07-05_2_Redacted

RCDENR
North Carolina Department of Environment and Natural Resources
Division of Land Resources
Land Quality Section
James D. Simons, PG, PE
Director and State Geologist
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
7003 1680 0000 1479 4974
Mr. Jeffrey C. Furness
Senior Scientist
PCS Phosphate Company Inc.
PO Box 48
Aurora, North Carolina 27806
Sevedy Eaves Perdue, Governor
December 2, 2009 Dee Freeman, Secretary
Re: Aurora Phosphate Mine (NCPC Tract)
Permit No. 07-05
Beaufort County
Tar River Basin
Dear Mr. Furness:
An inspection was made of the above mine on September 29, 2009 in accordance with G.S. 74-
56 of the Mining Act of 1971.
The 1075 acre area at the site requested to be released, as indicated on the mine map dated
October 26, 2009, has not been distubed by mining activities and is hereby transferred in its entirety to
Mining Permit No. 07-01 as per your company's request. Reclamation responsibilities for the 1075 acre
area is now under Mining Permit No. 07-01.
As a reminder, your company's permitted acreage at the 07-05 Mine Permit Site is now 1962
acres and the amount of land allowed to be disturbed at this site is 0 acres. No mining related activities
may occur at this site until a modification request that includes detailed erosion and sediment control
plan is submitted to and approved by the Division of Land Resources.
Thank you for your cooperation in this matter.
Very truly yours,
414-x
Floyd R. Williams, PG, CPG, CPESC
State Mining Specialist
Land Quality Section
FRWIjw
cc: Mr. Pat McClain, PE
1612 Mail Service Center, Raleigh, North Carolina 27699-1612 - Telephone [phone] FAX: [phone]
512 North Salisbury Street, Raleigh, North Carolina, 27604 • Internet:http:Nwww.dlr.enr.state,nc,us/pages/Iandqualitysection.html
An Equal Opportunity I Affirmative Action Employer — 50% Recycled 110% Post Consumer Paper

MINING
ROUTING SLIPS
JUDY W.
FL O YD W:
MELL N:
JIM S:
COMMENTS

North Carolina Department of Environment and Natural Resources,
Division of Land Resources, Land Quality Section
(PE M )
1. MINE NAMEe"6� A 6J 1 e �q . M aNG PERMIT #y
3. OPERATOR 4. COUNTY.,n.7
S. ADDRESS AY IV c . ;7 0u
6. PERMIT EXPIRATION DATE �e 7. RIVER BASIN
8. Person(s) contacted at site -I.s%rr.��✓css _
9. Was mine operating at time of inspection? ❑ Yes 8-'No 10. Pictum? ❑ Yes B-No
I L Date last inspected: 12. Any mining since last inspection? Cl Yes G�-No
13. Is the mine in compliance with the Operating Conditions of the Permit? C `Yes ❑ No
If no, explain:
14. Is the mine in compliance with the Reclamation Conditions of the Permit? G-Yes ❑ No
If no, explain:
IS. Did any of the above deficiencies result in offsite damage? ❑ Yes 3-No If yes, describe the
type and severity of the damage:
16. Corrective meamm needed and/or taken:
17. Other recommendations and comments:
18. Is the Annual Reclamation Report +/-map accurate? ❑ Yes ❑ No (Explain) 5-Mt Reviewed
19. Follow-up inspection needed? ❑ Yes LfiNo Proposed date I I
20. No. of additional pages of Inspection Report__. 21. Copy of Report sent to operator I I
(date)
INSPECTED BY: DATE GI I � °Y I ,20"
Telephone No: ,-.3-1 7`
While copy to file Yellow copy to operator Pink copy to Mining Specialist 10197

North Carolina Department of Environment and NaWral ReaO=4'
D vision of Land Resources, Land Quality Swdon ;
1TJ.J1tJ1 JL 17i A"%--iA%.F11q 4%\ & V&%i 11-'+ f-,' LUVJ
(PERNIYTTED MINE)
1. MINE NAME 2. M NWG PERMIT #
3. OPERATOR 4. COITNTY
5. ADDRESS r
6. PERMIT EXPIRATION DATE 7. RIVER BASIN
S. Person(s) contacted at site
9. Was mine operating at time of inspection? ❑ Yes ❑ No 10. Pictures? ❑ Yes ❑ No
11. Date leaf inspected: / / 12. Any mining since lst ainspection? ❑ Yes ❑ No
13. Is the mine in compliance with the Operating Conditions of the Permit? ❑ Yes . ❑ No
If no, explain:
14. Is the mine in compliance with the Reclamation Conditions of the Permit? 0-Yes ❑ No
If no, explain:
15. Did any of the above deficiencies result in offsite damage? ❑ Yes C7'No If yes, describe the
type and severity of the damage:
16. Corrective measures needed and/or taken:
17. Other recommendations and comments:
I S. Is the Annual Reclamation Report +l--map accurate? ❑ Yes ❑ No (Explain) ❑ Not Reviewed
19. Follow-up inspection needed? ❑ Yes ❑ No Proposed date I I
20. No. of additional pages of Inspection Report . 21. Copy of Report seat to operator
(daft)
INSPECTED BY: _ DATE
Telephone No: ( 1
White copy to file Yellow copy to operator Pink copy to Mining Specialist 10197

■ Complete Rams 1, 2, and 3. Also complete
Rem 4 It Restricted Delivery Is desired.
■ Print your name and address on the reverse
so that we can return the card to you.
■ Attach this card to the back of the mailplece,
or on the fnant R space permits.
1. Article Addressed to:
MR JEFFREY C FURNESS
SENIOR SCIENTIST
PCS PHOSPHATE CO INC
PO BOX 48
AURORA NC 27806
A. ftnati
8. ecel by { FWrrte¢ Man*) I C. Data }oi� ve
�y Norris 11 / /�
D. Is delivery address dHterwd from Item 1? U Yt
If YES, enter delivery address below: ❑ No
3. Type
ertified MailfC7.0D.
Mail
�EO�DRIegjhwftwrewd Receipt for Merchandise
❑ tnaured Mall
4. Restricted Delivery? (Extra Fee) ❑ yes
2. Article7EE3 1680 0000 1�479 4974
rn�fer r
� ftmse"ke kw
PS Form 3811, February 2004 907+ Domestic Return Receipt / PV -Vq 102595-02-M-1540

f
... . ....... .
sl?t 1912
NEW PERMIT 7-1 AREA (14,036 Ac)
0,5 mi 1.0 Hi 1.5 Hi
ow:
Permit Lout or Mop
Date. 10-26-09 Proposed Permits 1/-1 &, 7`5
Scale- I' = 2,000'
ReN
A
AURORA DIVISION
Location:
D%\g. No.

0 0
MINING CHECKLIST FOR ROUTING
vltcants New.
A ik./Pe►ntit No. C.ourd�:
Project Nano:
Rcvtmer: Rtq'[1' Bast! Nme:
Date RMIRad:
❑ N9R ❑ Rent d ❑ md*4tian (Dwk yemd bwt 49w)
❑ Mooutim (mtdde yermit bcundartes) ❑ Trwo ftr ❑ Release
❑ Partial Repast ❑ AddtUOXd 14►n OM ❑ Fa NU" $ ❑ Fa Reutval: $
Pjcau route mfErt a1tu[fan dackaff to
❑, ,.' ii . I i 4 RtgtOnal Offia (z c yfW coyW, attack tkc *UZ WMW OffW MIMV AyylicOM RMIN
ChedU' to one coyy and attirek botk tke DWQand DAQ'Mtntr& A)ThUtIM RCVIN FO► r to W otkcr W , 9 both r," to the RoImfal
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Dak: RoMW Rtc'd
❑ DtvfM ° water RGsairces Date: Routed Reed
❑ Nc Wildltft Raarw Can[ntts A Date: Routed Red
❑ US Ftsk & Wtldkfi servta Date: ROW Reed
(only new macattmu ma modocattan rcpek that add (and to thcrcrpm
Plcasc restic irsf 3-EW o t6 g6timt ad T Ioadm !s to.
❑ DMdm of Parks et Rec►catlan Date: Ratted Reed
❑ Nc GM106W Strvg ScCUM Date: RNW Rtc d
❑ DM.stOn Of Martnc FtS6ft Date: Ratted Read
❑ Dtvi O o f Soil & Water calMdan (ylus 7.F.A) Daft: Ratted Read
(only ww ayyltcaumts and inadficatto►i m1usu ad add w to tkererNr o
❑ DtYtttan of Arck M et Hts 7 Daft: Ratted Red
(only WN arylicattons)
❑ otkp
Daft: Ratted Reed
**SWyeW Date for CoWeNtS: (w later tiara 25 da'sfim ram)
❑ Please uatt t6 ftfff":

Please FedEx to:
Ms. Judy Wehner
NCDENR - Division of Land Resources
512 North Salisbury Street, Room 519
Raleigh, North Carolina 27604
Phone No. 919-733-4574
Account No:
From: Jeff Furness - Environmental Affairs

•
Vk PotashCoroo
Helping Nature Provide
Federal Express
November 10. 2009
Ms. Judy Wehner
Assistant State Minim Specialist
NC DE NR - Division of Land Resources
512 North Salisbury Street, Room 519
Raleigh, North Carolina 27604
RE: Permit Boundary Maps for Mine Permit 07-05
Dear Ms. Wehner:
Enclosed are two copies ol'the PCS Phosphate Mine Permit Location Map, �khich you recently requested
101- your files Ior Otir Mine PCI-Mit 07-05. If yoti have any questions. please call me at {252} 322-8249, or
e-mail nie at jfgjmcss�ci'twsphosplmw_com.
Sincerely,
1 'ff'rey C. Furness
Senior Scientist
Enclosures
pc: 23-04-001-62 w/o encl
RECEIVED
R. M. Smith w/o olio].
.I.M. Waters w/o encl.
LAND QUALITY
MIMING PROGRAfA
1530 NC HWY 306 S, Aurora, NC U5 27806-9245 T 252-322-4111
I www.potashcorp.com

•
ft PotashCorp'
Helping Nature Provide
Federal Express
October 28, 2009
Ms. Judy Wehner
Assistant State Mining Specialist
NC DENR - Division of Land Resources
512 North Salisbury Street, Room 519
Raleigh, North Carolina 27604
RE: Mine Permit 07-01 Modification — Supplemental Information
Dear Ms. Wehner:
•
LICTD
D21"_r7.tn
This letter is in response to your letter of October 12, 2009, requesting additional information to continue
processing PCS Phosphate's application to modify Mining Permit 07-01. Enclosed are two copies of a
revised mine map, which shows the 2009-201 1 impact block, with proposed erosion and sediment control
measures, and has the existing permit line darkened. Also enclosed are two copies of a mine permit
location map, showing boundary revisions to Mining Permits 07-01 and 07-05. An original and a copy of
a new Affidavit of Notification are also enclosed.
Mining Permit 07-05 currently consists of 3,037 acres, and w equest a prial release of that permit,
transferring 1,075 acres out of 07-OS and into 07-0 1. This le ves 1,962 a in 07-05. Mining Permit
07-01 currently consists of 12,299 acres. With the addition o 07 • ;e from 07-05 and 662 acres that
were permitted within the Corps Modified Alternative L (404 permit) that lie outside of the 07-05
boundary, the new total for Mining Permit 07-01 will be 14,036 acres. At this time, we are requesting to
impact 763 acres of the 1,737 acres added to 07-01, increasing the total acreage that we are permitted to
disturb to 11,868 acres.
Due to the preference of most environmental agencies involved in the EIS process for reclaimed land to
be as low as possible along South Creek, it is necessary to raise the elevation of the current R-3
reclamation area. Raising the elevation of R-3 and deposition of additional gypsum -clay blend material
will impact the timing for capping of this area. Based on the dates shown on the graphic labeled
Attachment 12 included in the original application, R-3 will be capped between 2014 and 2017.
Therefore, we request a delay in the requirement to cap R-3 to December 31, 2017.
Finally, PCS Phosphate acknowledges that an erosion and sediment control plan will be submitted to the
Washington Regional Office Land Quality Section at a later date for the tie-ins for the relocated Sandy
Landing Road. If you have any questions, please call me at [phone], or e-mail me at
I fu rn e ss(i�pcs phosphate. corn.
Sincerely,
f t C. J-11 ^an k
t ey� Furness
Senior Scientist
Enclosures
PC: 23-04-001-78 w/encl.
S.A. Becket w/o encl
J.M. Waters w/o encl
R. M. Smith w/o encl.
I. K. Gilmore w/encl.
M. P. Brom w/encl.
IS30 NC HWY 306 S, Aurora, NC US 27806.9245 T 252.322.4111
www.potashcorp.com

TRANSMISSION VERIFICATION REPORT
TIME
11/18/2009 11:35
NAME
NC DENR DLR
FAX
9197158801
TEL
9197333833
SER.#
xxxxxxxxxxxx
DATE J IME 11 / 18 11: 31
FAX NO./NAME 912529753716
DURATION 00: 03: 31
PAGE(S) 12
RESULT OK
MODE STANDARD

r a �
North Carolina Department of Environment and Natural Resources
Division of Land Resources - Land Quality Section ✓lining Program
1612 flail Service Center, Raleigh, North Carolina 27699
[phone] Fax: [phone]
FAX COVER SHEET
FAX NUMBER TRANSMITTED TO: 1 r%5'- 3% Aw
To:
Of:
From:
am
Date: 1
COMMENTS:
*IF YOU DO NOT RECEIVE ALL PAGES, PLEASE TELEPHONE US IMMEDIATELY AT [phone].

State of North Carolina
Department of Natural Resources and Community Development
Division of land Resources
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor February 26, 1987 Stephen G. Conrad
S. Thomas Rhodes, Secretary Director
Mr. Mitchell Harris
Texasgulf Chemicals, Inc.
P. a. Box 48
Aurora, North Carolina 27806
RE: Amendment to Mining Permit: Blend Dike Elevations
Dear Mr. Harris:
On February 13, 1987 Mr. Mike Breza of Texasgulf contacted Mr. Charles
Gardner of this office to request that your Mining Permit be modified regarding
the top of the gypsum -clay blend dike elevations.
Your latest mining permit indicates that the top elevation of the blend
disposal dikes will be at elevation 37 feet msl. This was based on the bl
disposal dike plans envisioned by your company at the time of your mining
renewal application. Subsequently, the plan was revised to have the top o
blend disposal dikes at elevation 50 feet msl and, in fact, we have approv
construction of R-1 to elevation 50 through our jurisdiction under the N.
Safety Law,
In order to clear the record this letter serves as a modification of
mining permit regarding the blend dike elevations, as follows:
The blend area dikes may be constructed to a top elevation not exceed
feet above mean sea level. The freeboard between the top of the dikes and
impounded fluids or materials may not be less than 5.0 feet, All dike des
construction, inspection, operation, and maintenance must be consistent wi
requirements of the N. C. Dam Safety Law of 1967.
We appreciate your bringing this to our attention. Please call if yo
any questions,
Sincerely,
Stephen G. Conrad
SGC/cft
cc: Mr., Charles Gardner
Mr. Tom Carroll
Mr, Jim Simons
Mr. Floyd Williams
P.O Box 27697, Raleigh, Nash Carolina 2761t-7687 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

State of North Carolina
Department of Natural Resources and Community Development
Division of Land Resources
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor Stephen G, Conrad
S. Thomas Rhodes, Secretary June 26, 1986 Director
Mr. Douglas G. Mercer
Texasgulf Chemicals Company
A Division of Texasgulf Inc.
P.O. Box 48
Aurora, North Carolina 27806
Re; Transfer of Mining Permits
Numbers 7--13 and 7-5
Beaufort County
Dear Mr. Mercer:
As requested, by your letter of May 20, 1986 we are transferring the mining
permits for the North Carolina Phosphate Corporation NCPC Sand Mine 07-13) and
NCPC Phosphate Mine (#7-5) to Texasgulf, Inc. The conditions of the permits are
unchanged.
The transfer of the phosphate mine is only an interim step until Texasgulf,
Inc. can revised mining plans that would consolidate this permit and permit no.
7-1. We would appreciate your advising us as soon as possible when we can
expect your revised plans. We would like to resolve this matter within the next
three months.
We will be happy to discuss possible modification to these permits at your
request. You are also welcome to examine our existing files for these two
mines.
Please advise should you have any questions concerning this matter.
Very truly yours,
C4.4-.41- CA-4—
Charles H. Gardner, C.P.G., P.E.
Chief, Land Quality Section
CHG/JDS/cj
Enclosures
cc: Mr. Floyd Williams
PO Box 27687, Raleigh, North Carolina 27611.7687 Tekphonc 919,733.3833
An Equal Opportunity AffirmatKt Action Ernooyw

o North Carolina Department of Natural
Resources &Community Development
r� �r James E3 Hunt, Jr., Governor Joseph W Grimsley, Secretary
GiMr.
2 December 1983
To: Jim Simons
Mining Specialist
Land Quality Section
From: David Gossett Da'
Environmental Consultant
Office of Coastal Management
OFFICE OF
COASTAL MANAGEMENT
Kenneth D Stewart
Director
Telephone [phone]
Field Services
P.O. Box 1507
Washington, NC 27889
[phone]
W- e' v ,, �' E
DEC
sub j• Pro +�:', .'� SE���►4N
� . posed Mining Permit Modification
North Carolina Phosphate Corporation
Beaufort County
I have reviewed the requested mining permit modification by North Carolina
Phosphate Corporation which involves a slight change in the height of the
disposal piles, and have no problems with the modification as requested.
I appreciate you giving me an opportunity to continent on the modification.
cc: Preston Pate - Chief, Field Services Section, OCM
P 0 Box 27687 Raleigh, N. C 27611-76B7
An Equal Opportunity Affirmative Action Employer

November 17, 1983
lulDu• e . ►ii UTI
TO: Dave Gossett, OCM, Washington
Stuart Critcher, WRC
Jim Mulligan, DEM, Washington
Terry Sholar.Marine Fisheries, Washington
FROM: Jim Simons P;
SUBJECT: NCPC Permit Modifications
N.C. Phosphate Corp. has applied to modify the reclamation conditions
of their mining permit to change the initial overburden heights.
I am attaching a copy of the requested modifications for your
comment as well as a copy of the current permit.
Your ccsmient or at least an indication if any objection will be
raised would be appreciated by November 29, 1983.
JDS:ps
cc: Floyd Williams

NCPC(D
AN AGRICO MINING COMPANY
Mr. James D. Simons
Mining Specialist
Land Quality Section
Division of Land Resources
NCDNRCD
P. O. Box 27687
Raleigh, North Carolina 27611-7687
Dear Mr. Simons:
November 8, 1983
ARE C E I k Lc
Novi u 1aAt
LAND QUALITY SECTION
With this letter, I am requesting modification of North Carolina Phosphate
Mine Permit #7-5. This permit is effective until June 16, 1986.
The modification requested affects the APPROVED RECLAMATION PLAN -
RECLAMATION CONDITIONS, 2.A Initial Overburden Dis osal on page 6 of 8. Due
to changes in C's pit opening sequence and equipment availability, we have been
able to decrease the size of our initial dragline overburden disposal pile by at least
50% in both height and areal extent. This is accompanied by a small increase in
height of the bucketwheel excavator spoil pile.
In order to reflect the necessary changes, the first two paragraphs of
this section should be modified to read as follows:
2. The specifications for reclamation shall be as follows:
A. Initial Overburden Dis osal
The overburden removed by large walking draglines during the
pit opening phase will be placed on a 30 (vice 75) acre area
located adjacent to the initial pit opening. The final disposal
pile height shall be no more than 50 (vice 100) feet above the
original ground elevation. The stabilization plan shall be to
slope the material at a minimum of 2.5.1 inside and 3.1 outside
slope.
The initial bucketwheel excavator overburden disposal site will
cover an area of approximately 250 acres upon which the
overburden removed by the bucketwheel excavators will be
stacked during the pit opening phase. The final disposal pile
height shall be no more than 50 (vice 35) feet above original
ground elevation. The stabilization plan shall be to bench the
material at 25 foot of vertical rise with outside slopes no steeper
than two horizontal to one vertical.
NORTH CAROLINA PHOSPHATE CORPORATION
P. O. Box 2247 * 1 Harding Square • Washington, North Carolina 27889 • 919/946-4181

Mr. James D. Simons
November 8, 1983
Page Two
All other Conditions, Plans and Schedules remain the same.
It is hoped that these requested modifications can be approved as soon as
possible, as our modified pit opening plans are nearly complete and pit opening will
commence in April. Please call if you need further information.
Thank you for your consideration.
PA: gm
Very_truly yours,
jAyres
Manager, Environmental Affairs

A.
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A rt7 A
Uj
cn
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. dr. 1'
DEPARTMENT OF NATURAL RESOURCES AND COMMUNITY DEVELOPMENT
DIVISION OF LAND RESOURCES
LAND QUALITY SECTION
P E R M. I 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 Permitting Regulation 15
N.C.A.C. 5B,and other applicable laws, rules and regulations
Permission is hereby granted to:
North Carolina Phosphate Corporation permittee
for the operation of a phosphate mine
entitled, N.C. Phosphate Corporation Mine , permit no. 7_5
and located in Beaufort County, 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.

2 Of 8
In accordance with the application for this mining permit, which is hereby
approved by the Department of Natural Resources & Community Development, here-
inafter referred to as the Department, and in conformity with the approved Recla-
mation 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 Reclmation 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
both 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 con-
ditions 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.
Dp.fini ri nnc
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.
C:nndi ti nna
The permitted mining operation shall not violate standards of air quality,
surface water quality, or ground water quality promulgated by the Environmental
Management Commission, or the requirements of the Office of Coastal Management.
This permit shall be effective from the date of its issuance until June 16, 1986
and 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:

3 of 8
OPERATING CONDITIONS
1. Protection of Air Quality
Any mining process producing air contaminant emissions shall be subject to
the permitting requirements and regulations promulgated by the Division of
Environmental Management.
2. Protection of Water Quality
A. Any wastewater processing or mine dewatering shall be in accordance with
permit requirements and regulations promulgated by the Division of
Environmental Management.
B. Erosion control measures, including vegetative or mechanical barriers,
shall be provided in the initial stages of any land disturbance when
necessary to prevent sediment from discharging onto adjacent surface
areas or into any lake or natural watercourse in proximity to the affected
land. Pleasures to be used will include, but not be limited to: 1) natural
buffer strips will be maintained between adjacent properties, waterways or
wetlands not included in the permit area and the "affected land," 2) the
mined area will be surrounded with ditching to prevent overland erosion
and to minimize any turbidity in surface runoff, 3) mechanical erosion
control measures will be provided to minimize offsite siltation from
settling pond dike construction until the dikes can be stabilized with
permanent vegetation.
3. Compliance with Office of Coastal Management
Any disturbance or restoration of wetlands and/or waterways shall be in
accordance to the rules and regulations of Coastal Management.
4. Spoilpile Slope Stability
Any overburden, spoil, or wastepile slopes shall be graded and terraced to
a stable configuration.
Height of spoilpiles shall be in accordance with any local governmental rules
and regulations.
5. Protection of Adjacent Properties
A. Sufficient buffer 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.
B. Excavation shall not come within 300 feet of any neighboring dwelling
house, school, church, hospital, commercial or industrial building,
public road or other public property without written modification to
this permit describing how physical hazard to such features will be
prevented.

4of8
6. Annual Report
An Annual Reclamation Report shall be submitted on a form supplied by the
Department of February 1 of each year until reclamation is completed and
approved.
7. Bonding
The security which was posted pursuant to N.C.G.S. 74-54 in the form of
$25,000.00 blanket bond is sufficient to cover the phosphate operation as
indicated on the approved application. This security must remain in force
for this permit to be valid. The total affected land shall not exceed the
bonded acreage.

5 of 8
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 term of the Mining Permit.
The approved plan provides:
Minimum Standards As Provided By G. S. 74-53
1. The final slopes in all excavations in soil, sand, gravel and other uncon-
solidated 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, or 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 N.C. Agricultural
Experiment Station and the N.C. 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, initiation of 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.
RECLAMATION CONDITIONS
1. Provided further, and subject to the Reclamation Schedule, condition #4, the
planned future use of the affected land subsequent to reclamation shall be
to backfill the mined areas and revegetate the backfilled areas with flora
determined by revegetation test programs to be best suited and ecologically
productive. A lake will be left where the mine excavation is not backfilled.
Anticipated future use of the lake and revegetative areas will be recreational
and agarian.

2. The specifications for reclamation shall be as follows:
1:1
19
Initial Overburden Disposal
The overburden removed by large walking draglines during the pit
opening phase will be placed on a 75"acre area located adjacent
to the initial pit opening. The final disposal pile height shall
be no more than 100 feet above the original ground elevation. The
stabilization plan shall be to bench the material each 30 feet of
vertical rise with outside slopes no steeper than two horizontal
to one vertical.
The initial bucketwheel excavator overburden disposal site will
cover an area of approximately 250 acres upon which the overburden
removed by the bucketwheel excavators will be stacked during the
pit opening phase. The final disposal pile height shall be no more
than 35 feet above original ground elevation. The stabilization
plan shall be to bench the material at 25 foot of vertical rise
with outside slopes no steeper than two horizontal to one vertical.
The two disposal piles shall be properly graded to control rain
water runoff and prevent erosion and off -site sedimentation.
The two areas will be fertilized, seeded, and mulched to establish
an erosion control cover crop.
The reclamation of these disposal piles will occur within the mine
production years one through three. The bucketwheel excavator
disposal pile will be rehandled and the ore located beneath will
be mined approximately twenty years after first mine production.
Subsequent to mining, the area will be reclaimed following the
routine reclamation practice scheduled for other mined out areas.
Clay Tailings Initial Disposal Area
After useful life of the initial clay tailings area has been exhausted,
approximately six to ten years after start of mine production, area
reclamation will begin. Reclamation will consist of decantation of
surface water, surface stabilization, grading of embankment freeboard
onto the stabilized surface, and establishment of a suitable cover crop.
C. Sand Tailings Initial Disposal Area
During the first eighteen months of operation the sand tailings will
be impounded in an area remotely located from the mine pit. The sand
will occupy approximately 140 acres to a height about 70 feet above
existing ground elevation. This sand tailings area shall be capped
with overburden material to sustain plant growth. After the area is
capped it will be graded, mulched, and seeded.

7 of 8
Mined Area Reclamation
The first phase of reclamation of the mined out pit area is the
introduction of backfill into the mined out pit with bucketwheel
excavator and spreader. In order to provide storage for clay and
sand tailings, embankments must be constructed within the mined
out pit as part of the continuous mining operations. These
embankments will be formed by selective placement of spoil by
the spreader and draglines. Heavy earth moving equipment, such
as dozers and scrapers, will be required to finish final grading
of these embankments. Decant towers also will be installed for
each storage area isolated by the embankments prior to the intro-
duction of sand and clay tailings.
During the second phase of reclamation, which also is an integral
part of the mining process, clay and sand tailings are introduced
into the areas isolated by the embankments in the mined out pits.
After the isolated areas have been filled with sand and clay tailings
and they have settled to planned elevation, the concluding reclamation
process is implemented. Surface water will be decanted, the embankment
freeboard will be dozed onto the clay and sand tailings fill, final
drainage will be created, and a suitable cover crop will be established.
This final reclamation phase will be accomplished within two years after
the filling with clay and sand tailings has been completed.
The final site grading drainage objective shall be to restore the
watershed area of any disturbed waterways to function similar to pre -
mining conditions.
E. Long Range Land Use
After the disturbed areas have been reclaimed as described, the land
will be retired from mine use and placed under control of the North
Carolina Phosphate Corporation Land Management Group for development
into the final long range land use.
F. All re-channelization of existing channels, streams and all new channels
shall be designed, constructed and maintained stable to prevent offsite
sediment damage, and to comply with all rules and regulations of the
Office of Coastal Management.
G. Collection of noxious, odious or foul water shall be prevented by
periphery drainage ditches during mining to control and direct all
surface drainage so as to prohibit unnecessary impoundment of waters.
After reclamation, all mined land shall be contoured to provide
appropriate natural drainage. The final unfilled area in the mining
pit shall be prepared as an ecologically sound lake.

8of8
3. Revegetation Plan
After regrading to a stable and drained condition, the mined area and
tailings ponds will be revegetated with suitable flora. Selection of
these flora will be based upon revegetation test programs conducted in
consultation with local specialists during the initial years of mining.
The selected flora are expected to return the mined area to ecologically
productive acreage.
4. Reclamation Schedule
The general reclamation schedule shall be as outlined in reclamation
condition 2A-2D.
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.
Final reclamation, including revegetation, shall be completed within two
years of completion or termination of mining or backfilling.
In the event that mining activities were to be prematurely terminated at
the N.C. Phosphate Corporation Mine so that the reclamation plan cannot
be fully implemented, the entire area that had been mined but not reclaimed
would become a lake with the water level at natural ground water level,
estimated to be approximately seven feet above sea level. In that event
N.C. Phosphate Corporation would grade to a maximum 2-�:1 slope, fertilize
and revegetate the lake shore, prevent erosion and to make it esthetically
pleasing.
Permit issued this the G --L"7 day of �qA;p , 19 B Z. .
B Y .
Stephen G. Conrad, Director
Division of Land Resources
By Authority of the Secretary
Of the Department of Natural Resources and Community Development.

August 7. 1985
Mr. Rusty Walker
NCPC 1
P.O. Box 398
Aurora, North Carolina 27806
Dear Dusty:
Thanks for the article on mined land reclamation in Florida.
It was very interesting and I appreciate your sharing it with me.
A quick glance at the figures shows that Agrico is by far the
leader in reclamation in Florida.
Hope everything is going Well for you and NCPC. Will look
forward to visit that way in the near future.
Best Regards, '
Stephen G. Conrad
SGC/ps
cc: Charles Gardner '�

C,ol -

NCPC(D
AN AGRICO MINING COMPANY
Mr. Steve Conrad
Resource Planning and Evaluation
North Carolina Department of Natural
Resources and Community Development
P. 0. Box 27687
Raleigh, North Carolina 27611
Dear Steve:
July 30, 1985
I enclose an article on reclamation in Florida which was not
only interesting but at the end of the article, Agrico is recognized as
one of the enviornmentally responsible leaders. I know you are aware of
this, but it made me feel good to see it acknowledged.
RW:gm
Enclosure
cc: R. G. Garcia
J. L. Wester
R. P. Ayres
Sincerely,
10
Rusty ker
jttttjq T'Q
b '85
NORTH CAROLINA PHOSPHATE CORPORATION
P. 0. Box 398 - Highway 306 N. - Aurora, North Carolina 27806 - 919/322-5151

Sunday, June 30, 1985
Bu iness 111-ic Lcd�;�l-
Dorfman, 2D/hvestirp. 4D/Markets, bD/Classilletl
Reclamation: The first 10 years
Industry off i c i als,
environmentalist still
w i,thhold judgment
By Ronnie Blair
The Ledger
Un July 1, 1975, it became official. No longer would
Florida put up with scarred lands created by phosphate
mining. The countryside would have to be restored, and
phosphate companies would be held responsible.
But 10 years after phosphate mine reclamation be-
came mandatory, some industry officials and environ-
mentalists still withhold judgment on just how effective
the law has been.
Perhaps there's good reason for that. The mandatory
reclamation program spent anything but a stable first
decade.
Industry representatives, environmentalists and the
state regularly proposed revisions. Communications
were often poor between state and local agencies that
have to approve mining permits. A rule change in 1980
caused a two-year hiatus in which no new reclamation
plans were approved.
In fact, the first 10 years in which the mandatory recla-
mation program sputtered its way into existence could
have spawned a whole passel of industry and environ-
mental versions of Spiro Agnew's famed nattering na-
bobs of negativism. Instead, some reclamation watchers
remain optimistic that the program steadily is progress-
ing from infant to toddler, and may yet reach maturity.
"I think we're making some progress each year," said
Charles Lee. vice president of conservation for the Flori-
da Audubon Society.
"I think just the fact that there is mandatory reclama-
tion should satisfy the regulators that all the land will be
reclaimed. It's just a must," said Don Morrow, general
manager of Florida mining operations for Agrico Chemi-
cal Co.
In 1975. the Florida Legislature voted to require recla-
mation of all lands mined after July 1, 1975. It's up to the
companies to pay for that reclamation, although they can
receive refunds from the state severance tax fund if they
reclaim land mined before 1975.
Reclamation can be costly. Don Morrow estimates
-lgric•o spends $4,043 to reclaim one acre of mined land
using conventional methods.
In the 10 years since mandatory reclamation took ef-
fect. phosphate companies in Florida have mined 57,944
acres, according to the state Bureau of Mine Reclama-
tion. The companies have reclaimed 14,532 acres.
But those raw figures don't reflect the trouble phos-
phatks vionipanies say they sometimes encounter. One of
Hit- chief complaints is that county governments and the
state give mixed signals because they often have differ-
ent objectives.
-3'he miner can do one or the other, but he can't satisfy
botli.' said R.F. "Whitey" Schulz, manufacturing manag-
er for Mobil Chemical Co.'s phosphorus division. "So you
end up going back and forth. It's a pretty nice merry 4-
round.
When a company decides to mine an area, it imm i
ately has to take reclamation into account. So do regui ;
tort' authorities. The first officials who have to approve
reclamation plans are the county and the regional plan-
ning council. Then the state Department of Natural Re-
sources has to approve the plan. Eventually, even the
Environmental Protection Agency will take part.
The problem created for the industry is that the local
authorities approve reclamation plans before the state
A Gemco unit, floating on 5-Toot tires, plows under drying clay to unearth wet clay Cawnr Knight rnr Meager
in a reclamation project near Agrico's Fort Green mine.
'Polk County is getting more
sophisticated in its review of
reclamation permits. Likewise,
see the same thing in Hardee
County. They get very involved in
your operations.'
gets involved in the process. Then if the state disagrees,
the company has to go back to the county and regional
planning council.
Charles Lee of the Audubon Society agrees something
needs to be dome to alleviate the Catch 22 situation in
which some companies fin,!. themselves trapped.
"There has been a lac',. of communication." he said.
"The reason for Uial. is there is nothing in the law thnt
fosters communication. Right now it is a catch -as -catch -
can system."
Schulz said he's beginning to see indications the process
may be improved. When Mobil was wading through the
paperwork for its South Fort Meade mine and encoun-
tered those problems, representatives from Polk County
and the Central Flohida Regional Planning Council came
to the company's deferige and-tmweiedta Tallahassee.
"During a meeting with the governor and the Cabinet it
came up that all the parties should have been involved
early on," Schulz said. "So this was the beginning of say-
ing. 'if we're going to have a thing Iike this, then all the
agencies should get involved when the local and regional
See 10 years on page 2D
Mandatory reclamation
In Florida
The state requires that Florida phosphate
companies reclaim all lands they have mined
since July 1, 1975. This chart shows, by com-
pany, how much acreage falls under the pro-
gram, and the number of acres that have been
reclaimed as of June 1, 1985,
Total acres Acres
Company under program reclaimed
'Aprico 22,548 5,305
Amax 2.757 223
Borden • 854 795
Beker 9,812 0
Brewster 11,424 1.627
CF Mining 1.176 23
C.M.Ooin .;*42 0
Fstech 5,753 832
Gardinier 50341 287
Hopewell 605 N/A
Mobil 9,633 473
T/A Minerals 27 2-
USS Agri -Chem 3,791 31
W.R. Grace 6,067 1.472
Tolai 110,119 14,5U
Source: Florida Bureau of Mine Reclamation
Karen Ca - pbeu Tnc Levgr�-

90 years of
reclamation:
Industry officials,
environmentalist still
withhold judgment
Continued from 1D
planning councils make a decision.' "
,Iurcwy Craft• chief of the Florida Bureau of Mine
Hcclansatinn, a division of the Department of !Natural
Itc;nurccs. uas on vacation last week and could not be
rvoc ht,d for comment.
lint in an interview earlier this year he said he feels
co,-peration among the companies, counties and the state
has improved.
Nlo row and Schulz both said they favor giving the
c„untw's views priority when there's a clash between
.t:,tc and local wishes dealing with reclamation.
1 h in like land reclamation involve the use of the
%furrow• said "1 fcrl that is more of a county -level
hlrm rather than a state- level problem. I think the
, outlty should have the final sap "
Polk County wants half agricultural and the other
h:,li for development," Schulz said. "To me that's much
i;,. a c srn.ible land use. In the long run, you've got to took
.,t it tram the point of view of the county's income from
act valorem taxes. The county is going to get more money
from residential development than it is from agricultural
Lind
1 don't think it should be all of one or the gther. I think
it should be b !"c, ed. Rut Fni 100 percent be;trnd what o
county and a regional planning council want, as opposed
to the state dictating that to them."
Lee takes a different point of view. He fears giving the
counties too much say would result in a multitude of
trailer parks and other types of development.
"The (reclamation) program would come close to being
a boondoggle," he said. "It might be better just to leave it
onreclaimed The county certainly has to have a role. But
that role has to be balanced with the state."
Lee said in his view the state regulatory agencies are
lkoiit1v?Sly understaffed. He expects a funding review in
MIXt year's legislature and a new focus on phosphate
rrcl.unation issues
St,,ffing is not a problem unique to phosphate recla-
ni,ition. ' he said. "It's true all through Florida state
government "
Lee s:itd the reclamation program has been a "mixed
ha g...
--lt s been somewhat effective in changing the configu-
ration of mined lands toward a more environmentally
desirable configuration, but the program is still one with
many. many problems," Lee said. "Industry resistance
has keen relatively high."
For its part, the industry argues that paperwork
slowed the early progress of the program, and that public
perceptions about reclamation might sometimes be
skt,wvd because reclamation takes a long time and begins
Lite in the mining process.
A 10-year-old mine, in all probability, would just have
inined acres and no reclamation," Schulz said. "A mine's
laic may be from year one to year 20. The major reclama-
tu,n might happen from year 12 to year SO."
Tho mandatory reclamation program also experienced
what might be termed a mid-life crisis. In 1980, the law
w.,s amended to require each operator to file a conceptu-
al pl.in for reclamation for the entire mine.
1nwrldrnents also required the operator to file applica-
tions for reclamation once a year, prior to mining, for all
inning the operator plans during the upcoming year.
Cowp:,nies also must file an annual report describing
.wh.it lands were mined in the previous year and the sta-
tu,� of reclamation.
Conceptual plans must be filed six months before min-
ing begins. They must detail in advance exactly what
kind of topography, drainage and vegetation the mine
will have once its been reclaimed.
It was 1982 before the first conceptual plans were
approved_
Two years went by in which no new reclamation pro-
gnitn�: .were received," Morrow said. "We had a two-year
Two Gemco units at work near the Fort Green Mine. -- y.
`Our experience has been there is
a wide variation of the quality and
sensitivity of the companies.
Some companies are virtually
outlaws as for as we're
concerned. Some would do
anything to get around the law.
Others are very conscientious.'
hiatus in which we couldn't do any new land
reclamation.
Almost every year there's an attempt to revise the
mandatory reclamation law. That means, Morrow said,
companies plan reclamation without knowing exactly
what might be required by the time their proposals are
being reviewed.
In addition, folk County, which once had a reputation
for being lenient with phosphate companies, is "getting to
be darned tough," Morrow said. Schulz said he doesn't
view Polk County so much as being lenient as being open
minded.
1 think they've been fair in the past," Morrow said.
"But they can get tough, too. Polk County is getting more
sophisticated in its review of reclamation permits- Like-
wise, I see the same thing in Hardee County. They get
very involved in your operations.
'"The people who are regulating are learning the min-
ing process and the reclamation process. I see that at the
county ]eve1. and at the state level there's some of that,
too.
"I think what's going to happen in the future, as every-
one becomes more knowledgeable, is there will be more
trust among the parties. When people don't understand,
it's hard to develop that trust."
The state, though, isn't always viewed as knowledge-
able about phosphate mining.
"You go to Tallahasse and some of the people you are
dealing with have never been here," Schulz said. "They
are doing all their stuff from an aerial photo. It's hard to
make a decision based on that."
Phosphate companies --- through the Florida Phos-
phate Council and through their own public relations pro-
grams — often try to convince the public that mining is
necessary and that reclamation is working. Some compa-
nies erect signs at their more prominent reclamation
sites. But there's no consensus on whether public opinion
has changed in the 10 years mandatory reclamation has
been in effect.
K'e spend a lot of time bringing people in and showing
them what we're doing," Morrow said. "We find they go
away feeling more comfortable about it than they were
when they arrived."
But he said fie doubts on a statewide level Floridians
know enough about phosphate's past to compare it to the
present and see the progress that has been made
Charles Lee said he's reluctant to speak about phos-
phate's reputation on an industrywide basis.
..Our ex erienc ion of
the qua i y and sensitivity a said.
Some coin antes are virtual outlaws as far as we're
concerned.Some would do anVthin4 to get around the
la w.
"Others are very conscientious Our experience -has
been we aye to ook at the industry on a com an '-by-
company as
He declined to name an exam le of an "outlaw" om
party, but he cited Agrico and International Minerals and
C e or . as two responsible com anies
"Thev have demonstrated to us they are concerne and
they try to discuss issues with the environmentalists."
Lee said. ' ose_ w o cout to us—TSey are
leaders."

j ',. '� K♦t I
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{ t �� 1 I t I f I � � �► � ' 41,ti ' � ��i���
'r Fifteen million years ago, during a time geologists call the Miocene
period, the Atlantic ocean began invading what is now Beaufort County on s
the Coastal Plain of Eastern North Carolina. It was not the first such in
vaslon nor the last, but It was special. .
` Those ancient Miocene waters over Beaufort were super rich in
phosphate. Upwelling from deeper ocean waters into a shallow coastal
embayment, the waters warmed rapidly and phosphate precipitated out
of solution. Life forms as varied as bacteria, worms, shellfish, sharks, and
primitive whales helped concentrate this vital life nutrient. v
North Carolina Phosphate Corporation has begun developing these
ancient deposits in Beaufort County and will ship its first product to
domestic and world fertilizer markets in late 1984 The Coastal Plain _
sediments which NCPC will remove in mining the phosphate ore will exposer;
a sweeping panorama of ancient life revealing other times when the
Atlantic covered Eastern North Carolina and times when carnets walked
f, there.
1 4r
�i .. .. NOR IH CAROLINA PH01,PHATE CORPORATION

Promise Into Reality -
A Challenge
North Carolina Phosphate Corporation (NCPC) Is a subsidiary of Agrico Chemical Company, one of
the Williams Companies. Agrico has been mining and marketing phosphate rock from Its Florida opera-
tions for almost a century. Today, Agrico's annual production capacity is 6.5 million metric tons from Its
Florida reserve base which places Agrico among the world's leading owners and producers of phosphate
rock. That position will be considerably strengthened when NCPC reaches Its planned annual capacity of
3.7 million tons (3.4 million metric tons) of calcined phosphate rock in 1985.
The tremendous phosphate resource in Eastern North Carolina has been a key to Agrico's future
since the early 1960's. NCPC owns 30,000 acres of these reserves in Beaufort and Pamlico Counties.
With new mining technology and a major breakthrough in ore processing, NCPC will turn promise
into reality.
Mining- The photo mural on the inside cover depicts NCPC's unique min-
ing method.
With reference to the numbers on the photo, two bucketwheel excavators
(1) will lead the operation removing about 50 feet (15 meters) of overburden.
The excavators have a combined capability of digging 18 million bank cubic
yards per year (14 million cubic meters). The overburden will be transferred to
shiftable conveyors (2) by mobile transfer conveyors (3) and carried to a spreader (4). The spreader
will deposit the material on the spoil dumps (5) created by draglines working on the bench created
by the bucketwheels.
Two draglines (6) with 68 cubic yard and 50 cubic yard buckets (52 and 38 cubic meters) will
operate on a bench elevation of 60 feet (18 meters) above the top of the ore. The overburden
removed by these draglines is cast into the mined -out area. The ore is then excavated and cast in a
windrow (7) on the dragline bench.
The ore windrow will be reclaimed by two bucketwheel excavators (8) feeding two mobile
transfer conveyors discharging the ore into two self-propelled portable sumps (9). The ore will be
slurried in the sumps and pumped to the beneficiation or processing plant.
Depressurization of the Castle Hayne aquifer, the top of which is approximately 15 feet (4.6
meters) below the bottom of the mining pit, will be necessary to prevent artesian water from
upwelling into the active mining pit. This will be accomplished by pumping from a series of deep
wells (10) located around the periphery of the open mine pit. Part of the water pumped from these
deep wells will be used to slurry the ore and the balance will flow in ditches to the plant for use In
the beneficiation process.
The pit is 4,000 feet (1220 meters) wide and the distance from outer bucketwheel to stacker will
average 2,300 feet (700 meters). Approximately 180 acres (73 hectares) of earth will be removed to a
depth of 150 feet (46 meters) by NCPC's unique system each year.
X7-,
BeneficiationAt the plant, NCPC will separate phosphate from
associated sands and clays, sharks teeth and shells, in the traditional manner.
Mechanical separation comes first. The ore is washed over a series of vibrating
' screens. Cyclones next use centrifugal force to separate the particles. Chemical
reagents are then called on to further refine the ore by removing even more of
the sands in flotation. The last step is calcination and there NCPC is again unique.
Calcination - A Major Breakthrough -The last
step in processing is calcination for the removal of organic carbon, inorganic
carbonates, and water. NCPC/Agrico has developed a new calcining technique
which utilizes coal in a confidential process to make phosphate rock from North
Carolina competitive on the domestic and world markets for the first time. It's
an achievement in which NCPC and Agrico take pride.
Arr Work 6v Whiting Toler

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01

Norfolk
Located five miles north of
Aurora, N.C. On south Creek
NCPC's new plant site and W =----- ~- -
i mine will be constructed
with an initial investment of $371.5 million.
It will employ 500
skilled people In
..
the first phase of
production. More
s
than 30 months will
be required to complete =� `
the construction now :-.
underway.Raleigh
r
Aurora
N G P C rCj
w
a r-
Morehead Port
-. --�..•r�.--s='...� '-.._�.► -.ate.+��
= , -
Wilmington
MIM
• II • - s • - s •
i�

IMPACT REPORT ON
DECLASSIFICATION OF PORTIONS OF
BROWN RUN AND CRAWFORD MILL RUN
Prepared on
4 September 1975
for
NORTH CAROLINA PHOSPHATE CORPORATION
Washington, North Carolina
0
WOO DWAR D-CLYDE CONSULTANTS
CONSULTING ENGINEERS, GEOLOGISTS AND ENVIRONMENTAL SCIENTISTS

1
n
17
H
[I

TABLE OF CONTENTS
SUMMARY
SECTION 1
PROJECT DESCRIPTION
1.1
INTRODUCTION
1.2
PURPOSE
1.3
REFERENCES
SECTION 2
JUSTIFICATION
2.1
CLAY REMOVAL AND TREATMENT REQUIREMENTS
2.2
SITE SELECTION
2.3
REFERENCES
SECTION 3
DRAINAGE
BASIN CHARACTERISTICS
3.1
INTRODUCTION
3.2
LAND AND WATER USES
3.3
SOILS
3.4
AQUATIC ECOLOGY
3.5
TERRESTRIAL ECOLOGY
3.6
HYDROLOGY
3.7
SURFACE WATER QUALITY
3.8
GROUNDWATER
3.9
REFERENCES
SECTION 4
ENVIRONMENTAL
IMPACTS OF DECLASSIFICATION
4.1
INTRODUCTION
4.2
LAND AND WATER USES
4.3
SOCIOECONOMICS
4.4
SOILS
4.5
HYDROLOGY
4.6
SURFACE WATER QUALITY
4.7
GROUNDWATER
4.8
AQUATIC ECOLOGY
4.9
TERRESTRIAL ECOLOGY
4.10
PREVENTIVE AND MITIGATING MEASURES
4.11
REFERENCES
Page
v
2-1
2-5
2--14
3-1
3-1
3-2
3-2
3-5
3-7
3-8
3-9
3-10
4--1
4-1
4-2
4-4
4-4
4-5
4-6
4-7
4-8
4-11
4-12
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LIST OF TABLES
Number Title
SECTION 2
2.2-1 Geohydrologic Factors Relevant to Alternate Clay
Pond Sites
3.4-1
Benthic Invertebrate Taxa Identified from Brown Run
in April, 1975
3.4-2
Total Number, Weight (Grams), and Respective Percent
Composition of the Predominant Benthic Invertebrate
Taxa Collected in Brown Run in April, 1975
3.4-3
Species, Total Number, and Percent Composition of
Nekton Collected from Brown Run and Crawford Mill
Run in April and July, 1975
3.5-1
Floral Taxa Observed in a 5-Year-Old Loblolly Pine
Plantation Occurring in the Vicinity of the Proposed
NCPC Clay Pond
3.5-2
Floral Taxa Observed in an 8-Year-Old Loblolly Pine
Plantation Occurring in the Vicinity of the Proposed
NCPC Clay Pond
3.5-3
Floral Taxa Observed in a 13-Year-Old Shortleaf Pine
Plantation Occurring in the Vicinity of the Proposed
NCPC Clay Pond
3.5-4
Floral Taxa Observed in a Hardwood Stream Bottom in
the Vicinity of the Proposed NCPC Clay Pond
3.5-5
Floral Taxa Observed in a Cypress Swamp Along the
Open Waters of Crawford Mill Run
3.5-6
Bird Taxa Observed in Various Habitats Occurring in
the Vicinity of the Proposed NCPC Clay Pond
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Number Title
3.7-1 Water Quality Standards Applicable to the Current
Classifications of Brown Run and Crawford Mill Run
3.7-2 Water Quality Data Collected from Brown Run and
Crawford Mill Run on 20 August 1975
LIST OF FIGURES
Number Title
SECTION 1
1.1-1 North Carolina Phosphate Corporation Facilities
Location Plan
1.2-1 North Carolina Phosphate Corporation Locations of
Requested Declassification Points Within the Brown
Run and Crawford Mill Run Drainage Basins
1.2-2 North Carolina Phosphate Corporation Pictorial
Presentation of Beneficiation Process
2.1-1 North Carolina Phosphate Corporation Typical Dike
Crossing - Brown Run and Crawford Mill Run
2.2-1 North Carolina Phosphate Corporation Locations of
Alternate Plant and Clay Pond Sites
SECTION 3
3.2-1 Land Uses in the Vicinity of the NCPC Clay Pond
3.7-1 Crawford Mill Run Looking Upstream from the Requested
Point of Declassification
3.7-2 Brown Run Looking Upstream from the Requested Point
of Declassification
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Number Title
3.7-3 Unnamed Tributary to Brown Run Looking Upstream from
the Requested Point of Declassification
3.7-4 Secondary Tributary to Brown Run Looking Upstream
from the Requested Point of Declassification
3.7-5 Secondary Tributary to Brown Run Looking Downstream
from the Requested Point of Declassification
3.7-6 Woodward -Clyde Consultants' Biologist Obtaining
Water Quality Data in Crawford Mill Run
3.7-7 North Carolina Phosphate Corporation Water Quality
Sample Points 20 August 1975
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SUMMARY
North Carolina Phosphate Corporation (NCPC) plans to
develop a phosphate mine and processing facility near the town
of Aurora in Beaufort County, North Carolina. An important
part of this facility will be a 1200-acre clay settling pond
to be located northwest of Durham Creek in the Brown Run and
Crawford Mill Run drainage basins. The construction and opera-
tion of this pond will necessitate the filling of portions of
both Brown Run and Crawford Mill Run, and result in an alter-
ation of freshwater flows from their basin areas into Durham
Creek. Therefore, NCPC is requesting the revocation of
classifications currently assigned to portions of these streams.
An analysis of the impacts resulting from the requested
declassifications indicates that there are socioeconomic
positive impacts associated with the project (e.g., increased
employment and income levels and encouragement of long-term
economic growth); and, there are various unavoidable negative
impacts on other aspects of the environment; see Table 1 for
summary of factors and data concerning the existing streams
and effects of requested revocation. However, NCPC has taken
a considerable effort in the design phase to avoid and mitigate
these negative impacts.
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TABLE I
SUMMARY
OF FACTORS
AFFECTING REVOKING STREAM
CLASSIFICATION
I. STRZAM llVDROUX'-IC CIIARACTERISTICS
CRAWFOkb MILL RUN
RAfW Ri1N
Existing Stream
Area Affected by Clay Pond
Existing Stream
Area Affected by Clay Pond
alto
520 ft. width at mouth
5 ft. width at clay pond dike,
640 ft. width at mouth
9 ft, width maximum at Clay
5 ft. width at pt. i500
total length upstream of clay
5 ft. width at pt. 3000
pond dikes, total length
ft, upstream from mouth
pond - i"n ft,
ft, upetroam from mouth
upstream of clay pond -
total length - lo,non fr,
total length 12,000 ft.
5000 ft.
Depth
5 ft. at. mouths <3 it. -
<3 ft. at clay pond dike
5 ft. at montbi 'l ft,
<2 ft, at clay pond dikes
150 ft. upstream from
300C ft. upntrtam from
mouth
mouth
Surface Are.
4 acre,
0.3 acres
13 Cr..a
0.3 acres
Weber Vnlume
L6 acre - feet
0.) acre - foul:
41 acre - feet
0.6 ..is - fact
Average Rate of
3.6 ft.V0— to anuthoa.t
Reduction of 0.9 Pt.3/eec.
1.7 ft. 3fso, to south-
Reduction of 1.3 ft."...
Flow and
..at
Diracticn
Stream Gradient
5/1.000
5/1,100
2/1000
VIGGO
Temperature
Wr to IWF
406F is B56F
40°F to 85'F
40r to WF
Classification
C - SC
Revoked
Sc
Revoked
I1. DIARACTER Or AREA BORDERING STREAMS IN AREA OF PROPOSED CLAY t'ONB
Area bordering Crawford Mill Run and Brown Run in the area of tile proposed clay pond can be characterix d as: Ras cneseurclal shortleaf
and lobiolly pine foreut, rang.ing in aye from 5 years to 13 years; 19% natural fnre.t, e.g., pine - mixed hardweode and swamp forests; and
16 fresh and low salinity tidal marsh. There to no regional or local dependency on waters of the subluct atrcam for the present major land
use and in fact the area is continually being drained.
111, WATER USE IN AREA OF PROPOSED CLAY PCNO
Because of the high salinity, waters in Crawford Mill Run mild 9-111 Run have not been and are not belnq used as a public water supply
or for domestic con.umlrc ion, nor is there any planned future was.
Because of the Sack of access and general characteristics of the.. strosms there has been no present planned bathing use of thane
Waters and none is Anticipated in the future.
stream areas to be dsclaasifimd peovid. habitat which support fish and wildlife populations. However, the affected portions of these
streams are not unique and in fact are only A small parcentagn of the total habitat available in the site region.
There ham been no present industrial consumption, tranaportatton, fire prevention, power generation, scientific, research, or eawage
disposal uses for the waters in the affected portions of the subject streams and none is anticipated.
1f rev ... tin. of classi Pi.r..ntion is granted, the affected area of the subject streams will be used as a pollution cnntrolLcd waste
impoundment area,
Iv, IMPAL'F OF LIEVOCATIIN OF CLASSIFICATION
Revecetion of the classification. assigned to affected pnrtione of Crawford Mill Rvn and Brown Run will result in A reduction of
commercial And natural forest acreage and the resulting wildlife habitat and hunting area these prnvlda. The filling cf portions of these
streams and the resultant reduction in freshwatur flow. will also reduce the fresh water habitat,, currently available for fish and wildlife
but will increase the more saline hahitata in the unaffected lower portions of the subject streams.
NCPC is purchasing a tract, on the order of five times that being romousd by the proposed clay pond, which in ideally located for apart
antl recreation 1 use. Tr is, and will continue to be, the policy of 11CPC to make this and as much of its land Itoldings in Eastern North
Carolina as [,a+oatble available for public use,
An analysis of the impacts of the project, of'which the Clay pond is an integral part, indicates that socin-economic benefits
le.g., lncreasad employment end income level. and anceuragement of long-term economic growth! art significant and will be gained at little
cost to the people of Eastern North Carolina.

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1 SECTION 1
PROJECT DESCRIPTION
1.1 INTRODUCTION
The Rennecott Copper Company and Agrico Chemical Company,
' owners of North Carolina Phosphate Corporation (NCPC), plan
to develop a $250 million phosphate mine and processing plant
' near the town of Aurora in Beaufort County, North Carolina.
An open dry pit mining method will be utilized to withdraw
phosphate matrix from a flat -lying phosphorite deposit for
processing and shipment to domestic and foreign markets. It
is presently anticipated that the project will require 30
' months for construction, to be followed by the first phase of
mining having a duration of approximately 15 years.
The 5000 acre mine and plant site complex (see Figure
1.1-1) is to be located in a traditionally agrarian and
commercial forestland area of low population density (there
' are no residents on the site area; approximately 45 people
live within one-half mile of the site). However, since world
War II the industrial sector has grown significantly in the
project region, including a nearby phosphate mine and processing
facility.
An important component of the NCPC facility will be a clay
settling pond which will be constructed in an area northwest of
Durham Creek (see Figure 1.1-1). This pond is required during
the first five years of operation, after which time the waste
clays will be returned to the mined area. Construction of this
pollution control facility will remove portions of the Crawford
Mill Run and Brown Run drainage basins, thus reducing the fresh-
water flows in these streams. NCPC is requesting that the classi-
fications of Brown Run and Crawford Mill Run be revoked in the
following portions of their drainage basins:
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Crawford Mill Run (A)l. From source to North Carolina
grid point X = 2638467, Y = 599071
Brown Run (B). From source to North Carolina grid point
X = 2639970, Y = 601018
Unnamed tributary to Brown Run (C). From source to North
Carolina grid point, X = 2641300, Y = 601412
Secondary tributary to Brown Run (D). From source to
North Carolina grid point, X = 2641697, Y = 601435
1.2 PURPOSE
This report has been prepared pursuant to General Statute
143-214.1 in conjunction with NCPC's application to the
Environmental Management Commission (EMC) for revocation of
the stream classifications presently assigned to portions of
the Brown Run and Crawford Mill Run drainage basins (Figure 1.2-1)
affected by the project. The requested revocation of classifi-
cation is required in order to construct the approximately
1200-acre settling pond for the purpose of storing the waste
clays removed from the ore during processing (Figure 1.2-2).
The data presented in the following chapters is based on
a more complete report of the environmental impacts resulting
from construction and operation of the proposed mining and
beneficiation facilities (NCPC, 1975), and partial results of
the aquatic and terrestrial field surveys conducted for NCPC
1 Letters correspond to points illustrated in Figure 1.2-1.
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by Woodward -Clyde Consultants (WCC). A more detailed dis-
cussion of the NCPC field surveys is presented by WCC (1975).
1 1.3 REFERENCES
' North Carolina Phosphate Corporation. 1975. Environmental
impact report for proposed mining and beneficiation
facilities, Aurora, North Carolina. Prepared by Woodward -
Clyde Consultants, Clifton, New Jersey for North Carolina
Phosphate Corporation, Washington, North Carolina.
'
U.S. Geological Survey. 1951.
7.5 minute series. U.S.
Bath, North Carolina quadrangle,
Geological Survey, Reston,
Virginia.
'
U.S. Geological Survey. 1953.
Blounts Bay, North Carolina quadrangle,
7.5 minute series. U.S.
Geolggical Survey, Reston, Virginia.
U.S. Geological Survey. 1974.
Bath, North Carolina orthophoto
'
quadrangle, 7.5 minute series.
U.S. Geological Survey,
Reston, Virginia.
Woodward -Clyde Consultants. 1975.
Results of aquatic and
terrestrial field surveys
conducted for North Carolina
Phosphate Corporation, Spring
1975.
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CHANNE
EXISTING RAILROAD SPUR
LEGEND
EXISTING ROADS
® CLAY POND DISCHARGE POINT
002 MINE DEPRESSURIZATION DISCHARGE POINT
[103 MILLPOND DISCHARGE POINT
MINING BLOCKS REPRESENT APPROXIMATIONS
IN TERMS OF YEARS. ACTUAL PROGRESSION IS
BASED ON PRODUCTION TONNAGE
L
SCALE
0 4000 8000 12000 FT
NORTH CAROLINA PHOSPHATE CORPORATION
FACILITIES LOCATION PLAN
FIGURE 1.1-1

m m = m = = m m = m m = m m = m m m m

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,ate,
O
_ _N
G 'Y
GE
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ic-
4t
a�
BROWN RUN DRAINAGE BASIN �
CRAWFORD MILL RUN DRAINAGE BASIN L
r► / ♦ ' C D
qi 0 RUN
4*`rr,#
--00 an y D�R�pM C
LEGEND
A_ DECLASSIFICATIONPOINTA'
SCALE
0 2000 4000 6000 FT
nm
SOURCE. U.S. GEOLOGICAL SURVEY; 1951, 1953, 1974
NORTH CAROLINA PHOSPHATE CORPORATION
LOCATIONS OF REQUESTED DECLASSIFICATION
POINTS WITHIN THE BROWN RUN AND
CRAWFORD MILL RUN DRAINAGE BASINS
FIGURE 1.2-1

m = = i = m m m m m= m= m= m

DRAGLINE
1! 1 f
OVERBURDEN
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RAIL TRANSPORT
BARGE TRANSPORT
WA. T ER Ft `` �.
w
Q
A.IATR
SLtJtC?' SLt
PIT
MASHER
& SCREENING
�.will, BUILDING
DAM
AQUIFER WATER
CALCINED PHOSPHATE ROCK
CALCINED
PHOSPHATE
ROCK
DRYSTORAGE
SAND TAILINGS
HYDRAULIC
STATION
FLOTATION PLANT
FEED STORAGE
TANKS
F LOTAT ION
PLANT
0
U
O
PHOSPHATIC cc
CLAYS
a
.-1
a
O
CLAY
THfCKNER PHOSPHATIC POND
CLARIF) ED
CZ
0 VE R F LOV7 CLAYS
WATE R
CLAY
z
THICKENER
PAMLICO
U
PHOSPHATE ROCK
RIVER
O
U
CALCINED
PHOSPHATE
ROCK
WET CONCENTRATE
STORAGE

m m = = = = = = m = = m = = m = = = m

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SECTION 2
JUSTIFICATION
2.1 CLAY REMOVAL AND TREATMENT REQUIREMENTS
The phosphate matrix contains fragments of rock, sea
shells, clays, silica sand, and pebbles of phosphate. Concen-
trating phosphate found in the matrix is achieved in three
operations: sizing and washing, froth flotation, and calcina-
tion (Figure 1.2-2). The sizing and washing process produces
minus 150-mesh(1) clays which must be removed from suspension
before discharging the process water to the Pamlico River.
Since these clays range down to colloidal sizes, they require
substantial settling periods. Current research into the
treatment of phosphate clays includes such additional processes
as filtration, freezing, drying, bacteriological dewatering,
ultrasonics, and centrifugation. However, settling ponds
currently offer the only practicable solution to the removal
of suspended phosphatic clays. Ponds can attain removal
efficiencies of 99 percent or higher. A discussion of the
various treatment methods follows.
Settling Ponds. Settling ponds represent the predominant
technique currently in use for removal of suspended solids in
wastewater. Solids settle by gravity to the bottom and the
w
clear supernatant is either recycled or discharged to a near-
by stream. Pond performance is a function of particle settling
characteristics, retention time, and design of the inlet and
outlet structures. Properly constructed ponds are capable of
(1) Numerical mesh designation indicates number of openings
per lineal inch of screen.
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reducing the suspended solids content of the decanted water to
less than 25 parts per million (ppm) (Environmental Protection
Agency, 1975). once previously mined -out areas provide
sufficient space, clays are returned to the mine (approximately
five years).
Thickeners. An alternative method of removing suspended
solids involves the use of thickeners, which incorporate
mechanical rakes or baffles to shear flow and thereby promote
clay dewatering. The use of thickeners eliminates the
possibility of wastewater seepage into groundwater resources
and also eliminates any stream sedimentation due to increased
erosion in the pond area. However, thickeners do not provide
sufficient retention time to enable the colloidal sized clays
to settle.
In addition, the other disadvantages of using thickeners
to treat the clay slurry are prohibitive capital cost, high
operation maintenance costs due to the large volumes of clay
slurry to be handled, and limited storage capacity.
in
Cyclones and Screens. Hydrocyclones are widely used
the phosphate industry to separate minus 150-mesh
phosphate
waste from plus 150-mesh fractions of the matrix.
However,
these units become ineffective for particle sizes
less than
25-50 microns and therefore cannot be used to produce a clear
effluent stream from the clay wastes. Studies of
Florida
phosphate clays have shown that over 70 percent of
the material
is finer than 1 micron in diameter (United States
Department
of the Interior, 1975).
Screens have similar limitations to those of
thickeners
and are not practical for wastewater treatment.
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Flocculation, or coagulation, involves the addition of
inert materials to the clays to increase particle attraction
and agglomeration. The additives alter the "zeta potential"
or ionic charges surrounding suspended particles to promote
formation of flocculated solids. This method of solids removal
is fairly common in the mineral processing industry and is capa-
ble of controlling suspended solids concentrations in the 10-20
milligrams/liter range. However, application of this treatment
technology to the phosphate clays problem is still the subject
of research programs (U.S. Department of the Interior, 1975).
Summary. Current research into the treatment of phosphate
clays includes such processes as filtration, freezing, drying►
bacteriological dewatering, ultrasonics, and centrifugation.
These techniques are in the development stage and most have
the disadvantages of high cost and/or high energy requirements.
Settling ponds currently offer the only practicable solution
to the problem of suspended solids removal from phosphate
clays. The major advantages are ease of construction, rela-
tively low cost, low maintenance, and the dual role of solids
removal and storage area for solid waste. The large land area
requirement is often reduced by utilizing mined -out areas for
new pond cells. Ponds that have been constructed properly can
attain removal efficiencies of 99 percent of higher (Environ-
mental Protection Agency, 1975).
The NCPC clay pond will be created by an earthen dike
approximately 6.5 miles in length. The proposed pond will
have a storage capacity of about 42 million cubic yards of
material. The dikes surrounding the impoundment will have a
maximum height of 28 feet. The dike typically will have a
crest width of 20 feet and an inside dike slope of approximately
2 1/2 (horizontal) to 1 (vertical) and an outside dike slope
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of approximately 3 (horizontal) to 1 (vertical) (see Figure
2.1--1). Prior to constructing the dikes, the base will be
cleared of any organics or soils of inferior construction
quality in order to ensure adequate support for the structure.
The dike materials will be obtained from borrow pits within
the impoundment area at a distance sufficiently removed from
the dikes so as not to interfere with stability.
Since the final design of the dikes are dependent upon
the foundation characteristics of the soils in the impoundment
area, the final cross -sections of the dikes will vary according
to the actual foundation characteristics. The final design of
the dike will be done by a geotechnic consulting firm registered
in the State of North Carolina and specializing in the design
of earthen retaining structures. The firm will certify to the
stability of the structure and prepare the necessary dam
safety permit applications for the North Carolina Department
of Natural and Economic Resources (DNER).
The clay slurry discharge pipe into the pond will be
directed down the inside slope of the dam to discharge at a
point sufficiently away from the sides of the dam so as to
prevent erosion. The maximum height of liquid within the
impoundment area will be approximately 23 feet, leaving five
feet of freeboard at all times. Three decant towers will be
located within the impoundment, separated so as to allow
channeling the clay slurry to all areas of the impoundment
and minimize the build-up of clear water. Each decant tower
will be of sufficient capacity to transport all the decanted
inflow from the plant. Consequently, there will be adequate
capacity in case of a blockage of one or two decant towers.
The impoundment will be operated so that,only approximately
1 foot of clear water will be above the thickened clays during
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normal operation. This method of controlling the deposition
of the clay slurry in the pond will permit a continual sealing
of the inside face of the earthen dike with a clay slurry and
will limit and amount of clear water in direct contact with
the sides of the dike, thus ensuring continued stability.
The crest and outer dike slopes will be seeded and mulched
to prevent erosion and minimize siltation in adjacent areas.
The clay pond spillway structures will be placed on large
concrete piers. The discharge pipe through the dike will be a
minimum of 8 gauge corrugated pipe of sufficient diameter to
permit unimpeded discharge of the decanted effluent. The pipe
joints will be welded and inspected prior to installation,
and anti -seepage rings will be placed around the pipe to pre-
vent seepage along the pipe.
A dike inspection program will be implemented and an
employee of NCPC will inspect the dike daily. This inspection
program will be coordinated with the requirements of the North
Carolina Dam Safety Statute.
During the approximate five-year life of the clay pond,
clarified water will be decanted and released to the Pamlico
River via an excavated channel (Figure 1.2-1).
2.2 SITE SELECTION
An analysis of the ecologic, socioeconomic, hydrologic,
and engineering characteristics of seven potential clay pond
sites was conducted to evaluate their relative desirabilities.
The evaluations were made on the basis of aerial and ground
reconnaissance of the various areas.
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Ecological considerations included: (1) the degree of
existing habitat alteration; (2) the value of the existing
habitat to wildlife; (3) the proximity to water bodies and
wetlands - including hardwood swamps; (4) the amount of dredg-
ing and/or filling required to construct the dikes and pipe-
lines required for the facility; and (5) the point source and
outfall zone locations associated with a pond at each location.
Socioeconomic considerations included: (1) the current
land use of the site,including ownership; (2) the proximity
to recreational and/or residential areas; and (3) the potential
for covering mineable deposits of phosphate.
The principal hydrologic concern regarding the location
of the clay disposal pond is the potential for seepage through
the bottom and sides of the pond into the underlying ground-
water environment. The basic criteria to be considered in
evaluating the desirability of a site based on the above
concern are: (1) the depth to the water table and its con-
figuration; (2) the permeability of the surface sediments;
(3) the proximity of shallow wells; (4) the head difference
between the water -table aquifer and the Castle Hayne Formation;
and (5) the vertical permeability and thickness of the aquitard
separating these aquifers.
Engineering considerations include: (1) existing topog-
raphy; (2) soil type; (3) groundwater level; and (4) construction
considerations. A discussion of the ecological, socioeconomic,
hydrologic and engineering aspects of each site considered is
presented below.
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Clay Pond Site Cl. Site Cl is located on the south shore
of the Pamlico River near Core Point (Figure 2.2-1). Although
the majority of the site area has been previously subjected
to habitat alteration through timber management, Cupler Slough,
a small tributary of the Pamlico River which would be eliminated
by the pond, supports a native cypress -mixed hardwood swamp
forest. The location of a pond on this site would permit the
discharge of overflow directly t❑ the Pamlico River, but it
is likely that filling of some Pamlico River shoreline would
be required during dike construction; dredging of Durham
Creek would also be required for pipeline construction.
The northeast site boundary is adjacent to the community
of Core Point, which contains summer homes and recreational
facilities. There are also several homes on the site and new
residences are being built. There is a significant amount of
farmland on the site, and the pine plantations which vegetate
the majority of the site are an economic natural resource.
This pond site is judged to have the lowest impact with respect
to covering potential phosphate resources.
Site Cl is characterized by a varying water table - 5
to 20 foot depth (Table 2.2-1). The eastern third of the site
has both a shallow and steep water table, and thus a relatively
high potential for vertical infiltration and consequent hori-
zontal seepage into the Pamlico River. This site has the
highest rates of horizontal seepage and vertical infiltration
(Table 2.2-1), but these disadvantages are partially offset by
the greater depth to the water table. There are no shallow
wells in the vicinity of the site.
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While the on -site soils appear suitable for dike con-
struction, the high topographic relief between the eastern
and western extremities of the site snakes this an economically
undesirable site for dike construction.
Clay Pond Site C2. Site C2 is located west of the Suffolk
Scarp in the headwaters of Nevil Creek (Figure 2.2-1). The
majority of the site has been subjected to habitat alteration
through timber management, except for portions of the Nevil
Creek stream channel which remain vegetated with swamp hard-
woods. The location of a pond at this site would require that
the overflow be drained through natural water courses (e.g.,
iNevil Creek) to the Pamlico River or piped to a point source
in the river. A pipeline would also be required to transport
the clays under Durham Creek.
No residences or active farmland presently occur on the
site. However, the pine plantations which vegetate the major-
ity of the site are an economic natural resource. This site
is judged to have a low impact with respect to covering
potential phosphate resources.
Site C2 is located on both a topographic and water table
divide. Although the site is drained by Nevil Creek, which
flows through it to the north, the subsurface seepage in the
water table aquifer is principally to the east into the Durham
Creek drainage basin and to the west into the Blounts Creek
basin. The inferred water table is fairly deep; however, the
area is apparently drained by surface ditches for timber
production, which indicates that the water table may be shallower
than given in Table 2.2-1. The rates of horizontal seepage and
vertical leakage are about the same at Site C2 as at Site Cl.
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However, the more consistent depth to the water table at Site
C2 makes it preferable to Site Cl. There are no shallow wells
in the vicinity of the site.
The topographic relief and onsite soils present on this
site are economically acceptable for dike construction.
Clair Pond Site C3. Site C3 is located at the mouth of
South Creek, adjacent to Muddy Creek and Davis Creek (Figure
2.2--1). The majority of the site area has been subjected to
habitat alteration through timber management. While the dis-
charge of overflow could be made directly from a pond on this
site to the Pamlico River, it is probable that coastal wetlands
would be altered during dike construction activities. In
addition, dredging would be required in portions of Muddy and
Bond Creeks during pipeline construction.
A seasonal community with several boat docks is located
near the northeastern boundary of the site, and the community
of Spring Creek lies to the southeast. Patches of active
farmland are located near the southern boundary of the site,
and the pine plantations which vegetate the majority of the
site are an economic natural resource. This site is judged to
have a very high impact with respect to covering potential
phosphate resources.
Site C3 is characterized by a shallow but flat water
table and very low leakage to the Castle Hayne (Table 2.2-1).
Thus, any seepage out of the pond would tend to remain quite
localized. There are no major shallow wells in the vicinity
of the site.
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While the topography of the site is suitable for dike
construction, the presence of swampy areas would make con-
struction difficult because of the high perched water table
and presence of organic soils.
Clad Pond Site C4. Site C4 is located in the headwaters
of Muddy Creek and Campbell Creek (Figure 2.2-1). Although a
large portion of the site area has been subjected to habitat
alteration through timber management, a portion of the Muddy
Creek drainage which would be eliminated by the pond is a hard-
wood swamp. In addition, the site is bordered on the north
(Muddy Creek) and south (Campbell Creek) by coastal wetlands.
The location of a pond at this site would require that the
overflow be drained through natural water courses to the Pamlico
River or piped to a point source in the river. A pipeline
would also be required to transport the clays under South,
Bond, and Muddy Creeks.
While no residences occur on the site, the pine plantations
which vegetate a portion of the site and the farmland present
are of economic value. This site is judged to have a high
impact with respect to covering potential phosphate resources.
Site C4 has a shallow water table, and low leakage to the
Castle Hayne. Horizontal seepage through the water table
aquifer should be very low, but some of the seepage would be
toward a shallow well near Bond Creek.
While the topography of the site is suitable for dike
construction, the presence of swampy areas would make construc-
tion difficult because of the high perched water table and
-presence of organic soils.
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Clay Pond Site C5. Site C5 is located in the northern
extremity of Gum Swamp (Figure 2.2-1). Although the site is
bordered on three sides by areas subjected to habitat altera-
tion through timber management and farming, the majority of
the site area is vegetated with swamp forest - a valuable
and diminishing wildlife habitat and source of nutrients for
the nearby estuarine waters. The location of a pond at this
site would require that the overflow be drained through natural
water courses to the Pamlico River or piped to a point source
in the river. A pipeline would also be required to transport
the clays under South Creek. Although no residences or farm-
lands occur on the site, the area is utilized by local hunting
clubs. This site is judged to have a low impact with respect
to covering potential phosphate resources.
Site C5 has a shallow, flat water table and low rate of
vertical leakage (Table 2.2-1). The inferred water table depth
is slightly greater here (four to six feet) than at Sites C3
and C4, but there is standing water on the floor of the swamp.
This may be perched on the thin layer of organic materials
covering the swamp floor,but it could also indicate that the
depth to the water table is somewhat less than that given in
Table 2.2-1. Seepage through the water table aquifer should be
low but some of it would migrate toward two shallow wells
which lie midway between Site C4 and C5.
Based on the results of field and laboratory investigations,
the subsoil at Site C5 can be described as an upper 2 feet to
3 feet layer of soft organic silt (muck) underlain by a 2 feet
to 4 feet layer of firm silty clay. The clay is underlain by
layers of silty sand and sandy clay. During field investigations
the swamp was inundated with 6 inches to 12 inches of perched
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water at el 141. The natural groundwater is believed to be
located at approximately el 4 to el 5 USGS Datum. While the
existing subsoils are suitable for dike construction, the
problems associated with dewatering the area and removing the
organic materials would make construction difficult on this
site.
Clay Pond Site C6. Site C6 is located in Gum Swamp along
the abandoned Atlantic Coast Line railroad bed (Figure 2.2-1).
Except for the thin border along the railroad bed itself, the
site area is a hardwood swamp forest. The location of a pond
at this site would require that the overflow be drained through
natural water courses to the Pamlico River or piped to a point
source in the river. A pipeline would also be required to
transport the clays under South Creek.
II Like Site C5, the site has no residences or farmlands on
it, but is it utilized by local hunting clubs. This site is
judged to have a high impact with respect to covering potential
Phosphate resources.
' Site C6 has about the same hydrologic environment as Site
C5, except that there are no shallow wells in its vicinity.
Tn addition, the same perched water table and soil character-
istics which would create dike construction difficulties
' at Site C5 occur at Site C6.
Clay y Y Pon pond
Two alternatives for this location
of the clay on e considered: Site C7 and C7-1. Both are
located west of Durham Creek in the headwaters of Brown Run
and Crawford Mill Run (Figure 2.2-1). However, Site C7-1 is a
1 (1) USGS Datum.
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revision of Site C7 which minimizes impact on Brown Run and
Crawford Mill Run. Although the majority of the site area
has been subjected to habitat alteration through timber
management, coastal wetlands do occur at the mouths of Crawford
Mill Run and Brown Run and it is probable that these would be
altered, though not directly affected during construction.
overflow from a pond at this location mould be drained through
an excavated channel directly to the Pamlico River. A pipe-
line would be required to transport the clays from the plant
sites under Durham Creek to the pond.
Although no residences or farmlands occur on the site,
the pine plantation which vegetates the area is of economic
value. This site is judged to have a low impact with respect
to covering potential phosphate resources.
The depth to the inferred water table at this location
varies from 5 feet along the western edge of the site to zero
where it intercepts Crawford Mall Run and Brown Run (Table
2.2-1). This shallowness suggests that clay pond effluent
could infiltrate to the water table fairly rapidly during the
early stages of operation. Any effluent which does reach
the water table would then travel under the influence of the
local hydraulic gradients toward Durham Creek.
The topographic relief and on -site soils present make
this location one of the most economically acceptable with
respect to dike construction.
SUMMARY
An analysis of the environmental impacts resulting from clay
pond construction on the various sites shown in Figure 2.2-1
indicates that the greatest potential for negative impacts would
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be at sites Cl, C3, C5 and C6. In addition, prohibitive costs
'
involved with operation of a clay pond at site C2 made this site
unfavorable. For these reasons, sites C4 and C7 - C7-1 were
'
selected as the candidate sites. The selection of the site
from these two areas was based on: (1) envirionmental and
engineering input from state agencies, including field trips
with state personnel; (2) anticipated difficulties in applying
for surface water discharge permits because of existing stream
classification in the receiving waters; and (3) property
'
acquisition with clay pond sites C7 and C7-1 remaining. C7-1
was selected as the proposed site because of the distinct
environmental advantage of minimizing the resulting impacts on
Brown Run and Crawford Mill Run. As can be seen in Figure 2.2-1,
site C7-1 occupies significantly less of the lower portions of
their drainage basins -- especially those areas which have
standing water year-round and are vegetated with low tidal and
fresh water marsh.
2.3 REFERENCES
United States Department of the Interior. 1975. The Florida
phosphate slimes problem. Bureau of Mines Information
Circular 8668. Tuscaloosa, Alabama. 41 pp.
'
United States Environmental Protection Agency. 1975. Develop-
ment document for effluent limitations guidelines and
standards of performance, mineral mining and processing
industry. Volume IT.
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TABLE 2.2-1
GEOHYDROLOGIC FACTORS RELEVANT TO ALTERNATE CLAY POND SITES
Maximum
Depth to Water Horizontal Seepagel
Site Table (feet) (feet/year)
Cl
5-20
1.57
C2
5--10
1.40
C 3
2--3
0.04
C4
2-4
0.04
C5
4-6
0.02
C6
4-6
0.02
C7
0-5
0.90
C7-1
n-s
n.9B
Vertical Leakage to
the Castle Hayne2
(Gallons Per Day/Acre)
174
163
4
3
4
3
33
1Horizontal permeability for all sites was taken as 2 x 10-4 cm/sec.
2Vertical permeabilities, aquitard thickness, and head differences were
determined for each site.
Source; North Carolina Department of Water and Air Resources. 1971.
Report on hydrogeology and effects of pumping from Castle Hayne
Aquifer system, Beaufort County, North Carolina.

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NORTH CAROLINA PHOSPHATE CORPORATION
TYPICAL DIKE SECTION CROSSING
BROWN RUN AND CRAWFORD MILL RUN
FIGURE 2.1-1

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SECTION 3
DRAINAGE BASIN CHARACTERISTICS
3.1 INTRODUCTION
The purpose of this chapter is to provide data concerning
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the factors listed in General Statute 143--214.1, subsections
(d)(1), (d)(2), and,(d)(3), which must be considered by the EMC
before revocation of the classifications presently assigned to
Brown Run and Crawford Mill Run. Additional data concerning
the environmental setting within the region of the site is
presented by NCPC (1975).
1 3.2 LAND AND WATER USES
The majority of the Brown Run and Crawford Mill Run
drainage basins to be affected by construction of the clay pond
(80 percent) is devoted to commercial forestlands (Figure 3.2-1).
Loblolly pine (:sinus taeda) and shortleaf pine (Pinus echinata)
are the major species planted. Ages of existing stands range
from 5 to 13 years. Natural forestlands comprise an additional
20 percent of the site. Fresh water marshlands are found on
less than 1 percent of the site. Because the site is entirely
forested and uninhabited, its best use, other than commercial
forestry, is for wildlife habitat and hunting.
The waters of Brown Run and Crawford Mill Run are presently
classified, pursuant to General Statute 143-214.1, to be
suitable for the following water uses:
Brown Run (from source to Durham Creek) and Crawford
Mill Run (from a point 0.5 miles above mouth to
Durham. Creek) -- Fishing, and any other usage except
bathing or shellfishing for market purposes (SC).
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Crawford Mill Run (from source to a point 0.5 miles
above mouth) --- Fishing, boating, wading and any
other usage except for bathing or a source of water
supply for drinking, culinary or food processing
purposes (C).
The standards auplicable to each of these classifications
are presented in Table 3.7-1.
Observations by WCC staff in the area of Brown Run and
Crawford Mill. Run during field surveys indicate that these
waters are utilized for sport fishing, especially in the
sections near Durham Creek where marshlands occur.
3.3 SOILS
Soils in the site locality are derived from unconsolidated
sands, silts, and clays which were deposited in marine and
terrestrial environments during glacial and interglacial times.
The source areas of the sediments from which the soils were
derived were the Piedmont Valley and Ridge, and Appalachian
Plateau physiographic provinces. The soil association occurring
over the majority of the clay pond site and the Brown Run and
Crawford Mill Run drainage basins is the Roanoke -Cape Fear -
Portsmouth association. This association typically consists
of clay, silt, and fine sand and is gray to black in color.
It is found in low areas in the coastal plains and is poorly
to very poorly drained. Subsoils range from friable sandy
clay loam to very firm clay.
3.4 AQUATIC ECOLOGY
Tributaries to the Pamlico River Estuary such as Brown
Run and Crawford Mill Run are the upstream extents of this
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estuarine system. While the midreaches of the Pamlico River
are considered mesohaline, 5 to 18 parts per thousand, these
tributaries are better termed oligohaline, 1 to 4 parts per
thousand, during most of the year.
Estuarine systems, such as the Pamlico River complex,
are noted for their high productivity and capacity to shelter
young of a number of commercially and recreationally important
fin- and shellfish. The high productivity of estuaries is
generally attributable to the high organic input, recirculating
influence of tides, and general shallowness of such areas.
Even though quite productive, these areas commonly have low
species diversity as a result of pronounced short-term (tidal)
and long-term (seasonal) fluctuations in the physical -chemical
makeup of these waters.
In order to better assess the biota of these waters,
biological samples were collected by WCC biologists from Brown
Run in late April -early May and July, 1975, and from Crawford
Mill Run in July, 1975. During these periods data was
collected on the macrozooplankton (specifically larval fish
and crustaceans of commercial value), benthos, and nekton
communities of the creeks in question. These data are presented
and discussed in this section.
Macrozooplankton. In late April, 1975, six 5-minute
plankton tows were taken in Brown Run using 1/2 meter nets
(505 micron). Although these tows, each of which sampled
approximately 90 cubic meters of water, captured a small number
of crustaceans and one juvenile fish (Menidia beryllina), no
larval fish or crustaceans of commercial value (crabs or
shrimp) were collected.
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Benthos. Table 3.4-1 presents the benthic invertebrate
taxa identified from Brown Run in April, 1975. Of the nine
benthic samples taken with a Ponar grab in Brown Run (three
each at the mouth, midreaches, and navigable headwaters),
the grand mean number and weight of organisms per square
meter were 3387 individuals and 9.16 grams, respectively.
Per sample area the mean number and weight (per square
meter) of benthic invertebrates were: mouth, 340 individuals
and 2.486 grams; midreaches, 6440 individuals and 13.482
grams; and headwaters, 3380 individuals and 11.512 grams.
The predominant organism groups encountered by weight and
numbers at all sample locations were amphipods (mainly
Gammarus spp.), polychaets (mainly Melinna sp.), and several
species of chironomids (larval dipterans). In the Brown Run
samples, amphipods comprised 63.1 percent by number of all
benthic organisms collected and were the biomass dominant as
well. Table 3.4-2 presents the predominant taxes and their
total abundance and weight and respective percent compositions
as found at each sample locale during the spring sample
period. None of the taxa collected from Brown Run or
Crawford Mill Run are of recreational or commercial importance.
Nekton. The nektonic fauna of Brown Run was intensively
sampled in late April -early May, 1975. In this period a
variety of gear types (active and passive) were utilized in
the various habitats found in Brown Run. In addition,
supplemental 50 foot bag seine hauls (found to be very
effective during spring sampling) were taken from Brown Run
and Crawford Mill Run in late July, 1975.
A list of taxa collected during each sample period and
at each locale is presented in Table 3.4-3. The bay anchovy
(Anchoa mitchilli) was the numerically dominant species
encountered during both spring (78.5 percent) and summer
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(58 percent in Brown Run and 71 percent in Crawford Mill Run)
by combined gear types and in near -shore habitats. In off-
shore habitats of Brown Run (sampled by otter trawl in spring
only) the species predominance was rather evenly distributed
among Atlantic croaker (Micro 0 on undulatus) - 180 specimens,
bay anchovy - 120 specimens, and spot (Leiostomus xanthurus) -
116 specimens. In most cases, biomass dominance was held by
the few large fish captured during each sample collection
(e.g., pumpkinseed-Ltp mis ib� bosus, largemouth bass-Micropterus
salmoides, and brown bullhead-Ictalurus nebulosus).
No crustaceans of commercial importance were collected
in the two streams sampled. However, of the 23 fish species
collected, 13 species were of potential commercial or sport
importance. During the spring sample period, a majority of
these species were young -of -the -year migrants (e.g., Atlantic
croaker and spot) which were utilizing these creeks as a nursery
grounds; while in the summer sample period, a majority of the
important species were young fish which were probably spawned
by the creeks year --round inhabitants (i.e., largemouth bass
and sunfish.
3.5 TERRESTRIAL ECOLOGY
The Brown Run and Crawford Mill Run drainage basins
encompass a variety of terrestrial habitats ranging from up-
land pine -mixed hardwood forest to low tidal marsh. Those
which will be directly affected are illustrated in Figure
3.2-1. A more detailed presentation of these and their
associated fauna follows.
Flora. As indicated in Section 3.2, the majority of the
Brown Run and Crawford Mill Run drainage basins is vegetated
with managed commercial pine forests, planted in either
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loblolly pine or shortleaf pine. Since the ages of these
plantings vary from 5 years to 13 years, the species present
with the pine varies greatly. The taxa observed by WCC biolo-
gists in 5-, 8-, and 13-year-old pine plantations, occurring
in the vicinity of the proposed clay pond, are presented in
Tables 3.5-1, 3.5-2, and 3.5-3, respectively.
The areas of the basins which are not vegetated with
pine plantations are, for the most part, wet areas and stream
bottoms which are not suitable for good pine growth. The
taxa observed by WCC biologists in such areas are given in
Table 3.5-4.
The wettest sites in the Brown Run and Crawford Mill Run
basins are those areas immediately adjacent to the open waters
of these streams. In the upper portions of the basins, such
areas as bald cypress (Taxodium distichum), occur as a dominant
species. A list of other species observed by WCC biologists
is given in Table 3.5-5.
In the lower portions of the basins below the requested
declassification points, fresh and low tidal marshes occur.
The dominant species in these areas is sawgrass (Cladium
jamaicense), with black needlerush (Juncus roemerianus) occurring
in greater amounts near the mouths.
A list of all the plant taxa which are known to occur in
the region of the proposed facility is provided by NCPC (1975).
Fauna. The field studies performed by WCC biologists for
NCPC include a survey of the birds utilizing various habitats
within the Brown Run and Crawford Mill Run drainage basins in
May and June of 1975. These data were collected utilizing
observation (transect) and live capture (mist net) techniques.
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Sample areas included loblolly and shortleaf pine plantations,
and hardwood bottomlands and marshlands. The taxa identified
within various habitats of the Brown Run and Crawford Mill Run
drainage basins are given in Table 3.5-6. One species observed,
the bald eagle, is considered endangered by both North Carolina
(DNER, 1973) and the U.S. Department of interior (1974).
However, the sighting was of a single bird in flight over the
site and no active nests were observed in the area.
3.6 HYDROLOGY
Brown Run and Crawford Mill Run are two tributaries of
Durham Creek, a tributary of the Pamlico River in Beaufort
County, North Carolina.
Brown Run is located within a 768 acre drainage basin
on the west shore of Durham Creek. The decernable creek
channels, including feeder streams, extend upstream for
approximately 12,000 linear feet. The width varies from 640
feet at the mouth to approximately 5 feet at a point 3000 feet
upstream.l Depth ranges from approximately 5 feet at the mouth
to approximately 2 feet, 3000 feet upstream. The water surface
area is approximately 12 acres, the majority of which occurs
near the mouth. If an average depth of 3.5 feet is assumed,
the volume is approximately 1,800,000 cubic feet. The maximum
elevation within the Brown Run basin (16 feet) is reached at
the divide between it and the Barris Creek drainage basin.
Utilizing this point and the point where sea level is reached,
Brown Run has a 0.2 percent gradient (2 foot verticle drop
per 1,000 linear feet).
Crawford Mill Run is located within a 1630 acre drainage
basin on the west shore of Durham Creek, adjacent to the Brown
lAll stream dimension data are on the basis of August, 1975
observations.
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Run basin. The discernable creek channels, including feeder
streams, extend upstream for approximately 10,000 linear feet.
The width varies from 520 feet at the mouth to approximately
5 feet at a point 1500 feet upstream. Depth ranges from
approximately 5 feet at the mouth to 3 feet a point 1500 feet
upstream. The water surface area is approximately 4 acres,
the majority of which occurs near the mouth. if an average
depth of 4 feet is assumed, the creek volume is approximately
700,000 cubic feet. The maximum elevation within the Crawford
Mill Run basin (57 feet) is reached along the divide between
it and the Nevil Creek basin to the west. Utilizing this
point and the point where sea level is reached, Crawford Mill
Run has a 0.5 percent gradient (5 foot verticle dropper
1000 linear feet).
Using the method of Thorntwaite and Mather (1957), Dewiest,
et. al. (1967) calculated the average
runoff in the vicinity
of the NCPC clay pond site. These data
indicate that yearly
runoff from the Brown Run and Crawford
Mill Run drainage basins
is approximately 19 inches. Utilizing
this figure, the average
annual flows resulting from runoff in
the Brown Run and Crawford
Mill Run basins are 1.7 and 3.6 cubic
feet per second (cfs),
respectively. Elimination of the areas
of these basins which
occur within the clay pond will result
in a reduction of the
average annual flow to 0.4 cfs and 2.7
cfs for Brown Run and
Crawford Mill Run, respectively.
Water levels and flows in Brown
Run and Crawford
Mill Run
are also influenced by the effects of
wind and
atmospheric
pressure (wind tides and setup), and
the normal
gravitational
effects of the sun and moon (periodic
tides).
3.7 SURFACE WATER QUALITY
The water quality standards applicable
to
fresh and tidal
salt waters of the Tar -Pamlico River
Basin are
given in DNER
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(1973). As indicated in Section 3.2, Brown Run is classified
SC from its source to Durham Creek and Crawford Mill Run is
classified C from its source to a point 0.5 miles above the
mouth and SC from this latter point to the mouth. The standards
applicable to these classifications are presented in Table 3.7-1.
Salinities in the Pamlico River Estuary vary greatly,
dependent upon fresh water flows from the drainage basins and
wind direction and speed. In addition, the Coriolis Force
causes much of the freshwater to flow along the south side of
the estuary. Hobbie (1970) reports that relatively high
salinities were found associated with low flow into the
estuary from March through June 1967, with the first lower
salinities appearing after a high river flow in mid -August
1967. Salinities increased over the next few months with
lower river flows until the high runoff of January 1968
flushed the river and resulted in low salinities throughout
the river.
In order to better assess the existing quality of the
waters of Brown Run and Crawford Mill Run (Figures 3.7-1,
3.7-2, 3.7-3, 3.7-4, and 3.7-5) water quality sampling
(Figure 3.7-6) was conducted during August of 1975 (Figure
3.7-7). These data are presented in Table 3.7-2. The
salinities measured in Brown Run and Crawford Mill Run during
August of 1975 ranged from 10 parts per thousand at their
mouths to 8 parts per thousand well within the forested
portions of the basins. Measurements taken during April,
1975 indicate that salinities were less than 1 part per
thousand in all parts of Brown Run,
3.8 GROUNDWATER
The thickness of the sedimentary rocks in the Beaufort
County area ranges from 1,200 feet in the western part to
about 4,500 feet in the eastern part. The sediments consist
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of clay, silt, sand, shells, and limestone. In general, the
units have a northeastern strike and dip southeastward at a
gradient of 20 feet per mile. They are generally wedge-shaped,
beginning as a feather edge along their western boundary and
thickening southeastward in the direction of regional dip. Of
the various units present, the post Miocene hydrogeologic unit
is most concerned with the location of the clay pond. In the
Brown Run and Crawford Mill Run basins this unit consists pri-
marily of surficial sand with some shell beds, silt, and
silty clay. The upper aquifer surface is the groundwater
table which fluctuates with changes in groundwater storage.
The top of the aquifer is the ground surface. In most cases
the base of this surface aquifer is a clay layer.
Recharge to this surface aquifer originates from direct
precipitation over the outcrop area and infiltration of pre-
cipitation and stream flow into the Post Miocene unit. This
occurs over the entire land area of the Brown Run and Crawford
Mill Run basins, except that occupied by water and swamps and
the areas adjacent to the streams. The materials which compose
this unit are generally permeable and provide a large reservoir
precipitation, where the reservoir is not already filled to
capacity, is estimated to be more than 10 inches per year on
the average. If the water table reservoir is full or nearly
full, the rainfall is mostly rejected as runoff to Brown Run
and Crawford Mill Run.
3.9 REFERENCES
DeWiest, R.J.M., A.N. Sayre, and C.E. Jacob. 1967. Evaluation
of potential impact of phosphate mining on groundwater
resources of eastern North Carolina. North Carolina
Department of Water Resources, Raleigh.
Hobbie, J.E. fiydrography of the Pamlico River Estuary. Water
Resources Research Institute Report No. 39, North Carolina
State University, Raleigh. 69 pp.
1 3-10

a
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North Carolina Department of Natural and Economic Resources.
1973a. Water quality management plan Tar -Pamlico River
Basin sub -basin 07. Board of Water and Air Resource,
Raleigh.
North Carolina. Department of Natural and Economic Resources.
1973b. Preliminary list of endangered plant and animal
species in North Carolina. Endangered Species Committee
of the Department of Natural and Economic Resources,
Raleigh. 27 pp.
North Carolina Phosphate Corporation. 1975. Environmental
impact report for proposed phosphate mining and beneficia-
tion facilities, Aurora, North Carolina. Prepared by
Woodward --Clyde Consultants, Clifton, New Jersey for North
Carolina Phosphate Corporation, Washington, North Carolina.
Radford, A.E., H.E. Ahles, and C. Ritchie Bell. 1968. Manual
of the vascular flora of the Carolinas. The University
of North Carolina Press, Chapel Hall. 1183 pp.
Thorntwaite, C.W., and J.R. Mather. 1957. Instructions and
tables for computing potential evapotranspiration and
the water balance. Publications in Climatology, Volume X,
No. 3, Drexel Institute of Technology.
U.S. Department of Interior. 1974. United States list of
endangered fauna. Office of Endangered Species and
International Activities, U.S. Fish and Wildlife Service,
Washington, D.C. 22 pp.
U.S. Geological Survey. 1974. Bath, North Carolina ortho-
photo quadrangle, 7.5 minute series. U.S. Geological
Survey, Reston, Virginia.
U.S. Geological Survey. 1951. Bath, North Carolina quadrangle,
7.5 minute series, U.S. Geological Survey, Reston, Virginia.
3-11

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TABLE 3.4-1
BENTHIC INVERTEBRATE TAXA IDENTIFIED FROM BROWN RUN
IN APRIL, 1975
Annelida
Oligochaeta
Polychaeta
Ampharetidae
Melinna sp.
Mollusca
Pelecypoda
Mactridae
Rangia cuneata
Tellinidae
Macoma sp.
Arthropoda
Crustacea
Isopoda
Cassidisca lunifrons
Cyathura op lita
Amphipoda
Corophium sp.
Gammarus sp.
Leptocheirus plumulosus
Insecta
Odonata
Anisoptera
Macrothemis sp.
Plathemis sp.
Zygoptera
Agrionidae
Caleoptera
Hydrophilidae
Berasus sp.
Diptera
Chironomidae
Heleidae
Palpomyia sp.
I

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40 as an am so
TABLE 3.4-2
TOTAL NUMBER, WEIGHT (GRAMS), AND RESPECTIVE PERCENT COMPOSITION
OF THE PREDOMINANT BENTHIC INVERTEBRATE TAXA
COLLECTED IN BROWN RUN IN APRIL, 1975
TAXA
MOUTH
MIDREACHES
HEADWATERS
No./%
No./%
No./%
Wt./%
Wt./%
Wt./%
Amphipoda
20/39.2
592/61.9
343/67.8
0.0367/17.8
1.0243/50.7
0.5363/31.1
Chironomidae
18/35.3
133/13.9
86/17.0
0.0377/18.3
0.2763/13.7
0.2701/15.6
Polychaeta
9/17.6
214/22.4
69/13.6
0.0331/16.1
0.6689/33.1
0.7044/40.8
i

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TABLE 3.4-3
SPECIES, TOTAL NUMBER, AND PERCENT COMPOSITION
OF NEKTON COLLECTED FROM
BROWN RUN AND CRAWFORD MILL RUN IN APRIL AND JULY, 1975
Crawford Mill
Brown
Run 1
Run
Species
April
July
July
Pisces
American eel
(Anguilla rostrata)
5/-2
1/-
Atlantic croaker
(Micropogon undulatus)
182/6.4%
Atlantic menhaden
(Brevoortia t r annus)
8/-
Atlantic needlefish
(Strongy lura marina)
1/-
Banded killifish
(Fundulus diaphanus)
2/-
5/-
Bay anchovy
(Anchoa mitchilli)
2231/78.5%
997/58.1%
781/71.3%
Brown bullhead
(Ictalurus nebulosus)
5/-
Chain pickerel
(Esox niger)
5/-
Golden shiner
(Notemigonus crysoleucas)
4/-
8/0.5%
Ladyfish
(Ela s saurus)
1/-
Largemouth bass
(Micropterus salmoides)
6/-
3/-
1/-
Longnose gar
(Lepisosteus osseus)
8/-
Naked goby
(Gobiosoma bocci)
8/-
Pumpkinseed
(Lepomis gibbosus)
20/0.7%
10/0.6%
4/-
Rainwater killifish
(Lucania parva)
4/--
Shad
(Clu eidae)
1/-
(Continues)

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TABLE 3.4-3 (continued)
Crawford Mill
Brown
Run
Run
Species
April
August
August
Southern flounder
(Paralichthys lethostigma)
3/-
1/-
Spot
(Leiostomus xanthurus)
117/4.1%
1/-
Sunfish
(Enneacanthus sp.)
10/-
134/7.8%
141/12.9%
Sunfish
(Lepomis sp.)
3/-
523/30.5%
131/12.0%
Tidewater silversides
(Menidia her llina)
220/7.7%
30/1.7%
33/3.0%
White perch
(Morone americana)
1/-
Yellow perch
(Perca flavescens)
4/-
1/-
Crustacea
Grass shrimp
(Palaemonetes sp.)3
36
3
1
IApril and July fishing efforts were not eauatible
2bash (-) indicates less than 0.5%
3Not considered in % abundance computations

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TABLE 3.5-1
FLORAL TAXA OBSERVED IN A 5-YEAR-OLD LOBLOLLY PINE PLANTATION
OCCURRING IN THE VICINITY OF THE
PROPOSED NCPC CLAY POND
OVERSTORY
Loblolly pine (Pinus taeda)l
Sweetgum (Liquidambar styraciflua)
Tulip -tree (Liriodendron tulai.pifera)
Willow oak ( uercus phellos)
UNDERSTORY
Azalea
(Rhodedendron spp.)
Beard grass
(Andropogon spp.)
Blackberries
(Rubes spp.)
Coral honeysuckle
(Lonicera sempervirens)
Juneberry
(Amelanchier spp.)
Red maple
(Ater rubrum)
Sweetgum
(Liquidambar styraciflua)
Sweet pepperbush
(Clethra spp.)
Wax myrtle
(Myrica cerifera)
Winged sumac
(Rhus co allina)
Vaccinium spp.
VINES
Grape (Vitas spp.)
Smilax spp.
lArranged alphabetically.
Scientific nomenclature after Radford, et al (1968).

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TABLE 3.5-2
FLORAL TAXA OBSERVED IN AN 8-YEAR-OLD LOBLOLLY PINE PLANTATION
OCCURRING IN THE VICINITY OF THE
PROPOSED NCPC CLAY POND
OVERSTORY
Lablolly pine
(Pinus taeda)1
Post oak
( uercus stellata)
Red maple
(Acer rubrum)
Southern red oak
(uercus falcata)
Sweet gum
(Liquidambar styraciflua)
Water oak
( uercus nigra)
Willow oak
( uercus phellos)
UNDERSTORY
Alder
(Alnus spp.)
Azalea
(Rhododendron spp.Y
Beard grass
(Andropogon spp.)
Black gum
(NYssa sylyatica)
Cane
(Arundinari.a gigantea)
Dogwood
(Cornus spp.)
Juneberry
(Amelanchier spp.)
Oak
( uercus spp.)
Sweetgum
(Liquidambar st raciflua)
Sweet pepperbush
(Clethra spp.)
Vaccinium spp.
Wax myrtle
(Myrica cerifera)
Winged sumac
(Rhus copallina)
1
VINES
Grape
(Vit.i.s spp.)
Arranged alphabetically.
Scientific nomenclature after Radford, et al (1968).

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TABLE 3.5-3
FLORAL TAXA OBSERVED IN A 13-YEAR-OLD SHORTLEAF PINE PLANTATION
OCCURRING IN THE VICINITY OF THE
PROPOSED NCPC CLAY POND
OVERSTORY
Shortleaf pine
(Pines echinata)l
UNDERSTORY
Blackberry
(Rubus spp.)
Black cherry
(Prunus serotina)
Black gum
(Nyssa sylvatica)
Cane
(Arundinaria gigantea)
Flowering dogwood
(Corpus florida)
Hercules club
(Aralia spinosa)
Holly
(Ilex opaca}
Post oak
( uercus stellata)
Southern red oak
( uercus falcata)
Red maple
(Acer rubrum)
Sweet bay
(Magnolia virginiana)
Sweetgum
(Liquidambar styraciflua)
Sweet pepperbush
(Clethra spp.)
Tulip -tree
(Lireodendron tulipifera)
Water oak
( uercus nigra)
VINES
Grape (Vitis spp.)
Smilax spp,
lArranged alphabetically.
Scientific nomenclature after Radford, et al (1968).

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TABLE 3.5-4
FLORAL TAXA OBSERVED IN A HARDWOOD STREAM BOTTOM
IN THE VICINITY OF THE
PROPOSED NCPC CLAY POND
OVERSTORY
Ash (Fraxinus spp.)l
Bald cypress (Taxodium distichum)
Black gum (Nyssa s lv�� atica)
Red maple (Ater rubrum)
Sweetgum (Liquidambar styraciflua)
Tulip --poplar (Lireodendron tulipifera)
Willow (Salix spp.)
Willow oak (uercus phellos)
Alder
(,Alnus spp.)
Cane
(Arundinaria gigantea)
Red maple
(Acer rubrum)
Sweetgum
(Liquidambar styraciflua)
Willow
(Salix spp.)
VINES
Honeysuckle (Lonicera spp.)
Smilax spp.
iArranged alphabetically.
Scientific nomenclature after Radford, et al (1968).

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TABLE 3.5-5
FLORAL TAXA OBSERVED IN A CYPRESS SWAMP
ALONG THE OPEN WATERS OF CRAWFORD MILL RUN
Bald cypress
Arrowhead
Black gum
Fern
Hydrocotyle spp.
Iris
Red bay
Red maple
Rubus spp.
Rumex spp.
Sweetgum
Violet
Wax myrtle
OVERSTORY
(Taxodium distichum)'
(Sagittaria spp.)
(Nyssa sylvatica)
(Osmundia spp.)
(Iris spp.)
(Persea borbonia)
(Acer rubrum)
(Liquidambar styraciflua)
(Viola spp.)
(My2LJ�ca cerifera)
lArranged alphabetically.
Scientific nomenclature after Radford, et al (1968).

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TABLE 3.5--6
BIRD TAXA OBSERVED IN VARIOUS HABITATS
OCCURRING IN THE VICINITY OF THE
PROPOSED NCPC CLAY POND
American goldfinch
Bald eagle
Black -and -white warbler
Black -billed cuckoo
Blue -gray gnatcatcher
Bluejay
Bobwhite
Brown -headed cowbird
Brown thrasher
Cardinal
Carolina chickadee
Carolina wren
Common crow
Common flicker
Common grackle
Common yellowthroat
Downy woodpecker
Eastern kingbird
Eastern meadowlark
Field sparrow
Gray catbird
Great creasted flycatcher
Henslow's sparrow
Hooded warbler
Indigo bunting
Mourning dove
Northern parula
Ovenbird
Pine warbler
Prarie warbler
Red -eyed vireo
Red --tailed hawk
Red -winged blackbird
Rufous -sided towhee
Song sparrow
Tufted titmouse
White -eyed vireo
Wilson's warbler
Yellow -billed cuckoo
Yellow -breasted chat
Yellow-rumped warbler
(S-pinu.s tristis) 1
(Haliaeetus Leucocephalus)
(Mniotilta varia)
(Coccyzus erythropthalmus)
(Polio ttila caerulea)
(Cyanocitta cristata)
(Colinus virginianus)
(Molothrus ater)
(Toxostoma rufum)
(Cardinalis cardinalis)
(Parus carolinensis)
(Th.ryothorus ]udovicianus)
(Corvas brachyrhynchos)
(Colaptes auratus)
( uiscalus quiscula)
(Geothlypis trichas)
(Dendrocopos pubescens)
(Tyrannus tyrannus)
(Sturnella magna)
(s izela pusilla)
(Dumetella carolinensis)
(Myiarchus crinitus)
(Ammodramus bairdii)
(wilsonia citrina)
(Passerina cya.nea)
(Zenaida macroura)
(parula americana)
(Seiurus aurocapil,lus)
(Denroica pinus)
(Dendroica discolor)
(Vireo olivaceus)
(Buteo jamaicensis)
(Agelaius phoeniceus)
(Pipilo erythrophthalmus)
(Melospiza melodia)
(Parus bicolor)
(Vireo griseus)
(wilsonia pusilla)
(Coccyzus americanus)
(Icteria virens)
(Dendroica coronata)
lArranged alphabetically.
Scientific nomenclature after American Ornithologists Union (1957;1973).
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TABLE 3.7•-1
WATER QUALITY STANDARDS APPLICABLE TO THE CURRENT CLASSIFICATIONS
OF BROWN RUN AND CRAWFORD MILL RUN
.FOR PORTIONS CLASSIFIED AS C WATERS
Parameters Standards
Floating solids; setteable solids;
sludge deposits.
PH
Dissolved oxygen.
Toxic wastes; oils; deleterious
substances; colored or other
wastes.
Organisms of coli.form group,
Only such amounts attributable tc
sewage, industrial wastes or
other wastes as will not, after
reasonable opportunity for dilu-
tion and mixture of same with the
receiving waters, make the waters
unsafe or unsuitable for fish and
wildlife, or impair the waters
for any other best usage estab-
lished for this class.
Shall be normal for the waters in
the area, which generally shall
range between 6.0 and 8.5, except
that swamp waters may have a low
of 4.3.
Not less than 6.0 mg/1 for natural
trout waters; 5.0 mg/l for put--and-
take trout waters; not less than a
daily average of 5.0 mg/l with a
minimum of not less than 4.0 mg/1
for non -trout waters, except that
swamp waters may have lower values
if caused by natural conditions.
Only such amounts, whether alone or
in combination with other substances
or wastes as will not render the
waters injurious to fish and wildlife
or adversely affect the palatability
of same, or impair the waters for
any other best usage established for
this class.
Fecal coliforms not to exceed to log
mean of 1,000/100 ml (MPN or MF
count) based upon at least five con-
secutive samples examined during any
30-day period; nor exceed 2,000/100 ml
in more than 20% of the samples exam-
ined during such period. (Not appli-
cable during or immediately following
periods of rainfall,)

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TABLE 3.7-1 (cont'd - 2)
C�
ITemperature
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Parameters
Standards
Not to exceed 5°F alcove the natu-
ral water temperature, and in no
case to exceed 840F for mountain
and upper piedmont waters and
9Q°F for lower piedmont and coastal
plain waters. The temperature of
natural trout waters shall not be
significantly increased due to the
discharge of heated liquids and
shall not exceed 68°F; however,
the temperature of put -and -take
trout waters may be increased by
as much as 30F but the maximum may
not exceed 70°F.
FOR PORTIONS CLASSIFIED AS SC WATERS
Parameters
Floating solids; setteable solids;
sludge deposits.
pH
Dissolved oxygen.
Standards
Only such amounts attributable to
sewage, industrial waste or other
wastes as will not, after reason-
able opportunity for dilution and
mixture of same with the receiving
waters, make the waters unsafe or
unsuitable for fish and wildlife,
or impair the waters for any other
best usage established for this
class.
Shall be normal for the waters in
the area, which generally shall
range between 6.0 and 8.5, except
that swamp waters may have a mini-
mum of 4,3.
Not less than 5.0 mg/l, except
that swamp waters may have a
minimum of 4.0 mg/l.

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TABLE 3.7-1 (cont'd - 3)
Parameters
Toxic wastes; oils; deleterious
substances; colored or other
wastes.
organisms of coliform group.
Temperature
Standards
only such amounts, whether alone
or in combination with other
substances or wastes as will not
render the waters injurious to
.fish and shellfish, adversely
affect the palatability of same,
or impair the waters for any other
best usage established for this
class.
Fecal coliforms not to exceed a
log mean of 1,000/10 ml (MPN or
MF count) based upon at least
five consecutive samples examined
during any 30-day period; nor
exceed 2,000/100 ml in more than
20% of the samples examined during
such period. (Not applicable
during or immediately following
period of rainfall.)
Shall not be increased above the
natural water temperature by more
than 1.5°F during the months of
June, July, and August nor more
than 4.0°F during other months,
and in no case to exceed 90°F,
due to the discharge of heated
liquids.

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Sample Depth
Point (meters)
BROWN RUN
B Rl
BR1
BR2
BR2
BR3
B R3
BR4
BR4
BR5
BR5
BR6
BR7
CRAWFORD MILL RUN
CM1
CM1
CM2
CM2
CM3
CM3
TABLE 3.7-2
WATER QUALITY DATA COLLECTED FROM BROWN RUN AND CRAWFORD MILL RUN
ON 20 AUGUST 1975
Dissolved Suspended
Salinity 2 Oxygen Fecal Total Solids
Temperature (parts per (parts per Coliforms Coliforms (parts per
(CO) thousand) pH million]' (No./100 ml) (No./100 ml) million)
S``
27.8
9.5
7.35
7.05
30
70
7
1.5
26.2
8.0
7.18
6.84
S
25.5
10.0
6.70
3.76
190
220
8
1.2
25.5
9.0
6.55
3.09
S
25.0
8.0
6.05
2.42
1000
1000
10
1.5
25.1
9.0
6.18
1.66
S
25.0
8.0
5.88
0.86
1000
1000
11
1.5
25.1
8.5
6.04
0.57
S
25.1
9.0
6.45
6.22
290
380
12
1.0
25.1
8.5
6.43
6.08
0.8
25.8
8.0
6.15
2.76
550
550
11
0.7
25.1
8.5
6.25
2.80
200
270
16
S
29.3
10.0
7.85
9.31
80
210
17
1.4
26.1
10.0
7.20
7.19
S
25.5
10.0
6.80
6.11
700
700
10
1.2
24.8
9.5
6.55
6.16
S
25.5
8.5
6.05
2.14
700
700
9
0.9
25.1
8.5
6.05
1.85
1See Figure 3.7-7 for sample point locations
2Derived from conductivity in micromhos/centimeter
3Corrected for salinity
4Surface

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FIGURE 3.7-3 Unnamed tributary to Brown Run looking upstream from a point 100 feet below the requested
Point of declassification
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FIGURE 3.7-4 Secondary tributary to Brown Run looking upstream from the requested point of declassification

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FIGURE 3.7-6 Woodward -Clyde Consultants' biologist obtaining water quality data in
Crawford Mill Run

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1 CLAY POND
1
BR4 \
' BR6 BR7
_ �RpMIF
CM3
C
LEGEND
CM1 • CRAWFORD MILL RUN WATER QUALITY SAMPLE POINT 1
BR4 w BROWN RUN WATER QUALITY SAMPLE POINT
SCALE
O 2000 4000 8000 FT
NORTH CAROLINA PHOSPHATE CORPORATION
WATER QUALITY SAMPLE POINTS
20 AUGUST 1975
FIGURE 3.7-7

mm� MEW " m mm4ommmm mmmmm

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SECTION 4
ENVIRONMENTAL IMPACTS OF DECLASSIFICATION
4.1 INTRODUCTION
The probable environmental impacts resulting from the
requested declassification of portions of the Brown Run and
Crawford Mill Run drainage basins (Figure 1.2-1) and the
construction of the NCPC clay pond are presented in this
chapter. Impacts are evaluated with respect to land and water
use, socioeconomics, soils, hydrology and hydrography, water
quality, groundwater regime, aquatic ecology, and terrestrial
ecology. An analysis of the impacts indicates that there are
socioeconomic positive impacts associated with the project
(e.g., increased employment and income levels and encourangement
of long-term economic growth); and, there are various unavoid-
able negative impacts on other aspects of the environment.
However, NCPC has undertaken a considerable effort in the
design phase to avoid and mitigate these impacts. Section 4.10
discusses the various preventive measures to be implemented by
NCPC during the construction and operation of the clay pond.
A more detailed assessment of the impacts resulting from the
project as a whole is given by NCPC (1975).
4.2 LAND AND WATER USES
Construction of the clay pond will result in the conversion
of 1200 acres of mostly forested drainage basin area (Figure
3.2-1) to a pond for the storage of waste clays. Additional
smaller acreages will be required for construction and lay -
down areas, drainage ditches, pipelines, and discharge channels.
This conversion will not cause any relocation of homes, businesses,
or major transportation routes.
1 4-1

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Because those portions of the Brown Run and Crawford
Mill Run drainage basins which are most often utilized for
their best uses (e.g., fishing, boating) as currently classified
are located downstream of the proposec lay pond; they should
continue to provide these opportunities to the citizens of
Beaufort County and North Carolina, in general. Those portions
of these waters which will be directly altered through pond
construction will no longer provide the best uses currently
assigned to them. However, as indicated in Section 2.2, NCPC
has made efforts to locate the proposed pond such that this
loss will be minimized.
It is, and will continue to be, the policy of NCPC to
make as much of its land holdings in Eastern North Carolina
as possible available for sport and recreation. Since these
holdings are substantial, NCPC feels this policy will result
in an increase in the acreage dedicted to such use.
At the time of this report, NCPC is purchasing a large
tract of land, which is ideally located for sport and recrea-
tional use. It will represent acreage on the order of five
times that being removed by the proposed activity associated
with the clay pond facilities discussed in this report.
4.3 SOCIOECONOMICS
As indicated in Section 1.1, the clay pond is an important
component of the proposed NCPC facilities. Without it the ore
processing would not be economically feasible (Section 2.1).
Its location is key to the operation of the project. Thus,
the socioeconomic benefits which will be created by the project
as a whole cannot be obtained without the requested declassi-
fication of portions of Brown Run and Crawford Mill Run.
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The NCPC project will create employment opportunities and
greatly increase incomes for area residents. As many as 800
construction workers will earn a total of over $16 million during
the construction period. The 468 employees required during
full operation will earn $5.4 million per year. Indirect jobs
resulting from the project should equal as many as 600 during
construction and about 320 during operation. Approximately half
of these jobs and the resulting wage payments should accrue to
residents of area counties (Beaufort, Craven and Pamlico Counties).
Tax revenues to be generated during project operation should
be substantial, with Beaufort County to receive property taxes
of about $1 million per year from the facility, plus additional
revenue from the project -related population. The state would
receive approximately $2 million in annual taxes, over 80 per-
cent of which will be paid by NCPC in sales, franchise, and
corporate income taxes.
The project will spur relocation of construction and opera-
tion workers, with about 670 and 245 persons expected to
relocate to the area during peak construction and full operation,
respectively. Most of the relocated population will move to
Beaufort County, and a substantial number of these persons
should settle in Richland Township. This relocation will require
additional housing and local services, although the costs of
these services are far exceeded by anticipated NCPC-related tax
revenues.
Impacts on the socio-cultural setting of the immediate
project area should not be major, since a similar facility
already exists in the immediate project area. The unaesthetic
nature of the project should be mitigated because most of the
mine, plant, and clay pond facilities will be hidden from
view by appropriate buffer zones.
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4.4 SOILS
As indicated in Section 3.3, the soils over the majority
of the clay pond site are of the Roanoke -Cape Fear -Portsmouth
Association. Creation of the clay pond and its operation will
necessarily overtop 1200 acres of these soils with clays.
Additional acreages will be required for construction and
laydown areas, drainage ditches, pipelines, and discharge
channels. This will result in alterations of natural soil
horizons and compaction of surface soils in some areas. How-
ever, since the site area is already being managed for pine
plantations, extensive ditching and heavy equipment operation
are already present. Loss of soils through excessive erosion
will be controlled through the preventive measures discussed
I
n Section 4.10.
4.5' HYDROLOGY
As indicated in Section 3.6, the average annual runoff in
the
vicinity of the clay pond site is approximately 19 inches.
Utilizing this figure and the Brown Run and Crawford Mill Run
drainage basin averages (768 acres and 1,630 acres, respectively).
The average, annual flow from Borwn Run is 1.7 cfs, while
Crawford Mill. Run yields 3.6 cfs. Since the construction of
the clay pond will eliminate 74 percent of the Brown Run basin
and 24 percent of the Crawford Pill Run basin, a reduction in
average annual flow will result. Based on these basin area
losses, the resultant flows should be approximately 0.4 cfs
and 2.7 cfs for Brown Run and Crawford Mill Run, respectively.
Filling of portions of the Brown Run and Crawford Mill Run
basins will also result in a small reduction in the acreage and
volume of open water within their channels. As is evident in
Figure 1.2-1, the majority of the open waters occur below the
requested declassification points.
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4.6 SURFACE WATER QUALITY
Since no discharge will be made to either Brown Run or
Crawford Mill Run, the only impacts on the surface water quality
of these streams below the declassification points should be
increased sedimentation during clay pond construction and alter-
ation in salinity during periods of the year when fresh water
flow from the basins is sufficient to counteract the upstream
movement of more saline waters of Durham Creek and the Pamlico
River. Since freshwater runoff is an important factor in
determining salinities within all portions of the Pamlico River
Estuary, the reductions in the drainage basin areas of Brown
Run and Crawford Mill Run will alter flows and thus the salinity
regimes of the waters of these streams. Because winds also
play an important role in the movement of more saline waters
to Pamlico Sound upstream, the severity and periodicity of
this impact cannot be accurately predicted. However, the
salinities within Brown Run and Crawford Mill Run should never
be higher than those at their confluences with Durham Creek.
Using the "universal soil loss" equation and assuming a
drainage length of 5,000 feet, a soil erodibility factor of
.25, and a slope of .16 percent, the sediment yield from the
area of the clay pond in its natural condition was calculated
to be about 0.6 tons/acre-year. This would result in a total
yield of about 720 tons/year from the area which is to be
occupied by the clay pond. once the clay pond is constructed,
all of the sediment yield will come from the erosion of the
constructed dikes. The dikes enclosing the clay pond are to
be approximately 18 to 28 feet high with a total length of
approximately 35,000 feet. The total surface area of the
dikes was considered to be about 37 acres based upon a slope
of 3:1 (horizontal to vertical). The dikes will be covered
with grass, graded, and contoured to control erosion. Using
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the "universal soil loss" equation and assuming that there
will be a lag time of about four months between the time the
dikes are completed and the time that vegetation is established
on the dikes, a sediment yield of 110 tons/acre-year is
estimated for the first year of existence for the dikes. For
' every year thereafter, a yield of about three tons/acre-year
is estimated. These values will be easily reduced to the
natural condition value through the use of sediment basins and/
or the use of mulch or other protective covers between the
time of construction and the establishment of vegetation
(see Section 4.10).
4.7 GROUNDWATER
As indicated in Section 3.8, the construction of the
proposed clay pond in the Brown Run and Crawford Mill Run
drainage basins should only affect groundwater in the surficial
aquifer. The surficial aquifer serves two functions in Beaufort
County: (1) it supplies a few scattered stock and domestic
wells; and (2) it serves as a secondary source of groundwater
recharge to underlying aquifers. Construction of the clay pond
may cause some local dewatering of this aquifer. However,
since there are no wells in the immediate vicinity of the clay
pond site, and the area of effect is relatively small, the
impact on water users and the recharge to underlying aquifers
should be inconsequential. Since the majority of the site
area is being managed as pine forestland, localized dewatering
of the surficial aquifer is already occurring. The clay pond
will be designed and operated to create a clay seal between
the groundwater and the clay slurry water. Thus, there should
be no leakage of water from the pond's interior into the
groundwater once the initial clays have settled.
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4.8 AQUATIC ECOLOGY
The significant aquatic impact associated with the
construction of the NCPC clay pond will be the reduced fresh
water flow and resultant reduction of low salinity aquatic
nursery areas of Brown Run and Crawford Mill Run. Minor
impacts, expected to be of short duration, will include
increased sedimentation and siltation in the named streams,
and mechanical disruption.
The proposed clay pond will disrupt natural flows within
24 percent of the Crawford Mill Run drainage basin, and 74
percent of the Brown Run drainage basin. Although these
streams do not appear to be unique, these losses will reduce
the availability of such habitat in the Durham Creek and
surrounding drainage basins. Nine streams of similar character
which will not be directly affected by the project exist
within the site locality. The low salinity area of Durham
Creek in which these streams are located is noted for its
excellent sport fishing (largemouth bass and sunfish) and its
ability to shelter and,feed young of commercial species (includes
menhaden, mullet, red drum, and spot, among others). Reducing
the drainage basin area of Brown Run and Crawford Mill Run
will reduce their fresh water flows and allow more saline
waters to penetrate them more often than with current flows.
This will make them less desirable for species requiring a
fresh or near -fresh water environment, but more desirable
for species requiring slightly higher salinities than presently
occur in these creeks. Since salinities in the estuary change
throughout the year, with fluctuations in fresh water runoff
and wind speed and direction, the periodicity and severity
of this impact cannot be accurately predicted.
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Sedimentation and siltation from the cleared pond area
and the newly constructed dike will reduce light penetration,
smother benthic faunal or floral forms, and possibly cause
physical damage to biota in Brown Run and Crawford Mill Run.
These factors will act to temporarily reduce primary productivity
'
(growth and oxygen production of green plants), increase oxygen
demand and promote the growth of unfavorable plant species
(e.g., red tide plankton), and reduce local nekton and benthic
biomass. These impacts should be short-term and minimized by
the Dreventive measures discussed in Section 4.10.
As the clay pond retaining dike is constructed and portions
of Brown Run and Crawford Mill Run are filled, all biota unable
to escape such activity will be destroyed. Organisms lost will
include aquatic vegetation (mainly pond weed), benthic forms (e.g.,
amnhipods, polychaets, and several species of chironomias), and a
small number of motile forms (fish and crustaceans) which will
be unable to
escape.
The operation of heavy machinery during this construction
process will cause the accumulation of chemical substances on
'
land area which may in turn be washed into Brown Run and
Crawford Mill Run. However, these substances will be present
in small quantities and will only be present intermittently
during construction.
4.9 TERRESTRIAL ECOLOGY
Flora. Clay pond site preparation will necessitate the
removal of existing flora from portions of the Brown Run and
Crawford Mill Run drainage basins. During clearing operations,
marketable trees will be salvaged by Weyerhaeuser for use by
the wood products industry. Slashings and unmarketable vegeta-
tion will be burned in accordance with North Carolina Forest
Service regulations. Since the majority of the clay pond site

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area is vegetated with planted commercial loblolly and short -
leaf pine forests, these impacts will be the same as those
to which these forests have already been committed to through
accepted timber management practices. However, the creation
of the pond dikes and the storage of up to 25 feet of clay over
1200 acres will make it doubtful that these portions of the
Brown Run and Crawford Mill Run basins will support similar
habitats in the foreseeable future. 'Those portions of the
site which are vegetated with natural stands (e.g., cypress
swamp) will most likely never support that forest type again.
Lacking the high porosity and low plasticity of humus,
the clays will be very hard and dense when dry and very sticky
and viscous when wet. Such soils may become almost impervious
to air, water and plant roots (Muller, 1969). International
Minerals and Chemical Corporation (1974) indicates that the
re -use of settling basin land is generally limited to agricul-
tural pursuits because of the bearing strength limits within
these areas.
Moorman (1975) indicates that although willow (Salix spp)
occurs naturally on these areas, trees have not been planted
on abandoned ponds because of the blowdown potential resulting
from the unconsolidated nature of the subsurface clays. Becker
Phosphate Corporation (1974) indicates that once clay ponds
have been settled and drained via shallow ditches, seeding with
grass legume (rye) can be accomplished three to four years
after an area becomes inactive.
Moorman (1975) indicates that Agrico Chemical Company has
leased reclaimed clay ponds to truck farmers in the past and
is currently grazing cattle on the winter rye planted on
abandoned settling pond areas. Engineering and Mining Journal
(1967) reports that Mobil Chemical Company has planted old clay
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areas with Bahia, Argentina bahia, Pensacola bahia and Aeschyno-
mene and is planning to plant Okinawa lespedeza, buffelgrass
lespedeza, buffelgrass, signalgrass, arb peanuts and hemarthria
atlissima grass and legume on additional areas. However, the re-
claimed clay pond will most likely be suited to only agrarian use.
Fauna. The removal of existing flora during site prepara-
tion and construction and the storage of the waste clays will
cause a direct loss of individuals for some and a loss of
habitat for many other terrestrial fauna. The success with
individuals
which can emigrate from the affected areas will be
largely dependent upon their mobility. The loss of habitat
for the successful will cause translocation of individuals
to similar adjacent areas not directly affected by the project.
Because population density is an important factor in determining
both the survival of individuals and the future size of the
population, the extent to which these adjacent habitats can
absorb these individuals will depend on their carrying -capacities,
the populations already existing in them, and the rate of dis-
Should influx individuals
persal. the of occur during a period
of the year other than.the most critical, ample food, cover and
open space may exist to allow the new population to subsist
until the limiting factors (conditions which near or surpass
the limits of tolerance for the organism) which control the
carrying capacity act to initiate a population decline. The
adjusted level may be lower than the initial optimal density
if the overpopulation resulted in detrimental effects on the
ecosystem (e.g., over -browsing). The length of time required
for this adjustment to occur will vary with the physiological
characteristics of the species (e.g., reproductive rate).
As indicated in Section 1.1, the clay will no longer be
required after the fifth year of operation. However, the
vegetation type which the area will be reclaimed with will
i
most likely be agrarian.
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Although such areas
are frequented
by various fauna,
they seldom provide all
of the habitat
requirements of a
species. The area will
be suitable for
pasturing domestic
animals during the drier
seasons of the
year.
1 4.10 PREVENTIVE AND MITIGATING MEASURES
The following text describes the various procedures and
plans that NCPC will employ to prevent and minimize the impacts
resulting from declassification of portions of the Brown Run
and Crawford Mill Run drainage basins.
Before final reclamation can be accomplished after the
fifth year of operation, it is likely that erosion and sedimenta-
tion will occur if temporary erosion control measures are not
implemented. Such measures can significantly reduce accelerated
erosion and siltation during the early stages of the mining
operation. Procedures to be used will be typical of those
outlined by DNER (1974) to trap sediment before it leaves the
affected area.
'
As mining progresses and mined -out areas become available,
the waste clays will be returned to the mine area. Since the
'
vegetation occurring on these areas will have been removed
prior to mining, no additional impacts on existing terrestrial
flora will result from the creation of future clay ponds in
mined -out areas. In addition the manner in which the sands
and clays will be mixed after year 5 will create mediums more
for
suitable revegetation by natural floral communities than
the clays alone. Woodhouse (1975) reports that in North
Carolina up to 10 percent clay solids can be mixed with sand
tailings to form a very productive soil in the laboratory and
on small plots.
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Revegetation of the affected areas will be initiated as
soon as possible after a given area's use is terminated. During
the initial years of operation, studies will be conducted in
consultation with local specialists in order to select the
plant taxa which are tolerant of the properties of the re-
claimed soils and the altered local microclimates, and suitable
for returning these areas to useful acreages.
Thus, the waste disposal areas utilized during the later
years of operation will be capable of providing a wider variety
of habitats available for repopulation by associated fauna.
As indicated in Section 4.2, NCPC will make as much as
possible of its land holdings in Eastern North Carolina avail-
able for sport and recreation. At the time of this report,
NCPC is purchasing a tract, on the order of five times that
being removed by the proposed clay pond facility, which is
ideally located for sport and recreational use.
4.11 REFERENCES
Becker Phosphate Corporation. 1974. Development of regional
impact application for development approval. On file at
the Tampa Bay Regional Planning Council, St. Petersburg,
Florida.
Engineering and Mining Journal. 1967. Mine plan for total
resource management. E/MJ - July, 1967. pp. 77-82.
International Minerals and Chemical Corporation. 1974. Devel-
opment of regional impact application for development
approval. On file at the Tampa Bay Regional Planning
Council, St. Petersburg, Florida.
Moorman, M.L. 1975. Personal communication. Director of
Land Management, Agrico Chemical Company, Pierce, Florida.
I
Muller, W.H. 1969. Botany, a functional approach. The
MacMillan Co., New York. 400 pp.
n
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North Carolina Phosphate Corporation. 1975. Environmental
impact report for proposed phosphate mining and beneficia-
tion facilities, Aurora, North Carolina. Prepared by
Woodward -Clyde Consultants, Clifton, New Jersey for North
Carolina Phosphate Corporation, Washington, North Carolina.
Woodhouse, W.W. 1975. Prospects for reclamation of phosphate
lands in North Carolina. Paper presented before the 72nd
Meetings of the Southern Association of Agricultural
Scientists.
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Norfolk
Located five miles north of
Aurora, N.C. on South Creek
NCPC's new plant site and
mine will he constructed -- - W
with an initial investment ----_ _
of $371.5 million. i=-- -
It will employ 500 i_==
skilled people in
the first phase of � --�-�-
production. More
than 30 months will
s
he required to complete
the construction now = --m
underway.
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Promise Into Reality -
A Challenge
North Carolina Phosphate Corporation (NCPC) is a subsidiary of Agrico Chemical Company, one of
the Williams Companies. Agrico has been mining and marketing phosphate rock from its Florida opera-
tions for almost a century. Today, Agrico's annual production capacity is 6.5 million metric tons from Its
Florida reserve base which places Agrico among the world's leading owners and producers of phosphate
rock. That position will be considerably strengthened when NCPC reaches its planned annual capacity of
3.7 million tons (3.4 million metric tons) of calcined phosphate rock In 1985.
The tremendous phosphate resource in Eastern North Carolina has been a key to Agrico's future
since the early 1960's. NCPC owns 30,000 acres of these reserves in Beaufort and Pamlico Counties.
With new mining technology and a major breakthrough in ore processing, NCPC will turn promise
into reality.
Mining - The photo mural on the inside cover depicts NCPC's unique min-
ing method.
With reference to the numbers on the photo, two bucketwheel excavators
(1) will lead the operation removing about 50 feet (15 meters) of overburden.
The excavators have a combined capability of digging 18 million bank cubic
yards per year (14 million cubic meters). The overburden will be transferred to
shiftable conveyors (2) by mobile transfer conveyors (3) and carried to a spreader (4). The spreader
will deposit the material on the spoil dumps (5) created by draglines working on the bench created
by the bucketwheels.
Two draglines (6) with 68 cubic yard and 50 cubic yard buckets (52 and 38 cubic meters) will
operate on a bench elevation of 60 feet (18 meters) above the top of the ore. The overburden
removed by these draglines is cast into the mined -out area. The ore is then excavated and cast in a
windrow (7) on the dragline bench.
The ore windrow will be reclaimed by two bucketwheel excavators (8) feeding two mobile
transfer conveyors discharging the ore into two self-propelled portable sumps (9). The ore will be
slurried in the sumps and pumped to the beneficiation or processing plant.
Depressurization of the Castle Hayne aquifer, the top of which is approximately 15 feet (4.6
meters) below the bottom of the mining pit, will be necessary to prevent artesian water from
upwelling into the active mining pit. This will be accomplished by pumping from a series of deep
wells (10) located around the periphery of the open mine pit. Part of the water pumped from these
deep wells will be used to slurry the ore and the balance will flow in ditches to the plant for use in
the beneficiation process.
The pit is 4,000 feet (1220 meters) wide and the distance from outer bucketwheel to stacker will
average 2,300 feet (700 meters). Approximately 180 acres (73 hectares) of earth will be removed to a
depth of 150 feet (46 meters) by NCPC's unique system each year.
ie Beneficiation - At the plant, NCPC will separate phosphate from
j associated sands and clays, sharks teeth and shells, in the traditional manner.
Mechanical separation comes first. The ore is washed over a series of vibrating
-= screens. Cyclones next use centrifugal force to separate the particles. Chemical
reagents are then called on to further refine the ore by removing even more of
the sands in flotation. The last step is calcination and there NCPC is again unique.
Calcination - A Major Breakthrough -The last
step in processing is calcination for the removal of organic carbon, inorganic
carbonates, and water. NCPC/Agrico has developed a new calcining technique
which utilizes coal in a confidential process to make phosphate rock from North
Carolina competitive on the domestic and world markets for the first time, It's
an achievement in which NCPC and Agrico take pride.
Art Work By WhIting Toler

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"VA IN
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Fifteen minion years ago, during a time geologists call the M'tnc(i�e-
71€; period, the Atlantic Ocean began invading what is now Beaufort County on
the Coastal Plain of Eastern North Carolina. it was not the first such in
vaslon nor the last, but It was special.
Those ancient Miocene waters over Beaufort were super riche in
phosphate Upwelling From deeper ocean waters into a shallow coastal
embayment, the waters warmed rapidly and phosphate precipitated out
t, of solution, Life forms as varied as bacteria, worms, shellfish, sharks, and 4,
primitive whales helped concentrate this vital life nutrient.
North Caroline Phosphate Corporation has begun developing itaese - "
F,► . ,. ancient deposits in Beaufort County and will ship its first product to
domestic and world fertilizer markets in late 1984. The Coastal Plain
sediments which NCPC wili remove in mining the phosphate are will expose , e"
a sweeping panorama of ancient life revealing other tinges when the
Atlantic covered Eastern North Carolina and times when camels walked
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MEMORANDUM
TO: James D. Simons
State Mining Specialist
FROM: Floyd Williams
Land Quality Regional Engine
Washington Regional Office
DATE: November 26, 1984
SUBJECT: Review of Draft Environmental Protection Program
North Carolina Phosphate Corporation
I have the following comments on the above subject draft:
On page 6 or 7, it should be included that under NCPC's mining permit #7-5
issued April 6, 1982, by the Director, Division of Land Resources of the
N.C. Department of Natural Resources and Community Development, any violation
of the standards of surface water, groundwater, and air quality promulgated
by the Environmental Management Commission or the requirements of the Office
of Coastal Management is a direct violation of NCPC's mining permit.
Page 12: In the last sentence, need to insert "must" in place of "should."
*An NCPC or contracted employee must consult with the
Environmental Department....
Page 21: First paragraph - second sentence - need to remove "should" and
insert "must."
*Every effort must be made to insure compliance....
Page 22: (7) Need to add "Division of Land Resoucces and Division of
T Environmental Management."
Page 27: #1 - first sentence - need to replace "should" with "must."
*They must go immediately to the area....
#1 - last sentence -- need to replace "should" with "must.'"
*An estimate of the severity of the problem must be made so that
this information....
Page 28: #3 - last sentence - need to replace "should" with "must."
*However, if there is a major incident, the Environmental person
on call must report to the plant site....
Additional comments made of pages 29 and 30 are attached.

n
Environmental Incident Procedure
1.
Responsibilitios -- Manager, Environmental Affairs
In an environmental incident involving waters or wetlands (or a
r_htmical spill), the Manager of Environmental Affairs has the responsibility
of notifying other management personnel and Federal and State regulatory
agencies. The following procedures outline these responsibilities.
1) When the Manager is notified of an incident he/she shsuld�
determine what additional actions should be taken. Instructions
s r ri he given to field personnel further > g p if u ther actions need to he
taken. This Haight invulve continuous monitoring of thf- problem or
corrective actions that the field personnel might assist with.
i
The Manager stZ<f ev aluatc the situation and decide if addition
notification of rrianagvrnent personnel is necessary. %Vher e a minor
in' ;dent has occurred and has been contained, additional act ions
o, notification should
normally
be unpe,cessary.
If
the situation
appears serious, the
Manager
report to
the
plantsite and
make a personal
evaluation
of the roblem. If
a major incident
has occurred,
the Manager
sh
d at this time
notify the appro-
priate Operations Manager and give an appraisal of the situatio,
-29-

For some incidents, it may he required that certain Federal and
State regulatory agencies be notified. This notification will
be made by the Manager of Environmental Affairs.
�) The Manager will prepare a complete report for management evalu-
ation. This report si d contain a complete investigation of the
incidc.its leading u and causing the problem and all corrective
actions. It also contain suggestions for the prevention
c
of further incidents. A copy of this report will be filed with
the Manager of the Department in which the incident occurred aril
with the President of NCPC.

NORTH CAROLINA DEPARTMENT OF NATURAL.
RESOURCES AND COMMUNITY DEVELOPMENT
Date I 12-4) 1en
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I
CDN TENTS
Introduction ........................................ 0........................ 2
Waters and Wetlands.......................................................... R
Activities Requiring Permits in Waters/Wetlands 8
NPDES - Waste Water Discharge................................................10
Air Emissions............................................................... 11
Use and Disposal of Deleterious Substances .................................. 12
Education and Communication..................................................13
Presentations and Landmarks..................................................14
Cormunications with Contractors..............................................15
Cz mmunications with Regulatory Agencies and Update ................0......... 16
Waters and Wetlands Project Procedures ...................................... 17
Waters and Wetlands Incident Procedure...............0...................... 21
Waters and Wetlands Project Inspection Procedure 23
Environmental Incident Procedures - Responsibilities - .................... 27
Field Environmental Auditor
Environmental Incident Procedure - Responsibilities ..................... 29
Manager, Environmental Affairs
Environmental Inspection Report ............................................. 31
Managers Listing............................................................ 32

Introduction
NCPC is committed to minimize the impact of its operations un the
environment and to fully comply with all environmental laws and rL-julations.
This environmental protection manual provides policies, procedures, and
guidance to North Carolina Phosphate Corporation (NCPC) personnel and
contractors working in and around NCPC property and in or near Waters of the
United States and Estuarine waters of North Carolina (hereafter "Waters and
Wetlands"). These areas are subject to regulations administered by federal
and/or state regulatory agencies. Unauthorized excavation, fill, di -charge,
or other activity in these regulated areas is against the law.
All NCPC personnel and contractors working for NCPC must be familiar
with the policies and procedures contained in this manual. Management
personnel in areas of activity potentially affecting the environment must
maintain current copies of the manual.
It is the responsibility of each NCPC employee to assist the company
in protecting the environment. The company's Environmental Department is
directly responsible for the implementation of NCPC's environmental
protection program. The Manager of Environmental Affairs will work with all
planning and operations departments to help insure that environmental
M
`., �, 14
considerations are built into the design, construction, &and operation of NCPC
-2-

facilities. The Manager will be the primary contact for the Company with the
government regulatory agencies. He is directly responsible for securing
permits for and environmental monitoring of all projects. The Environmental
Department will he responsible for all permits and stop work or cease and
desist communications with company personnel and contractors related to
environmental concerns. Names, and home telephone numbers of key personnel
in the Department are provided in Appendix A to this manual.
This program is adopted, and distributed to all management personnel
this day of 19
-3-

WATERS AND WETLANDS
In order to protect the valuable waters and wetlands within and
adjacent to NCPC property, it is necessary first to recognize these special
environments. Second, it is important to he acquainted with regulations
which the government regulatory agencies have adopted and administer to
define their areas of jurisdiction and protect these areas.
The federal regulations generally define waters of the United States
to include all waters within the United States extending to the mean high
water mark and adjacent wetlands. Under this general description all of the
following major water bodies near NCPC are classified as waters of the United
States.
1)
Pamlico River
2)
Durham Creek
3)
Porter Creek
4)
South Creek
5)
Whitehurst Creek
6)
Jacks Creek
7)
Jacobs Creek
8)
Drinkwater Creek
9)
Tool ey Creek
10)
Lewellyn Creek
11)
Sibyl Creek
12)
Hudles Cut
-4 -

These creeks also have small tributaries, some of which are named
while others are not. In addition to those listed and their tributaries,
there are many other smaller tributaries. Figure l provides an overview of
most of these areas within NCPC's initial mine/plant area.
Obviously, nearly all of the water areas located on or near NCPC are
covered by the federal regulations. The Company's man-made wetland and open
water areas commonly referred to as Project Areas One and Two are included.
Company constructed sediment ponds, mill ponds, waste impoundment areas and
the dike are not. These areas are regulated but not as wetlands or waters.
"Wetlands" are broadly defined as those areas which are covered or
saturated by water often enough to support vegetation which normally lives in
wet soils. Common names for wetlands include swamps, bogs, marshes, and
savannahs. Photographs of the major wetland types on and around NCPC are
included in Appendix B. A prime example of this type of vegetation is black
needlerush, the long rounded marsh plant with a sharp point which lines most
of the larger creeks in the area. Adjacent to this rush may be sawgrass, so
named because its leaf edges are serrated and will cut. Common cattails are
perhaps the best known marsh type vegetation, although it is not as common as
needlerush in NCPC areas of concern. These marsh type plants immediately
adjacent to the water are usually easily recognized. The trickier areas are
the transition zones between what is clearly marsh and what is upland pine,
-5-

hardwood or field. This is where most unauthorized impacts occur. The
photographs show some of these areas. They may either be dominated by just
one kind of plant like lizard tail or very mixed in vegetation type. Larger
trees normally found in wetlands are cypress, red maple, black and sweet gum
and ash.
Proper identification of wetlands often requires the ability to
identify specific types of vegetation in combination with soil conditions.
Personnel should always consult with the Environmental Department if there is
question about planning any direct actions that affect these areas.
Determination of what is or what is not a regulated water or wetland
area for the purpose of carrying out actions in these areas can only he made
by the appropriate regulatory agencies based on their field
inspections.
Generally, the Federal definitions of waters and wetlands are also
used In the State enforcement programs. The State uses the additional term
"Estuarine waters" which includes all the tidal waters in the coastal areas.
The State also defines as wetlands the areas which are periodically flooded
and have any one of nine specific type of marshgrass growing on the land.
The North Carolina Office of Coastal Management (OCM) also regulates
activities within a 75 foot setback from all Estuarine waters' shorelines
regardless of_the type of water or land within that area. This is an
important area for all employees to recognize. Activities by the company in
this setback area are regulated even if the area is high ground with pine
plantation. This is because activity in this area can directly impact water
-6 -

and wetlands areas unless (for example) proper drainage safeguards are in
place to prevent sedimentation.
Federal Regulation of Wetlands and Waters
The U. S. Army Corps of Engineers enforces two
applicable federal laws, the Rivers and Harbors
Act of 1899, and the Federal Water Pollution
Control Act (Clean Water Act). These provide
the authority to adopt regulations to protect
waters of the United States. Copies of appro-
priate sections of these laws are available
upon request from the Environmental Department.
State Regulation of Wetlands and Waters
The North Carolina Office of Coastal Management
(OCM) administers regulations adopted by the
Coastal Resources Commission (CRC) authorized
by two sections of the North Carolina General
Statutes (N.C.G.S.) pursuant to the Coastal
Area Management Act, or the Dredge and Fill
Law (N.C.G.S. Section 113-229). These two laws
contain definitions in N.C.G.S. Section 113-229 (n)
and N.C.G.S. Section 113A-103.
-7-

Activities Requiring Permits In Waters/Wetlands
The following list of activities is not intended to include all
activities in water/wetlands that must be permitted but it does include most
of the typical activities in these areas which NCPC employees and/or
contractors undertake.
- Fill: Filling or dumping of material into
waters/wetlands. This could include anything
from land clearing and building to grade to
power pole installation or pipe line supports.
- Excavation: Digging or mulching of or in waters/
wetlands.
Discharge of any substance into waters/wetland - This is a very
sensitive area and all employees and contractors must be careful when
planning to use or using materials in and around waters/wetlands which could
eventually get into these areas if spilled. Even if the spill was accidental
or not adjacent to water or wetland, if the material is toxic or deleterious
(such gas and oil or sediments from land clearing), the discharge into waters
or wetlands is still illegal.
-8-

Emergency St02 Work Procedure
In order to insure the immediate cessation of an activity which has
the potential to cause a violation of environmental regulations or permits to
perform work in sensitive areas, the Manager of Environmental Affairs or the
Environmental Auditor may direct the responsible employee to immediately
correct the situation causing the problem. If necessary, this includes
immediately stopping the activity.
Enforcement
Failure by any employee to abide by adopted environmental procedures
or to promptly report environmental incidents will lead to disciplinary
action. These actions may Include verbal or written reprimands, suspension
from work without pay, or termination of employment.
-9-

NPDES - Waste Water Discharge
NCPC will discharge waste water from its mining and processing
activties at two locations into the Pamlico River. These points can be seen
as Discharge 001 and 002 in Figure 2. Both are located at some distance from
actual operations. This distance means that the discharges enter the largest
water body in the area where dilution is greatest. Impacts of these
discharges can be better absorbed by the larger Pamlico than Jacks, Jacobs,
or even South Creek. NCPC discharges will be decanted from the clay pond at
001. At 002 the discharge will include mill pond water and excess mine
depressurization water when the mine pumps are operating but the plant is
not. These discharges will meet all State and Federal standards.
This section of the manual dealing with waste water discharge will be
expanded to include more detail on these discharges when the company gets
into operation. Until then, the discharge points are releasing only rain
water which falls in the plant/mine and clay pond areas during construction.
Even these discharges, however, are controlled and must meet standards. The
standard of most concern with drainage is for suspended solids which the rain
water picks up moving overland, particularly over cleared Iand. The standard
is measured in units which require laboratory equipment but a good guide is
that if an employee observes "muddy" water entering the River at these
discharge points he/she should report it to his/her supervisor and/or the
Environmental Department immediately.
-10-

Use and Disposal of Deleterious Substances
During construction, the substances of most concern for proper
disposal include, but are not limited to: fuel, oil and grease from any
source (including heavy equipment changeout) , other lubricants, paints and
other coatings, and solvents. None of these substances are to be disposed of
on NCPC property by NCPC personnel or contractors working for NCPC. They are
to be contamarized and carried to the appropriate land fills.
During operation, other substances such as reagents will be itemized
in this manual in addition to those listed above.
An NCPC or contracted employee should consult with the Environmental
Department prior to disposal of any substance of a questionable nature.
-12-

Education and Communication
Meetings - Since awareness and attitude by employees will be
essential to NCPC in ensuring protection of the environment, a related series
of activities will be a regular part of the company's environmental program.
Quarterly environmental awareness meetings will be held with management
personnel and field crews to make them aware of general and typical
environmental concerns and to acquaint them with environmental regulations
which govern NCPC operations.
The organization of NCPC operations (see organization chart in
Appendix C) is such that the following categories of activity might impact
the environment. These are, as follows:
I. Mining
2. Engineering
3. Maintenance
4. Construction
5. Beneficiation
6. Calcination
Regular employee safety meetings within these departments will also
include specific discussions regarding environmental matters or areas subject
to environmental regulations. Subjects to be discussed may be provided by
the Environmental Department and can include such issues as the wetlands and
estuarine waters regulations, air emissions, waste water discharges,
groundwater protection, mining and reclamation programs.
-13-

Presentations
At least one general audio visual presentation will be developed by
the Environmental and Training Departments to inform employees of
environmental concerns and potential problems. It will be updated or
modified to insure that it includes current regulatory requirements.
Landmarks
In areas for which permits are issued for projects in or adjacent to
wetlands, easily identified landmarks have been, or will be, placed so that
employees can observe in the field the wetlands limits established by
agreement between the regulatory agencies and NCPC. The Environmental
Department, working with planning and operations personnel, will continue to
clearly mark jurisdictional limits determined during onsite visits by
representatives of the regulatory agencies. These limits will be marked on
maps drawn for use in project planning and construction.
-14-

Communications with Contractors
Because major portions of the work NCPC carries out adjacent to or
within wetlands/waters is actually performed by independent contractors, key
contractor personnel from supervisory to project management level must follow
the appropriate procedures in this policy manual. Key contractor personnel
from supervisors to project manager, whose work potentially affects
wetlands/waters will be given the audio visual presentation on wetlands,
waters, and regulations. They will be given specific reporting instructions
in case of incidents. As part of the established NCPC bidding procedure,
each bidding contractor will have a pre -bid conference and site visit (where
appropriate) with a representative of the Environmental Department to
familiarize himself with the environmental regulations which may apply to his
performance and to the kinds of potential problems associated with the work
or area.
-1s-

Communications with Regulatory Agencies
In order to provide an opportunity for representatives of the
regulatory agencies to comment on proposed activities, meetings will be held
with appropriate members of these respective agencies on at least a quarterly
basis until NCPC construction activity gets fully underway. At that time,
meetings will be held monthly. Many of the meetings will involve onsite
visits to allow for determination of the applicability of regulations.
Members of NCPC's Environmental, Mining, Plant, and Maintenance Departments
may participate in the visits.
Update
The Environmental Protection Program will be reviewed at least once a
year and modified as necessary in order to insure full compliance with any
permit conditions, laws or regulations.
21-T

Waters and Wetlands Project Procedures
Engineering Research and Development -- To insure that
construction projects and operations will not be harmful to areas subject to
environmental regulations, all new construction projects or modifications to
existing or in -place projects that potentially affect waters and wetlands
will be reviewed and approved by the Environmental Department before
construction is authorized. Drawings for such work will have an approval
block and the plans will not be finalized nor used to initiate work until the
Environmental Department has initialed this block. The following procedures
will be followed:
1) The originating department will determine if any
project is potentially in or near any water and wetlands,
including but not limited to, the following waterways,
their tributaries, or adjacent wetlands:
a)
Pamlico River
b)
Durham Creek
c)
Porter Creek
d)
South Creek
e)
Whitehurst Creek
f)
Jacks Creek
g)
Jacobs Creek
h)
Drinkwater Creek
i)
Tooley Creek
j)
Lewelyn Creek
k)
Sibyl Creek
1)
Hudles Cut
-17-

2) If the project lies in one of these areas or if
there is a question that the area may be a water
or wetland area, or affect these, the Environmental
Department will be notified.
3) If a project is already permitted, it is the re-
sponsibility of the department carrying out the
work to do so in a manner that is consistent
with the permit, thus department personnel must
be thoroughly familiar with the involved permit or
permits. If a permitted project is modified in the design
or construction phase, it is the responsibility of the
department personnel doing the design, redesign,or preparing
to construct, to notify the Environmental Department which
must then seek the required modification authority.
4) For a new project, the Environmental Department will make
an initial determination if the area is subject to regula-
tions for the activity proposed. If there is any question,
the Environmental Department will request an on -site
conference with representatives of the Corps and/or
OCM, or other responsible agencies. This may take
from several days up to two weeks to arrange.
_18-

S) If the Department's initial evaluation or consultation with
regulatory personnel Indicate the need for a permit, then
the Environmental staff will advise the originating
department as to the information required to file any
permit applications. The Environmental Department will
complete the application package and submit it to the
proper review agency.
6) During processing of a permit application, staff from
the originating department will participate in dis-
cussions with the review agencies to insure that
permit conditions are reasonable and acceptable to
the Company and to assure that responsible managers
are familiar with permit conditions.
7) Upon the receipt of a permit, the original will be filed
with the Environmental Department and a copy will be provided
the department responsible for the project. All restrictions
will be noted by the Department responsible for carrying
out the project and the responsible manager will initial the
permit. If the originating department feels the permit
conditions are too restrictive or cannot be achieved, they must
notify the Environmental Department immediately so that appeals
may be started. No work can be started until an_acceptable^
permit is received.
-19-

8) When the
permit is
accepted, any
limitations shall be
observed
to insure
full compliance
with permit conditions.
9) Specific wetlands and/or waters which are permitted or other-
wise authorized to be impacted must be clearly staked out or
flagged by the Environmental Department prior to commencement
of work. In these specific areas, the Environmental Auditor
or his designee mast be on site when work commences and remain
as long as is appropriate to the project.
Maintenance and Activities - Daily maintenance activities
conducted by maintenance or operations personnel are subject to the same
procedures as described for construction and operations activities. They
shall not impact in any harmful or unlawful way on areas subject to
environmental regulations and/or permits. All major, non -routine,
maintenance projects which could have environmental impacts will be reviewed
in advance by the Environmental Department to insure proper consideration of
environmental concerns. Such major projects will be inspected by members of
the Environmental Department no less frequent by than once a week and as
often as necessary to insure full compliance with any applicable regulation
or permit condition. Written reports will be prepared by the Environmental
Auditor and kept on file in the Environmental Department.
-20-

Waters and Wetlands Incident Procedure
This is a procedure designed to confine excavation and fill
activities to permitted areas as required by Federal and State laws and
regulations. Every effort should be made to insure compliance with these
laws and regulations and to immediately stop any action which may be in
violation of them while providing prompt notice to appropriate authorities.
To accomplish this goal the following procedure has been established.
Z) When any employee sees what he/she believes to be
the placement of fill or the excavation of wetlands
not in keeping with this policy, he/she should
immediately notify the Environmental Auditor or the
Environmental Department and the work stopped if it
Is a violation. Phone numbers for emergency
contact are provided in Appendix A.
2) When notification is received, an onsite inspection will
be made immediately by the Environmental Auditor or designee
and an incident report will be prepared as soon as possible.
3) If it is determined a violation of regulations or permit
conditions has occurred, the responsibility for further
evaluation and control of the problem lies with the
Manager of Environmental Affairs (or his designee). No
action will be taken without consulting with that person.
-21-

4) Emergency action to prevent further damage to
waters and wetlands, such as shutting off culverts
or erecting sediment fences downstream from a
spill may be taken by the project supervisor on
site, if considered appropriate.
tir
5) Notification of State or Federal regulatory
agencies will be done by the Environmental
Department, All questions regarding the
incident should be referred to the Environ-
mental Department.
6) An incident report will be completed and filed
by the project supervisor and placed in the
files of the department involved in the accident.
A copy of the report will be forwarded to the Environ-
mental Department.
7) In the event of an incident which impacts on areas
subject to waters and wetlands regulations, cleanup
should not be started without approval of the Environ-
mental Department which must consult with the Corps
of Engineers and the Office of Coastal Management. I ,
-22-

Waters and Wetlands Project Inspection Procedure
To Insure full compliance with regulations or permit conditions, all
active projects including drainage Into or near waters or wetlands will be
inspected according to the following procedure.
1) The project area will be inspected daily by the
Foreman in charge. If the project is operating
more than one shift, each shift Foreman will
inspect the project. Items to be observed should
include:
a) Visual inspection of any control system to
see if the systems are working properly.
b) If sediment fences are required, check to
see that they are in place and not filled with
silt, that they are not not undercut, or being
by passed.
c) If fill or spoil material is being placed,
check to see that all material is being
retained within the permitted or planned area.
-23-

2) The Environmental Auditor will establish and
perform an inspection program for all active
waters and wetlands projects. All construction
projects which might impact the environment will
be inspected by the Environmental Auditor or
designee at the initiation of the work and at
least three times during the week. Written reports
will be prepared by the Environmental Auditor and
kept on file in the Environmental Department. A
copy will be forwarded to the project or department
management routinely. If the report notes problems
which require attention, immediate or otherwise, the
report will document these, note what field discussion
with supervisory personnel was held and what action was
agreed to or recommended. These exception reports will
be forwarded to management as soon as possible. The
Manager of Environmental Affairs will inspect the site
at least twice each week.
3) After the start of a significant rainfall, an inspection
shall be made by the project foreman to insure that sedi-
ment control systems are operating properly. The timing
and number of these inspections will depend upon the amount
and direction of the rain event. If there is any question
about the operation of a sediment control system, the foreman
shall arrange for an immediate inspection by the Environmental
Auditor or designee.
-24-

4) No project in or around waters and wetlands
with potential to affect these areas in the
event of heavy rainfall Is to be left totally
unattended for more than 48 hours even on weekends.
Such projects must be made as secure as possible
both overnight and over weekends and holidays.
5) Control structures such as flashboard risers will
be left in their secure position if they are to be
unattended for more than one eight hour shift.
Even during such an eight hour shift provision
must be made to fully board up the system in the
event of a significant rainfall.
6) If any condition which violates permit conditions
or regulations is observed during any inspection,
the activity will be stopped immediately by the
foreman in charge of the work. The cause of the
problem will be determined If it is not readily
apparent.
-25-

7) If any other Department Head or Manager observes any
activity which he believes is being conducted in a
manner which may cause an impact on waters or wetlands
he should stop the project immediately and notify the
Environmental Department.
8) Once a project has been stopped In accordance with
paragraph 7) and 8) above, the project can only be
resumed with the written authorization of the Manager
Environmental Affairs (or his designee).
9) Failure to stop an activity upon receipt of instructions
in accordance with this procedure will result in dis-
ciplinary action. Disciplinary actions may include:
a) Oral reprimands
b) Written reprimands
c) Suspension from work without pay
d) Termination of employment
10) Failure by an employee to promptly report an activity
which is recognized to be a violation of this policy
or of regulations or permit conditions will also re-
sult in disciplinary action.
-26-

Environmental Incident Procedure
Responsibilities - Field Environmental Auditor
In the event of an environmental incident the person or department
detecting the Incident will report it to the Environmental Auditor who will
alert the Manager of Environmental Affairs. Telephone notification of
incidents will be received by the Environmental Department during the hours
of 8:00 a.m. to 4:30 p.m. During the evening shifts and on the weekends and
holidays, tails will be made to the person on call. That person will then
follow this procedure.
1) They should go immediately to the area where the incident
has occurred to evaluate the problem. If possible this
evaluation should be made with the Foreman of the department
responsible for this incident. An estimate of the severity
of the problem should be made so that this information can
be relayed to the appropriate supervisory personnel.
2) They should notify the Manager of Environmental Affairs as
soon as the inspection is completed. if this person is
unavailable, they have authority to contact any supervisory
personnel necessary, up to and including the General Manager.
-27-

3) Upon notification, the Environmental person on call will
instruct the field personnel as to what additional actions
should be taken. If the Environmental person on call feels
that all necessary corrective actions are underway and the
problem Is not a major one, he/she may instruct the personnel
to continue to monitor the activities and to report periodically.
However, if there is a major incident, the Environmental person
on call should report to the plantsite to survey the pr )blem
personally.
4) The Field Environmental Auditor will complete an incident report
for all Incidents reported. This report will be submitted to the
Manager of Environmental Affairs and the Manager of the Department
in which the incident occurred and the President of NCPC.
-28-

Environmental Incident Procedure
Responsibilities - Manager, Environmental Affairs
In an environmental incident involving waters or wetlands (or a
chemical spill), the Manager of Environmental Affairs has the responsibility
of notifying other management personnel and Federal and State regulatory
agencies. The following procedures outline these responsibilities.
1) When the Manager is notified of an incident he/she should
determine what additional actions should be taken. Instructions
should be given to field personnel if further actions need to he
taken. This might involve continuous monitoring of the problem or
corrective actions that the field personnel might assist with.
2) The Manager should evaluate the situation and decide if addition
notification of management personnel is necessary. Where a minor
Incident has occurred and has been contained, additional actions
or notification should normally be unnecessary. If the situation
appears serious, the Manager should report to the plantsite and
make a personal evaluation of the problem. if a major incident
has occurred, the Manager should at this time notify the appro-
priate Operations Manager and give an appraisal of the situation.
-29-

3) For some incidents, it may be required that certain Federal and
State regulatory agencies be notified. This notification will
be made by the Manager of Environmental Affairs.
4) The Manager will prepare a complete report for management evalu-
ation. This report should contain a complete investigation of the
Incidents leading up to and causing the problem and at, corrective
actions. it should also contain suggestions for the prevention
of further incidents. A copy of this report will be filed with
the Manager of the Department in which the incident occurred and
with the President of NCPC.
-3o-

Environmental Ins ection Report
DATE: TIME:
WORK SITE
Permit Number(s)
Permit(s) Available at site? Yes No
SITE CONDITIONS
WEATHER CONDITIONS
WORK UNDERWAY
PROBLEMS OBSERVED
CORRECTIVE ACTION RECOMMENDED/AGREED TO/TAKEN
WORK SUPERVISOR:
SIGNED:
-31-

Managers
R. W. Grosz
President
North Carolina Phosphate Corporation
H. M. Breza
Manager, Mine
E. E. Walker
Manager, Customer E Public Relations
R. P. Ayres
Manager, Environmental Affairs
-32-
J. L. Wester
Manager, Operations
M. V . Davis
Manager, Maintenance
W. D. Tripp
Manager, Administration
N. R. Guest
Manager, Calcination
L. D. Williamson
Manager, Beneficiation

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NORTH CAROLINA DEPARTMENT OF NATURAL
RESOURCES AND COMMUNITY DEVELOPMENT
Date
CTO-m:
Remarks:
ACTION
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❑ your caw nw . PVaata
p Note and see ma about this
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❑ News information for ma to mphy
❑ Par your request
p PNaae answer, with copy to me

APMnRANnI@U
TO: Jim Simons
Charles Gardner
FROM: Rudy Smithwick(ZS
Washington Regional Office
DATE: November 20, 1984
SUBJECT: Brown Mill Run at NCPC
Enclosed for your information are two photographs of the Brown Mill Run
violation at NCPC.
Note the sediment which is easily visible in this gut.
RAS:mgr
Enclosures: 2

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M srA7c
."k
North Carolina Department of Natural
Resources & Community Development
James B. Hunt, Jr,, Governor James A. Summers, Secretary
October 23, 1984
Mr. R. W. Grosz, President
N. C. Phosphate Corporation
P. 0. Box 82
Washington, NC 27889
Dear Mr. Grosz:
OFFICE OF
COASTAL MANAGEMENT
David W Owens
Director
Telephone [phone]
My staff has advised me that H.C. Phosphate Corporation has recently
been found to be in violation of the Coastal Area Management Act and the
Dredge and Fill law as a result of the recent filling of a portion of two
tributaries of Durham Creek and an area of Pamlico River. I understand
the filling occurred due to the release of sediments being held within a
clay pond system and a failure of a water control weir installed on the
discharge canal from that clay pond system.
Unfortunately, we have had several incidents of this type over the
past few years. Our records show that N.C. Phosphate Corporation was
charged a similar violation in June, 1981 due to the lack of effective
sedimentation and erosion control measures at the company's barge
facility on South Creek. In July, 1981, there was a problem with
sediments entering Durham Creek at the clay pond site. In June, 1983,
there was a problem with sediments contained in a settling pond being
released into a tributary of Jacobs Creek. In August, 1983, there
were erosion problems occurring along the north side and west end of the
company's barge slip, causing sediments to enter South Creek. All of
these incidents had adverse environmental impacts on the coastal waters
of North Carolina.
It is my understanding that several of the problems I have pointed
out which have occurred on N.C. Phosphate property have been corrected
to the maximum extent possible. However, there are also impacts which
have occurred which cannot adequately be restored and will result in
either long term or permanent loss of productivity of the affected
areas. These violations must be handled through our established
enforcement procedures.
As your phosphate mining operation continues and expands in Beaufort
County, it is important that we establish a mechanism to assure the
prevention of these types of problems. Resolving frequently occurring
problems associated with this development requires a great deal of staff
time and expense to be committed by both the state and your company. I
think you will agree that such a situation is notin the best interest of
either of our programs.
P 0 Box 27687 Raleigh, N C 27611-768'
A^ 4CIi, Fmk--, ,,

F
Mr. R. W. Grosz
r October 23, 1984
Page Two
I believe that future problems can best be avoided through effective
communications between our staffs. This will contribute to a better
understanding of North Carolina Phosphate's responsibility to ensure that
construction and operations associated with your development will receive
careful monitoring by company staff to prevent the types of violations
noted above. I believe a meeting between the company, our state staff,
representatives from the U.S. Army Corps of Engineers, and other appropriate
agencies to discuss these matters would appear to be appropriate at this
time. I hope you will agree and contact me so that we may make arrangements
to meet in the near future.
I greatly appreciate your consideration of this matter. We look
forward to working with N.C. Phosphate to see that the vitally important
estuarine resources of North Carolina are adequately protected as your
work continues.
Sincerely,
avid W. Owens
DWO:cn
cc: Preston Pate
David Gossett
Terry Moore
Milan Muzinich
Ofeve Conrad
Billy Ray hall
Charles Hollis

MRMOPANIMIM
TO: Charles Gardner
THROUGH: James D. Simons
Harlan Britt
FROM: Floyd Williams
DATE: February 1, 1
SUBJECT: February 1,/1985, meeting in field office with NCPC
Today, NCPC personnel (Rusty Walker and Page Ayers) met with the Division
of Coastal Management and me. This meeting was held to discuss a number
of items of interest to both the state and to NCPC.
Mr. Walker discussed the present status of NCPC, which I will briefly note:
1. All comments have been received on the environmental
monitoring program, and this program is now being
implemented. Mr. Nat Parker has been assigned the position
of Environmental Auditor.
2. The board of directors of the Williams Company met this past
Monday and gave NCPC notice to move full speed ahead. They
will start construction of a demonstrator calciner plant
within a month.
3. We discussed the past violations and feel that NCPC will
stay on top of things, which should minimize future problems
with our department.
We are planning to meet with NCPC bimonthly in an effort to create a line of
better communications.
FRW:mgr

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TEXASGULF, INC.
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NCPC(D
AN AGF IC0 MINING tAir,'F' NV
R. W. GROSz
President
Mr. Steve Conrad, Director
Resource Planning s Evaluations
Department of Natural Resources and
Community Development
P. O. Box 27687
Raleigh, North Carolina 27602
Dear Mr. Conrad:
October 22, 1984
In the past three months, NCPC has had several Incidents of off site
sedimentation resulting primarily from construction activity at our clay pond
site at Core Point. Two of these incidents involved requests by your office
and the N. C. Office of Coastal Management (OCM) to restore the affected
areas. These included sedimentation into a tributary of Brown Run (itself a
tributary of Durham Creek) and sedimentation into the Pamlico River which
resulted from a failed weir at our NPDES discharge point.
These incidents have precipitated action by NCPC in four areas
Including restoration, modification to drainage control, the formalization
of environmental procedures and training, and the creation of a new position
In the company designated "Environmental Auditor." The purpose of this letter
Is to summarize our present situation in these action areas and to submit for
your office to review a draft version of our environmental control policy and
procedures manual which is enclosed. We are also submitting permit modifica-
tion requests to the Corps of Engineers and N. C. Office of Coastal Management
as explained below.
Restoration
Brown Run Tributary - One of NCPC's major projects during the 1984
construction season was the removal of four culverts which have been providing
drainage during construction for the Impounded clay tailings area at Core
Point. The culverts were being removed in order to end the potential for
significant sedimentation through these structures. In order to accomplish
this, the settling area behind each culvert had to be drained to enable heavy
equipment to bring the area up to working elevations (+ 10' MSL) in prepara-
tion for replacing the culverts with the dike material.
IHORI H CAROLINA PHOSPHATE CORPORATION
P. O. Box 398 • Highway 306 N. • Aurora, North Carolina 27806 a 919/322-5151

Mr. Steve Conrad
October 22, 1984
Page Two
On the last day of the draining phase, sediment fences were erected in
front of the culverts in order to effect as free drainage as possible while
still protecting downstream areas against rainfall initialed sedimentation.
That night, the area received something between 3.5 and 8.5 inches of rain.
This event washed approximately 50-75 cubic yards of sediment into a tributary
of Brown Run, which is a tributary of Durham Creek. The sediment so released
settled in an area approximately 600 feet long, varying in width from 2 ft. to
20 ft. and varying in thickeness from 3 ft. to one-half inch.
After plans for restoration were reviewed by OCM and Corps of
Engineers personnel, removal of this material was initiated with a 12 hp
gasoline powered pump moving a water/sediment slurry approximately 500 feet
over the clay pond dike back into the clay pond. Clear water decant release
was effected at the NPDES discharge point for the clay pond, approximately 3
miles away. The additional 20 feet of head necessitated by the completed dike
caused too much back pressure on the pump, causing it to leak oil. Therefore,
an 18 hp pump was purchased on an emergency basis and was put into service.
A pump mechanic and 3-man "dredging" crew are working to complete the sediment
removal by the end of October.
Pamlico River - NCPC's NPDES permit for the discharge of clear
water decant from settled clays requires measurement of the quantity of water
released. The method chosen to accomplish this was the installation of a
large concrete retaining weir with a calibrated overflow notch in the decant
ditch at the Pamlico River discharge point.
The rains associated with Hurricane Diana (approximately 14.5 inches
In five days, according to a television weather spotter located on Core Point)
resulted in a failure of the weir structure even though the weir was designed
to handle such conditions. The ditch sides supporting the structure failed
due to a thin layer of clay near the bottom of the weir which prevented water
from flowing properly to a gravel drain provided under the concrete weir
downstream apron. The earth surrounding the concrete sides of the weir became
saturated, unstable, and finally gave way under the pressure head supplied by
the retained rainwater (see Attachment A).
This sudden release carried not only the failed soils, but also a
portion of the ditch bottom upstream of the weir out and deposited these
materials on the wetland area and In the Pamlico River immediately in front of
the weir. About 2000 cubic yards of sand were carried out.
Plans were developed for removal of the sediment material in
conjunction with the N. C. Office of Coastal Management and U. S. Army Corps
of Engineers personnel, incorporating a combination of a dragline, "pans," and
a final grading machine. The dragline walked on mats to place itself offshore

Mr. Steve Conrad
October 22, 19134
Page Three
to dig the sand out and reestablish pre -accident elevations. The excavated
material was placed in pans for transport to an upland borrow pit. After the
removal of sand from the River was complete, a grading machine scraped
deposited sand off of the wetland and upland areas, down to pre -accident
elevations. This work was completed on October 12. It has been field
Inspected and approved by OCM personnel.
Improved Drainage Control
NCPC's drainage control program during construction has been reviewed
in concept and implementation since the recent sediment problems. We found
that the systems in place including ditches, sedimentation ponds, and sediment
fences, were doing a good job for normal rainfall events. We also found,
however, that we needed to provide extra safeguards for the possibility of
rainfall events in excess of 100-year storms since we have experienced two of
these in the past three months.
In the past three weeks, we have completed removal of the four
culverts in the clay pond dike and replaced the culverts with dike material.
This was the work we were undertaking at the clay pond (prior to our problems)
to avoid off site sedimentation problems. With removal of the culverts we
have eliminated a major problem potential. Drainage from the clay pond area
is now routed through a series of ditches and ponds and released from our
NPDES discharge point. It currently flows through a series of three new rock
dams in the system to slow velocity and provide retention time for sediments
to fall out. As explained below, we are in the process of final design of a
replacement weir to replace the one that failed in our second major incident.
Once the new weir is in place in an estimated two months, it will provide
further retention time and give us additional control of the runoff through a
flashboard system which is a part of the weir.
Other areas of new work to improve our drainage control are summarized
below.
- We have cleaned out and have expanded two sediment ponds. One of
these was doubled in size since it drains a portion of the pit
opening area which cannot be completely seeded.
- We have seeded and mulched about 15 acres Including drainage
ditches and slopes of sediment ponds to reduce their loading.
- We have stabilized or redirected drainage from problem
areas on the plant site.

Mr. Steve Conrad
October 22, 1984
Page Four
- We have placed double sediment fence lines at 4 locations where
such extra precaution was appropriate.
The Weir Failure and Replacement and Permit Modification
As mentioned earlier, enclosed as Attachment A is a report on our weir
failure. Enclosed as Attachment B is a request to modify our Corps and CAMA
permits to allow weir replacement. The design of the replacement weir system
Includes a proposed method to control runoff to acceptable water quality
standards during installation of the weir. We have discussed these plans and
proposals with field personnel from the N. C. Land Quality Division, Water
Quality Division, Office of Coastal Management and Corps of Engineers.
Included in this communication is a request to modify our permits to
Increase the width of our NPDES discharge canal 001. The location point of
the discharge remains the same. The discharge canal is in place but is wider
than shown in the typical cross section drawing in the permits. This
apparently happened when Ardaman Engineering Company did the final design of
Phase One of our clay pond construction. They felt that in order to maintain
the flow rate through the canal at the rate suggested by permitting agencies
of 2 feet per second, the wider ditch was required. Our engineering
department adopted the recommendation and submitted the detailed Phase One
construction plans from Ardaman to the environmental department to submit to
the Land Quality Division for review and approval. It appears in retrospect
that the reason neither the Office of Coastal Management nor the Corps were
specifically asked to modify the permit to reflect the wider canal is that
the environmental department did not realize that the final canal design was
different than that permitted. When the Land Quality Division signed off on
the detailed plans and stated that all appropriate state agencies had reviewed v
and approved the plans, NCPC went to work. It was a failure in communication
between two NCPC departments. The new NCPC environmental procedures manual
enclosed In draft form is designed to eliminate the potential for this kind of
miscommunication to occur again. We have checked other projects such as the
other discharge canal more completely and verified that they are constructed
as permitted so the communcation problem was related only to the clay pond
canal width. The manual requires more formal communications between the
departments prior to the initiation of new design, redesign, construction or
operation of any NCPC work or facility.

Mr. Steve Conrad
October 19, 1984
Page Five
Formal Program - Policies and Procedures
Attachment C Is a draft of our newly adopted environmental procedures
manual designed to improve communications, educate, and prevent environmental
Incidents resulting from NCPC activities. It is submitted for your review and
comment. The procedures spelled out are being implemented now. Both the
enclosed manual and the procedures are subject to change with input from your
office. We are preparing an audio-visual training film which will be sub-
mitted to your office for review within a month. It should be in place by
mid -December unless reviewers have substantive changes. As explained in the
manual, It will be required viewing by all employees and contractors doing
work which might affect wetlands or waters.
As part of the company's overall program, a weekend and holiday
Inspection program has been implemented which insures that active project
areas are inspected at least daily and provide procedures to respond through
on -duty management In the event of problems.
Environmental Auditor - A New Position
To bring together NCPC's environmental policies and procedures and
Implement same in a more formal program, the company has created the position
of Environmental Auditor. It will be an exempt level position reporting
directly to the Manager of Environmental Affairs. Because of his authority to
stop work and the responsbility this entails, the position will also have
direct reporting responsibilities to the President of NCPC where the situation
warrants.
The Environmental Auditor will perform duties as outlined in the
manual enclosed as Attachment C. He will help develop and implement the
environmental training program and be directly responsible for monitoring not
only NCPC construction and operations activities as they affect the water and
wetland areas but also the work of all contractors from job bidding through
Job completion.
The company has filled this position with a trained mining engineer
with 15 years of experience in the mining industry. Nat Parker is currently
undergoing training with the NCPC Environmental Department in wetlands
regulations and sedimentation and erosion control policies and regulations.

Mr, Steve Conrad
October 22, 1984
Page Six
The State and Corps will be asked to work with NCPC on this training by going
Into the field with the Manager of Environmental Affairs and Parker to review
procedures for determining regulatory jurisdications, discussing standard
operating procedures both of NCPC and the agencies, and initiate personal
communications channels.
Parker was selected because of his experience and knowledge of earth
moving and engineering practices and requirements and his experience in
developing and implementing NCPC's safety training program. Because of his
engineering experience and knowledge, Parker will only fill the position an
estimated six to nine months. This is expected to be sufficient time to
establish both the training and procedures within the company and the
communications channels with the agencies in this specific area. Once
established, Parker will train a replacement who will take over an In -place
program. Parker will return to the engineering department where his temporary
but Intensive responsibility for environmental matters should serve NCPC
well.
We would appreciate a meeting with your office to discuss the items
covered In this letter and attachments at your convenience.
Sincerely,
�Yte'7
R. W. Grosz
RWG:gm
Enclosures

0
ssnie�"•� DIVISION OF
,ir.;..,.. North Carolina Department of Natural RESOURCES
Resources &Community Development stepnenG°,fa p °'°`
James B. Hunt, Jr., Governor James A. Summers, Secretary re;rpr,u'•e9', 72's
October 9, 1984
Mr. Rusty Walker
N. C. Phosphate Corporation
P.O. Box 398
Aurora, North Carolina 27806
Dear Mr. Walker:
Thank you for your letter of September 28, 1984 indicating the
measures being taken to correct the mining permit violations. My field
personnel have also informed me of your efforts.
I am happy to learn that you have already taken measures to correct
the violation and that future preventative measures will be taken.
We look forward to receiving your plans for preventative measures.
SGC/JS/cj
cc: Floyd Williams
Sincerely,
Stephen G. Conrad
Director
/ r
'7

NCPC(D
AN ?".GRICO t.1IN1W_ '_6P2,PAej e
Mr. Stephen G. Conrad, Director
Division of Land Resources
NCDNRCD
P. O. Box 27687
Raleigh, North Carolina 27611
Dear Mr. Conrad:
September 28, 1984
The violation of our mining permit referenced in your letter of September 14th
resulted from a combination of a bad judgement call that it was safe to remove flash -
board risers unattended overnight, and unusually heavy rains.
For the record, I need to explain that we did place sediment fences in front
of the culvert when the risers were removed in keeping with recommended procedures
and good practice. Obviously, such limited measures could not deal with the flows
resulting from the torrential rains we experienced. I note this not as an excuse but
to make sure you know that we did not Ignore good practice altogether. We did pro-
vide a "mechanical barrier" as our permit requires to prevent sediment discharge.
We recognize, however, that it was our responsibility to insure that measures were
adequate. The measures we took would only have been adequate for a normal rain
shower.
As you know, since the incident referenced in your letter of September 14th,
we have had another incident involving the loss of a weir and other problems associ-
ated with Hurricane Diana. We are evaluating our entire environmental protection
program with special emphasis on sedimentation and erosion control. This evaluation
will result in much more formalized procedures including education and training for
all appropriate employees on the values of wetlands (much like safety programs now
for common industry) . We will adopt policies providing better guidance to employees
on how to protect these sensitive areas Including, for example, a policy on flashboard
risers. Our program will include weekend and holiday monitoring of the mine, plant,
and waste disposal sites and a series of physical steps, some of which are already in
place, to shore up our existing sedimentation and erosion control facilities and systems.
We will be submitting for your staff's comments our protection manual and
training program and we are consulting with your staff in the field concerning the
physical steps to be taken. Drafts of these plans will be submitted within the 30
days specified in your letter.
Ni-JV_I H C AROLINA PHOSPHATE COPPORAT ION
P. O. Sox 398 0 Highway 306 N. *Aurora, North Carolina 27806 • 919/322-5151

r I N
Mr. Stephen G. Conrad Page Two September 26, 1964
I am enclosing a separate description of the Brown Run restoration plan we
have developed and partially implemented with input in the past two weeks from your
office, the Army Corps of Engineers, and the Office of Coastal Management. You
will be receiving another restoration plan shortly for our spill resulting from the loss
of the weir. We have already worked with your staff on this as well.
We very much regret that our recent policies, procedures, and facilities did
not provide the kind of protection weather events required to avoid the problems we
have experienced in the past two months. We are working hard to repair damage
done and prevent future problems.
Sincerely,
Ru ty iker
for R.rosz
RW : gm

ma 16
PLAN FOR REMOVING SEDIMENT FROM TRIBUTARY
OF BROWN RUN, BEAUFORT COUNTY, NORTH CAROLINA
NCPC plans to use a Corman Rupp 311 pump model number 13A-K 301P.
-this pump will be mounted on a float and is equipped with a 12 horsepower
jasoline engine, a 3 inch Suction hose and a !t-inch discharge hose. The maxi-
rrlum discharge distance will be 600 feet as we begin at the area further from
the existing dike and work Our way upstream. The discharge will be inside
our existing dike with Mly- uutfall of clear water taking place at our permit
discharge 001, approximately 3 miles away. This system will operate at 260
GPM handling G,$ Tph and will require approximately one week to completely
remove the sediment if >, e Rio not have excessive downtime.
Initially, the attvnipt will be made to pump over the new dike section
ri+)w in place, into thc) IlL;1)c1 area. If it is found that the resultant head is too
,Treat, either a notch will he cLlt in the dike into which to lower the discharge
lint,, or a bOOSter I)crrlll) %trill be utilized.
f'rrrchase of iLmie of the necessary materials is required. The items
"hotIld be on site by hiofid,ly, September 3, 1984. This will allow the protect
I- Begin 115 early as S,,ptomher 11, 1984. Presently, a framed removable so -di -
fence is in place Wr ,t downstream from the point at which the sediment
r(-rrroval operation must ,)L'riirl. This fence is designed to prevent sediments
from advancing} further clrrwliytreanr, yet allow easy entrance and exist to the
"ystenl fr'c+nl Durham C:r a-, k.
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er , — ,nlhsiwe� -- ._ ..�—

S Ardaman & Associates,lnc.
Cw1mill'ints In Soils, Hydm('Jeology,
Foiind,itions and M,3ttfi iT lls estiny
North Carolina Phosphate Corporation
Post Office BOX 398
Aurora, North Carolina 27806
Attention: Mr. Michael Breza
September 24, 1984
File Number 79-095
Subject: Inspection and Engineering Evaluation of Weir Failure at Decant
Ditch for the Proposed Initial Settling Area, Aurora, North
Carolina
Gentlemen:
As requested, Mr. Bill Jackson of our office made a site visit on September 19,
1984 to inspect the above referenced decant weir which recently failed during
heavy rains associated with hurricane Diana. This report presents his findings and
our conclusions as to the cause of failure.
The following key points were observed during that visit:
• The southernmost embankment beneath the weir structure was eroded,
or washed away resulting in the complete undermining and collapse of
the concrete weir base on that side. The vertical portion of the
overflow weir was still intact.
• The weir structure did not appear to have been overtopped. A high
water mark on the structure indicates that the water level prior to
failure was only a few inches above the design weir crest elevation of
12.0 feet (NGVD).
• Some erosion was noted on the northern embankment immediately
adjacent to the upstream and downstream edges of the stucture. This
erosion apparently resulted from rainfall runoff which caused an erosion
gully on the embankment slope that was, in spots, as deep as the "turn-
down" portion of the concrete weir structure.
0 A very thin layer of gray sandy clay (approximately 3 to 4 inches thick)
.r was noted in the iorthern embankment of the ditch bottom on the
upstream side of the weir. This layer was approximately 3 to 4 feet
SEN ,S below the design ditch bottom elevation of +7 feet (NGVD). A hand
auger boring drilled immediately downstream of the weir revealed a
1M1E' „ 's similar clay layer at approximately the same elevation.
Based on these observations and a review of design considerations, we are of the
opinion that, because of the clay layer, the gravel underdrain was not effective in
controlling seepage beneath the structure. Failure was caused by subsurface
,.i003,{L"i,1.i 313;19 P!��n
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North Carolina Phosphate Corporation
File Number 79--095 -2-
erosion, i.e., "piping" of soil from beneath the downstream toe of the southern
embankment. The thin clay layer observed in the field appears to be a continuous
layer located just above the drain elevation. At this location, the clay layer will
retard downward seepage through the more pervious sand and effectively isolate
the gravel drain. The attached figures illustrate the concepts involved.
Figure 1 shows the results of two test borings performed along the proposed
alignment of the decant ditch. Superimposed on this figure is the location of the
weir bottom. As can be seen, no clay layers were encountered in this boring and
approximately 10.5 feet of relatively clean sand underlies the base of the weir.
Cross sectional and plan view, two-dimensional flow nets shown in Figure 2
illustrate the anticipated seepage flow patterns and the proper operation of the
drain. Grain size distribution curves for the natural ground sands and the proposed
underdrain gravel are presented in Figure 3. The gravel drain was provided with a
filter fabric to prevent migration of and clogging by fines.
Figure 4, illustrates the influence of the observed thin clay layer on
underseepage. The lower permeability clay layer severely retards the downard
flow of seepage to the drain and effectively isolates and prevents it from
controlling seepage as designed. Seepage is forced to flow laterally on top of the
clay layer and exit in an uncontrolled manner at the downstream edge of the
weir. Piping of soil probably started at this point of discharge and progressed
upstream until complete undermining and failure of the structure occurred.
We trust that this engineering evaluation of the weir failure will meet your
immediate needs. We will be glad to assist you in the redesign of the weir, if
desired. If you have any questions or need any additional assistance, please do not
hesitate to contact us.
Very truly yours,
ARDAMAN do ASSOCIATES, INC.
`f
Bill E. Jackson, P.E.
Project En ineer
fhn . Gar anger, h.D., P.E.
pal
North Carolina Registration No. 9046
BEJ:cc
Enclosures
SEP -
is

♦-
AE V
CROSS SecTlorj
+?' GAVEL
R I c- RA P
EL +2� Y 1I
FINE SAND 10.5
CLAYE'`T FING SAND
SCA L.E
PLAN VIEW„
CC40=_ ; I = 2O
PLOW
DESIGN FLOW CONDITIONS
FIGURE Z

0
U.S. STANDARD SIEVE SIZE
- - 4
GRAIN SIZE IN MILLIMETERS
GRAVEL SANp SILT CLAY
COARSE FINE COJAFSL MLDIDM FINK
SAMPLE Q -' LIGHT BROWN + YFLZOW ISH BROWN SAND
FROM WEIR SITE
SAMPLE Q - No, 57 (MARTIN MARIETTA AGGREGATE
USED FOR GRAVEL DRA N
SEN
A G A}NS.I F_ Drs-rpiauT10Ns
F! GVRE

CROSS SECTION
CL..,L-,Y
FLOW
..-_a d•r,C�OOC►%G�.rY-a+n Ka
�A^G.^'r;•f i��aCj
' LAYER RETARDS COWNWARD FINE SA-40
SEEPAGE TO DRAIN
SCA><E : ! _ !O'
CLAY
4s
FRoN Ew
GRAVEL DRAIN
THIN LA,,Y LAYER PRE V E NV
SEEPAGE FROM REACHING
DPA I N
C 65ERVED FIELD CONDITIONS
SCALE: I"= ZOO
FGURE 4

TH-31
20- 1
5-
-Eo-
_ 15 --
-20�_,=T
NM=7
Z txi = 3
P;M=8
11
TH - 32
w
BOTTOM OF WEIR
to
10.5
ti- f
13
-32
BORING LCCATiON PLAN
LEGEND
T1�,I l) LIGHT BROm A�,D GRAY SArIDY CLAY
LIGHT naJwN A.ND SPA- CLAYEY MLDI" TO FI:1E SA',D
-D3 GRAY SILTY CLAY WI71 LENSES OF FINE SAND AND CLAYEY FINE SAND
t-� 14) LIGHT GRAt FINE TO .LIGHTLY SILTY FI'+E SAND
:5) GRAY SILTY-V_DIUM Tj FINE SA;iII WITH SHELL FRAGMENTS
`6 LIGHT GRAY TO BR0'nr. CLAYEY MEDIUM T3 FINE SAND WITH SHELL FRAGMENTS
GRAY SLIGHTLY SILTY TO SILTY MEDIUM TO FINE SAND
' 0 GRAY ZLAYEY MU'Ll, G FINE SAND
0
0 GRAY SANDY CLAY 411m SHELL FRAGMENTS
GRAY M-E IUM TO Fl,:. SVC xITH LENSES OF SILTY CLAY
11 GRAY SLIGHTLY SILTt TO SILTY FGJE SAND, TOPSOIL, ROOTS. ORGANIC SOIL
9 LOCATIGN OF TEST 'MOLE
N STANDARD PEN. RATICN RESISTANCE IN BLOWS PER FOOT
.�. GROUND -ATER LEVEL • '�'
NM NATURAL M015TURE IN PERCENT
rC lryl �
A• 4J
-200 PERCENT PASSING THE NUMBER 200 StcVE
FIGURE. 4

Cf.USZ
Mr. John Parker
Permits Coordinator
Office of Coastal Management
P. 0. Box 27687
Raleigh, North Carolina 27611
Dear Sirs:
October 22, 1984
Mr. Wayne A. Hanson
Colonel, Corps of Engineers
District Engineer
Wilmington District
P. 0. Box 1890
Wilmington, North Carolina 28402
The purpose of this communication is to request modification of NCPC's
N. C. State Dredge and Fill Permit No. 79-76 and U. S. Department of the Army
Permit SAWC076-07-23-025. The reason for this request is to reflect refine-
ments and improvements in the location and design of NCPC's flow measurement
weir at our NPDES permitted clay pond decant discharge point. These refine-
ments are the result of the failure of the weir as installed, and the
opportunity for Improvement which rebuilding affords.
Attached are eight (8) drawings which detail our plans for the
replacement weir. Please accept these drawings and the brief narrative which
follows as request for modifications as shown.
After reviewing our original plans to Iocate the flow measuring weir
at the Pamlico River shoreline, it was decided that NCPC would have better
control and a safer installation if this weir was located at the beginning of
the discharge channel rather than at the river. As shown on ':etch D04-32-813
three rock dams will be installed in addition to the existing two rock darns.
The existing rock dam at the Pamlico River wiU be left in place and
additional rip rap will be placed to prevent erosion (see SK DO-4-32--820).
This dam will serve to slow velocity, hold sediment, and prevent fish from
migrating upstream in the ditch.
Sketch SK DO-4-32-814 shows the placement of the ditch block required
to allow construction of the new weir and the location of this weir. The
block will be installed in the existing ditch to an elevation of +13MSL. NCPC
will use a GIW diesel powered pump to route the water from behind the ditch
P. 0. Box 398 a Highway 306 N. • Aurora, North Carolina 27806 0 919/322-5151

v
Mr. John Parker
Mr. Wayne E. Hanson
October 22, 1984
Page Two
block to a point in the channel downstream of the construction activity. It
should be noted that the three additional rock dams will be installed prior to
Installing the ditch block and pump. The ditch block elevation of +13MSL will
allow six feet of storage in the ditch and low areas upstream as well as
providing four feet of freeboard as a safety discharge in the event of
excessive rains. The pump has a rated capacity of 4000 gpm and should easily
handle the rainfall expected. The remaining sketches show the typical ditch,
the new rock dams to be installed, and the new weir. The weir will have a
flashboard riser to enable NCPC to control discharge from this area prior to
start-up.
As also mentioned in the letter from R. W. Grosz to Mr. Steve Conrad
of October 22, 1984, NCPC is requesting modification of the width of the clay
pond decant channel to the specifications shown in attached drawing s
SK-D04-32-816 from those shown in the original permits on Figure 7. The
fundamental change involves a widening of the ditch from bottom width of 6
feet to 20 feet In order to slow decant water velocity.
NCPC hopes these requests can receive immediate attention because the
1984 construction season is coming to a close and the weir is an integral part
of water control at the clay pond.
RWG.gm
Thank you for your consideration.
Sincerely,
R. W. Grosz

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Introduction................................................................. 2
Waters and Wetlands.......................................................... 4
Activities Requiring Permits in Waters/Wetlands .............................. 8
NPDES- Waste Water Discharge................................................10
Air Emissions............................................................... 11
Use and Disposal of Deleterious Substances .................................. 12
Education and Cormiunication..................................................13
Presentations and Landmarks..................................................14
Communications with Contractors..............................................15
Communications with Regulatory Agencies and Update .......................... 16
Waters and Wetlands Project Procedures...............0.......I.............. 17
Waters and Wetlands Incident Procedure ...................................... 21
Waters and Wetlands Project Inspection Procedure 23
Environmental Incident Procedures - Responsibilities - .................... 27
Field Environmental Auditor
Environmental Incident Procedure - Responsibilities ..................... 29
Manager, Environmental Affairs
Environmental Inspection Report ............................................. 31
Managers Listing............................................................ 32

Introduction
NCPC is committed to minimize the impact of its operations on the
environment and to fully comply with all environmental laws and regulations.
This environmental protection manual provides policies, procedures, and
guidance to North Carolina Phosphate Corporation (NCPC) personnel and
contractors working in and around NCPC property and in or near Waters of the
United States and Estuarine waters of North Carolina (hereafter "Waters and
Wetlands"). These areas are subject to regulations administered by federal
and/or state regulatory agencies. Unauthorized excavation, fill, discharge,
or other activity in these regulated areas is against the law.
All NCPC personnel and contractors working for NCPC must be familiar
Yvith the policies and procedures contained in this manual. Management
personnel in areas of activity potentially affecting the environment must
maintain current copies of the manual.
It is the responsibility of each NCPC employee to assist the company
in _protectin_g the environment. The company's Environmental Department is
directly responsible for the implementation of NCPC's environmental
protection program. The Manager of Environmental Affairs will work with all
planning and operations departments to help insure that environmental
considerations are built into the design, construction, maintenance and
-2-

operation of NCPC facilities. The Manager will be the primary contact for
the Company with the government regulatory agencies. He is directly
responsible for securing permits for and environmental monitoring of all
projects. The Environmental Department will be responsible for all permits
and stop work or cease and desist communications with company personnel and
contractors related to environmental concerns. Names, and home
telephone numbers of key personnel in the Department are provided in Appendix
A to this manual.
This program is adopted, and distributed to all management personnel
this day of 19
-3-

WATERS AND WETLANDS
In order to protect the valuable waters and wetlands within and
adjacent to NCPC property, it is necessary first to recognize these special
environments. Second, It is important to be acquainted with regulations
which the government regulatory agencies have adopted and administer to
define their areas of jurisdiction and protect these areas.
The federal regulations generally define waters of the United States
to include all waters within the United States extending to the mean high
water mark and adjacent wetlands. Under this general description all of the
following major water bodies near NCPC are classified as waters of the United
States.
1)
Pamlico River
2)
Durham Creek
3)
Porter Creek
4)
South Creek
5)
Whitehurst Creek
G)
Jacks Creek
7)
Jacobs Creek
8)
Drinkwater Creek
9)
Tooley Creek
10)
Lewellyn Creek
11)
Sibyl Creek
12)
Hudles Cut
QM

These creeks also have small tributaries, some of which are named
while others are not. In addition to those listed and their tributaries,
there are many other smaller tributaries. Figure 1 provides an overview of
most of these areas within NCPC's initial mine/plant area.
Obviously, nearly all of the water areas located on or near NCPC are
covered by the federal regulations. The Company's man-made wetland and open
water areas commonly referred to as Project Areas One and Two are included.
Company constructed sediment ponds, mill ponds, waste impoundment areas and
the dike are not. These areas are regulated but not as wetlands or waters.
"Wetlands" are broadly defined as those areas which are covered or
saturated by water often enough to support vegetation which normally lives in
wet soils. Common names for wetlands include swamps, bogs, marshes, and
savannahs. Photographs of the major wetland types on and around NCPC are
included in Appendix B. A prime example of this type of vegetation is black
needlerush, the long rounded marsh plant with a sharp point which lines most
of the larger creeks in the area. Adjacent to this rush may be sawgrass, so
named because its leaf edges are serrated and will cut. Common cattails are
perhaps the best known marsh type vegetation, although it is not as common as
needlerush in NCPC areas of concern. These marsh type plants immediately
adjacent to the water are usually easily recognized. The trickier areas are
the transition zones between what is clearly marsh and what is upland pine,
-5-

hardwood or field. This is where most unauthorized impacts occur. The
photographs show some of these areas. They may either be dominated by just
one kind of plant like lizard tail or very mixed in vegetation type. Larger
trees normally found In wetlands are cypress, red maple, black and sweet guns
and ash.
Proper identification of wetlands often requires the ability to
identify specific types of vegetation in combination with soil conditions.
Personnel should always consult with the Environmental Department if there is
question about planning any direct actions that affect these areas.
Determination of what Is or what is not a regulated water or wetland
area for the purpose of carrying out actions in these areas can be made
by the appropriate regulatory agencies based on their field
inspections.
Generally, the Federal definitions of waters and wetlands are also
used in the State enforcement programs. The State uses the additional term
"Estuarine waters" which includes all the tidal waters in the coastal areas.
The State also defines as wetlands the areas which are periodically flooded
and have any one of nine specific type of marshgrass growing on the land.
The North Carolina Office of Coastal Management (OCM) also regulates
activities within a 75 foot setback from all Estuarine waters' shorelines
regardless of the type of water or land within that area. This is an
Important area for all employees to recognize. Activities by the company in
this setback area are regulated even if the area is high ground with pine
plantation. This is because activity in this area can directly impact water
-6-

and wetlands areas unless (for example) proper drainage safeguards are in
place to prevent sedimentation.
Federal Regulation of Wetlands and Waters
The U. S. Army Corps of Engineers enforces two
applicable federal laws, the Rivers and Harbors
Act of 1899, and the Federal Water Pollution
Control Act (Clean Water Act). These provide
the authority to adopt regulations to protect
waters of the United States. Copies of appro-
priate sections of these laws are availahle
upon request from the Environmental Department.
State Regulation of Wetlands and Waters
The North Carolina Office of Coastal Management
(OCM) administers regulations adopted by the
Coastal Resources Commission (CRC) authorized
by two sections of the North Carolina General
Statutes (N.C.G.S.) pursuant to the Coastal
Area Management Act, or the Dredge and Fill
Law (N.C.G.S. Section 113-229). These two laws
contain definitions in N.C.G.S. Section 113-229 (n)
and N.C.G.S. Section 113A-103.
-7-

Activities Requiring.Permits In Waters/Wetlands
The following list of activities is not intended to include all
activities in water/wetlands that must be permitted but it does include most
of the typical activities in these areas which NCPC employees and/or
contractors undertake.
- Fill: Filling or dumping of material into
waters/wetlands. This could include anything
from land clearing and building to grade to
power pole installation or pipe line supports.
- Excavation; Digging or mulching of or in waters/
wetlands.
Discharge of any substance into waters/wetland - This is a very
sensitive area and all employees and contractors must be careful when
planning to use or using materials in and around waters/wetlands which could
eventually get into these areas if spilled. Even if the spill was accidental
or not adjacent to water or wetland, if the material is toxic or deleterious
(such gas and oil or sediments from land clearing), the discharge into waters
or wetlands is still illegal.
-8-

Emergency_Stop Work Procedure
In order to insure the immediate cessation of an activity which has
the potential to cause a violation of environmental regulations or permits to
perform work in sensitive areas, the Manager of Environmental Affairs or the
Environmental Auditor may direct the responsible employee to immediately
correct the situation causing the problem. If necessary, this includes
immediately stopping the activity.
Enforcement
Failure by any employee to abide by adopted environmental procedures
or to promptly report_ environmental _incidents will lead to disciplinary
action. These actions may include verbal or written reprimands, suspension
from work without pay, or termination of employment.
-9-

NPDES - Waste Water DischarEje
NCPC will discharge waste water from its mining and processing
activities at two locations into the Pamlico River. These points can be seen
as Discharge 001 and 002 in Figure 2. Both are located at some distance from
actual operations. This distance means that the discharges enter the largest
water body in the area where dilution is greatest. Impacts of these
discharges can be better absorbed by the larger Pamlico than Jacks, Jacobs,
or even South Creek. NCPC discharges will be decanted from the clay pond at
001. At 002 the discharge will include mill pond water and excess mine
depressurization water when the mine pumps are operating but the plant is
not. These discharges will meet all State and Federal standards.
This section of the manual dealing with waste water discharge will be
expanded to include more detail on these discharges when the company gets
Into operation. Until then, the discharge points are releasing only rain
water which falls in the plant/mine and clay pond areas during construction.
Even these discharges, however, are controlled and must meet standards. The
standard of most concern with drainage is for suspended solids which the rain
water picks tap moving overland, particularly over cleared land. The standard
is measured in units which require laboratory equipment but a good guide is
that if an employee observes "muddy" water entering the River at these
discharge points he/she should report it to his/her supervisor and/or the
Environmental Department immediately.
-10-

Air Emissions
The company will release air emissions from a boiler, coal
preparation plant, and phosphate calciners. The emissions will contain
sulfur dioxide and particulate matter in small amounts. These substances are
regulated and therefore NCPC must have permits to insure that its emissions
will meet standards. This section will also be expanded when the company
begins operation.
-11-

Use and Disposal of Deleterious Substances
During construction, the substances of most concern for proper
disposal include, but are not limited to: fuel, oil and grease from any
source (including heavy equipment changeout), other lubricants, paints and
other coatings, and solvents. None of these substances are to be disposed
of on NCPC property byNCPCor contractors working for NCPC. They
are to be containorized and carried to the appropriate land fills.
During operation, other substances such as reagents will he itemized
in this manual in addition to those listed above.
An NCPC or contracted employee should consult with the Environmental
Department prior to disposal of any substance of a questionable nature.
-12-

Education and Communication
Meetings - Since awareness and attitude by employees will be
essential to NCPC in ensuring protection of the environment, a related series
of activities will be a regular part of the company's environmental program.
Quarterly environmental awareness meetings will be held with management
personnel and field crews to make them aware of general and typical
environmental concerns and to acquaint them with environmental regulations
which govern NCPC operations.
The organization of NCPC operations (see organization chart in
Appendix C) is such that the following categories of activity might impact
the environment. These are, as follows:
1. Mining
2. Engineering
3. Maintenance
4. Construction
5. Beneficiation
6. Calcination
Regular employee safety meetings within these departments will also
include specific discussions regarding environmental matters or areas subject
to environmental regulations. Subjects to be discussed may be provided by
the Environmental Department and can include such issues as the wetlands and
estuarine waters regulations, air emissions, waste water discharges,
groundwater protection, mining and reclamation programs.
-13-

Presentations
At least one general audio visual presentation will be developed by
the Environmental and Training Departments to inform employees of
environmental concerns and potential problems. It will be updated or
modified to insure that it includes current regulatory requirements.
Landmarks
In areas for which permits are issued for projects in or adjacent to
wetlands, easily identified landmarks have been, or will be, placed so that
employees can observe in the field the wetlands limits established by
agreement between the regulatory agencies and NCPC. The Environmental
Department, working with planning and operations personnel, will continue to
clearly mark jurisdictional limits determined during onsite visits by
representatives of the regulatory agencies. These limits will be marked on
maps drawn for use in project planning and construction.
-14-

Communications with Contractors
Because major portions of the work NCPC carries out adjacent to or
within wetlands/waters is actually performed by independent contractors, key
contractor personnel from supervisory to project management level ,nest follow
the appropriate procedures in this policy manual. Key contractor personnel
from supervisors to project manager, whose work_potentially affects
wetlands/waters will be given the audio visual presentation on wetlands,
waters, and regulations. They will be given specific reporting instructions
in case of incidents. As part of the established NCPC bidding procedure,
each bidding contractor will have a pre -bid conference and site visit (where
appropriate) with a representative of the Environmental Department to
familiarize himself with the environmental regulations which may apply to his
performance and to the kinds of potential problems associated with the work
or area.
Compliance with all State and Federal environmental laws and
regulations and the policies and procedures contained in this manual are "a
condition of the contract,"
-15-

Communications with Regulatory Agencies
In order to provide an opportunity for representatives of the
regulatory agencies to comment on proposed activities, meetings will be held
with appropriate members of these respective agencies on at least a quarterly
basis until NCPC construction activity gets fully underway. At that time,
meetings will be held monthly. Many of the meetings will involve onsite
visits to allow for determination of the applicability of regulations.
Members of NCPC's Environmental, Mining, Plant, and Maintenance Departments
may participate in the visits.
Update
The Environmental Protection Program will be reviewed at least once a
year and modified as necessary in order to insure full compliance with any
permit conditions, laws or regulations.
-16-

1p`
Waters and Wetlands Project Procedures
Engineering Research and Development - To insure that
construction projects and operations will not be harmful to areas subject to
environmental regulations, all new construction projects or modifications to
existing Or_in-placeprojects that _potentially affect waters and wetlands
will be reviewed and approved by the Environmental Department before
construction is authorized. Drawings for such work will have an approval
block and the 21ans will not be finalized nor used to initiate work until the
Environmental Department has initialed this block. The following procedures
will be followed:
i) The originating department will determine if any
project is potentially in or near any water and wetlands,
including but not limited to, the following waterways,
their tributaries, or adjacent wetlands:
a)
Pamlico River
b)
Durham Creek
c)
Porter Creek
d)
South Creek
e)
Whitehurst Creek
f)
Jacks Creek
g)
Jacobs Creek
h)
Drinkwater Creek
0
Tooley Creek
j)
Lewelyn Creek
k)
Sibyl Creek
0
Hudles Cut
-17-

2) If the project lies in one of these areas or if
there is a question that the area may be a water
or wetland area, or affect these, the Environmental
Department will be notified.
3) If a project is already permitted, it is the re-
sponsibility of the department carrying out the
work to do so In a manner that is consistent
with the permit, thus department personnel must
be thoroughly familiar with the involved permit or
permits. If a permitted project is modified in the design
or construction phase, it Is the responsibility of the
department personnel doing the design, redesign,or preparing
to construct, to notify the Environmental Department which
must them seek the required modification authority.
u) For a new project, the Environmental Department will make
an initial determination if the area Is subject to regula-
tions for the activity proposed. If there is any question,
the Environmental Department will request an on -site
conference with representatives of the Corps and/or
OCM, or other responsible agencies. This may take
from several days up to two weeks to arrange.
-18-

5) If the Department's initial evaluation or consultation with
regulatory personnel indicate the need for a permit, then
the Environmental staff will advise the originating
department as to the information required to file any
permit applications. The Environmental Department will
complete the application package and submit it to the
proper review agency.
6) During processing of a permit application, staff from
the originating department will participate in dis-
cussions with the review agencies to insure that
permit conditions are reasonable and acceptable to
the Company and to assure that responsible managers
are familiar with permit conditions.
7) Upon the receipt of a permit, the original will be filed
with the Environmental Department and a copy will be provided
the department responsible for the project. All restrictions
will be noted by the Department responsible for carrying
out the project and the responsible manager will initial the
permit. If the originating department feels the permit
conditions are too restrictive or cannot be achieved, they must
notify the Environmental Department immediately so that appeals
may be started. No work can be started until an acceptable
permit is received.
-19-

8) When the permit is accepted, any limitations shall be
observed to insure full compliance with permit conditions.
9) Specific wetlands and/or waters which are permitted or other-
wise authorized to be impacted must be clearly staked out or
flagged by the Environmental Department prior to commencement
of work. In these specific areas, the Environmental Auditor
or his designee must be on site when work commences and remain
as long as Is appropriate to the project.
Maintenance and Activities
- Daily maintenance activities
conducted by maintenance or operations personnel are subject to the same
procedures as described for construction and operations activities. They
shall not impact in any harmful or unlawful way on areas subject to
environmental regulations and/or permits. All major, non -routine,
maintenance projects which could have environmental impacts will be reviewed
in advance by the Environmental Department to insure proper consideration of
environmental concerns. Such major projects will be inspected by members of
the Environmental Department no less frequent by than once a week and as
often as necessary to insure full compliance with any applicable regulation
or permit condition. Written reports will be prepared by the Environmental
Auditor and kept on file in the Environmental Department.
-20-

Waters and Wetlands Incident Procedure
This is a procedure designed to confine excavation and fill
activities to permitted areas as required by Federal and State laws and
regulations. Every effort should be made to insure compliance with these
laws and regulations and to immediately stop any action which may be in
violation of them while providing prompt notice to appropriate authorities.
To accomplish this goal the following procedure has been established.
1) When any employee sees what he/she believes to be
the placement of fill or the excavation of wetlands
not in keeping with this policy, he/she should
immediately notify the Environmental Auditor or the
Environmental Department and the work stopped if it
is a violation. Phone numbers for emergency
contact are provided in Appendix A.
2) When notification is received, an onsite inspection will
be made immediately by the Environmental Auditor or designee
and an incident report will be prepared as soon as possible.
3) If it is determined a violation of regulations or permit
conditions has occurred, the responsibility for further
evaluation and control of the problem lies with the
Manager of Environmental Affairs (or his designee). No
action will be taken without consulting with that person.
-21-

4) Emergency action to prevent further damage to
waters and wetlands, such as shutting off culverts
or erecting sediment fences downstream from a
spill may be taken by the project supervisor on
site, if considered appropriate.
5) Immediate notification of State or Federal regulatory
agencies will be done by the Environmental Department.
All questions regarding the incident should be referred
to the Environmental Department.
6) An incident report will be completed and filed
by the project supervisor and placed in the
files of the department involved in the accident.
A copy of the report will be forwarded to the Environ-
mental Department.
7) In the event of an incident which impacts on areas
subject to waters and wetlands regulations, cleanup
should not be started without approval of the Environ-
mental Department which must consult with the Corps
of Engineers and the N. C. Office of Coastal Management
and Land Quality Section.
-22-

Waters and Wetlands Project Inspection Procedure
To insure full compliance with regulations or permit conditions, all
active projects including drainage Into or near waters or wetlands will be
inspected according to the following procedure.
1) The project area will be inspected daily by the
Foreman In charge. If the project is operating
more than one shift, each shift Foreman will
inspect the project. Items to be observed should
include:
a) Visual inspection of any control system to
see if the systems are working properly.
b) If sediment fences are required, check to
see that they are in place and not filled with
silt, that they are not not undercut, or being
by passed.
c) If fill or spoil material is being placed,
check to see that all material is being
retained within the permitted or planned area.
-23-

2) The Environmental Auditor will establish and
perform an inspection program for all active
waters and wetlands projects. All construction
projects which might Impact the environment will
be inspected by the Environmental Auditor or
designee at the initiation of the work and at
least three times during the week. Written reports
will be prepared by the Environmental Auditor and
kept on file in the Environmental Department. A
copy will be forwarded to the project or department
management routinely. If the report notes problems
which require attention, immediate or otherwise, the
report will document these, note what field discussion
with supervisory personnel was held and what action was
agreed to or recommended. These exception reports will
be forwarded to management as soon as possible. The
Manager of Environmental Affairs will inspect the site
at least twice each week.
3) After the start of a significant rainfall, an inspection
shall be made by the project foreman to insure that sedi-
ment control systems are operating properly. The timing
and number of these Inspections will depend upon the amount
and duration of the rain event. If there is any question
about the operation of a sediment control system, the foreman
shall arrange for an Immediate inspection by the Environmental
Auditor or designee.
_24_

4) No project in or around waters and wetlands
with potential to affect these areas in the
event of heavy rainfall is to be left totally
unattended for more than 48 hours even on weekends.
Such projects must be made as secure as possible
both overnight and over weekends and holidays.
5) Control structures such as flashboard risers will
be left in their secure position if they are to be
unattended for more than one eight hour shift.
Even during such an eight hour shift provision
must be made to fully board up the system in the
event of a significant rainfall.
6) If any condition which violates permit conditions
or regulations is observed during any inspection,
the activity will be stopped immediately by the
foreman in charge of the work. The cause of the
problem will be determined if it is not readily
apparent.
-25-

7) If any other Department Head or Manager observes any
activity which he believes is being conducted in a
manner which may cause an Impact on waters or wetlands
he should stop the project immediately and notify the
Environmental Department.
8) Once a project has been stopped in accordance with
paragraph 7) and 8) above, the project can only be
resumed with the written authorization of the Manager
Environmental Affairs (or his designee).
9) Failure to stop an activity upon receipt of instructions
in accordance with this procedure will result in dis-
ciplinary action. Disciplinary actions may include:
a) Oral reprimands
b) Written reprimands
c) Suspension from work without pay
d) Termination of employment
10) Failure by an employee to promptly_re22rt an activity
which Is recognized to be a violation of this policy
or of_requlations or permit conditions will also re-
sult in disciplinary action.
-26-

Environmental Incident Procedure
Responsibilities - Field Environmental Auditor
In the event of an environmental incident the person or department
detecting the incident will report it to the Environmental Auditor who will
alert the Manager of Environmental Affairs. Telephone notification of
incidents will be received by the Environmental Department during the hours
of 8:00 a.m. to 4:30 p.m. During the evening shifts and on the weekends and
holidays, calls will be made to the person on call. That person will then
follow this procedure.
i) They should go immediately to the area where the Incident
has occurred to evaluate the problem. if possible this
evaluation should be made with the Foreman of the department
responsible for this incident. An estimate of the severity
of the problem should be made so that this information can
be relayed to the appropriate supervisory personnel.
2) They should notify the Manager of Environmental Affairs as
soon as the inspection is completed. If this person is
unavailable, they have authority to contact any supervisory
personnel necessary, up to and Including the General Manager.
-27-

3) Upon notification, the Environmental person on call will
instruct the field personnel as to what additional actions
should be taken. If the Environmental person on call feels
that all necessary corrective actions are underway and the
problem is not a major one, he/she may instruct the personnel
to continue to monitor the activities and to report periodically.
However, if there is a major incident, the Environmental person
on call should report to the plantsite to survey the problem
personally.
4) The Field Environmental Auditor will complete an incident report
for all incidents reported. This report will be submitted to the
Manager of Environmental Affairs and the Manager of the Department
in which the incident occurred and the President of NCPC.
-28-

Environmental Incident Procedure
Responsibilities Y- Manager, Environmental Affairs
In an environmental incident involving waters or wetlands (or a
chemical spill), the Manager of Environmental Affairs has the responsibility
of notifying other management personnel and Federal and State regulatory
agencies. The following procedures outline these responsibilities.
1) When the Manager is notified of an incident he/she should
determine what additional actions should be taken. Instructions
should be given to field personnel if further actions need to be
taken. This might involve continuous monitoring of the problem or
corrective actions that the field personnel might assist with.
2) The Manager should evaluate the situation and decide if addition
notification of management personnel is necessary. Where a minor
incident has occurred and has been contained, additional actions
or notification should normally be unnecessary. If the situation
appears serious, the Manager should report to the plantsite and
make a personal evaluation of the problem. if a major incident
has occurred, the Manager should at this time notify the appro-
priate Operations Manager and give an appraisal of the situation.
-29-

3) For some incidents, it may be required that certain Federal and
State regulatory agencies be notified. This notification will
be made by the Manager of Environmental Affairs.
4) The Manager will prepare a complete report for management evalu-
ation. This report should contain a complete investigation of the
incidents leading up to and causing the problem and all corrective
actions. It should also contain suggestions for the prevention
of further incidents. A copy of this report will be filed with
the Manager of the Department in which the incident occurred and
with the President of N CPC.
-30-

Environmental Inspection Re22rt
DATE:
WORK SITE
Permit Number(s)
Permit(s) Available at site?
SITE CONDITIONS
WEATHER CONDITIONS
WORK UNDERWAY
PROBLEMS OBSERVED
TIME:
Yes No
CORRECTIVE ACTION RECOMMENDED/AGREED TO/TAKEN
WORK SUPERVISOR:
SIGNED:
-31-

Manager
R. W. Grosz
President
North Carolina Phosphate Corporation
H. M. Breza
Manager, Mine
E. E. Walker
Manager, Customer & Public Relations
R. P. Ayres
Manager, Environmental Affairs
-32-
J. L. Wester
Manager, Operations
M. V. Davis
Manager, Maintenance
W. D. Tripp
Manager, Administration
N. R. Guest
Manager, Calcination
L. D. Williamson
Manager, Beneficiation

•
E 6�
North Carolina Department of Natural
Resources &Community Development
James B. Hunt, Jr., Governor James A. Summers, Secretary
CERTIFIED MAIL
RETURNED RECEIPT REQUESTED
NOTICE OF VIOLATION OF MINING PERMIT
September 14, 1964
Mr. R. Ward Grosz
North Carolina Phosphate Corporation
P.O. Box 398
Aurora, North Carolina 27806
Dear Mr. Grosz:
DIVISION OF
LAND RESOURCES
Stephen G Conrad. Director
leiephore919 733 3833
This letter is to inform you of a violation of your mining permit
no. 7-5, issued to your firm to operate a phosphate mine in Beaufort
County, North Carolina.
On August 27, 1984, personnel of this office inspected the clay
pond dike located in the Core Point area. The inspection revealed that
a serious violation of operating condition no. 2B under "protection of
water duality' had occurred.
Number 2B states that a vegetative or mechanical barrier shall be
provided in the initial stages of any land disturbance to prevent
sediment discharge into adjacent surface waters and wetlands.
Condition 2B-3) states mechanical erosion control measures will be
provided to minimize off -site siltation from settling pond dike
construction until the dikes can be permanently stabilized.
The inspection revealed that Brown Run (a tributary of Durham
Creek) and its adjacent wetlands have been severely damaged by off -site
sediment deposition as a result of removing flashboard risers and
culvert systems at the clay pond dike. Off -site sediment deposition in
the creek itself exceeded an area of approximately 5 to 20 feet wide,
450 feet long, and 1 inch to 2 feet deep.
You have already taken measures to stop further off -site
sedimentation. I urge you to maintain adequate sediment control
measures.
I understand that a restoration plan has been developed. Please
submit within 5 days a copy of the restoration plan to this office to be
reviewed in conjunction with the Offices of Coastal Management and the
Army Corps of Engineers. In addition, an environmental monitoring plan
to prevent future violations should be submitted within 30 days.

Mr. R. Ward Grosz
Page -2-
September 14, 1984
If the above steps are not taken within the dates specified, this
matter will be referred for enforcement and a civil penalty will be
assessed. if a civil penalty is assessed, the amount may be up to One
Hundred Dollars ($100.00) for each day of violation, beginning with the
date of your receipt of this Notice of Violation G.S. 74-64. Other
enforcement actions may include seeking an injunction, criminal penalty,
or revocation of your mining permit.
The responsibility for understanding and complying with the
conditions of your mining permit rests with you. Please advise should
you have any questions concerning this matter.
Sincerely,
S/Ga+�1 6i. r#*"4
Stephen G. Conrad
Director
CC: SGC/.1S/cj
Floyd Williams
David Owens

August 29, 1984
MEMORANDUM
TO: Charles Gardner
THROUGH: James D. Simons
Harlan Britt
FROM: Floyd Williams
SUBJECT: North Carolina Phosphate Corporation
Violation of Conditions of Mining Permit
During the week of July 30, 1984, North Carolina Phosphate Corporation failed
to adequately control sediment during removal of a culvert from beneath their
clay pond dike at Core Point in Beaufort County. This resulted in a considerable
amount of sediment being discharged and deposited offsite within public trust
areas (areas of environmental concern) of Browns Run and adjacent wetlands of
Browns Run.
The problem developed during removal of a culvert with flashboard riser that
was installed during phase one of construction. It appears that North Carolina
Phosphate Co. elected to leave the flashboards off the riser during the night,
and a large storm caused a considerable amount of sediment to be transported
from exposed areas inside the dam, resulting in sediment being discharged into
Browns Run, which is a tributary of Durham Creek.
The Office of Coastal Management and the Corps of Engineers are working with
North Carolina Phosphate concerning restoration.
During June and July of 1983, North Carolina Phosphate was notified of violations
of conditions of their mining permit involving offsite sedimentation problems
at the plant site, which they adequately corrected. After this, it appeared
that North Carolina Phosphate had a good inspection program of sediment control
structures and devices.
I think the latest problem at the clay pond resulted from poor judgment in
leaving the flashboards off the riser during the night.
I am recommending that North Carolina Phosphate Corp. be mailed a letter of
violation for violating condition 2(B) of their mining permit (permit #7-5)
and that appropriate enforcement actions be taken in an effort to prevent
future problems relating to sediment control.

V\ 1
ID: lLoyd Williams
FROM: .Edy Smithwick
PAQ: �n;us; 29, 1984
SUNNI; inspection of NCPC Clay Pond
On Au� ui t '7, 1984, 1 met with Page Ayres to insVe- t recent p r; h I cum which
have .rrud at the NCPC clay pond facility. 11c Uspectioc IINIed the
foljowlk :
I , i Knhhuurd risers and culvorts, toad to Want waric pond ipg beh Wd the,
dika, Y-ra being Qnd had been) removvo. Two q�r"rwros locawd ai ihe head,-;
of Unnn 4un and Crawford Mill Rtm had Uready hvwd rcmovva, inp owcu
Striz!Pr. Curtained W place.
!!11 '-'.p.',,!rs had houn complcLad :T :hc twu nt,is ;n whi& Y1 a Nhuar'l
rijor:1Ij bwen removed.
J. <j�iantiticn of sediment hNd huun discharL-d Wtu thr wsTKnVs and
cruck N rasult of the culvouts hoNg remov& from To two wcviirnod arcns'
ZLIIL', .,aving the drainage ways zmpr41=i.;ctud Kon 1 Uke repwrn nore
4, W third riser to be remavcd was it place, and a sudimm hanin had Hun
excAynnod to provide more storago until the riser iz ramok K
5, 31 11 Cances had been crectod on UP jowostrudm Was of the rupal ucd dike
SWC to prevent dike Vil 1 wor:V frum untwricn
U . .. "111tographs of two f i 1 1, d , . :' KS 0on C _UAS 1UP 1'rniNn to
AAV'- & jN nhose two creov; aq yci 1 as Kuthr n Ccowk.
7. A! �,air urvan of the dike jr- to he ;ts5i1i�wd immediAtcly, iccarding
to PAIC Ayres,

1
1
1
SOIL & MATERIAL ENGINEERS INC.
1
1
SLOPE STABILITY ANALYSIS REPORT
PHOSPHATE ORE MINE PIT SLOPES
' NORTH CAROLINA PHOSPHATE CORPORATION PLANT SITE
AURORA, NORTH CAROLINA
S&ME JOB NO. 051-84-127-A
1
1
1
1

1
1
1]
SOIL & MATERIAL ENGINEERS INC. ENGINEERING -TESTING -INSPECTION
3109 Spring Forest Road, Box 58069, Raleigh, NC 27658-8069, Phone [phone]
.June 18, 1984
North Carolina Phosphate Corporation
Post Office Box 398
Aurora, North Carolina 27806
Attention: Mr. Joe Wall
Reference: Slope Stability Analysis Report
Phosphate Ore Mine Pit Slopes
North Carolina Phosphate Corporation Plant Site
Aurora, North Carolina
SBME Job No. 051-84-127-A
Gentlemen:
Soil and Material Engineers, Inc, has completed the authorized
slope stability analyses and geotechnical engineering evaluations of the
stability of temporary slopes in the phosphate ore mine pits at the referenced
plant site. This report presents the findings of the investigation with
conclusions relative to the excavation of the temporary mine pit slopes.
PROJECT DESCRIPTION
The original mining permit, issued by the North Carolina
Department of Natural Resources and Community Development in 1976,
stipulated that the west edge of the phosphate ore mine pit be located 300
feet east of the centerline of North Carolina Highway 306 (NC 306).
Subsequent changes in the project schedule has allowed North Carolina
Phosphate Corporation sufficient time to recover as much phosphate ore as
feasible without causing potential failure of NC 306 and maintaining a minimum
set -back distance from the highway right-of-way.
The revised mining plan provides for a Level 1 working bench to
be excavated to a depth of 25 feet at a distance of 120 feet from the
centerline of NC 306. The Level 1 bench will be excavated with a bucket
wheel excavator working at the level of the Level 1 bench (25 feet below
existing ground surface). The bench excavation slope will be 0.75:1.0
(horizontal to vertical) and the bench will have a width of approximately 150
feet. The mining plan provides for a drainage ditch at the toe of the Level 1
bench slope and the bench will be sloped toward the ditch at about 0.5
percent. The primary ore mine pit excavation will be initiated by making a
second cut of 25 feet (50 feet below ground surface) with a bucket wheel
excavator working at Level 2 (50 feet below ground surface). The primary
ore mine pit excavation will be approximately 290 feet from the centerline of
NC 306 at a depth of 25 feet below existing ground surface. The excavation
RALEIGH, GREENSBORO, ASHEVILLE, WILMINGTON, FAYETTEVILLE, CHARLOTTE, NC
SPARTANBURG, COLUMBIA, CHARLESTON, MYRTLE BEACH, SC
ATLANTA, ALBANY, GA-TRI-CITIES, TN-CINCINNATI, OH-ORLANDO, TAMPA, FL

' North Carolina Phosphate Corporation
June 18, 1984
Page 2
' slope for the second pass to Level 2 will be the same as the working bench
slope (0.75:1) . The remaining 60 feet of overburden will be excavated on a
' slope of 0.75 to 1.0 by a dragline operating at the Level 2 excavation
elevation. Once the overburden has been removed to a depth of 110 feet in
the box cut, the 40 foot stratum of phosphate ore will be removed by a
' dragline operating from the east side of the excavation. Since the dragline
will operate from the east side of the cut, the west slope of the final
excavation (phosphate ore excavation) will be a maximum of 2:1 (horizontal to
vertical) .
' The box cut ore mine pit will be reclaimed by backfilling with a
spreader working from the Level 1 bench. Mining operations will require that
' the excavation below Level 3 remain open for a period of approximately 2
months. The 60 foot cut between Level 2 and Level 3 will be backfilled
within 6 months. Sackfilling to Level 1 will require approximately 18 months
' with complete reclaimation to original ground surface requiring approximately
24 months. Figure 1 of this report provides a cross-section of the proposed
phosphate ore mining operations. The time schedule for backfilling to each
working level is provided on the cross-section.
SOIL SHEAR STRENGTH PARAMETERS
Soil shear strength parameters for this investigation were
established by modification and adaptation of values presented in the "Pit
Opening Investigation for Proposed Mine Site" by Ardaman and Associates,
' Inc., dated November 20, 1981. Based upon more recent soil test boring data
and laboratory testing done by Soil and Material Engineers, Inc., the
cohesion values of the clayey sand soils were reduced below the values
' presented in the Ardaman and Associates, Inc. report. The angle of internal
friction of the silty fine sand at a depth of 10 to 20 feet was increased from
28 to 30 degrees. T•he effect of reduction of cohesion values by 500 pounds
' per square foot was to produce a more nearly conservative factor of safety
for the temporary slopes analyzed. Soil shear strength parameters proposed
by Ardaman and Associates, Inc. and these utilized in this investigation are
presented in Table 1 of this report.
SLOPE STABILITY ANALYSES
Slope stability analyses for this investigation were conducted by a
computerized version of the Simplified Janbu Method of Slices for Irregular
Failure Surfaces. This program allows the input of multiple soil strata and
' phreatic surfaces to represent perched or shallow aquifers as well as deep
artesian aquifers acting on more impervious confining soil strata. In this
manner, the shallow groundwater aquifer above the Yorktown Formation and
' the hydrostatic pressure associated with the Castle Hayne Formation below the
Yorktown Formation could be modeled as representative of various stages of
construction.
1 A total of some 30 slope stability analyses
investigation to evaluate the stability of the temporary
were conducted in this
excavation slopes and
SOIL & MATERIAL ENGINEERS INC.

1
1
11
1
North Carolina Phosphate Corporation
June 18, 1984
Page 3
the sensitivity of the stability of the slopes to various hydrostatic pressure
conditions. Hydrostatic pressures associated with the upper aquifer above
the Yorktown Formation will be controlled by a conventional shallow well
dewatering system. Hydrostatic pressures in the Yorktown Formation
produced by the Castle Hayne Formation aquifer will be controlled by the use
of a deep well depressurization system which reduces the hydrostatic pressure
acting on the Yorktown formation.
Working Bench Excavation ( Level 1) - Slope stability analyses
were conducte or—Tinitia working bench excavation (Level 1) to evaluate
during -construction and after -construction factors of safety.
During -construction groundwater conditions represent operation of the shallow
well dewatering system to draw the upper water table elevation down to the
working bench elevation. After -construction conditions represent removal of
the shallow well point system and allowing the water table to intersect the
excavation slope near the toe of the slope just above the bench drainage
ditch. The factor of safety for the during -construction condition is 1.73.
The factor of safety for the working bench excavation slope in the
after -construction condition is 1.62. Both failure conditions were circular toe
failures with the failure plane intersecting the natural ground surface
approximately 18 to 20 feet from the top of the slope.
The factors of safety obtained for the working bench excavation
slope are well above safety factors normally required for temporary and
long-term cut slopes. In addition, the critical failure plane intersects the
ground surface within the distance to the shallow well dewatering system and
approximately 100 feet from the centerline of NC 306. Although the removal
of the shallow well dewatering system has little effect on the factor of safety
after construction or excavation of the slope, the working bench excavation
should not be made without installation of the dewatering system since the
excavation slope would become unstable as the groundwater level transgressed
from the existing elevation to the working bench elevation. Seepage from the
cut slope can be effectively controlled by the ditch at the toe of the slope
after the excavation is completed. Critical failure planes for the
during -construction and after -construction conditions are presented in Figures
2 and 3 of this report.
Mine Pit Excavation (Level 1 to Level 3) - The stability of the
mine pit excavation was analyzed with the upper aquifer being controlled by
the shallow well dewatering system and with the shallow well system removed
to determine the sensitivity of this cut slope to the control of groundwater in
the upper aquifer. The critical condition for this excavation slope is not
during the initial excavation of the slope but during backfilling when the
spreader will be operating on the working bench. Placement of the spreader
load within 25 feet of the top of the mine pit slope on the working bench
produces a factor of safety of 1.22 for the critical toe failure condition.
Hydrostatic pressures developed from the Castle Hayne Formation will be
controlled by deep depressurizing wells. The critical failure plane intersects
the working bench approximately 40 feet from the top of the mine pit
excavation slope. Although the critical failure plane intersects the working
bench within the area of the spreader load area, the factor of safety of 1.22
SOIL 6 MATERIAL ENGINEERS INC.

II�
North Carolina Phosphate Corporation
June 18, 1984
Page 4
is considered adequate for temporary excavation slopes and movement of the
spreader loading further from the edge of the pit excavation does not
increase the factor of safety significantly. Figure 4 of this report represents
the critical failure plane for the mine pit excavation to Level 3.
Phosphate Ore Excavation (Level 3 to Bottom of Pit) - Analysis of
the total phosphate ore mine pit revealed that safety factors range from 2.08
to 2.62 depending upon the initiation point of critical failure planes in the
overall box cut mine pit excavation. This most critical failure plane is a toe
failure condition that intersects the working bench (Level 1) at a distance of
approximately 60 feet from the crest of the mine pit excavation. Figures 5
and 6 of this report represent the most critical failure planes with the
spreader on the working bench.
CONCLUSIONS
Conclusions presented herein are based upon an evaluation of the
results of stability analyses conducted during this investigation. As indicated
previously in this report, soil shear strength parameters utilized in this
study were established by modification and adaptation of those presented in
the Ardaman and Associates, Inc. report of November 20, 1981. In the event
that localized areas of soils dissimilar to those described herein are
encountered, these conditions should be reported to Soil and Material
Engineers, Inc. for evaluation as may be necessary.
' The following statements form the conclusions to this
investigation:
1 . A working bench excavated to a depth of 25 feet ( Level 1)
with a slope of 0.75 to 1.0 (horizontal to vertical) can be
constructed at a distance of 120 feet from the centerline of
' North Carolina Highway 306 without producing potential
stability related failures in the highway or roadway
right-of-way.
' 2. excavation of overburden in the primary mine pit to depths of
50 (Level 2) and 110 (Level 3) feet below existing ground
surface with cut slopes of 0.75:1.0 (horizontal to vertical)
will not produce stability related failures which will affect the
operation of North Carolina Highway 306.
3. Removal of phosphate ore to a depth of approximately 150 feet
below ground surface with a cut slope of 2:1 (horizontal to
vertical) below the overburden depth of 110 feet will not
create potential slope stability related problems that will affect
the operation and performance of North Carolina Highway 306.
4. The shallow well dewatering system to be used for control of
' the upper aquifer during excavation of the working bench
( Level 1) can be removed after excavation of the working
SOIL d MATERIAL ENGINEERS INC.

' North Carolina Phosphate Corporation
June 18, 1984
' Page 5
tbench
without adversely affecting the stability of the cut
slope.
'
5.
The bench drainage ditch at the toe of the working bench cut
slope should be sufficient to control seepage of groundwater
'
from the toe of the cut slope after removal of the shallow well
dewatering system.
6.
The excavation backfilling equipment can be operated within
25 feet of the crest of the mine pit excavation ( Level 1 )
'
without adversely affecting the stability of cut slopes within
the phosphate ore mine pit.
'
Soil
and Material Engineers, inc. appreciates the opportunity to
be of professional service on this project. If there are questions concerning
this report, or
if we can provide additional information, please contact us at
'
your convenience.
Very truly yours,
'
SOIL & T RIAL ENGI R C.
rks, P ., P.
N. C. Re istration No. 9 633 1
hn R. Browning, P.E.
N. C. Registration No. 9246
BDM/JRB:bsp
So$L O MATERIAL ENGINEERS INC
1

TABLE 1
SOIL SHEAR STRENGTH PARAMETERS
DEPTH,FEET
DESCRIPTION
ARDAMAN & ASSOCIATES, INC.
SOIL & MATERIAL ENGINEERS,INC.
JUNIT
TOTAL
UNIT WEIGHF
OHESION
FRICTION
ANGLE
TOTAL
WEIGHT
COHESION
FRICTION
ANGLE
0.0 to 5.0
CLAYEY FINE SAND
115pcf
1500psf
31'
115pcf
1000psf
30°
5.0 to 10.0
CLAYEY FINE SAND
115 pcf
750 psf
33'
115pcf
750 psf
33°
10.0 to 20.0
SILTY FINE SAND
115pcf
2311
115pcf
300
20.0 to 45.0
CLAYEY TO SILTY FINE SAND
WITH SHELL FRAGMENTS
117.5pcf
42'
117.5pcf
42°
45.0 to 150.0
CLAYEY FINE SAND AND
SANDY CLAY
115pcf
2500psf
36'
115pcf
OOOpsf
35
o m n I c^ T
SOIL B MATERIAL ENGINEERS, INC.
RALE 1GH , NORTH CAROLINA
SCALE:
JOB N0:
F IG NO
sM-01

Edge of
R/W
60` 30,
30'
Mine
SHALLOW
DEPTH
Road
WILL
FEET
NC 306
S�STEM
0
1
24 I40NTHS
3/4 WORKING BENCH
25
�^
0.5
— LEVEL 1
1S Months
40
25'
1 — LEVEL 2
3/4 601
80
6 Months
LEVEL 3
120
1 PHOSEHATF O�.I 40'
2 2 Months
160
0 40 SO
120 160 200
240 20 320 360 400 440 480
DISTANCE FEET
SOIL $ MATERIAL ENGINEERS,INC.
RALEIGH, NORTH CAROLINA
Ommmt CHMAW: BDM
NORTH CAROLINA PHOSPHATE CORP.
PHOSPHATE ORE MINE PIT X4 Ma- OATS.
6/12/E4
CALs ii![T 1 OR

■■ ■■r m m m m m ■. m m = m m m m m= m=
A
14
28
42
56
0 14 28 42 56 70 84 98
PROJECT SOILS MATERIAL ENGINEERS, INC. SCALE. AS SHOWN
N. C. PHOSPHATE CORP. RA L E I G H , NORTH CAROLI NA J 0 B NO' 051-84-127-A
PHOSPHATE ORE MIME PIT
FIG NO'. 2
M-6I

0
0.7
14 1
�.
f �
ZIPPER AQUIFER '
AFTER REMOVAL'
28 0� DEWATERING SYSTEM
1
j
42 - - - ---
56
0
14 28 42 56
84
PROJECT SOIL MATERIAL ENGINEERS, INC. SCALE. AS SHOWN
N. C. PH HATE CORP. PHOSPHATE ORE MIME PIT RA L E I G H , NORTH CAROLI NA J 0 B NO. 051-84-127-A
FIG N0: 3
A-B I

1
SPREADER LOAD
ON LEVEL 1
0
168
252
0 84 168 252 366 420 504
PROJECT SOIL a MATERIAL ENGINEERS, INC. SCALE' AS SHOWN
N. C. PHOSPHATE CORP. RA L E I G H , NORTH CAROLI NA J 0 B N0: 051-84-127-A
PHOSPHATE ORE MINE PIT
FIG NO- 4
-B 1

w
0
M
N
IT.":
252
0
PROJECT
N. C. PHOSPHATE CORP.
PHOSPHATE ORE MINE PIT
84 168 252 366 420
SOILS MATERIAL ENGINEERS, INC.
RALE I G H , NORTH CAROLINA
504
SCALE' AS SHOWN
J 0 8 NO' 051-84-127-A
FIG NO'. 5
IM-B 1

m m m m m m m m m m m m
n
252
v
PROJECT
NORTH CAROILNA PHOSPHATE CORP.
PHOSPHATE ORE MINE PIT
UPPER
AQUIFER
SPREADER LOAD ON LEVEL
1 WORKING BENCH
84 168 252 366 420
SOIL 8 MATERIAL ENGINEERS, INC.
RALE IGH , NORTH CAROLINA
F.S.=2.62
504
SCALE- AS SHOWN
J 0 B N0:O51-84-127-A
F IG NO' 6
am-B1

July 13, 1984
Mr. Jim Simons
Division of Land Quality
North Carolina Department of
Natural Resources and Community
Development
P. 0. Box 26787
Raleigh, North Carolina 27611
Dear Mr. Simons:
As per our continuing discussion, enclosed is a report completed by
Soil and Material Engineers, Inc, concerning slope stability of NCPC's mine pit.
The purpose of this letter and accompanying report is to request modification
of NCPC's mining permit - # 7--5.
On Page 3 of the permit, Operating Condition 5.13. states:
Excavation shall not come within 300 feet of any neighboring
dwelling house, school, church, hospital, commercial or industrial
building, public road or other public property without written
modification to this permit describing how physical hazards to such
features will be prevented.
As may be seen In the report, results of stability analyses indicate
that . . .
1. A working bench excavated to a depth of 25 feet (Level 1) with
a slope of 0.75 to 1.0 (horizontal to vertical) can be constructed
at a distance of 120 feet from the centerline of North Carolina
Highway 306 without producing potential stability related failures
In the highway or roadway right-of-way.
2. Excavation of overburden in the primary mine pit to depth of
50 (Level 2) and 110 (Level 3) feet below existing ground surface
with cut slopes of 0.75:1.0 (horizontal to vertical) will not pro-
duce stability related failures which will affect the operation of
North Carolina Highway 306.
3. Removal of phosphate ore to a depth of approximately 150 feet
below ground surface with a cut slope of 2:1 (horizontal to
vertical) below the overburden depth of 110 feet will not create
potential slope stability related problems that will affect the operation
and performance of North Carolina Highway 306.
P. O. Box 398 • Highway 306 N. • Aurora, North Carolina 27806 • 919/322-5151

Mr. Jim Simons
Page Two
July 16, 1984
4. The shallow well dewatering system to be used for control of
the upper aquifer during excavation of the working bench
( Level 1) can be removed after excavation of the working bench
without adversely affecting the stability of the cut slope.
5. The bench drainage ditch at the toe of the working bench cut
slope should be sufficient to control seepage of groundwater
from the toe of the cut slope after removal of the shallow well
dewatering system.
6. The excavation backfilling equipment can be operated within 25
feet of the crest of the mine pit excavation (Level 1) without
adversely affecting the stability of cut slopes within the
phosphate ore mine pit.
Based on this information, it is requested that NCPC's Mining Permit
be modified to allow excavation at a distance of 120 feet from the centerline
of North Carolina Highway 306.
Thank you for your consideration. If you have any questions, suggestions
or comments, please let me know.
Very truly yours,
Fy2
R. Page Ayres
Manager of Environmental Affairs
RPA: gm
Enclosure
cc: Mr. Joe Wall
NCPC

April 30, 1982
The Honorable Grace H. Bonner
Mayor, Town of Aurora
Aurora, N.C. 27806
Dear Mayor Bonner:
As requested in your letter of April 21, 1982, ; am enclosing a copy
of N.C. Phosphate Corporation's mining permit #7-5 as modified, dated
April 6, 1982, and also a copy of The Mining Act of 1971 as amended by the
1981 General Assembly.
Under The Mining Act of 1971, we are requiring certain operating and
reclamation conditions for each phase of mining. On pages 6 to 8 of the
permit, we are requiring certain specific conditions with regard to the
initial overburden disposal areas.
We will be closely monitoring each phase of mining to ensure that
N.C. Phosphate Corporation meets conditions as set forth in its mining permit.
If you have any additional questions, feel free to contact me or James D.
Simons, State Mining Specialist. Telephone: [phone], Raleigh, N.C.
FRW:mgr
CC: James D. Simons J
State Mining Specialist
Since ely,
lay R. Williams
Regions Engineer
Div. of Land Resources
Land Quality Section
RECEIVED
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LAND QUALITY SECTION

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Y'STnrc „° N.
North Carolina Department of Natural
Resources & Community Development
James B Hunt, Jr„ Governor James A Summers, Secretary
December 6, 1984
Mr. R. Ward Grosz
North Carolina Phosphate Corporation
P.O. Box 398
Aurora, North Carolina 27806
Dear Mr. Grosz:
DIVISION OF
LAND RESOURCES
Stephen G Conrad. D,rector
Te,F!pno,e 9ID 7 ;3a33
This is in refernce to your letter of October 22, 1984 with the
description of the weir failure, request for modification of the Office
of Coastal Management and Corps of Engineers permits for the clay pond
decanting channel, and a draft of your Environmental Protection Program.
Several site inspections have been made since the Notice of Mining
Permit Violation was sent to you on September 14, 1984. The inspections
have found that the permit violations have been corrected.
I understand that the request for modification of the decant
channel is being reviewed by Coastal Management and the Corps. Our
personnel have discussed their input with members of your staff and with
Coastal Management.
We have also reviewed your proposed Environmental Protection
Program and feel that it will be very effective in preventing future
environmental problems if it is carried through and maintained by
management. We particularly agree that frequent and open communication
between the Department and your staff is vital. We also agree that it
is a good idea to have a known company policy to monitor and report work
that could adversely impact or, the environment.
I appreciate your cooperation in these matters. Please feel free
to call my staff or me if you wish to further discuss these matters,
Sincerely,
Stephen G. Conrad
Director
SGC/JDS/cj
CC: Mr. Charles Gardner
Mr. Jim Simons t.
Mr. Floyd Williams
Geo IGG iCi i:A, rvr-, �,: c'4^[,� S�.'vPy- _ t�]F Lanr. Qja.i',- Fo

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North Carolina Department of Natural
Resources &Community Development
Jernes B. Aunt, Jr., Governor Jpsecrh V4 vrirr iy4ey�la
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Page Ayers
Manager of Environmental
North Carolina Phosphate
P.O. Box 398
Aurora, North Carolina
Dear Mr. Ayers:
July 29, 1983
Affairs
Corporation
27806
AUG 1 1983
iAND
This letter will document the July 27, 1983 inspections that
were made of NCPC's barge slip and clay pond phase I dam. As you
recall, the following people were present during the inspection:
Mr. Ralph Mobley, Assistant State Dam Safety Engineer; Mr. Rudy
Smithwick, of this office; Mr. ,Jerry Waters with NCPC; you and
myself.
As noted during the barge slip inspection, a considerable
amount of erosion is taking place along the north and west slope
toes. tinder the conditions of NCPC's renewed mining permit No. 7-5
issued on April 6, 1982, it is required that North Carolina Phosphate
Corporation utilize adequate erosion and sedimentation control devices
or measures to prevent sediment from discharging into adjacent waters
or lands in proximity to areas being affected by initial phases of
construction and mining related activities.
In order to prevent further discharging of sediment into adjacent
waters, we are recommending the following measures be utilized at the
barge slip area and be installed on or before August 11, 1983.
Construct a sediment device along the toe of the slopes
by utilizing posts, boards and filter fabric. I feel
that 2" x 12" x 16' boards nailed to 4" x 4" post would
be adequate. The bottom board should be buried approx-
imately six inches with the filter fabric approximately
eight inches into the ground below the bottom of the
lower board. The upper board should be placed approximately
ten inches above the bottom board to provide filtering
with the filter cloth firmly attached to both hoards.
Sections of the fence can be removed as you progress with
regrading slopes and providing rip -rap.
Washington Regional Office 1502 N. Market Street, P. o, Box 1507, Washington, N. C. 27B89-1507 Teleornone [phone]
An Equal Dppurtun;ty Afflrrnatrve Action Employer

Mr. Page Ayers
Page Two
July 29, 1983
During June of 1983, it was reported to the office that a creed:
was discolored by clay material. As you recall, further discussion
revealed that the problem occurred when personnel of North Carolina
Phosphate Corporation pulled all the boards on a sediment basin's
flashboard riser. This released most of the impounded sediment laden
water. In discussing this matter, you stated that responsible personnel
of NCPC were instructed to remove the boards but were supposed to decant
the water by removing one board at a time. You also stated that the
communication problem had been dealt with.
The barge slip erosion problem and the releasing of sediment laden
waters are violations of NCPC's mining permit conditions. It is pertinent
that proper planning and timely installations and operations of erosion
and sedimentation measures and devices be carried out at all times to
prevent these types of problems.
The clay pond dam area was found to be in good shape with regards to
erosion and sediment control.
We appreciate you accompanying us during the inspection and if
you have any questions or need further assistance, feel free to give
us a call.
Sincerely,
Floy R. Williams, C.P.G.S.
Regional Engineer
Division of Land Resources
Land Quality Section
FRW:jt
cc: J�Imes D. Simons
State Mining Specialist
Jim Mulligan
Regional Supervisor, DF.N1
Washington Regional Office
Preston Pate
Office of Coastal Management
David Gossett
Office of Coastal Management
Steve Brown
Corps of Engineers

NCPC(D
AN AGRICO MINING COMPANY
August 12 CJ98-3 -
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Mr. Dave Gossett
Office of Coastal Management
Washington Regional Office
P. O. Box 2247
Washington, North Carolina 27889
Mr. Floyd Williams
Land Quality Division
Department of Natural Resources
and Community Development
Washington Division Office
Washington, North Carolina 27889
Gentlemen:
This letter is in response to your letters of July 29 and August 3, 1983,
respectfully. These letters documented your on -site meeting with NCPC per-
sonnel to discuss the NCPC barge slip.
In my letter to you of July 29, 1983, 1 described steps which NCPC pro-
posed to undertake in order to permanently address erosion control. Also discussed
were the causes for the delay in permanent stabilization. NCPC will expend the
necessary capital this summer instead of continued temporary control measures until
1985 as planned.
We have had contractors on -site and considered use of Fabriform, rip -rap
and interlocking wire baskets filled with ballast. The decision has been reached
to use the Fabriform as described in the brochure attached to my July 29th letter.
Recontouring of the slopes will begin on August 22, 1983 and installation of the
Fabriform is planned to start two days later on Wednesday, August 24th so that
there is a minimum of lead time with exposed soils. As we discussed, additional
sediment control during this recontouring activity is unnecessary due to the coarse
nature of the material, prevailing wind direction and short amount of time before
the soils will be covered by fabric. Installation parameters (elevations, areal
coverage, monitoring) will follow that laid out in my letter of July 29th.
Due to the quick installation of permanent control measures, it has been
agreed that it is not necessary to implement the temporary measures recommended
in Mr. Williams' letter of July 29, 1983. Sedimentation control during the interim
NORTH CAROLINA PHOSPHATE CORPORATION
P. O. Box 2247 a 1 Harding square • Washington, North Carolina 27889 a 919/946-4181

w �s
Mr. Dave Gossett
Mr. Floyd Williams
Page Two
August 12, 1983
three week period is being exercised by refurbishment of the existing sediment
fences as mentioned in Mr. Gossett's letter. As discusGQd on -site, where it was
felt that sufficient fence remained exposed to control silt during this interim
period (4 to 6 inches), that fence was reattached. In the few cases where in-
sufficient material remained, that section was replaced. Refurbishment activities
began on July 29th and were complete by August 1, 1983.
The Company appreciates the consideration, advice, and suggestions
given us by the Division of Land Quality and Office of Coastal Management.
PA : gm
cc; James D. Simons
State Mining Specialist
Jim Mulligan
Division of Environmental Management
Preston Pate
Office of Coastal Management
Steve Brown
U . S . Army Corps of Engineers
Frank Foreback
NCPC
J . L. Wester
NCPC
Sincerely yours,
�-
f
PageAAyres
Manager, Environmental Affairs

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July 27, 1981
14 E m 0 It A 11 D tu M
TO: Floyd Williams
FROM: Charles Gardner
SUBJECT: N. C. Phosphate
Attached is the Core letter I discussed with you by phone today.
From our conversation I understand that you have been working
with N. C. Phosphate on this problem and that they have taken appropriate
corrective action. Thanks for Staying as close to it as you can under
the circumstances.
CHG : gf
cc: Steve Conrad
Jim Simons ✓
Harlan Britt
Attachment

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DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
P. a. Box aeao
WILMINGTON. NORTH CAROLINA 28402
IN REPLY REFER TO
SAWC080-N-001-000341
SAWC076-07-23-025
Mr, R. Ward Grosz, President
PO Sox 1157
Washington, NC 27869
Dear Mr. Grosz:
1 • 1981
., �UL 3 I982
COMM.
A recent onsite inspection of your clay pond and slurry pipeline crossing site
on Durham Creek, Beaufort County, North Caroliha, has given cause for serious
concern as co N.C. Phosphate Corporation's compliance with current Department of
the Army permits authorizing work in these areas.
On bath Crawford Mill and Browns Run, the specific crossing sites for your clay
pond dike were selected during the public interest review of the permit
,:application. The selection of these points recognized that resources upstream
of the crossing point would be incorporated in impoundment construction and that
resources downstream would be protected against degradation.
Our onsite inspection revealed:
a. Culverts had been installed through the clay pond dike at the crossing of
Crawford Mill and Browns Run (three locations). Our records do not reflect
coordination concerning this change in construction nor any review of their
likely impacts. This work is an unauthorized and unacceptable modification of
the permitted work.
b. No LAforLs at erosion control had been undertaken on the extensive
dt,nud,--d areas Wlthlrl the dike allowing considerable material to he discharged
into downstream wetlands by way of the aforementioned culverts.
C. SilL fences along the toe of the dike were ineffective in controlling
erosion through either improper installation or lack of proper maintenance.
Coupled with the lack of an adequate perennial vegetative cover on the dike,
existing silt fencing has allowed an unacceptable -sloughing and erosion of the
dike toe into Liu., adjoining wetlands,

' SOBO-N-007-000341 20 .July 1981
4C076-07-23-025
,r. R. Ward Grosz, President
d. Work was also nearing completion on equipment access to the Durham Creek
clay slurry pipeline crossing leaving significant areas denuded upslope from
wetlands bordering Durham Creek without any erosion control efforts. Only after
contact by the N.C. Office of Coastal Management were any efforts exerted and
then only on the: south side of Durham Creek.
In summary, our recent onsite inspections have revealed waters and wetlands
adjoining your construction sites art being significantly degraded and in some
cases actually buried under significant amounts of eroding fill. materials.
While your field staff expressed dismay and concern over these problems and
indicated that steps will be taken towards expedient corrective action, erosion
control efforts continue to lag far behind land disturbing operations. To date,
tributaries of Durham Creek have been subjected to significant degradation
downstream of the permitted crossing points with the potential for additional,
even more severe, degradation imminent. You are therefore directed to close the
culverts discharging through the dike of your clay pond on tributaries of Durham
Creek until such time as this potential for degradation can be reduced to an
acceptable level. We shall expect a plan, in writing, within 10 days of your
receipt of this letter, outlining the steps you propose to bring work in the
area of Durham Creek up to an acceptable level. Upon approval of this plan and
successful implementation in the field, we will consider further use of the
existing culverts.
Should you be unable to bring your operations and construction under control and
existing conditions be allowed to deteriorate, we must consider other
appropriate administrative or legal actions available to us, including
suspension and/or revocation of your existing permit.
The Environmental Impact Statement and permit issued for your project was, to a
large degree, the result of frequent written and verbal assurances of a high
level of environmental sensitivity in carrying out your project. It was
oxpected that this would apply to planning, design, and construction. In recent
months we have had several occasions to seriously question that commitment in
the construction phases of your project. Wv are presently considering your
proposal to modify your mine advance plan to allow mining in sensitive wetland
areas with the assurance that you have not only the technical expertise but the
environmental sensitivity to perform mitigative work. Continued problems with
clay -to -day construction techniques, which do not reflect such environmental
sensitivity, can only erode the credibility your organization has enjoyed and
damage your efforts to convince review agencies of not only yoQ ability to be
environmentally sensitive but your intent as well. Should you have questions,
piOase contact Mr. Steve brown of my staff at telephone [phone],
Sincerely,
ROBERT K. HUGHES
Colonel, Corps of Engineers
Commander and District Engineer
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