23-01_2

NCDENR
North Carolina Department of Environment and Natural Resources
r);w;cinn of I -nnel Gncnllrrnc
LJIYIJIV11 VI L.U11{.1 1\GJVli1V4�7
James D. Simons, PG, PE Land Quality Section Beverly Eaves Perdue, Governor
Director and State Geologist Dee Freeman, Secretary
Rine 28, 2010
Chemetall Foote Corporation At6E7Mr. George Rohlman JUL348 Holiday Inn DriveKings Mountain, North Carolina 28086
RE: Kings Mountain Mine {Pere}it 9 23-01)
Cleveland County, N.C.
Dear Mr, Rohlman:
Attached is a copy of our report documenting an inspection recently conducted at a rnine site for
Which our records show you to be responsible. The inspection was performed under the
provisions of North Carolina General Statute 74-56 of the Mining Act of 1971.
Please review the report carefully and note any problems or deficiencies documented by the
inspector. Furthermore, please note any recommendations and/or specific corrective actions
required to correct any deficiencies that may be listed.
The responsibility for understanding and complying with the terms and conditions of your
mining perniit and the Act lies �,N,ith you.
please An not hoc' asF to r.nnfar.t thic f5ffw..P- if vntl liaVe an_�' c]l..leStinns concerning the attached
report.
Your cooperation is Appreciated.
Sincere
arnera1-1. Lpl� 1, PE ���
Assistant Regional Engineer
'1'l-1 E/ern
Attachment
cc: Mining Specialist
Mooresville Regional Office
610 East Center Avenue, Suite 301, Mooresville, North Carolina 28115
Telephone: [phone] FAX: [phone] • Internet: httpalwww.dlr.enr.state.nc.us/pages/landqualitysectior,.html
An Equal Opportunity 1 Affirmative Action Employer — 50% Recycled / 10% Post Consumer Paper

North Carolina Department of Environment and Natural Resources,
Division of Land Resources, Land Quality Section
MINE INSPECTION REPORT
(PERMITTED MINE)
1. Mine Name.- Kings Mountain Mine 2. Mining Permit #: 23-01
3. Operator: Chemetall Foote Corporation 4. County: Cleveland
5. Address: 348 Floliday Inn Drive, Kings Mountain, North Carolina 28086
6. Permit Expiration Date: 5/31/2012 7. River Basin: Broad
8. Person(s) contacted at site: George Rohlman
9. '4'4'as mine operating at time of inspection? ❑ Yes ® No 10. Pictures? ❑ Yes ® No
1.1. Date last inspected: 4/28/09 12. Has mining occurred since last inspection? ❑ Yes N No
13. is the mine in compliance with the Operating Conditions of the Permit? ® Yes ❑ No
If no, explain:
S7 Vfc l-1 No
If no, explain:
.15. Did any of the above deficiencies result in offsite damage? ❑ Yes N No
If ycs, describe the hype and severity of the damage:
1riilu e ra needed nri �n4aunlnu\jno ni rir:a—a11v J� uL ufimn
uur�
17. Other recommendations and comments: A revision of the mining slap will need to be submitted
when the Kings Mountain `['rail has been completed.
18. Is the Annual Reclamation Report +/- :nap accurate? ❑ Yes ❑ No (l-xplain) ® Not Reviewed
19. Follow-up inspection needed? ❑ Yes ❑ No Proposed date:
20. Number of additional pages of Inspection Report: 21. Date report sent to operator: 6/25/10
Inspected by: Ryan Kormanik Date: 6/24/10
Telephone No: 704-663-1699
Copy to fill; Copy to operator Copy to Mining Specialist
RECEIVED
IIN n. _
JIjL U 1 Z010
LAND QUALITY
MINING PROGRAM

M _ 4
- 1 -
State of North Carolina
Department of Environment, Health, and Natural Resources
n; S-.-jcm rf I fkmA I?acnr rrrac
Jaynes G. Martin, Govemor
Wiliam W. Cobey, Jr., secretary
March 4, 1992.
Mr. L.E. Dotson, Manager
Kings Mountain Operations
Cyprus Foote Mineral Company
P.O. Box 689
Kings Mountain, North Carolina 28086
RE: Permit No. 23-01
Kings Mountain Mine
Cleveland County
Dear Mr. Dotson:
Charles H. Gardner
Director
Your application for renewal of Permit No. 23-01 for the
Kings Mountain Mine in Cleveland County has been approved. A
copy of the renewed permit is enclosed.
The conditions in the permit renewal were based primarily
upon the initial application. Modifications to the permit were
made as indicated in the renewal request and as required to
insure compliance with The Mining Act of 1971. The new
expiration date is March 4, 2002.
Please review the renewed permit and advise this office at
(919) 733.-4574 should you have any question concerning this
matter.
Sincerely,
Tr cy E a is, E.I.T.
Min pecialist
Land Quality Section
TED/se
Enclosure
CC: Mr. Richard Phillips
P.O. Box 27687 • Raleigh, N.C. Z7611-7687 • Telephone [phone]
. An Equal Opportunity Affirmative Action Employer

DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
DIVISION OF LAND RESOURCES
LAND QUALITY SECTION
P E F' . I.9 I .T
for the oper,ati on- of a mining actj_vity
In accordance with the proDvisions of G.S. 74-46 through 68,
"The Mining Act of 1971," Mining Permit Rule 15A NCAC
5 B, and other applicable laws, rules and regulations
Permission is hereby granted to:
Cyprus Foote Mineral Company
Kings Mountain Mine
Cleveland County - Permit No. 23-01
for the operation of a
Industrial Minerals Mine
which shall provide that the usefulness, productivity and scenic
values of all lands and waters affected by this mining operation
will receive the greatest practical degree of protection and
.restoration.
MINING PERMIT EXPIRATION DATE - MARCH 4, 2002

Page 2 of 10
in accordance with the application for this mining permit, which
is hereby approved by the Department of Environment, Health and
h■1c�-.rio`.a;.naa4a+i �-c�ri- ric�.f�a..r�Y..a.�r.�. t�o•.• a� the� Department- and
111atural Resources
in conformity with the approved Reclamation Plan attached to and
incorpo.rated as part of this permit, provisions must be made for
the protection of the surrounding environment and for reclamation
of the land and water affected by the permitted mining operation.
This permit is expressly conditioned upon compliance with all the
requirements of the approved Reclamation Plan. However,
completed performance of the approved Reclamation Plan is a
separable obligation, secured by the bond or other security on
file with the Department, and may survive the expiration,
revocation or suspension of this permit.
This permit is not transferable by.the-permittee with the
following.exception: If another operator succeeds to the
interest of the permittee in the permitted mining operation, by
virtue of a sale, lease, assignment or otherwise, the Department
may release the permittee from the duties imposed upon him by the
conditions of his permit and by the Mining Act with reference to
the permitted operation, and transfer the permit to the successor
operator, provided that 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 even- that the Department determines that the permittee or
per.,,; +-moo' S c„rr-accnr i �, not complying rice_ with the Reclamation Plan
or other terms and conditions of this permit, or is failing to
achieve the purposes and requirements of the Mining Act,..the
Department may give the operator written notice of its intent to
modify,- revoke or suspend the permit, or its intent to modify the
Reclamation Plan as incorporated in the permit. The operator
shall have right to a hearing at a designated time and place on
any proposed modification, revocation or suspension by the
Department. Alternatively and in addition to the above, the
Department may institute other enforcement procedures au�11Ur1ZGu
by law.
Definitions
Wherever used or referred to in this permit, unless the context
clearly indicates otherwise, terms shall have the same meaning as
supplied by the Mining Act, N.C.G.S. 74-49.
Expiration Date
This permit shall be effective from the date of its issuance
until March 4, 2002.

Conditions
This Permit shall
N.C.G.S. 74-46, et
limitations:
Page 3 of 10
be subject to the provisions of the Mining Act,
. seq., and to the following conditions and
OPERATING CONDITIONS:
1. Wastewater and Quarry Dewatering
Any wastewater processing or mine dewatering shall be in
accordance with the requirements and rules promulgated by
the N.C. Environmental Management Commission.
2. Air Quality and Dust Control
A. Any mini rig related process producing air contaminant
emissions including fugitive dust shall be subject to
the requirements and rules promulgated by the N.C.
Environmental -Management Commission.
n U. -- g-r`ry operatLonUlr1+----, water rucks or other means . that may be necessary shall be utilized to prevent dust
from leaviirg the permitted area.
3. Buffer Zones
A. Aiiy,'Sl-mining activity affecting wetlands shall be in�Y';>
accordance with the requirements and regulations
promulgated by the U.S. Army Corps of Engineers.
B. Sufficient buffer shall be maintained between any
affected land and any adjoining waterway to prevent
sedimentation of that waterway from erosion of the
___affecte-d___land, and ._to preserve the integrity of the
natural watercourse.
C. Sufficient buffer (minimum of 50 feet) shall be
maintained between any land disturbing activity and any
adjoining property boundary to prevent caving of said
property and to allow grading of the side slopes to the
required angle. These buffer zones, with the exception
of the installation of required sediment control
measures and earthen berms, shall remain undisturbed.
4. Erosion and Sediment Control
T T.7r.-ri-.�� e�.�}z�nirr�7 barr.�..er� �nrllr(�inCY �lllt' 1'1C'lt 1lTT1ltP(�
n, nuc�uu t.v 14 +1U1114U..4 � ,
to diversidiis;-eazthen dikes, brush barriers, silt
check dams, silt retarding structures, rip rap pits, or
ditches shall be provided in the initial stages of any

'age 4 of 10
land disturbance and maintained to prevent sediment
from discharging onto adjacent surface areas or into
anv lake or natural watercourse in proximity to the
affected land. +
B. Appropriately designed erosion and sedimentation
control measures shall be installed and maintained
along the downstream edge of any affected land (most
specifically, the Mixed Ore and waste Stockpiles,
Active Mine Waste Dump Area and all on -site haul roads)
to prevent off -site sedimentation.
C. An erosion and sediment control plan(s) shall be
submitted to the Department for approval prior to any
land disturbing Aactivitie's not indicated by the
approved application-for.a mining permit and any
subsequent, approved renewals and modifications. Such
areas include, but are -not limited to, expansion
outside of the initial pit area, creek crossings -;,or
expansion.of overburden disposal areas.
Groundwater Protection,.
A. Observation wells shall be installed and monitored at
the site as deemed appropriate by the Department.
B. Copies of any records compiled by the permittee through
the monitoring of existing wells on the site shall be
forwarded to the Mooresville Regional Office,
Groundwater Section, on a monthly basis for review.
6. Graded Slopes and Fills
A. The angle for graded slopes and fills shall be no
greater than the angle which can be retained by
vegetative cover or other adequate erosion control
measure, structure, or device. In any event, exposed
slo-es or an- excavated rrhannAl c i-Y)A ornci nn n4-- o.7'nJ nh
may cause offsite damage because of siltation, shall -be
planted or otherwise provided with groundcover, devices
or structures sufficient to restrain such erosion.
B. Overburden cut slopes along the perimeter of any
furture pit openings -subsequent to this renewal
.shall be graded to a minimum 2 horizontal to 1 vertical
or flatter and shall be stabilized within 60 days of
completion. Furthermore, a minimum ten (10) foot wide
horizontal safety bench shall be provided at the top of
the rock and at the toe of the overburden slope.

7 .
M
Page 5 of 10
Surface Drainage
The affected land shall be graded so as to prevent
collection of pools of water that are, or likely to become,
noxious or foul. Necessary structures such as drainage
ditches V1 conduits shall. 3JG i. oiis tt u c tcu or lllo tuii....a
required to prevent such conditions.
Blasting
The operator shall provide to the Department a copy of the
findings.of any_.seismic studies conducted at this facility.
The opera tor1 s°tsalI make every reasonable effort to
incorporate, t.lF_�,.,•st,udies' recommendations into the production.
blasting program;:
The following'biasting conditions shall be observed by the
operator to prevent, hazard to persons and adjacent property
from thrown �rocik` r' vibrations:
A. In all °b"as ting operations, except as hereinafter
otherwise provided, the maximum peak particle velocity
of any component of ground motion shall not exceed 1
inch per second at the immediate location of any
building outside of the permitted area regularly
occupied by human beings such as dwelling house,
church, school, public building, or commercial or
institutional building outside of the permitted area.
The operator shall monitor each blast with a
seismograph.
_ B.Aizblast overpressure: shall not exceed 128 decibels
linear (DBL) as measured at the immediate location of
any regularly occupied building outside of the
" permitted area such as any dwelling house, church,
school, public building, or commercial or institutional
building.
C. The operator shall take all reasonable precautions to
insure that flyrock is not thrown beyond areas where
the access is temporarily or permanently guarded by the
operator. Should flyrock occur beyond the guarded area
or the levels in Items A and B above are exceeded, the
operator shall report the incident to the -Department
immediately and further use of explosive at the site
shall be immediately suspended until the following
actions have been taken:
1. A thorough investigation as to the cause(s) of the
incident shall be conducted.

Page 6 of 10
2• A satisfactory report detailing the investigation
shall be provided to the Department within 10 days
of the incident. Said report shall, at a minimum,
document the cause(s) of the incident along with
technical and management actions that will be
taken to prevent further incidents.
The report shall meet with the approval of the
Department before blasting may resume at the site.
Failure to take corrective measures to prevent flyrock
and repeated instances of flyrock shall be considered a
violation of this permit.
D.. The operator=shall,.maintain records -on each individual
blast describing:_,`the :total number of holes; pattern
of holes and delay of'intervals; depth and size:.of
holes; type and total pounds of explosives; maximum
pounds per delay interval;- amount of.stemming and
burden for each hole; and blast location. Records
shall -be maintained -at the permittee's mine office and
copies shaf=l; b'e--pzov1ded' to the Department upon
requdst:
E. The operator shall, when requested by the Department,
give 24 hour advance notice to the Land Quality Section
prion-Ito any blast during a period for which notice is A -
requested.
9. High Wall Barrier
A physical barrier consisting of large boulders placed end -
to -end, vegetated earthen berms or fencing shall be
maintained -at -all times around the perimeter of any highwall
to prevent inadvertent.public access. In addition, a minimum
ten foot wide horizontal safety bench shall be.provided at
the junction between the top of rock and the toe of the
overburden cut slope.
10. Visual Screeninq
A. Existing vegetation shall be maintained between the
mine and public thoroughfares to screen the operation
from the public. Additional screening methods, such as
constructing earthen berms, shall be employed as deemed
appropriate by the Department.
B. In addition to grasses, loblolly and/or Virginia pines
shall be planted at this site as deemed appropriate by
the Department to improve visual and noise buffering.

Page 7 of 10
L1. Plan, Modification
The operator shall notify the Department in writing of the
desire to delete, modify or otherwise change any part of the
mining, reclamation, or erosion/sediment control plan
contained in the annI i rat inn for a mini no nF_rmi t
and any subsequent approvals. Approval to implement such
changes must be obtained from the Department prior to on -
site implementation of the revisions.
.12. Refuse Disnosal
A. No on-sitc"-disposal of refuse or other solid. >.>aste that -
are gerrer'a.ted outside of the mining permit area shal•1 .
be allowed within the boundaries of the mining permit
area unless authorization to conduct said disposal has
first been obtained from both the Division -of Solid
Waste Management and the Land Quality Section,
Depart 'ment�� of Environment, Health and Natural
Resour'ces.._:.The method of disposal shall be consistent
with the -approved reclamation plan.
13. Mining refuse as defined by G4S. 74-49 (14) of The
Mining Act of 1971 generated on --site and directly
'associated with the mining activity may be disposed -of
in a designated refuse area. All other waste products
must be disposed of in a disposal facility approved by
the Division of Solid Waste Management. No petroleum
products, acids, solvents or their storage containers
or any other material that maybe considered hazardous
shall be disposed of-.-within--the permitted area.
13. Annual Reclamation Report
An Annual Reclamation Report shall be submitted on a form
supplied by the Department by February 1 of each year until
reclamation is completed and approved.
14. Bonding
r The security which was posted pursuant to N.C.G.S. 74-54 in
the form of. a $25,000.00 Blanket Bond is sufficient to cover
the 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.
15. Archaeological Resources
Authorized representatives of the Division of Archives and
History shall be granted access to the site to determine the
presence of significant archaeological resources.

Page 8 of-10
15. Archaeological Resources
Authorized representatives of the Division of Archives and
History shall be granted access to the site to determine the
presence,.of significant archaeolcgical resources.
APPROVED RECLAMATION PLAN
The Mining Permit incorporates this Reclamation Plan, the
performance of which is a condition on the continuing validity of
that Mining Permit. Additionally, the Reclamation Plan is a
separable obligation of the permittee, which continues beyond the
terms of the Mining Permit.
The approved -plan.• pr.ovid.e.s,:. ,
Minimum Standafds'As`Prov ded By G.S. 7 4 - 5 3
1.- The final slopes in -all excavations in soil, sand, gravel
and other unconsolidated materials. -shall be at such an angle
as to minimize -the -possibility of slides and be consistent
with the f uture - use - of the land.
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.,.T,.y
which ins in accordance with accepted conservation practices
and which is suitable for the proposed subsequent use of the
land.
4. No small pools of water shall be allowed to collect or
remain on the mined area that are, likely to become noxious,
odious --or foul.
5. The revegetation plan shall conform to accepted and
recommended agronomic and reforestation practices as
established by the North Carolina Agricultural Experiment
Station and the North Carolina Forest Service..
6. Permittee shall conduct reclamation.activities pursuant to
the Reclamation Plan herein incorporated. These activities
shall be conducted according to the time schedule included
in the plan, which shall to the extent feasible provide
reclamation simultaneous with mining operations and in any
event, provide reclamation at the earliest practicable: time
after completion or termination of mining on any segment of.
the pert area and shall be completed within two years
after c4pletion or termination of mining. -

Page 9 of 10
RECLAMATION CONDITIONS:
I. Provided further, and subject to the Reclamation Schedule,
the planned reclamation shall be to allow the quarry
excavation to fill with water, provide a permanent barricade
(fence) along the top of any highwall, and grade and
revegetate any areas in unconsolidated material.
2. The specifications for surface gradient restoration to a
surface suitable for the planned future use are as follows:
A. All areas„ of unconsolidated material such as overburden
or waste u:'Ies' shall. be graded to a 2 horizontal to 1
vertical or Matter slope and terraced as necessary to
insure slope stability.
B. Any settling ponds and sediment control basins shall be
backfilled, graded, and stabilized or cleaned out and
made into -acceptable lake areas.
t�. C. The processing, stockpile, and ocher disturbed areas
.- neighboring the mine excavation shall be leveled and
�
siiiou the i_�,xcu .
D. Compacted surfaces shall be disced, subsoiled or
otherwise prepared before revegetation.
E. No contaminants shall be permanently disposed of at the
mine site. on -site disposal of waste shall be in
accordance with Operating Condition 12A and B.
F; _ The --affected --land shall be graded to prevent the
collection of noxious or. -foul water.
3. Revegetation Plan:
After site preparation, all disturbed Land areas shall be
revc-getated as follows:
Lime:
Fertilizer -
According to soil tests; otherwise, use 4,000
lbs./acre
According to soil tests; otherwise; use 1,000
lbs./acre 1.0-10-10
Seeding Mixtl-; T_e :
p
Tall fescue
Sericea lespedeza
Kobe lespedeza
100 lbs./acre
30 lbs./acre
10 lbs./acre

Page 10 of 10
Seeding Dates:
Fall: August Zo - October. 25
Late Winter: February 1 - April 15
the
best
for Tail fescue anr? late wi Tlt winter for
Hall 1.S L11C S.JC�L. J,.Vl .taia. 1�..��..u�- u...,. ..-__-�_- ---
lespedezas. Overseeding of Kobe lespedeza over fall -seeded
Tall fescue is eery effective. Use unhulled Bermudagrass
seed in fall.
Nurse Plants:
Between May"l "''aridoAugus.t- 1-5 ; add 10 lbs . /ac:re German,.millet
. o& 1'S 1bs':'/acre .Su'danc.zass: Prior to May 1 or after„
15 add 10 lbs./acre rye (grain).
__. Mulch
Apply 4,000-5,.000 albs jacre -grain -straw-, or equivalent cover
of another su_itabl6 mulching material-. Anchor mulch by
tacking with asphalt, roving, dr netting.
4. Reclamation Plan:
Reclamation shall be conducted simultaneously with mining -tot..
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.
This permit. issued April 22, 1972 and renewed April 22,
1982,is subsequently renewed this 4th day of March., 1992
pursuant to G.S. 74-52.
By:
Charles H. Gardner, Director
Division of Land Resources
By Authority of the Secretary
Of the Department of Environment, Health and Natural Resources

Author: Tracy Davis at NROLR0IP
Date: 10/17/97 11:22 AM
Priority: Normal
1V: Elditwtg; Jonathan" <lll tCi'i`lGl:liliVCllll l.. State.Fll:. liJ> at Internet
Subject: Re: Cyprus Foote Mineral memo
------------------------------------- Message Contents -------------------
Good point, Jon. I'll go ahead and change the main inventory to "A"
so that when I finish updating your office's inventory, it will be
shown as active.
Thanks!
TD
I'll go ahead and fax a copy of my memo to Ralph Hawk so he can begin
putting together his revised reclamation plan.
Reply Separator
Subject: Cyprus Foote Mineral memo
Author: "Hartwig; Jonathan" <[e-mail]> at Internet
Date: 10/17/97 11:03 AM
Tracy,
Doug and I have both reviewed your memo and everything looks fine.
The only question I have is that the mine is currently listed as
inactive on Paradox. Aren't they currently mining? Even if they
aren't, should we change the status to active since Franklin Ind.
Minerals will be mining the tailings area?
I will put a copy of your memo in the file.
Jon
North Carolina Department of Environment & Natural Resources
Land Quality Section
Mooresville Regional Office
919 N. Main St.
Mooresville, NC 28115
704.663.1699
[e-mail]

Author: Tracy Davis at NROLR01P
Date: 10/16/97 11:27 AM
Priority: Normal
1V: DS•1111Ci1;111iVClliti.state.11 C:. lls at 1lSteLflet
TO: [e-mail] at Internet
CC: Tracy Davis
CC: Mell Nevils
Subject: Cyprus Foote Mineral Company
--------------------------- Message Contents--------------------------------------
Doug/Jon:
I have completed my memo to file that describes the site inspection
and reclamation issues that Jon and I discussed with Cyprus Foote
Mineral Company (CFMC) on 10/7...see attached. Please review its
contents and let me know if I need to add/change anything.
Once I receive your concurrence, I will fax it to Ralph Hawk so he can
use it to prepare: a formal modification request to update CFMC's
reclamation plan.
Thanks!
TD

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Permit No.: 23--01 Owner: CYPRUS FOOTE MINERAL CO
County: CLEVE Mine Name: KINGS MOUNTAIN MINE ■
Region. 3
Contact Person: RALPH HAWK Phone: [phone]
Mailing Address: 348 HOLIDAY INN DRIVE
City: KINGS MOUNTAIN State: NC zip: 28086 -
Commodity Code: LI
Issue Date: 8/01/72
Permit Revised Date: 3/04/92
Total Acres Permitted: 972
Total Acres Bonded:
Type of Bond: B01
Bond Amount: 25,000.00
Last Inspection: 8/24/93
Last NOV:
No . Insp/ Yr : v No . Iiiop to Date
Latitude: 3521500 Longitude:
Application Rec'd Date: 4/01/72
Public Hearing Date:
Expiration Date: 3/04/2002
Date Denied:
Mine Status: I
Release Date:
ARR Rec'd Date: 1/24/97
Next Inspection: 9/22/94
Last NOD:
ri
y River BasiLQ.7111 .
8135816 Quadrangle:
*ACRES DISTURBED ANNUALLY* (no. 2 on ARR form)
<: _!
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*ACRES RECLAIMED AND RELEASED ANNUALLY* (Central office only) •
■
Tailings Ponds: 0 Stockpiles: 0 Wastepiles: 0
Processing Plant: 0 Active Mine Area: 0 Total: 0
*CUMMULATIVE ACRES DISTURBED AND UNRECLAIMED* ( no. 4 on ARR form)
Tailings Ponds: 65 Stockpiles: 1 Wastepiles: 33
Processing Plant: 30 Active Mine Area: 120 Total: 249
CENTRAL OFFICE COMMENTS: Mining stopped in December 1991 per ARR received
1/28/97. -
REGivNAL vFF TCE Cviiiirr'iv T 0
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N.C. Department of Environment, Health, and Natural Resources
Division of Land Resources, Land Quality Section
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<. Content of conversxuw

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CYPRUS FOOTE
MINERAL COMPANY
A Cyprus AmaK Company
Tracy Davis, P.E.
State Mining Specialist
Land Quality Section
Division of Land Resources
P. O. Box 27687
Raleigh, NC 27611-7687
RE: Permanent Disposal of Radioactive Mining Refuse
Kings Mountain Mine
Mining Permit No. 23-01
Cleveland County
Dear Mr. Davis:
We have reviewed the procedure in your letter of January 8, 1997,
Cyprus Foote Mineral Company
348 Holiday Inn Drive
Kings Mountain, North Carolina 28086
[phone]
FAX [phone]
March 5, 1997
DEHNR
MAR 1 01997
i
LAND QUALITY SECTION
S. E. Hooper has confirmed that the brick clay that will be used meets or exceeds the requirements of the
USCS class SC or CL clay for the liner, and the liner will be sloped up at the edges.
We propose a change to condition 3. We will place a four (4) foot layer of clay as the bottom liner
instead of two (2) feet. This will reduce the possibility that in placing the material on the liner, the liner
could be penetrated
We propose a change to condition 4. After the radioactive material is placed on the liner and compacted,
we will place sand from the tailings area over the material. The sand should sift down into the radioactive
material better than the clay. This should reduce settling over time.
As required in condition 5, the two foot layer of clay will be placed on top of the radioactive material to
encase it.
Since these changes exceed the requirements in the January 8 letter, we will proceed with the work in
mid -March unless we hear from you.
If at anytime you or any of your staff wish to check the progress of this project, please feel free to contact
me at [phone].
If I can be of further assistance, please let me know.
Best Regards,
k'a' "` Gv
Ralph W. Hawk
Safety and Environmental Coordinator
FOOTE
LITHIUM j;;;�

CYPRus roOTE
MINERA1. COMPANY
A Cyprus Amax Company
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Tracy E. Davis, P.E.
Land Quality Section
North Carolina DEHNR
P. 4. Box 27687
Raleigh, North Carolina 276 l 1-7687
Dear Mr. Davis:
Cyprus Foote Mineral Company
348 Holiday Inn Drive
Kings Mountain, North Carolina 28086
[phone]
FAX [phone]
February 12, 1997
Attached is your copy of the topographic map of the Cyprus Foote Mineral Company
property in Kings Mountain.
Thank you for letting us use the print to color in a copy for our files.
Sincerely yours,
R'd� '�/ 9-e'4-
Ralph W. Hawk
Senior Process Engineer
RWH: ssg
Attachment
FOOTE
LrrINutM

MINING
ROUTING SLIP
JU
`RACY
ME N:
CRE G
COUNTS

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Land Resources
James B. Hunt, Jr., Governor
Jonathan B, Howes, Secretary
Charles H. Gardner, P.G., P.E.
Director and State Geologist
January 8, 1997
Mr. Ralph W. Hawk
Senior Process Engineer
Cypress Foote Mineral Company
348 Holiday Inn Drive
Kings Mountain, North Carolina 28086
KWA
/••
OOMM% OEM%r
1i��Q
RE: Permanent Disposal of Radioactive Mining Refuse
Kings Mountain Mine
Mining Permit No. 23-01
Cleveland County
Dear Mr. Hawk:
This letter is a follow-up to our onsite meeting and site
inspection conducted on December 18, 1996 by you and Mr. Stephen
Hooper of Cyprus Foote Mineral Company (CFMC), Mr. Sam Garrison
of Champion Contracting Company, Mr. Chris Fidalgo of the
Division of Radiation Protection (DRP), and Mr. Doug Miller and
me from the Land Quality Section. At that time, we discussed the
permanent disposal of two to three tandem truck loads of
radioactive mining refuse (old processing plant materials) at the
mine site.
I agreed to -contact- thiE -"Division____ of --Was t,e Management--(DWM)--,-
to determine if they would require a solid waste disposal permit
to allow the disposal of the above material onsite, well above
the water table. During a telephone conversation with Mr. Julian
Foscue of DWM on January 6, 1997, it was determined that the
above materials are considered "mining refuse" and, -therefore,
are exempt from the solid waste rules. Thus, no solid waste
permit will be required by DWM. However, Mr. Foscue agreed with
the procedure we discussed at the site for the permanent disposal
of the material. This procedure included the following:
1) The radioactive material will be located in the upper
end of the tailings pond, above the high water table
level; - -
2) A portion of the tailing pond material will be
excavated to provide an area for disposal of the
radioactive material;
Geological Survey Section Land Quality Section Geodetic Survey Section
[phone] [phone] [phone]
FAX: (919) 733-M FAX: [phone] FAX: [phone]
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50%recycled/ 10% post -consumer paper

T9

Mr. Hawk
Page 2
3) A minimum two foot thick clay liner (using USCS class
SC or CL) will be placed in the excavated area prior to
the placement of the radioactive material;
4) The radioactive material will be placed in a "thin"
layer, and compacted as much as possible, to reduce the
potential for settlement of the area in the future;
5) USCS class SC or CL clay material will be placed a
minimum of two foot thick along the sides and top of
the radioactive material so as to encase the material;
6) A minimum 20 foot of cover will be provided on top of,
and to the sides of, the radioactive material;
7) A detailed description of the disposal method and an
accompanying map of the disposal area will be prepared
by a registered land surveyor that indicates the
following:
i) the normal pool elevation of the adjacent water
supply pond
ii) the top and bottom elevations of the radioactive
material
iii) the top elevation of the finished tailings pond
surface above the radioactive material
iv) the coordinates of each corner and the distances
between corners of the radioactive material
disposal area ---__ _----- --- -- ------------------ ---- - -
8) Final seeding and tree planting specifications will be
provided, including lime, fertilizer, seeding mixtures,
seeding rates and dates, mulching rates, tree types,
planting dates, and tree spacings
9) Once four (4) copies of a final description of the
above work (including Croy 1r:e'�il1tLt:i Of teb-ting conducted
on the radioactive material) and accompanying map have
been submitted to and approved by this office (after
review and comment by the DRP and DWM), the surveyed
map will be recorded on the deed in the Cleveland
County Tax Office identifying the type and location of
the materials and the recorded radiation levels of the
materials permanently disposed at the site

Mr. Hawk
Page 3
10) Four (4) copies
be forwarded to
disposal project
of the recorded deed description will
this office to verify completion of the
At the December 18th meeting, Mr. Fidalgo of DRP requested
that you forward him a copy of your consultant's test results so
that they could be reviewed and included in his report. If you
have not already done so, please forward these results to Mr.
Fidalgo as soon as possible. Also, I loaned this office's most
recent mane map to you during the meeting so that you could have
it duplicated and promptly returned. To date, the map has not
been returned to this office.
In order to verify that your company concurs with the above
disposal procedure, please advise this office in writing of your
acceptance of this procedure and the tentative dates for
commencement and completion of the disposal activity.
Lastly, please address the other concerns at the mine site
as noted in Mr. Doug Miller's Mine Inspection Report dated
December 18, 1996 (copy enclosed) . ..
I greatly appreciate your company's cooperation regarding
this matter. If'you should have any questions on the above,
please contact me at [phone].
Sincerely,
Tiacy E. Davis, P.E.
State Mining Specialist
Land Quality Section
/td
23-01rad.dis
Enclosure: December 18, 1996 Mine Inspection Report
cc: Mr. Doug Miller, P.E., Mooresville Land Quality Section
Mr. Chris Fidalgo, Division of Radiation Protection
MrR -r'.,l Foscue, r%: --F TAT-.n 4-A M-,r rremar�f-
I . UUilan L'\.1scue, 1J1 Visio 11 lJL 1f Gl C7 l.G 1-ica1ILA la6G a l i
Mr. Stephen Hooper, P.E., Cypress Foote Minerals Company
Mr. Dave Douglas, Cypress Foote Minerals Company
Mr. Sam Garrison, Champion Contracting Company

RECEIVED
Nnrth r`.arnlinn nPrtgrtmant of PmArnmmant HPn1th nrwl IVntl, 1 Riocni irrpc t _ P
..�. � . �.�. �....... � ter.,.. � ....... �. �..... �........ ....�..� � .� j;jqEn
Division of !._and Resouroes, Land Quality
MINE INSPECTION REPORTJ DEC 3 0 N6
roceRetr=n RMKIt,
1. MINE NAME C11 P+Zu 7-oOT<-- M 1 N6C/a) 2. MINI O� T� CT
3. OPERATOR C: `i rJ5 r-�DG'C ►►vim! TY LC� we A{J
5. ADDRESS `1 0l �dn y TAN air ✓� , L'1�k56'I PERMIT EXPIRATION DATE s-c -G
7. Person(s) contacted at site tSNc PH Hal o•JK
8. Was mine operating at time of inspection? ❑ Yes EZNo 9. Pictures? ❑ Yes ® No
10. Date fast inspected: t�l2J�liV 11, Any mining since last inspection? ❑ Yes JZ No
12. Is the mine in compliance with the Operating Conditions of the Permit? ® Yes ❑ No
If no, explain:
13. Is the mine in compliance with the Reclamation Conditions of the Permit? l�§Yes ❑ No
If no, explain:
14. Did any of the above deficiencies result in offsite damage? [:]Yes ❑ No if yes, describe the type
and severity of the damage: !
15. Corrective measures needed and/or taken: 40 44 h,0'—
(.104� 'cck 00 400 99{ il0e -Ve c: / -flee; Z) ✓e W ,C,'�
i:)t,II A� 02mec 0,ca*ShPc S► e_ A5 �Nr/.�i,i,a�,r.✓ /�,['cr�ru�Y. '�7 �.�•�1Q�/�
001es 5 Cl 4couNd a'- yt 4r1/ .5i?�rA',= r %C'-- 4V!2zc J
16. Other recommendations and comments: f11 �i,/��� , � � ►s / s /
�1 d+Orlcr]r(� QrvS�` �F%y UIUItCIJD/r4 f'C 5��4(i CIeF'�'
17. Is the Annual Reclamation Report +/- map accurate? j Yes ❑ No (Explain) ❑ Not Reviewed
18. Follow-up inspection needed? ❑ Yes 0 No Proposed date / 1
19. No. of additional pages of Inspection Report 20. Copy of Report sent to operator 1 I_
T (date)
INSPECTED BY: ` 1G I� 1, �L�� Rai ►. Oal 5 DATE /2 1 /9 I J
Phone No: (-70 st
White copy to fife Yellow copy to operator Pink copy to Mining Specialist
9/91
ON

N.C. Department of Environment, Health, and Natural Resources
Division of Land Resources, Land Quality Section
rrAI,&" inn& T vs
Sheet �- of
Tune: Z ❑ am Cali: Placed ❑ Rcccivcd Q",
Returned ❑
( L�
t. Project:_ CNlu1 �Gbt-� -- 77JAA t� MAI U County:
.-7," ,1 r�,e.,,,,, i r,.r\ 7�K�6 � 'C�o-ti.Li-nZo*
2. Conversation with: l 11- �u'� trw
_t:� Teicphunc: v
3. Affiliation:
<. Content of conversation:
�G_•/J.-f/ .-I` O_iwl /S� / "0 • i%If.:i - r- _ :n."• - '�:�`-I-/L-.'Q ://V
cc: vx-X— Filed by:
�r��(j�t��`dL�-/+�'p--,r,�.C���,c�v r�Y�w:.�v- � r �wv �c% �%--`� �-C�Ns_"•�. ,� y !1

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7
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Adam% nwooft%mmoo
�EHNR
NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT,
HEALTH, AND NATURAL RESOURCES
DIVISION OF LAND RESOURCES
LAND QUALITY SECTION
-n rr.�7v ..srnrr
r.v. DUA L/v8/
RALEIGH, NORTH CAROLINA 27611
TELEPHONE: [phone] FAX: (9l!) 733-2876
FACSIMILE MESSAGE
TO: t7�W�-
COMPANY/DEPARTMENT.-- 460��- .fir )Vtvo ,s
PHONE NO.:
FAX NO.: t7W i -4L— v Zo zo?
FROM. q4±1 `bm�,
DATE:_ 77ME: �—
NUMBER OF PAGES BEING SENT" (INCLUDING THIS PAGE): 2-
•t
, "If
WIMA AM

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Radiation Protection
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
Dayne H. Brown, Director
January 28, 1997
Tracy Davis, RE,
State Mining Specialist
Land Quality Section
n: f r an n .
L1I vlJl Vil iJ1 �.a11U l\�rsVL{r L\,s
P.O. Box 27687
Raleigh, NC 27611-7687
Dear Mr, Davis:
WT?WA
VCI-IIVI �
DEHNR
!A ki 2 8 1997]
.AND QUALITY SECTION �
Upon review of your draft letter dated January 7, 1997, concerning the Cyprus Foote radioactive refuse
disposal, I have been instructed by my supervisor, S. W. (Felix) Fong, Phd., to inform you that the
Division of Radiation Protection is in agreement with the nronosed actions detailed in the draft letter,
This agreement is based on our understanding that the following facts are correct: the waste material in
question consists of demolition debris from the crusher mill area. This debris has a low amount of
naturally occurring radioactive material (in this case, uranium) deposited on its exterior surfaces. In
addition, this material is considered "mining refuse" and as such is exempt from solid waste
rules/regulations. Furthermore, it is our understanding that the materials will be buried in the upper end
of the tailings pond area in accordance with the requirements detailed in your draft letter.
In particular, our management felt that the disposal area for this material must be clearly demarcated
and that detailed records of the disposal process be kept in the appropriate location(s) so that any
disturbance of the material by third parties can be avoided at all costs. Also, these records will be very
important should the land containing the tailings pond area be sold, leased, etc., at any time in the future.
Finally, it is my understanding that the Division of Radiation Protection can expect to receive within the
first quarter of 1997 the following information: a detailed description of the disposal method, a disposal
area map prepared by a registered surveyor, and a final description of the disposal work performed
(including any radiological analyses performed during the disposal process). Additionally, if available, I
`r'r'iii rvvide to both you and tv the a ry riatV r."!U3 Foote veisonnel an LUUUJUJ U1 P1Gv1UUJ WNUR'
P ) pp p rY Y y Y �
by NCDRP of materials collected at Cyprus Foote site. If you have any further questions concerning the
information as detailed in this letter, please do not hesitate to contact me .
Sincerely,
r
r
Christo her J. italizo
Environmental Radiation Technician
Nuclear Facilities & Environmental
Radiation Surveillance Section
cc: S. W. (Felix) Fong, NCDRP
3825 Barrett Dr„ N%ICAn
FAX [phone]
Raleigh, North Carolina 27609-7221 Equal opportunity/Affirmative Action Employer
voice 010_571_4141 vv o reCy�iedj iuic Nost-coii5i.iiiiei paper

RADIATION PROTECTION Fax:[phone] Jan 28 '97
13:39
DIVISION OF RADIATION PROTECTION
Raleigh, North Carolina
Phone: [phone]
FAX [phone]
FACSIMILE TRANSMITTAL COVER SHEET
,
TO: {�-� VG " 1 ! J'
ADDRESS: L G �cSo vd CQI �J l3 f� /1 �c c; L�4�
R • .
FAX
FROI4: C_ (A,r1.5 �4Q.I per`. �� S ��._n ! dG CC�r�
1
DATE:- 0
NU14BER OF PAGES ( Including Cover page)
Should you have any problems with this transmittal, please call:
Name Telephone Number
Revision 2, 02/06/91
W `
�ZE1.Dx�� fix- Dix- �t �5. mac• � �- A- �
Chu- WM;57, S I&XtW.

RADIATION PROTECTION Fax:[phone]
Slate pf. NMC'rollna
,.,epari�i 4 Erl ironmont,
Health and Natural Resources
Division of Radiation Rroiection
James B. Hunt, Jr.; Gov ' mar
Jonathan B. Howes, Se reto
Dayne H. Brown, Direct r
January 28, 1997
Tracy Davis, P.E.
,State Mining Specialist
Land Quality Section
Division of Land Resource
P.O. Box 27687
Raleigh, NC 27611-7687
Dear. Mr. Davis:
Upan�review of your draft
disposal, I have been instri
Division of Radiation Prot
This•agreement is based of
question consists of demo]
naturally occurring radio,%
addition, this material is ci
rules/;regulations. Further
of the tailings pond area it
Jan 28 ' 97 13 : 40 P. 02/02
e��
�EHNR
letter dated January 7, 1997, concerning the Cyprus Foote radioactive refuse
cted by my supervisor, S. W. (Felix) Fong, Phd., to inform you that the
on 15 in agreernunt wlul U1G pA VlJuseu acLIO'n5 ueuldeu in Llle uleuL le-cr.,
our understanding that the following facts are correct: the waste material in
tion debris from the crusher mill area. This debris has a low amount of
Live material (in this case, uranium) deposited on its exterior surfaces. In
nsidered. "mining refuse" andas such is exempt from solid waste
xore, it is our understanding that the materials will be buried in the upper end
accordance with the requirements detailed hi your draft letter.
in particular, our manager ent felt that the disposal area for this material must be clearly demarcated
altd'that detailed records o the disposal process be kept in the appropriate location(s) so that any
di§turbance of the materi by third parties can be avoided at all costs. Also, these records will be very
important should the land ntaining the tailings pond area be sold, leased, etc., at any time in the future.
Fii Oa ! it is my understar
first quarter of 1997 the R
area 'map prepared by a re
(including any radiologicg
will'provide to both you a
by NCDRP of materials c
infohnation as detailed in
Sincerely,
! I - J
t / r
Christopher J. dalgo
Enuirbmxtental Radiation
Nuclear.Facilities & Envi1
RadYation Surveillance S
cc':' S. W. (Felix) Fongl NCDRP
ing that the Division of Radiation Protection can expect to receive within the
owing information: a detailed description of the disposal method, a.disposal
stered surveyor, and a final description of the disposal work performed
analyses performed during the disposal process). Additionally, if available, I
i to the appropriate Cyprus Foote personnel any records of previous testing
lected at Cyprus Foote site. If you have any further questions concerning the
as letter, please do not hesitate to contact me .
3825 130rrott pr.. I � A FAX [phone]
Raleigh, North Carolina 27609-7227 N�� An Equal ORPa�unity/Af�rmEmployer
atNe Action Em to er
Voice 91 rJ 571,4741 50% recycled/10% post -consumer paper

919 233 1007
.-ICEMAX 315 ID:919-233-1007 MAR 09'94 11:24 No.013 P.01
o a�� pro'nov Intooxom
PAX:TRANSMISSION
-VXr10s Wayne C: Fiel,er
Cyprus Foote Mineral Compiiny
DEHNR
FAR 6IAg7-
LAND QUALITY SECTION
Priillip Mapp
Louisiana Chemical & Dismantling Co..
FROM: Willie J. Lee, MPH, MSPH
Radiation Protection, Inc. ,
DATE: March 4, 1994
SUBJECT: Sample Results
Included.are the results of eight samples taken in February.
I apologize for the delay-. My fax machine is out of order.
I vill,meet briefly with NC Division of Radiation Protection
officials,to discuss the results. I think-ve should meet
with State officials early next week to discuss personnel
protection'and waste disposal. I will be in touch.
�i�
BOX 5Q24 CARY, NC 27511 . (919) 4O6-751 i
��/ .

.�QFFICEMAX 316
ID:919-233-1007
MAR 09'94 11:25 Na.013 P.02
NUCLEAR ENERGY SERVICES
ACTIVATION ANALYSIS REPORT
CLIENT Willie J . Lee P. 0. No. VerbalRe Report Na. 420946
Radiation Protection, Inc.
Box ' 5024 Dale of Repoli 3/4/94
Cary, NC 27512 Phone [phone]
EXPERIMENTAL PARAMETERS
3 Hr. irradiations: 1.5 x 1012n/cm2-sec.
Monitored Decay
600 Sec. Counts On An Ortec 38% and 42% GeLi Detector Coupled To
An Ortec Omnigam-N.Computerized Gamma Detection System
ANALYSIS RESULTS
DATA TABLES ATTACHED
1. NAA U and Th Results
2. Natural Gamma Spectroscopy Scans of
Air Slide Ore and Air Slide Fabric
(Based on 12--hour overnight gamma
counts on these samples in as -received
condition)
Issued by: ZWeaver
Jack N.
Head, Nuclear Services
LOCATED AT:
NUCLEAR ENGINEERING DEPARTMENT / N. C. STATE UNIVERSITY / RALEIGH, N. C. 27095 / PHONE: [phone]

, OFFICEMHX 61b iV:91y-266-1UUl MHK Uy'y4 11;15 No.U16 r.U6
TABLE 1
GAMMA SPECTROSCOPY OF AIR SLIDE ORE
Radionuclide
p1cogmroes
Th-234
731.57 ± 1.17010
Ra-226
837.81 ± 0.68%
Pb-214
489.02 ± 0.27010
Bi-214
426.03 ± 0.27%
Pb-210
323.00 ± 28.18%
U-235
34.977 ± 1.04010
Th-227
21.816 ± 10.01 %
Ra-223
16.801 ± 13.52%
Rn-219
18.027 ± 11.48%
AC-228 4.754 ± 13.68°10
Th-228 341.59 ± 12.16%
Pb-212 3951 ± 18.18010
Bi-212 4.858 ± 42.76%
I A48 ± 17.49%
TOTAL, activity in gQM121= scan = 4581.1 pci/grim.

!Jh} l,l`tl"IHR J1J lll yl—LJJTlUUf MHK Uy'y4 11;L*D N0.UlJ t'.U4
TABLE 2
GAMMA SPECTROCOPY OF AIR SLIDE I+ABRIC
Radionuclide _ vicaeurles / jffr_.�
Th-234 2752.9 ± 4.15010
—10Cc'2 -L A IAe)l_
Kh 440 10,)o...) _ -r.1 .7 iv
Pb-214 1609.9 ± 1.23%
Bi-214 1231.4 ± 1.S3%
Pt)-210 1312.8 ± 42.40%
U-235 48.649 ± 10.44%0
Th-227 91.666 ± 28.659/o
Ra-223 85.459 ± 28.34%
Rn-219 88.623 ± 28.74%d
Th-228 1279.2 ± 33.63%
Pb-212 16,129 ± 59.91%
Ti-208 5.476 ± 69.82%
TOTAL activity in complete scan M 17.783 mi/brain.

U �-1ltlylHn Jlb lU �l�" LJJ-lUVf PIHK UJ 'Ju 11 -LC) IYU.UIO f .UJ
n n ._l_ ram_- =rl
Sample 1
Sample 2
Sample 3
Sample 4
Sample 5
Sample 6
Sample. 7
Sample 8
NRC UT
NRC UTH
TABLE 3
NAA of U and Th in Ore Matrices
U
Th
48.263 ± 10.0Q/o " `'
6.118 ± 20.1 %
76,596 t 6.1% 5rp9
23.824 t 14.0%
47.754
6.419 ± 20,0%
46.939 ± 10.4% �, ff°`�
< 1.0
ofc
88.974 ± 5.3% ,��
81,137 t 10.3%
216.82 ± 0.91FO
4.471 ± 27.4 %
Vi.r
977.86 ± 1.2% ° 'OK
45.745 ± 11.6%
t
63.053 ± 7.3010 �`��
< 1.0
112.13 (116 ± 3)
81.509(76±4)
2582.48 (2629 ± 3)
928.00 (910 ± 30)
"0A/0C Note; The values in brackets are the certified or hes1-known values for this
element in these NRC Standard Reference Materials irradiated and analyzed along with
your unknown samples.

PREPARED BY:
DATE:
Willie J. Lee, MPH, MSPH
Rnrlintinn PrntPrtinn Inr_
Box 5024
Cary, N. C. 27512
[phone]
May 2, 1994
On April 21, 1994, fourteen (14) wipe tests were taken on pieces of equipment at the
Cyprus Foote Mineral Company's King's Mountain location and analyzed for removable
radioactive contamination. The wipes taken and equipment tested was identified as
follows:
#10 KREBS CYCLONE (WASHED)
1)
Tub Area
2)
Tub Area
3)
Outside Tub
KMn-In M Ag-RIFIFR (RINSFQ%
4) Inside Basin
5} Outside Surface
KM028 CLASSIFIER UNWASHED
6) Inside Basin
7) Outside Surface
8) GALLAGHER SUMP SURFACE
9} KN049 FLOAT CELL BOX (INSIDE SURFACE)
10) KM052 FLOAT CELL BOX (INSIDE SURFACE)
11) KM029 ROD MILL (UNDERNEATH LIP)
12) KM044 FLOAT CELL BOX (INSIDE SURFACE)
13) KM151 ROTARY KILN LINING
14) THICKENING TANK (RUBBER LINING)
NOTE items $through 14 were also unwashed `the.. area waped .was
approximateliy'100 , cmZ.....

Wipes were analyzed at the Bowman Gray School of Medicine and the results were as
fo11i„nic in rnllntc nor rninisito N-nm]•
I VIIV YYJ VLI, a.V p+ •!•
Sample No. Gamma Count (cpm) Beta -Alpha Count (cpm)
I
339
T3
2
322
30
3
280
27
4
300
28
5
269
27
6
274
21
7
297
29
8
298
33
9
306
'31
10
264
18
11
285
17
12
280
16
13
295
22
14
292
21
Background
274 t 17
39 t 6
The gamma count was performed by a Canberra Model 35 Multi -Channel Analyzer. The
beta -alpha count was performed with an Fberline Model MS-2 Gas Flow Proportional
Counter. The gamma standard used was 137Cs with a reported activity of 0.114 /!Ci on
4-20-81. Correcting for radioactive decay, the activity as of 4-22-94 was 0.0841rCi or
187,430 disintegrations per minute (dpm). The alpha -beta standard was "Sr with a
reported activity of 0.0203 uCi on 9-14-81. Correcting for radioactive decay, the activity
as of 4-22-94 was 0.0149 NCi or 33,009 dpm. The counts for the standards were
29,687 cpm for "Sr and 50,407 cpm for 137Cs. Therefore, the counting efficiencies
were 90% and 27% respectively. As indicated, none of the beta -alpha counts were
outside the statistical variation of background. The gamma count for sample numbers 1,
2, 4, 7, 8, 9, 13 and 14 were slightly above the statistical variation of background.
After subtracting the background count, the following are the results for those wipes:
Sample No. Gamma Count (cpm) Gamma Count (dpm)
1
339
178
2
322
115
4
300
33
7
297
22
8
298
26
9
306
56
13
295
15
14
292
4
When analyzing the 2313U series, the major contributors of gamma emission are 21'Bi and
214Pb, which do not have alpha emissions. The lack of positive results from the beta -
alpha counts may suggest that the slightly elevated counts outlined above might be from
those radionuclides.

� ' '•'fin:'
TABLE 2
GAMMA SPECTROCOPY OF AIR SLIDE FABRIC
Radionuclide
yicocuries / liramn
Th-234
2752.9 ± 4.15%
Ra-226
1855.3 ± 4,19%
Pb-214
1609.9 ± 1.23%
Bi-214
1231.4 ± 1.53 %
Pb-210
1312,8 ± 42.40%
U-235
48.649 ± 10.44%
Th-227
91.666 ± 28.65 %
L2 a.77
. �M rr✓
RS QSQ 7R IAM
•.✓. . ✓ i W rv.. • I v
Rn-219
88.623 ± 28.74%
111-LLO
1 17(1 )
1G!7.4 1 J-7 U-)%U
]Pb-212
16,129.± 59.91%
mrann
11-LU�f
r �rri i..w
J.4 /U M 69.82 o
TOTAL activity in S�lmplptp, scan = 17,783 pci/gram.

STATE OF NORTH CAROLINA CHARLES H. GARDNER
DEPARTMENT OF ENVIRONMENT, DIRECTOR
HEM TLl Akin AIATI ICAI OCCIl11Dr'` c M� M n Q e lU
�.-.�— — � -^.W'— r wvv"--- ■wI am Iw■ \i I v I nrvv
DIVISION OF LAND RESOURCES STATE GEOLOGIST
TO: A [/"" -
DATE _
SUBJECT:
�� � � � "lrlf, _ cl� cs �.2�
,
CL-

State of North Carolina 'T
Department of Environment, ffl7;TA
Health and Natural Resources 4 • •
Division of land Resources
James B. Hunt, ..rr., vcwerrrvr U � 1--1
Jonathan B, Howes, Secretary
Charles H. Gardner, P.G., P,E,
Director and State Geologist
January 8, 1997
Rrt�„ n..l ...L, r.T rr-._.l-
['iL iC0._L IL Y4 Hawn.
Senior Process Engineer
Cypress Foote Mineral Company
348 Holiday Inn Drive
Kings Mountain, North Carolina 28086
RE: Permanent Disposal of Radioactive Mining Refuse
Kings Mountain Mine
Mining Permit No. 23-01
! 1 Cleveland County J IY—__��__
Dear Mr. Hawk:
This letter is a follow-up to our onsite meeting and site
inspection conducted on December 18, 1996 by you and Mr. Stephen
Hooper of Cyprus Foote Mineral Company (CFMC), Mr. Sam Garrison
of Champion Contracting Company, Mr. Chris Fidalgo of the
Division of Radiation Protection (DRP), and Mr. Doug Miller and N^�'
froffi the Land Quality Section. At that time, we discussed the
permanent disposal of two to three tandem truck loads of
radioactive mining refuse (old processing plant materials) at the
mine site.
I agreed to contact the Division of Waste Management (DWM)
to determine if they would require a solid waste disposal permit
to allow the disposal of the above material onsi,te, well above
the water table. Through a telephone conversation with Mr.
Julian Foscue of DWM on January 6, 1997, the above materials are
considered "mining refuse" and, therefore, are exempt from the
solid waste rules. Thus, no solid waste permit will be required
by DWM. However, Mr. Foscue agreed with the procedure we
discussed at the site for the permanent disposal of the material.
This proposed procedure included the following:
1) The radioactive material will be located in the upper
end of the tailings pond, above the high water table
level;
2) A portion of the tailing pond material will be
excavated to provide an area for disposal of the
radioactive material;
Geological Survey Section Land Quality Section Geodetic Survey Section
(9.19) 733-2423 [phone] [phone]
FAX: [phone] FAX. [phone] FAX. [phone]
n _.. n-,�n-r n_�_•_ ntin-inn nnnn rwv_1^-,nn
P.V. WXL/QO/, I,Caie'�lh, Norlfi Cuiuiiriu 2701 1-7687 t;4e hone Y IY-/JJ-JOJJ FAX9IY-M-44U7
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

Mr. Hawk
Page 2
3) A minimum two foot thick Oe
nerwill be placed in
the excavated area priorplacement of the
radioactive material;
4) The radioactive material will be placed in a "thin"
layer, and compacted as much as possible, to reduce the
potential for settlement of the area in the future;
5) Pck
material will be placed a minimum of two foot
along the sides and top of the radioactive
material so as to encase the material;
b) A minimum 20 foot of cover will be provided on top of,
and to the sides of, the radioactive material;
7) A detailed description of the disposal method and an
accompanying map of the disposal area will be prepared
by a registered land surveyor that indicates the
following:
i) the normal pool elevation of the adjacent water
supply pond
ii) the top and bottom elevations of the radioactive
material
iii) the top elevation of the finished tailings pond
surface above the radioactive material
iv) the coordinates of each corner and the distances
between corners of the radioactive material
disposal area
8) Final seeding and tree planting specifications will be
provided, including lime, fertilizer, seeding mixtures,
seeding rates and dates, mulching rates, tree types,
planting dates, and tree spacings
9) Once four (4) copies of a final description of the
above work (including any results of testing conducted
on the radioactive material) and accompanying map have
been submitted to and approved by this office (after
review and comment by the DRP and DWM), the surveyed
map will be recorded on the deed in the Cleveland
County Tax Office identifying the type and location of
the materials and the recorded radiation levels of the
materials permanently disposed at the site

Mr. Hawk
Page 3
10) Four (4) copies of the recorded deed description will
be forwarded to this office to verify completion of the
disposal project
At the December 18th meeting, Mr. Fidalgo of DRP requested
that you forward him a copy of your consultant's test results so
that they could be reviewed and included in his report. If you
have not already done so, please forward these results to Mr.
Fidalgo as soon as possible. Also, I loaned this office's most
recent mine map to you during the meeting so that you could have
it duplicated and promptly returned. To date, the map has not
been returned to this office.
In order to verify that your company concurs with the above
disposal procedure, please advise this office in writing of your
acceptance of this procedure and the tentative dates for
commencement and completion of the disposal activity.
Lastly, please address the other concerns at the mine site
as noted in Mr. Doug Miller's Mine Inspection Report dated
December 18, 1996 (copy enclosed).
I greatly appreciate your company's cooperation regarding
this matter. If you should have any quest' s on the above,
please contact me at (919) 733,,-4574. 7
Sincere!
6n/d'Quality
E. D vis, P.E.
o Minin Specialist
ction
/td
23-01rad.dis
Enclosure: December 18, 1996 Mine Inspection Report
CC: Mr. Doug Miller, P.E., Mooresville Land Quality Section
Mr. Chris Fidalgo, Division of Radiation Protection
Mr. Julian Foscue, Division of Waste Management
Mr. Stephen Hooper, P.E., Cypress Foote Minerals Company
Mr. Dave Douglas, Cypress Foote Minerals Company
Mr. Sam Garrison, Champion Contracting Company

Author: Tracy Davis at NROLROIP
Date: 1/7/97 11:38 AM
Priority: Normal
mn. rr�w, l l .. r,,.,..g" .-.'1 9 ...CA9l.1.... o -.' .r ..a.a' '.t Internet
et
1V l'1..J.J. G4, U Utj <l1,1„. -)V-d V: kV.� 1111 ,�.�4c74C.114 lJ.."7> [74 1111.�L�1�4
CC: Tracy Davis
Subject: Re121: Cypress Foote Minerals Company, ##23-01
------------------------------------ Message Contents ------------------------------------
Doug,
Great idea! I'll add this to the letter.
Thanks for your PROMPT response!! I'll let you know when I hear back
from DRP.
Thanks!!
Tracy
Subject:
Author:
Date:
Reply Separator
Re: Cypress Foote Minerals Company, #23-01
"Miller, Doug" <[e-mail]> at Internet
1/7/97 11:32 AM
A quick review of the letter found that it included all the items I
can recall that we talked about on site. I feel better about the
process with Solid Waste included in the loop and their procedures
used including the recording on the deed about the disposal process.
The only additiion we might do is to ha- e them include onh_e
Leed-@ocraen ut the_leiaf vels of radi6n recorded_so-that whoever
i esear.ches-thi:s� a _that-it_is_not. "hot_s,tuff� What do you think?
Doug

w
Author: Tracy Davis at NROLR0IP
Date: 1/7/97 11:06 AM
Priority: Normal
___
t V : Dl"1111e'L�1n![lr V . e!lS1I.. stdte. ill;.. u5 at Iaxtcrilet
CC: Tracy Davis
Subject: Cypress Foote Minerals Company, #23-01
------------------------------------ Message Contents ------------------------------------
Doug,
Attached is a letter a drafted as a follow-up to our 12/18/96 meeting
regarding the permanent disposal of radioactive materials within the
mining permit area. I tried to lay out all the requirements we
discussed (even though Julian Foscue said no DWM permit will be
required, he agreed strongly with the procedure outlined in the
letter) .
I am faxing a copy to Chris Fidalgo of DRP for his (and his
supervisors) review and comment. I will hold off sending this letter
until I get feedback from both you and Chris, to be sure that
everyone's recommendations are included.
Thanks for your time and help on this .... Let me know what you think
(of the letter)!!
Tracy

N.C. Department of Environment, Health. and Natural Resources
Di%ision of Land Resources, Land Quality, Section
Telenhnne T nQ
E �r>L ■1 LJi lam. �JV
b Ditc:E__ J�i Sheet l of t
Tune: 90 warn Call Placed ❑ Received ❑
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2. Conversation wild: 3 r ) _ Telephone: ( )
4
. Content of conversation:
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NOR771 CAROLINA
DEPARTAl ENT OF ENVIRONMENT,
SEA.L771, AND ' NATURAL RESOURCES
DIVISION OF LAND RESOURCES
LAND QUALITY SECTION
P.O. BOX 27687
RALEIGH, NORTH CAROLINA 27611
TELEPHONE: [phone] FAX. [phone]
FACSIMILE MESSAGE
COMPANY/DEPARTMENT.- -bry, bl�- Ak-b iA<op) NW)
PHONE NO.: 1511 - gig 1
FAX NO.: 511 (�(qd
FROM: "�IL,�-u� ��✓►�
DATE: TIME: l l f S
NUMBER OF PAGES BEING SENT (INCLUDING THIS PAGE):
COMMENTS.: r
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Ju.1�_�ta�� .(C.ok-t5- lO' u49� Win✓ — ym VhL� — � �--

January 7, 1997
Mr. Ralph W. Hawk
Senior Process Engineer
Cypress Foote Mineral Company
348 Holiday Inn Drive
Kinqs Mountain, North Carolina 28086
RE: Permanent Disposal of Radioactive Mining Refuse
Kings Mountain Mine
Mining Permit No. 23-01
Cleveland County
Dear Mr. Hawk:
This letter is a follow-up to our onsite meeting and site
inspection conducted on December 18, 1996 by you and Mr. Stephen
Hooper of Cyprus Foote Mineral Company (CFMC), Mr. Sam Garrison
of Champion Contracting Company, Mr. Chris Fidalgo of the
Division of Radiation Protection (DRP), and Mr. Doug Miller and I
fro<<i the Land QuallLy SecLion. At that time, we discussed the
permanent disposal of two to three tandem truck loads of
radioactive mining refuse (old processing plant materials) at the
mine site.
I agreed to contact the Division of Waste Management (DWM)
to determine if they would require a solid waste disposal permit
to allow the disposal of the above material onsite`, well above
the water table. Through a telephone conversation with Mr.
Julian Foscue of DWM on January 6, 1997, the above materials are
considered "mining refuse" and, therefore, are exempt from the
solid waste rules. Thus, no solid waste permit will be required
by DWM. However, Mr. Foscue agreed with the procedure we
discussed at the site for the permanent disposal of the material_
This proposed procedure included the following:
1) The radioactive material will be located in the upper
end of the tailings pond, above the high water table
level;
2) A portion of the tailing pond material will be
excavated to provide an area for disposal of the
radioactive material;

Mr. Hawk
Page 2
3)
4)
5)
a
A minimum two foot thick clay liner will be placed in
the excavated area prior to the placement of the
radioactive material;
The radioactive material will be placed in a "thin"
layer, and compacted as much as possible, to reduce the
potential for settlement of the area in the future;
Clay material will be placed a minimum of two foot
thick along the sides and top of the radioactive
material so as to encase the material;
A minimum 20 foot of cover will be provided on top of,
and to the sides of, the radioactive material;
7) A detailed description of the disposal method and an
accompanying map of the disposal area will be prepared
by a registered land surveyor that indicates the
following:
i) the normal pool elevation of the adjacent water
supply pond
ii) the top and bottom elevations of the radioactive
material
iii) the top elevation of the finished tailings pond
surface above the radioactive material
iv) the coordinates of each corner and the distances
between corners of the radioactive material
disposal area
8) Final seeding and tree planting specifications will be
provided, including lime, fertilizer, seeding mixtures,
seeding rates and dates, mulching rates, tree types,
planting dates, and tree spacings
9) Once four (4) copies of a final description of the
above work (including any results of testing conducted
on the radioactive material) and accompanying map have
been submitted to and approved by this office (after
review and comment by the DRP and DWM), the surveyed
map will be recorded on the deed in the Cleveland
County Tax Office identifying the type and location of
the materials �p- 4pentl spored at the sate 4&
10) Four (4) copies oftherecorded Aed description will
be forwarded to this office to verify completion of the
disposal project

Mr. Hawk
Page 3
At the December 18th meeting, Mr. Fidalgo of DRP requested
that you forward him a copy of your consultant's test results so
that they could be reviewed and included in his report. If you
have not already done so, please forward these results to Mr.
Fidalgo as soon as possible. Also, I loaned this office's most
recent mine map to you during the meeting so that you could have
it duplicated and promptly returned. To date, the map has not
been returned to this office.
In order to verify that your company concurs with the above
disposal procedure, please advise this office in writing of your
acceptance of this procedure and the tentative dates for
commencement and completion of the disposal activity.
Lastly, please address the other concerns at the mine site
as noted in Mr. Doug Miller's Mine Inspection Report dated
December 18, 1996 (copy enclosed).
I greatly appreciate your company's cooperation regarding
this matter. If you should have any questions on the above,
please contact me at [phone].
Sincerely,
Tracy E. Davis, P.E.
State Mining Specialist
Land Quality Section
/td
23-01rad.dis
Enclosure: December 18, 1996 Mine inspection Report
cc: Mr. Doug Miller, P.E., Mooresville Land Quality Section
Mr. Chris Fidalgo, Division of Radiation Protection
Mr. Julian Foscue; Division of Waste Management
Mr. Stephen Hooper, P.E., Cypress Foote Minerals Company
Mr. Dave Douglas, Cypress Foote Minerals Company
Mr. Sam Garrison, Champion Contracting Company

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State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Land Resources
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
Charles Gardner, P.G., P.E.
Director and State Geologist
June 1, 1994
Mr. L.E. Dotson, Manager
Kings Mountain Operations
Cyprus Foote Mineral Company
P.O. Box 689
Kings Mountain, North Carolina 28086
RE: Mining Permit No. 23-01
Kings Mountain Mine
Cleveland County
Dear Mr. Dotson:
.A F15TA
, T4 '*a
DEHNR
This letter is in reference to the potentially radioactive
"belt/fabric" material that exists at the above referenced site
that was part of the airslide portion of your company's old
processing plant. This material was determined to be radioactive
and, thus, unacceptable by a local scrap metal dealer. As the
dealer would not accept this material, it was transported back to
the mine site for permanent disposal.
As permanent disposal of this material is to occur within the
mining permit boundaries of Mining Permit No. 23-01, such activity
falls within the jurisdiction of the Mining Act of 1971. Such
disposal activity must be considered acceptable under the mine
reclamation plan before such activity can occur at the mine site.
Thus, representatives of the Division of Radiation Protection
(DRP), the N.C. Geological Survey Section, the Land Quality Section
and I have discussed this situation and the results of DRP's
investigation of the subject material. It has been determined that
permanent disposal of the "belt/fabric" material at the mine site
is acceptable provided that all such material is buried at least
twenty (20) feet below the natural ground elevation in a
consolidated, designated area. Four (4) copies of the mine map,
cleariv delineating the size and location of the disposal area,
must be submitted to this office prior to initiating such disposal
activities. . Copies of said map will be provided to each agency
noted above for their information and files.
Geological Survey Section
[phone]
FAX: [phone]
Land Quality Section
[phone]
FAX: [phone]
Geodetic Surrey Section
[phone]
FAX: [phone]
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50%recycled/ 10% post -consumer paper

Mr. Dotson
Page 2
Please be advised that the "belt/fabric" disposal plan noted
above shall be considered a part of your company -Is existing
approved reclamation plan for this site. This disposal plan as,
well as all --other .aspects of your reclamation plan specified in
Mining Permit No..... _23 Q1 _must be adhered --to in order foryour
com,pany to be considered in com fiance with its mining ermit and
the Mining Act of 1971.
Your cooperation in this matter will be greatly appreciated.
If you should have any questions on the above, please contact Mr.
Tracy Davis, State Mining Specialist, at [phone] or me at
[phone].
Sincerely,
Charles H. Gardner, P.G., P.E.
CHG/TED/td
cc* (Mr_ -Tracy--Davis-,--State Mining Specialist
Mr. Jerry Cook, Mooresville Land Quality Regional Engineer
Dr. Jeffrey Reid, N.C. Geological Survey Section
Mr. Mel Fry, Division of Radiation Protection

Author: Tracy Davis at NROLROIP
Date: 12/3/96 5:55 PM
Priority: Normal
iv. us-i.c.i..s.crZiuro.ciiisr oi.uuc.isc.uS u� int'ernet
CC: Tracy Davis
Subject: Cypress Foote Minerals Site Visit
------------------------------------ Message Contents --------
Doug,
I talked to Johnny James of the Div. of Radiation Protection on 12/2
and he is to get back to me this week as to who, if anyone, they want
present at the onsite meeting regarding the final disposal/reclamation
of the radiation contaminated belts/cloth.
I discussed a tenative date with Dave Douglas of Cyprus Foote Minerals
today ... we agreed upon Wednesday, 12/18 at 11:00 am at the mine
office..
Mr. Douglas will be out that week with surgery but has lined up Ralph
Hawk to give us the tour and discuss the disposal. Also, Carl
Champion, the contractor who is to handle the actual disposal, will be
present.
Mr. Douglas said he has a meeting next week with Franklin Industries
to discuss possibly leasing a portion of the tailings pond to them for
re -mining. Franklin Industries has indicated that if they do re -mine,
they will also handle the final disposal of the material, per our
requirements. If the deal goes through, Mr. Douglas will have someone
from Franklin Industries present at the meeting as well.
Please hold this date and time open and I will confirm it with you
once I get final word from DRP (let your appropriate staff members
know as' well).
Thanks!!
Tracy
LvlLb

MEMO
TO: Li W
DATEl � � G
SUBJECT: 6g1k"� f'u�
4�- zz,-0 1
µrY 10 I�h
North Carolina Department of Environment,
r¢• �� 77Aaa �-7-�
Health, and Natural Resources �� prinSedonRecycledPaper

Author: "Miller, Doug" <[e-mail]> at Internet
Date: 11/22/96 8:35 AM
Priority: Normal
n_ _�
Receipt Requested
TO: Tracy Davis at NROLROIP
Subject: Foote Mineral Inspection
-------------------------------------- Message Contents -------------------- =---------------
I have another meeting on 12/10 but the remainder of the time in tour
memo is ok. Let me know as soon as you can.
Doug

Author: Tracy Davis at NROLR0IP
Date: 11/19/96 3:54 PM
Priority: Normal
1 V • 4l11111G1rA
,7mro . G11nr . .7 ate . nc . us at Internet
CC: Tracy Davis
CC: Mell Nevils
CC: Charles Gardner
CC: Jim Simons
CC: Tony Sample
CC: Judy Wehner
Subject: Cyprus Foote Minerals - Permit No. 23-01, Cleveland Co.
------------------------------------ Message Contents -------___---------------------------
Doug,
Back in mid-1994, CFM had problems disposing of some belt/fabric from
the aizslide portion of its old processing plant offsite. The
Division of Radiation Protection and the Geological Survey Section
brought this matter to our attention because of the radioactive nature
of this material. The issue was the final disposal of this material
ONSITE as part of final reclamation. It was determined that if it was
buried in a designated area at least 20 feet deep, it should be ok
(see the 6/1/94 letter from Charles to CFM and Daphne Cartner's memo
to file dated 4/3/95 in your file for more specific information).
Johnny James of DRP called me yesterday and asked me the status of the
disposal and if we had a map indicating the size and location of the
area. I then called Dave Douglas, Mine Manager of CFM, and asked him
the status. He said they have not yet disposed of the material but he
was planning to do so by the end of 12/96 as he currently has a
contractor onsite (and wants this billed to his 1996 budget). I
reminded him of the requirement to submit a map PRIOR TO disposal for
all agencies to review the size and location.
He requested that LQS and DRP schedule an onsite meeting with him so
he can show us the size and location of the disposal area he wants to
use. He said it is in one end of an existing tailings pond at the
site. He also said that Franklin Industries is interested in
"re -mining" the tailings pond for feldspar and other minerals. Thus,
the question arises as to how close mining can occur to the disposal
area.
I agree that we should meet at the site and discuss this matter with
all those concerned present. Dave did not have a problem with the
week of 12/9-13 or 12/16-20. Do you have any preferences? Who is
your tech for this county? I recommend that you and your tech attend
as well as me and Mell (as a minimum from this office). Once we pick
a date, I will call CFM and DRP to finalize the date and time.
Please let me know something by the end of the week!
Thanks!!
Tracy

Author: Tracy Davis at NROLR01P
Date: 11/19/96 5:19 PM
Priority: Normal
TO: Mell Nevils'
Subject: Re[2]: Cyprus Foote Minerals - Permit No. 23-01, Cleveland C
-------------------------------------- Message Contents -_--_------------------------------
Mell,
I just thought you might be interested in this as there was such a big
stink about it 2 years ago! No problem, Doug, his tech and I can
handle!!
Tracy
Reply Separator
Subject: Re: Cyprus Foote Minerals - Permit No. 23-01, Cleveland Co.
Author: Mell Nevils at NROLR0IP
Date: 11/19/96 5:02 PM
Tracy
Probably don't need two people.
Forward Header
Subject: Re: Cyprus Foote Minerals - Permit No
Author: Charles Gardner at NROLROIP
Date: 11/19/96 5:03 PM
23-01, Cleveland Co.
Mell, I question whether two people from Raleigh need to go, unless it
happens to fit with some other real need for two from here to travel
in that same area. Your call.
Reply Separator
Subject: Cyprus Foote Minerals - Permit No. 23-01, Cleveland Co.
Author: Tracy Davis at NROLR0IP
Date: 11/19/96 3:54 PM
Doug,
Back in mid-1994, CFM had problems disposing of some belt/fabric from
the airslide portion of its old processing plant offsite. The
Division of Radiation Protection and the Geological Survey Section
brought this matter to our attention because of the radioactive nature
of this material. The issue was the final disposal of this material
ONSITE as part of final reclamation. It was determined that if it was
buried in a designated area at least 20 feet deep, it should be ok
(see the 6/l/94 letter from Charles to CFM and Daphne Cartner's memo
to file dated 4/3/95 in your file for more specific information).
Johnny James of DRP called me yesterday and asked me the status of the
disposal and if we had a map indicating the size and location of the
area. I then called Dave Douglas, Mine Manager of CFM, and asked him
the status. He said they have not yet disposed of the material but he
was planning to do so by the end of 12/96 as he currently has a

contractor onsite (and wants this billed to his 1996 budget). I
reminded him of the requirement to submit a map PRIOR TO disposal for
all agencies to review the size and location.
He requested that LQS and DRP schedule an onsite meeting with him so
he can show us the size and location of the disposal area he wants to
use. He said it is in one end of an existing tailings pond at the
site. He also said that Franklin Industries is interested in
"re -mining" the tailings pond for feldspar and other minerals. Thus,
the question arises as to how close mining can occur to the disposal
area.
I agree that we should meet at the site and discuss this matter with
all those concerned present. Dave did not have a problem with the
week of 12/9-13 or 12/16-20. Do you have any preferences? Who is
your tech for this county? I recommend that you and your tech attend
as well as me and Mell (as a minimum from this office). Once we pick
a date, I will call CFM and DRP to finalize the date and time.
Please let me know something by the end of the week!
Thanks!!
Tracy

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH,
AND NATURAL RESOURCES
ML
REF--iNf=l
FAX TRANSMITTAL COVER SHEET
DATE: 41-1j6,
FROM. -
DEPARTMENT OF ENVIRONMENT HEALTH AND NATURAL RESOURCES
DIVISION OF LAND RESOURCES
LAND QUALITY SECTTON
P.O. BOX 27687
D A T UTL"T TT XTn7)'TIT 7 !TA H/1T TA7A -1 "f LYY
LLrfL.LaLVLI, lytIAIA LtALI{lLL1Yt7 L/Ull
(9I9) 733-4574
FAX NUMBER: 733-2876
'TO: -t,)kvc -Drw,-LA
COMPANY/DEPARTMENT.6 ffW 'S Fb9��
PHONE NO.: (�Uq) -7 ;7i'127i
FAX NO.:
COMMENTS:
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State of North Carolina
Department of Environment,
Health and Natural Resources
Dlvlslon of Land Resources
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
Charles Gardner, P.G., P.E.
Director and State Geologist
June 1, 1994
Mr. L.E. Dotson, Manager
Kings Mountain Operations
Cyprus i VlJ to in al Company
P.O. Box 689
Kings Mountain, North Carolina 28086
RE: Mining Permit No. 23-01
Kings Mountain Mine
Cleveland County
Dear Mr. Dotson:
X71.6MA,
IDEHNR
This letter is in reference to the potentially radioactive
"belt/fabric" material that exists at the above referenced site
that was part of the airslide portion of your company's old
processing plant. This material was determined to be radioactive
and, thus, unacceptable by a local scrap metal dealer. As the
dealer would not accept this material, it was transported back to
the mine site for permanent disposal..
As'
ppermanent disposal of this material is to occur within the
mining permit boundaries of Mining Permit No. 23-01, such activity
falls within the jurisdiction of the Mining Act of 1971. Such
disposal activity must be considered acceptable under the mine
reel amati r)n' nl an hPfnrP s»r-h activity r-an nrr-ivr at the mina cii-in ,
Thus, representatives of the Division of Radiation Protection
(DRP), the N.C. Geological Survey Section, the Land Quality Section
and I have discussed this situation and the results of DRP's
investigation of the subject material. It has been determined that
permanent disposal of the "belt/fabric" material at the mine site
is acceptable provided that all such material ,is buried at least
twenty (20) feet below the natural ground elevation in a
consolidated, designated area. Four (4) copies of the mine map,
clearing delineating the size and location of the disposal area,
must be submitted to this office prior to initiating such disposal
activities. . Copies of said map will be provided to each agency
noted above for their information and files.
Geological Survey Section
[phone]
FAX: [phone]
Land Quality Section
[phone]
FAX: [phone]
Geodetic Survey Section
[phone]
FAX: [phone]
P.O. Box 27687 Raleigh, Nnr+1, rvnrdin�n, 27(,1 7_76R7 Tnlcnhnnn 070_734_3A343 FAY ol0_733__7
An Equal opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

Mr. Dotson
Page 2
Please be advised that the "belt/fabric" disposal plan noted
above shall be considered a part of your corn an 's existinq
approved reclamation plan for this site. Thisdisposal_Rlan as
well as all other aspects of your reclamation tan specified in
Mining Permit No._23-01 must be adhered to in order for your
company to be considered in compliance with its mining permit and
the Mining ,Act of 1971.
Your cooperation in this matter will be greatly appreciated.
If you should have any questions on the above, please contact Mr.
Tracy Davis, State Mining Specialist, at [phone] or me at
[phone].
Sincerely,
Charles H. Gardner, P.G., P.E.
CHG/TED/td
cc: Mr. Tracy Davis, State Mining Specialist
Mr. Jerzy Cook, Mooresville Land Quality Regional Engineer
Dr. Jeffrey Reid, N.C. Geological Survey Section
Mr. Mel Fry, Division of Radiation Protection
J

April 3, 1995 rD UIVE ZdMEMORANDUM 9anc f�l�
TO FILE
By
FROM: DAPHNE CARTNER t&KC—
SUBJ: CYPRUS'FOOTE'MINERALS
CLEVELAND COUNTY
on March 29-, 1995, Jerry -Cook and I met with Carl Champion and
Sam Garrison, with Champion Grading and Dave Douglas, Wayne Fieler,
and Gary Cooper with Cyprus Foote Minerals. The purpose of the
meeting was the reclamation of the plant tailings pond. Champion
W.' l,�ri r�rnr.nceri »cinrt f-he ��ilinrrc ir, ti,e imren�inrl,nor�� �re� �n
grade and. slope the basin area.
The tailing -pond is dry and has no drainage area except that
which falls on the area. The material is sufficiently dry to be
move (panned) through the basin area to met the slope requirements
of the permit and stabilization needs.
The Cyprus Foote representatives asked about burying the
radioactive contaminated materials from the old processing plant in
the upper end of the tailings pond using a clay cap. Jerry said
that this was an options but that the material should clay encased
no just capped. This area is about the groundwater table and is
deep enough to met the requirements outlined in the letter dated
June 1, 1995, from Charles Gardner. Jerry noted that a location
map must be submitted prior to such burial.
We asked about the status of the breach of the chemical
tailings pond. We were told that it was completa and as -built
drawings were in the final stages prior to submittal. Inspection
of the breach revealed a riprapped channel 56' wide at the mouth,
511 wide -near -the center and then began to flair to the outlet of
the channel... The disturbed areas had been seeded but not yet
mulched..
"-. Douglas said t'-twt they wcul d c:,mplete the as-- laL,i lts for
the chemical tailings pond and submit location maps for the
proposed burial of l.i1G radAJLoaL 4,.1Ve material a a laas soon as pVw�7 w�71i.]1C.
Mr.. Garrison said that Champion Grading would not begin
reclamation of the plant tailings pond until the location maps had
been submitted..
cc:, Bracy Davis, PE
Jim Leumas, PE

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MEMO
TO: FILE
FROM: J.W. COO �C
RE: FOOTE MINERAL MINE
CLEVELAND COUNTY
SUBJ: RADIOACTIVE MATERIAL
10 MARCH 19 9 4: 1
MAR 1 u
NELL NEVILS TELEPHONED ME IN REFERENCE TO SOME SCRAP METAL
BEING HAULED FROM THE MINE AND BEING DETECTED AS RADIOACTIVE, THEN
BEING RETURNED TO THE MINE. HE REQUESTED THAT I ACCOMPANY SOME OF
MY STAFF TO INSPECT THE MINE.
I CONTACTED THE RADIOACTIVE MATERIAL SECTION IN RALEIGH AND
SPOKE WITH GRANT MILLS, TWO TIMES.
HIS RESPONSE TO QUESTIONS;
- IF THEY KNEW ABOUT SUBJECT?
YES, IF SAME SITE, INCIDENT HAPPENED ABOUT TWO WEEKS AGO.
- SOME BACKGROUND?
THEY HAD RECEIVED A TELEPHONE CALL FROM SOME SCRAP YARD,
THOUGHT SCRAP YARD WAS IN KINGS MOUNTAIN, RELAYING THAT
THEIR INSTRUMENT HAD DETECTED HIGH LEVELS OF
RADIOACTIVITY.
- THAT HAPPENED TO METAL?
SORTED AND AFFECTED PIECES SHIPPED BACK TO MINE SITE.
- HOW MUCH METAL?
TWO TRAIN CAR LOADS.
- DO YOU HAVE PEOPLE IN YOUR SECTION TO DO FIELD SURVEY AND
ASSIST US IF NEEDED?
YES, FOUR PEOPLE THAT COVERS THE STATE, MUST HAVE
ADVANCED NOTICE.
HE ALSO TOLD ME THAT WHEN AN INCIDENT IS REPORTED, THE OWNER
MUST HIRE A PRIVATE CONSULTANT TO CONDUCT TESTS AT THE SITE OF
ORIGIN. HE TOLD ME A MR. WILLIE LEE HAD BEEN HIRED AND HAD BEEN AT
THE MINE. RADIOACTIVE MATERIALS TELEPHONE # [phone].
CON,T.---15 MARCH 1994
I HAD TELEPHONED MR. LEE AND PLACED A MESSAGE ON HIS ANSWERING
MACHINE. HE RETURNED MY TELEPHONE CALL AND I WAS TALKING ON THE
PHONE. HE STATED THAT HE WOULD BE IN UNTIL LUNCH TIME, THIS DATE.
I TELEPHONED HIM AGAIN AND SPOKE WITH HIM FOR ABOUT TWENTY--
FIVE MINUTES. THE MAJOR ITEMS WE DISCUSSED ARE AS FOLLOWS:
HE HAS BEEN TO THE MINE AND DID SOME TESTING. HE IS GOING BACK
TO THE MINE THIS THURSDAY.
THE SCRAP METAL IS FROM A BUILDING BEING TORN DOWN, PRIMARILY
FROM CONVEYOR FABRIC AND METAL DUCTS. THE MATERIAL WAS TRANSPORTED
TO FLORIDA STEEL IN CHARLOTTE, BY TRAIN AND THEY ARE

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PAGE 2 — FOOTE MINERAL
15 MARCH 1994
THE PEOPLE THAT REPORTED THE RADIOACTIVITY TO RADIOACTIVE MATERIALS
IN RALEIGH. SOME MACHINERY HAS ALSO BEEN SOLD TO COMPANIES OUT OF
STATE THAT MAY BE CONTAMINATED.
— CAUSE OF PROBLEM? DUST IN OLD BUILDING, STOCKPILED ORE AND
WASTED ORE IN AND AROUND BUILDING. ORE CONTAINS URANIUM OR URANIUM
THORIUM, SPODUMENE (LITHIUM ALUM. SILICATE) AND SAMPLES TESTED TO
BE HIGHER THAN ANYWHERE ELSE IN NORTH CAROLINA.
— RESIDUAL ORE WAS ONLY PLACE TESTED, RADIOACTIVITY THREE OR
FOUR TIMES HIGHER THAN NATURAL OCCURRENCE.
OTHER PROBLEMS? RADON GAS?
AIR QUALITY?
OLD QUARRY FILLED WITH WATER, MAY BE
CONTAMINATED?
LARGER WASTE PILES?
RECLAMATION PROBLEMS?
WE ALSO DISCUSSED OTHER SITES IN THE AREA; MARTIN—MARIETTA
QUARRY NEXT TO THIS SITE, OTHER QUARRIES THAT MINE SPODUMENE
AS THEY MIGHT HAVE THE SAME PROBLEMS, AND SOME DISCUSSION ABOUT WHO
HANDLES " A , PLUS THERE BEING NO Lnl1.JLES COVERING THIS TYPE OF
PROBLEM.
NOTE: DAPHNE CARTNER AND I ARE GOING TO CONDUCT AN ON —SITE
INSPECTION OF THE QUARRY TOMORROW, 16 MARCH 1994.
MR. LEE WILL KEEP ME INFORMED AS TO FINDINGS AND DECISIONS AND
I WILL ALSO KEEP HIM ABREAST OF OUR ACTIONS.
ilR. LEE, S TELEPHONE N 919�6667i 0909, VOICE VPa 1. n 919=406—
7511.