.4
21
1.6
3.1
6.4
9.0
11.4
11.3
12.7
11.4
8.6
6.1
3.7
2.4
22
1.6
2.9
6.2
8.9
11.2
11.1
12.5
11.4
8.5
5.9
3.5
2.1
23
1.4
2.8
5.7
8.6
11.2
11.1
12.2
11.3
8.1
5.8
3.4
2.0
24
1.4
2.5
5.2
8.4
11.0
10.9
11.7
11.3
7.8
5.4
3.0
1.9
25
1.2
2.3
5.1
8.4
10.8
10.2
11.7
11.2
7.3
5.4
2.9
1.9
26
1.1
2.3
5.0
8.3
10.6
9.8
11.4
11.1
7.3
5.1
2.8
1.4
27
1.1
2.2
4.9
7.9
10.3
9.3
11.0
11.1
7.2
5.1
2.7
1.1
28
.8
1.9
4.5
7.9
10.3
8.0
10.2
10.7
5.4
4.9
2.6
1.0
'
29
.6
1.7
4.3
7.8
9.9
7.5
9.8
8.9
5.0
4.1
2.3
.9
30
.4
.7
3.1
7.7
6.4
5.7
4.6
6.9
2.3
3.7
2.2
.0
AVERAGE
2.5
4.3
7.4
9.8
12.1
11.6
12.7
11.8
8.7
6.6
4.1
2.8
1
1
I

1
1
l]
I
1
1
1
1
1
kA
Fl
I
1
ACTUAL EVAPOTRANSPIRATION FROM A TYPICAL. DRAINED HARDWOOD FORESTED WETLAND
SITE NEAR PLYMOUTH, NC, 1957-1987. ASSUMED DRAINAGE CONDITIONS ARE 1 METER
DEEP DITCHES SPACED 200 METERS APART. (MAXIM" SURFACE STORAGE 2.5 CM).
EFFECTIVE ROOT DEPTH IS ASSUMED TO BE 40 CM DURING THE GROWING SEASON AND 5 CM
DURING THE DORMANT PERIOD.
RANKING OF MONTHLY
EVAPOTRANSPIRATION
RANK
.LAN
FEB
MAR
APR
MAY
.TUN
JUL
AUG
SEP
OCT
NOV
DEC
1
7.8
7.2
10.2
12.4
14.9
13.8
15.5
13.0
10.4
9.2
7.2
5.7
2
4,5
6.9
10.0
12.0
14.5
13.7
15.4
12.7
10.4
9.2
5.2
5.0
3
4.0
6.6
9.7
11.5
14.1
13.6
15.0
12.7
10.3
8.5
5.1
4.2
4
4.0
6.1
9.2
11.2
14.0
13.4
14.4
12.7
10.2
8.1
5,0
4.1
5
3.8
5.8
9.1
11.1
13.8
13.2
14.2
12.6
10.1
7.8
5.0
3.8
6
3.5
5.6
9.0
10.7
13.4
13.1
13.8
12.5
9.9
7.8
4.9
3.8
7
3.2
5.6
8.9
10.6
13.3
12.6
13.5
12.4
9.8
7.7
4.9
3.3
8
3.1
5.5
8.6
10.5
13.1
12.4
13.4
12.4
9.7
7.4
4.8
3.2
9
3.0
5.4
8.5
10.0
12.8
12.2
13.4
12.2
9.7
7.3
4.7
2.9
10
2.9
5.1
8.1
10.0
12.7
12.0
13.4
12.2
9.5
7.3
4.3
2.9
11
2.8
5.1
7.9
10.0
12.7
12.0
13.3
12.0
9.5
7.0
4.3
2.8
12
2.8
4.9
7.9
9.9
12.2
12.0
13.3
12.0
9.5
6.9
4.2
2.7
13
2.7
4.8
7.6
9.7
12.2
11.9
13.3
11.8
9.4
6.5
4.2
2.7
14
2.3
4.7
7.6
9.5
12.1
11.7
13.3
11.8
9.3
6.4
4.1
2.6
15
2.2
4.5
7.2
9.5
11.9
11.6
13.2
11.7
9.0
6.4
4.1
2.5
16
2.2
4.2
6.9
9.5
11.9
11.5
12.8
11.5
8.9
6.3
3.9
2.5
17
2.1
4.1
6.8
9.4
11.6
11.5
12.7
11.4
8.8
6.3
3.9
2.5
18
2.0
3.9
6.8
9.3
11.6
11.5
12.7
11.4
8.8
6.2
3.7
2.5
19
1.9
3.6
6.8
9.2
11.5
11.3
12.7
11.3
8.8
6.1
3.6
2.4
20
1.8
3.6
6.4
9.0
11.4
11.1
12.5
11.3
8.6
6.0
3.4
2.1
21
1.6
3.1
6.4
8.9
11.2
10.9
12.5
11.3
6.1
5.9
3.0
2.0
22
1.6
2.9
6.2
8.6
11.2
10.3
12.2
11.2
8.0
5.8
2.8
1.9
23
1.4
2.8
5.7
8.4
10.8
9.8
11.7
11.1
7.8
5.4
2.8
1.9
24
1.4
2.5
5.2
8.4
10.6
7.9
11.7
11.1
7.5
5.4
2.6
1.8
25
1.2
2.3
5.1
8.3
10.3
7.7
11.3
11.1
7.3
5.4
2.6
1.4
26
1.1
2.3
5.0
7.9
10.1
7.3
11.0
10.9
7.2
5.1
2.4
1.1
27
1.1
2.2
4.9
7.9
8,5
6.5
10.9
10.6
5.9
5.1
2.4
1.0
28
.8
1.9
4.5
7.8
8.1
6.5
10.1
8.9
4.6
4.5
2.2
.9
29
.6
1.7
4.3
7.7
7.5
5.7
8.5
8.8
4.0
3.9
1.0
.7
30
.4
.7
3.1
5.6
6.5
5.7
4.5
6.8
2.3
3.5
.0
.0
AVERAGE 2.5 4.2 7.1 9.5 11.7 10.8 12.5 11.4 8.4 6.5
3.7 2.6
5, / c wA
3 5.� ;ekes
1

ACTUAL
EVAPOTRANSPIRATION
FROM
A MATURE
PINE
PLANTATION ON A DRAINED
'
PORTSMOUTH
SOIL NEAR
PLYMOUTH.
NC. DITCHES
ARE 1 METER
DEEP,
SPACED
200 METERS
APART.
SURFACE
STORAGE
IS
2.0 CM. EFFECTIVE
ROOTING
DEPTH
IS 45
CH ALL
YEAR.
RANKING OF MONTHLY
EVAPOTRANSPIRATION
RANK
JAN
FEB
MAR
ATR
MAY
JUN
JUL
AUG
SEP
OCT
NOV
DEC
1
7.8
7.2
10.6
12.4
14.9
13.7
15.5
13.0
10.4
9.2
7.2
5.6
2
4.5
6.9
10.0
12.4
14.8
13.6
15.4
12.7
10.4
9.2
5.1
5.0
3
4.0
6.3
10.0
12.2
14.1
13.4
15.0
12.7
10.3
8.5
5.0
4.2
4
4,0
6.1
9.7
11.6
14.0
13.3
14.4
12.7
10.2
8.5
5.0
4.1
5
3.6
5.8
9.3
11.5
13.9
13.2
14.2
12.7
10.1
8.1
4.9
3.8
'
6
3.5
5.6
9.3
11.2
13.4
12.9
13.8
12.6
9.9
7.8
4.9
3.8
7
3.2
5.6
9.3
10.9
13.3
12.6
13.5
12.5
9.8
7.7
4.8
3.3
8
3.1
5.5
9.2
10.9
13.1
12.6
13.4
12.4
9.7
7.4
4.8
3.2
9
3,0
5.4
9.0
10.7
12.8
12.4
13.4
12.4
9.7
7.3
4.5
2.9
10
2.9
5.1
8.9
10.6
12.7
12.2
13.4
12.2
9.6
7.3
4.3
2.9
11
2.8
5.1
8.8
10.5
12.7
12.0
13.3
12.2
9.6
7.2
4.3
2.8
12
2.8
4.9
8.7
10.1
12.7
12.0
13.3
12.0
9.5
7.0
4.2
2.8
13
2.7
4.8
8.6
10.0
12.4
12.0
13.3
12.0
9.5
6.9
4.2
2.7
14
2.3
4.7
7.6
10.0
12.2
11.9
13.3
11.9
9.4
6.5
4.1
2.6
15
2,2
4.5
7.2
9.8
12.1
11.6
13.2
11.8
9.3
6.4
4.1
2.5
'
16
2,2
4.2
6.9
9.7
11.9
11.5
12.8
11.8
9.2
6.4
3.9
2.5.
17
2.1
4.1
6.8
9.5
11.6
11.5
12.8
11.7
9.0
6.3
3.9
2.4
18
2.0
3.9
6.8
9.5
11.5
11.5
12.7
11.5
8.9
6.3
3.7
2.4
19
1.9
3.6
6.8
9.4
11.4
11.3
12.7
11.4
8.8
6.3
3.5
2.3
1
20
1.8
3.6
6.4
9.3
11.4
11.1
12.7
11.4
8.8
6.2
3.0
2.1
21
1.6
3.1
6.4
9.0
11.2
10.9
12.5
11.4
8.8
6.1
2.8
2.0
'
22
23
1.6
1.4
2.9
2.8
6.2
5.7
8.9
8.6
11.2
10.8
10.8
10.6
12.2
12.0
11.3
11.3
8.6
8.4
5.9
5.8
2.7
2.6
1.9
1.9
24
1.4
2.5
5.2
8.4
10.6
8.5
11.7
11.2
8.1
5.4
2.2
1.8
25
1.2
2.3
5.1
8.4
10.3
7.7
11.6
11.1
7.8
5.4
1.6
1.4
26
1.1
2.3
5.0
8.3
9.3
7.3
10.9
11.1
7.3
5.1
1.5
1.1
27
1.1
2.2
4.9
7.9
8.8
7.3
10.9
10.5
6.7
5.1
1.0
1.0
28
.8
1.9
4.5
7.9
8.3
7.2
10.1
9.7
5.6
4.7
.6
.9
29
.5
1.7
4.3
7.8
7.8
6.6
8.5
8.8
5.4
4.4
.6
.6
'
30
.4
.7
3.1
7.1
4.1
5.6
4.5
6.8
2.4
3.8
.4
.0
AVERAGE
2.5
4.2
7.3
9.8
11.6
11.0
12.6
11.6
8.7
6,6
3.5
2.5
1
7'-?) 7'� /
4�,Z
�-- `-
zAclej
1
u
I

1
1
u
1
1
1
1
F1
Ll
ACTUAL EVAPOTRANSPIRATION (AET) FROM DRAINED PORTSMOUTH SOIL NEAR PLYMOUTH
WITH WELL ESTABLISHED FESCUE. DITCHES ARE 1 METER DEEP AND 200 METERS APART.
MAXIMUM SURFACE PONDING IS 2 CM AND EFFECTIVE ROOT DEPTH IS 30 CH DURING THE
ACTIVE GROWING PERIOD AND 15 CM DURING THE SEMI-DOREANT PERIOD (JUNE 20 TO
SEPTEMBER 15)
RANK
JAIL
FEB
1
7.8
10.0
2
4.6
7.2
3
4.0
6.9
4
4.0
6.1
5
3.8
5.8
6
3.5
5.6
7
3.2
5.6
8
3.1
5.5
9
3.0
5.4
10
2.9
5.1
11
2.8
5.1
12
2.8
4.9
13
2.7
4.8
14
2.3
4.7
15
2.2
4.5
16
2.2
4.2
17
2.1
4.1
18
2.0
3.9
19
1.9
3.6
20
1.8
3.6
21
1.7
3.1
22
1.6
2.9
23
1.6
2.8
24
1.6
2.5
25
1,4
2.3
26
1.4
2.3
27
1.2
2.2
28
1.1
1.9
29
1.1
1.7
30
,4
.7
AVERAGE
2.5
4.3
RANKING OF
MONTHLY
EVAPOTRANSPIRATION
MAR
APR
MAY
,TUN
JUL
AUG
SEP
OCT
NOV
DEC
11.2
12.4
13.2
12.6
15.5
12.7
10.4
9.2
7.2
6.1
10.6
12.2
13.1
12.2
14.2
12.5
10.3
9.2
5.7
5.9
10.0
11.6
12.7
12.2
14.1
12.2
10.3
8.5
5.1
5.0
10.0
11.5
12.2
12.0
13.5
11.9
10.2
8.1
5.1
4.2
9.7
11.2
12.2
12.0
13.3
11.9
10.1
7.8
5.0
4.1
9.3
10,7
12.1
11.9
13.3
11.8
9.8
7.8
5.0
4.0
9.3
10.6
11.9
11.6
13.3
11.8
9.7
7.7
4.9
3.8
9.2
10,5
11,9
11.5
13.2
11.6
9.6
7.4
4,9
3.8
9.2
10.2
11.9
11.5
13.0
11.5
9.5
7.3
4.9
3.3
9.0
10.1
11.6
11.3
12.7
11,5
9.5
7,3
4.8
3.2
8.9
10.1
11.5
11.1
12.7
11.4
9.4
7.0
4.7
3.1
8.8
10.0
11.2
10.7
12.5
11.4
9.3
6.9
4.3
3,1
8.6
10.0
11.2
10.6
12.2
11,4
9.0
6.5
4.3
2.9
7.6
9.8
11.1
10.5
12.1
11.3
8.9
6.5
4.3
2.8
7.2
9.5
11.1
10.0
12.0
11.3
8.8
6.4
4.2
2.7
6.9
9.5
10.9
9.8
11.9
11,3
8.8
6.4
4.2
2.7
6,8
9.4
10.8
9.1
11.7
11.2
8.8
6.3
4.1
2.7
6.8
9.3
10.8
8.7
11.7
11.1
8.5
6.3
4.1
2.6
6.8
9.0
10.6
8.7
11.7
10,9
8.3
6.3
4.1
2.5
6.4
8.9
10.3
8.4
11.7
10.8
8.2
6.3
4.1
2.5
6.4
8.6
10.2
8.4
11.3
10.2
8.1
6.3
3.9
2.4
6.2
8.4
10.2
7.0
11.2
9.8
8.0
6.2
3.9
2.4
5.7
8.4
9.4
5.4
10.9
9.3
8.0
6.1
3,7
2.1
5.2
8.3
9.1
5.2
10.7
8.9
7,8
5.9
3.4
2.0
5,1
7.9
8.7
4.8
10.1
8.9
7.7
5.9
3.4
1.9
5.0
7.9
6.2
4.6
10.1
8.4
7.7
5.8
3.3
1.9
4.9
7.8
5.4
4.4
7.1
6.9
7.3
5.4
3.2
1.8
4.5
7.7
5.2
3,4
7.1
6.0
7.1
5.4
3.0
1.4
4.3
6.3
4.1
3.4
5.4
5.7
6.8
5.1
2.8
1.1
3.1
4.5
2.4
2.3
4,2
5.2
3.7
5.1
2.6
1.0
7.4
9.4
10.1
8.8
11.5
10.4
8.6
6.7
4.3
3.0
-�o�a / ? ?, j Gk%-A
3L/,3 -�ckrs

EVAPORATION FROM A
BARE,
DRAINED
PORSTMOUTH
SOIL NEAR PLYMOUTH,
NC.
DITCHES
._
ARE 1 METER
DEEP,
SPACED
200 METERS APART.
MAXIMUM
SURFACE
PONDINC
IS 2 CM.
RANKING
OF MONTHLY
EVAPOTRANSPIRATION
RANK
JAN
FEB
MAR
APR
MAY
JUN
JUL
AUG
SEP
OCT
NOV
DEC
1
7.8
7.2
9.7
10.0
11.6
11.5
14.7
12.3
9.8
8.9
6.4
4.9
2
4.6
6.5
9.0
9.4
11.4
11.2
13.2
11.8
9.4
8.5
5.0
4.8
'
3
4.0
6.1
8.8
9.3
11.2
ll.l
L2.7
11.6
9.2
7.4
5.0
4.2
4
4.0
5.8
8.8
9.2
10.9
10.5
12.3
11.4
9.1
7.3
4.9
4.1
5
3.8
5.6
8.6
9.1
10.5
10.4
12.0
11.3
8.6
6.8
4.8
4.1
6
3.5
5.6
8.0
8.5
10.2
10.3
11.9
11.1
8.5
6.5
4.8
4.0
'
7
3.2
5.6
7.6
8.0
10.1
10.1
11.9
10.8
8.5
6.4
4.7
3.8
8
3.1
5.5
7.5
8.0
10.1
10.1
11.8
10.7
8.4
6.2
4.5
3.8
9
3.0
. 5.4
7.5
7.9
9.5
10.0
11.6
10.6
8A
6.2
4.3
3.3
'
10
2.9
5.1
7.3
7.8
9.5
9.9
11.6
10.5
7.6
6.1
4.3
3.2
11
2.8
5.1
7.1
7.8
9.2
9.7
11.5
10.3
7.6
6.1
4.2
3.1
12
2.8
4.9
6.8
7.5
8.9
9.6
11.2
10.0
7.5
6.1
4.2
3.1
13
2.6
4.8
6.8
7.4
8.9
9.4
11.0
9.9
7.4
6.0
4.1
2.9
14
2.3
4.7
6.7
7,4
8.6
8.7
10.9
9.8
7.3
5.8
4.1
2.8
15
2.2
4.5
6.5
7.4
8.5
8.6
10.9
9.6
7.3
5.8
3.9
2.7
16
2.2
4.0
6.4
7.3
8.3
8.1
10.6
9.6
7,3
5.7
3.9
2.7
17
2.1
3.9
6.2
7.2
8.2
8.1
10.5
9.5
7.2
5.6
3.9
2.6
18
2.0
3.6
6.2
7.2
8.2
8.1
10.4
9.3
7.1
5.5
3.7
2.5
19
1.9
3.6
6.1
6.8
8.1
7.4
10.3
8.9
7.1
5.2
3.4
2.5
'
20
1.8
3.4
6.0
6.7
7.3
7.4
10.3
8.8
6.5
5.2
3.4
2.4
21
1.6
3.1
5.9,
6.4
7.3
7.3
10.2
8.5
6.5
5.1
3.2
2.1
22
1.6
2.9
5.7
6.1
7.3
7.2
10.0
7.3
5.7
5.1
3.0
2.0
23
1.4
2.8
5.2
6.1
7.1
7.1
10.0
7.2
5.6
4.9
2.8
1.9
24
1.4
2.5
5.1
5.4
6.4
6.1
9.4
7.1
5.5
4.9
2.8
1.9
25
1.2
2.3
5.0
5.1
5.7
6.1
8.9
6.9
5.4
4.9
2.5
1.9
26
27
1.1
1.1
2.3
2.2
4.9
4.7
4.5
4.2
5.5
5.4
5.4
5.3
8.9
7.3
6.4
5.8
5.2
4.1
4.4
3.6
2.4
2.3
1.7
1.6
28
.9
1.9
4.5
4.1
3.6
5.3
6.4
5.4
3.4
3.5
2.2
1.4
29
.7
1.7
4.3
4.0
3.3
5.1
4.2
4.6
3.2
3.4
2.1
1.1
30
.4
.7
3.1
3.1
2.9
4.7
3.6
3.4
3.1
3.2
1.9
1.0
AVERAGE
2.5
4.1
6.5
7.0
8.1
8.3
10.3
9.0
6�9
5.7
3.8
2.8
r
7Lo7-1zz,