WQ0008149_Regional Office Historical File Pre 2018

NUMBER NCD000771964 DATE ISSUED August 15, 1990
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NO. NCD000771964
•-- H A Z A R D O U S W A S T E M A N A G E M E N T P E R M 1 T
Permittee Lithium Corporation of America Owner: FMC Corporation
Post Office Box 795
Highway 161
Bessemer City, North Carolina 28016
Pursuant to the 10 NCAC 10F North Carolina Hazardous Waste Management Rules,
an operating permit is issued to the FMC Corporation - Lithium Division,
hazardous waste management facility located in Bessemer City, Gaston County
on Highway 161, at latitude 35' 17' 00" and longitude 810 17' 45".
The Permittee must comply with all terms and conditions of the permit. This
permit consists of the conditions discussed in Parts I, II, III, IV, V, VI,
and VII, the applicable regulations contained in 40 CFR Parts 260 through
264, 266, 268, 270 and 124 [as adopted in 10 NCAC (North Carolina
Administrative Code) 10F .0001 - .0002 and .0029 - .0037, .0039 and .00421,
statutory requirements of N.C.G.S. 130A-Article 9 (Solid Waste Management Act
as amended) and the attached Application. Applicable regulations are those
which are in effect on the date of issuance of this permit [40 CFR 270.32(c)
as adopted in 10 NCAC 10F .0034] and are attached. This permit is based on
the assumption that the information submitted in the permit application -and
as modified by subsequent amendments (hereafter referred to as the
attachment) is accurate and that the facility will be operated as specified
in the attachment. Any inaccuracies found in this information could lead to
the termination or modification of this permit and potential enforcement
action [40 CFR 270.41, 270.42, and 270.43 as adopted in 10 NCAC 1OF .00343.
The Permittee shall inform the North Carolina Department of Environment,
Health, and Natural Resources of any deviation from or changes in the
information in the application :which would affect the Permittee's ability to
comply with the applicable regulations or permit conditions.
This permit is effective as of September 14, 1990, and shall remain in effect
until September 14, 2000, unless revoked and reissued, or terminated [40 CFR
270.50 as adopted in 10 NCAC 1OF .0034] or continued in accordance with 40
CFR 270.51 as adopted in 10 NCAC 1OF .0034.
William L. Meyer, Dire nor
Solid Waste Management Division
0182-1-28
DEHNR-11/89
g /S��D
Date

PART I
PART II
PART III
PART IV
PART V
PART VI
PART VII
APPENDIX A
APPENDIX B
PART A
PART
B
PART
C
PART
D
PART
E
PART
F
PART
G
PART
H
PART
I
PART
J
PART
K
PART
L
SUPPLEMENT I
SUPPLEMENT II
TABLE OF CONTENTS
TOPIC
Standard Conditions
General Facility Conditions
Storage 'in Containers
Storage in Tanks
Solid Waste Management Units
Waste Minimization
Land Disposal Restrictions
Solid Waste Management Unit Summary
RCRA Facility Investigation (RFI) Workplan Outline
ATTACHMENT - Lithium Corporation of America
Permit Application
Part A Application
Facility Description
Waste Characterization
Process Information
Ground Water Monitoring
Procedures to Prevent Hazards
Contingency Plan and Emergency Procedures
Personnel Training
Closure Plan
Other Federal Laws
Certification
Disclosure Statement
RCRA Facility Assessment Report
Response to January 30, 1990 EPA
Notice of Deficiency
2

PART I - STANDARD CONDITIONS
T
The Permittee is allowed to store hazardous waste in accordance with the
conditions of this permit. Any storage, treatment, or disposal of hazardous
waste not authorized in this permit is prohibited. Compliance with this
permit constitutes compliance, for purposes of enforcement, with the N.C.
Hazardous Waste Management Rules (10 NCAC 10F) and NCGS 130A-Article 9 (Solid
Waste Management Act as amended). Issuance of this permit does not convey
property rights of any sort or any exclusive privilege; nor does it authorize
-any injury to persons or property, any invasion of other private rights, or
any infringement of State or local law or regulations. Compliance with the
terms of this permit does not constitute a defense to any action brought
under any law governing protection of public health or the environment for
any imminent and substantial endangerment to human health or the environment.
B. PERMIT ACTIONS
This permit may be modified, revoked and reissued, or terminated for cause as
specified in 40 CFR 270.41, 270.42, and.270.43 as adopted in 10 NCAC 1OF
.0034. The filing of a request for a permit modification, revocation and
reissuance, or termination or the notification of planned changes or
anticipated noncompliance on the part of the Permittee does not stay the
applicability or enforceability of any permit condition.
C. SEVERABILITY
- The provisions of this permit are severable, and if any provision of this
permit or the application of any provision of this permit to any
circumstance, is held invalid, the application of such provision to other
circumstances, and the remainder of this permit shall not be affected
thereby.
D. DUTIES AND REQUIREMENTS
1. Duty to Comply. The Permittee shall comply with all conditions of this
permit, except to the extent and for the duration such noncompliance is
authorized by an emergency permit issued under 40 CFR 270.61 as adopted
in 10 NCAC 1OF .0034. Any permit noncompliance constitutes a violation
of N. C. Hazardous Waste Management Rules and N.C.G.S. 130A-Article 9
(Solid Waste Management Act as amended) and is grounds for enforcement
action, permit termination, revocation and reissuance, modification, or
for denial of a permit renewal application.
2. Duty to Reapply. If the Permittee wishes to continue an activity
regulated by this permit after the expiration date of this permit, the
Permittee must submit a complete application for a new permit at least
180 days before this permit expires.

Permit Expiration. This permit and all conditions therein will remain
in effect beyond the permit's expiration date and until a decision is
made concerning issuance of a new permit if the Permittee has submitted
a timely, complete application'(see 40 CFR 270.14-270.29 and 270.10 as
adopted in 10 NCAC 1OF .0034) and through no fault of the Permittee; the
Secretary of the Department of Environment, Health, and Natural
Resources or his designee (hereafter referred to as the Department) has
not issued a new permit as set forth in 40 CFR 124.15 as adopted in 10
NCAC 1OF .0035.
4. Need to Halt or Reduce Activity Not a Defense. It 'shall not be a
defense for a Permittee in an enforcement action that it would have been
necessary to halt or reduce the permitted activity in order to maintain
compliance with the conditions of this permit.
5. Duty to Mitigate. The Permittee shall take all reasonable steps to
minimize or correct any adverse impact on the environment resulting from
noncompliance with this permit.
6. Proper Operation and Maintenance. The Permittee shall, at all times,
properly operate and maintain all facilities and systems of treatment
and control (and related appurtenances) used by the Permittee to achieve
compliance with the conditions of.this permit. Proper operation and
maintenance includes..effective.performance, adequate.funding, adequate
operator staffing and training, and adequate laboratory and process
controls, including appropriate quality assurance procedures. This
provision requires the operation of -back-up or auxiliary facility or
similar systems only when necessary to achieve compliance with the
conditions of the permit.
7. Duty to Provide Information: The Permittee shall furnish to the
Department, within a reasonable time, any relevant information which the.
Department may request to determine whether cause exists for modifying,
revoking and reissuing, or terminating this permit, or to determine
compliance with this permit. The Permittee shall also furnish to the
Department, upon request, copies of records required to be kept by this
permit.
8. Inspection and Entry. The Permittee shall allow the Department or an
authorized representative, upon the presentation of credentials and
other documents as may be required by law to:
a) Enter at reasonable times upon.the Permittee's premises where a
regulated facility or activity is located or conducted, or where
records must be kept under the conditions of this permit;
b) Have access to and copy, at reasonable times, any records that must
be kept under the conditions of this permit;
I-2

c) Inspect at reasonable times any facilities, equipment (including
monitoring and control equipment), practices, or operations
regulated or required under this permit; and
d) Sample or monitor, at reasonable times, for the purposes of
assuring permit compliance or as otherwise authorized by the N. C.
Hazardous Waste Management Rules, any substances or parameters at
any location.
9. Monitoring and Records.
a) Samples and measurements taken for the purpose of monitoring shall
be representative of the monitored activity. The method used to
obtain a representative sample of the waste to be analyzed must be
the appropriate method from Appendix I of 40 CFR Part 261 as
adopted in 10 NCAC 1OF .0029 and as stated in Section C of the
attachment. Laboratory methods must be those specified in Section
C-2b of the attachment.
b) The Permittee shall retain records of all monitoring 'information,
including all calibration and maintenance records, and all original
strip chart recordings for continuous monitoring instrumentation,
copies of all reports and records_ required by this permit, and
records of all data used to complete the application for this
permit for a period of at least three (3) years from the date of
the sample, measurement, report or record. These periods may be
extended by request of the Department at any time and are
automatically extended during the course of any unresolved
enforcement action regarding this facility.
c) Records of monitoring information shall include:
(1) The date, exact place, and time of sampling or
measurements;
(2) The individual(s).who performed the sampling or
measurements;
(3) The date(s) analyses were performed;
(4) The individual(s) who performed the analyses;
(5) The analytical techniques or methods used; and
(6) The results of such analyses.
10. Reportinq Planned Changes. The Permittee shall give notice to the
Department as soon as possible of any planned.physical alterations or
additions to the permitted facility.
11. Anticipated Noncompliance. The Permittee shall give advance notice to
the Department of any planned changes in the permitted facility or
activity which may result in noncompliance with permit requirements.
I-3

Transfer of Permits. This permit may be transferred to a new owner or
operator only if it is modified or revoked and reissued pursuant to 40
CFR 270.40, 270.41 and 270.42 as adopted in 10 NCAC 1OF .0034. Before
transferring ownership or operation of the facility during its operating
life, the Permittee shall notify the new owner or operator in writing of
the requirements of 40 CFR 264 as adopted in 10 NCAC 1OF .0032 and 40
CFR 270 as adopted in 10 NCAC 1OF .0034.
13. Compliance schedules. Reports of compliance or noncompliance with, or
any progress reports on, interim and final requirements contained in any
compliance schedule of this permit shall be submitted no later than
fourteen (14) days following each schedule date.
14. Twenty-four Hour Reporting. The Permittee shall report to the Department
any noncompliance which may endanger health or the environment. Any
information shall be provided orally within 24 hours from the time the
Permittee becomes aware of the circumstances. The following shall be
included as information which must be reported orally within 24 hours:
a) Information concerning release of any -hazardous waste that may
cause an endangerment to public drinking water supplies.
b) Any information of a release or discharge of hazardous waste, or of
a fire or explosion from the facility, which could threaten the
environment or human health outside the facility. The description
of the occurrence and its cause shall include:
(1) Name, address, and telephone number of the owner or
operator;
(2) Name, address, and telephone number of the facility;
(3) Date, time, and type of incident;
(4) Name and quantity of material(s) involved;
(5) The extent of injuries, if any;
(6) An assessment of actual or potential hazard to the
environment and human health outside the facility, where
this is applicable; and
(7) Estimated quantity and disposition of recovered material
that resulted from the incident.
A written submission shall also be provided within five (5) days of the
time the Permittee becomes aware of the circumstances. The written
submission shall contain a description of the noncompliance and its
cause; the periods of noncompliance (including exact dates and times),
and if the noncompliance has not been corrected, the anticipated time it
is expected to continue; and steps taken or planned to reduce,
eliminate, and prevent reoccurrence of the noncompliance. The Permittee
need not comply with the five-day written notice requirement if the
Department waives that requirement and the Permittee submits a written report
within fifteen (15) days of the time the Permittee becomes aware of the
circumstances.
I-4
T

15. Other Noncompliance. The Permittee shall report all other instances of
noncompliance not otherwise required to be reported at the time
monitoring reports are submitted. The reports shall contain the
information listed in Condition I.D.14.
16. Other Information. When the Permittee becomes aware that he failed to
submit any relevant facts in the permit application, or submitted
incorrect information in a permit application or in any report to the
Department, the Permittee shall promptly submit such facts or
information.
E. SIGNATORY REQUIREMENTS
All reports or other information requested by the Department shall be signed
and certified according to 40 CFR 270.11 as adopted in 10 NCAC 1OF .0034.
F. DOCUMENTS TO BE MAINTAINED AT FACILITY SITE
The Permittee shall maintain at the facility, until closure is completed and
certified by an independent registered professional engineer, the following
documents and amendments, revisions and modifications to these documents:
1. Waste.analysis plan submitted in accordance with 40 CFR 264.13 as
adopted in 10 NCAC 1OF .0032 and Section C of the attachment.
2. Personnel training documents and records submitted in accordance with 40
CFR 264.16(d) as adopted in 10 NCAC 1OF .0032 and Section H of the
attachment.
3. Contingency plan submitted in accordance with 40 CFR 264.53(a) as
adopted in 10 NCAC 10F .0032 and Section G of the attachment.
4. Closure plan submitted in accordance with 40 CFR 264.112(a) as adopted
in 10 NCAC 10F .0032 and Section I of the attachment.
5. Cost estimate for facility closure submitted in accordance with 40 CFR
264.142(d) as adopted in 10 NCAC 1OF .0032 and Section I of the
attachment.
6. Operating record required by 40 CFR 264.73 as adopted in 10 NCAC 1OF
.0032, and Sections C, F, G and H of the attachment.
7. Inspection schedules developed in accordance with 40 CFR 264.15(b) as
adopted in 10 NCAC 10F .0032 and Section F of the attachment.
All amendments, revisions and modifications to any plan or cost
estimates required by this permit shall be submitted to the Department
for approval and/or permit modifications.
I-5

REPORT
The Permittee shall prepare and submit an annual report by March 1 of each
year in accordance with 10 NCAC 1OF .0037. The report shall include, in
accordance with 40 CFR 264.75 as adopted in 10 NCAC 1OF .0032, the following
information for facility activities during the previous calendar year:
1. The EPA identification number, name, and address of the facility;
2. The calendar year covered by the report;
3. For off -site facilities, the EPA identification number of each hazardous
waste generator from which the facility received a hazardous waste
during the year; for imported shipments, the report must give the name
and address of the foreign generator;
4. A description and the quantity of each hazardous waste the facility
received during the year;
5. The method of treatment, storage, or disposal of each hazardous waste;
6. The most recent closure cost estimate under 40 CFR 264.142 as adopted in
10 NCAC 10F .0032;
7. For generators who treat, store, or dispose of hazardous waste on -site,
a description of the efforts undertaken during the year to reduce the
volume and toxicity of waste generated;
l.'
8. For generators who treat, store, or dispose of hazardous waste on -site,
a description of the changes in volume and toxicity of waste actually
achieved during the year in comparison to previous years to the extent
such information is available for the years prior to 1984; and
9. The certification signed by the owner or operator of the facility or his
authorized representative.
H. MANIFEST SYSTEM
1. The Permittee shall utilize the manifest system when receiving hazardous
waste from off -site in accordance with 40 CFR 264.71 as adopted in 10
NCAC 10F .0032 unless the Permittee submits an unmanifested waste report
in accordance with 40 CFR 264.76 as adopted in 10 NCAC 1OF .0032.
2. The Permittee shall report any manifest discrepancies in accordance with
40 CFR 264.72 as adopted in 10 NCAC 1OF .0032.
I-6

INITIONS
For purposes of this permit, terms used herein shall have the same meaning as
those in RCRA and 40 CFR Parts 124, 260, 261, 264, and 270, unless this permit
specifically provides otherwise; where terms are not defined in the
regulation, the permit, or EPA guidance documents or publications, the
meaning associated with such terms shall be defined by a standard dictionary
reference or the generally accepted scientific or industrial meaning of the
term.
J. CONFIDENTIAL INFORMATION
The Permittee may claim confidential any information required to be submitted
by this permit in accordance with 40 CFR 270.12 as adopted in 10 NCAC 1OF
.0034.
I-7

I
hazardous
conditions
PART II - GENERAL FACILITY CONDITIONS
Waste. The Permittee is authorized to store the following
waste(s) or categories of hazardous waste in accordance with the
specified in this permit:
1. Characteristic Wastes
D001
Ignitable
D002
Corrosive
D003
Reactive - Lithium compounds
D004
EP Toxicity -
Arsenic
D007
EP Toxicity -
Chromium
D008
EP Toxicity -
Lead
D009
EP Toxicity -
Mercury
2. Nonspecific Sources
F003 The following spent non -halogenated solvents: xylene,
acetone, ethyl acetate, ethyl benzene, ethyl ether,
methyl isobutyl ketone, n-butyl alcohol, cyclohexanone,
and methanol; and the still bottoms from the recovery of ---
these solvents.
F005 The following spent non -halogenated solvents: toluene,
methyl ethyl ketone, carbon disulfide, isobutanol, and
pyridine; and the still bottoms from the recovery of
these solvents.
3. Commercial Chemical Products, Manufacturing Chemical Intermediates,
or Off -specification Commercial Chemical Products
U031 n-Butyl Alcohol
U055 Cumene
U117 Ethyl Ether
U124 Furan
U213 Tetrahydrofuran,
The Hazardous Waste Container Storage area may be used to store containers of
D001, D002, D003, D004, D007, D008, D009, F003, F005, U031, U055, U117, U124, and
U213 as specified in Section D of the attachment and Condition III. A -I.
The Hazardous Waste Storage Tanks may be used to store D001, D003, F003, F005,
U031, U055, U177, U124, and U213 as specified in Section D of the attachment and
Condition IV. A-J.
B. Design and Operation of Facility. The Permittee shall maintain and operate
the facility to minimize the possibility of a fire, explosion, or any
unplanned sudden or nonsudden release of hazardous waste constituents to air,
soil or surface water which could threaten human health or the environment.
C. Reauired Notice for Receipt of Off -Site Wastes.
1. The Per:ittee shall notify the Department in writing at least four (4)
weeks in advance of the date the Permittee expects to receive hazardous
waste from a source outside of the United States. Notice of subsequent
shipments during the same calendar year of the same waste from the same
foreign source is not required.

)ermittee receives hazardous waste from an off -site source
sere the Permittee is also the generator), he must inform the
in writing that he has the appropriate permit(s) for, and will
_.ie waste the generator is shipping. The Permittee shall keep a
copy of this written notice as part of the operating record.
D. General Waste Analysis. The Permittee shall follow the procedures described
in the waste analysis plan as indicated in Section C of the attachment. All
waste streams shall have on file a Hazardous Material Profile as described in
Part C of the attachment. All waste streams shall be fully analyzed with a
minimum frequency of once per year. Waste streams generated off -site by
Lithium Corporation of America customers will not be received without
certification that the waste is an unused and uncontaminated returned Lithium
Corporation of America product and accompanied by a product Certification of
Analysis. Results of these analyses shall be maintained as per 40 CFR 264.13
as adopted in 10 NCAC 1OF .0032 and as identified in Condition I.D.9.
The Permittee shall verify his waste analysis as part of the quality assurance
program. The quality assurance program will be in accordance with current
EPA practices or equivalent methods approved by the Department; and at a
minimum shall ensure that the Permittee maintains proper functional instruments,
uses approved sampling and analytical methods, assures the validity of
sampling and analytical procedures, and performs correct calculations.
E. Security. The Permittee shall comply with the security provisions of 40 CFR
264.14(b) and (c) as adopted in 10 NCAC 1OF .0032 and Section F of the
attachment.
F. General Inspection Requirements. The Permittee shall follow the inspection
schedule as described in Section F of the attachment and shall comply with 40
CFR 264.15(c) and (d) as adopted in 10 NCAC 1OF .0032.
G. Personnel Training. The Permittee shall conduct personnel training in
accordance with 40 CFR 264.16 as adopted in 10 NCAC IOF .0032 and as
described in Section H of the attachment.
H. General Requirements for Ignitable, Reactive, or Incompatible Waste. The
Permittee shall comply with the requirements of 40 CFR 264.17(a) and (c) as
adopted in 10 NCAC IOF .0032.
I. Required Equipment. The Permittee shall equip the facility and make readily
available to operating personnel the necessary equipment to carry out the
contingency plan, as described in Section G of the attachment. At all times,
the equipment requirement described in 40 CFR 264.32 as adopted in 10 NCAC
1OF .0032 shall be met.
J. Testing and Maintenance of Equipment. The Permittee shall test and maintain
the equipment specified in the previous permit condition and as identified
in Section F of the attachment as necessary to ensure its proper operation in
time of emergency.
K. Access to Communications or Alarm System. The Permittee shall maintain '
access to the communications or alarm system as required by 40 CFR 264.34 as
adopted in 10 NCAC 1OF .0032.
II-2

n.
tion of Plan. The Permittee shall immediately carry out the
Frw _L�_Lu„� of the contingency plan whenever there is afire, explosion,
or release of hazardous waste or constituents which threatens or could
threaten human health or the environment as required by 40 CFR 264.56 as
adopted in 10 NCAC 1OF .0032.
2. Copies of Plan. The Permittee shall comply with the requirements of 40
CFR 264.53 as adopted in 10 NCAC IOF .0032.
3. Amendments to Plan. The Permittee shall review and immediately amend,
if necessary, the contingency plan, in accordance with 40 CFR 264.54 as
adopted in 10 NCAC 1OF .0032.
4. Emergency Coordinator. The Permittee shall comply with the requirements
of 40 CFR 264.55 as adopted in 10 NCAC 1OF .0032, concerning the
emergency coordinator.
M. Manifest System. The Permittee shall comply with the manifest requirements
of 40 CFR 264.71, 264.72, and 264.76 as adopted in 10 NCAC 1OF .0032.
N. Recordkeeping and Reporting.
1. Operating Record. The Permittee shall maintain a written operating
record at the facility in accordance with 40 CFR 264.73(a), (b)(1), (2),
(3), (4), (5), (6), (7), (8), (9), (10), (15), and (16) as adopted in 10
NCAC 1OF .0032, and as described in Sections C, F. G and H of the
attachment.
2. Annual Report. The Permittee shall comply with the annual report
requirements of 40 CFR 264.75 as adopted in 10 NCAC IOF .0032 and 10
NCAC 1OF .0037.
0. Closure.
1. Performance Standard. The Permittee shall close the facility in
accordance with the closure plan as described in Section I of the
attachment and as required by 40 CFR 264.111 as adopted in 10 NCAC 1OF
.0032.
2. Amendment to Closure Plan. The Permittee shall amend the closure plan
in accordance with 40 CFR 264.112(c) as adopted in 10 NCAC 1OF .0032
whenever necessary.
3. Notification of Closure. The Permittee shall notify the Department in
writing at least forty-five (45) days prior to the date he expects .to
begin closure.
II-3

PPPI 4. Time Allowed For Closure. Within ninety (90) days after receiving the
final volume of hazardous waste, the Permittee shall treat or remove
from site all hazardous waste in accordance with the schedule specified
in the closure plan. After receiving the final volume of hazardous
waste, the Permittee shall complete closure activities in accordance
with the schedule specified in the closure plan in Section I of the
attachment.
5. Disposal or Decontamination of Equipment. The Permittee shall comply
with the requirements of 40 CFR 264.114 as adopted in 10 NCAC 1OF .0032.
6. Certification of Closure. The Permittee shall certify that the facility
has been closed in accordance with the specifications in the closure
plan as required by 40 CFR 264.115 as adopted in 10 NCAC 1OF .0032.
P. Cost Estimate for Facility Closure. The Permittee shall comply with the
requirements of 40 CFR 264.142 as adopted in 10 NCAC 1OF .0032, including the
requirements to adjust and revise the cost estimates, when necessary. The
Permittee's approximate closure cost estimate is described -on page 5 through
8 in Section I of the attachment
Q. Financial Assurance for Facility Closure. The Permittee shall demonstrate
continuous compliance with 40 CFR 264.143 as adopted in 10 NCAC 1OF .0032, or
where applicable with 40 CFR 264.146, 264.149, 264.150,and 264.151 as adopted
in 10 NCAC 1OF .0032 by providing documentation of financial assurance in at
least the amount of the cost estimates required by Condition II.P. and pages
5 through 8a in Section I of the attachment.
4 The financial mechanism used shall be that instrument specified on page
8 of Section I of the attachment. The Permittee may propose using a
different mechanism by submitting a new financial instrument to the
Department for approval. The Permittee must submit this documentation no
later than sixty (60) days prior to the effective date of the proposed
change. The existing financial mechanism shall remain in force until the
change is approved.
R. Liability Requirements. The Permittee shall comply with the requirements of
40 CFR 264.147 as adopted in 10 NCAC IOF .0032, including the requirements to
have and maintain liability coverage for sudden and accidental occurrences in
the amount of at least $1 million per occurrence with an annual aggregate of
at least $2 million, exclusive of legal defense costs.
The financial mechanism used shall be that instrument specified on page
9 of Section I of the attachment. The Permittee may propose using a
different mechanism by submitting a new financial instrument to the for
approval. The Permittee must submit this documentation no later than sixty
(60) days prior to the effective date of the proposed change. The existing
financial mechanism shall remain in force until the change is approved.
S. Incapacity of Owners or Operators, Guarantors, or Financial Institutions.
The Permittee shall comply with 40 CFR 264.148 as adopted in 10 NCAC IOF
.0032 whenever necessary.
II-4

Cost Estimate for Completion of Corrective Action.
1. The Permittee shall prepare a cost estimate for the completion of any
corrective action required under this permit for solid waste management
units in order to provide financial assurance for completion of
corrective action as required under 40 CFR 264.101(b) as adopted in 10
NCAC IOF .0032. Such cost estimate will be based upon the cost of
operation, inspection, monitoring, and maintenance of the corrective
action system to meet the requirements of 40 CFR 264.101 as adopted in
10 NCAC 1OF .0032 and this permit.
2. The Permittee shall submit a cost estimate for any additional corrective
action for prior or continuous releases on the date specified by the
Department.
U. Financial Assurance for Corrective Action.
1. The Permittee shall demonstrate continuous compliance with 40 CFR
264.101 as adopted•in 10 NCAC 1OF .0032 by providing documentation of
financial assurance using a mechanism specified in 40 CFR 264.143 as
adopted in 10 NCAC 1OF .0032 in at least the amount of cost estimate
required under Condition II.T. The words "completion of corrective
action".shall be substituted for "closure and/or post -closure" as
appropriate in the financial mechanism.
2. The Permittee shall submit financial assurance for completion of
corrective action as required under 40 CFR 264.101 as adopted in 10 NCAC
F. IOF .0032 no later than thirty (30). days prior to beginning full
,d. operation of the approved corrective action.
V. Special Conditions.
1. When a discrepancy exists between the wording of an item in the
attachment and this permit, the permit requirements take precedence over
the attachment.
2. Where a discrepancy exists between the RCRA Facility Assessment (RFA)
report (attached as part of the permit) and this permit as to the future
requirements to be taken at the facility, the permit requirements take
precedence over the requirements reflected in the report.

PART III - STORAGE IN CONTAINERS
ge area consists of
high durbing with
northwest corner. Container capacity
most common containers are:
a 90' x 90' reinforced concrete slab with
a metal frame structure 40' x 50' over the
of the entire area is 16,500 gallons. The
Portable Tanks: C480 containers DOT51 (ASME VIII)
Steel Drums: 55-gallon DOT17C, 17E
Steel Cylinders: DOT 4BA and 4BW
Other: 30 gallon and smaller drums of
laboratory waste (labpacks)
The Hazardous Waste Container Storage area may be used to store containers of
D001, D002, D003, D004, D007, D008, D009, F003, F005, U031, U055, U117, U124, and
U213 as specified in Section D of the attachment.
Secondary containment is in the form of a 3' x 3' x 3' sump which leads to a 10'
x 15' x 7' storage sump outside the curbed containment area for a total containment
capacity of 29,625 gallons. Precipitation which may accumulate in the sumps is
analyzed for pH and visually inspected for organics before being released to the
surrounding area.
A. Condition -of Containers. If a container holding hazardous waste is not in
good condition (e.g., severe rusting, apparent structural defects) or if it
begins to leak, the Permittee shall transfer the hazardous waste from such
container to a container that is in good condition or manage the waste in
some other way that complies with the requirements of this permit.
B. Compatibility of Waste with Containers. The Permittee shall comply with 40
CFR 264.172 as adopted in 10 NCAC lOF .0032 and ensure that the ability of
the container to contain the waste is not impaired.
C. Management of Containers. The Permittee shall manage containers in
accordance with 40 CFR 264.173 as adopted in 10 NCAC 1OF .0032 and as
described in Section D of the attachment. All drums will be stored on
pallets.
D. Inspections. The Permittee shall inspect container storage areas in
accordance with 40 CFR 264.174 as adopted in 10 NCAC 1OF .0032 and as
described in Section F of the attachment.
E. Aisle Space. At a minimum, the Permittee shall maintain aisle space as
required by 40 CFR 264.35 as adopted in 10 NCAC 1OF .0032. Minimum aisle
space between rows of pallets will be at least three (3) feet.
F. Containment. The Permittee shall comply with the requirements of a
containment system found in 40 CFR 264.175(b)(1)-(5) as adopted in 10 NCAC
1OF .0032, including having a base which is free of cracks and gaps and is
able to contain leaks, spills and accumulated rainfall until such time that

'the material is detected and removed. The containment system must be
designed for efficient drainage and have sufficient capacity to contain 10%
of the total volume of containers: The Permittee shall maintain the
containment system in accordance with Section D of the attachment.
G. Special Requirements for Ignitable or Reactive Waste. The Permittee shall
not locate containers holding ignitable or reactive waste within 15 meters
(50 feet) of the facility's property line.
H. Special Requirements for Incompatible Waste.
1. The Permittee shall not place incompatible wastes in the same container.
2. The Permittee shall not place hazardous waste in an unwashed container
that previously held an incompatible waste or material.
3. The Permittee shall not store a container of hazardous waste that is
incompatible with any waste or material stored nearby in other
containers, piles, open tanks or surface -impoundments unless the
container is separated from the other materials by a.dike,- berm, wall,
or other device.
I. Closure. The Permittee shall follow the closure plan as described in Section
I of the attachment and shall comply with 40 CFR 264.178 as adopted in 10
NCAC 1OF .0032.

PART IV - STORAGE IN TANKS
Dre authorized wastes as identified in this permit in the
Tank
Tank
Permitted
Waste
Constituents
No.
Capacity
Volume
Type
(Gallon)
(Gallon)
T-527
1,200
960
*
Ignitable, Reactive, and
U-Listed waste
T-528
2,400
1,000
*
Ignitable, Reactive and
U-Listed waste
(proposed)
10,000
10,000
D001/F003
Methanol
(proposed)
2,000
2,000
D001
Hexane
(proposed)
1,000
1,000
*
Waste solvent
mixture
(proposed)
1,000
1,000
D001/D003
Lithium reactive
solvents
(proposed)
1,000
1,000
D003
Air and/or water
reactive
p * indicates the following waste codes may apply: D001, D003, F003, F005, U031,
U055, U117, U124, and U213.
Secondary containment is in the form of a diked area 22' x 26' x 9" and an 18" x
18" x 8" sump in the corner of the containment area. Total capacity is greater
than 2,945 gallons. The containment area is checked daily for precipitation which
is analyzed for pH and visually examined for organics before being discharged.
A. Design of Tanks. The Permittee shall maintain all tanks in accordance with
Section D of the attachment
B. Secondary Conta].nment and Integrity Assessments.
1. The Permittee shall comply with 40 CFR 264.193(b)-(f) as adopted in 10
NCAC 1OF .0032 and design, construct, and operate the secondary.
.containment system for Tanks T-527 and T-528 in.accordance with the
detailed design plans described in Section D of the attachment.
2. The new: 10,000; 2,000; and three (3) 1,000-gallon tank systems must
comply with 40 CFR 264.195(b)-(f) as adopted in 10 NCAC 1OF .0032
secondary containment requirements prior to being put into service.
C. General Operating Requirements.
1. The Permittee shall not place hazardous wastes or treatment reagents in
the tank system if they could cause the tank, its ancillary equipment,
or a containment system to rupture, leak, corrode, or otherwise fail.
IV-1

2. The Permittee shall prevent spills and overflows from the tank or
containment systems using the methods described in 40 CFR 264.194(b) as
adopted in 10 NCAC 1OF .0032 and in Sections D and F of the attachment.
D. Response to Leaks or Spills.
In the event of a leak or a spill from the tank and/or secondary containment
system, or if a system becomes unfit for continued use, the Permittee shall
comply with 40 CFR 264.196 as adopted in 10 NCAC 1OF .0032 and remove the
system from service immediately and complete the following actions:
1. Stop the flow of hazardous waste into the system and inspect the system
to determine the cause of the release;
2. Remove the waste and accumulated precipitation from the system within
twenty-four (24) hours of the detection of the leak to prevent further
release and to allow inspection and repair of the system. If the
Permittee finds that it will be impossible to meet this time period, the
Permittee must notify the Department and demonstrate that a longer time
period is required;
3. Contain visible releases to the environment. The Permittee shall
immediately conduct a visual inspection of all releases to the
environment and based on that inspection: (a) prevent further migration
of the leak or spill to soils or surface water and (b) remove and
properly dispose of any visible contamination of the soil or surface
water;
4. Close the system in accordance with the closure plan as described in
Section I of the attachment, unless the following actions are taken:
a) For a release caused by a spill that has not damaged the integrity--.,_`
of the system, the Permittee shall remove the released waste and
make any necessary repairs to fully restore the integrity of the
system before returning the tank system to service;
b) For a release caused by a leak from the primary tank system to the
secondary containment system, the Permittee shall repair the
primary system prior to its return to service;
c) For a release to the environment caused by a leak from a component
of the tank system that is below ground and does not have secondary
containment, the Permittee must provide this component with
secondary containment that meets the requirements of 40 CFR 264.193
as adopted in 10 NCAC 1OF .0032 before the component can be
returned to service;
d) For a release to the environment caused by a leak from the
aboveground portion of the tank system that does not have secondary
containment, and can be visually inspected, the Permittee shall
repair the tank system before its return to service;
IV-2

E.
F.
release to the environment caused by a leak from the portion
a tank system component that is not readily available for
1 inspection, the Permittee shall provide secondary
inment that meets the requirements of 40 CFR 264.193 as
adopted in 10 NCAC 1OF .0032 before the component can be returned
to service;
f) If the Permittee replaces a component of the tank system to
eliminate the leak, that component must satisfy the requirements
for new tank systems or components in 40 CFR 264.192 and 264.193 as
adopted in 10 NCAC 1OF .0032.
5. For all major repairs to eliminate leaks or restore the integrity of the
tank system, the Permittee must obtain a certification by an
independent, qualified, registered professional engineer that the
repaired system is capable of handling hazardous wastes without release
for the intended life of the system before returning the system to
service.
Inspections.
1. The Permittee shall inspect the tank systems in accordance with 40 CFR
264.195 as adopted in 10 NCAC 1OF .0032 and the inspection schedule
as indicated in Part F and Attachment F-4 of the attachment.
2. The Permittee shall inspect the following components of the tank system
once each operating day:
a) Overfill controls;
b) Aboveground portions of the tank system, if any, to detect
corrosion or releases of waste;
c) Data gathered from monitoring and leak detection equipment (e.g.
pressure or temperature gauges, monitoring wells) to ensure that
the tank system is being operated according to its design;
d) The area immediately surrounding the externally accessible portion
of the tank system, including the secondary containment system, to
detect erosion or signs of releases of hazardous waste.
3. The Permittee shall document compliance with Conditions IV.E.2. and
IV.E.3. and place this documentation in the operating record for the
facility.
Notifications and Recordkeeping.
1. The Permittee shall report to the Department within twenty-four (24)
hours of detection when a leak or spill occurs from the tank or
secondary containment system to the environment as described in 40 CFR
264.196(d)(1) as adopted in 10 NCAC 1OF .0032.
2. Within thirty (30) days of release detection, the Permittee shall report
to the Department the information in 40 CFR 264.196(d)(3) as adopted in
10 NCAC 10F .0032.
IV-3

3. The Permittee shall submit to the Department all certifications of major
repairs to correct leaks within seven (7) days from returning the tank
system to use.
4. The Permittee shall obtain and keep on file at the facility the written
statements by those persons required to certify the design and
installation of the tank system as required by 40 CFR 264.192(g) as
adopted in 10 NCAC 1OF .0032.
5. The Permittee shall keep on file at the facility the written assessment
of the tank systems' integrity as required by 40 CFR 264.191(a) as
adopted in 10 NCAC 1OF .0032.
G. Closure and Post -Closure Care.
1. The Permittee shall follow the closure plan as described in Section I of
the attachment and shall comply with 40 CFR 264.197 as adopted in 10
NCAC IOF .0032.
H. Special Requirements for Ignitable or Reactive Wastes.
1. The Permittee shall comply with 40 CFR 264.198(a)(1), (2) or (3) as
adopted in 10 NCAC IOF .0032. '
2. The Permittee shall comply with the requirements of 40 CFR 264.198(b) as
adopted in 10 NCAC IOF .0032.
I. Special Requirements for Incompatible Wastes.
1. The Permittee shall not place incompatible wastes in the same tank.
2. The Permittee shall not place hazardous waste in an unwashed tank which,....
previously held an incompatible waste or material.
J. Special Requirement.
1. The Permittee shall submit to the Department bi-monthly construction
progress reports for the five (5) proposed hazardous waste storage tanks
and secondary containment area. These reports will begin sixty (60)
days after the effective date of this permit and continue through
start-up of the tank systems.
2. Prior to any of the five (5) hazardous waste storage tanks being placed
!' into service, the Permittee shall submit a written report to the
Department stating that the tank(s) and containment system have been
installed, inspected and tested as per 40 CFR 264.192(b), (d), and (e)
,as adopted in 10 NCAC 1OF .0032 and Chapter 2 of the attachment. The
report must be submitted, in accordance with 40 CFR 270.11(d) as adopted
in 10 NCAC 1OF .0034, by an independent, qualified, registered
professional engineer who is trained and experienced in the proper
installation of tank systems and components.
IV-4

7. "Corrective action" for purposes of this part, may include all
corrective measures necessary to protect human health and the
environment for all releases of hazardous waste or hazardous
constituents from any solid waste management unit at the facility,
regardless of the time at which waste was placed in the unit, as
required under 40 CFR 264.101 as adopted in 10 NCAC 1OF .0032.
Corrective measures may address releases to air, soils, surface water,
groundwater, or subsurface gases.
C. RCRA FACILITY ASSESSMENT (RFA
1. The Permittee shall notify the Department of any additional SWMUs as
discovered under Condition V.A.2. within fifteen (15) days of discovery.
2. The Permittee shall prepare and submit to the Department the following
information for each SWMU identified under Condition V.C.1. within
ninety (90) days of notification.
a)
Location of unit(s) on a topographic map of appropriate scale such
as required under 40 CFR 270.14(b)(19) as adopted in-NCAC 1OF
.0034.
b)
Designation of type and function of unit(s).
c)
General dimensions, capacities and structural description of
unit(s).(supply any available plans/drawing).
d)
Dates that the units) was operated.
e)
Specification of all wastes that have been managed at/in the
unit(s) to the extent available. Include any available data on 40
a
CFR 261, Appendix VIII as adopted in 10 NCAC 1OF .0029,
--
constituents in the wastes.
f)
All available information pertaining to any release of hazardous
waste or hazardous constituents from such unit(s) (to include
groundwater data, soil analyses, air, and/or surface water data).
D. RCRA FACILITY INVESTIGATION (RFI)
1. The Permittee shall prepare and submit to'the Department within 120 days
of the effective date of this permit a RCRA Facility Investigation (RFI)
Plan for those units indicated in Appendix A, Paragraph I, -as subject
to the RFI. This Plan shall be developed to meet the requirements of
Condition V.D.4.
2. The Permittee shall prepare and submit a RFI plan to the Department
within ninety (90) days of the submission of the RFA information in
Condition V.C.2., for -those units identified under Condition V.C.1.
This Plan shall be developed to meet the requirements of Condition
V.D.4.
3. The Permittee shall notify the Department of any release of a hazardous
waste or hazardous constituent from any SWMU listed in Appendix A,
Paragraph II within fifteen (15) days of discovery. The Permittee shall
submit to the Department RFI Plan for these units within ninety (90)
days of notification. This Plan shall be developed to meet the
requirements of Condition V.D.4.
V-2

lan(s) shall meet the requirements of Appendix B at a minimum.
(s) shall include schedules of implementation and completion of
actions necessary to determine the nature and extent of
and the potential pathways of contaminant releases to the air,
land, surface water, and groundwater. The Permittee must provide
sufficient justification and/or documentation that a release is not
probable if a unit or a media/pathway associated with a unit
(groundwater, surface water, soil,.air or subsurface gases) is not
included in the RFI Plan. Such deletions of a unit, media or pathway
from the RFI(s) are subject to the approval of the Department. The
RFI(s) shall be conducted in accordance with the approved RFI Plan(s),
Appendix B. The Permittee shall provide sufficient written
Justification for any omissions or deviations from the minimum
requirements of Appendix B. Such omissions or deviations are subject to
the approval of the Department. The scope of the RFI Plan(s)" shall
include all investigations necessary to ensure compliance with 40 CFR
264.101(c) as adopted in 10 NCAC 1OF .0032.
5. If the time required to conduct the RFI(s) is greater than 1BO days, the
Permittee shall provide the Department with quarterly RFI'Progress
Reports (90-day intervals) beginning ninety (90) days from
implementation of the approved plan containing:
a) A description of the portion of the RFI completed;
b ) Summaries of f inding;
c) Summaries of all deviations from the approved RFI Plan during the
reporting period.
rt d) Summaries of all problems or potential problems encountered during
the reporting period;
e) Projected work for the next reporting period; and
f). Copies of daily reports, inspection reports, laboratory/monitoring
data, etc.
6. The Permittee shall prepare and submit to the Department, Draft and
Final RCRA Facility Investigation Report(s) for the investigation
conducted pursuant to the Plan(s) submitted under Condition V.D.1.,
V.D.2., or V.D.3. The draft RFI Report(s) shall be submitted to the
Department for review ninety (90) days after completion of the RFI. The
final RFI Report(s) shall be submitted to the Department within thirty
(30) days of receipt of comments on the draft RFI Report. The RFI
Report(s) shall include an analysis and summary of all required
investigations of solid waste management units and their results. The
summary shall describe the type and extent of contamination at the
facility, including sources and migration pathways, and a description of
actual or potential receptors. The Report(s) shall also describe the
extent of contamination (qualitative/quantitative) in relation to
background levels indicative for the area. The objective of this task
shall be to ensure that the investigation data are sufficient in quality
(e.g., quality assurance procedures have been followed) and quantity to
describe the nature and extent of contamination, potential threat to
human health and/or the environment, and to support a Corrective Action
Study and/or Plan, if necessary.
V-3

3S
ttee, (upon approval of the Department, may conduct
y..����.....aasures to contain, remove or treat contamination resulting
from the release of hazardous constituents from a solid waste management
unit in order to protect public health and the environment. Such
Interim Measures may be conducted concurrently with investigations
required under the terms of this permit.
2. The Permittee shall notify the Department of any proposed interim/
corrective measures at least thirty (30) days prior to implementation.
The notice shall include a description and a schedule of implementation
of any proposed Interim Measures.
3. The Permittee shall give notice to the Department as soon as possible of
any planned changes, reductions or additions to the Interim Measures.
4. Final approval of corrective action achieved through Interim Measures
required under 40 CFR 264.101 as adopted in 10 NCAC 1OF .0032 shall be
in accordance with 40 CFR 270.41 as adopted in 10 NCAC 10F .0034. and
Condition V.F.2. as a permit modification.
5. If the time required for completion of an Interim Measure is greater
than one (1) year, the Permittee shall provide the Department semi-annual
progress reports (180-day intervals) beginning 180 days after initiation
for the Interim Measure(s). Such reports shall include:
a) A description of the portion of the Interim Measure completed;
b) Summaries of all deviations from the Interim Measures Plan during
the reporting period;
c) Summaries of all problems or potential problems encountered during
the reporting period;
d) Projected work for the next reporting period; and
e) Copies of laboratory/monitoring data.
6. Within ninety (90) days of completion of Interim Measures conducted
under Condition V.E., the Permittee shall submit an Interim Measures
Report to the Department that contains:
a) A description of measure(s) implemented;
b) Summaries of results;
c) Summaries of all problems encountered;
d) Summaries of accomplishments and/or effectiveness of interim
measure; and
e) Copies of all relevant laboratory/monitoring data, etc. in
accordance with Condition I.D.9.
F. CORRECTIVE ACTION
1. The Department will review the final RFI report(s) required under
Condition V.D.6. and notify the Permittee of the need for further
investigative actions and/or the need for a Corrective Action Study
and/or Plan to meet the requirements of 40 CFR 264.101 as adopted in 10
NCAC 1OF .0032.
" V-4

2. Upon determination by the Department that a Corrective Action Study
and/or Plan is needed, the permit shall be modified pursuant to 40 CFR
270.41 as adopted in 10 NCAC 1OF .0034 to address such requirements.
The modification shall identify the solid waste management unit(s) and
associated releases requiring corrective action plans and/or studies;
specify requirements for development, submission and implementation of
such plans/studies; specify requirements for financial assurances for
completion of corrective action as required under 40 CFR 264.101(b) as
adopted in 10 NCAC 1OF .0032; and include other HSWA requirements as
appropriate.
3. Corrective action shall be instituted by the Permittee under an approved
Corrective Action Plan as necessary to protect public health and the
environment for all releases of hazardous waste or hazardous
constituents from any solid.waste management unit at the facility,
regardless of the time at which waste was placed in such unit or whether
such unit was originally intended for management of solid waste.
4. The Permittee shall implement corrective actions beyond the facility
boundary, where necessary to protect human health and the'environment,
unless the Permittee demonstrates to the satisfaction of the Department
that, despite the Permittee's best efforts, the Permittee was unable to
obtain the necessary permission to undertake such actions. The
Permittee is not relieved of all responsibility to clean up a release
that has migrated beyond the facility boundary where off -site access is
denied. On -site measures to address such releases will be determined on
a case -by -case basis. Assurances of financial responsibility for
completion of such off -site corrective action will be required.
G. IMMINENT HAZARDS
1. The Permittee shall report to the Department of any imminent or existing'.,.
hazard to public health or the environment from any release of hazardous
waste or hazardous'constituents from a solid waste management unit.
Such information shall be reported orally within twenty-four (24) hours
from such time the Permittee becomes aware of the circumstances. This
report shall include the information specified under Condition I.D.14.a.
and b.
2. A written report shall also be provided to the Department within fifteen
(15) days of the time the Permittee becomes aware of the circumstances.
The written report shall contain the information specified under
Conditions I.D.14.a and b.; a description of the release and its cause;
the period of the release; whether the release has been stopped; and if
not, the anticipated time it is expected to continue; and steps taken or
planned to reduce, eliminate, and prevent recurrence of the release.
H. PLAN AND REPORT REQUIREMENTS
1. All plans and schedules shall be subject to approval by the Department
prior to implementation. The Permittee shall revise all submittals and
schedules as specified by the Department. Upon approval the Permittee
shall implement all plans and schedules as written.
V-5

is of all plans and reports shall be submitted in accordance
approved schedule. Extensions of the due date for submittals
anted by the Department based on the Permittee's demonstration
icient justification for the extension exists.
3. If the Permittee at any time determines that the RFA information
required under Condition V.C. or RFI Plan(s) required under Condition
V.D. no longer satisfy the requirements of 40 CFR 264.101 as adopted in
10 NCAC 10F .0032 or this permit for prior or continuing releases of
hazardous waste or hazardous constituents from solid waste management
units, he shall submit an amended RFI Plan(s) to the Department within
ninety (90) days of such determination.
4. All reports shall be signed and certified in accordance with 40 CFR
270.11 as adopted in 10 NCAC 1OF .0034.
S. Two (2) copies of all reports and plans shall be provided by the
Permittee to the following address.
Mr. Jerome H. Rhodes, Chief
Hazardous Waste Section
Post Office Box 27687
Raleigh, North Carolina 27611-7687
V-6

PART VI - WASTE MINIMIZATION
:ERTIFICATION
Until certification of closure, the Permittee shall certify annually that the
Permittee has a program in place to reduce the volume and toxicity of hazardous
waste that he generates to the degree determined by the Permittee to be
economically practicable and the proposed method of treatment, storage or disposal
is that practicable method currently available to the Permittee which minimizes
the present and future threat to human health and the environment.
A. Pursuant to 40 CFR 264.73(b)(9) as adopted in 10 NCAC 1OF .0032 and Section
3005(h) of RCRA, 42 U.S.C. 6925(h), the Permittee must certify, no less often
than annually, that:
1. The Permittee has a program in place to reduce the volume and toxicity
of hazardous waste to the degree determined by the Permittee to be
economically practicable; and
2. The proposed method of treatment, storage or disposal is the most
practicable method available to the Permittee which minimizes the
present and future threat to human health and the environment.
3. The Permittee shall also maintain copies of certification in the
facility operating record as required by 40 CFR 264.73(b)(9) as adopted
in 10 NCAC 1OF .0032.
B. The Waste Minimization program required under A.1 and A.2 above should as a
-•`£ minimum address the following topics:
1. Identify each hazardous waste stream with the source of generation.
2. Types and amounts of hazardous waste that is generated at the facility.
3. Present and proposed method of treatment, storage or disposal that is
available to the Permittee.
4. Description of technique implemented in the past for hazardous waste
reduction and their effectiveness.
5. An evaluation of technically and economically feasible hazardous waste
reduction techniques.
6. A program and schedule for implementing the selected hazardous waste
reduction technique.
VI-1

PART V - SOLID WASTE MANAGEMENT UNITS
APPLICABILITY
The Conditions of this Part apply to:
1. The solid waste management units (SWMUs) identified in Appendix A,
Paragraph I and Paragraph II.
2. Any additional SWMUs discovered during the course of groundwater
monitoring, field investigations, environmental audits, or other means.
B. DEFINITIONS
For purposes of this Part, the following definitions shall be applicable:
1. The term "solid waste" means any garbage, refuse, sludge from a waste
treatment plant, water supply treatment plant, or air pollution control
facility and other discarded material, including solid, liquid,
semisolid, or contained gaseous material resulting from industrial,
commercial, mining, and agricultural operations, and from community
activities, but does not include solid or dissolved material in domestic
sewage, or solid or dissolved materials in irrigation return flows or
industrial discharges which are point sources subject to permits under
Section 402 of the Federal Water Pollution Control Act, as amended (86
Stat. 880), or source, special nuclear, or by-product material as defined
by the Atomic Energy Act of 1954, as amended (68 Stat. 923).
2. A "hazardous constituent" for the purposes of this part are those
substances listed in 40 CFR Part 261 Appendix VIII as adopted in 10 NCAC
1OF .0029.
3. A "Solid Waste Management Unit" (SWMU) for the purposes of this part
includes any unit which has been used for the treatment, storage, or
disposal of solid waste at any time, irrespective of whether the unit is
or ever was intended for the management of solid waste. RCRA regulated
hazardous waste management units are also solid waste management units.
4. A "unit" for the purposes of this part includes, but is not limited
to, any landfill, surface impoundment, waste pile, land treatment unit,
incinerator, injection well, tank, container storage area, septic tank,
drain field, wastewater treatment unit, elementary neutralization unit,
transfer station, or recycling unit.
5 A "release" for purposes of this part includes any spilling, leaking,
pumping, pouring,.emitting, emptying, discharging, injecting, escaping,
leaching, dumping, or disposing into the environment of any hazardous
waste or hazardous constituents.
6. "Contamination" for the purposes of this part refers to the presence of
any hazardous waste or hazardous constituents in a concentration which
exceeds the background concentration of that waste or constituent in the
immediate vicinity of the facility (i.e., in areas not affected by the
r facility). _
�' V-1

PART VII - LAND DISPOSAL RESTRICTIONS
-tions
1. 40 CFR Part 268 as adopted in 10 NCAC 1OF .0042 identifies hazardous
wastes that are restricted from land disposal and defines those limited
circumstances which an otherwise prohibited waste may continue to be
placed on or in a land treatment, storage or disposal unit. The
_ Permittee shall maintain compliance with the requirements of 40 CFR 268.
Where the Permittee has applied for an extension, waiver or variance
under 40 CFR 268 the Permittee shall comply with all restrictions on
land disposal under this Part once the effective date for the waste has
been reached pending final approval of such application.
2. For the purposes of 40 CFR Part 268 as adopted in 10 NCAC 10F .0042,
"Land Disposal" means placement in or on the land and includes, but is
not limited to, placement in a landfill, surface impoundment, waste
pile, injection well, land treatment facility, salt dome formation,
underground mine or cave, or concrete vault or bunker intended for
disposal purposes.
VII-1

APPENDIX A
SOLID WASTE MANAGEMENT UNITS

APPENDIX A
Solid Waste Management Unit Summary
:rs Following SWMU description correspond to RFA Report
I. List of Solid Waste Management Units requiring an RFI:
SWMU No. Description
1
Kiln Particulate Scrubber (#1)
2
Butyllithium Spill Impoundment (#6)
3
Sulfuric Acid Discharge Pipe (#8)
4
Bermet Waste Site (#15)
5
Industrial Landfill (#18)
6
Kiln Scrubber Ponds (#19)
7
Bessemer City Landfill (Lithco Property) (#20)
8
Miscellaneous Operations Landfill (#23)
9
Old Bessemer City Landfill (#26)
10
Lithene Resin Disposal Area (#27)
11
Chemical Plant Water Recycle Lake ((#28y-
12
Sanitary Landfill (#29)
13
Old Bermet Sump (#30)
14
Gaston County School Burial Site (#31)
15
Bermet Bag -Filter House & Contaminated Stockpiled
Soil (not in EPA RFA Report)
II. List of Solid Waste Management Units with no known releases:
SWMU No. Description
1 Rotary Kiln (#2)
2 Lithium Chloride Filter Units and Hopper (#3)
3 Lithium Bromide Filter Unit and Hopper (#4)
4 Sodium Hypochlorite Filter Unit and Hopper (#5)
5 Lithium Metal Hydrolysis Unit (#9)
6 Quench Treatment Filter Unit and Hopper (#12)
7 Quench Treatment Circuit (#11)
8 Area for the Destruction of Cylinders of Reactive
Materials (#16)
9 Old Ore Tailing Deposits Lake (#17)
10 Eutectic Salt Drum Storage (#22)
11 Air Oxidation Area (#24)
12 Automotive Waste Oil Storage Area (#25)
13 Waste Cement Location (132)
III. List of Solid Waste Management Units with no known releases and
regulated by State permit or interim status closure requirements:
SWMU No. Description
1 Hazardous Waste Fuel Storage Tanks (#7)
2 Solvent Burning Units (#10)
3 Hazardous Waste Storage Facility (#13)
4 Old Hazardous Waste Storage Facility (#14)
5 Waste Water Treatment Surface Impoundment (#21)

APPENDIX B
RFI GUIDANCE

APPENDIX B
RCRA FACILITY INVESTIGATION (RFI) WORKPLAN OUTLINE
I. RFI WORKPLAN REQUIREMENTS
The Permittee shall prepare a RCRA Facility Investigation (RFI) Workplan
that meets the requirements of Part II of this document and the RFI
Guidance, EPA-530/SW-87-001. This Workplan shall also include the
development of the followinq plans, which shall be prepared concurrently:
A. Project Management Plan
The Permittee shall prepare a Project Management Plan which will
include 'a discussion of the technical approach, schedules, and
personnel. The Project Management Plan will also include a description
of qualifications of personnel performing or directing the RFI,
including contractor personnel. This plan shall also document the
overall management approach to the RCRA Facility Investigation.
B. Samplinq and Analvsis Plan(s)
The Permittee shall prepare a plan to document all monitoring pro-
cedures: field sampling, sampling procedures and sample analysis
performed during the investigation to characterize the environmental
setting, source, and releases of hazardous constituents, so as to
ensure that all information and data are valid and properly documented.
The Sampling Stategy and Procedures shall be in accordance with
Characterization of Hazardous Waste Sites A Methods Manual: Volume
II. Available Sampling Methods, EPA-600 4-84-076, or EPA Region IV
Engineering Support Branch's Standard Operating Procedure and
Quality Assurance Manual (SOP). Any deviations f ran these references
must be requested by the applicant and approved by EPA. The Sampling
and Analysis Plan must specifically discuss the following unless the
EPA-600/4-84-076 or SOP procedures are specifically referenced.
1. Sampling Strategy
a. Selecting appropriate sampling locations, depths, etc.;
b. Obtaining all necessary ancillary data;
c. Determining conditions under which sampling should be
conducted;
e. Determining which media are to be sampled (e.g., groundwater,
air, soil, sediment, etc.);
f. Determining which parameters are to be measured and where;
1 of 14

Selecting the frequency of sampling and length of sampling
period;
h. Selecting the types of samples (e.g., composites vs. grabs) and
number of samples to be collected.
2. Sampling Procedures
a. Documenting field sampling operations and procedures, including;
i) Documentation of procedures for preparation of reagents or
supplies which become an integral part of the sample
(e.g., filters, preservatives, and absorbing reagents);
ii) Procedures and forms for recording the exact location and
specific considerations associated with sample acquisition;
iii) Documentation of specific sample preservation method;
iv) Calibration of field instruments;
v) Submission of field -biased blanks, where appropriate;
vi) Potential interferences present at the facility;
vii) Construction materials and techniques, associated with
monitoring wells and piezometers;
viii) Field equipment listing and sampling containers;
ix) Sampling order; and
x) Decontamination procedures.
b. Selecting appropriate sample containers;
c. Sampling preservation; and
d. Chain -of -custody, including:
i) Standardized field tracking reporting forms to.establish
sample custody in the field prior to shipment;. and
ii) Pre -prepared sample labels containing all information
necessary for effective sample tracking.
2 of 14

le Analvsis
Sample analysis shall be conducted in accordance with SW-846:
"Test Methods for Evaluating Solid Waste - Physical/Chemical
Methods" (third edition). The sample analysis section of the
Sampling and Analysis Plan shall specify the following:
a. Chain -of -custody procedures, including:
i) Identification of a responsible party to act as samplinq
custodian at the laboratory facility authorized to sign.for
incoming field samples, obtain documents of shipment, and
verify the data entered onto the sample custody records;-
ii) Provision for a laboratory sample custody log consisting of
serially numbered standard lab -tracking report sheets; and
Specification of laboratory sample custo`iy'procedures for
sample handling, storage, and dispersement for analysis.
b. Sample storage;
c. Sample preparation methods;
i) Scope and application of the procedure;
ii) Sample matrix;
iii) Potential interferences;
iv) Precision and accuracy of the methodology; and
v) Method detection limits.
d. Analytical procedures, including:
i) Scope and application of the procedure;
ii) Sample matrix;
iii) Potential interferences;
iv) Precision and accuracy.of the methodology; and
v) Method detection limits.
e. Calibration procedures and frequency;
f. Data reduction, validation and reporting;
3 of 14

Internal quality control checks, laboratory performance and
systems audits and frequency, including:
i) Method blank(s);
ii) Laboratory control sample(s);
iii) Calibration check samples(s);
iv) Replicate sample(s);
v) Matrix -spiked sample(s);
vii) Control charts;
viii) Surrogate samples;
ix) Zero and span gases; and
x) Reagent quality control checks.
h. Preventive maintenance procedures and schedules;
i. Corrective action (for laboratory problems); and
j . Turnaround time.
C. Data Management Plan
The Permittee shall develop and initiate a.Data Management Plan to
document and track investigation data and results. This plan shall
identify and set up data documentation materials and procedures,
project file requirements, and project -related progress reporting
procedures and documents. The plan shall also provide the format
to be used to present the raw data and conclusions of the investi-
gaticn.
1. Data Record
The data record shall include the following:
a. Unique sample or field measurement code;
b. Sampling or field measurement location and sample or measure-
ment type;
C. Sampling or field measurement raw data;
d. Laboratory analysis ID number;
e. Property or component measured; and
f. Result of analysis (e.g. concentration).
4 of 14

Tabular -Displays
The following data shall be presented in tabular displays:
a. Unsorted (raw) data;
b. Results for each medium, or for each constituent monitored;
c. Data reduction for statistical analysis, as appropriate;
d. Sorting of data by potential stratification factors (e. g.,
location, soil layer, topography); and
e. Summary data
3. Graphical Displays
The following data shall be presented in graphical formats
(e. g., bar graphs, line graphs, area or plan maps, isopleth
plots, cross -sectional plots or transects, three dimensional
graphs, etc.):
a. Display sampling location and sampling grid:
b. Indicate boundaries of sampling area, and area where more
data are required;
c. Display geographical extent of contamination;
d. Illustrate changes in concentration in relation to distances
fran the source, time, depth or other parameters; and
e. Indicate features affecting intramedia transport and show
potential receptors.
II. RCRA Facility Investigation (RFI) Requirements
RCRA Facility Investigation:
The Permittee shall conduct those investigations necessary to:
characterize the facility (Environmental Setting); define the source,
(Source Characterization); define the degree and extent of release of
hazardous constituents (Contamination Characterization); and identify
actual or potential receptors.
The investigations should result in data of adequate technical content'
and quality to support the development and evaluation of the corrective
action plan if necessary. The information contained in a RCRA Part B
permit application and/or RCRA Section 3019 Exposure Information Report
may be referenced as appropriate.
5of14

ing and analyses shall be conducted in accordance with the
and Analysis Plan. All sampling locations shall be documented'
in a log and identified on a detailed site map.
A. Environmental Settinq
The Perimittee shall collect information to supplement and/or verify
Part B information on the environmental setting at the facility.
The Permittee shall characterize the following as they relate to
identified sources, pathways and areas of releases of hazardous
constituents from Solid Waste Management Units.
1. Hydrogeology
The Permittee shall conduct a program to evaluate hydrogeologic
conditions at the facility. This program shall provide the
following information:
a. A description of the regional and facility specific geologic
and hydrogeologic characteristics affecting ground -water
flow beneath the facility, including:
i) Regional and facility specific stratigraphy: description
of strata including strike and dip, identification of
stratigraphic contacts:
ii) Structural geology: description of local and regional
structural features (e. g., folding, faulting, tilting,
jointing, etc.) ;
iii) Depositional history;
iv) Regional and facility specific ground -water flaw patterns;
and
v) Identification and characterization of areas and amounts of
recharge and discharge.
b. An analysis of any topographic features that might influence
the ground water flaw system.
c. Based on field data, tests, and cores, a representative and
accurate classification and description of the hydrogeologic
units which may be part of the migration pathways at the
facility (i. e., the aquifers and any intervening saturated
and unsaturated units), including:
i) Hydraulic conductivity and porosity (total and effective);
ii) Lithology, grain size, sorting, degree of cementation;
6 of 14

iii) An interpretation of Hydraulic interconnections between
saturated zones; and
iv) The attenuation capacity and mechanisms of the natural
earth materials (e. g., ion exchange capacity, organic
carbon content, mineral content etc.).
d. Based on data obtained from groundwater monitoring wells and
piezometers installed upgradient and downgradient of the
potential contaminant source, a representative description
of water level or fluid pressure monitoring including:
i) Water —level contour and/or potentioe-tric maps;
ii) Hydrologic cross sections showing vertical gradients;
iii) The flow system, including the vertical and horizontal
components of flow; and
iv) Any temporal changes in hydraulic gradients, for -example, due to
tidal or seasonal influences.
e. A description of manmade influences that may affect the hydrology
of the site, identifying:
�z
- i) Local water —supply and production wells with an approximate
schedule of pumping; and
ii) Manmade hydraulic structures (pipelines, french drains,
ditches, etc.).
2. Soils
The Permittee shall conduct a program to characterize the soil and rock
units above the water table in the vicinity of contaminant release(s).
Such characterization may include, but not be limited to, the following
types of information as appropriate:
a. Surface soil distribution;
b. Soil profile, including ASTM classification of soils;
c. Transects of soil stratigraphy;
d. Hydraulic conductivity (saturated and unsaturated).;
e. Relative permeability;
f. Bulk density;
g. Porosity;
h. Soil sorptive capacity;
i. Cation exchange capacity (CEC);
j. Soil organic content;
k. Soil pH;
1. Particle size distribution;
m. Depth of water table;
7 of 14

I1.
o.
p.
q-
r.
• S.
t.
Moisture content;
Effect of stratification on unsaturated flow;
Infiltration;
Evapotranspiration;
Storage capacity;
Vertical flow rate; and
Mineral content.
3. Surface Water and Sediment
The Permittee shall conduct a program to characterize the surface
water bodies in the vicinity of the facility. Such characterization
may include, but not be limited to, the following activities and
information:
a.__ Description of the temporal and permanent surface water bodies
including:
i) For lakes and estuaries: location, elevation, surface area,
inflow, outflow, depth, temperature stratification, and volume;
ii) For impoundments: location, elevation, surface area, depth,
volume, freeboard, and construction and purpose;
For streams, ditches, and channels: location, elevation, flow,
velocity, depth, width, seasonal fluctuations, flooding
tendencies (i. e., 100 year event), discharge point(s), and
general contents.
iv) Drainage patterns; and
v) Evapotranspiration.
b. Description of the chemistry of the natural surface water and
sediments. This includes determining the pH, total dissolved
solids, total suspended solids, biological oxygen demand,
alkalinity, conducti}Nity, dissolved oxygen profiles, nutrients
(NH3 , NO3 /NO2-, PO ), chemical oxygen demand, total organic
carbon, specific contaminant concentrations, etc.
c. Description of sediment characteristics including:
i) Deposition area;
ii) Thickness profile; and
iii) Physical and chemical parameters (e. g., grain size, density,
organic carbon content, ion exchange capacity, pH, etc.)
8 of 14

The Permittee shall provide information characterizing the climate
in the vicinity of the facility. Such information may include, but
not be limited to:
a. A description of the followinq parameters:
i) Annual and monthly rainfall averages;
ii) Monthly temperature averages and extremes;
iii) Wind speed and direction;
iv) Relative humidity/dew point;
v) Atmospheric pressure;
vi) Evaporation data;
vii) Development of inversions; and
viii) Climate extremes that have been know to occur in the
vicinity of the facility, including frequency of occurrence.
(i. e. Hurricanes)
b. A description of topographic and manmade features which affect
air flow and emission patterns, including:
i) Ridges, hills or mountain areas;
ii) Canyons or valleys;
iii) Surface water bodies (e. g. rivers, lakes, bays, etc.);
iv) Buildings.
B. Source Characterization
For those sources from which releases of hazardous constituents have
been detected the Permittee shall collect analytic data to carpletely
characterize the wastes and. the areas where wastes have been placed,
to the degree that is possible without undue safety risks, including:
type, quantity; physical form; disposition (containment or nature of
deposits); and facility characteristics affecting release (e. g.,
facility security, and engineering barriers). This -shall include
quantification of the following specific characteristics, at each
source area:
1. Unit/Disposal Area Characteristics:
9 of 14

Period of operation;
Age of unit/disposal area;
g. General physical conditions; and
h. Method used to close the unit/disposal area.
2. Waste Characteristics:
a. Type of wastes placed in the unit;
i) Hazardous classification (e. g., flamnable, reactive,
corrosive, oxidizing or reducing agent);
ii) Quantity; and
iii) Chemical composition.
b: Physical and chemical characteristics such as;
i) Physical form (solid, liquid, gas);
ii) Physical description (e. g., powder, oily sludge);
iii) Temperature;
iv) ,)H;
v) General chemical class (e. g., acid, base, solvent);
vi) Molecular weight;
vii) Density;
viii) Boiling point;
ix) Viscosity;
x) Solubility in water;
xi) Cohesiveness of the waste; and
xii) Vapor pressure.
c. Migration and dispersal characteristics of the waste such as;
i) Sorption capability;
ii) Biodegradability, bioconcentration, biotransfonnation;
iii) Photodegradation rates;
10 of 14

L..
ydrolysis rates; and
,heroical transformations.
The Permittee shall document the procedures used in making the above
determinations.
C. Characterization of Releases of Hazardous Constituents
The Permittee shall collect analytical data on groundwater, soils,
surface water, sediment, and subsurface gas contamination in the
vicinity of the facility in accordance with the sampling and analysis
plan as required above. These data shall be sufficient to define
the extent, origin, direction, and rate of movement of contamination.
Data shall include time and location of sampling, media sampled,
concentrations found, conditions during sampling, and the identity
of the individuals performing the sampling and anaylsis. The
Permittee shall address the following types of contamination at
the facility:
1. Groundwater Contamination
The Permittee shall conduct a groundwater investigation to
characterize any plumes of contamination detected at the facility.
This investigation shall at a minimum provide the following
information:
a. A description of the horizontal and vertical extent of any
plume(s) of hazardous constituents originating from the
facility;
b. The horizontal and vertical direction of contamination
movement;
c. The velocity of contaminant movement;
d. The horizontal and vertical concentration profiles of
hazardous constituents in the plume(s);
e. An evaluation of factors influencing the plume movement;
and
f. An extrapolation of future contaminant movement.
The Permittee shall document the procedures used in making the
above determinations (e. g., well design, well construction,
geophysics, modeling, etc.).
11 of 14

r
it Contamination
The Permittee shall conduct an investigation to characterize
the contamination of the soil and rock units above the saturated
zone in the vicinity of any contaminant release. The investi-
gation may include the following information:
a. A description of the vertical and horizontal extent of
contamination;
b. A description of appropriate contaminant and soil chemical
properties within the contaminant source area and plume.
This may include contaminant solubility, speciation, absorption,
leachability, exchange capacity, biodegradability, hydrolysis,
photolysis, oxidation and other factors that might affect
contaminant migration and transformation;
c. Specific contaminant -concentrations;
d. The velocity and direction of contamination movement; and
e. An extrapolation of future contaminant movement.
The Permittee shall document the procedures used in making the above
determinations.
3. Surface Water and Sediment Contamination
The Permittee shall conduct a surface water investigation to
characterize contamination in surface water bodies resulting from �.
releases of hazardous constituents at the facility.
The investigation may include, but not be limited to, the following
information:
a. A description of the horizontal and vertical extent of any
plumes) originating from the facility, and the extent of
contamination in underlying sediments;
b. The horizontal and vertical direction of contaminant movement;
c. The contaminant velocity;
d. An evaluation of the physical, biological and chemical factors
influencing contaminant movement;
e. An extrapolation of future contaminant movement; and
12 of 14

A description of'the chemistry of the contaminated surface
waters and sediments. This includes determining the pH,
total dissolved solids, specific contaminant concentrations, etc.
4. Air Contamination
The Permittee shall conduct an investigation to characterize
gaseous releases of hazardous constituents into the atmosphere
or any structures or buildings. This investigation may provide
the following information:
a. A description of the horizontal and vertical direction and
velocity of contaminant movement;
b. The rate and amount of the release; and
c. The chemical and physical composition of the contaminants(s)
released, including horizontal and vertical concentration
profiles.
The Permittee shall document the procedures used in making the above
determinations.
D. Potential Receptors
r The Permittee shall collect data describi.g the human populations
and environmental systems that are susceptible to contaminant
exposure from the facility. Chemical analysis of biological samples
and/or data on observable effects in ecosystems may also be obtained
as appropriate. The following characteristics shall be identified:
1. Current local uses and planned future uses of groundwater:
a. Type of use (e. g., drinking water source: municipal or
residential, agricultural, dcmestic/non-potable, and
industrial); and
b. Location of ground water users, to include withdrawal and
discharge wells, within one mile of the impacted area.
The above information should also indicate the aquifer or
hydrogeologic unit used and/or impacted for each item.
2. Current local uses and planned future uses of surface waters
directly impacted by the facility:
a. Domestic and municipal (e. g., potable and lawn/gardening
watering);
b. Recreational (e. g. swiuning, fishing) ;
13 of 14

e.
Agricultural;
industrial; and
Environmental (e. g., fish and wildlife propagation).
3. Human use of or access to the facility and adjacent lands,
including but not limited to:
a. Recreation;
b. Hunting;
c. Residential;
d. Commercial; and
e. Relationship between population locations and prevailing wind
direction.
4. A general description of the biota in surface water bodies on,
adjacent to, or affected by the facility.
5. A general description of the ecology within and adjacent to
the facility.
6. A general demographic profile of the people who use or have
access to the facility and adjacent land, including, but not
limited to: age; sex; and sensitive subgroups.
7. A description of any known or documented endangered or threatened
species near the facility.
14 of 14

APPENDIX C
FACILITY SUBMISSION SUMMARY

APPENDIX C
Facility Submission Summary
` A summary of the planned reporting requirements contained in the EPA HSWA permit is
�d presented below:
Facility Submission Requirements
RFA Information
Condition II.B.2.
RFI Plan for SWMU(s) identified in Appendix
A, Paragraph I .
Condition II.C.l.
RFI Progress Reports
Condition II.C.5.
Draft RFI Report
Condition II.C.6.
Final RFI Report
Condition II.C.6.
Interim Measures Progress Reports
from Condition II.D.5.
Interim Measure Report
Condition II.D.6.
Imminent Hazard Report
Condition II.F.1. and II.F.2.
Corrective Action Study/Plan
Condition II.E.2.
Due Date
Within 90 days of notification
120 days after effective date of
permit
Quarterly,,beginning 90 days from
implementation of RFI plan*
Ninety (90) days after RFI completion
Thirty (30) days after receipt
of EPA comments on Draft RFI Report
Semi-annually, beginning 180 days
implementation of Interim Measures*
Within ninety (90) days of completion
Oral within 24 hours; Written within
15 days
As determined by EPA after review
of RFI and permit modification
The above reports must be signed and certified in accordance with 40 CFR 5270.11.
* This applies to Plan execution that requires more than 180 days.

FMC Lithium Division WQOOO8149
SITE HISTORYAND CLOSURE REQUEST
FMC LITHIUM COPRPORATION LOCATION at Hwy 16 and SR 1403 in BESSEMER CITY, GASTON COUNTY,
NC is a chemical processing facility located in Bessemer City, NC. That has been in operation in N.C. since
1957. AS part of their waste disposal, FMC'used two Kiln Dust Scrubber Ponds to receive dust produced
by kiln present on site in the Lithium production processing. The dust was of the composition of
flocculent material size and this dust was sent to a fluid pond for the purpose of settling of the waste
material.
During the time frame between 1971 through 1998. The original compliant came through Gaston
County Health Dept. From Haslip & Landry. Another compliant was submitted by Mrs. Baumgardner in
November of 1971. These compliant were filed as the result of blasting activities at the FMC facility and
that these activities were the cause of private receptor wells becoming contaminated by excess iron and
mud. Samples were collected by Gaston County Health Department and copies sent to FMC. FMC
denied their activities could have fouled the Baumgardner WSW and claimed the well was bad. Further
investigation eventually tied the WSW contamination to FMC operations. In February of 1972, Mrs.
Baumgardner then contacted the USDI and through Raleigh the request was sent to Division of
Groundwater.
In March of 1972, the US Department of the Interior, Geologic Survey wrote that the case had been
referred to the Water resources Department of the USGS. In April of 1972, this case was referred to the
N.C. Dept. of Economic Resources Office of Water and Air.
On May 11, 1972, a letter was received from Nalco Chemical Company indicating that the well was old
and corroded and therefore the likely cause of the fouled well was corrosion of the well pipe casing. As
of this time period, FMC denied their operation was the cause of private well contamination.
During this same time period, several other residential wells located near the Lithium mine became
unusable. These well exhibited similar characteristics as did the Baumgardner well. Further
investigations lead to the creation of incident number 15150. It was determined that the FMC facility
was responsible for elevated levels of RCRA metals, Sulfate, Iron, Manganese and pH.
The Division of Waste Management had an active permit # NCD000771964, for the Industrial Landfill
present at the FMC facility. In January of 1975 the State of North Carolina, Groundwater Division along
with the Division of Waste Management were jointly monitoring Groundwater activities of the FMC
facility.
Through the sampling of onsite monitoring wells, it was discovered that the Kiln Scrubber Ponds present
on the site appeared to be to cause of the GW pollution. These two unlined ponds received waste
material from the kiln and were allowed to settle prior to being removed and placed into the onsite
landfill. Division of Groundwater issued a non -discharge water quality permit to FMC #WQ0008149 on
or about 1978. A groundwater monitoring plan was established and additional monitoring wells were
installed for the delineation of GW impacts resulting from the scrubber ponds.

In July and again in October of 1995 NOV's were sent to FMC for violation of the Title 15A Section 2L
water quality standards, for Fe, SO4/SO3, SO2, Mn, F, Li, Ca, pH and TDS caused by the unlined scrubber
ponds.
In correspondence between Division of Water Resources and Ms. Barbara Ritchie of FMC, it was agreed
to install a liner in the scrubber ponds. FMC already had a closure plan in place to remove the kilns from
service in 1998 and also begin the closure of the onsite industrial waste permitted facility.
Prior to the installation of the pond liner, core samples were collected after the pond sludge had been
removed and graded. The core samples indicated the presence of a Saprolite clay that through SPT
testing. These clays had a natural permeability of 1 x 10 (1/6) cm/sec. As these ponds were used in
alternating sequence; the scrubber pond not in use at the time had the sludge removed and a clay liner
was installed. The clay liner was compacted to a vertical permeability of 2.5 x 10(1/8) cm/sec.
In April of 1997, GW monitoring data reported the COCs for this site had come into compliance with the
2L water quality standards.
In July of 1998, FMC requested the discontinuation of GW monitoring for permit WQ0008149 and
stayed that closure of the Kiln Operation and subsequent ponds were scheduled to be taken off-line in
accordance with FMC's new business plan. The closure of the scrubber ponds are to be incorporated
with the closure of the on -site industrial solid waste disposal area. In September of 1998, permit
WQ0008149 was rescinded. This rescintion can be found on the BIMS site.
There is currently a Inorganic chemical manufacturing, Organic Chemical Manufacturing and Stormwater
Discharge permit NC 0005177 currently in under review at this site. This permit pertains to an Air
scrubber WW, condensate, blowdown and Stormwater cooling/condensate. This updated information
will be entered into the IBEAM site for update purposes.

State of North Carolina
Department of Environment,
Health and Natural Resources
Mooresville Regional Office
James & Hunt, Jr., Governor
Jonathan B. Howes, Secretary
1DEHNR
DIVISION OF WATER QUALITY
May 5, 1997
8 W f`
6,0
f7j
CERTIFIED MAIL
v
RETURN RECEIPT REQUESTED
-J
;=
c� r�r
FMC Corporation/Lithium Division
�,
-,-rn
Highway 274 Tryon School Road
-,i
Box 795
C?
Bessemer City, North Carolina 28016
cJ1
/J
G,
Attention: Scott Howell
c-�
RE: Notice of Violation
15A NCAC 2L Classifications and
Water Quality Standards Applicable
to the Groundwaters
FMC Lithium Mine - Bessemer City
Site Priority Rank 60B
Class AB
Incident No. Pending
Gaston County, N.C.
Dear Mr. Howell:
Chapter 143, North Carolina General Statutes, authorizes and
directs the Environmental Management Commission of the Department
of Environment, Health, and Natural Resources to protect and
preserve the water and air resources of the State. The Division
of Water Quality has the delegated authority to enforce adopted
pollution control rules. This letter is a standard notification
and is intended to advise you of the legal requirements under
North Carolina law.
Accompanying this Notice of Violation is a Notice of
Regulatory Requirements (NORR) for the North Carolina underground
storage tank (UST) rules, 15A NCAC 2N. While the NORR outlines
the steps necessary to bring the subject site into regulatory
compliance with the UST rules, this notice documents a violation
of the North Carolina groundwater standards as identified -in the
Site Assessment report received on April 9, 1997.
919 North Main Street, V FAX [phone]
Mooresville, North Carolina 28115 �f C An Equal Opportunity/Affirmative Action Employer
Voice 704-663-1699 50% recycled/100/. post -consumer paper

E
FMC Corporation
May 5, 1997
Page Two
Specific violations of 15A NCAC 2L .0103(d) - No person
shall conduct or cause to be conducted any activity which causes
the concentration of any substance to exceed that specified in
15A NCAC 2L .0202 - are as follows:
Constituent
benzene
ethylbenzene
Concentration*
3.5
71.0
*Concentration in parts per billion
2L Standard*
1.0
29.0
You are responsible for causing, contributing to or allowing
the continuing violation of the underground water quality
standards because you are the owner and operator of the former
USTs that leaked at the subject site.
According to 15A NCAC 2L .0106(c), you are required to
assess the cause, significance and extent of the violation,
submit a plan and schedule for eliminating the source and for
restoration of the groundwater, and implement an approved plan in
accordance with a schedule established by the director. In
establishing a schedule, the director shall consider any
reasonable schedule proposed by the person submitting the plan.
According to 15A NCAC 2L .0111, you are required to submit a
report of these activities in such detail as the Director of the
Division requires.
To achieve compliance with the above -cited laws or rules,
you are required to submit additional information to complete the
------pr-ev ous_y bmitted site assessment report in accordance with----
15A NCAC 2L .0106(c)(3) and .0106(g) and the enclosed guidelines.
The additional information required below and highlighted on the
enclosed guidelines must be received by this office within 60
days from your receipt of this letter. This data will then be
used to submit a corrective action plan which will be due within
60 days after the site assessment report is submitted and
approved by this office. In addition, you must submit a summary
of the site assessment report to the local Health Director and
the local Chief Administrative Officer in accordance with 15A
NCAC 2L .0114. That report should be submitted no later than
five working days after submittal of the comprehensive site
assessment report to this office. Please note
that prior to drilling any type of well in Gaston County,
including monitoring and recovery wells, you must have a well
permit from Gaston County Environmental Health. Call (704) 853-
5204 if you have questions about county permits.
Please be aware that your recommendation for no further
action at the subject site cannot be approved at this time. The

FMC Corporation
May 5, 1997
Page Three
risk -based framework used as a basis for your recommendation is
not expected to be in effect for at least two years, and the
adoption of 15A NCAC 2L .0115 ("Risk -Based Assessment and
Corrective Action for Petroleum Underground Storage Tanks") is
not expected for at least six months. In order to complete the
site assessment for the subject site, you should:
1. Complete the delineation of the vertical and horizontal
extent of soil contamination associated with.UST basin #1
(waste oil tank). Note that only one sample collected
beneath the south end of the UST was analyzed for Method
9071 (see Approved Methods for Soil Analyses). At a
minimum, additional samples should be collected immediately
below the north end and the middle of the UST. All samples
collected to define the extent of contamination around UST
#1 should be analyzed by EPA Methods 9071, and modified 8015
with both 5030 and 3550 as sample preparations.
2. Complete the delineation of the horizontal extent of soil
contamination associated with UST basin #2 (gasoline/diesel
USTs).
3. Complete all of the deficiencies noted on the attached Site
Assessment Format Guidelines.
Please note that the subject site is currently ranked as
high priority due to the presence of one reported water supply
well ("E") within 1,500 feet of the release. If you abandon
water supply well "E," then the priority ranking of the site
could be reduced to low priority. Senate Bill 1317 temporarily
suspends the requirement to continue with site assessment and
corrective action activities at low priority sites pending the
adoption of the risk -based rules for petroleum underground
storage tanks cited previously. By lowering the priority rank at
the subject site, you could wait for the adoption of the risk -
based rules before proceeding with further investigation.
You should be aware that any violation of 15A NCAC 2L.may
subject you to a civil penalty assessment under the authority of
G.S. 143-215.6A of up to $10,000 per rule violation. Each day
that the violation continues may be considered a separate
violation. Failure to respond within the time specified and to
voluntarily achieve compliance may result in a recommendation for
enforcement, the issuance of a Special Order against you under
the authority of G.S. 143-215.2, or a.request to the Attorney
General to institute an action for injunctive relief.

FMC Corporation
May 5, 1997
Page Four
Your response and/or questions should be directed to Steven
Bograd of the Mooresville Regional Office at [phone], ext.
246:
Sincerely,
D. Rex Gleason, P.E.
Acting Regional Supervisor
CC: ill Cutler - FMC Corporation
Groundwater Section - Raleigh
Gaston County Health Dept.
Joe Beaman - Fluor Daniel GTI (CSA Guidelines Enclosed)
Enclosures: Highlighted Comprehensive Site Assessment Guidelines
Approved Methods for Groundwater Analyses
Approved Methods for Soil Analyses
SEB/fmc2l.nov

Cal)
State of North Carolina
Department of Environment,
Health and Natural Resources •
Mooresville Regional Office
James B. Hunt, Governor ID� H-N
Jonathan B. Howes, Secretary
DIVISION OF ENVIRONMENTAL MANAGEMENT
December 20, 1995
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
FMC Corporation/Lithium Division
Post Office Box 795
Bessemer City, North Carolina 28016
Attention: Barbara Ritchie
RE: Notice of Violation
15A NCAC 2L Classifications and Water
Quality Standards Applicable,to the
Groundwaters
FMC Corporation/Lithium Division
Non=Discharge Permit W WQ0008149
Gaston County, N.C.
Dear Ms. Ritchie:
On October 31, 1995, FTIC Corporation/Lithium Division
received a Notice of Violation (NOV) of the North Carolina
groundwater standards. You were requested to install a monitor
well at the compliance boundary downgradient from MW1 and submit
analytical results for a water sample collected from the
monitoring well. The results were due by December 15, 1995.
While the October 27, 1995 NOV outlined steps necessary to bring
the subject site into regulatory compliance with Commission Rule
15A NCAC 2L .0106(d), this Notice documents a violation of 15A
NCAC 2L .0106(b).
During two meetings between FMC Corporation/Lithium Division
and staff of the Mooresville Regional Office on November 9, 1995
and December 7, 1995, it was demonstrated that the permitted
activities are a continuing source of contamination. In order to
control the source in accordance with Commission Rule 15A NCAC 2L
.0106(b), it was agreed that a schedule for lining the permitted
ponds was acceptable in lieu of submitting the analytical results
required in the October 27, 1995 NOV. On December 15, 1995, FMC
919 North Main Street, Mooresville, North Carolina 28115 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post-ccnsumer paper

FMC Corporation/Lithium Division
December 20, 1995
Page Two
Corporation/Lithium Division verbally requested an extension for
submitting the schedule until February 15, 1996.
You are requested to submit a schedule for implementation of
the chosen method of abatement by no later than February 15,
1996. The chosen method of abatement shall be completed by no
later than June 15, 1996. Your failure to respond within the
time specified and to voluntarily achieve compliance may result
in a recommendation from the Mooresville Office to the Director
of the Division for the assessment of civil penalties in.
accordance with G.S. 143-215.6A or in a request to the Attorney
General to institute an action for injunctive relief. Until such
time that the above requested information is received.in this
Office, you will remain in violation of North Carolina law. You
should note that any enforcement action, including assessment of
civil penalties, may begin from the original due date established
in the October 27, 1995 Notice.
Your questions should be directed to Steven Bograd or me in
the Mooresville Regional Office at [phone].
Sincerely,
B. Keith Overcash, 4E.
Regional Supervisor
cc: Rex Gleason - Mooresville Water Quality Section
Bob Cheek - Permits and Compliance Unit, Raleigh
seb

Control Number
County Number
5a 5
GROUNDWATER POLLUTION SOURCE INVENTORY
D (e 2--
"Source Name
OWNERSHIP
• :"
O Private
2 Municipal
Source Address
PC 161 — Q 14 0 3
3 County
4 State
City
County
Region
tfce►"er
5 Federal
6 Military
Owner/Operator
C/ A 60
w
71Quad Name
MultiPTe lources at Site
County Source Vs
YES
POTENTIAL SOURCE OF GROUNDWATER POLLUTION
LOCATION
OPERATION TYPE
TYPE OF WASTE
DISPOSAL FACILITY
OTHER SOURCE
D Facility
1 Municipal
1 Gasoline/diesel
Q Lagoon, etc.
1
Agricultural Activity
2 Highway
®Industrial
2 Other oil
2 Landfill-contro.
2
Salt water intrusion
3 Railroad
3 Agricultural
3 Solvents
3 Landfill-uncont.
3
Chemical stock pile
4 Waterway
4 Oil and gas
4 Corrosives
4 Land application
4
River infiltration
5 Pipeline
5 Mining
5 Other chemical
5 Abandoned site
5
Mine drainage
6 Dumpsite
6 Other Source
6 Sewage/septage
6 Sewer system
6
Intentional dump
7 Other
7 Sludge
7 Septic tank
7
Spill
8 Leachate
8 Injection well
8
Leak --above ground
9 Other solids
9 Disposal well
9
Leak --underground
0 In use
10 Gas
WASTE:
STATUS OF SOURCE: 2 Inactive
11 Pest/herbicides
3 Other
12 Fertilizers
11
`171+:N.a 0►t jRa(�rtr;el w��j�t)
POLLUTION STATUS AND CROSS-REFERENCES
GROUNDWATER POLLUTION
FACILITY PERMITTED: Yes No
1 Confirmed 0 Rank
1 NPDES 6 Mining
Q2 Potential 2 Tabulate
No: AJC 0 D 6 5 I Co I No:
2 DEM Nondischarge 7 Hazardous Waste (RCRA)
MONITORING WELLS
No: No:
�Q
1 No monitoring
_�
2 State has data
O Well Construction 8 Solid Waste
(Landfill)
3 Data at facility
No: No:
® Status unknown
4 Capacity Use 9 Oil Terminal
Registration
DATABASE CROSS-REFERENCE
No: No:
1 ERRIS (CERCLA) list
5 UIC 0 Air Quality
ID: A el0.600 9111 el t.,
No: No:
2 Surface Impoundment (SIA)
Comments
ID: '3
isv dor!'pd p•.tQ Tv.� 04 ort
3 GW Pollution Source Inv.
Date: f - Q , 76
4 Other DEM investigation
Date:
Compiler: Date:
�861

o{ FORM APPROVED
OMB NO. 158-S78004
DATE PREPARED SERIAL NUMBER
U.S. ENVIROIfMENTAL PROTECTION AGENCY
=
::. MONTH DAY YEAR . SURFACE IMPOUNDMENT ASSESSMENT (SIA)
LOCATION AND COUNT OF IMPOUNDMENTS
75 76 77 78 79 80 SECTION I '
FACILITY IDENTIFICATION
How many impoundments are
located at this site?
STATE IDENTIFICATION NO. (Optional)
•-'
STATE
CNTY.!CITY
PLACE
CATEGORY
SIA SITE NUMBER
..
_ `-
1 2
3 - 5
6 - 10
11 - 13
14 - 18
22
23 - 25
26 - 37
STANDARD INDUSTRIAL
SITE LOCATION J
NPDES NUMBER
DEGREES
MINUTES
SECONOS
DEGREES
MINUTES SECONDS
CLASSIFICATION (SIC Code)
<
'LATITUDE --op-
ONGITUDE-�
y59
I`7
65�56
60 61 62 '6r3
38 _ 46
47 - 50
51 52
53 54
57 -
OWNER
NAME OF OWNER
_
22 e - _ 59
OWNER'S MAILING ADDRESS (Street No. or P.D. Box)
22 - 59
CITY OR TOWN
c
STATE
ZIP CODE
OPERATOR
NAME OF OPERATOR
22 - 59
OPERATOR'S MAILING ADDRESS (Street No. or P.O. Box)
22 _ 59
CITY OR TOWN
STATE
ZIP CODE
7
<;
22 - 52
53 54
55 - 59
EPA Form 7500-44 (6-78) STATE COPY

MAY2
�oG�,
YG
Rk�iGy,
State of North Carolina
Department of Natural Resources and Community Development
Mooresville Regional Office
James G. Martin, Governor
S. Thomas Rhodes, Secretary Albert F. Hilton, Regional Manager
DIVISION OF ENVIRONMENTAL MANAGEMENT
May 20, 1987
Lithium Corporation of America (LITHCO)
Highway 161
P. 0. Box 795
Bessemer City, N. C. 28220
Subject: Well Construction Permit No.
35-0078-WM-0103
Lithium Corporation of America
(LITHCO)
Gaston County, N. C.
Dear Sir:
In accordance with your application received May 18, 1987 we are forwarding
herewith Well Construction Permit No. 35-0078-WM-0103 dated May 20, 1987,
issued to Lithium Corporation of America (LITHCO) for the construction of
a monitor well system.
This Permit will be effective from the date of its issuance and shall
be subject to the conditions and limitations as specified therein.
jr1cere ly,
Ronald L. McMillan
Regional Supervisor
Enclosure
cc: Vtaw Engineering, Inc.
ermits & Engineering
919 North Main Street, P.O. Box 950, Mooresville, N.C. 28115-0950 • Telephone [phone]
An Equal Opportunity Affirmative Action EmnU—

r L `
NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF NATURAL RESOURCES AND COMMUNITY DEVELOPMENT
PERMIT FOR THE CONSTRUCTION OF A WELL OR WELL SYSTEM
In accordance with the provisions of Article 7, Chapter 87, North Carolina
General Statutes, and other applicable Laws, Rules and Regulations,
PERMISSION IS HEREBY GRANTED TO
Lithium Corporation of America
FOR THE CONSTRUCTION OF A MONITOR WELL SYSTEM located in Bessemer City in
Gaston County in accordance with the application dated May 14, 1987 and in
conformity with specifications and supporting data, all of which are filed with
the Department of Natural Resources and Community Development and are
considered a part of this Permit. The monitor well system is to be constructed
in the residuum of the Charlotte Belt.
This Permit is for well construction only, and does not waive any
provisions or requirements of the Water Use Act of 1967, or any other
applicable laws or regulations.
Construction of a well under this Permit shall be in compliance with the
North Carolina Well Construction Regulations and Standards, and any other laws
and regulations pertaining to well construction.
This Permit will be effective from the date of its issuance until November
20, 1987 and shall be subject to other specified conditions, limitations, or
exceptions as follows:
1. The borehole shall not penetrate to a depth greater than the depth to
be monitored or the depth from which contaminants are to be
recovered.
2. The well shall not hydraulically connect separate aquifers.

Permit Number 35-0078-WM-0103
Page Two
3. Construction materials shall be compatible with the contaminants to
be monitored or recovered. The casing shall equal or exceed Schedule
40.
4. The well shall be constructed in such a manner that water fromC land
surface cannot migrate into'the gravel pack or well screen area.
5. When a sand pack is placed around the screen, a seal shall be
installed above the sand.
6. Grout shall be placed in the annular space between the casing and
the borehole wall from land surface to a depth within two feet
above the top of the well screen or to the bottom of the casing
for open end wells. The top of the well screen should be two feet
above the mean high seasonal water level.
7. All wells shall be secured to reasonably insure against unauthorized
access and use. The well shall be permanently labeled with a warning
*that it is for monitoring purposes and the entrance to the well must
be secured with a lockable cap.
8. All wells shall be afforded reasonable protection against damage
during construction and use.
9. Each well.shall have permanently affixed an identification plate.
10. A completed GW-1 and copies of all water quality results must be
submitted for each well to the Division of Environmental Management.
11. When any monitor well is no longer useful for its intended purpose,
it shall be properly abandoned and an abandonment -report filed with
the Division of Environmental Management.
Permit issued this the 20th day of May, 1987.
FOR THE NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
Ronald L. McMillan, Regional Super isor
Division of Environmental ManaRem t
By Authority of the Environmental Management Commission
---Parmit-No. 35-0078-WM-0103

RECEIVED
mmmm of "Worm NORTH CAROLINA
O
gg� TMENT OFVIRNATURALTAL RESOURCESMENT AND CO MUNITYNDEVELOPMENT
CATION FOR PERMIT
TO CONSTRUCT'MONITOR/RECOVERY WELLS)
To: NORTH CA OLINA ENVIRONMENTAL MANAGEMENT COMMISSION May 14
Gentlemen: 19 87
In accordance with the provisions of Article 7, Chapter 87, General Statutues of
North Carolina, and regulations pursuant thereto, application is hereby made by
Lithium Cor ora of America LITHCO
name of we owner for a permit to construc— t— a
monitor/recovery well(s) as described below and in the accompanying data submitted as a
part of this application.
(a) Name of property owner: LITHCO
(b) Location of property: Highway 161, Bessemer HE Gaston County
Road, Industry, Community, etc.j Town County (c) Type of facility or site being monitored: Industrial
(d) Types of, contamination being 49njtor or recovered: Volatile organic
com unds (VoC's) heav metals, inorganic compounds
(e) Existing monitor -well numbers: w-1 w-2 w-3
(f) Existing monitor wells showing contamination (well no.): w-1, w-2, w-3
(9) Estimated water -table depth: 20
feet
(h) Estimated date of construction: Begin 5/15
Complete 5/20
(i) Drilling constractor: Law Engineering, Inc.
(J) Location of well: Provide a detailed map showing the location of the proposed well(s),
and of any wells in an existing monitoring system (if applicable), in relation to the
Pollution source(s) being monitored and to at least two (2) nearby permanent reference .
Points such as roads, intersections, and streams. Identify roads with State Highway
road identification numbers. (Show all existing water supply wells within a radius of
1,000 feet of the proposed well.)
(k) Well constructi.on diagram: Provide a diagram showing including diameter, estimated depth, screens, sand ck,groutroposed construction specifications,
The Applicant hereby agrees the proposed pack, grout, type of materials, etc.
Highway 161, P. O. Box 795
well will be constructed in accordance with Bessemer City, NC 28016-0795
approved specifications and conditions of
the Well Construction Permit. As regulated LawEngineering,°ice Owner -Required)
under the Well Construction Standards (Title 501 Minuet Lane, Charlotte, NC 28220
15 - North Carolina Administrative Code,
Subchapter 2 (Mailing Address of Agent -if other
than above)
Signature of We] Owner or ent
Hydrogeologist FOR OFFICE USE ONLY
.0 Ole
Title if applicable PERMIT NO wsM 19!
issued
GW-22B

�'` ��\ \� `\\� C�J , / �• / /�/ r^� JAl
(I r� _ ..�i � �/• mil`. � \. \\; • • \ • _ � I I II
(
-14
`•\ ;fir. �. -- � :�4� � 1 I•i�- =-�'' ''�• � � ,�1��•___� l�1 �/1��.�� ��:�'tst� � \�• � .\: �. .. � 1
a w `; ``,,\\�1 \ % It ''I l:'III �i/' � `���•� j\� � „� ��/�+?,b`] l pO -0 �_ -� ,�1 � �\ • �t�
"( .. �-, / .I,�/ ._ .�Iti;.�' , r., ,��Y��=i�-a�L+��•••��p`� •. i' -. i __ •• + � \ `1: `�j I + ,`l � 1�i
\,`�'• •����+1' l � .� :r _�_�- i_:�� r r ^�� y_4 .�/! f '�\�j'��%'��..•f' `t'r •� _ •� - i - 1 /\ I t�,, 1`. �.`' r-
+`i � , /Ii ,\. ,�� � .. � \�/��: _.� j, r 'T �(���i �--tt/ _(1I�/ � � � ;� f� •: f`�•' - li.. �'I'1 Q I, I ..�\
�`K'y-: I` � � — •�l.�rwi
_ .:�� �—/1t�• sly �i• t��� _ `_�� �, — ,: i, ,� - ,
_ :.. Al � �\
lKI—^ .. '�.` \ �H• 11ytt \ ••� __ .. �� - '�;//.��-;.i•V.(\;\� 1 ..J � U�� 1.1 dJl.
LA ENGINEERING E ER
! li�:'1,(; '�- • ,.� i* i ,%'--,� �.•�. �,' ..;" .,,� �� ..♦ .��`• 1'\, =�;. _��:- W ENG TESTINGCo.
il►r a ( �1•;r\ �, ,;t CHARLOTTE, rORTH CAROLINA
LEGEND
0 545 APPDXIMATE MONITORING
B EXISTING MONITORING WELL WELL LOCATIONS
A PROPOSED MONITORING WELL aPPRox SCALE, FT.
JOB NO- CHW 5636 FIGURE I

i
6°Steel Pip
Concrete or Groui
Borin
Casin(
Grout Backfi
2" PVC Pipe
Bentonite Seal
Sand
11 PVC Screen
Cap
Note: All PVC Pipe Joints
Have Screw Connectors
Of
l�l�s • w-S
- - Cap
;crew Cap
Ground Surface
TYPICAL MONITORING WELL INSTALLATION
LAM ENGWEEM0 TETIM CCMFI4W
Zone of 'Interest
FIGURE 2.

T11r�VnAr W nTn

GROUNO SURrAC£ ' 11 �-,
SOLIO PVC RISER PtPE
(INSIOC OIAMETICR 2.0 INCHESI
PLUSH THREAOEO JOINTS
-:i-+rye;
SLOTTED PVC WELL SCREEN
(SLOT SIZE O.O t 0 INCH)
�o y/, orik
REMov,
CD� .-
WA
CEMENT SEAL
IICNTONITC SEAL
SANOPACK
ORILL HOLE: OIAMETER "NCHES
THRCAOEO PLUG —
TYPICAL DIAGRAM OF MONITORING WELLS
(NOT TO SCALE)
MONITORING WELL. INSTALLATION DETAILS
WELL NUM OCR
W-1
w-2 W-3
GROUND ELEVATION (FT-)
*889
*878 - ±915
i
•GROUNO WATER DEPTH (FT-1
20.2
- 9.1 -35.2
TOTAL OEPTH OF WELL (FT.1
27.0
23.5 48.5
MEASURING POINT ELEVATION (rT.l
Ground
Surface
Ground Ground
I Surface Surface
SCREEN LENGTH (M)
10.0
10.0 10.0
SOLID RISER LENGTH (FT.)
20.0
16.8 41.5
PVC HEIGHT AOOVE GROUNO (FT.)
3.0
3. 3 ` 3.0
THICKNESS Or RENTONITE SEAL
1.0
1.5 1.5
THICKNESS OF CEMENT SEAL (FT.) 14.0
7.5
28.5
LAW ENGINEERING TESTING MONITORING WELL
COMPANY INSTALLATION DETAILS
JOe No. CH-5275 FIGURE 2

GROUNDWATER POLLUTION SOURCE EVALUATION
R A 0 K I N G CRITERIA
/ THREAT TO GROUNDWATER
Probability of Groundwater Violations
3 Violations documented or highly probable
2 Default
QJ Violations unlikely .
Extent of Groundwater Contamination
3 Mappable, migrating plume
2 Defaul t
0 Insignificant contamination expected
Seriousness of Groundwater Threat
THREAT TO PEOPLE OR ECONOMY
How Hazardous to Health/Economy
3 People or business advised of contamination
�2 Default
( 10
� No expected impacts on people or business
Number of People at Risk
3 4 or more family units, or $10,000 loss
2 Default
0 No people or other interests at risk
Seriousness of People Threat
3 One of most serious in DEM region 3 Strong DEM concern over threat to people
2 Default 2 Default
Not considered a serious problem No threat to people or economy
FEASIBILITY FOR TAKING ACTION
Feasibility for Remedial Action
3 Remedial action both feasible and desirable
2 Default
0 No remedial action recommended
Desirability of Remedial Action
3 One of top regional office priorities
2 Defau.l t
Not a priority incident
FEASIBILITY OF RECLASSIFYING GROUNDWATER
Need to Reclassify Groundwater
3 Groundwater should be relassified RS or GC
2 Default
ONo reclass. nor remedial action recommended
Desirability of Reclassification
3 One of top reclassification priorities
2 Default
lO Not a priority incident
I THREAT OF POLLUTANTS
How Toxic are Pollutants (use Sax)
3 High value
2 Mod value
CLow or None value
Quantity of Pollutants in Ground
3 Reportable quantity of hazardous material
(CERCLA def.) or quantity of real concern
2 Default
17 Not of concern to regional office
Seriousness of Pollutant Threat
3 One of most serious in DEM region
2 Default
Not a serious threat
RANK SCORE:
Source Name:
Control Number: 15;?3
County:
Ranker -
Date:

l
�r•� � GROUND,:`WATER -.D:I.VI S I ON GSP 015
` P 71 x
OFFICE OF WATER AND AIR RESOURCES
35 20 20
DEPARTMENT OF NATURAL AND ECONOMIC RESOURCES 81 1830
RECORD OF GROUND WATER POLLUTION SOURCE
RECORD BY: Bill Crawford DATE 1/2/76 W.D. PERMIT NO . 8090
TOWN: Bessemer City COUNTY: Gaston
LOCATION (SKETCH ON BACK; at intersection of SR 1441 and SR 1442
OWNER(S) OF FACILITY OR INSTALLATION: Lithium Corp.
TYPE SOURCE: (LAND FILL, LAGOON, ETC) lagoons
CHARACTER AND QUANTITY OF POLLUTANTS: 50,000 gpd
DESCRIPTION OF FACILITY (SKETCH ON BACK) : several ponds or lagoons for
settling slimes created by flotation process for recovery of spodumene. Size of ponds
unknown.
HYDROGEOLOG I C CONDITIONS AT SITE: sandy clay saprolite mica schist and pemmatite
of Kings Mountain Group. --
POLLUTION CONFIRMED BY ANALYSIS? no DATE ANALYST:
MONITORING FACILITIES INS-TALLED:
no
SAMPLING SCHEDULE: none
NEAREST STREAM: UT Long Creek DISTANCE 0.1 mile
NEAREST WATER SUPPLY WELL: unknown DISTANCE
ANALYSES AND OTHER DATA AVAILABLE:
REMARKS: topographic map available (WQ files)
PAAF'f
Rf; J U D I, � V.
FORM GW-46

.Jro113J 5y !-CA
— i utur3 S:IRna3 Lagccas
`N
l�
Future. ?onc ?
7ac
Ford
.NI,
goon
1
5=-
'Martin
t 21ac. '
E4'ariat4a f
To rd �
Tryon
jSchool
23
3Z.s ac
Beam
r % StTQti j]Y&-
ti dung
CC)✓ �LJ 'JY z; T e--1 / r,_i..-•?i3Y"'l/�� / '•� %1,%• SW .
/ Pit Lit / C y u1
tun
i. -33
G i ' Co:net3"Y
0

-h,
0
FACILIT : Lithium Corporation
COUNaston
SUB-BASIN:03.-08-36
OWNERSHIP:
Individual in Charge: Operator in Charge:
H.E. Uhlend
Vice -President
Lithium Corporation of America
P.O. Box 795
DISCHARGECAIO' C. 28016
Latitude - 35020130" Longitude - 80016'40"
Directions - 300 feet north of SR 1442.
HYDROLOGIC:
Receiving Stream
Name - UT Long Creek
Class - A -II
Drainage Area -
Average Discharge -
7/10 Low Flow - 0 cfs
Stream System -
UT Long Creek- 2.6 miles
Long Creek - 13 miles.
South Fork Catawba River - 15.9 miles
FACILITY DATA:
Type
Class - I
Design Capacity - 0.216 mgd
Influent Flow - 0.05 mgd
Percent Industrial -
Priority Number -
Date in Operation -
Population Served -
construction of three pond to replace 1st pond
PERMIT DATA: NPDES eel n STATE
Number - NC00051 9 8035
Effective - 1-20-75 9-16-74
Expiration - 1-20-80-� 79
Effluent Limits - Interim T
Parameter Daily Avg Daily Max. Daily Avg. _Daily Max.
Flow (MGD) .216
TSS (lbs/day) 313 453
Settleable Solids (30 min.)
163
0.1 ml/l
Turbidity of the effluent shall be such as to prevent a turbidity in the receiving stream of more than
50 JTU above background:
Temperature of the effluent shall be such as to prevent a temperature in the receiving stream of more
than 50F above the ambient stream water temperature.
OPERATION AND MAINTENANCE:
SYSTEM MODIFICATIONS PROPOSED BY DISCHARGER: The permittee shall achieve compliance with the effluent
limitations specified for discharge in accordance with
the following schedule:
Progress Report: June 30, 1975
Progress Report: March 31, 1976
Attainment of Operational Level: December 31, 1976
STATE OF NORTH CAROLINA - DEPARTMENT OF NATURAL AND ECONOMIC RESOURCES
ORIGINAL FIRST UPDATE PAGE FSECOND UPDATE THIRD UPDATE
8•zz•�S HA; ryM CTB36-V-9

.+
Name of Establishment
Lithium Corporation Mine
*Gallons per day.
INDUSTRIAL CLASSIFICATIONS ASSIGNED TO SEWAGE
Process from Which
Wastewater Is isc arged
Mining and concentration
of lithium ore
CCCI IIChIT nATA
4-Di 'tt Approximate Dail *
SIC N Wastewater VoTume
1479
TESTS REQUIRED BY MONITORING ACT
DATA CURRENTLY AVAILABLE
PARAMETER
UNITS
STORET
NO.
SAMPLE
FREQUENCY
NO.
SAMPLE
MEAN
MAX
MIN
BEG
DATE
END
DATE
pH
S.U.
00403
1
7.0
7-19-74
Temperature
of
00011
Settleable Matter
ML L
00545
Daily
Turbidity
JTU
00070
Dailv
Residual Chlorine
MG L
50060
BOD, 5-day, 200C
MG/L
00310
COD
MG/L
00335
Color, true
PT -CO
00080
Formaldehyde
MG L
71880
Grease & Oil
MG L
00550
Tot ldahl Nitro
MG
00625
Phenols
32730
Total Phosphorous
00665
Total Residue
MG/L
00500
Total Sus . Res.
MG/L
00530
Detergents (MBAS)
MG/L
38260
OTHERS:
CTB36-V-10
1!
El

'
OPERATOR
NAME OF OPERATOR
59
22
OPERATOR'S MAILING ADDRESS (Street No. or P.O. Box)
59
22
CITY OR TOWN STATE ZIP CODE
21

-T
. — .
U.S. ENVIRONMENTAL PROTECTI(
DATE PREPARED
SURFACE IMPOUNDMENT ASSES
OPERATIONAL FEATURES OF THE IMPOUNDMENT AND GRr-
Mq_
MONTH
DAY
YEAR
SECTION H
INSTRUCTIONS: This form is to be completed for one impoundment per site (facility) identift
77
78
79 80
impoundment per site selected via random sampling procedures. Complete multiple choice que
7 7 ..
.. .... ... . .
I. FACILITY IDENTIFICATION
STATE
CNTY./CITY
PLACE
CATEGORY
SIA SITE NUMBER
I M POUND —
. ...... . . .
MENT NO.
1 2
3 5
L.._j
6 10
11 13
14 is
..s.77
19 21
111. IMPOUNDMENT DESCR
a. Age of impound
b. IS IMPOUNDMENT
PRESENTLY USED?
c. If answer to IIis
'yes',
d. If answer to III.b 's
e. Surface area of impoundment.
f. Surface area (
ment in years.
give no. of
'no', give last year
at this site (ij
1. Yes 2. NO
years in operation.
of operation.
(in acres)
..............
I
Ll
F
I
I
I
35 3
839
..... ...
40 4jJ.44
50
III. IMPOUNDMENT DESCRIP]
h. Average effluent
for 4_11js impoundment (gallons per day and year of record).
i. Average daily influent for all impoundments at this
of record).
GALS./DAYYEAR
:-I
I
OF
GALS./DAY,T71
RECORD
3 6
44
45 48
49
III. IMPOUNDMENT DESCRIPI
EPA Form 7500-44A (6-78)

GROUND WATER DIVISION GSP 067
OFFICE OF WATER AND AIR RESOURCES Q71 q
35 16 20
DEPARTMENT OF NATURAL AND ECONOMIC RESOURCES 81 1830
RECORD OF GROUND WATER POLLUTION SOURCE
RECORD BY: Michael S. Marsh DATE 1/76 W.D. PERMIT N0. 8028
TOWN: Bessemer City COUNTY: Gaston
LOCATION (SKETCH ON' BACK: Southwest of Bessemer City off 161.
OWNERCS) OF FACILITY OR INSTALLATION:
Lithium Corp.
TYPE SOURCE: (LAND FILL, LAGOON, ETC)
waste treatment plant
CHARACTER AND QUANTITY OF POLLUTANTS:_
10,000 gpd domestic waste
DESCRIPTION OF FACILITY (SKETCH ON BACK)
: Extended aeration type
packaize
treatment plant.
HYDROGEOLOG I C CONDITIONS AT SITE: Sandy
clay saprolite, mica gneiss
bedrock.
± 10 feet to water table
POLLUTION CONFIRMED BY ANALYSIS? no
DATE ANALYST:
MONITORING FACILITIES INS-TALLED: no
SAMPLING SCHEDULE: none
NEAREST STREAM: UT Abernathy Creek
DISTANCE
NEAREST WATER SUPPLY WELL: unknown
DISTANCE
ANALYSES AND OTHER DATA AVAILABLE:
REMARKS:
4i�ii�j L:t i 1••�iUil
RALEIGH,. ['4
FORM GW-46

November 13, 1975
Hr.. H.'. H. 11hl.and, Vice President
Lithium 'Corporation of America
P. 0. Box 795 {; ' :_.• :. ` :. r.>
' �,}✓.•: Ja..lr 4i L ti .a 5 .ply
Bessemer City,, North Carolina 28016
SUBJ CT: Amendment to Permit No. 2i2I3. NOV 18 1975
Lithium Corporation of Ax rica
Gaston County, North Carolina- C' >,'' t
'" R
Dear Hr. UI a6d s RALE
A review .has been completed of tU4 subject plan documents submitted for the
construction and operation of..a 4,;042 lineal foot 12-inch connector newer to dis-
charge from the existing tailings storage lagoon No. I into existing lagoon No. 2,
a storm water runoff drainage system to bypass the storage lagoons, modifications
to "the effluent spillway of existing storage lagoon . Wo. 2, " and a. dry -stacking area.,
for the ,ore: tailings.
The plan documents are satisfactory, and Permit No. 2123, dated August 23, 1971,
is hereby amended for the construction and operation of 3the 'aforestated modifications,
subject to the following conditions and, l.imi.tationsa
l.. The proposed modifications shall be constructed in accordance
with the Dam Safety Law of 1967 and the Sedimentation Pollution
Control Act of'1973.
2. Construction of the'store'tater runoff drainage system shall. not
;be initiated until final plans and specifications have beeu'received,
reviewed and approved by -this Division.
3,r All other conditions.and 11mitations as specified in Permit'2123,
dated August - 23, 1971,, shall remain in full force "and affect.
These proposed,nodifications should bring thex discharge from the chemical plant
into compliance with the Lithium Corporation of America's NPDES Permit.
Also, unclosed is a copy of WPC Form #50 "Cost of Wastemter Treatment W6rka."
This fora is to be completed and returned to this office within thftty. (30) days
after the project is completed.
Si car v,._
Ortg�na] 'WAed by'
L€ Pg. WRTIN
Director
cc: Gaston County Health .Depa_rt=Mt
Itsbinso®& Saie�rer, Inc.'
Mi. Robert Carter
Mr. J. Craig McKenzie
Mr. John C. Murdock- III
Mr. W.: S. $offsaus Technical 3erwie" .

STATE OF NORTH CAROLINA
DEPARTMENT OF NATURAL AND ECONOMIC RESOURCES
Box 27687 Raleigh 27611
JAMES E. HARRINGTON
SECRETARY
TELEPHONE
AREA CODE 919-829-4984
December 2, 1974
MEMORANDUM TO: Lee Laymon
FROM: Mike Groves
SUBJECT: Application for Discharge Permit
Lithium Corporation of America
Bessemer City, North Carolina
STATE
'ya.. yo
N�
:a
� r
ry�s J�
JAMES E. HOLSHOUSER, JR.
GOVERNOR
The enclosed application was forwarded to me for my comments.
The application is for an addition to existing facilities. It is
my opinion that the potential for ground water pollution is
present, but due to the nature of the effluent and the facility,
the probability of contamination will be slight.
Mike Groves
2
DECT
GIRWi D `-Vi" u ►` 9�10
MEGA. t ae. G, .

PPLICATIONFOR DISCHA�p
HCE PEP-'I�
- SEP - 0 . _974
Priority H-andli.no reouired
`all actions should be initi aled by per son.(�ta tt i n g a ��D AIR
_ �C t ldeflt-f 1 C? 10t1 : h.r �r��1 Li VYt t �t-� c� 1 �WI.EY� CGIW.-9
e_-.-t Co-ordinator
s �- received i-- Raleigh 1-7 4- Date Logged in .Raleigh?
a--, sw, tted to :�o Al�i e. w���Hegional Office �-,2 `%-'%ti2--
cn_ Engineer:
'ec--'Jed 1r1 ReCif171a1 0Tf��.n_CONH �� LCi7"�d ✓�� i�/'t' �� ? �i�� =�
o o "
(date) (date),
roject assigned to K'r�,�a�k, 1�6�a_t�S� iorL
-r- date As ; on eni, ac anowledged
Cf1eCk one and Complete
/ Application not com-ol.ete. Returned to Raleig2 �,rith letter to appli-,
cant describing deficiencies
Acl o�,rledgement (for. Mr. Hubbard s signature) Returned to Raleigh
.Ld=(,= Applicant
Cr_rfeted Eval-zat,? on and Site .Inspection ors
- - e�are and check off
Stai`f Report and Rec, 'ations %--�7�Draf Permit
_ Pb1ic No mice 1!�_--- Letter- of Notice Trap s-
rlitted to C1er ; o f Court
i Fact Sheet
Letter ofotice Transmitted /�'f-- Routing Sheet u_eplica,-
to. Local '?e::spaper Lion and date(l COD-,;-'
wrd �% expirac,7 dare Dr
Lroi ^•ar G Concur COi��en%S
it-zl-7¢
ec'r?2ical Ser ri caS _GI --Concur I / Co=ents
= , eld Se r : ' c e s Z�7 Concur Corfu^er_zS

rlicat on No. 1740")14I)atc fievio,rod
Section I GENERAL INFOFHATION,
1. Name of Applicant Lithium Corporation of America
--------------
2. Mailing address of. applicant -ay
Street _ o.r Box No. 795 3
Post Office Bessemer City - State North Carolina Zip 23o16
3. Location of Treatment Works and discharge point
County 'Gaston City, of Torn
Street No. or other location description Intersection of State Road -
No. 1441 and State Road No. 1442
4 Check type of application Original g i Z- 7 Revision:
i• Does this application include proposed construction -
��--7 yes no
If yes con. ete 6 �7
P ' 7, and 8, Tf no go to No. g.
b. Description of Proposed Works construction of an additional tailings
storage lagoon to receive residues from the flotation plant =z
(Proposed Lagoon D)
7. Construction Schedule
Plans and Specifications submitted on or before October 1, 1974
(date)
Begin Construction on or before December 1, 1971i _
(allot 30 days for plan review') (date
Complete ConstJune 1, 1g75
ruction on or before

.inued
-ge Two
Begin Operation on or before 5ertember i,
-
a
1975 ; -
5.
Name and address of Desigrk' Engineer. Clyde H. Robinson, P.E.
Robinson & Sawyer, Inc.; 205 S. York Street, Gastonia, PI: C. 23052
9.
Name and title of person. responsible for the works
Gee_: C. Blanton, Manager, Mining Department, Lithium Corporation of A;riEr@ca ,.
_1d
10.
Is discharge to % Surface Waters 0r Treatment P1ant
-o=
Another Owner?
11.
-If discharge is to surface wate.rs name of receiving 'strta-n
a tributary of Long Creek (A -II) Catawba
basin
,river
12.
If discharge is to Plant of Another Name.of Owner
and location of plant
Sec Dion
IT DISCHARGE DESCR_L 1'I iuTti
1.
Design average daily discharge (daily average for.-30 days)
t.!GD
4.32 MGD
' L4
Design maximum daily discharge (one day maxims-.m in -JO days)
MGD
4.68 MGD
3
Design peak discharge rate (peak hour flow in TtGD)
t`t=D
5. 0 MGD _ _

Parameter,
Influerlt,
£,ffluent
reduction,
7.0 _ ,0
r
Temperature .(winter). (P°)
55 of
50- o F:
Xr Cal_ 1
Tem 'erature (summer)' (1-, 0)
80 OF
70 o.
BOD K .dav 200 C ( Not 'Appl'cable)
m /i
Mg/ L
To�tal�..Solids
ds
15,000 tn_g/1 ' .
�0v g/Z
•T tal" Suspended Solids (no.
determin )/l
nil mg/1
T'01 N:(not determined)
mg/1.
0.3 m?/1
NIitrate-T`aitrite .(N) (not determined)
mg/1
.0.01 mg./l
-Phosphorus-(Total)
20 mg/1
i.5 mg/1
Turbidity
y
50 JTli .
F .Coliform Bacteria
xxxxxxxxx
- /100 ml
(not Applicable)

-'+ STATE OF NORTH CAROLINA
DEPARTMENT OF
NATURAL AND ECONOMIC RESOURCES
MEMORANDUM
DATE:
T0: (_ �'� C`� "`� ' ` rs �`k� SUBJECT:
�!%S'e' Slvd r�J ` h' s ,!�l7d� � �i%�/9 ✓v�� ll�,z d �d /md� �� /� /.s2�
// 1, ,/ /<
s
Rom,FRI
_<7x
a e•
FEB 3 1975
111UND L"JIA i ER 6IIION
RALOGH, At. C. .

.1630
I ��`-2 '
' . i�y� 1631� ;� 1627 1610 O 7
.8 0 I 1667 �p,S / 0
Ln
1_ s 1.0 1673/.6,.:: 'St. Marks 1622 1 b _ q / 1,607
1 9 I - � / _
i 626 Ch. 1624 1623 l Q
2. J. 1438 / `, Bethel g
.� r 1609 1665
X�/ 21 1666 I 1621co f a
t 1 4 31 1h I D �Q
7 . \
277 �� r • 1_661 v� Z
i 1? p1437
1448
q 144,, F%'� 1608 O c
X• r " S
•as /1416i .1 b� FAS �' •3 `\ 5 y � 1608
.cp:. f ; 45 i�4,� . co 3 2 2 2 '.�. 1602
1440 T� 1440 .3/ .2 S
FAS
Go 143 r �/j fu q `� �': `r .3 1475 ? 1447 1468 277 t
1439 'FP
1472 1460 d 9 ?�i
<1®►' 1414 1660
7.5 FqS h 1441 h a N 1446 1 480 • "� ��
r
1-16 i 274�
7 \ cn COnc d �• O -- 1455 9
y/ Ch. 1474 .0
1413 1412 `3` 1 1444 1445 � ��:. i .
.4 5
1442 5� 161
y6`` v . j c� 1446 1 —
5 1 ( 1448 `� 6
3 2 ` j4 `e 1 d52 ,.
S 11=76 1 1453
1445 ��
V 1450 cp
q u�
cb 1449 .9 1456
77 5 1410 '� Sunnyside' —
.sN1409 ,- 1 0 S` k al�S \G� 1453
Fp ee
%\ �4a2�` ^� ao9 ..t4oa�1443N �d43
6�� L�n9 ra -'� 5 1452 1456
10
1408 L` ti 'F \
7 1431 r C-3 2.3
2.0 1405 t ��
1401 14o4x '' r
1478
77Long Cr. I 1 ��. �.::;... 1459 '� 148t ,
z �� BESSEM� P,.� _ ry
_ 1466
O 1 02 i d01 1 403 i c.::, :``: ' .4
CITY ~ 10 g x 1 West Gastc
• �1407 .4 POP.4,017 274
lj
1402 e_ w�� ? 1312 1313All
1400
l
1401
1346
6 -
4 h 1 309
OJ 130__
:� -y
b L' 1 30� 1 306 2
/ ---- J
v,�,> Z 2 t 3 l 1
R " b 73-0 i
1. I c 1 310 4 1 f_ : T- I i 1.0
�� 1 �' ; 186 11 35 :✓
3 5' 1 5' i, d 1/> i 1 87 \` tt

MEMOTO:
DATE:
SUBJECT:
/^'LiCCJ
�✓ i o.....�t...-� % � if✓+Ca .,�,:i7 c.l i✓C. G.G._ �VG,q /L .�/L.^) fa. r�. b b i.✓5 Ga rd N 7
� • G
.Oy .r�e...`J
-/7 Ge_, ri e� e
/ /
Gi..��l . /�iL:ieeJ
GJ•9ytiC/f
GJIQ/ /•.sip/�..rJ c� / � r_//"-a ifiQuJi._.�
/!�
iS
.t%Li�,cc� !e/..*
/�JvF"� .
�U / ��� G�o.� C./� �urr!
� %:..c> ��.Ai '/c:z•7�
�7
From: /�
1Mc STATE Q
�^rs North Carolina Department of Environment,
Health, and Natural Resources
' Printed on Recycled Paper

199 4 14 : 14
V e
p . I
NC DEHNR
DEM-Groundwater Section
51214. Salisbury Street Raleigh, NC 27604
Phone: [phone]
Fax: (919' ) 716-0588
Date:
Pages inhiding this
Oe
A�e"11
4e, A
IV
J�
ell V
z

tq 11.=0.19'J4 14:15
FMC Corporhfloit
IIIttNVCly 1B1 DEM4 GROUND WTER SEC.
B(;x 795
j3essomer City NUrth C 1ruhi)1 2 601 Nov
704 868 5300 Fax 70 8( :,4tiEi
�Irmc
is ad r 1 1E;x its
NoveMber 28, 1994
State of North Car
Department of Envi
Wateir Quality Sect
r.o. Box 29535
Raleigh, NC 27626
Attn: Ms. Colleen
Permits and
1 inal
onmental Management
on
0535
llins, Supervisor
gineering
Res FMC Corporation - Lithium Division
Bessemer City Non -Discharge Permit NO, WQO008149
Permit Modification Application,
Dear Ms. Sullins
FMC Corporation's
( "F'MC" ) was issue(
1994 for the opera
including two 1.1
No. 20 in this pe:
existing groundwa.'
speoifi.ed in the
been installed to
Facility Investig
sampled these wel
Deportment of Env
permit NO. WQ0008
permit No. WQ0006
the groundwater q
detected in wells
groundwater wells
defined at 15A NC
Lithium Division facility in Bessemer City
Non -Discharge permit No. WQ0008149 on .June 14,
tion of its kiln scrubber water recycle system,
acre recycle ponds ("kiln onds"). Condition
mit re uired that FMC same a two previously
,er monitor wells, DC -I and,DC-2, for. parameters
.ori-discharge permit. (Wells DC-1 and DC-2 had
investigate the kiln ponds, ppursuant to a RCRA
•tion underway at the FMC facility.) FMC
•s and reported the results to North Carolina
.ronmental Management ("DEKII) in accordance with
.4 9 can October 13, 1994. Condition 20 (c ) of
.49 includes provisions that if exceedences of
=ality standards at 15A NCA' 2L .0202(g) are
DC-1 and/or DC--2, then two, additional
shall be installed at the "review boundary" as
�C 2L .0108.
Concurrent with F C's submission of the results of sampling wells
DC-1 and DC-2, pm also advised DEM that, while the installation
of an additional dell downgradient of well No. DC-1 and the
western kiln pond appears to be warranted, it is unclear that
well No. DC-2 reflects any impact by the eastern kiln pond.. FMC
included the following discussion in its October 13 letter:
F. 2

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uTTTnS UGOTTOO 'ski
j

Me. colleen Sullins
Non-p,i$charge perms{
November 26, 1994 --i
FMC beli.evee that
manganese in well
generally approxim
assessment is diff
point. Moreover,
fluorides, and as
believes that then
of the eastern kil
FMC has contacted
telephone and died
it was agreed that
non -discharge perm
to install another
and, rather, Bette
continuing to moni,
Additionally, Mr.
system to track gr
limitations on wel
programming.
Thus., FMC... is re
Item 20(C) should
"Within 90 days of
downgradient monit
the water lovel it
(open) portion of
general location e
Each monitoring wE
permit, and appro%
11.30.1994 14:16
No. WQ0008149
Page 3
4ile the values observed for pH, iron, and
C-2 do not duplicate those.in w-7, they may
to background conditions and further
cult based on the existence of only one data
s FMC's kiln scrubber water contains
o fluorides were detected in DC-2, FMC
data do not support additional investigation
pond pursuant to the non -discharge permit.
r Brian Wagner [BEM Groundwater Section, by
P. 4
sled these results and FMC's evaluation.
rmc would request a modification of
t No. wQ0008149 to eliminate the requirement
well downgradient of the eastern kiln pond �
characterize existing conditions by
or wells DC-2 and W-7 for at least one year.
agner informed FMC of DEM's new computer
undwater monitoring results and the
identification numbers inherent in the
tinq that DEM modif non ischar a permit
nf _r%_I 1 rtw nrY f`nn ti ons.
e modified to state:
the initial sampling of wells DC -I and DC-2, a
Dr well (WQ-1) shall be constructed such that
the well is never above of below.the screened
the well at any time during the year. The
nd name for the well .is marked on Attachment A.
ll shall be constructed in accordance with this
ed by the Mooresville Regional Office..
item 21 should be modified to state:
"Mogi.tor wells WQ 1, DC-2, and W-7 shall be identified fox
purposes of this permit as "wQ-1", "WQ-2 ANA DCe-2111 and "WQ-3 ANA
W-711. Monitor well WQ-1 shall be sampled initially after
construction. Mollitor well wQ-11 114Q-2 and WQ-3 shall be sampled
evety April, Augu t, and December for the following parameters:
14
IIA IC

i 11.30.1994 14:15
P. 5
Ms" olleen Sull.ino
Non- isch&rge perm t Eta. WQ0008149
Novo ber 28d 1994 � Page 4
u
A.
The map included al Attachment A has been revised an is attached.
FMc has included tie permit modification processing fee of
$400.00; a check ia enclosed.
Lastly+ FMC requests that this permit modification be processed
as soon as possible but no later then January 7, 1995, the date
when the current p rrmit would appear to require installation of
two downgradient m nitoar wells*
thank you for your IIprompt attention to and cooperation in this
matter. If you have any questions, or require additional
information, please contact me at 704/868-0806.
V y tru y yours,
Barbara � itchi
Environm ntal Mar► gee`
Mr. Bran Wag er
DEHN1 Groan water Section
512 North Sal sbury Street
Raleigh, NC 7604
a

11.30 1994 14. 17
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DIVISION OF ENVIRONMENTAL MANAGEMENT
GROUNDWATER SECTION
• N.CyDEI�T 9OF
ENVIRONMENT, HEALTH,
MEMORANDUM & NATURAL RESOURCES
TO: Carolyn McCaskill V`,N z 1994
THROUGH: Ted Bush(�47OfV��4�t3 4� Ef��flt ;d-9fidT 4 f�AfdflGf�; T
\ftifjCAEs'�1tlE CfSfOf�L UFF1Cf
FROM: Bob Cheek
SUBJECT: Adjudication for:
FMC Corporation/Lithium Division
Gaston County
WQ0008149/GW94093
The Groundwater Section (GWS) has reviewed the adjudication for the subject facility. In
a letter from FMC, dated May 2, 1994, commenting on the draft nondischarge permit, objection
was raised to several groundwater related conditions. Among the issues raised were sampling
methods, use of certain monitoring wells and their locations, duplicative sampling for this permit
and the companies RCRA Facility Investigation, and the need for lagoon liners. Brian Wagner
has contacted Barbara Ritchie of FMC to clarify FMC's comments to the draft nondischarge
permit and explain Groundwater's position. A draft copy of our comments to this letter were
faxed to Barbara Ritchie on May 17, 1994.
FMC commented back to the GWS in a letter received May 24, 1994. Their response is
attached to these comments. Six points were raised by FMC to our draft comments. On May 25,
1994, Brian Wagner contacted Ms. Ritchie to verbally discuss FMC's response and the GWS's
position and work out any differences. In FMC's response, item 2(B) has been clarified by only
requiring one sampling event. For item 2(A) and 4 a 30 days time limit for submitting sample
results to the GWS has been agreed upon. Our comments in this memo are a result of this
conversation and all are agreed to by the GWS and Ms. Ritchie.as FMC's spokesperson. This has
also been discussed with the Mooresville Regional Office/Groundwater Section.
Therefore, we recommend the following comments replace conditions 20 through 28 on
the draft nondischarge permit dated April 11, 1994:
*20. The following outline defines the events.that will dictate the need for additional
monitoring wells:
(A) Within 90 days of permit issuance, RCRA Facility Investigation wellsDC-1 and
DC-2 shall be sampled for the parameters listed in condition 20(C)(1),

achieving detection limits as specified in 15A NCAC 2L .6202 (b). The results
from this sampling, and a diagram showing construction details for each well,
shall be submitted to the Groundwater Section, Permits and Compliance Unit,
P.O. Box 29535 Raleigh, N.C. 27626-0535 within 30 days of the sampling.
(B) If it is determined by the Division that no exceedences of groundwater quality
standards are present in DC-1 or DC-2, then no further groundwater
monitoring will be required under this permit.
(C) If any exceedance of the standards, specified in 15A NCAC 2L .0202 (g); are
detected as a result of groundwater sampling analyses in either DC-1 or DC-2,
then within 90 days of this detection, two (2) new downgradient monitor wells
(WQ-1 and WQ-2) shall be installed to monitor groundwater quality. The
well(s) shall be constructed such that the water level in the well is never above
or below the screened (open) portion of the well at any time during the year.
The general location and name for each well is marked on Attachment A. Each
monitoring well shall be constructed in accordance with this permit, and
approved by the Mooresville Regional Office.
Monitor wells WQ-1 and WQ-2 shall be sampled initially after
construction and thereafter every April, August, and December for the
following parameters:
Calcium
TDS
pH
Chloride
Chromium*
Iron*
Aluminum*
Sulfate
Water Level
Fluoride
Manganese*
Lithium*
* use method 3030C, preparation for metals, in Standards Methods, 17th
edition
2. The measurement of water levels must be made prior to sampling for the
remaining parameters: The depth to water in each well shall be measured
from the surveyed point on the top of the casing.
The measuring points (top of well casing) of all monitoring wells shall be
surveyed to provide the relative elevation of the measuring point for each
monitoring well. —
4. The results of the sampling and analysis shall be sent to the Groundwater
Section, Permits and Compliance Unit, P.O. Box 29535 Raleigh, N.C.
27626-0535 on Form GW-59 [Compliance Monitoring Report Form]
every May, September, and January.

14.
All wells that are constructed for purposes of groundwater monitoring
shall be constructed in accordance with 15A NCAC 2C .0108 (Standards
of Construction for Wells Other than Water Supply) and any other state
and local laws and regulations pertaining to well construction.
6. The Mooresville Regional Office, telephone number [phone], shall
be notified at least forty-eight (48) hours prior to the construction of any
new monitoring well required under this permit so that an inspection can
be made of the monitoring well location. Such notification to the
regional groundwater supervisor shall be made during the normal office
hours from 8:00 a.m. until 5:00 p.m. on Monday through Friday,
excluding state holidays.
7. Within sixty (60) days of completion of all new monitoring wells required
under this permit, the permittee shall submit two original copies of a
scaled topographic map (scale no greater than 1":100') signed and sealed
by a professional engineer or a state licensed land surveyor that indicates
all of the following information:
a. the location and identity of each monitoring well,
b. the location of the waste disposal system,
c. the location of all property boundaries,
d. the latitude and longitude of each monitoring well,
e.. the relative elevation of the top of the well casing (which shall be
known as the "measuring point"), and
f. the depth of water below the measuring point at the time the
measuring point is established.
The maps shall be sent to the Groundwater Section, N.C. Division of
Environmental Management P.O. Box 29535 Raleigh, N.C. 27626-0535.
Upon completion of all well construction activities, a certification must
be received from a professional engineer certifying that the monitoring
wells are located and constructed in accordance with the Well
Construction Standards _(15A NCAC 2C) and this permit. This
certification should be submitted with copies of the Well Completion
Form (GW-1) for each well. Mail this certification and the associated
GW-1 forms to the Permits and Compliance Unit, Groundwater Section,
P.O. Box 29535, Raleigh, NC, 27626-0535.
9. For the initial sampling of the well as specified elsewhere in the permit,
the permittee shall submit a copy of the GW-1 form with the
Compliance Monitoring Form (GW-59) for that well. Compliance
Monitoring Forms that do not include copies of the GW-1 form will be
returned to the permittee without being processed. Failure to submit

-46
these forms as required by this permit may result in the initiation of
enforcement activities pursuant to NC General Statutes 143-215.6.
21. The COMPLIANCE BOUNDARY for the disposal system is specified by
regulations in 15A NCAC 2L, Groundwater Classifications -and Standards. The
Compliance Boundary for disposal systems constructed after December 31, 1983 is
established at either (1) 250 feet from the waste disposal area, or (2) 50 feet within
the property boundary, whichever is closest to the waste disposal area. An
exceedance of Groundwater Quality Standards at or beyond the Compliance
Boundary is subject to immediate remediation action in addition to the penalty
provisions applicable under General Statute 143-215.6A(a)(1).
22. In accordance with 15A NCAC 2L, a REVIEW BOUNDARY is established around
the disposal systems midway between the Compliance Boundary and the perimeter
of the waste disposal area. Any exceedance of standards at the Review Boundary
shall require remediation action on the part of the perrdttee.
Note: * = different from standard language
D_ 1T�VOW
t'�c��7laYi�l�U�a�aa-a�e�-a
Central Files
Permit Files
baw/94093 . doc

F Rj-1 1-1 F . I
DIVISION OF ENVIRONMENTAL MANAGEMENT
GROUNDWATER SECTiON
May 13,19,04
MEMORANDUM
North Carolina - Department of
Environment, Health, and Natural Resources
Division of Environmental Management
Groan dwatc,,r Sectioll
5 1 .2',N. Salisbury Street, Raleigh, N.C. 270'04
I
FIU='DA' Cov
Company -..-A
Phone:
Fax:
From
Pages ffieludim, chl'U.
v Phone: [phone]
Fax.; [phone]
NMI,
rx &&441
An U K/I
MINIMUM— 177—

F R 01-1
01 . u1 . 2000 0 G ; 17' 0 F. 2
DIVISION OF ENVIRONMENTAL MANAGEMENT
May 13, 1994
MEMORANbUM
TO; Carolyn N�Xaskill
THROUGH; Ted Bush
FROM: Bob Cheek
SUBJECT; Adjudicat;on for;
FMC Cor�oration/Lithium Division
Gaston C6unty
WQ0008149/GW94093
The Groundwater Section has reviewed the adjudication for the subjact facility. In a letter
from FMC, dated May 2,. 1994, commenting on the draft nondischarge permit, objection was
raised to several grourid'ator related conditions. Among the issues raised were sampling
methods, use of certain *nitoring wells and their locations, duplicative sampling for this permit
and the companies RCRA Facility Investigation, and the need for lagoon liners. Brian Wagner
has contacted 13arbara Ritchie of FMC to clarify FMC's comments to the draft nondischarge
permit and ex0lain Cirous dwater's position,
The Mooresville Regional Office/Groundwater Section has been consulted on these
comments. We recommend the following comments replace conditions 20 through 28 on the
draft nondischarge permit;
*20. The following outline defines the events that will dictate the need for additional
monitoring wells;
(A) As a result of the RCItA Facility Investigation, the laboratory methods used to
analyze groundwater quality samples in wells DC-1 and DC-2 shall have
detection limits as specified in 1 SA NCAC 2L 0202 (b). The results from this
sampling, And a diagram showing construction details for each well, shall be
submitted to the Groundwater Section, Permits and Compliance Unit, P.O.
Box 29535 Raleigh, N,C. 27626-0335, with in 90 days of the date. of permit
issuance,
(H) If it is determined by the Division that no exceedences of groundwater quality
standards are present in IBC-1 or DC-2, then no further groundwater
monitoring will be required.
(C) If any exceedance of the standards, specified in 15A NCAC 2L ,0202 (g), is
deteoted as a result of groundwater sampling analyses in either DC-1 or DC-2,
then within 90 days oftlus detection, two (2) downgradient monitor wells shall
be installed to monitor groundwater quality. The well(g) shall be constructed
such that the water level in the well is never above or below the screened
(open) portion of the well at any time during the year, The general location

FROP1 91.01.2000 :^R: i C.. F. 3
and n4me for each well is marked on Attachment �. Each monitoring well shall
be constructed in accordance with this permit, and approved by the
Moor6sville Regional Office.
Monitor wells WQ-1 and WQ-2 shall be sampled initially after
construction and thereafter every April, August, and December for the
following parameters;
Calcium
Aluminum*
TDS
Sulfate
pH
Water Lovel
Chloride
Fluoride
Chromium*
Mangangse*
Iron*
Lithium*
* use method 3030C, preparation for metals, in Standards Methods, 17th
edition
2. The measurement of water levels must be made prior to sampling for the
remaining parameters, The depth to water in each well shall be measured
firom the surveyed point on the top of the casing,
3, The measuring points (top of well casing) of all monitoring wells shall be
surveyed to provide the relative elevation of the measuring point for each
monitoring well.
4. The results of the sampling and analysis shall be sent to the Groundwater
Section, Permits and Compliance Unit, P.O. Box 29535 Raleigh, N,C.
27626.0535 on Form GW-59 [Compliance Monitoring Report Forth]
every May, September, and January.
All wells that are constructed for purposes of groundwater monitoring
shall be constructed in accordance with 15A NCAC 2C .0108 (Standards
of Construction for Wells Other than Water Supply) and any other state
and local laws and regulations pertaining to well construction.
6. The Mooresville Regional Office, telephone number [phone], shall
be notified at least forty-eight (48) hours prior to the construction of any
monitoring well so that an inspection can be made of the monitoring well
location. Such notification to the regional groundwater supervisor shall
be made during the normal office hours ftom 8:00 a,m, until 5:00 p,m, on
Monday through Friday, excluding state holidays.
7. Within sixty (60) days of completion of all monitoring wells, the
ermittee shall submit two original copies of a scaled topographic map
(scale no greater than V:100') signed and sealed by a professional
Ongineer or a state licensed land surveyor that indicates all of the
following information:
a. the location and identity of each monitoring well,
b. the location of the waste disposal system,

FROM
01.01.2000 0 0 : 0 0 F. 4
c. the location of all property boundaries,
d. the latitude and longitude of each monitoring well,
e, the relative elevation of the top of the well casing (which shall be
known as the "measuring point"), and
f the depth of water below the measuring point at the time the
measuring point is established,
The maps shall be sent to the Groundwater Section, N.C. Division of
Environmental Management P.O. Box 29535 Raleigh, N.C. 27626-0535,
8. Upon completion of all well construction activities, a certiflcation roust
be received from a professional engineer certifying that the monitoring
wells are located and constructed in accordance with the Well
Construction Standards (15A NCAC 2C) and this permit. This
certification should be submitted with copies of the Well Completion
Form (OW-1) for each well, Mail this certification and the associated
GW-1 forms to the Permits and Compliance Unit, Groundwater Section,
P.O. Box 29535, Raleigh, NC, 27626-0535.
9. For the initial sampling of the well as specified elsewhere in the permit,
the permittee shall submit a copy of the GW-1 form with the
Compliance Monitoring Form (GW-59) for that well. Compliance
Monitoring Forms that do not include copies of the GW-1 form will be
returned to the permittee without being processed. Failure to submit
these forms as required by this permit may result in the initiation of
enforcement activities pursuant to NC General Statutes 143-215.6.
21. The M2LIANCE BOUNDARY for the disposal system is specified by
regulations In I SA NCAC 2L, Groundwater Classiticatipns and Standards. The
Compliance Boundary is for the disposal system constructed after December 31,
1983 is established at either (1) 250 feet flom the waste disposal area, or (2) 50 feet
within the property boundary, whichever is closest to the waste disposal area, An
eicceedance of Groundwater Quality Standards at or beyond the Compliance
Boundary is subject to immediate remediation action in addition to the penalty
provisions 4pplic4ble under General Statute 143-215,6A(a)(1).
22. In accordance with 15,E NCAC 2L, a R.E'VMW B®UNDAM is established around
the disposal systems midway between the Compliance Boundary and the perimeter
of the waste disposal area. Any exceedance of standards at the Review Boundary
shall require remediation action on the part of the permittee.
oc; Barbara Christian
Central Files
Permit 'Fllcs
baw/94093.doc

FR01-1
01.01.2000 00:00 P. 1
j '. :\ :�:,;;
Environment, Health, and Natural Resources
S
,SAS
ra'`i+' �witrfi4'£i�4'a�y: l�i,�;K... � .4.. r, �i .•fi€�'�'; r�; .;�£;'°
�;;�;i:?' r . kSj'+Y,is'.Tr :� � ��.;y;�i�•�j �.,g?ti,{iS; �i,vf,3is�'„i, . � 3ii's�
�
iv►sion of n�i�°o�en talManagement
�t4Groundwater
Section
► 94 Ss 6 b6 '�4e \• 6 b � 'a ffi
Y
r
512-N. Salisbury Street, Raleigh, N.C. 27604,
LI
Toni ¢ r i a I,\; ti-)z.e. ti r '
Phone: [phone]
Fax; [phone]
Date:
Pages inolud4 this cover page;_
yet 1V'" �,��/
A�qv�.. A►,
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FROM , 01.111.12000 05:00 F. 2
and n'tt�e for each well is marked on Attachment 3. Each monitoring well shall
be constructed in accordance with this permit, and approved by the
Mooresville regional Office,
I. Monitor wells' Q_I and WQ-2 shall be sampled initially after
I
onstruction and thereafter every April, August, and December for the
�bllowing parmneters:
Calcium Aluminum*
TDS
PH
Chloride
Chromium*
Iran*
Sulfate
Water Level
Fluoride
Manganese*
Lithium*
* use method 3030C, preparation for metals, in Standards Methods, 17th
edition
2. The measurement of water levels must be made prior to sampling for the
remaining parameters. The depth to water in each well shall be measured
ftoim the surveyed point on the top of the casing.
3, The measuring points (top of well casing) of all monitoring wells shall be
Murveyed to provide the relative elevation of the measuring point for each
onitoring well.
i
4. the results of the sampling and analysis shall be sent to the Groundwater
Section, Permits and Compliance Unit, PD, Box 29535 Raleigh, N.C.
27626-0535 on Form OW-59 [Compliance Monitoring Report Form]
�vety May, September, and January,
i
5. .ill wells that are constructed for purposes of groundwater monitoring
shall be constructed in accordance with 15A NCAC 2C .0108 (Standards
bf Construction for Wells Other than Water Supply) and any other state
and local laws and regulations pertaining to well construction.
6. The Mooresville Regional Office, telephone number [phone], shall
be notified at least forty-eight (48) hours prior to the construction of any
monitoring well so that an inspection can be made of the monitoring well
location. Such notification to the regional groundwater supervisor shall
be made during the normal office hours from 8:00 a.m. until 5:00 p,m, on
Monday through Friday, excluding state holidays.
7. Within sixty (60) days of completion of all monitoring wells, the
permittee shall submit two original copies of a scaled topographic map
scale.no greater than 1":100) signed and sealed by a professional
engineer or a state licensed land surveyor that indicates all of the
Following information:
a, the location and identity of each monitoring well,
b. the location of the waste disposal syetem,

FROM
01 . ©1 . 2000 00.' OEM P. _
c. the location of all property boundaries,
d. , the latitude and longitude of each monitoring well,
b, the relative elevation of the top of the well casing (which shall be
known as the "measuring point"), and
£ the depth of water below the measuring point at the time the
measuring point is established.
' he maps shall be sent to the Groundwater Section, KC, Division of
environmental Management P.C. Box 29535 Raleigh, N,C, 27626-0535.
Vpon completion of all well construction activities, a certification must
be received from a professional engineer certifying that the monitoring
wells are located and constructed in accordance with the Well
Construction Standards (15A NCAC 2C) and this permit. This
certification should be submitted with copies of the Well Completion
Form (GW-1) for each well, flail this certification and the associated
GW- I forms to the Permits and Compliance Unit, Groundwater Section,
F.C. Box 29535, Raleigh, NC, 27626-0535.
9. For the initial sampling of the well as specified elsewhere in the permit,
the permittee shall submit a copy of the GW-1 forth with the
goanpliance Monitoring Form (GW-59) for that well. Compliance
Monitoring Fortes that do not include copies of the QW-1 form will be
returned to the permittee without being processed. Failure to submit
these fortes as required by this permit may result in the initiation of
enforcement activities pursuant to NC General Statutes 143-215,6.
21. The QQMPLI ' 1,NDARY for the disposal systems is specified by
regulations in i $A NCAC 2L, Groundwater Classifications and Standards. The
Compliance Boundary is for the disposal system constructed slier December 31,
1983 is established at either (1) 250 feet atom the waste disposal area, or (2) 50 feet
within the property boundary, whichever is closest to the waste disposal area. An
exceedance of Groundwater Quality Standards at or beyond the Compliance
Boundary ig subject to immediate remediation action in addition to the penalty
provisions applicable under General Statute 143-21 $.6A(a)(1),
22. In accordance with 15A NCAC 2L,, a REDEW BQLIMAM is established around
the disposal systems midway between the Compliance Boundary and the perimeter
of the waste disposal area. Any exceedance of standards at the Review Boundary
shall require remediation action on the part of the permittee.
cc, Barbara Christian
Central Files
Permit Files
baw/94093.doc
:+::+::rEHD***

FMC Corporation
Lithium Division��".:,
Highway 161„����
Box 795Oi
Bessemer City North Carolina 28016 9 JID
704 868 5300 Fax [phone] p«G o
August 5, 1993
Mr. Robert B. Krebs, Hydrologist
Groundwater Section
Division of Environmental Management
P.O. Box 950
Mooresville, NC, 28115
Dear Mr. Krebs:
It was a pleasure to meet you here at our plant on
Tuesday.
At your request, I am sending you herewith the following:
1. A well log for our upgradient well, W-7.
2. Listing of our proposed plans (to EPA) for additional
wells below these two surface impoundments.
Please call me or Mr. Gerald Scott if you have questions.
Sincerely yours,
Arthur S. Gillespie, Jr.`�
Environmental Manager

GROUND -WATER MONITORING WELL INSTALLATION RECORD
JOB NAME LITHCO JOB NUMBER CHW-5852
WELL NUMBER W-7 GROUND SURFACE ELEVATION 970 (APPROX.)
LOCATION NORTHEAST CORNER OF FACILITY - NEAR HIGHWAY 161
INSTALLATION DATE 5-15-87
GROUND SURFACE
STEEL PIPE
BORING
(6"DIA.)
GROUT
BENTONITE SEAL
2" PVC PIPE
SAND
PVC SCREEN
CAP
NOTE: ALL PVC PIPE JOINTS
HAVE SCREW CCNNECTORS
LOCKABLE CAP
VENTED PVC .CAP
STICKUP - 1.9 FT.
TOTAL DEPTH
DEPTH TO TOP OF WELL
OFSAND BACKFILL 38.5 FT.
CEPTH TO 12 FT.
LITHCO LAW ENGINEERING TESTING GROUND -WATER MONITORING
COMPANY
BESSEMER CITY, N C WELL INSTALLATION RECORD
CHARLOTTE NORTH CAROL IHA
B-4

Table 3-1
Summary of Planned Activities (Grouped by Area)
Phase I Investi ation
Phase II Investigation
Subsurface
Surface Water
Boring/Drilling
Planned Phase I
Potential Phase 11
No.
SWMU
Waste/Soils
and Sediment
Groundwater
Activities
SWAfU Group Activities
SWMU Group Activities
1
Kiln Particulate
3 samples
1 water sample
f None
1 soil boring
• Collect 3 subsurface soil samples from 1 boring in
• Install monitor well at SB-1 if significant
Scrubber
(SW-1) from scrubber i
(SB-1)
vicinity of active spill area near surface midway
contamination found at the water table interface
discharge pipe to Kiln
just above water table
Scrubber Ponds
• Collect 1 surface water sample from scrubber
• Sample new well at least 2 times
wastewater flow to ponds at distribution box
6
Kiln Scrubber Ponds
None
1 sediment sample
Sample 2 new
2 new monitor
• Install 2 downgradient monitor wells
(from active pond)
wells quarterly
wells (DC-1 and
below ponds - monitor 4 times
for 1 year
DC-2)
• Collect 1 particulate sediment sample
from Active Pond
• Compare analytical results to historical
analyses
2
Butyllithium
None
1 surface water (SW-2)
None
None
• Collect 1 surface water and sediment
• No anticipated Phase 2 activities for this
Spill Impoundment
and 1 sediment
sample from center of impoundment
SWMU group
sample
11
Chemical Plant
None
4 surface water and
Sample 1 new
1 new monitor
• Collect I surface water and corresponding
Water Recycling Lake
4 sediment samples
well quarterly
well (DC-3)
sediment sample at 3 locations within lake
(SW-3, 4, 5 and 6)
for 1 year
(inlet area, center, outlet area)
• Compare analytical results to historical
analyses
• Collect 1 surface water and sediment sample
from head of Western Surface Drainage
Channel (SW-6), perform 2 times
• Install 1 downgradient monitor well
near out et, sample 4 tines
3
Sulfuric Acid
None
None
None
None
• No SWMU specific activity planned. The source
Drainage Pipe
has been removed.
Drain pipe has continuous 300+ gpm flow of
noncontact cooling water leading to lake
(SWAfU I1).

Table 3-4
Environmental Sampling Plan
ring I.D. Location Rationale for
SB-1 SWMU's No.1 and 6 Characterize soil quality near area of active spill.
SB-2 SWMU No.13 Characterize soil quality adjacent to sump.
SB-3,4,5,6,7 SWMU No.15 Characterize soil quality near old bag house.
SB-8 Near Well W-7 Provide site background soil quality data.
Surface Water/
Sediment I.D.
SW-1
SWMU's No.1 and 6
Characterize surface water/sediment quality at scrubber
discharge pipe to active Kiln Scrubber Pond.
SW-2
SWMU No.2
Characterize surface water/sediment quality near center of
Butyllithium Spill Impoundment.
SW-3,4,5
SWMU No.11
Characterize surface water/sediment quality near the inlet,
center and outlet within the Chemical Plant Recycling Lake.
SW-6
SWMU No.11
Characterize surface water/sediment quality from head of
Western Surface Drainage Channel west of SWMU.
SW-7 and 8
SWMU's No.5,10,12
Characterize surface water/sediment quality from Western
Surface Drainage Channel west of SWMUs.
SW-9 and 10
SWMU No.8
Characterize surface water/sediment quality in Eastern
Surface Drainage Channel east of SWMU.
SW-11 and 12
SWMU No.4
Characterize surface water/sediment quality in marsh area
east of SWMU No.4 and in Eastern Surface Drainage Channel
SW-13
SWMU No.7
Characterize surface water/sediment quality in Western
Surface Drainage Channel west of SWMU.
SW-14
Site NPDES Outfall
Verify surface water/sediment quality at most downgradient
site outfall.
Monitor Well I.D.
Location
Rationale for Selection
L-1,2,3,4,5
SWMU No.5
Characterize groundwater quality and provide water table
data in area of Industrial Landfill.
W-1,2,4,8,9,
SWMU No.4
Characterize groundwater quality and provide water table
10,11 and 12
data in area of Bermet Waste Site.
W-3 and 6
SWMU No.8
Characterize aroundwater quality and provide water table
data in Miscellaneous Operations Landfill area.
VV-5
SWMU No.14
Characterize groundwater quality and provide water table
data downgradient of Gaston Co. School Burial Site.
W-7
DC-1
North -central site area
Provide site background water quality water level data.
and 2
SWMU's No.1 and 6
Access shallow aquifer system for water quality and water
DC-3
SWMU
table data downgradient of Kiln Scrubber Ponds.
DC-4
No.11
Access shallow aquifer system for water quality and water
table data downgradient of Chemical Plant Water Recycling
Lake.
DC-5 and 6
SWMU No.5
Access shallow aquifer system for water quality and water
table data on east side of Western Surface Drainage Channel
DC-7,8,9
SWMU No.7
Access shallow aquifer system for water quality and water
table data from one well upgradient(DC-7) and two wells
downgradient (DC-8, 9) of Bessemer City Landfill.
DC-10,11.12
SWMU No.9
Access shallow aquifer system for water quality and water
table data from one well upgradient (DC-10) and two wells
downgradient (DC-11, 12) of Old Bessemer City Landfill.
Note: Landfill wells (L-1 through 5) and wells W-1 through 7 are existing monitor wells
3-10
30956.06209

DIVISION OF.ENVIRONMENTAL MANAGEMENT
August 4, 1993
MEMORANDUM TO: Brian Wagner
FROM: R b KM- bs
THROUGH: Barbara Christianl'T-
SUBJECT: FMC.Corporation-Lithium Division
WQ W 8149/GW N4 93137
The Superfund and Hazardous Waste Sections are currently
involved with a majority of permitted activities at this
location, including the area encompassing the lagoon non -
discharge systems. These lagoons have been in operation for
numerous years and until now have fallen under a NPDES permit for
operation.
. Currently, the plant has submitted a site assessment
proposal to the Hazardous Waste Section that addresses the
installation of three downgradient monitor wells for the lagoon
systems. These wells are labeled DC-1, DC-2., and DC-3 on the
attached site map. The proposed location of the monitor wells
(immediately adjacent to the lagoons) are sufficient for
groundwater monitoring, although they will not meet the guidance
of having wells located at a review boundary. Further, due to
the high hydraulic conductivity of the fill material and
saprolite, I recommend that a liner be installed in each lagoon.
RBK/sc

GROUNDWATER SECTION
DIVISION OF ENVIRONMENTAL MANAGEMENT GW _ >3i3
RECORD OF WASTE DISPOSAL PERMIT APPLICATION REVIEW
REVIEW DATE 8ja�� a FIELD INVESTIGATION? (O/N)1
FACILITY NAME ^tic 4-"p�-^^rro•� —Gi'T.rr�iJ�+ liidiJiv� COUNTY <9�AY,0•J
LOCATION �•7y N `-
TYPE OF DISPOSAL SYSTEM ( LAGOON, ETC.) 6 cs©,J DESIGN CAP. (GPD) AS Zc'o
DESCRIPTION OF FACILITY�� l'���„x .--� �� G��{+'��=�- y �� ��%�✓r P a.�l� s�r� s_�
SIZE OF IMPOUNDMENT (FT. SQ) ` %4o0 & / OR SIZE OF APPLICATION AREA
WASTE SOURCE: ❑MUN. SLUDGE MUN. W. WATER: PRIMARY FJ SECONDARY TERTIARY
F�IND. SLUDGE F-JIND. W. WATER OTHERS
DISTANCE FROM WASTE SOURCE TO NEAREST: STREAM - y00 FT., WELL � S02- FT.
FOR WELL: TYPE OF USE
, DEPTH
,PUMP RATE( EST.)
WHAT DESIGN CONDITIONS WILL REDUCE INCREAS CHANCEOFGW CONTAMINATION:
oe,. j; wiTtf NO . ,—.0CL a -4~.o -1,14 filEAll�.��G
WHAT NATURAL SITE CONDITIONS WILL REDUCE .I CREAS HANCE OF GW CONTAMINATION:
DEPTH TO: BEDROCK ` yn FT. , SEASONAL HIGH W. T. Z S FT: , ANNUAL W. T. FLUX: _FT.
SURFICIAL AQUIFER BEDROCK / ARTESIAN AQUIFER
GEN. LrrHOLOGY
HYD. COND. �� FT./DAY MEASURED jp- FT./DAY El MEASURED
9ESTIMATED ESTIMATED
THICKNESS rye FT.
NO. OF MONITOR WELLS: PROPOSED: UPS_ DOWN :3 : EXISTING: UP I DOWN 0
FROM WORKSHEET: SITE NUMERICAL DESCRIPTION =
T 1 2 3 4 5 6 6A 6B
SITE GRADE (HYDROGEOL.) = L� SITUATION GRADE _
PROPOSED SAMPLING SCHEDULE & PARAMETER(S) : L•r AM-Cz- ID s., Sn .1� Ph,-, C , O
CrC/ Tf*e,,,E //�n , Ike r4,u:a V06 ..S �o:se..�Se._ T.ei-�t.+�iv✓4C,La .Js....�[.�
REMARKS/RECOMMENDATIONS :
GW-48 Revised 8/87
HYD. REGIONAL SUPERVISOR

DIVISION OF ENVIRONMENTAL MANAGEMENT
GROUNDWATER SECTION
.September 3, 1993
MEMORANDUM IL Q Dom; OF NATUxiX
RrAOURCEs AND
COMMMiTY $3r"V1'L0PMrNT
To: Carolyn McCaskill
Through: Bob Cheek SEP 8 3 9993
VISION OF;.pfF
From: Brian Wagner •- VOORESVILLE REG1,04A! OFFo%E
Subject: FMC Corp. -Lithium Division
Lagoon System
Gaston County
WQ0008149/GW93137
( Angela Griffin: DEM SERG Review Engineer)
The Groundwater Section has reviewed the subject permit application. The applicant has
three lagoons that accept wastewater from two sources. One source is a cooling water tower at
7,300 gallons per day into a 4 acre lagoon. The second source is an air scrubber on the exhaust
stack that uses 187,200 gallons per day that empties into two lagoons each 1.1 acres. However,
only one lagoon is in use at a time. The second is drained and sediment removed.
All three lagoons have been in operation for a number of years, but had fallen under the
plant's NPDES permit. The Division of Solid Waste is currently permitting an area of this
property for RCRA cleanup. Another area just off site and downgradient from the lagoons is an
abandoned landfill site.
Due to the nature of the wastewater and the high hydraulic conductivity of the fill
material the site is on, we are recommending that liners be installed in the two lagoons that
handles the scrubber water. This liner can be either a natural liner with hydraulic conductivity
of lx10-6 cm/sec or a reinforced synthetic linear of no less then 30 mil.
. The proposed monitoring wells (DC-1, DC-2, and DC-3) are not located near the review
boundary. The monitor wells should be located at the review boundary. Due to the placement
of the lagoons near the plant and tailings pile, we recommend that the well W-7, used by Solid
Waste as an upgradient well, be used as the upgradient well for this permit.
The Groundwater Section recommends issuance of the permit with the following
conditions:
Within 90 days of permit issuance, three (3) monitor wells, downgradient from the
lagoons, shall be installed to monitor groundwater quality. The well(s) shall be
constructed such that the water level in the well is never above or below the

2
screened (open) portion of the well at any time during the year. The location and
name for each well is marked on Attachment A. Approval to relocate any
monitoring well shall be approved by the Mooresville Regional Office. All
monitoring wells shall be constructed in accordance with the conditions of this
permit.
The three (3) downgradient wells and W-7 shall be sampled initially after
construction and thereafter every April, August, and December for the following
parameters:
Calcium
Aluminum
TDS
Sulfate
pH
Water Level
Chloride
Fluoride
Chromium
Manganese
Iron
Lithium
The measurement of water levels must be made prior to sampling for the remaining
parameters. The depth of water in each well shall be measured from the surveyed
point on the top of the casing.
The measuring points (top of well casing) of all monitoring wells shall be surveyed
to provide relative elevations of the measuring point for each monitoring well.
The results of the sampling and analysis shall be sent to the Groundwater Section,
N.C. Division of Environmental Management P.O. Box 29535 Raleigh, N.C.
27626-0535 on Form GW-59 [Compliance Monitoring Report Form] every May,
September, and January.
3. The two lagoons that accept wastewater from the kiln scrubber shall be installed
with either a natural clay linear (as described below) or a synthetic linear (as
described below) within 180 days of permit issuance.
-For the natural clay liner, it shall be at least one foot in thickness, compacted to
95% proctor standard dry density and installed and compacted in layers no
thicker than six inches, with a hydraulic conductivity of no greater than 1 x
10-6 cm/sec. Following installation and inspection of the lagoon liner, and
prior to waste disposal operations, verification of the liner's compliance with
hydraulic conductivity and thickness specifications must be provided to the
Division of Environmental Management, Groundwater Section, by the project
engineer.
-For the synthetic linear, it shall be at least 30-mils thick and reinforced. It
shall be photo -resistant, as the linear may be exposed during "downtime."
Following installation and inspection of the lagoon liner, and prior to waste
disposal operations, certification of the liner's compliance with approved

construction specifications and the liner's integrity must be provided to the
Division of Environmental Management, Groundwater Section, by the project
engineer.
4. Any groundwater quality monitoring, as deemed necessary by the Division, shall be
provided.
5. All wells that are constructed for purposes of groundwater monitoring shall be
constructed in accordance with 15A NCAC 2C .0108 (Standards of Construction
for Wells Other than Water Supply) and any other state and local laws and
regulations pertaining to well construction.
6. The Mooresville Regional Office, telephone number [phone], shall be
notified at least forty-eight (48) hours prior to the construction of any monitoring
well so that an inspection can be made of the monitoring well location. Such
notification to the regional groundwater supervisor shall be made during the normal
office hours from 8:00 a.m. until 5:00 p.m. on Monday through Friday, excluding
state holidays.
7. Within sixty (60) days of completion of all monitoring wells, the permittee shall
submit two original copies of a scaled topographic map.(scale no greater than
1":100') signed and sealed by a professional engineer or a state licensed land
surveyor that indicates all of the following information:
a. the location and identity of each monitoring well,
b. the location of the waste disposal system,
c. the location of all property boundaries,
d. the latitude and longitude of each monitoring well,
e. the relative elevation of the top of the well casing (which shall be known as
the "measuring point"), and
f. the depth of water below the measuring point at the time the measuring
point is established.
The maps shall be sent to the Groundwater Section, N.C. Division of
Environmental Management P.O. Box 29535 Raleigh, N.C. 27626-0535.
8. Upon completion of all well construction activities, a certification must be received
from a professional engineer certifying that the monitoring wells are located and
constructed in accordance with the Well Construction Standards (15A NCAC 2C)
and this permit. This certification should be submitted with copies of the Well
Completion Form (GW-1) for each well. Mail this certification and the associated
GW-1 forms to the Permits and Compliance Unit, Groundwater Section, P.O. Box
29535, Raleigh, NC, 27626-0535.
9. For the initial sampling of the well as specified elsewhere in the permit, the
permittee shall submit a copy of the GW-1 form with the Compliance Monitoring
Form (GW-59) for that well. Compliance Monitoring Forms that do not include

copies of the GW-1 form will be returned to the permittee without being
processed. Failure to submit these forms as required by this permit may result in
the initiation of enforcement activities pursuant to NC General Statutes 143-215.6.
10. The COMPLIANCE BOUNDARY for the disposal system (see Attachment A) is
specified by regulations in 15A NCAC 2L, Groundwater Classifications and
Standards. The Compliance Boundary is established at either (1) 250 feet from the
waste disposal area, or (2) 50 feet within the property boundary, whichever is
closest to the waste disposal area. An exceedance of Groundwater Quality
Standards at or beyond the Compliance Boundary is subject to immediate
remediation action in addition to the penalty provisions applicable under General
Statute 143-215.6A(a)(1).
Also in accordance with 15A NCAC 2L, a REVIEW BOUNDARY (see
Attachment A) is established around the disposal systems midway between the
Compliance Boundary and the perimeter of the waste disposal area. Any
exceedance of standards at the Review Boundary shall require remediation action
on the part of the permittee.
cc: Barbara -Christian__
Central Files
Permit Files
baw/93137.doc

C3
(Fz)
O �/VPCJSGr�L /)'��Dh1 To p^�y�J
ElLt.0owhs

IMPACT ON DRINKING WATER SUPPLIES
WELLS AFFECTED 1. YES
NUMBER OF WELLS AFFECTED
Well(s) Contaminated: (Users Name)
1,
2.
3.
4.
5.
Circle Appropriate Responses
Lab Samples Taken By:
1. DEM 2. DHS � %spon�ble Party
4. Other 5. None
Samples Taken Include:
1, Groundwate 2, Soil
LOCATION OF INCIDENT
7 1/2 Min. Quad Name
Lam: Deg: Min: Sec:
5 Min, Quad Number
19=: Deg :Min: Secfj
-900
y/
Draw Sketch of Area or Attach Additional Maps
�G
140
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II
11
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POLLUTION INCIDENT/U.S.T. LEAK REPORTING FORM
)epartment of Environment, Health, Natural Resources Confirm, GW Contamination (Y/N)--4_
Incident #
)!vision of Environmental Management Major Soil Contamination (Y/N)
Date Incident Occurred
or Leak Detected S 195'
3ROUNDWATER SECTION
Minor Soil Contaminatin (Y/N)
INCIDENT DESCRIPTION
Incident Location/Name
Ffv\L I,_, riL
Address � . `
1
City/Town i?pS
C� County (
Region
r
jl(�, p11o; t11Q
Briefly Describe Incident
11
l r c0
r fej b U,D rnI\�
go x C-0 o o-A -
POTENTIAL SOURCE OWNER -OPERATOR
Cani-tr_�-; B""'\04`r"
Telephone
Potential Source Owner -Operator
F M C cx- 0 ot�.,
Company
Street Address
Cl ty
County
State
Zip Code
OWNERSHIP
0. N/A 1. Municipal
2. Military 3. Unknown a e 5.Federal
6. County 7. State
OPERATION TYPE
0. N/A 1. Public Service
2. Agricultrural 3. Residential 4. Educational/Relig. 5. Industrial 6. Commercial 7. Mining
POLLUTANTS INVOLVED
MATERIALS INVOLVED
AMOUNT
LOST AMOUNT RECOVERED
la�ciynn ��r•nn
6 ���&e , 71�_S
SOURCE OF POLLUTION
PRIMARY SOURCE OF POLLUTION
PRIMARY POLLUTANT TYPE
LOCATION SETTING
(Select one)
(Select c­)
1. Intentional dump
13. Well 1, Pesticide/herbicide
1. F 1. Residential
2. Pit, pond, lagoon
14. Above -ground 2. Radioactive waste
2. Railroad 2. Industrial
3. Leak -underground
Storage Tank
3, Gasoline/diesel
3. Waterway 3. Urban
4. Spray Irrigation
15. Nonpoint source 4. Heating oil
4, Pipeline 4. Rural
5. Land application
5. Other petroleum prod.
5. Dumpsite
6. Animal feedlot
6. Sewage/septage
6. Highway
7. Source unknown
7. Fertilizers
7. Residence
8. Septic tank
B. Sludge
8. Other
9. Sewer line
olid waste leactiate
10. Stockpile
.eta
Site Priority
11. Landfill
11. Other inorganics
Ranking
�U
12. Spill -surface
12, Other organics
D.E.M. Regional Contact
Sign ur
Date
GW-61 Revised 2/95 v Z

I
/ Il/ pE I x KILN PARTICULATE (APPR01(• 130' ST,,'
SEDTO 352 ! 0-2JH RREESSULT SSA sitI \\\ MISCL A II I 5 1
0 1' 1.6 I V
n�ISWl1)( 220 TO 2'558((P)
- uITHERC� �EME71 DITrr
EB-3 ■ ( `� D I <D.0124 TO 0.?71T) (� ISWW 59) %
1
H �- az..n gYQq I 0.012 TO 0.04761F) 1 I DC_7
T•S T FB e 1 vim'= 270 TO 313(T) T
I -5
N85-37-07V SED-129DO TO 11000 7.7 (T) \ �''---- �� 1l1 E-1p� RI•)SUL
0.0153 TO O.OB3(T) 8 2.6 IL TS .6(F) y, �\ 111 12-74' 34S
(0.017 TO 0.072(F) \ Q ( n <p p� Tpo O.Ot4(7)
7 \ PJH RESULT _ 1�
<8.� TO <l.(XFTi
6.266
_ 0.15 TO 0.41ff1 / � 2 6.8 1 i�
<0.0D3T0 0.0.0 (I
44pD ,:,.� ,KILN � <0.003 TO <0.02ff) \\ E�0' S.6 1 Tjy
1 \ J 65.7 T 0 62 6(F) f 5 rre6l `\ <0.00 TO 0.0?745afF>
1 1
\ Nr \ J a 4, 1 C000, �py
6 TO J.iR) TV \ �L•= . � IQ9 1 SED-MO°241 TO 367
0.36;
\ SED-7 346 TO 370 '^ \\ \ rr 7 �r - \ MIl�. T 1
W�STER
INOUSTR AL LANDFILL ST�q Cp �I 93 9 N
G JN4GE CH %IL IS A16) m D SITE SVAJ n I4) I `
N \ RME5lT� WAS 1
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f1.i1S(F) \ R/ 40'a
582-17 � 99.E
1 \ !
0.097 TO 0.23(T)
O.OSD TO 0.23ff) �� �`� S HT? Sn
_ _ 0.465 TO 4IT , �- �L 'n
0.25 TO 3.7tFI) \
1 _7 Bq 74) pp p pp T P R 2'33'0 y
1 ; i <0.001TT00. 0301(F)
v ppq
0.0676 TO 0.2«T) SANITARY II 141 LiF01 ) L i , �\ <0.08044OTO 0 DOHF) �0'OOSIF) TO <n02
\ c
0.0674 TO 0.076(F) (0.00 TO 0.1.O
I-12 a59.v I <0.0023 TO O.00WFl
rl
0:88391 T8 1.
R,2.20.0y2S1TT�O44
\ m L0.27Jff) I
II pTI TrsiEZOrM •NToIDirn SATER/SEDINENT
LANDFILL c•s suvLE LOCATIONO2F
(LOOM TO 0.D0(T) OS.
\y y�p MONITOR SELL LOCATION
0.0087 TO 0.035(F)
AV SOIL SO RING SANFLE LOCATIOp
% ■Ol SOIL SAS SANFLE LOCATION
O 011(T 1 2 \\ 6 rSOSS WATER/SEOINT SANFLE LOCATION
< 0.007` QNC
I O.ux 0.5o \ , TO KT) $°
b �_6 646 SED-12 323 TO 679 _- IM r•SNE LO•f.E1ENI UNIT
Oahu LDCA IDII
r• TOTAL WT1115
SV2.3 / Irl FIELD FILTERED
A PRELIMINARY ISSUE REF 3/13/95 NAMES DATE MAP AREA I I ENVIRONMENT &
B RE -ISSUE REF 6/29/95 DRAWN: JFM 1/13/95t•Nt-ri7l�IAI°%
CHECKED: " -' Ian I ' INFRASTRUCTURE
DESIGN: RESULTS EXPRESSED IN rrq/L FOR WATER
ENGINEER: Ug/Kq FOR SOIL AND SEDIMENT PROJECT NUMBER 35586.400 DATE 1/13/95
PROJ. MGR. RUST DWG REV. NUMBER
��� FMC Corporation NUMBER FIGURE 6-9 B
SCALE: 1 "=200' CLIENT DWG SHEET NUMBER
NO. REVISIONS MADE CHK DATE Lithium Division NUMBER
___._ :____•_ ;^ I,- nee -1,1, With resnprt to this Droiect and. CAD FILE NAME: 5586FP02
drawings, specifications and other documents preporea Dy ale OrlyDlccln y Tn N; Vh ; ,^ �ii n... -- - n nok- rnrn,,,o t rinhrc inrb i..n Ihp rnnvrinht nr � •-�• ^ •^� •^•
�..,_. __ •,. _.,,�.� .N.. r.. ,.,..., ... �L...II 1... .l ..n.-.n.l 14.n n•�Ih.. n( th �In^ nlc n.i cl�nllr �Int��/n nil

9ggi�pp KILNS,MARLATE ® (AP ROggpp 5130 )
-6 502 / DpE-0N ZJH R7BESIA.T IS *1) \\\ ISMIUYAR ( Q (ap ST C
LL / LT ❑O Be1235 ,' �0 W ❑
Dll�LRE 1Be 3 I
\J ■ l If NI O1 4000 TO WOO � J o •O / �`n
/ / EB-3J • / �1 1
)
■ r 1 naz H ~T� .3 9169 I / 57 TO 02 1 X(IITI fy ®E SELLLR
G EF-B •! - `� I. * 54E4D 1z°107e0r0)sao0(F) 1 ��-- \O �e JC1TfY5 LAMFI) DC_7
BS TO BB /� ` ;EP B6RESULT
3E00 TO 4100 pp
0 1 12-14' F.0
u 1500 TO 2000 1 KILX_�C¢IMBEII 1 EPjH RESULT 1 j (2 TO 4.5
++5 IVpI� �pg0 /
9x3 IS NM6) (2 TO 0.1 1 R;, 65 /
\ if00 TO tM �921.9 \ -
2.4 TO 5.3 It180 TO 250
\ I u 1
d�L �7p �p
1' SED?7 (56 TO. 73 \\; �\ 1160 1 W70 270 TO 18.2
WESTER Ac z \ wuslneoEI.vwo sLL w)
D All,'4GE CH 914 \ OAS ) 11 2q
9>r.♦7 t� BERNE ASTE SIT�Is • 1 \I ) l
\ INDUSTRIAL LANDFILL az9a I TE)T1 _ .
'1 (Sww 05) \\\� 430 TO 400D
40W
•1 �) 4600 TO 0400
\i N &VS1tW
1200 TO VD0 / f- i SED-1665
'
LILL / \•� 4 110 TO 1500
460 TO 650 /
700 TO BBO
/ \ 910T0 1100
1
/ 11-12 ± I Cl TO 2.5
(t6 TO 130
Nr 310 TO iK10
I rk
ti T— SIAWLEELOCA /W WATWSEDINT
IT NNE
h
120 TO t30
1 ('>t�J TO=-2_4� \ I tc-M LANDFILL GAS SaeslC LOCATION
1 \V WJUP NOIITW WELL LOCATION
% .Sp SOIL 80AINNC SAWLE LOCATION
B.S TO 15 2 `\ '1 SOIL GAS SAMPLE LOCATION
��77pp / �3p ��
1 t3b SED-B 1000 /i SED-1T20140TO �� SIB IROCESS IIATCR/S[D VENT SAWLE LOCA71 O1
862.3 \ /� mU-O-i �°AoiiISATh LaiiS i uN1Tlsnul
/
A PRELIMINARY ISSUE REF 3/13/95 'NAMES GATE MAP AREA 11 ENVIRONMENT &
B RE -ISSUE REF 6/29/95 DRAWN: JFM 1/13/95 SULFATE CONCENTRATIONS
CHECKED: INFRASTRUCTURE
DESIGN: RESULTS EXPRESSED IN (DO/L FOR WATER
ENGINEER: U®/Kg FOR SOIL AND SEDIMENT PROJECT NUMBER 35586.400 DATE 1/13/95
PROJ. MGR.: RUST DWG REV. NUMBER
FMC Corporation I NUMBER FIGURE 6-12 B
N0. - REVISIONS MADE CHK DATE SCALE 1 "=200N PAc Lithium DIVISIOn I NLimEaFRDWG SHEET NUMBER
­ _. __ ,,,, ,, .. NL.nr ,Il_,,,.,, _,_ ...... ",r h„ Nti. c... i—, fn. W , n io f — i, #,.­ntc ,.f Ihn < —i— f— .— a 1.1t with recnorl - lhic n iarl —A CAI) FII F NAMP: 55RfiFPOPi

GROUND SURFACE ARR 5 Wl 8729 W2 914.0 W3 875.1 W4 8381 W5 9194 WS
867.4
870.7
847.9
8613 - Bor"
886E 's =
Auger Terrriroted 881-5
Relual _ _ ;tf
8799
1-7i: 8744L-j
864.0
Boring
Terminated
Boring
= Boring
Terminated
= Termimi'd
ORE
EXPLANATION
TAILINGS
SILTY Fine SAND, light tan, very [Dose to firth
-
Penetration Resistance less than or equal to 10 Blows per
---•• . - -
Fool
FILL
Clayey SILT, red, -stiff
//�
Penetration Resistance less than or equal to 20 Blows per
Foot
SA7'POLrE-
SOIL
Fine to Coarse Sandy SILT with gravel size fragments of
weathered rock, micaceous, red brown, tan, and gray, stiff
to hard
. Penetration Resistance less than 100 Blows per Fool
SAPROLITE-
WEATHERED
Silty Fine to Medium SAND with gravel size fragments of
ROCK
rock and weathered rock, tan, brown, and gray, hard
�� M
Penetration Resistance greater than or equal to 100 Blows
per Fool
Rack Cored Sample (Baring W87-Fine-Grained Biolile
BEDROCK
GNEISS with Ouartz-Feldspar Brands or Intrusions, medium
dark gray to light gray, moderately hard to hard, slightly
7- W
Y' �•�•
weathered. Joints and heated loinls are dosed to very close)
spaced. Follialion varies but typically dips about 70 degrees.
Accessory minerals include chlorite, calcite, pyrite, and
homblende _
Water Screen Interval
879.91 Water Level Measured on 2/2aMO
__T__
W7
W8
W9
W10
W11
W12
Ll
L2
943.1
875.5
866.1 866.1
981.3
881-3
934.9
8849
_
927.3
=
E 866.1
= 865.7
=
-
Yy
= 313.6
=
_
_-
Boring
Terminated
903.1
z
Boring
825.1
i
Teminsted
_c'
-
Wash
Brill
-
flclual
fP-_;
_
Wash
Drill
Relual
775-1 L; j
Boring 773.5
Terminated Boring
Terminated
NOTE:
Sections derived from map prepared
by ESI.
813.4
809.7 M
Wash
001 802J
flelval Boring
Terminated
Chu To
Bedrock
8782 l� 875.9 -1 8802 L5
t73.7
'2-9 - 974.6
- s =
837-6
Auger
_ fldual
Auger
Relual
IRS L29
Boring
Terminated
• 0
10
20
30
SCALE: 1 INCH • 15 FEET
GEOLOGIC INFORMATION ADAPTED FROM LAW
ENGINEERING REPORTS OF 615185, 8114/87.9113/88.
AND 7131189.
ALL MONITORING WELLS ARECONSTRUCTEO OF 2 INCH
SCHEDULE 40 PVC PIPE AND 10 FOOT MANUFACTURED
WELL SCREEN WITH 0.010 INCH WIDEUPENING$
8259
Boring
Teminoted
Cloa. To
Bedrock
Of Geologic Information From
DUNK CORPORATION $uutrna.
r-� i &,6inrers,Ceang;sts,B„v;ronm,,,iatsarrtats Existing On -Site Boreholes/Wells
: at..4n rs.a wry,tt.e,wslwS5..PA »RS FMC CORPORATION -LITHIUM DIVISION
DIJNNPhme ]I]/ASaml F.:: 71]/]95 pad
Bessemer City FaSl
PnOJECT NO.: 3112306 DATE 22593 — SCALE: As Note❑ i GURE NO.: 1•4
311234161r

85-37-(
<0.1 TO <0.1
I
6 0.2 TO 02
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-
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.
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i
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yy a .50 9.9
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A
PRELIMINARY ISSUE
REF
3/13/95
NAMES
DATE
AREA -•
B
RE -ISSUE
REF
6/29/95
DRAWN: JFM
1/13/95
-I
ENVIRONMENT &
CHECKED:
C
INFRASTRU(:TJ E
DESIGN:
RESULTS EXPRESSED IN m0/L FOR WATER
EXPRESSED IN L F
ENGINEER:
Ug/Kq FOR SOIL AND SEDIMENT
PROJECT NUMBER 35586.400 DATE 1/13/95
PROJ. MGR.:
FMC Corporation
RUST DWG
NUMBER FIGURE 6-11
REV. NUMBER
g
NO.
REVISIONS
MADE
CHK
DATE
SCALE: 1 Il=too/
���
Lithium Division
CLIENT DWG
NUMBER
SHEET NUMBER
The drawings, specifications and other documents prepared by the Engineer for this project are instruments of the Engineer's service for use solely with respect to this project and. CAD FILE NAME:
5586FP26

-,, 10:35 RUST E 8. I HBG PA 1 717 795 8280 P.02iO4
ENVIRONMENT &
WRASTRUC rM
2 MOrke1 Plaza Way [phone]
Mechaaksbura; PA 17055 (717) 79S4= (PAX)
Test Boring/Well Construction Log
Project: FMC - Water Quality Permit
Boring No. WQ-1
Client . FMC Corporation - Lithium Division
Shcct 1 of 1
Purpose: Monitor Well - Water QualityPermit
Job No. 38632.100
Drilling Contractor. McCall Brothers, Inc. Driller: K. McDonald
Total Depth 53'
Geologist: Jeff Painter
"�t1gTwo mnniv
'�` I a.
Daze Started 12/6/94
Time Log: Begin Finish Depth
Casing
Notes: 2" PVC scrwn
Slot size-0.01"
DaLe Finished 12/6/94
S,W.L.17' TOCIC�L
Bore
Auger.
10.5"
Well
PVC
2"
Elevation TOC
929.91
Surface
927.41
Sampler
Depth
(Fcct)
Sample
Numbers
Blow
Counts
Sample
Recovery
Visual
Dexnpaon
---
--
= -
-'
-
g
Lithologic Description
Notes
10
20
30
40
50
60
t
0-6" Brown topsoil, grass
6"-24' Light brown ore tailings,
silty, damp to [Hoist
wet
24'-53' Silty clay, red, very small
roi-k (quartz and schist)
fragmensts
49.5' Bottom of well
53' Bottom of borehole
Well materials:
PVC Riser-
+1.5'-9.5'
PVC Scrcen-
9.5'-49.5'
Bentonit&Gmur-
0'-6.5'
Bentonite
Sandpack (#3)
7.5'-53'
Bentonite/Grout
Bentonite
� Sandpack
Screened PVC
Soil Classifications:
Ore tailings
Clay

r
..r
r._,.
ENVIRONMENT &
INFRASTRUCTURE
2 Market Plaza way (111)7vs-K(M)I
Mechanicsburg, PA 17055 (717)7y5-s+xtip°Ax1
:�
Test Boring/Ve ;Construction Log
,
i
Project: FMC-RFI
Boring No. DC-2
Client: FMC Corp. Lithium Division
Sheet 1 or I
Purpose: MonitorWells
Job No. 35586
Drilling Contractor :McCall Brothers Inc. Driller: J. Carter
Total Depth 46.0'
Geologist: Jeff Painter
peciticatlons
Tyre Dimneler
Hammer
eigh,: u,s
Date Staved 3/4/94
Time Loa: Begin Finish Depth
Casina
Notes: 2" PVC -
Screen slot size -
01"
Date Finished 3/4/94
Bore
Auger
8.0,,
S.W.L 16.58' TOC/GL
Well
PVC
2"
Elevation TOC
9tv.go
-�+
Surface
gr9,-41-
Samplcr
Depth
(Feet)
Sample
Numbers
Blow
Counts
Sample
Recovery
-
_
_
_
_
=
_
_
_
_
=
_
_
=
-
-
Visual
Descri
Loa
do
Lithologic Description
Notes
-
10
20
30
40
50
60
��
-
=
=
=
=
=
=
=
=
-
=
=
=
=
=
=
0.0" - 6.0" Top soil.
6.0" - 6.0' Light brown, silty ore
tailings, damp.
6.0'- 47.0' Clay - red -brown, silty,
damp, occasional light
grey to olive grey,
severly weathered mica
schist and grayish dark
quartz fragments.
21.0' Cuttings are moist,
slightly darker red,
moisture content
increases slightly with
depth.
36.0' As above, but cuttings
sli�,,htly harder.
37.0' - 47.0' Cuttims soft, damp.
46.0' Bottom of well.
47.0' Bottom of borehole.
Well materials:
PVC Riser -
+1.5' - 17.0'
PVC Screen -
1(O;eO - 46.0'
Bentonite/Grout -
0.0' - 11.0'
Bentonite -
11.0' - 13.0'
Sandpack-
13.0' - 47.0'
Bentonite/Grout
Bentonite
0 Sandpack
Screened PVC

"+ Vl
l�
D C') a
aw' F1
d
�z� F-
4�¢ C
z
wCb
W ENVIRONMENT &
o INFRASTRUCTURE
Test Boring ell Construction Log
1: Ukel P1az-1 way (717)795-K1K11
a tdy'chanicsburp. PA 17055 (717) 795.92X1111'A%)
l;'ect : FMC - RFI
Boring No. DC -I
Pllent : FMC Corp. Lithium Division
sheet I of I
Purpose: MonitorWells
Job No. 35586
Drilling Contractor :McCall Brothers Inc.
Driller : J. Carter
Total Depth 60ff
Geologist:Specifications
Joseph J. Ozog, Jr.
Tyvx Diameter
iamnter
eight:
Date Started 3/3/94
Time Log: Begin Finish - Depth
Casing
Notes: 2" PVC -
Date Finished 3/3/94
Screen slot size -
Borc
Auger
8.0"
01"
S.W.L 15.87' TOC/GL
Well
PVC
�•
r1eva71;onT0CjSurface
Sampler
Depth
Sample
slow
Sample
Visual Log
Lithologic Description
Notes
(Feet)
Numbers
Counts
Recovery
Descri lion
0.0" - 6.0" Brown topsoil.
Well materials:
�2
6.0" - 18.0' Light brown ore tailings
.:
wet, & silty.
PVC Riser -
;�
+2.0' - 29.0'
PVC Screen -
��
29.0' - 59.0'
10
Bentonite/Grout -
%%
0.0' - 23.0'
Bentonite -
;;
23.0' - 25.0'
18.0' - 26.0' Darker brown ore
Sandpack -
25.0' - 59.0'
tailings, wet.
20
30
40
50'
_
_
=
_1.
_
=
_
-
_
-
=
=
=
X-
=
-
=
=
_
=
=
26.0' Groundwater was
encountered.
26.0' - 60.0' Silty clay - natural soil,
orangish-red.
37.0' Silty clay - as above,
but material is softer.
44.0' Silty clay - as above,
material is very soft.
59.0' Bottom of well.
® Bentonite/Grout
Bentonite
0 Sandpack
Screened PVC

A
FMC Corporation
Lithium Division
Highway 161
Box 795
Bessemer City North Carolina 28016
704 868 5300 Fax [phone]
Certified Mail
Return Receipt Requested
March 3, 1998
• J[
3VVlt'�f��'r I'T, rxr,R I. F?
NATUlZA 1, t,_L=S 0U
iNIAR 4 1998
DiVISVI c i TF... ,..z .., ,..�t <.
YEFESVILLE v�l Q�TfWf
+MC
Groundwater Section
NCDENR
919 North Main Street
Mooresville, North Carolina 28115
Subject: Groundwater Monitoring Requirements
Hallman -Beam Mine/Mill, Permit No. 36-01
Fourth Quarter Report, 1997
Dear Mr. Turner,
This letter contains the chemical analysis for our groundwater monitoring program
at the Hallman -Beam Mine under Permit No. 36-01 for fourth quarter 1997, we
have sampled wells #003 and #004 for lead and lithium.
The following table shows all data for this chemical analysis:
WELL #003 WELL #004
Lithium 1.03 mg/I <0.01 mg/I
Lead <0.10 mg/I <0.10 mg/I
Please remember that we have designated well #003 as the well upstream and
well #004 as the well downstream of Tailings Pond "F". Also, I have included
copies of the certificate of analysis from our contracted laboratory.
In reviewing last years reports I would like to make a correction to fourth quarter
1996 report. For well #003 lithium should have been reported as 0.7 mg/I instead
of 0.1 mg/I this was a typographical error. The certificate of analysis was correct
which was attached to this report.
(continued)

If you have any questions please call me at 704-868-7630.
Sincerely,
) - U
JL
Rodney S. Willis
Technical Environmental Contact
Enclosures (2)
cc: NCDENR, Land Quality Section, Morresville

l
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Pace A13alytdral _ Huntersville, NC 26078
Tel: [phone]
Fax: [phone]
March 02, 1998
Mr. Rodney Willis
FMC Corporation — Lithium Division
P.O. Box 795
Bessemer City, NC 28016
RE: PACE Project No. 671117.505
Client Reference: Monitor Wells
Dear Mr. Willis:
Enclosed is the report of laboratory analyses for samples received
November 17, 1997.
Footnotes are given at the end of the report.
If you have any questions concerning this report, please feel free
to contact us.
Sincerely,
�r Kelly H. Wallace
Project Manager
Enclosures
I b any CertificAtion IN I aharalory CartfBcsNon IDs
Le Wastewater 2 KY Drinking water 900M
NNO O Drinking Water 1REPORT OF LABORATORY ANALYSIS TN UST List
so 9KO6 This report shall not be reproduced, except in full, VA Drinking water 213
without the written consent of Pace Analytical Services, Inc.

Pace Analytical Services, Inc.
9800 MneW Avenue, Sub 100
P X 01 Huntersvllle, NC 28078
Tel: [phone]
Fax [phone]
FMC Corporation - Lithium Division
P.O. Box 795
Bessemer City, NC 28016
Attn: Mr. Rodney Willis
Client Reference: Monitor Wells
PACE Sample Number:
Date Collected:
Date Received:
Client Sample ID:
Param2tPr
March 02. 1998
PACE Project Number: 671117505
92 0236718
11/17/97
11/17/97
jlnits PRL Well 003gn4nn 11ATF ANALYZED
INDIVIDUAL PARAMETERS
Lead mglL 0.10 ND 200.7
Lithium mg/L 0.0100 1.03 6010A
PACE Sample Number:
Date Collected:
Date Received:
Client Sample 1D:
INDIVIDUAL PARAMETERS
.Lead
Lithium
Th se data have been reviewed
I
fSiMrust.
Margaret S. Harding
Manager, Laboratory Operations
1zrtffirgfion IDs
NO wastewater 12 REPORT OF LABORATORY ANALYSIS
NO Drinking Warr 3770e
so 99008 This report shall not be reproduced, except In full,
without the written consent of Pace Analyucal-WACes, Inc.
92 0236726
11/21/97
11/23/97
11/17/97
11/17/97
Well 004
Units PRL MFIHM_ DATF ANALYZED
mg/L 0.10 ND
mg/L 0.0100 ND
and are approved for release.
200.7 11/21/97
6010A 11/23/97
KY Drinking Water 90020
TN UST ust
VA Drinking Water 213

} Pace Analytical Services. Inc.
9200 Kincey Avenue, Suite 100
Pace
Q nalu t"raa l Huntersyille. NG 28078
Tel: 704-67SA092
Fax [phone]
Mr. Rodney Willis FOOTNOTES
Page 2 - for page 1
Client Reference: Monitor Wells
ND
PRL
Not detected at or above the PRL.
PACE Reporting Limit
Laboratory CertificatlorilDS
NC wastewater 12
NG Drinking Water 37706
SC 99006
March 02, 1998
PACE Project Number: 671117505
REPORT OF LABORATORY ANALYSIS
This report sh II not be reproduced, except in full,
without the written onsenl of Pace Analytical Servioe8, Inc.
1 abormfy CertiScatton 1Ds
KY Drinking Water 80090
TN UST List
VA Drinking Water 213

CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Dear
A review of the
shows that the
You must submit the
time) within
(FORM23.GW) OVERDUE.GW
11/94
DIVISION OF ENVIRONMENTAL MANAGEMENT
Date:
RE: Overdue Notice
County, N.C.
incident file,
was due on
and has not been received. (OPTIONAL)
(or request additional
days of receipt of this letter.
Your failure to respond within the time specified and to
voluntarily achieve compliance (may result/has resulted) in a
recommendation from the Mooresville Office to the Director of the
Division for the assessment of civil penalties in accordance with
G.S. 143-215.6A(.) (Use only with "may result") or in a request to
the Attorney General to institute an action for injunctive relief.
Until such time that the above requested information is received in
this Office, you will remain in violation of North Carolina law.
You should note that any enforcement action, including assessment
of civil penalties, may begin from the original due date
established in the , 199 Notice.
Your questions should be directed to or me
in the Mooresville Regional Office at [phone].
Sincerely,
B. Keith Overcash, P.E.
Regional Supervisor

f l.�/ 1 •� , "% it /
i�anl ine� ,1
\ is y ' •'� Y^ / '`I _� ,1�1V•�—'1
Site Location
vw�
12
-= _-f�
j-=—=
AC Property
Boundary
NOTE: Map Derived From U.S.G.S. 7.5 Minute
11 l Topo. Quad. Bessemer City, N.C.
6 O
go Y, � tS
o DUNN CORPORATION Site Location Map
Engineers, Geologists, Environmental Scientists FMC CORPORATION-LTITEUM DIVISION
L T �JV 2 Market Plaza Way, Mechanicsburg, PA 17055
D U1 V 1 Phone: [phone] Fax: [phone] Bessemer City Facility
PROJECT NO.: 31123-06194 DATE: 2/25/93 SCALE: 1 "=20o0' FIGURE NO.: 1.1
31123-061-04

4eyfC4 cjjyp41615o
s
4 p-f/vim i r
a_% KILN PARTICULATE TO OC-4 11
1.3(T> I! SCRUBBER � (�PROX. 130' /
SED-B 352 DEPTH RESULT (SVIII) \\ MISC. Or Rl, I S STE ./
0-2 240 f \ LANDFILL U8R G C l
S / 8-10' ..8 I �L_ prT SYIU I
THEN€ RESIN // 0 ❑ I
(SP AL AR; A 1 '� 210 TO 2311, , O
aynu 220 TO 25B(F) /I '�
r D ° 1 �SB2, ORTHERN BE SE Eft CITY/
3 I` 974Z �- 9zy3 91&9 I / <0.0124 TO 0.'f4(T) t'� LANDFILL
l 0D-37 SED-121x)0 TO 11000 DC-7 EB 9 270 TO 313(T) . 1 c 0.012 TO 0.0478(F) 1 _ ISYW 99)
NB5-07N - / 1 \ /�' I
0.0153 TO 0. 3(T) 8 2.6 _ ;E�' ZIjSULT /
<0.017 TO 0.072(F) // 7.7 TO 12(T) \ O -� y� 4 Il
`.) I I II 1B2-1 �' 34.5 '
0:15 TO 3.1F) \_ (/ � 1, n (0.001 TO 0(I.D( )
0.15 TO 0.41(Fl / \ DEPTFI RESULT 1• <0.002 TO <1.0(� f
! 9D9.3 <11003TO 0.02B(T) \ 0-2 8.6
1 J 4 0 SSR) ILN D SBBER <O.OD3 TO <0.02IF) 1 { I 'I
55.7 TO 62.6IF) IS ) 1
<0.002 TO 0.024(T)
- 1 1` (0.002 TO 0.011D(f)
0.388 TO 3.IR) n1 1\\ , vu. 1 / ppck \ 1 T
1!/ SFD-7 348 TO 370 ;� \\ •' 915.0 1\ Sm-10O2414TO 387 1 \ I q( 1
V E•STER ,\\ , \ v �2 I \ ul q RATIONS AwF I 1 1 •2 B 1 J;
G w!r GE Cti }' 1)DUSTS AL 45)IDFILL \\ ll • 191 'k l J /
1 ( e \ ram• �r1,.
4 a34.e /SplOd tILRI
\ SITE ISYW r 141 /r9
y 909.G vw.e \ 9ee.a Si
YAS
0.013 O 0.42(T7 SITE L-6 O.1B4 TO 4.2(T)
1� ti 0.013 TO 0.115(Fr) (SMU tot)
0.02DT0 0.542ff)
\ \ AAll O.OD7 O 0.20 T3IT) \ / \\ I A EB2-�'a
-•1 \ 1 0.059 TO 0.23(F) \ • / �\ / f` 7 // 99
0.4565 TO 4(T7 ' 0.5(T) •r"
1 \ 931.3 +��'�•- G•))y, W\ 0.23 TO ]. (FI / E-R rr SED-R 511
\` L-A/00 T O0.001( TT))
<0.00
i
r`} •I
I O0..O0B87)84 TTOD 0.2SANITARY LANDF L < S•0 �(TO 0.2(T
0.01Sx11 #127 F) TO l02781E c /
<0.00 TO 0.001(F) _7
t /
T ` r 1 z K LS.. I °o°.00z3 °ro°'i ooxr� /
< 0 003fF1 TO < 1 22yy
°• 0.02DTTL O 0.273(F) I IELEdQ
II \ T\\10N I ICTER R�S-AG/ YATER/EOIIENi
0.008E TO .2(T) 0TO O.19 T) AAv
00087 O 0035<6.ITO 0.0 5 (F a-WLANDFILL GAS LAPLE LOCATION
(ram( 11�1P "ITOR YELL LOCATION
SOIL /dn NG SAIPLC LOCATION
LLL /
/I < pp} TD O.fl(T7 2 \ / ® SOIL GAS SAIPLE LOCATION
/ b . SED�8 548 <5.001 TO o.02D(F) \ /
1 SL7 PROCCSS YAiCR/SED VENT $uPLC LOC1i1W
SED 12 323 TO 979 o
\\ / SAID VASTF NµaGE1ENT UNIT
1 862.3 ' �__� IAP1 IIIIATC IOCAT IONI
1 / \ 1T1 TOTAL MATRIX
A PRELIMINARY ISSUE IFI FIELD FILTERED
RE -ISSUE
REF 3/13/95 NAMES DATE MAP AREA II
B REF 6/29/95 DRAWN: JFM 1/13/95 -LITHIUM CONCENTRATIONS ENVIRONMENT
CHECKED: cXNFRASTRUCTURE
_ DESIGN: RESULTS EXPRESSED IN ma/L FOR WATER ffiff
ENGINEER: Up/K9 FOR SOIL AND SEDIME14T PROJECT NUMBER 35586.400
- DATE 1/13/95
PROJ. MGR.: uFM� RUST DWG REV. NUMBER
FMC Corporation NUMBER FIGURE 6-9 B
NO. REVISIONS MADE CHK DATE SCALE( 1 "=200' Lithium Division CLIENT DWG SHEET NUMBER
NUMBER
the drawings, specifications and other documents prepared by the Engineer for this project pre instruments of the Engineer's service for use solely with respect to this project and, CAD FILE_ NAME: 5586FP02
.' ". ••' 'I• r.. ,. I, .Ii I.., 1:., •„n:l Il,n n"Il,..r n! Il,ncn 'hall, nnrl all. r.l� nllr
1' I ,�",•r. "` ^^^^'^.• r., .,. ,nonn.arl rinhtc inrinrf. ., Ih:• rnncrir.hl . 7 ..� ..,-

DIVISION OF ENVIRONMENTAL MANAGEMENT
GROUNDWATER SECTION
January 3, 1995
MEMORANDUM
TO: Carolyn McCaskill
THROUGH: Bob Cheek �1 15 C
FROM: Brian Wagner.9'�-
SUBJECT: Permit Modification for:
FMC/Lithium Division
Gaston County
WQ0008149/GW94251
N.C. DEPT. OF
ENVIRONMENT, HEALTI=r",
& NATURAL RESOURCES
JAN 17 1995
DIVISIO11 OF E11VIR0111,1E1ITAL fiARAGEMENT
MOORESVILLE REGIONAL' OFFICE
The Groundwater Section has reviewed the subject permit modification request. To
better evaluate groundwater quality with only one well, we have decided to move the location of
WQ-1 more to the East and between the lagoons (see Attachment A). I have been in contact with
Barbara Ritchie of FMC and she has agreed to this new location. We recommend reissuance of
the permit with the following items to replace the permitted conditions:
20. Within 90 days of the initial sampling of wells DC-1 and DC-2, one (1)
downgradient monitor well shall be constructed such that the water level in the well
is never above of below the screened (open) portion of the well at any time during
the year. The general location and name for each well is marked on Attachment A.
Each monitoring well shall be located at the review boundary, constructed in
accordance with this permit, and approved by the Mooresville Regional Office.
21. Monitor wells WQ-1 and W-7 shall be identified for purposes of this permit as
11WQ-1 ", and "WQ-2" AKA W-7. Monitor well WQ-1 shall be sampled initially
after construction. Monitor wells WQ-1 and WQ-2 shall be sampled every April,
August, and December for the following parameters:
Calcium
Aluminum*
TDS
Sulfate
pH-
Water Level
Chloride
Fluoride
Chromium*
Manganese*
Iron*
Lithium*
* use method 3030C, preparation for metals, in Standards Methods, 17th edition

The measurement of water levels must be made prior to sampling for the remaining
parameters. The depth to water in each well shall be measured from the surveyed
point on the top of the casing.
The measuring points (top of well casing) of all monitoring wells shall be surveyed
to provide the relative elevation of the measuring point for each monitoring well.
The results of the sampling and analysis shall be sent to the Groundwater Section,
Permits and Compliance Unit, P.O. Box 29535 Raleigh, N.C. 27626-0535 on Form
GW-59 [Compliance Monitoring Report Form] every May, September, and
January.
All other conditions should remain as permitted.
cc: `-UB'ar-tiara-Christian=
Central Files
Permit Files
baw/94251.doc

0
Spud �'� �•
.M Obi
bM
GSSoJ�'Ue1
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f,rca�►,3
t•''� G�
moo,<I.A a ..�,y�; y�• di,-).

•: • .•: is n ds i�IN
r..• i i� F-,V Iva Mwja •:
r
N.C. DEPT. OF
ECdVIRONMENT, HEALTH,
& NATURAL RESOURCES
DEC 14 1994
DIVISIOII Of EgIROVERTAL (iMAUGMENT
In054ESVILLE REGIONAL OFFICE
DATE: .O'ec •-5-, If
FRCM: Jack Floyd-4Z-
SUBJECT: Application for i/ PMMML/AMRZMENr of Permit No. (,J ,`%
i.Qa. * 3: wM�
Facility Name: AM C - l: >'V :u �, .�%'✓: s vn
county:
Type of Project: M-CVC/n lagoon
Central Office Contact:
Applicable Permit Numbers: ItQ GW 4?V2-T/
DEH AC
EPA
The Groundwater Section has received a copy of the above referenced
permit application. A copy of the application package is attached.
The Groundwater Section has received a copy of the above referenced
permit application, which has been sent to the regional office water
quality supervisor. If a copy has not been sent to the regional
office please let me know.
The Groundwater Section has received the subject Division of
Environmental Health project for review. A copy of the application
has been forwarded to , Regional Soil
Specialist. Please coordinate your review with the regional soil
specialist.
Please review the application materials for completeness and submit
any request for additional information to the central office contact on
or before 'a C -.? o A copy of the formal request for
additional information will be forwarded to you.
If you do not require any additional information to complete your review,
please provide your final comments by
If you have any questions, please let me know as soon as possible.

FMC Corporation
Lithium Division
Highway 161
Box 795
Bessemer City North Carolina 28016
704 868 5300 Fax [phone]
Via Federal Express
November 28, 1994
State of North Carolina
Department of Environmental Management
Water Quality Section
P.O. Box 29535
Raleigh, NC 27626-0535
Attn: Ms. Colleen Sullins, Supervisor
Permits and Engineering
N.C. DEPT. OF
ENVIRONMENT, HEAL,`
& NATURAL PEBOURG
DEC 14 1994
Divisin Or MI'lRONMENTAE @tARAGEtIENT
MOORESVILLE REGIONAL OFFICE
Re: FMC Corporation - Lithium Division
Bessemer City - Non -Discharge Permit No. WQ0008149
Permit Modification Application
Dear Ms. Sullins:
FMC Corporation's Lithium Division facility in Bessemer City
("FMC") was issued Non -Discharge Permit No. WQ0008149 on June 14,
1994 for the operation of its kiln scrubber water recycle system,
including two 1.1 acre recycle ponds ("kiln ponds"). Condition
No. 20 in this permit required that FMC sample two previously
existing groundwater monitor wells, DC-1 and DC-2, for parameters
_ specified in the non -discharge permit. (Wells DC-1 and DC-2 had
been installed to investigate the kiln ponds, pursuant to a RCRA
�- Facility Investigation underway at the FMC facility.) FMC
sampled these wells and reported the results to North Carolina
Department of Environmental Management ("DEM") in accordance with
r permit No. WQ0008149 on October 13, 1994. Condition 20(c) of
permit No. WQ0008149 includes provisions that if exceedences of
the groundwater quality standards at 15A NCAC 2L .0202(g) are
detected in wells DC-1 and/or DC-2, then two additional
groundwater wells shall be installed at the "review boundary" as.
defined at 15A NCAC 2L .0108.
Concurrent with FMC's submission of the results of sampling wells
DC-1 and DC-2, FMC also advised DEM that, while the installation
of an additional well downgradient of well No. DC-1 and the
western kiln pond appears to be warrented, it is unclear that
well No. DC-2 reflects any impact by the eastern kiln pond. FMC
included the following discussion in its October 13 letter:

Colleen Sullins
Discharge permit No.
November 28, 1994 - Page
WQ0008149
2
"The results of DC-2, however, show exceedences of the
.0202(g) standards for only three parameters: pH, manganese,
and iron ... FMC thus believes that the pH observed in well
DC-2 is reflective of background condition, and that the
manganese and iron values may likely also reflect background
conditions. Thus, FMC requests that DEM approve the
following course of action which FMC proposes with respect
to well DC-2 and the eastern kiln scrubber recycle pond:
FMC proposes to arrange to have upgradient well W-7
sampled within the next thirty days (by November 13) and
analyzed for pH, Iron and Manganese with the methodology
required under permit No. WQ0008149. These results will
be submitted to DEM within 30 days of sampling, by
December 13th. If the levels of iron and manganese
observed in well W-7 approximate those observed in well
DC-2, then FMC would not be required to install'an
additional well downgradient of the eastern kiln scrubber
recycle pond."
FMC has sampled upgradient well W-7 and is here providing a copy
of the laboratory report. The following table summarizes the
September 1994 DC-1 and DC-2 monitoring results for permit no.
WQ0008149 parameters and the November 1994 sampling of W-7, where
a standard has been promulgated at 15A NCAC .0202; all values are
shown in mg/l, except pH:
DC-1
TD S
pH
14.9
Chloride
_
(280 1
Sulfate
1200
Fluoride
1_13.
Chromium
0.09251
Iron
Manganese
f53.7
DC-2
W-7
2L Std(1)
ND
--
500
6.5-8.5
2.7 ------ -----
--- --
250
4.4
--
250
ND
--
2
0.0106
--
0.05 (2)
5.6
2.5
0.3
^0.650 00.048
----
0.05
(1) Standard from 15A 2L .0202(g) for "GA" class groundwaters.
(2) National Primary Drinking Water Standard has been changed
from 0.05 mg/l to 0.10 (see 40 CFR Part 141).

Colleen Sullins
Discharge permit No.
November 28, 1994 - Page
WQ0008149
3
FMC believes that while the values observed for pH, iron, and
manganese in well DC-2 do not duplicate those in W-7, they may
generally approximate background conditions and further
assessment is difficult based on the existence of only one data
point. Moreover, as FMC's kiln scrubber water contains
fluorides, and as no fluorides were detected in DC-2, FMC
believes that these data do not support additional investigation
of the eastern kiln pond pursuant to the non -discharge permit.
FMC has contacted Mr. Brian Wagner, DEM Groundwater Section, by
telephone and discussed these results and FMC's evaluation.
It was agreed that FMC would request a modification of
non -discharge permit No. WQ0008149 to eliminate the requirement
to install another well downgradient of the eastern kiln pond
and, rather, better characterize existing conditions by
continuing to monitor wells DC-2 and W-7 for at least one year.
Additionally, Mr. Wagner informed FMC of DEM's new computer
system to track groundwater monitoring results and the
limitations on well identification numbers inherent in the
programming.
Thus, FMC is requesting that DEM modify non -discharge permit No.
WQ0008149 to reflect the following conditions.
Item 20(C) should be modified to state:
"Within 90 days of the initial sampling of wells DC-1 and DC-2, a
downgradient monitor well (WQ-1) shall be constructed such that
the water level in the well is never above or below the screened
(open) portion .of the well at any time during the year. The
general location and name for the well is marked on Attachment A.
Each monitoring well shall be constructed in accordance with this
permit, and approved by the Mooresville Regional Office.
Item 21 should be modified to state:
"Monitor wells WQ-1, DC-2, and W-7 shall be identified for
purposes of this permit as "WQ-1", "WQ-2 AKA DC-2", and "WQ-3 AKA
W-711. Monitor well WQ-1 shall be sampled initially after
construction. Monitor well WQ-1, WQ-2 and WQ-3 shall be sampled
every April, August, and December for the following parameters:

Colleen Sullins
Discharge permit No. WQ0008149
November 28, 1994 - Page 4
The map included as Attachment A has been revised an is attached.
FMC has included the permit modification processing fee of
$400.00; a check is enclosed.
Lastly, FMC requests that this permit modification be processed
as soon as possible but no later than January 7, 1995, the date
when the current permit would appear to require installation of
two downgradient monitor wells.
Thank you for your prompt attention to and cooperation in this
matter. If you have any questions, or require additional
information, please contact me at 704/868-0806.
V y truly yours,
Barbara E itchie
Environm ntal Manager
cc: Mr. Brian Wagner
DEHNR - Groundwater Section
512 North Salisbury Street
Raleigh, NC 27604

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November 18, 1994
Ms. Barbara Ritchie, Environmental Manager
FMC Corporation - Lithium Division
Highway 161
P.O. Box 795
Bessemer City, NC 28016
post -It" brand fax transmittal memo 70
Fof p ses . %4
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Re: Water Quality Permit No.WQ0008149
Analytical Results - Monitor Well W-7
Dear Barbara:
Attached please find analytical results from the recent sampling of (background) monitor well W-
7. Also included are a log sheet summarizing field parameters, and the Chain of Custody (COC)
record that accompanied the water samples, which were submitted to MA laboratory for analysis.
Please note that when I had arranged for ]EA to ship bottles to the site, I had infomred Ms. Becky
Teisman that the iron and manganese sample was to be analyzed using Method 3030C (as specified
in the water quality permit). She recorded this request in their computer system and indicated that
the samples would be analyzed accordingly upon receipt, She had also asked that our field
personnel note this on the COC just as an additional reminder. This was not indicated on the COC
that was submitted, and I recently learned that IEA analyzed the samples one day beyond the three-
day retention time.
I compared the results of well W-7 with data from wells DC-1 and DC-2 as well as historical data
for iron and manganese, However, there are few historical data available for a reasonable
comparison except for results of kiln pond water analyses. These data were presented in our RE
Work Plan. I discussed the results of well and kiln pond water analyses with one of our chemists,
Mr. Tim Fahrenkopf, and it was his opinion that the results of the W-7 sample would not be
significantly different were the sample analyzed within the three-day retention time. Therefore, it
appears that the Mn concentration in well W-7 is below the 2L Standard of 0.05 mg/1, one order of
magnitude less than well DC-2 and three orders of magnitude less than DC-1.
If you have any questions or need additional information please contact Gerry Ahnell or me.
sincerely,
Jeffrey J. Painter, P.G.
Project Hydrogeologist

03: 27PM RUST E&I HBG PA P. Fw""-
tndnstrial a Enviroumental Analysts, Inc. (ISA)
.L&A rrv�.o� WO 1900-030
WA sample ft 9411068-01 matrix: Water
client Name: RUST 8nv. 4 Infra. Date neceived:11/03/94
Client praj. =.D.:35586.690 FRC Corp -Lithium Date sampled: 11/82/94
Sample t.D.1 VXC (W-7)
Quanti'tation
Date
Date
Farameter method
Limits
Results
prepared
Analysed
Analyst
S'PA 200.7
0.10 mg/L
3.5 mg/L 11/07/962
11/11/94
tw
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0.015 mtg/L
0.148 mg/L
11/07/94*
11/11/94
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9.1
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N/A
11/04/94
PC
Comments:
*Preparation date exceeded the protaeol bolding time specified by the method.
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North Carolina
vent of Environment,
ind Natural Resources
:)f Environmental Management
Hunt, Jr., Governor
WWI IGi Li IG.1 i B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
June 14, 1994
CERTIFIED MAIL
RETURN RECEIPT REQUESTED.
Mr. J. E. McLeod, Plant Manager
FMC Corporation/ Lithium Division
Post Office Box 795
Bessemer City, North Carolina 28016
Dear Mr. McLeod:
QT
Kim
[DEHNR
Subject: Permit No. WQ0008149
FMC Corporation/ Lithium Division
Wastewater Recycle System
Gaston County
In accordance with your comments dated May 2, 1994 in reference to the April 11, 1994 draft
permit we are forwarding herewith Permit No. WQ0008149, to FMC Corporation/ Lithium Division. The
objections expressed in your May 2, 1994 letter and the Divisions position on those concerns are
discussed below:
Objection 1: FMC seeks further clarification of the key term "waste" as it pertains to it's
operation to better allow for continued compliance with applicable laws and
regulations.
Response 1: The North Carolina General Statute siting which specifies that air pollution control
systems are regulated and permitted under 15A NCAC 2H .0200 is found in
sections 143-215.1 (a)(2) which define activities for which a permit is required.
This citing states that if a person constructs or operates any sewer system,
"treatment works", or disposal system within the state a permit is required.
Furthermore, 143-213(17) defines a "treatment works" as any plant, septic
tank, disposal field, lagoon, pumping station, construction drainage ditch or surface
water intercepting ditch, incinerator, area devoted to sanitary landfill, or other
works not specifically mentioned herein, installed for the purpose of treating,
equalizing, neutralizing, stabilizing or disposing of "waste". Whereas, 143-
213(18b) defines "industrial waste" as any liquid, solid, gaseous, or .other
waste substance or a combination thereof resulting from any process on industry,
manufacture, trade or business, or from the development of any natural source.
Based on the interpretation of these Statues, it has been determined that the
"waste" from this operation is the liquid stream being treated by settling out of
solids and recycled back into the process Therefore, FMC Corporation's kiln
scrubber operation does meet the criteria of a treatment works generating a waste,
therefore, requiring a permit under North Carolina General Statute.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

McLeod
Permit No. WQ0008149
June 14, 1994
Objection 2: FMC requests that the description of the permitted system be modified to include,
"scrubber water processing tanks" as opposed to, "a scrubber makeup tank (water)"
as indicated in the November 29, 1993 and April 11, 1994 draft permit.
Response 2: The modification to the description is granted and reflected under the description
portion of this permit.
Objection 3: FMC believes that the issuance and expiration dates for this permit should be
revised to reflect the (future) date of resolution of FMC's petition for contested case
hearing.
Response 3: The issue date will be based on the date of resolution between FMC and the
Division. The expiration date of the permit will be five (5) years following
issuance.
Objection 4: The correct number of lagoons referenced on page 2, Item 10 should now be two
(2) since the R&D pond has been removed from the permit.
Response 4: This has been modified.
Objection 5: FMC has objection to the Groundwater Comments listed as items 20 thru 27 of the
April 11, 1994 draft permit.
Response 5: Based upon FMC's review of the Groundwater Comments faxed to FMC on May
17, 1994 and a response to those comments received May 24, 1994, the
Groundwater comments have been modified as agreed upon.
Objection 6: FMC requests that it be notified of the classification of the facility by the
Certification Commission and be granted a sufficient time period to locate a certified
wastewater treatment operator.
Response 6: Once the permit is issued, the Certification Commission will notify you of the class
of the facility and will require a wastewater operator. The facility classification will
be a Grade I. If FMC already has a Grade I wastewater operator onsite, that person
will suffice for this operation also. Further clarification can be obtained from the
Training and Certification Unit, telephone [phone].
All issues specified in the adjudication request and May 2, 1994 letter have been addressed
accordingly and a draft permit was sent on June 2, 1994. No further comments were received by the
Division, and on June 6, 1994, the Division verified with Ms. Barbara Ritchie of your office that the draft
permit was acceptable. Therefore, this permit is final and binding.
This permit shall be effective from the date of issuance until May 31, 1999, and shall void Pemit
No. WQ0008149 issued November 29, 1993, and shall be subject to the conditions and limitation as
specified therein. Please pay particular attention to the monitoring and reporting requirements contained in
this permit. Failure to establish an adequate system for collecting and maintaining the required operational
information will result in future compliance problems.

eod
o. W Q0008149
1994
,oti need additional information concerning this matter, please contact Ms. Angela Y. Griffin at
,083.
Sincerely,
4r&estjon/1oward, Jr., P.E.
cc: Mooresville Regional Office, Water Quality Section
Mooresville Regional Office, Groundwater Section
Ms. Betsy Mosely, Attorney General's Office
Dave Goodrich, NPDES Group

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION -
ARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
RALEIGH
RECYCLE SYSTEM PERMIT
In accordance with the provisions of Article 21 of Chapter 143, General Statutes of North Carolina
as amended, and other applicable Laws, Rules, and Regulations
PERMISSION IS HEREBY GRANTED TO
FMC Corporation/ Lithium Division
Gaston County
operation of a 187,200 GPD wastewater recycle system consisting of two (2) parallel scrubbing towers, a
scrubber surge tank, scrubber water processing tanks, and two (2) 1.1 acre kiln ponds that are capable of
removing solids collected by scrubbers on kiln dust exhaust stacks to serve FMC Corporation/ Lithium
Division with no discharge of wastes to the surface waters, pursuant to the application received July 9,
1993 and in conformity with the project plan, specifications, and other supporting data subsequently filed
and approved by the Department of Environment, Health and Natural Resources and considered a part of
this permit.
This permit shall void Permit No. WQ0008149 issued November 29, 1993 and shall be effective
from the date of issuance until May 31, 1999, and shall be subject to the following specified conditions
and limitations:
1. This permit shall become voidable unless the facilities are constructed in accordance with
the conditions of this permit, the approved plans, specifications, and other supporting data.
2. This permit is effective only with respect to the nature and volume of wastes described in
the application and other supporting data.
3. The facilities shall be properly maintained and operated at all times.
4. This permit is not transferable. In the event there is a desire for the facilities to change
ownership, or there is a name change of the Permittee, a formal permit request must be
submitted to the Division of Environmental Management accompanied by an application
fee, documentation from the parties involved, and other supporting materials as may be
appropriate. The approval of the request will be considered on its merits and may or may
not be approved.
5. In the event that the facilities fail to perform satisfactorily, including the creation of
nuisance conditions, the Permittee shall take immediate corrective action, including those as
may be required by this Division, such as the construction of additional or replacement
wastewater treatment or disposal facilities.

The sludge generated from these treatment facilities must be disposed of in accordance with
General Statute 443-215.1 and in a manner approved by the North Carolina Division of
Environmental Management.
The issuance of this permit shall not relieve the Permittee of the responsibility for damages
to surface or groundwaters resulting from the operation of this facility.
8. The facilities shall be effectively maintained and operated as a non -discharge system to
prevent the discharge of any wastewater resulting from the operation of this facility.
9. Diversion or bypassing of untreated wastewater from the treatment facilities is prohibited.
10. Freeboard in the two (2) lagoons shall not be less. than two feet at any time.
11. Any monitoring deemed necessary by the Division of Environmental Management to insure
surface and ground water protection will be established and an acceptable sampling
reporting schedule shall be followed.
12. Adequate inspection, maintenance, and cleaning shall be provided by the Permittee to
insure proper operation of the subject facilities.
13. The Permittee or his designee shall inspect the wastewater recycle facilities to prevent
malfunctions and deterioration, operator errors and discharges which may cause or lead to
the release of wastes to the environment, a threat to human health, or a nuisance. The
Permittee shall keep an inspection log or summary including at least the date and time of
inspection, observations made, and any maintenance, repairs, or corrective actions taken
by the Permittee. This log of inspections shall be maintained by the Permittee for a period
of three years from the date of the inspection and shall be made available upon request to
the Division of Environmental Management or other permitting authority.
14. Any duly authorized officer, employee, or representative of the Division of Environmental
Management may, upon presentation of credentials, enter and inspect any property,
premises or place on or related to the recycle. system at any reasonable time for the purpose
of determining compliance with this permit; may inspect or copy any records that must be
kept under the terms and conditions of this permit; or may obtain samples of groundwater,
surface water, or leachate.
15. The annual administering and compliance fee must be paid by the Permittee within thirty
(30) days after being billed by the Division. Failure to pay the fee accordingly may cause
the Division to initiate action to revoke this permit as specified by 15 NCAC 2H .0205
(c)(4)•
16. Failure to abide by the conditions and limitations contained in this permit may subject the
Permittee to an enforcement action by the Division of Environmental Management in
accordance with North Carolina General Statute 143-215.6A to 143-215.6C.
17. The issuance of this permit does not preclude the Permittee from complying with any and
all statutes, rules, regulations, or ordinances which may be imposed by other government
agencies (local, state, and federal) which have jurisdiction.
18. A set of approved plans and specifications for the subject project must be retained by the
Permittee for the life of this project.
2

Noncompliance Notification:
The Permittee shall report by telephone to the Mooresville Regional Office, telephone
number [phone], as soon as possible, but in no case more than 24 hours or on the
next working day following the occurrence or first knowledge of the occurrence of any of
the following:
a. Any occurrence at the wastewater treatment facility which results in the treatment of
significant amounts of wastes which are abnormal in quantity or characteristic, such
as the dumping of the contents of a basin or tank; the known passage of a slug of
hazardous substance through the facility; or any other unusual circumstances.
b. Any process unit failure, due to known or unknown reasons, that render the facility
incapable of adequate wastewater treatment such as mechanical or electrical failures
of pumps, aerators, compressors, etc.
c. Any failure of a pumping station, sewer line, or treatment facility resulting in a by-
pass directly to receiving waters without treatment of all or any portion of the
influent to such station or facility.
d. Any time that self -monitoring information indicates that the facility is not in
compliance with its permit limitations.
Persons reporting such occurrences by telephone shall also file a written report in letter
form within 15 days following first knowledge of the occurrence. This report must outline
the actions taken or proposed to be taken to ensure that the problem does not recur.
20. The following outline defines the events that will dictate the need for additional monitoring
wells:
(A) Within 90 days of permit issuance, RCRA Facility Investigation wells DC-1 and
DC-2 shall be sampled for the parameters listed in Condition 20 (C)(1), achieving
detection limits as specified in 15A NCAC 2L .0202(b). The results from this
sampling, and a diagram showing construction details for each well, shall be
submitted to the Groundwater Section, Permits and Compliance Unit, P: O. Box
29535, Raleigh, N.C. 27626-0535 within 30 days of the sampling.
(B)- If determined by the Division that no exceedances of groundwater quality standards
are present in DC-1 or DC-2, then no further monitoring will be required under this
permit.
(C) If any exceedances of the standards, specified in 15A NCAC 2L .0202 (g), are
detected as a result of groundwater sampling analyses in either DC-1 or DC-2, then
within 90 days of this detection, two (2) downgradient monitor wells (WQ-1 and
WQ-2) shall be installed to monitor groundwater quality. The well(s) shall be
constructed such that the water level in the well is never above or below the
screened (open) portion of the well at any time during the year. The general
location and name for each well is marked on Attachment A. Each monitoring well
shall be constructed in accordance with this permit, and approved by the
Mooresville Regional Office.
21. Monitor wells WQ-1 and WQ-2 shall be sampled initially after construction and thereafter
every April, August, and December for the following parameters:
Calcium Aluminum*
- TDS Sulfate
pH Water Level
Chloride Fluoride .
3

Chromium* Manganese*
Iron* Lithium*
* use method 3030C, preparation for metals, in Standards Methods, 17th edition.
The measurement of water levels must be made prior to sampling for the remaining
parameters. The depth of water in each well shall be measured from the surveyed point on
the top of casing.
The measuring points (top of well casing) of all monitoring wells shall be surveyed to
provide relative elevations of the measuring point for each monitoring well.
The results of the sampling and analysis shall be sent to the Groundwater Section, N. C.
Division of Environmental Management, P. O. Box 29535, Raleigh, N. C. 27626-0535 on
form GW-59 [Compliance Monitoring Report Form] every May, September, and January.
22. All wells that are constructed for purposes of groundwater monitoring shall be constructed
in accordance with 15A NCAC 2C .0108 (Standards of Construction for Wells Other Than
Water Supply) and any other state and local laws and regulations pertaining to well
construction.
23. The Mooresville Regional Office, telephone number [phone] shall be notified at
least two weeks prior to the construction of any new monitoring well required under this
permit so that an inspection can be made of the monitoring well location. Such notification
to the regional groundwater supervisor shall be made during the normal office hours from
8:00 a.m. until 5:00 p.m. on Monday through Friday, excluding state holidays.
24. Within sixty (60) days of completion of all new monitoring wells required under this
permit, the Permittee shall submit two original copies of a scaled topographic map (scale no
greater than 1:100) signed and sealed by a professional engineer or a registered land
surveyor that indicates all of the following information:
a. the location and identity of each monitoring well,
b. the location of the waste disposal system,
C. the location of all property boundaries,
d. the latitude and longitude of each monitoring well,
e. the relative elevation of the top of the well casing (which shall be
known as the "measuring point"),
f. the depth of water below the measuring point at the time the measuring
point is established.
The maps shall be sent to the Groundwater Section, N. C. Division of Environmental
Management, P. O. Box 29535, Raleigh, N. C. 27626-0535.
4

Upon completion of all well construction activities, a certification must be received from a
professional engineer certifying that the monitoring wells are located and constructed in
accordance with the Well Construction Standards (15A NCAC 2C) and this permit. This
certification should be submitted with copies of the Well Completion Form (GW-1) for
each well. Mail certification and the associated GW-1 forms to the Permits and Compliance
Unit, Groundwater Section, P.O Box 29535, Raleigh, N.C., 27626-0535.
26. For the initial sampling of the well as specified elsewhere in the permit,; the Permittee shall
submit a copy of the GW-1 form with the Compliance Monitoring Form (GW-59) for that
well. Compliance Monitoring Forms that do not include copies of the GW-1 form will be
returned to the Permittee without being processed. Failure to submit these forms as
required by this permit may result in the initiation of enforcement activities pursuant to NC
General Statutes 143-215.6.
27. The COMPLIANCE BOUNDARY for the disposal system (See Attachment A) is specified
by regulations in 15A NCAC 2L, Groundwater Classifications and Standards. Compliance
Boundary is established at either (1) 250 feet from the waste disposal area, or (2) 50 feet
within the property boundary. An exceedance of Groundwater Quality Standards beyond
the Compliance Boundary is subject to the penalty provisions applicable under General
Statute 143-215.6(1)a.
Also in accordance with 15 A NCAC 2L, a REVIEW BOUNDARY (See Attachment A) is
established around disposal systems midway between the Compliance Boundary and the
perimeter of the waste disposal area. Any exceedance of standards at the Review Boundary
shall require remediation action on the part of the Permittee.
28. Upon classification of the facility by the Certification Commission, the Permittee shall
employ a certified wastewater, treatment plant operator to be in responsible charge (ORC) of
the wastewater treatment facilities. The operator must hold a certificate of the type and
grade at least equivalent to or greater than the classification assigned to the wastewater
treatment facilities by the Certification Commission. The Permittee must also employ a
certified back-up operator of the appropriate type and grade to comply with the conditions
of Title 15A, Chapter 8A, .0202. The ORC of the facility must visit each Class I facility at
least weekly and each Class H, I11, and IV facility at least daily, excluding weekends and
holidays, and must properly manage and document daily operation and maintenance of the
facility and must comply with all other conditions of Title 15A, Chapter 8A, .0202.
29. The Permittee, at least six (6) months prior to the expiration of this permit, shall request its
extension. Upon receipt of the request, the Commission will review the adequacy of the
facilities described therein, and if warranted, will extend the permit for such period of time
and under such conditions and limitations as it may deem appropriate.
Permit issued this the 14th day of June, 1994
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
reston oward, Jr., P.E., Director
Division of Environmental Management
By Authority of the Environmental Management Commission
Permit No. WQ0008149

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr„ P.E., Director
January 24, 1995
FMC Corporation/Lithium Division
Post Office Box 795
Bessemer City, NC 28016
Attn: Mr. J.E. McLeod
Plant Manager
FIFAA•
[D FE F1
N.C.- DEPT, OF
ENWRONMENT, HEAL't'q
& NATURAL RESOURCES
SUBJECT: Permit No. WQ0008149/GW94184
FMC Corporation/Lithium Division
Wastewater Recycle System
Gaston County
Dear Mr. McLeod:
JAN 26 1995
DIVISION OF ENVIRONMEN1Ai "ANAGRI'ai .
MOORESVILLE RENONAL OFFICE
In accordance with the policy of the Division of Environmental
Management to ensure the good quality of North Carolina's
groundwater, the referenced Permit requires several activities
related to groundwater monitoring. The following guidelines and
forms are presented to assist you in complying with those
requirements. If you have any questions concerning these matters,
you should contact Barbara Christian at the address shown below to
discuss the requirements relevant to your specific facility:
Mooresville Regional Office
919 North Main Street
Mooresville, NC 28115
[phone]
Condition No. 20: The installation of monitor wells as
approved by the Department's Mooresville Regional Office.
Note: Each well shall be developed such that
the level of turbidity or settleable
solids does not preclude accurate
chemical analyses of any fluid samples
collected. Arrangements to satisfy this
requirement should be made by you with
the well contractor prior to the
installation of wells. Prior, to
accepting a new well, you should verify
that the driller has developed the well
to an acceptable level as stated above.
Failure to ensure proper development may
P.O, Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

McLeod
uary 24, 1995
_ e 2
result in samples containing excessive
amounts of suspended'solids and sediment
which could lead to analysis and
compliance problems. Such samples may
generate analytical data exceeding
standard limits in violation of 15A NCAC
2L regulations and may ultimately results
in fines and/or revocation of your
permit.
Condition No. 21: Sampling of the referenced wells on the
schedule and for the constituents listed below:
SCHEDULE: Monitor well WQ-1 shall be sampled initially after
construction. The two (2) monitor wells WQ-1 and
WQ-2 shall be sampled every April, August, and
December.
CONSTITUENTS: Aluminum*
Lithium*
Calcium
Manganese*
Chloride
pH
Chromium*
Sulfate
Fluoride
TDS
Iron*
Water Level
* use Method 3030C, Preparation for Metals, in
Standard Methods, 17th edition
The measurement of water levels must be made prior to sampling
for the remaining parameters.
The results of all analyses specified in the monitoring
requirements must be submitted simultaneously.
* A suDDly of forms (GW-59) on which the analvtical results_
must be reported are attached. Instructions are provided on the
reverse of the white copy of each four part form. The analytical
results should be sent the address shown at the top of the form and
are due in our office no later than the last working day of the
month following sample collection.
A supply of forms (GW-1) on which monitor well construction
data is reported by the well drilling contractor or accent are
attached. A GW-1 form is to be completed for each well
constructed.
* FOR ANY ADDITIONAL INFORMATION RELATED TO REQUIREMENTS FOR
GROUNDWATER QUALITY PROTECTION, PLEASE REFER TO YOUR PERMIT. A
copy of the Groundwater Requirements for Permit No. WQ0008149 is
attached for your reference.

McLeod
nary 24,
3
1995
If you have any questions, please do not hesitate to contact
me at [phone] EXT. 435.
Sincerely,
�� a, 460/S-"L-
Cynthia A. Boyles
Hydrogeological Technician II
Permits and Compliance
Groundwater Section
Attachments
cc : @.ar, ab xa�`C rias�t. ian
Central Files
Compliance Monitoring Files

9. Noncompliance Notification:
The Permittee shall report by telephone to the Mooresville Regional Office, telephone
number [phone], as soon as possible, but in no case more than 24 hours or on the
next working day following the occurrence or first knowledge of the occurrence of any of
the following:
a. Any occurrence at the wastewater treatment facility which results in the treatment of
significant amounts of wastes which are abnormal in quantity or characteristic, such as
the dumping of the contents of a basin or tank; the known passage of a slug of
hazardous substance through the facility; or any other unusual circumstances.
b. Any process unit failure, due to known or unknown reasons, that render the facility
incapable of adequate wastewater treatment such as mechanical or electrical failures of
pumps, aerators, compressors, etc.
c..Any failure of a pumping station, sewer line, or treatment facility resulting in a by-pass
directly to receiving waters without treatment of all or any portion of the influent to
such station or facility.
d. Any time that self -monitoring information indicates that the facility is not in compliance
with its permit limitations.
Persons reporting such occurrences by telephone shall also file a written report in letter
form within 15 days following first knowledge of the occurrence. This report must outline
the actions taken or proposed to be taken to ensure that the problem does not recur.
20. Within .90 days of the initial sampling of wells DC-1 and DC-2, one (1) downgradient
monitor well shall be constructed such that the water level in the well is never above or
below the screened (open) portion of the well at any time during the year. The general
location and name for each well is marked on Attachment A. Each monitoring well shall be
located at the review boundary, constructed in accordance with this permit, and approved
by the Mooresville Regional Office.
21. Monitor wells WQ-1 and WQ-7 shall be identified for purposes of this permit as "WQ-1",
and "WQ-2" a.k.a. W-7. Monitor well WQ-1 shall be sampled initially after construction.
Monitor wells WQ-1 and WQ-2 shall be sampled -every April, August, and December for
the following parameters:
Calcium
TDS
pH
Chloride
Chromium*
Iron*
Aluminum*
Sulfate
Water Level
Fluoride
Manganese*
Lithium*
* use method 3030C, preparation for metals, in Standards Methods, 17th edition
The measurement of water levels must be made prior to sampling for the remaining
parameters. The depth of water in each well shall be measured from the surveyed point on
the top of casing.
The measuring points (top of well casing) of all monitoring wells shall be surveyed to
provide relative elevations of the measuring point for each monitoring well.
9

The results of the sampling and analysis shall be sent to the Groundwater Section, N. C.
Division of Environmental Management, P. O. Box 29535, Raleigh, N. C. 27626-0535 on
form GW-59 [Compliance Monitoring Report Form] every May, September, and January.
I. All wells that are constructed for purposes of groundwater monitoring shall be constructed
in accordance with 15A NCAC 2C .0108 (Standards of Construction for Wells Other Than
Water Supply) and any other state and local laws and regulations pertaining to well
construction.
23. The Mooresville Regional Office, telephone number [phone] shall be notified at
least two weeks prior to the construction of any new monitoring well required under this
permit so that an inspection can be made of the monitoring well location. Such notification
to the regional groundwater supervisor shall be made during the normal office hours from
8:00 a.m. until 5:00 p.m. on Monday through Friday; excluding state holidays.
24. Within sixty (60) days of completion of all new monitoring wells required under this
permit, the Permittee shall submit two original copies of a scaled topographic map (scale no
greater than 1:100) signed and sealed by a professional engineer or a registered land
surveyor that indicates all of the following information:
a. the location and identity of each monitoring well,
b. the location of the waste disposal system,
c. the location of all property boundaries,
d. the latitude and longitude. of each monitoring well,
e. the relative elevation of the top of the well casing (which shall be known as the
. "measuring point"),
f. the depth of water below the measuring point at the time the measuring point is
.established.
The maps shall be sent to the Groundwater Section, N. C. Division of Environmental
Management, P. -O. Box 29535, Raleigh, N. C. 27626-0535.
25. Upon completion of all well construction activities, a certification must be received from a
professional engineer certifying that the monitoring wells are located and constructed in
accordance with the Well Construction Standards (15A NCAC 2C) and this permit. This
certification should be submitted with copies of the Well Completion Form (GW-1) for
each well. Mail certification and the associated GW-1 forms to the Permits and Compliance
Unit, Groundwater Section, P.O Box 29535, Raleigh, N.C., 27626-0535.
26. For the initial sampling of the well as specified elsewhere in the permit, the Permittee shall
submit a copy of the GW-1 form with the Compliance Monitoring Form (GW-59) for that
well. Compliance Monitoring Forms that do not include copies of the GW-1 form will be
returned to the Permittee without being processed. Failure to submit these forms as
required by this permit may result in the initiation of enforcement activities pursuant to NC
General Statutes 143-215.6.
27. The COMPLIANCE BOUNDARY for the disposal system (See Attachment A) is specified
by regulations in 15A NCAC 2L, Groundwater Classifications and Standards. Compliance
Boundary is established at either (1) 250 feet from the waste disposal area, or (2) 50 feet
within the property boundary. An exceedance of Groundwater Quality Standards beyond
the Compliance Boundary is subject to the penalty provisions applicable under General
Statute 143-215.6(1)a.
Also in accordance with 15 A NCAC 2L, a REVIEW BOUNDARY (See Attachment A) is
established around disposal systems midway between the Compliance Boundary and the
perimeter of the waste disposal area. Any exceedance of standards at the Review Boundary
shall require remediation action on the part of the Permittee.
4

MEMO
TO:
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From:
DATE:
SUBJECT:
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North Carolina Department of Environment,
>
Healthand Natural Resources
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Type or Use a ball-point pen and press firmly.
Facility Name rmc o e_P — t, r?11vpt-1 II%/
Address 81114 1 lo) 601� -4q S .
Well Locatio
Well Identification Number VvLA — I Well Depth "r" 1 - - _Ft.
Well Diameterc9k In Sample (Screened) Interval Q15- Ft. To 41 Ft.
Depth to Water Level aa-. 3j ft. below measuring point (before sampling)
Measuring point is a,S ft. above land surface
Gallons of water pumped/bailed before sampling 6.0
DIVISION OF
PERMIT NUMBER: (REQUIRED)
Non -Discharge WGL 000 E3149
NPDES
TYPE OF DISPOSAL OPERATION BEING MONITOREC
(REQUIRED)
Lagoon S�eptic,TanklDrain,Field •• ..
clY,
Spray Field Subsurface•Low=Pressure=''
Piping (LPP)
Land Application of Sludge
A Other
Rotary Distributor jZl= CgC1S_ ll�t PotaNa � T
Field Analysis: pH &v 5 Specific Conductance 3540 uMhos Temp. 1(P oC Odor A0Ae— Appearance CL5kP — U''3 ivT LLS
Date Sample Collected '41Date Lab Sample Analyzed Si11198 — 611-11R8
Laboratory Name Z.Aw CAS TFl2 L-A-6S Certification No. 'Z1
SAMPLES FOR METALS WERE COLLECTED UNFILTERED AND FIELD ACIDIFIED YES x NO
COD
NA
mg/I
Coliform: MF Fecal
Nq
/100ml
Coliform: MF Total
Nq-
/100ml
(Note: Use MPN method for highly turbid samples)
Dissolved Solids: Total 33 C?v
mg/I
pH (when analyzed)
6. Z
units
TOC
mg/1
Chloride
mil. r,
mg/I
Arsenic
mg/I
Grease and Oils
N&
mg/I
Hardness: Total
N4
mg/I
Phenol
NA
_ mg/I
Sulfate
3390
mg/I
Specific Conductance
NA
uMhos
Total Ammonia
IJA
mg/I
TKN as N
N
mg/1
Nitrite (NO2) as N
NA►
mg/I
Nitrate (NO3) as N
NA-
mg/I
Phosphorus: Total as P "k
mg/I
Al - Aluminum
O,Zia
mg/I
Ba - Barium
NN
mg/I
Ca - Calcium
5_0Z-
mg/I
Cd - Cadmium
pi
mg/I
Chromium: Total
C a, 30
mg/I
Cu - Copper
tj A
mg/I
Fe - Iron
4 0, 10
mg/1
Hg - Mercury
N4
mg/1
K - Potassium
N4
mg/1
Mg - Magnesium
NA
mg/I
Mn - Manganese
31,6
mg/1
Na - Sodium
Ndk
mg/l
Ni - Nickel NA
mg/I
Pb - Lead NA-
mg/I
Zn - Zinc PA
S?mg/I
Pesticides/Herbicides
Co
(Specify Compounds)
c=
o
N/1-
1C=—
Leg/I
ug/I
Other (Specify Compounds and
�19
Concentration units)
M70
FYy0f.IIV 5 it,1 rn!5
i.iTif ) UPA L o VIA
N Ar— NwA I-`4515 Nei
bv)1211\
I CERTIFY THAT THIS REPORT IS TRUE AND ACCURATE. Note: Values should reflect dissolved and
colloidal concentrations. (see #3 on back)
` See back for instructions.
Signature of Permittee (or Authori gent*) at
ed ** Submit blue and yellow copies only to address above.
GW-59 REV. 8/96

i 0"
J :WS WAR* wwffl; MAN r- .54fimmal -W I& - I I
2. Metals Analyses: Use Standard Method 3030C for sample preparation (mercury excluded). DO NOT FILTER METALS SAMPLES IN THE FIELD !!!
Unfiltered samples must be collected for metals, then field acidified with 5 ml concentrated nitric acid per liter of sample, and should be submitted to the
lab within 24 hours.
Sample preparation in the laboratory (extraction and fiitration) must be completed within 72 hours of collection.
BVMHZWM� KIN;MIL
4. As per Title 15, North Carolina Administrative Code, Subchapter 2L, analytical procedures shall be in accordance with the methods described in one of
the following publications, or by other methods approved beforehand by the Director, Division of Environmental
Management:
(a) Standard Methods for the Examination of Water and Wastewater, 16th Edition, 1985 and 17th Edition, 1989, published jointly by
American Public Health Association, American Water Works Association and Water Pollution Control Federation;
(b) Methods for Chemical Analysis of Water and Waste, 1979, U.S. Environmental Protection Agency publication number
EPA-600/4-79--020, as revised March 1983;
(c) Test Methods for Evaluating Solid Wastes: Physical/Chemical Methods, 3rd Edition, 1986, U.S. Environmental Protection Agency
publication number SW-846;
(d) Test Procedures for the Analysis of Polluants Under the Clean Water Act, Federal Register Vol. 49, No. 209, 40 CFR Part 136,
October 26, 1984;
5. Measure and record the depth of water in the well prior to pumping or bailing any water from the well.
6. At least 3 volumes of water in the well should be pumped or bailed prior to collecting a sample for analysis. If the well is pumped/bailed dry before 3 well
volumes are removed, samples can be collected as soon as the well recovers to the point where enough water is available to collect your sample.
7. Determination for pH, Specific Conductance, temperature, odor and appearance must be made in the field on unfiltered samples when the sample is
collected.
8. Field equipment must be calibrated in accordance with recommendations by the manufacturer.
9. Samples must be filtered through a 0.45 micron filter immediately after collection when a dissolved analysis is required. (See 44. above)
I Q.The sample container should be labeled at the time of collection with the facility name, well identification numbeir and date and time collected.
11 ."Authorized agent" is any corporate officer or public official authorized by the company, corporation, or governmental body to sign official documents.

PP_PPP_
,.__4
DIVISION OF WATER QUALITY - GROUNDWATER SECTION
GROUNDWATER QUALITY MONITORING: P.O.BOX 29578
For additional' forms RALEIGH, NC 27626.0578 :
COMPLIANCE REPORT FORM Please Write or call: [phone]
Type or Use a ball-point pen and press firmly. PERMIT NUMBER: (REQUIRED)
Facility Name I%M C C019-P — L1'1141v't"^ 'bit/ Non -Discharge W61 000 &► `}9
Address flatx NPDES
P �S�cl�Yl ii2 01► . NC - County C��r-� TYPE OF DISPOSAL OPERATION BEING MONITORED
(REQUIRED)
��
Well Location C alit of Pl(? ite- M '> Z®00 -�fi L' e� �aCk� Lagoon Septic Tank/Drain Field
Well Identification Number W GI 2- A-iA W :I ---Well Depth 3 & o _ Ft. Spray Field Subsurface Low -Pressure
Well Diameter A ►y\ Sample (Screened) Interval a&, Ft. To 318-5Ft. Piping (LPP)
Depth to Water Level +' SI ft. below measuring point (before sampling) Land Application of Sludge
Measuring point is I t ft. above land surface 9 Other
Gallons of water pumped/bailed before sampling (0, C) Rotary Distributor P_ZC4cLG lYt,pQ 10'�2ti
Field Analysis: pH S 3T_ Specific Conductance l8i q uMhos Temp. I lP oC Odor n6 ne- Appearance f t1" 1 % —'Y& S Nr' S
Date Sample Collectg13 Date Lab Sample Analyzed Sh I aK i0110195
Laboratory Name 1,h&P_r*_MYtlE5 Certification No.
SAMPLES FOR METALS WERE COLLECTED UNFILTERED AND FIELD ACIDIFIED YES x NO
COD
►JA
mg/I
Coliform: MF Fecal
N'A
/100ml
Coliform: MF Total
W PT
/100ml
(Note: Use MPN method for highly turbid samples)
52-
Dissolved Solids: Total
mg/I
pH (when analyzed)
units
TOC
N
mg/I
Chloride
mg/I
Arsenic
rJ 6.
mg/I
Grease and Oils
N1*
mg/I
Hardness: Total
N4r
rng/1
Phenol
Nh
mg/I
Sulfate
47-0
mg/I
Specific Conductance
N h
uMhos
Total Ammonia
Nk
mg/I
TKN as N
0 h
mg/I
Nitrite (NO2) as N
w4
mg/I
Nitrate (NO3) as N
mg/I
Phosphorus: Total as P N Pr
mg/I
Al - Aluminum
<0.-1-0
mg/I
Ba - Barium
Mk
mg/I
Ca - Calcium
0. 07;5
mg/I
Cd - Cadmium
NAr
mg/I
Chromium: Total
a ,ova
mg/I
Cu - Copper
NA
mg/I
Fe - Iron
tf)
mg/I
Hg - Mercury
N&
mg/I
K - Potassium
Nb,
mg/I
Mg - Magnesium
NA,
mg/I
Mn - Manganese
0• 0Zl
mg/I
Na - Sodium
)JN
mg/I
-5-2-1
Ni - Nickel N41
mg/I
Pb - Lead V4
mg/I
Zn - Zinc NA
mg/I
Pesticides/Herbicides
c.0
(Specify Compounds)
N)4
co
r ,
C=
2;r;riug/I
'
C� ug/I
Z
ug/I
Other (Specify Compounds and
Concentration units)m
F�Uot2-1 l) doz 10
`
1-1'r lum `0,ozo
I CERTIFY THAT THIS REPORT IS TRUE AND ACCURATE. Note: Values should reflect dissolved and
colloidal concentrations. (see #3 on back)
See back for instructions.
Signature of Permittee (or Authoriz ent*) Dc# Submit blue and yellow copies only to address above.
GW-59 REV. 8/96

&JAMMoAff.�mMmal WTI NITim"MA
2. Metals Analyses: Use Standard Method 3030C for sample preparation (mercury excluded). DO NOT FILTER METALS SAMPLES IN THE FIELD !!!
Unfiltered samples must be collected for metals, then field acidified with 5 ml concentrated nitric acid per liter of sample, and should be submitted to the
lab within 24 hours.
Sample preparation in the laboratory (extraction and filtration) must be completed within 72 hours of collection.
FM a as r!
ago-
WYA
IMIKKAMOLP
Ii IN =I
4. As per Title 15, North Carolina Administrative Code, Subchapter 2L, analytical procedures shall be in accordance with the methods described in one of
the following publications, or by other methods approved beforehand by the Director, Division of Environmental
Management:
(a) Standard Methods for the Examination of Water and Wastewater, 16th Edition, 1985 and 1 7th Edition, 1989, published jointly by
American Public Health Association, American Water Works Association and Water Pollution Control Federation;
(b) Methods for Chemical Analysis of Water and Waste, 1979, U.S. Environmental Protection Agency publication number
EPA-600/4-79-020, as revised March 1983;
(c) Test Methods for Evaluating Solid Wastes: Physical/Chemical Methods, 3rd Edition, 1986, U.S. Environmental Protection Agency
publication number SW-846;
(d) Test Procedures for the Analysis of Polluants Under the Clean Water Act, Federal Register Vol. 49, No. 209, 40 CFR Part 136,
October 26, 1984;
7. Determination for pH, Specific Conductance, temperature, odor and appearance must be made in the field on unfiltered samples when the sample is
collected.
8. Field equipment must be calibrated in accordance with recommendations by the manufacturer.
9. Samples must be filtered through a 0.45 micron filter immediately after collection when a dissolved analysis is required. (See #4. above)
10. The sample container should be labeled at the time of colioction,with the facility name, well identification number and date and time collected.
11 ."Authorized agent" is any corporate officer or public official authorized by the company, corporation, or governmental body to sign official documents.

FMC Corporation
Lithium Division
Highway 161
Box 795
Bessemer City North Carolina 28016
704 868 5300 Fax [phone]
fMC
Certified Mail
Return Receipt Requested
July 14, 1998
NC Department of Environment and Natural Resources
Division of Water Quality - Groundwater Section
P.O. Box 29535 .
Raleigh, NC 27626-0535
Re: Non -Discharge Permit No. WQ0008149
Groundwater Quality Monitoring - Compliance Report Forms
Dear Sir or Madam:
N -j
In accordance with the requirements of item No. 21 of the North Carolina Water Quality
Permit No. WQ0008149 for the Recycle System (kiln scrubber ponds) located at FMC
Corporation's Lithium Division facility in Bessemer City, FMC is submitting two
Compliance Monitor Forms (GW-59) for the sampling and analysis of groundwater
monitoring wells WQ-1 and WQ-7 (AKA W-7) on April 30, 1998. The methods for
sample digestion and analyses are consistent with those described in FMC's January 27,
1997 letter transmitting the monitoring results for the December 1996 sampling event.
Laboratory report sheets and chain of custody records are available upon request.
Modified sample collection procedures, as described in FMC's September 29, 1995 letter
to DEM were used during this sampling event in an attempt to reduce turbidity of
collected groundwater. Again while turbidity has been reduced, the EPA guideline in
SW-846 of five NTU could not be achieve without filtering. All results represent
analysis of filtered samples, as recommended in FMC's letter of September 29, 1995, to
which DEM has not responded.
FMC apologizes for the delay in reporting the results from the April sampling. While
FMC has required that the firm collecting the samples and coordinating their analyses
(Fluor Daniel/GTI) provide data within 30 days of sampling, an unforeseen volume of
samples received at the laboratory resulted in slower than anticipated lab turn around.
The laboratory did not complete analyses until June 19 and FMC did not receive the
reports from Fluor Daniel/GTI on July 6th.

NC DENR/Groundwater Quality Monitoring
Permit No. WQ0008149
July 14, 1998 - Page 2
Lastly, FMC notes that its spodumene ore processing decrepitation kiln was permanently
shut down on approximately April 1, 1998. The air pollution control scrubbers associated
with this kiln discharged water to the recycle impoundments regulated pursuant to Water
Quality Permit No. WQ0008149. Thus, FMC has begun closure of the kiln scrubber
ponds and is providing notice to the Department of Environment and Natural Resources
that Permit No. WQ0008149 should be canceled; future sampling should not be required
pursuant to that permit.
If you have any questions, please contact me at 704/868-0806.
Vgf-j truly
E.
ble Care Manager
cc: DEHNR/Mooresville

GROUNDWATER QUALITY MONITORING:
COMPLIANCE REPORTFORM
Type or Use a ba
Facility Name M Cap' Cimi_%-'
Address ,`
Well Locatio
f l� DIVISION OF WATER QUALITY - GROUNDWATER SECTION'
P.O. BOX 29578 `
For additional forms - RALEIGH, NC 27626-0578
please write or call; (919)'733-3221
....
PERMIT NUMBER: (REQUIRED)
Non -Discharge W 1 QQCI lD l-q f'-I j {� 8
NPDES
TYPE OF DISPOSAL OPERATION BEING MONITORED
(REQUIRED) Chl?�:i
Lagoon Sgetic TanklDraio,Fielii;; iz
Well Identification Number WQ"Z. 141-0- W -�— Well Depth ' 98 , 5 Ft.
- Well Diameter 1 vL Sample (Screened) Interval -26 + `� Ft. To 3y ; 5_ Ft.
Depth to Water Level 6- Oi- ft. below measuring point (before sampling)
Measuring point is 19 ft. above land surface
Gallons of water pumped/bailed before sampling 510
Field Analysis: pH 5-t ? Specific Conductance 1 A _ uMhos Temp. Ito% I°C Odor
Date Sample Collected I L Date Lab Sample Analyzed
Laboratory Name L6 00-�P-1 t—> Certification No.
SAMPLES FOR METALS WERE COLLECTED UNFILTERED AND FIELD ACIDIFIED YES X NO
pen and press fi
s o County 604
? zevo T•Ie id/aei e
COD
toe
mg/I
Coliform: MF Fecal
IVA.
/100ml
Coliform: MF Total
t4a'
/100ml
(Note: Use MPN method for highly
turbid samples)
Dissolved Solids: Total 4--- mg/I
pH (when analyzed)
5-,35
units
TOC
NA-
mg/i
Chloride
�3,. WO
mg/I
Arsenic
IV' at
mg/1
Grease and Oils
N A
mg/I
Hardness: Total
n/A
mg/I
Phenol
NA_
mg/I
Sulfate
151
mg/I
Specific Conductance a -A. uMhos
Total Ammonia
N'A
mg/I
TKN as N
Nor
mg/I
Nitrite (NO2) as N
Nat
_ mg/I
Nitrate (NO3) as N
04
mg/I
Phosphorus: Total as P 1114
mg/I
Al - Aluminum
< C,, z0
mg/I
Ba - Barium
IQ A,
mg/I
Ca - Calcium
o
mg/I
Cd - Cadmium
fL'�
mg/I
Chromium: Total
< Ali
mg/I
Cu - Copper
AlAr
mg/I
Fe - Iron
4 01 I o
mg/I
Hg - Mercury
IJn
mg/I
K - Potassium
NR
mg/I
Mg - Magnesium
#\)At
mg/I
Mn - Manganese
0. O'k(v
mg/I
Na - Sodium
tjA-
mg/I
I CERTIFY THAT THIS REPORT IS TRUE AND ACCURATE.
of Permittee (or
orized Agent*)
Spray Field Subsurface Low -Pressure
Piping (LPP)
Land Application of Sludge
_X Other
Rotary Distributor XI-C i CL_�_ /M PeU114IR
Appearances ito t%" 5
6-2-
Ni - Nickel NA
mg/I
Pb - Lead_ tv
r-n mg/I
Zn - Zinc
mg/I
Pesticides/Herbicides
(Specify Compounds)
N 4-
ml
Ig/I
?
yg/I
Other (Specify Compounds and
rr1s,
Concentration units)
G7
CP
10 ,4l-1
.
`N)'0M < 6, 0 W
i1sm_vjI4,iS woi—
iL
Note: Values should reflect dissolved and
colloidal concentrations. (see #3 on back)
hk,
I r * See back for instructions.
Da a **-Submit blue and yellow copies only to address above.
REV. 8/96

Samples should be analyzed as soon as possible after collection. SAMPLES WHICH ARE NOT ANALYSED WITHIN THE HOLDING TIME SPECI-
FIED FOR THE METHOD USED (SEE #4. BELOW) MUST BE DISCARDED AND NEW SAMPLES COLLECTED.
2. Metals Analyses: Use Standard Method 3030C for sample preparation (mercury excluded). DO NOT FILTER METALS SAMPLES IN THE FIELD !!!
Unfiltered samples must be collected for metals, then field acidified with 5 ml concentrated nitric acid per liter of sample, and should be submitted to the
lab within 24 hours.
Sample preparation in the laboratory (extraction and filtration) must be completed within 72 hours of collection.
11
I10r j - r - 610102M...," � rr � w -.. o � Alawil film,
4. As per Title 15, North Carolina Administrative Code, Subchapter 2L, analytical procedures shall be in accordance with the methods described in one of
the following publications, or by other methods approved beforehand by the Director, Division of Environmental
Management:
(a) Standard Methods for the Examination of Water and Wastewater, 16th Edition, 1985 and 17th Edition, 1989, published jointly by
American Public Health Association, American Water Works Association and Water Pollution Control Federation;
(b) Methods for Chemical Analysis of Water and Waste, 1979, U.S. Environmental Protection Agency publication number
p , EPA-600/4-79-020, as revised March 1983;
(c) Test Methods for Evaluating Solid Wastes: Physical/Chemical Methods, 3rd Edition, 1986, U.S. Environmental Protection Agency
publication number SW-846;
(d) Test Procedures for the Analysis of Polluants Under the Clean Water Art, Federal Register Vol. 49, No. 209, 40 CFR Part 136,
October 26, 1984:
5. Measurb and record the depth of water in the well prior to pumping or bailing any water from the well.
6. At least 3 volumes of water in the well should be pumped or bailed prior to collecting a sample for analysis. If the well is pumped/bailed dry before 3 well
volumes are removed, samples can be collected as soon as the well recovers to the point where enough water is available to collect your sample.
7. Determination for PH, Specific Conductance, temperature, odor and appearance must be made in the field on unfiltered samples when the sample is
collected.
8. Field equipment must be calibrated in accordance with recommendations by the manufacturer,
9. Samples must be filtered through a 0.45 micron filter immediately after collection when a dissolved analysis is required. (See #4. above)
10.The sample container should be labeled at the time of collection with the facility name, well identification number and date and time collected.
11. "Authorized agent" is any corporate officer or public official authorized by the company, corporation, or governmental body to sign official documents.

DIVISION OF WATER: QUALITY'- GROUNDWATER SECTION
GROUNDWAT
ER UALITY MONITORING: �.o. Box 2s5za
For additional forms RALEIGH,, NC 27626.0578
COMPLIANCE REPORT FORM please Write or ca°' [phone]
Type or Use a ball-point pen and ress firmly. PERMIT NUMBER: (REQUIR
Facility Name � L �� ' 7n N' L► i 1 tll �AI) IV A.o Non -Discharge
Address ZJ 0 NPDES
r ti� Z�®I County 1 TYPE OF DISPOSAL OPERATION BEING MONITORED
n (REQUIRED)
Well Location-���'�1`"e-�1� + ifl�cl.4J &ijNWi�'l Q� IClfil�lbNbLagoon Septic Tank/Drain Field
Well Identification Number Well Depth �Ft. Spray Field Subsurface Low -Pressure
Well Diameter�Sample (Screened) Interval �, Ft. To 1,S Ft. Piping (LPP)
Depth to Water Level 30L U5�ft. below measuring point (before sampling) Land Application of Sludge
Measuring point is �: 5 Rotary Distributor �
ft. above land surface Other
-v3e
Gallons of water pumped/bailed before sampling &+ 3 L�
Field Analysis: pH tl- Specific Conductance 2180 uMhos Temp P, `��C Odor PA)i— Appearances&�5) — 4tL_7-- N_;tt�
Date Sample Collected Date Lab Sample Analyzed%�����— f1o''h
Laboratory Name LnkLJl4-kJ R_. 4-116S _ Certification No. �Z'1
SAMPLES FOR METALS WERE COLLECTED UNFILTERED AND FIELD ACIDIFIED YES 5Q NO
COD
NA_
mg/I
Coliform: MF Fecal
NA
/100ml
Coliform: MF Total
Ij Pr
/100ml
(Note: Use MPN method for highly turbid samples)
Dissolved Solids: Total
a lit%
mg/I
pH (when analyzed)
units
TOC
NA
mg/I
Chloride
5b, B
mg/I
Arsenic
NA,
mg/1
Grease and Oils
N or
mg/I
Hardness: Total
N
mg/I
Phenol
Ai"k
_ mg/I
Sulfate
ice®
mg/I
Specific Conductance
h+A
uMhos
Total Ammonia
NA
mg/I
TKN as N
NA-
mg/1
Nitrite (NO2) as N
NA _
mg/I
Nitrate (NO3) as N
LV%
mg/I
Phosphorus: Total as
P NA-
mg/I
Al - Aluminum
171i I
mg/I
Ba - Barium
mg/I
Ca - Calcium
/
mg/1
Cd - Cadmium
WA
mg/1
Chromium: Total
G Q; 030
mg/I
Cu - Copper
10-
mg/I
Fe - Iron
01 a-3
mg/1
Hg - Mercury
NA
mg/I
K - Potassium
aAc
mg/I
Mg - Magnesium
�jA-
mg/1
Mn - Manganese
ol°'r 90
mg/1
Na - Sodium
tiA'
mg/I
I CERTIFY THAT THIS REPORT IS TRUE AND ACCURATE.
re of Permittee (
thorized Agent*)
Ni - Nickel NA
mg/I
Pb - Lead P/
; mg/I
Zn - Zinc /y
CO
mg/I
Pesticides/Herbicides
(Specify Compounds)
IN
. `
cam ,
4
ry
_-Ug/I
C:' ^ug/I
mm
ij .<ug/I
Other (Specify Compounds and
�.o
M-7-:
Concentration units)
o
Cn
F1,ta°�I,�IC C/
�� � 11Y✓l i2�7� r�i✓t�
I �iL.
lI! iS A of F l;qo ED
Note: Values should reflect dissolved and
colloidal concentrations. (see #3 on back)
16 * See back for instructions.
Dat ** Submit blue and yellow copies only to address above.
REV. 8/96

1. Samples should be analyzed as soon as possible after collection. SAMPLES WHICH ARE NOT ANALYSED WITHIN THE HOLDING TIME SPECI-
FIED FOR THE METHOD USED (SEE #4. BELOW) MUST BE DISCARDED AND NEW SAMPLES COLLECTED.
2. Metals Analyses: Use Standard Method 3030C for sample preparation (mercury excluded). DO NOT FILTER METALS SAMPLES IN THE FIELD !!!
Unfiltered samples must be collected for metals, then field acidified with 5 nil concentrated nitric acid per liter of sample, and should be submitted to the
lab within 24 hours.
Sample preparation in the laboratory (extraction and filtration) must be completed within 72 hours of collection.
4. As per Title 15, North Carolina Administrative Code, Subchapter 2L, analytical procedures shall be in accordance with the methods described in one of
the following publications, or by other methods approved beforehand by the Director, Division of Environmental
Management:
(a) Standard Methods for the Examination of Water and Wastewater, 16th Edition, 1985 and 17th Edition, 1989, published jointly by
American Public Health Association, American Water Works Association and Water Pollution Control Federation;
(b) Methods for Chemical Analysis of Water and Waste, 1979, U.S. Environmental Protection Agency publication number
EPA-600/4-79-020, as revised March 1983;
(c) Test Methods for Evaluating Solid Wastes: Physical/Chemical Methods, 3rd Edition, 1986, U.S. Environmental Protection Agency
publication number SW-846;
(d) Test Procedures for the Analysis of Polluants Under the Clean Water Act, Federal Register Vol. 49, No. 209, 40 CFR Part 136,
October 26, 1984;
5. Measure, -and record the depth of water in the well prior to pumping or bailing any water from the well.
6. At least 8-volumes of water in the well should be pumped or bailed prior to collecting a sample for analysis. If the well is pumped/bailed dry before 3 well
volumes are removed, samples can be collected as soon as the well recovers to the point where enough water is available to collect your sample.
7. Determination for pH, Specific Conductance, temperature, odor and appearance must be made in the field on unfiltered samples when the sample is
collected.
8. Field equipment must be calibrated in accordance with recommendations by the manufacturer.
9. Samples must be filtered through a 0.45 micron filter immediately after collection when a dissolved analysis is required. (See #4. above)
10. The sample container should be labeled at the time of collection with the facility name, well identification number and date and time collected.
11. "Authorized agent" is any corporate officer or public official authorized by the company, corporation, or governmental body to sign official documents.

FMC Corporation
Lithium Division
Highway 161
Box 795
Bessemer City North Carolina 28016
704 868 5300 Fax [phone]
Certified Mail
Return Receipt Requested
January 15, 1998
NC Department of Environment and Natural Resources
Division of Water Quality - Groundwater Section
P.O. Box 29535
Raleigh, NC 27626-0535
Re: Non -Discharge Permit No. WQ0008149
Groundwater Quality Monitoring - Compliance Report Forms
Dear Sir or Madam:
+MC
In accordance with the requirements of item No. 21 of the North Carolina Water Quality
Permit No. WQ0008149 for the Recycle System (kiln scrubber ponds) located at FMC
Corporation's Lithium Division facility in Bessemer City, FMC is submitting two
Compliance Monitor Forms (GW-59) for the sampling and analysis of groundwater
monitoring wells WQ-1 and WQ-7 (AKA W-7) on December 4 and 5, 1997. The
methods for sample digestion and analyses are consistent with those described in FMC's
January 27, 1997 letter transmitting the monitoring results for the December 1996
sampling event. Laboratory report sheets and chain of custody records are available upon
request.
Modified sample collection procedures, as described in FMC's September 29, 1995 letter
to DEM were used during this sampling event in an attempt to reduce turbidity of
collected groundwater. Again while turbidity has been reduced, the EPA guideline in
SW-846 of five NTU could not be achieve without filtering. All results represent
analysis of filtered samples, as recommended in FMC's letter of September 29, 1995, to
which DEM has not responded.
If you have any questions, please contact me at 704/868-0806.
Ver truly yours,
Barbara E. tcl ie
HSE/Responsible Care Manager
lip cc: DEHNR/Mooresville

Type or Use a ball-point pen and press firmly. PERMIT NUMBER: (REQUIRED)
Facility Name l71 CY-P " Ll 11-4 1 V►"' -b1 v k S 16 Y" Non -Discharge W6k 000 t) �L-9 SEP 9997
Address l4iA.'t'l 1 � 5 NPDES
s a TYPE OF DISPOSAL OPERATION BEING MONITORED p
S•yililzi� /���1fvCounty (REQUIRED) Old!11 ` ll'7 AF
,yae
5 n• rt liJ 9l}��� W.:k lx+al
Well Location Nl; k A A-nA P`c.1' vi ? Z000 �' LIPM—Ab i reAJT Lagoon Septic Tanwgrlairr,,Fjeldt NCE
Well Identification Number Wa ` 2- A-KA 'Vt1— Well Depth 36 +57 Ft.
�` ,� Spray Field Subsurface Low -Pressure
Well Diameter Sample (Screened) Interval 62� a Ft. To 29' S Ft. Piping (LPP)
Depth to Water Level 18, 52-ft. below measuring point (before sampling) Land Application of Sludge
Measuring point is ft. above land surface —� Other
Gallons of water pumped/bailed before sampling i4 ® Rotary Distributor Zgc Ct y pr���1�a1ZR-
Field Analysis: pH 9+ Specific Conductance q� uMhos Temp. )�'1, `��°
C Odor Ml-i- Appearance 60
Date Sample Collected f 1� 9--+- Date Lab Sample Analyzed—T1-7-"— g12-j - - _
Laboratory Name Lft e` � j7L Z i E�f�r'+�A�1 `L� Certification No. 5-2-1
SAMPLES FOR METALS WERE COLLECTED UNFILTERED AND FIELD ACIDIFIED YES )L NO
IAA fU1 AL RRI, GURC LS
SIP 17 9997
COD
tJ4
m /l
Nitrite ( NO as N
NA-
m /I
r-a
Ni - Nickel
-1
Coliform: MF Fecal
N4
/100ml
Nitrate (NO3) as N
NA
mg/I
Pb - Lead r. ""`�'' ;Irrmg/I
Coliform: MF Total
NP'
/100ml
Phosphorus: Total
as P 11J
mg/I
Zn - Zinc �1ila-kt ? mg/I
(Note: Use MPN method for highly turbid
samples)
Al - Aluminum
C ®, 1-0
mg/I
Pesticides/Herbicides
`-n
Dissolved Solids: Total
'he 1
mg/I
Ba - Barium
IVA-
mg/I
(Specify Compounds)
IV -aa
pH (when analyzed)
S.2
units
Ca -Calcium
®�`L�
mg/I
ug/I
TOC
[4A
mg/I
Cd - Cadmium
NA
mg/I
= ug/I
Chloride
l u a
mg/I
Chromium: Total
mg/I
•• ug/I
Arsenic
IV
mg/I
Cu - Copper
— mg/I
Other (Specify Compounds and � �1
Grease and Oils
IUA
mg/I
Fe - Iron
mg/I
Concentration units) L.
Hardness: Total
Phenol
NA
mg/I
mg/I
Hg - Mercury
K - Potassium
NA
mg/I
mg/I
Fwi,e I a e ID on
IIVA,
NA►
Sulfate 4 8,0
_
mg/I
Mg - Magnesium
NA
mg/I
1,iT1411VM °' -2-o �
Specific Conductance
N
uMhos
Mn - Manganese
®
mg/I
Total Ammonia
N A-
mg/I
Na - Sodium
Nft
mg/I
_N%
TKN as N
10-
mg/I
N�► i
��-�
I CERTIFY THAT THIS REPORT IS TRUE AND ACCURATE.
Note:
Values should reflect dissolved and
n 1),1
colloidal concentrations. (see #3 on back)
re of Permed (br Authorized Agent*)
o-7 A7 See back for instructions.
Date ** Submit blue and yellow copies only to address above.
REV. 8/96

COLLECTION AND ANALYSIS OF GROUNDWATER SAMPLES
4. As per Title 15, North Carolina Administrative Code, Subchapter 2L, analytical procedures shall be in accordance with the. methods described in one of
the following publications, or by other methods approved beforehand by the Director, Division of Environmental
Management:
(a) Standard Methods for the Examination of Water and Wastewater, 16th Edition, 1985 and 171h Edition, 1989, published jointly by
American Public Health Association, American Water Works Association and Water Pollution Control Federation;
(b) Methods for Chemical Analysis of Water and Waste, 1979, U.S. Environmental Protection Agency publication number
EPA-600,14-79--020, as revised March, 1983;
(c) Test Methods for Evaluating Solid Wastes: Physical/Chemical Methods, 3rd Edition, 1986, U.S. Environmental Protection Agency
publication number SW-846;
(d) Test Procedures for the Analysis of Polluants Under the Clean Water Act, Federal Register Vol. 49, No. 209, 40 CFR Part 136,
October 26, 1984;
5. Measure n,d record the depth of water in the well prior to pumping or bailing any water from the well.
6. At least 3 volumes of water in the well should be pumped or bailed prior to collecting a sample for analysis. If the well is pumped/bailed dry before 3 well
volumes are removed, samples can be collected as soon as the well recovers to the point where enough water is available to collect your sample.
7. Determination for pH, Specific Conductance, temperature, odor and appearance must be rnade in the field on unfiltered samples when the sample is
collected.
8. Field equipment must be calibrated in accordance with recommendations by the manufacturer.
9. Samples must be filtered through a 0.45 micron filter immediately after collection when a dissolved analysis is required. (See#4. above)
'10. The sample container should be labeled at the time of collection with the facility name, well identification number and date and time collected.
11 ."Authorized agent" is any corporate officer or public official authorized by the company, corporation, or governmental body to sign official documents.

Uallons of water pumpecimaiieo Detore sampiing I C.-�
Field Analysis: pH 4, Specific Conductance 26 fib uMhos Temp. _ J'7 C Odor N--A�L Appearance W 561J
Date Sample Collected 6 i� 9 4" Date Lab Sample Analyzed alto
Laboratory Name L�Fk6l ie f'.�/�HH-1'�.9 e� Certification No. Z�
SAMPLES FOR METALS WERE COLLECTED UNFILTERED AND FIELD ACIDIFIED YES K NO
COD
NYC
mg/I
Coliform: MF Fecal
NA
/100m1
Coliform: MF Total
NA
/100ml
(Note: Use MPN method for highly turbid samples)
Dissolved Solids: Total
'131®
mg/I
pH (when analyzed)
units
TOC
mg/I
Chloride
45%9
mg/I
Arsenic
M4
mg/I
Grease and Oils
N
mg/I
Hardness: Total
N1
mg/I
Phenol
_ mg/I
Sulfate IU 6 U
mg/I
Specific Conductance
i%/4
uMhos
Total Ammonia
mg/I
TKN as N
>✓
mg/I
Nitrite (NO2) as N
NA
mg/I
Nitrate (NO3) as N
NA
mg/I
Phosphorus: Total as P
mg/I
Al - Aluminum
110
mg/I
Ba - Barium
NA
mg/I
Ca - Calcium
I S"1"
mg/I
Cd - Cadmium
NA
mg/I
Chromium: Total 4 o • ° �0
mg/I
Cu - Copper
/vA
mg/I
Fe - Iron
o i
mg/I
Hg - Mercury
mg/I
K - Potassium
IVA-
mg/I
Mg - Magnesium
P
mg/I
Mn - Manganese
2-5,�;
mg/I
Na - Sodium
/VA
mg/I
Ni - Nickel ro4
Ln
mg/I
Pb - Lead 64
-
mg/I
Zn - Zinc N
mg/I
Pesticides/Herbicides
...
C-F*
(Specify Compounds)
NA-
::m
_ Cp ug/I
=�
ug/I
r*a.
ug/I
Other (Specify Compounds and
N
Concentration units)
c�
r-. i rut r vM a . 'z 1h
NA-= (*Jr, i -qK✓ k,
I CERTIFY THAT THIS REPORT IS TRUE AND ACCURATE. Note: Values should reflect dissolved and
colloidal concentrations. (see #3 on back)
0 r See back for instructions.
TWinature of Permlttee (o uthorized Agent*) to ** Submit blue and yellow copies only to address above.
-59 REV. 8/96

1 - Samples should be analyzed as soon as possible after collection. SAMPLES WHICH ARE NOT ANALYSED WITHIN THE HOLDING TIME SPECI-
FIED FOR THE METHOD USED (SEE #4. BELOW) MUST BE DISCARDED AND NEW SAMPLES COLLECTED.
2. Metals Analyses: Use Standard Method 3030C for sample preparation (mercury excluded). DO NOT FILTER METALS SAMPLES IN THE FIELD
Unfiltered samples must be collected for metals, thee► field acidified with 5 ml concentrated nitric acid per liter of sample, and should be submitted to the
lab within 24 hours.
Sample preparation in the laboratory (extraction and filtration) must be completed within 72 hours of collection.
3. ANALYSES ARE TO BE MADE OF THE MOBILE CONSTITUENTS (DISSOLVED AS WELL AS COLLOIDAL) IN THE
GROUNDWATER, NOT THOSE THAT ARE A PART OF SEDIMENT ASSOCIATED WITH WELL QR SAMPLING PROEDUREE.
CHECK WITH YOUR LABORATORY ON PROPER PROCEDURES FOR SAMPLE COLLECTION AND PRESERVATION.
4. As per Title 15, North Carolina Administrative Code, Subchapter 2L, analytical procedures shall be in accordance with the methods described in one of
the following publications, or by other methods approved beforehand by the Director, Division of Environmental
Management:
(a) Standard Methods for the Examination of Water and Wastewater, 16th Edition, 1985 and 17th Edition, 1989, published jointlyjby
American Public Health Association, American Water Works Association and Water Pollution Control Federation;
(b) Methods for Chemical Analysis of Water and Waste, 1979, U.S. Environmental Protection Agency publication number
EPA-600/4-79-020, as revised March 1983;
(c) Test Methods for Evaluating Solid Wastes: Physical/Chemical Methods, 3rd Edition, 1986, U.S. Environmental Protection Agency
publication number SW-846;
(d) Test Procedures for the Analysis of Polluants Under the Clean Water Act, Federal Register Vol. 49, No. 209, 40 CFR Part 136,
October 26, 1984;
5. Measure and record the depth of water in the well prior to pumping or bailing any water from the well.
6. At least 3 volumes of water in the well should be pumped or bailed prior to collecting a sample for analysis. If the well is pumped/bailed dry before 3 well
volumes are removed, samples can be collected as soon as the well recovers to the point where enough water is available to collect your sample.
7. Determination for pH, Specific Conductance, temperature, odor and appearance must be made in the field on unfiltered samples when the sample is
collected.
8. Field equipment must be calibrated in accordance with recommendations by the manufacturer.
9. Samples must be filtered through a 0.45 micron filter immediately after collection when a dissolved analysis is required. (See #4. above)
1 O.The sample container should be labeled at the time of collection with the facility name, well identification number and date and time collected.
11. "Authorized agent" is any corporate officer or public official authorized by the company, corporation, or governmental body to sign official documents.

FMC Corporation
Lithium Division
Highway 161
Box 795
Bessemer City North Carolina 28016
704 868 5300 Fax [phone]
Certified Mail
Return Receipt Requested
September 9, 1997
North Carolina Department of Environment,
. Health, and Natural Resources
Division of Water Quality
Groundwater Section
P.O. Box 29535
Raleigh, NC 27626-0535
Re: Non -Discharge Permit No. WQ0008149
Groundwater Quality Monitoring - Compliance Report Forms
Dear Sir or Madam:
+MC
In accordance with the requirements of item No. 21 of the North Carolina Water Quality
Permit No. WQ0008149 for the Recycle System (kiln scrubber ponds) located at FMC
Corporation's Lithium Division facility in Bessemer City, FMC is submitting two
Compliance Monitor Forms (GW-59) for the sampling and analysis of groundwater
monitoring wells WQ-1 and WQ-7 (AKA W-7) on August 13, 1997. The methods for
sample digestion and analyses are consistent with those described in FMC's January 27,
1997 letter transmitting the monitoring results for the December 1996 sampling event.
Laboratory report sheets and chain of custody records are available upon request.
Modified sample collection procedures, as described in FMC's September 29, 1995 letter
to DEM were used during this sampling event in an attempt to reduce turbidity of
collected groundwater. Again while turbidity has been reduced, the EPA guideline in
SW-846 of five NTU could not be achieve without filtering. All results represent
analysis of filtered samples, as recommended in FMC's letter of September 29, 1995, to
which DEM has not responded.
If you have any questions, please contact me at 704/868-0806
Ve yours
/Barba?ra. Ritchie
Environmental Manager
cc: DEHNR/Mooresville

FMC Corporation
Lithium Division
Highway 161
Box 795
Bessemer City North Carolina 28016
704 868 5300 Fax [phone]
Certified Mail
Return Receipt Requested
September 9, 1997
North Carolina Department of Environment,
. Health, and Natural Resources
Division of Water Quality
Groundwater Section
P.O. Box 29535
Raleigh, NC 27626-0535
Re: Non -Discharge Permit No. WQ0008149
Groundwater Quality Monitoring - Compliance Report Forms
Dear Sir or Madam:
+MC
*N-C. D7`," v' Q,,7,
ENVIR0 Tr..,--'3'h 2,9V,, ,
'
& T,TAS iJ_'. _
MVlcir1p'
In accordance with the requirements of item No. 21 of the North Carolina Water Quality
Permit No. WQ0008149 for the Recycle System (kiln scrubber ponds) located at FMC
Corporation's Lithium Division facility in Bessemer City, FMC is submitting two
Compliance Monitor Forms (GW-59) for the sampling and analysis of groundwater
monitoring wells WQ-1 and WQ-7 (AKA W-7) on August 13, 1997. The methods for
sample digestion and analyses are consistent with those described in FMC's January 27,
1997 letter transmitting the monitoring results for the December 1996 sampling event.
Laboratory report sheets and chain of custody records are available upon request.
Modified sample collection procedures, as described in FMC's September 29, 1995 letter
to DEM were used during this sampling event in an attempt to reduce turbidity of
collected groundwater. Again while turbidity has been reduced, the EPA guideline in
SW-846 of five NTU could not be achieve without filtering. All results represent
analysis of filtered samples, as recommended in FMC's letter of September 29, 1995, to
which DEM has not responded.
If you have any questions, please contact me at 704/868-0806.
Ve trul yours
Barbara . Ritchie
Environmental Manager
cc: DEHNR/Mooresville
1

DIVISION OF WATER QUALITY
P.O. Box'
GROUNDWATER QUALITY MONITORING:
For additional forms RALEIGH.. NC
COMPLIANCE REPORT FORM please Write or. cau: (919),733
Type or Use a ball-point pen and press firmly.
Facility Name RAC C"' �ti�+tuf� �IViS1U/J
Address ti� I lit f
l^ (: Ig2j (o County^ _ .
Well Location -2cu
PERMIT NUMBER: (REQUI D)
Non -Discharge
NPDES
TYPE OF DISPOSAL OPERATION BEING MONITORED
fREOUIREDI
Lagoon
Septic Tank/Drain Field
Well Identification Number Well Depth "�97 Ft. Spray Field Subsurface Low -Pressure
Well Diameter A t V\ Sample (Screened) Interval L?i 5— Ft. To 4 1.5 Ft. Piping (LPP)
Depth to Water Level 3`f • 3 '_' ft. below measuring point (before sampling) Land Application of Sludge
k_ Other
Measuring point is a?.S ft. above land surface Rotary Distributor p_�'�yct�z 1w91'��Lli�?rc�;
Gallons of water pumped/bailed before sampling I
Field Analysis: pH `F, Specific Conductance a-S}b uMhos Temp. °C Odor ru°�N� Appearance �'�' '!�
Date Sample Collected 8 i3 -4- Date Lab Sample Analyzed 81 to/ q ';?' MN `J 17
Laboratory Name L NC ttS 2 L�&k't9-TV%Zl C5 Certification No. Z�
cAnnDI Gc DnR Mr-TAI c wi=RF C ni I FCTFD UNFILTERED AND FIELD ACIDIFIED YES K NO
COD
NA
mg/I
Coliform: MF Fecal
r"Ar
/100ml
Coliform: MF Total
N%
/100ml
(Note: Use MPN method for highly turbid samples)
Dissolved Solids: Total
0310
mg/I
pH (when analyzed)
`�,-49
units
TOC
T'
mg/I
Chloride
s 9
mg/I
Arsenic
N4
mg/I
Grease and Oils
N6
mg/I
Hardness: Total
Nt�
mg/I
Phenol
tvA-
_ mg/I
Sulfate I to 3 o
mg/I
Specific Conductance
Pv4
uMhos
Total Ammonia
tin
mg/I
TKN as N
N
mg/I
Nitrite (NO2) as N
N4
_ mg/I
Nitrate (NO3) as N
rJA
mg/I
Phosphorus: Total as P
I"
mg/I
Al - Aluminum
lid
mg/I
Ba - Barium
NA
mg/I
Ca - Calcium
151-
mg/I
Cd - Cadmium
NA
mg/I
Chromium: Total 0 . ° 30
mg/I
Cu - Copper
/v.A
mg/I
Fe - Iron
0,110
mg/I
Hg - Mercury
N4
mg/I
K - Potassium
NA
mg/I
Mg -Magnesium
EA-
mg/I
Mn - Manganese
2b.i6
mg/I
Na - Sodium
/VA
mg/I
Ni - Nickel M4 mg/I
Pb - Lead N4 mg/I
Zn - Zinc N mg/I
Pesticides/Herbicides
(Specify Compounds)
N/k ug/I
ug/I
ug/I
Other (Specify Compounds and
Concentration units)
r�vrn I.D 2- 1,Y 3 M 1 L
I CERTIFY THAT THIS REPORT IS TRUE AND ACCURATE. Note: Values should reflect dissolved and
colloidal concentrations. (see #3 on back)
?� ! See back for instructions.
i 'nature of Permlttee (o uthorized Agent*) to ** Submit blue and yellow copies only to address above.
W-59 REV. 8/96

GROUNDWATER QUALITY MONITORING:
COMPLIANCE REPORT FORM
Facility Name
Address
DIVISION OF.WATER.i
F
For additional forms RALE
please write or call:
Type or Use a ball-point pen and press firmly.
(7,,3 0 _ Li 'r-4, /-,A^ b IV k s 16 -/
i26-0578
21
PERMIT NUMBER: (REQUIRED)
Non -Discharge W&kye),D 4 3I
NPDES
TYPE OF DISPOSAL OPERATION BEING MONITORED
(REQUIRED)
Well Location NI✓ l,0eJyMI'c_ Of' L" V I-Ftl T —r'" rryl�TIJr c•" Layuun
Well Identification Number WR —Z /> KA W -_�' Well Depth 3b i S+ Ft.
� � Spray Field
Well Diameter „
_ 2" Sample (Screened) Interval 426, Ft. To 9915 Ft.
Septic Tank/Drain Field
Subsurface Low -Pressure
Piping (LPP)
Depth to Water Level /131 52-ft. below measuring point (before sampling) Land Application of Sludge
Other
Measuring point is 1,47 ft. above land surface Rotary
Gallons of water pumped/bailed before sampling �` Distributor
Field Analysis: pH y I Q Specific Conductance � uMhos Temp. ic?, S °C Odor M� T419A- � Appearance
Date Sample Collected 13) 9 -4- Date Lab Sample Analyzed
Laboratory Name L►4NSI��T� L'2 �� 1 `L Certification No. E;7-1
SAMPLES FOR METALS WERE COLLECTED UNFILTERED AND FIELD ACIDIFIED YES X NO
COD
N4
mg/I
Coliform: MF Fecal
NA
/100ml
Coliform: MF Total
NA'
/100ml
(Note: Use MPN method for highly turbid samples)
Dissolved Solids: Total
`t'te 1
mg/I
pH (when analyzed)
5. Z 3
units
TOC
PIA
mg/I
Chloride
I u
mg/I
Arsenic
N4
mg/I
Grease and Oils
N4
mg/I
Hardness: Total
1VA
mg/I
Phenol
NA
_ mg/I
Sulfate G
I.
mg/I
Specific Conductance
►j4
uMhos
Total Ammonia
N k-
mg/I
TKN as N
tdA-
mg/I
Nitrite (NO2) as N
NA
_ mg/I
Nitrate (NO3) as N
NA
mg/1
Phosphorus: Total
as P !"JA-
mg/I
Al - Aluminum
C 0,-z0
mg/I
Ba - Barium
IvA-
mg/I
Ca - Calcium
1-0
mg/1
Cd - Cadmium
N4
mg/l.
Chromium: Total
0, C)`50
mg/I
Cu - Copper
N&
mg/I
Fe - Iron
<o s 1 1)
mg/I
Hg - Mercury
raA
mg/I
K - Potassium
IVA7
mg/I
Mg - Magnesium
NA
mg/I
Mn - Manganese
o ou3`L
mg/I
Na - Sodium
NP
mg/1
Ni - Nickel
%g1r
mg/1
Pb - Lead
p V+
mg/I
Zn - Zinc
1L11-
mg/I
Pesticides/Herbicides
(Specify Compounds)
ug/I
ug/I
ug/I
Other (Specify Compounds
and
Concentration units)
(^ wy o-10 5, --� 0, 10 f2,
i,iTH1%141
o -,?-ac
CI
I CERTIFY THAT THIS REPORT IS TRUE AND ACCURATE. Note: Values should reflect dissolved and
f colloidal concentrations. (see #3 on back)
L3
See back for instructions.
Si a ure of Perrh' ee ( r uthorized Agent*) Date ** Submit blue and yellow copies only to address above.
,:
G -59 REV. 8/96

t - ` _` FMC Corporation
Lithium Division
Highway 161
Box 795
Bessemer City North Carolina 28016
704 868 5300 Fax [phone]
Certified Mail
Return Receipt Requested
June 12, 1997
North Carolina Department of Environment,
Health, and Natural Resources
Division of Water Quality
Groundwater Section
P.O. Box 29535
Raleigh, NC 27626-0535
Re: Non -Discharge Permit No. WQ0008149
Groundwater Quality Monitoring - Compliance Report Forms
Dear Sir or Madam:
J 0;
In accordance with the requirements of item No. 21 of the North Carolina Water Quality Permit No.
WQ0008149 for the Recycle System (kiln scrubber ponds) located at FMC Corporation's Lithium Division
facility in Bessemer City, FMC is submitting two Compliance Monitor Forms (GW-59) for the sampling
and analysis of groundwater monitoring wells WQ-1 and WQ-7 (AKA W-7) on April 17, 1997. The
methods for sample digestion and analyses are consistent with those described in FMC's January 27, 1997
letter transmitting the monitoring results for the December 1996 sampling event. Laboratory report sheets
and chain of custody records are available upon request.
Please note that FMC has changed both the contract firm which collects samples and the analytical
laboratory for the 1997 sampling program. Due to some transitional miscommunication, the sample results
reported here represent analysis of unfiltered, field acidified samples, which is not consistent with the
recommendations and sampling protocols described in FMC's September 29, 1995 letter recommending
analysis of filtered samples, due to high turbidity levels. Further, again resulting from a misunderstanding
in contractor transition, the analytical laboratory did not expedite sample turn around which resulted in the
slight delay in reporting of results. Lastly, pH is,reported here as measured in the field and was not
analyzed in the laboratory. These issues are expected to be corrected in advance of the next sampling event
scheduled for August 1997. -
If you have any questions, or require additional information, please contact me at 704/868-0806.
truly urs,
bara tc ie
Enviro
ntal Manager
cc: B. Keith Overcash - DEHNR/Mooresville

Well Location 6oVT,)iiaK) E)h l"16-N `.y l Lagoon Septic Tank/Drain Field
Well Identification Number ` 1 Well Depth G S _Ft.
Spray Field Subsurface Low -Pressure
Well Diameter sR I 1,J Sample (Screened) Interval cf . =J Ft. To • q , !-, Ft. Piping (LPP)
Depth to Water Level 30 1-2-1 ft. below measuring point (before sampling) Land Application of Sludge
Measuring point is 2 5 ft. above land surface 7_ Other
Gallons of water pumped/bailed before sampling I V Rotary Distributor --- -- c'r.; jMPcu.t:_)111 IN
Field Analysis: pH 10 Specific Conductance A' L) uMhos Temp. )CO oC Odor 00'2- Appearance
Date Sample Collected 'fi I �' Date Lab Sample Analyzed -
Laboratory Name Certification No. S Z 1
SAMPLES FOR METALS WERE COLLECTED UNFILTERED AND FIELD ACIDIFIED .K YES _-;X— NO
COD
N 4
mg/1
Coliform: MF Fecal
tjh
/100ml
Coliform: MF Total
Nh
/100ml
(Note: Use MPN method for highly turbid samples)
Dissolved Solids: Total
a5AO
mg/I
pH (when analyzed)
N4
units
TOC
Nk
mg/I
Chloride
q I, S
mg/I
Arsenic
N.4
mg/I
Grease and Oils
(14V
mg/I
Hardness: Total
Iv N
mg/I
Phenol
N A
mg/I
Sulfate
i --Ir 0 0
mg/I
Specific Conductance
N4
uMhos
Total Ammonia
NN
mg/I
TKN as N
K "k
mg/I
Nitrite (NO2) as N
N.k
mg/I
Nitrate (NO3) as N
WN
mg/I
Phosphorus: Total as P N k
mg/I
Al - Aluminum
3
mg/I
Ba - Barium
NA
mg/I
Ca - Calcium
mg/I
Cd - Cadmium
N
mg/I
Chromium: Total
C), e;3y
mg/I
Cu - Copper
N4
mg/I
Fe - Iron
1. ZI
mg/I
Hg - Mercury
N4
mg/I
K - Potassium
Nf\
mg/I
Mg - Magnesium
N
mg/I
Mn - Manganese
-,2q �
mg/I
Na - Sodium
NN_
mg/l
I CERTIFY THAT THIS REPORT IS TRUE AND ACCURATE.
re of Permittee
uthorized Agent*)
1Z �%
Date
Ni - Nickel k, &, mg/I
Pb - Lead N mg/I
Zn - Zinc mg/I
Pesticides/Herbicides
(Specify Compounds)
IN-
Other (Specify Compounds and
Concentration units)
Nk- - ►,jc i APh"i 12-z6
ug/I
ug/I
ug/I
Note: Values should reflect dissolved and
colloidal concentrations. (see #3 on back)
* See back for instructions.
** Submit blue and yellow copies only to address above.
REV. 11 /95

DIUI510N QF ENVIRONMENTAL MANAGEMENT -GROUNDWATER SECTION
GROUNDWATIER
QUALITY MONITORING: For. additional torms
p.o. Box 2957s
; RALEIGH,;NC 27t26-(1578.
COMPLIANCrE REPORT FIRM pleasewrne,orcau:
[phone]
Type or Use a ball-point pen and press firmly.
PERMIT NUMBER: (REQUIRED) u
Non ���� ���'���' )L,6f
Facility Name f-VU1C Cc.0-P - Ll171106 151C' iy
-Discharge
Address W I L"
NPDES
TYPE OF DISPOSAL OPERATION BEING MONITORED
2-9)OUr, i ly�
CountY �►'
Well Location NE L'c�,'j•tYZ ELF IUNIR "J ? ZC1CG i-t Uefjir''.d lc'► +-
(REQUIRED) Lagoon SepticTank/Drain Field
Well Identification Number 'N& Z AY�rr IN' Well Depth dbe. 7) Ft.
Spray Field Subsurface Low -Pressure
Well Diameter 0 ►t Sample (Screened) Interval c2t 12-I Ft. To ALI,Z Ft.
Piping (LPP)
Depth to Water Level I �' "L ft. below measuring point (before sampling)
Land Application of Sludge
Measuring point is 1-9 ft. above land surface
�_ utner
Rotary Distributor �L'GCI.(t`' (`z. I A-t'{�(?i?Nt%111 �i•l
Gallons of water pumped/bailed before sampling
Field Analysis: pH �' , k Specific Conductance cllo uMhos Temp. 1-1- °C
Odor c F'` Appearance 0061 b -
Date Sample Collected q `►}l—Date Lab Sample Analyzed 5 f Z I I q-q
Laboratory Name iNc,�11Ji2 L-660e_i)Ty2' ES
Certification No.
SAMPLES FOR METALS WERE COLLECTED UNFILTERED AND FIELD ACIDIFIED YES NO
COD
N,
mg/I
Coliform: MF Fecal
N'ti
/100ml
Coliform: MF Total
N k
/100ml
(Note: Use MPN method for highly
turbid samples)
Dissolved Solids: Total
'-:� �u
mg/1
pH (when analyzed)
Nh
units
TOC
N /�
mg/I
Chloride
IQ. a
mg/I
Arsenic
N-/\
mg/I
Grease and Oils
Nk-
mg/I
Hardness: Total
►JN
mg/I
Phenol
NN
mg/I
Sulfate
i415
mg/I
Specific Conductance
Nk
uMhos
Total Ammonia
NN
mg/I
TKN as N
Nor
mg/I
Nitrite (NO2) as N
N4
mg/I
Nitrate (NO3) as N
N4
mg/I
Phosphorus: Total as P ISA
mg/I
Al - Aluminum
012-0
mg/1
Ba - Barium
Nk
mg/I
Ca - Calcium
0 � 2- `
mg/I
Cd - Cadmium
N
mg/I
Chromium: Total
61, n 0
mg/1
Cu - Copper
NN_
mg/I
Fe - Iron
0, b 0
mg/I
Hg - Mercury
NN
mg/I
K - Potassium
N�
mg/I
Mg - Magnesium
fi Ar
mg/1
Mn - Manganese
o , 0]�'
mg/I
Na - Sodium
N k
mg/I
I CERTIFY THAT THIS REPORT IS TRUE AND ACCURATE.
A
itte� 3-0
hature of Perme(9
Authorized
Agent*) Dat
GW-59 REV. 11 /95
Ni - Nickel 1j'h mg/I
Pb - Lead /,%A- mg/1
Zn - Zinc /%,, mg/I
Pesticides/Herbicides
(Specify Compounds)
ug/I
ug/I
ug/I
Other (Specify Compounds and
Concentration units)
e 1 F:1 %r Q
Nk =
Note: Values should reflect dissolved and
colloidal concentrations. (see #3 on back)
* See back for instructions.
** Submit blue and yellow copies only to address above.

GROUNDWATER QUALITY IVIO For
Well Location `JQL! , lii_ ►) K 01MAJ 13oi-.uhs"W?,Li OF (;1 LN
PERMIT NUMBER: (REQUIRED) /� ; q
Non -Discharge VVQ C W_)Q iI f oI JI IVY 21 C
NPDES
TYPE OF DISPOSAL OPERATION BEING MONITORED. : -
(REQUIRED) r.• s
Lagoon Septic Tank/Drainki -Fie� Jtr;
Well Identification Number W a - 1 Well Depth G , 5— _Ft.
Spray Field Subsurface Low -Pressure
Well Diameter�Sample (Screened) Interval 6I. t' Ft. To (, S Ft. Piping (LPP)
Depth to Water Level 30 _ft. below measuring point (before sampling) Land Application of Sludge
Measuring point is Q 1 ft. above land surface —X Other
CL� �MPoz,a��1
Gallons of water pumped/bailed before sampling 1
Rotary Distributor PAC Ilv;
Field Analysis: pH 5 • k' Specific Conductance � uMhos Temp. Rio °C Odor e(J`L Appearance � � -) � `— �D ti-�► LDS
Date Sample Collected R 1 I i! 61-4- Date Lab Sample Analyzed 791
Laboratory Name Certification No. 5 l
SAMPLES FOR METALS WERE COLLECTED UNFILTERED AND FIELD ACIDIFIED YES -0-- NO
COD
N h
mg/I
Coliform: MF Fecal
NZ
/100ml
Coliform: MF Total
9A
/100ml
(Note: Use MPN method for highly
turbid samples)
Dissolved Solids: Total
095�o
mg/1
pH (when analyzed)
h%A
units
TOC
Ph-
mg/I
Chloride
4I, `'
mg/I
Arsenic
N'A
mg/I
Grease and Oils
NN
mg/I
Hardness: Total
K h
mg/I
Phenol
N N
mg/I
Sulfate
i __"0 0
mg/I
Specific Conductance
N4
uMhos
Total Ammonia
NPC
mg/I
TKN as N
>"t-
mg/I
Nitrite (NO2) as N
NA
mg/I
Nitrate (NO3) as N
NN
mg/1
Phosphorus: Total as P N
mg/1
Al - Aluminum
�q• _+3
mg/I
Ba - Barium
NA
mg/I
Ca - Calcium
3__�-
mg/I
Cd - Cadmium
tU'k
mg/1
Chromium: Total
0, 030
mg/I
Cu - Copper
N.4
mg/I
Fe - Iron
1. ZI
mg/I
Hg - Mercury
eU_A
mg/I
K - Potassium
N;At
mg/I
Mg - Magnesium
N
mg/I
Mn - Manganese
aq
mg/I
Na - Sodium
Nhr
mg/I
I CERTIFY THAT THIS REPORT IS TRUE AND ACCURATE.
ature of Permittee
uthorized Agent*)
6// o%
Date
Ni - Nickel �J
mg/I
Pb - Lead f✓
mg/I
Zn - Zinc NAr
mg/I
Pesticides/Herbicides
---�
(Specify Compounds)'!:
NA-
_
-,`fig/I
Other
- pug/I
(Specify Compounds and
Concentration units)
I' I- UOP-A b E_ 31 s'h
LP
s—
n%k - rjc 1 A-P kt_. { -�:'zl
Note: Values should reflect dissolved and
colloidal concentrations. (see #3 on back)
See back for instructions.
** Submit blue and yellow copies only to address above.
-59 REV. 11/95

1. Samples should be analyzed as soon as possible after collection. SAMPLES WHICH ARE NOT ANALYSED WITHIN THE HOLDING TIME SPECI-
FIED FOR THE METHOD USED (SEE #4. BELOW) MUST BE DISCARDED AND NEW SAMPLES COLLECTED.
2. Metals Analyses: Use Standard Method 3030C for sample preparation (mercury excluded). 90 NOT FILIER -METALS SAMPLES IN _THEFIELD !!
Unfiltered samples must be collected for metals, then field acidified with 5 ml concentrated nitric acid per liter of sample, and should be submitted to the
lab within 24 hours.
Sample preparation in the laboratory (extraction and filtration) must be completed within 72 hours of collection.
4. As per Title 15, North Carolina Administrative Code, Subchapter
oter 2L, analytical procedures shall be in accordance with the methods described in one of
the 'following publications, or by other methods approved beforehand by the Director, Division of Environmental
Management:
(a) Standard Methods for the Examination of Water and Wastewater, 16th Edition, 1985 and 17th Edition, 1989, published jointly by
American Public Health Association, American Water Works Association and Water Pollution Control Federation;
(b) Methods for Chemical Analysis of Water and Waste, 1979, U.S. Environmental Protection Agency publication number
EPA-600/4-79-020, as revised March 1983;
(c) Test Methods for Evaluating Solid Wastes: Physical/Chemical Methods, 3rd Edition, 1986, U.S. Environmental Protection Agency
publication number SW-846;
(d) Test Procedures for the Analysis of Polluants Under the Clean Water Act, Federal Register Vol. 49, No. 209, 40 CFR Part 136,
October 26, 1984;
5. Measure and record the depth of water in the well prior to pumping or bailing any water from the well.
6. -At leasi.3 voiumes of water in the well should be pumped or bailed prior to collecting a sample for analysis. If the well is pumped/bailed dry before 3 well
volume-s, are removed, samples can be collected as soon as the well recovers to the point where enough water is available to collect your sample.
t
7. Determination for pH, Specific Conductance, temperature, odor and appearance must be made in the field on unfiltered samples when the sample is -
collected.
8. Field equipment must be calibrated in accordance with recommendations by the manufacturer.
9. Samples must be filtered through a 0.45 micron filter immediately after collection when a dissolved analysis is required. (See #4. above)
10. The sample container should be labeled at the time of collection with the facility name, well identification number and date and time collected.
11 ."Authorized agent" is any corporate officer or public official authorized by the company, corporation, or governmental body to sign official documents.

DIVISION OF ENVIRONMENTAL MANAGEMENT- GROUNDWATER SECTIOI
well Location L,.yic-p-a - Eli- f ,Lt U LI= J `I —U." -%-r V�ny d-c.i is vx , Lagoon Septic Tank/Drain Field
Well Identification Number 1n%6 Z. AY�� IN'--1 Well Depth d&.yl Ft.
Spray Field Subsurface Low -Pressure
Well Diameter Q Iv\ Sample (Screened) Interval at 1ZI Ft. To Ab' -7) Ft. Piping (LPP)
Depth to Water Level Itn-0 - ft. below measuring point (before sampling) Land Application of Sludge
Measuring point is 11q ft. above land surface _ —' Other
Gallons of water pumped/bailed before sampling Rotary Distributor ��Cc,f CZ� 0u'Pooli>1af
Field Analysis: pH -�' , il Specific Conductance % uMhos Temp. C Odor oNy Appearance �-U2,'bi b -- is, 30 I- I G-5
Date Sample Collected IV-- Date Lab Sample Analyzed SiZI I
Laboratory Name W NcA--5Al2 &A600-rk TZ RA E S Certification No. 5
SAMPLES FOR METALS WERE COLLECTED UNFILTERED AND FIELD ACIDIFIED AYES NO
COD
N'k
mg/I
Coliform: MF Fecal
Na
/100ml
Coliform: MF Total
N k
/100ml
(Note: Use MPN method for highly
turbid samples)
Dissolved Solids: Total
A—, ?)u
mg/I
pH (when analyzed)
ivN
units
TOC
N ter
mg/I
Chloride
10, a
mg/I
Arsenic
N\
mg/I
Grease and Oils
NAk
mg/I
Hardness: Total
AJN
mg/I
Phenol
PN
mg/I
Sulfate
14. 5
mg/I
Specific Conductance
Nk-
uMhos
Total Ammonia
NA-
mg/I
TKN as N
Nk
mg/I
Nitrite (NO2) as N
N4
mg/I
Nitrate (NO3) as N
N!k
mg/I
Phosphorus: Total as P Mik
mg/I
Al - Aluminum
012,0
mg/I
Ba - Barium
Nk
mg/I
Ca - Calcium
6). i 0
mg/I
Cd - Cadmium
NN
mg/I
Chromium: Total
mg/I
Cu - Copper
mg/I
Fe - Iron
0. E50
mg/I
Hg - Mercury
(ik
mg/I
K - Potassium
NIV-
mg/I
Mg - Magnesium
Mv
mg/I
Mn - Manganese
0, 0�5 1:
mg/I
Na - Sodium
N /k
mg/I
I CERTIFY THAT THIS REPORT IS TRUE AND ACCURATE.
�J
'.S' hature of Perm ittee (5 Authorized Agent*) Dat
,GW-59 REV. 11/95
Ni - Nickel
114
- : mg/I
Pb - Lead
N
-` mg/I
Zn - Zinc
Pesticides/Herbicides=�
(Specify Compounds)
--
=r--'
ug/I
ug/I
---
: ug/I
Other (Specify Compounds
and
Concentration units)
rv=-
W
►
0 NIA I -
I1-111i
C)-Z0
r`,�
Note: Values should reflect dissolved and
colloidal concentrations. (see #3 on back)
* See back for instructions.
** Submit blue and yellow copies only to address above.

1 . Samples should be analyzed as soon as possible after collection. SAMPLES WHICH ARE NOT ANALYSED WITHIN THE HOLDING TIME SPECI-
FIED FOR THE METHOD USED (SEE 94. BELOW) MUST BE DISCARDED AND NEW SAMPLES COLLECTED.
2. Metals Analyses: Use Standard Method 3030C for sample preparation (mercury excluded). DO NOT FILTER METALS SAMPLES IN THEFIELD III
Unfiltered samples must be collected for metals, then field acidified with 5 ml concentrated nitric acid per liter of sample, and should be submitted to the
lab within 24 hours.
Sample preparation in the laboratory (extraction and filtration) must be completed within 72 hours of collection.
=own==
4. As per Title 15, North Carolina Administrative Code, Subchapter 2L, analytical procedures shall be in accordance with the methods described in one of
the following publications, or by other methods approved beforehand by the Director, Division of Environmental
Management:
(a) Standard Methods for the Examination of Water and Wastewater, 16th Edition, 1985 and 17th Edition, 1989, published jointly by
American Public Health Association, American Water Works Association and Water Pollution Control Federation;
(b) Methods for Chemical Analysis of Water and Waste, 1979, U.S. Environmental Protection Agency publication number
EPA-600/4-79-020, as revised March 1983;
(c) Test Methods for Evaluating Solid Wastes: Physical/Chemical Methods, 3rd Edition, 1986, U.S. Environmental Protection Agency
publication number SW-846;
(d) Test Procedures for the Analysis of Polluants Under the Clean Water Act, Federal Register Vol. 49, No. 209, 40 CFR Part 136,
October 26,1984,-
5. Measure:and record the depth of water in the well prior to pumping or bailing any water from the well.
6. At least 3 volumes of water in the well should be pumped or bailed prior to collecting a sample for analysis. If the well is pumped/bailed dry before 3 well
volumes are removed, samples can be collected as soon as the well recovers to the point where enough water is available to collect your sample.
7. Determination for pH, Specific Conductance, temperature, odor and appearance must be made in the field on unfiltered samples when the sample is
collected.
8. Field equipment must be calibrated in accordance with recommendations by the manufacturer.
9. Samples must be firlered through a 0.45 micron filter immediately after collection when a dissolved analysis is required. (See #4. above)
1 O.The sample container should be labeled at the time of collection with the facility name, well identification number and date and time collected.
1 l."Authorized agent" is any corporate officer or public official authorized by the company, corporation, or governmental body to sign official documents.

I
FMC Corporation
Lithium Division
Highway 161
Box 795
Bessemer City North Carolina 28016
704 868 5300 Fax [phone]
+MC
Certified Mail
Return Receipt Requested
June 12, 1997
North Carolina Department of Environment,
Health, and Natural Resources
Division of Water Quality
Groundwater Section
P.O. Box 29535
Raleigh, NC 27626-0535
Re: Non -Discharge Permit No. WQ0008149
Groundwater Quality Monitoring - Compliance Report Forms
Dear Sir or Madam:
In accordance with the requirements of item No. 21 of the North Carolina Water Quality Permit No.
WQ0008149 for the Recycle System (kiln scrubber ponds) located at FMC Corporation's Lithium Division
facility in Bessemer City, FMC is submitting two Compliance Monitor Forms (GW-59) for the sampling
and analysis of groundwater monitoring wells WQ-1 and WQ-7 (AKA W-7) on April 17, 1997. The
methods for sample digestion and analyses are consistent with those described in FMC's January 27, 1997
letter transmitting the monitoring results for the December 1996 sampling event. Laboratory report sheets
and chain of custody records are available upon request.
Please note that FMC has changed both the contract firm which collects samples and the analytical
laboratory for the 1997 sampling program. Due to some transitional miscommunication, the sample results
reported here represent analysis of unfiltered, field acidified samples, which is not consistent with the
recommendations and sampling protocols described in FMC's September 29, 1995 letter recommending
analysis of filtered samples, due to high turbidity levels. Further, again resulting from a misunderstanding
in contractor transition, the analytical laboratory did not expedite sample turn around which resulted in the
slight delay in reporting of results. Lastly, pH is reported here as measured in the field and was not
analyzed in the laboratory. These issues are expected to be corrected in advance of the next sampling event
scheduled for August 1997.
If you have any questions, or require additional information, please contact me at 704/868-0806.
V truly urs,
bara E. tc ie
Enviro ntal Manager
cc: B. Keith Overcash - DEHNR/Mooresville
M
Aj

.� 14.C. DEFT- OF
pa NATURAL RE3®URGE
FMC Corporation
OWN 2 9 1997
Lithium Division
Highway 161
Box 795 ONSH OF E� dl
Bessemer City North Carolina 28016 #QMSgUE offm
704 868 5300 Fax [phone]
CERTIFIED MAIL
+MC
RETURN RECEIPT REQUESTED
January 27, 1997
North Carolina Division of Environmental Management
Groundwater Section
P.O. Box 29535
Raleigh, NC 27626-0535
Re: Non -Discharge Permit No. WQ0008149
Groundwater Quality Monitoring - Compliance Report Forms
Dear Sir or Madam:
In accordance with the requirements of item No. 21 of the
North Carolina Water Quality Permit No. WQ0008149 for -the
Recycle System (kiln scrubber ponds) located at FMC
Corporation's Lithium Division facility in Bessemer City, FMC
is submitting two Compliance Monitor Forms (GW-59) for the
sampling and analysis of groundwater monitoring wells WQ-1
and WQ-7.(A.K.A. W-7) on December 11, 1996. The results
reported here for aluminum, chromium, iron, lithium and
manganese were obtained using method 3030C in Standard
Methods, 17th edition for digestion and EPA method 200.7 for
analysis. The results for fluoride were obtained using EPA
method 340.2; for TDS using EPA method 160.1; for chloride
using EPA method 325.2; for sulfate using EPA method 375.4,
and for calcium using EPA method 200.7. Laboratory report
sheets and chain of custody records are available upon
request.
Modified sample collection procedures, as described in FMC's.
September 29, 1995 letter to DEM, were used again during this
sampling event in attempts to reduce the turbidity of
collected groundwater. Again, while turbidity has been
reduced, the EPA guideline in SW-846 of five NTU could not
been achieved without filtering. All results represent
analysis of filtered samples, as recommended in FMC's letter
of September 29, 1995, to which DEM has not replied.
If you have any questions, or require additional information,
please contact me at 704/868-0806.
Ver tru y you s ,
Barbara Ritchie
Environmental Manager
cc: Bo Keith Overcash - DEHNR/Mooresville
,,��

W
Facility Name
Address
PERMIT NUMBER: (REQUIRED)
O Q�)
Non -Discharge
NPDES
TYPE OF DISPOSAL OPERATION BEING MONITORED
(REQUIRED)
Well Location 5ci N Rt U t4 w 13�vN►�lt✓t N Or' K 11-N (�D i�DS Lagoon Septic TanWDrain Field
Well Identification Number Wq —I Well Depth �1. 5 Ft. Spray Field Subsurface Low -Pressure
Well Diameter 12 10 Sample (Screened) Interval 9,t; Ft. To 42, Ft. Piping (LPP)
Depth to Water Level 3iy - o I ft. below measuring point (before sampling) Land Application of Sludge
�C__ Other
Measuring point is el 5 ft. above land surface Rotary Distributor Rpct�CLi /fN�PovN� fYlc
Gallons of water pumped/bailed before sampling (a'_1"
Field Analysis: pH 4,50 S ecific Conductance �rJ O uMhos Temp. I Cy °C Odor NoN� Appearance
Date Sample Collected ► L Date Lab Sample Analyzed ►:h,,11'— i
Laboratory Name--��C E�j—"tom O^� Certification No. Z
SAMPLES FOR METALS WERE COLLECTED UNFILTERED AND FIELD ACIDIFIED YES /As— NO
Type or Use a ball-point pen and press firmly.
COD
f" A
mg/I
Coliform: MF Fecal
*'4
/100ml
Coliform: MF Total
NA-
/100ml
(Note: Use MPN method for highly
turbid samples)
Dissolved Solids: Total
I�,5oo
mg/I
pH (when analyzed)
4.1-i�)
units
TOC
N k-
mg/I
Chloride
1:7L
mg/I
Arsenic
N k
mg/I
Grease and Oils
►` N
mg/ I
Hardness: Total
N A
mg/I
Phenol
N N_
m /l
Sulfate
) quo
mg/I
Specific Conductance
NA,
uMhos
Total Ammonia
N&
. mg/I
TKN as N
N A-
mg/I
Nitrite (NO2) as N
1 N A
mg/I
Nitrate (NO,,) as N
NA
mg/I
Phosphorus: Total as P Nk
mg/I
Al - Aluminum
`7, q
mg/I
Ba - Barium
KIA-
mg/I
'Ca - Calcium
/o o
mg/I
Cd - Cadmium
NA-
mg/I
Chromium: Total
D, o I o
mg/I
Cu - Copper
fJ tv
mg/l
Fe - Iron
< 01 o S o
mg/I
Hg - Mercury
N4-
mg/I
K - Potassium
NA-
mg/I
Mg - Magnesium
mg/I
Mn - Manganese
mg/I
Na - Sodium
l-
mg/I
Ni - Nickel
N & mg/I
Pb - Lead
mg/I
Zn -Zinc
/N mg/I
Pesticides/Herbicides
(Specify Compounds)
lk-
Other (Specify Compounds and
Concentration units)
Fw0(2_A b F 0,2
L crii )v ryl 1,4. ca M
ug/I
ug/I
ug/I
I CERTIFY THAT THIS REPORT IS TRUE AND ACCURATE. Note: Values should reflect dissolved and
/) 4 - / colloidal concentrations. (see #3 on back)
ature of
(or Authorized Agent*)
41 v1 1 1 * See back for instructions.
/ ate ** Submit blue and yellow copies only to address above.
W-59 REV. 11/95

Type or Use a
Facility Name FM C C-.(,pp - Li-na ) i
Address I�VW `4 1101_,,—I?>Q 4--
PERMIT NUMBER: (REQUIRED)
Non -Discharge W Gkoc702149
NPDES
TYPE OF DISPOSAL OPERATION BEING MONITORED
(REQUIRED)
Well Location Lim i 9- OF �� > 'LUQo t`�� U PC- a(+D I f-N 1— Lagoon Septic Tank/Drain Field
Well Identification Number W Gi 2- 11KA Vy --1- Well Depth 39 c 5 Ft. Spray Field Subsurface Low -Pressure
Well Diameter s2 Id Sample (Screened) Interval a$15— Ft. To 3b, 5- Ft. Piping (LPP)
Depth to Water Level 188 I ft. below measuring point (before sampling) Land Application of Sludge
A Other
Measuring point is I. 9 ft. above land surface Rotary Distributor po t)ND r)14 t✓T
Gallons of water pumped/bailed before sampling 3;::V
o N � Appearance 1 1. uC fi I D I j'� 8i'i NT ley
Field Analysis: pH � Sp1ecific Conductance � uMhos Temp. C Odor 1--
Date Sample Collec►Pr1 � 11 1-T!e Date Lab Sample Analyzed
Laboratory Name �A'�+-`1'h �L Certification No. —
SAMPLES FOR METALS WERE COLLECTED UNFILTERED AND FIELD ACIDIFIED YES �A,— NO
nt pen and press firmly.
11 VASICJ\j
COD
NA
mg/I
Coliform: MF Fecal
NA
/100ml
Coliform: MF Total
N/k
/100ml
(Note: Use MPN method for highly turbid samples)
Dissolved Solids: Total
6•7—
mg/I
pH (when analyzed)
9.00
units
TOC
N h
mg/I
Chloride
mg/I
Arsenic
N
mg/I
Grease and Oils
"'a
mg/l
Hardness: Total
06C
mg/I
Phenol
Nor
mg/l
Sulfate
46r
mg/I
Specific Conductance
Na
uMhos
Total Ammonia
[VA-
mg/I
TKN as N
NIL
mg/I
I CERTIFY THAT THIS
anature of Permittg
Nitrite (NO2) as N
NA
mg/I
Nitrate (NO3) as N
NN
mg/I
Phosphorus: Total
as P N Ir
mg/I
Al - Aluminum
C>,o>
mg/I
Ba - Barium
Nk
mg/I
Ca - Calcium
< o, i o
mg/I
Cd - Cadmium
ij
mg/I
Chromium: Total
< 0.010
mg/I
Cu - Copper
0 i'_
mg/I
Fe - Iron
L o, e50
mg/I
Hg - Mercury
NN
mg/I
K - Potassium
NA
mg/I
Mg - Magnesium
Nk
mg/I
Mn - Manganese
mg/I
Na - Sodium
N
mg/I
Ni - Nickel N`A
mg/I
Pb - Lead IVA
mg/I
Zn - Zinc N
mg/I
Pesticides/Herbicides
(Specify Compounds)
Nn
Other (Specify Compounds and
Concentration units)
t= t-Uo2-►bE < 0,1 MCI L
1-1 n-t 1 U •NA BCD . Iylnr� 12
N'Ik- ANAL_g4l1S Nor I.11.J1eif
ug/I
ug/I
ug/I
EPORT IS TRUE AND ACCURATE. Note: Values should reflect dissolved and
colloidal concentrations. (see #3 on back)
,
Date
r
or Authorized Agent*)
* See back for instructions.
** Submit blue and yellow copies only to address above.
W-59 REV. 11/95

Type or Use a bal
Facility Name EM C Co2P — (-I'na I V ly%
Address IIAN � 110
Dtli`IS10
PERMIT NUMBER: (REQUIRED)
B
Non -Discharge W t�e009514q c�
NPDES
TYPE OF DISPOSAL OPERATION BEING MONITOR.1 rD.Y;;
Well Location Niz C;,emQ ar P'U'N ? -2-000 > + uPL24D f F_IV 1 (REQUIRED) T -L
'"� Lagoon Septic Tank/Drain Eield'�E
Well Identification Number VV Q Z AKA 1N -2- Well Depth 3S, 5 Ft.
Well Diameter A Id Sample Screened Interval 5� Spray Field Subsurface Low -Pressure
p (Screened) Ft. TO �✓� � Ft. Piping (LPP)
Depth to Water Level lbi'81 ft. below measuring point (before sampling) Land Application of Sludge
Measuring point is i, of ft. above land surface '_ Other
Gallons of water pumped/bailed before sampling 3.1-5 Rotary Distributor eecgCL, ltMpoUtJbi S iUT
Field Analysis: pH ` a LoS, Specific Conductance 1/ 0 uMhos Temp. 11 oC Odor New 2— Appearance )= E P-A i b i'rj SS NTI.h
Date Sample Collected Date Lab Sample Analyzed i 4T1i �e�
Laboratory Name 211C-F lWAh� cAl l_ Certification No. PZ
SAMPLES FOR METALS WERE COLLECTED UNFILTERED AND FIELD ACIDIFIED YES YC. NO
pen and press firmly.
iSi0%\/
COD
NA
mg/I
Coliform: MF Fecal
iv
/100mI
Coliform: MF Total
N&
/100ml
(Note: Use MPN method for highly
turbid samples)
Dissolved Solids: Total
62-
mg/I
pH (when analyzed)
S -nu
units
TOC
N h
mg/I
Chloride
mg/I
Arsenic
N A-
mg/I
Grease and Oils
VA
mg/I
Hardness: Total
N!k
mg/I
Phenol
NA-
mg/I
Sulfate
a
mg/I
Specific Conductance
,Na
uMhos
Total Ammonia
Nh
mg/I
TKN as N
NAr
mg/I
'Tb N
Nitrite (NO2) as N
NA
mg/I
Nitrate (NO3) as N
rJA-
mg/I
Phosphorus: Total
as P Nnr
mg/I
Al - Aluminum
4 0,o5,
mg/I
Ba - Barium
mg/I
Ca - Calcium
< o> t o
mg/I
Cd - Cadmium
th-
mg/I
Chromium: Total
4 0.0 I 0
mg/I
Cu - Copper
jJ A
mg/I
Fe - Iron
< o, 050
mg/I
Hg - Mercury
N4
mg/I
K - Potassium
NA
mg/I
Mg - Magnesium
Nhr
mg/I
Mn - Manganese
o, v'tq
mg/I
Na - Sodium
NA-
mg/I
I CERTIFY THAT THIS REPORT IS TRUE AND ACCURATE.
LL,�,
h,
gnature of Perm
or Authorized Agent*)
/Date
Ni - Nickel N`A
mg/I
Pb - Lead N4
mg/I
Zn - Zinc
mg/I
Pesticides/Herbicides
(Specify Compounds)
«
N�
g/I
Other (Specify Compounds and
Concentration units)
C:m
,ate
FI-yo(�-t`DE < n. 1 ivl��
L'
`t s-►-t I V
J
IV IS - AVuA01 S1 S NoT- 1 _Qul 0 i i
Note: Values should reflect dissolved and
colloidal concentrations. (see #3 on back)
* See back for instructions.
** Submit blue and yellow copies only to address above.
REV. 11 /95

I . Samples should be analyzed as soon as possible after collection. SAMPLES WHICH ARE NOT ANALYSED WITHIN THE HOLDING TIME SPECI-
FIED FOR THE METHOD USED (SEE 14. BELOW) MUST BE DISCARDED AND NEW SAMPLES COLLECTED.
2. Metals Analyses: Use Standard Method 3030C for sample preparation (mercury excluded). 2�0 NQT FILTER METALS�aW -5AMPLE' -THE ELELD H
_ _
Unfiltered samples must be collected for metals, then field acidified with 5 ml concentrated nitric acid per liter of sample, and should be submitted to the
lab within 24 hours.
Sample preparation in the laboratory (extraction and filtration) must be completed within 72 hours of collection.
3 ANALYSES ARE TO BE MADE OF THE MOBILE CONSTITUENTS (DISSOLVED AS WELL AS COLLOIDAL) IN THE
GROUNDWATER, N_QT TH09E 1HAT ARE A PART OF SEDIMENT ASSOCIATED - —ED WrrH WELL CONSTRUCTION OR SAMPLING PROC-EDUBES.
CHECK WiTH YOUR LABORATORY ON PROPER PROCEDURES FOR SAMPLE COLLECTION AN O PRESERVATION.
4. As per Title 15. North Carolina Administrative Code, Subchapter 2.L, analytical procedures shall be in accordance with the methods described in one of
the following publications, or by other methods approved beforehand by the Director, Division of Environmental
Management:
(a) Standard Methods for the Examination of Water and Wastewater, 16th Edition, 1985 and 17th Edition, 1989, published jointly by
American Public Health Association, American Water Works Association and Water Pollution Control Federation;
(b) Methods for Chemical Analysis of Water and Waste, 1979, U.S. Environmental Protection Agency publication number
EPA-600/4-79-020, as revised March 1983;
(c) Test Methods for Evaluating Solid Wastes: Physical/Chemical Methods, 3rd Edition, 1986, U.S. Environmental Protection Agency
publication number SW-846;
(d) Test Procedures for the Analysis of Polluants Under the Clean Water Act, Federal Register Vol. 49*, No. 209, 40 CFR Part 136,
October 26,1984;
5. Measure and record the depth of water in the well prior to pumping or bailing any water from the well,
6. At least-.3 volumes of water in the well should be pumped or bailed prior to collecting a sample for analysis. If the well is pumped/bailed dry before 3 well
volume's are removed, samples can be collected as soon as the well recovers to the point where enough water is available to collect your sample,
7. Determination for pH, Specific Conductance, temperature, odor and appearance must be made in the field on unfiltered samples when the sample is
collected.
8. Field equipment must be calibrated in accordance with recommendations by the manufacturer.
9. Samples must be filtered through a 0.45 micron filter immediately after collection when a dissolved analysis is required. (See #4. above)
10 -The sample container should be labeled at the time of collection with the facility name, well identification number and date and time collected.
11. "Authorized agent" is any corporate officer or public official authorized by the company, corporation, or governmental body to sign offi-cial.clocuments.

Facility Name
Address
PERMIT NUMBER: (REQUIRED)
Non -Discharge WQ U© 0?J `-1
NPDES
TYPE OF DISPOSAL OPERATION BEING MONITORED
Well Location 5co'•• MAN K .'iVi1 W i6ovPbA-0 ) OF K I1-A1 f��fi�Ds (REQUIRED)
Lagoon Septic Tank/Drain Field
Well Identification Number Wq -1 Well Depth S Ft.
Well Diameter 2 it Sample (Screened) Interval ` , 5 Ft. To `)`(� S Ft. Spray Field Subsurface Low -Pressure
Piping (LPP)
Depth to Water Level 36, • o I ft. below measuring point (before sampling) Land Application of Sludge
Measuring point is de 5 ft. above land surface X Other
Gallons of water pumped/bailed before sampling (,V+1-5 Rotary Distributor (ZpCi e&L fiv+,0avAUj�$ jVISyi+
Field Analysis: pH 4,50 S ecific Conductance -'1060 uMhos Temp. I r °C . Odor NNoNS Appearance 14f.i Ivi�-& b I'TJ 130
Date Sample Collected I L + Date Lab Sample Analyzed )z]r�l�iG - i iLT
Laboratory Name RM Gam- Certification No. Z
SAMPLES FOR METALS WERE COLLECTED UNFILTERED AND FIELD ACIDIFIED YES 14% NO
COD
Coliform: MF Fecal
Coliform: MF Total
Type or Use a ball-point pen and press firmly.
NA
rJ
(Note: Use MPN method for highly turbid samples)
mg/I
/100ml
/100ml
Dissolved Solids: Total
1$i©©
mg/I
pH (when analyzed)
units
TOC
mg/I
Chloride
mg/I
Arsenic
mg/I
Grease and Oils
N
mg/I
Hardness: Total
N A
mg/I
Phenol
N Ik
mg/I
Sulfate
1 y t;G
mg/I
Specific Conductance
N4
uMhos
Total Ammonia
NA-
mg/I
TKN as N
(AAA:
mg/I
Nitrite (NO2) as N
N.4
mg/I
Nitrate (NO3) as N
NA-
mg/I
Phosphorus: Total as P N A-
mg/I
Al - Aluminum
`I'��I T
mg/I
Ba - Barium
mg/I
Ca - Calcium
mg/I
Cd - Cadmium
NA-
mg/I
Chromium: Total
<d, 010
mg/I
Cu - Copper
N h-
mg/I
Fe - Iron
< u 10 5 o
mg/I
Hg - Mercury
Kj4-
mg/I
K - Potassium
NPr
mg/I
Mg - Magnesium
fix
mg/I
Mn - Manganese
mg/I
Na - Sodium
mg/I
I CERTIFY THAT THIS REPORT IS TRUE AND ACCURATE.
nature of Perm
(or Authorized Agent*)
i z,-7 �I
bate
Ni - Nickel N N mg/I
Pb - Lead ti A; mg/I
Zn - Zinc ly1' r , mg/I
Pesticides/Herbicides
(Specify Compounds)
'mug/I
U /I
F ",ug/I
Other (Specify Compounds and
Concentration units) ; �M
F LU ® jZA'b r ®, Z irYl
I'_ i-n ) V .
YL-
Note: Values should reflect dissolved and
colloidal concentrations. (see #3 on back)
* See back for instructions.
** Submit blue and yellow copies only to address above.
REV. 11 /95

1. Samples should be analyzed as soon as possible after collection. SAMPLES WHICH ARE NOT ANALYSED WITHIN THE HOLDING TIME SPECI-
FIED FOR THE METHOD USED (SEE #4. BELOW) MUST BE DISCARDED AND NEW SAMPLES COLLECTED.
2. Metals Analyses: Use Standard Method 3030C for sample preparation (mercury excluded). PO NOT FILTER METALS SAM12LESIN-THE FIELD IT!
Unfiltered samples must be collected for metals, then field acidified with 5 ml concentrated nitric acid per liter of sample, and should be submitted to the
lab within 24 hours.
Sample preparation in the laboratory (extraction and filtration) must be completed within 72 hours of collection.
I I MUM=
MUM Man= SM1111
MWAMNS E A119MULMM
4. As ' per Title 15, North Carolina Administrative Code, Subchapter 2L, analytical procedures shall be in accordance with the methods described in one of
the following publications, or by other methods approved beforehand by the Director, Division of Environmental
Management:
(a) Standard Methods for the Examination of Water and Wastewater, 16th Edition, 1985 and 17th Edition, 1989, published jointly by
American Public Health Association, American Water Works Association and Water Pollution Control Federation;
(b) Methods for Chemical Analysis of Water and Waste, 1979, U.S. Environmental Protection Agency publication number
EPA-600/4-79-020, as revised March 1983;
(c) Test Methods for Evaluating Solid Wastes: Physical/Chemical Methods, 3rd Edition, 1986, U.S. Environmental Protection Agency
publication number SW-846;
(d) Test Procedures for the Analysis of Polluants Under the Clean Water Act, Federal Register Vol. 49, No. 209, 40 CFR Part 136,
October 26, 1984;
Measure and record the depth of water in the well prior to pumping or bailing any water from the well.
6. At least 8 volumes of water in the well should be pumped or bailed prior to collecting a sample for analysis. If the well is pumped/bailed dry before 3 well
volumes are removed, samples can be collected as soon as the well recovers to the point where enough water is available to collect your sample.
7. Determination for pH, Specific Conductance, temperature, odor and appearance must be made in the field on unfiltered samples when the sample is
collected.
8. Field equipment must be calibrated in accordance with recommendations by the manufacturer.
9. Samples must be filtered through a 0.45 micron filter immediately after collection when a dissolved analysis is required. (See #4. above)
10. The sample container should be labeled at the time of collection with the facility name, well identification number and date and time collected.
11. "Authorized agent" is any corporate officer or public official authorized by the company, corporation, or governmental body to sign official documents.

FMC Corporation
Lithium Division
Highway 161
Box 795
Bessemer City North Carolina 28016
704 868 5300 Fax [phone]
CERTIFIED MAIL oFMC ~-j
RETURN RECEIPT REQUESTED
January 27, 1997
North Carolina Division of Environmental Management _2
Groundwater Section
P.O. Box 29535
Raleigh, NC 27626-0535
Re: Non -Discharge Permit No. WQ0008149
Groundwater Quality Monitoring - Compliance Report Forms
Dear Sir or Madam:
In accordance with the requirements of item No. 21 of the
North Carolina Water Quality Permit No. WQ0008149 for the
Recycle System (kiln scrubber ponds) located at FMC
Corporation's Lithium Division facility in Bessemer City, FMC
is submitting two Compliance Monitor Forms (GW-59) for the
sampling and analysis of groundwater monitoring wells WQ-1
and WQ-7 (A.K.A. W-7) on December 11, 1996. The results
reported here for aluminum, chromium, iron, lithium and
manganese were obtained using method 3030C in Standard
Methods, 17th edition for digestion and EPA method 200.7 for
analysis. The results for fluoride were obtained using EPA
method 340.2; for TDS using EPA method 160.1; for chloride
using EPA method 325.2; for sulfate using EPA method 375.4,
and for calcium using EPA method 200.7. Laboratory report
sheets and chain of custody records are available upon
request.
Modified sample collection procedures, as described in FMC's
September 29, 1995 letter to DEM, were used again during this
sampling event in attempts to reduce the turbidity of
collected groundwater. Again, while turbidity has been
reduced, the EPA guideline in SW-846 of five NTU could not
been achieved without filtering. All results represent
analysis of filtered samples, as recommended in FMC's letter
of September 29, 1995, to which DEM has not replied.
If you have any questions, or require additional information,
please contact me at 704/868-0806.
ver;V truly yours,
Barbara Ritchie
Environmental Manager
cc: B. Keith Overcash - DEHNR/Mooresville

Type or Use a ball-point pen and press firmly. PERMIT NUMBER: (REQUIRED
Facility Name FMC Corporation - Lithium Division Non -Discharge W 1 08149 SEP 26 1996
Address Hwy 1.61, Box 795 NPDES
Bessemer City, NC _ 28016 Gaston TYPE OF DISPOSAL OPERATION BEING MONITORED
Southern Review Boundary of K� In Ponds (REQUIRED) DI`diS!I?rt LF I''�'q-`'t "'' 1` r' rE t�T
Well Location Lagoon SeptieTtgnfclDCairi.F-IW9, E
Well Identification Number WQ- We Depth Ft.
Well Diameter 2 in Sample (Screened) Interval 9' S Ft. TO �Ft. Spray Field Subsurface Low -Pressure
Piping (LPP)
Depth to Water Level 31.99 ft. below measuring point (before sampling) Land Application of Slk§}ge
Measuring point is 2.5 ft. above land surface—Rucyoctle Impoundment
Gallons of water pumped/bailed before sampling 15 Rotary Distributor
Field Analysis: pH 4.59 Specific Conductance_ uMhos Temp. 20. 1 °C Odor None Appearance Field Turbidity 94.5 NTU
Date Sample Collected 8/1/96 Date Lab Sample Analyzed 8/22/96 Filtered Turbidity 5.0 NTU
Laboratory Name Lancaster Laboratories, Lancaster, PA Certification No. 521
SAMPLES FOR METALS WERE COLLECTED UNFILTERED AND FIELD ACIDIFIED YES X NO
COD
NA
mg/I
Coliform: MF Fecal
/100ml
Coliform: MF Total
NA
/100ml
(Note: Use MPN method for highly turbid samples)
Dissolved Solids: Total
2400 _
mg/I
pH (when analyzed)
units
TOC
NA
mg/I
Chloride
49
mg/I
Arsenic
NA
mg/I
Grease and Oils
NA
mg/I
Hardness: Total
NA
mg/I
Phenol
NA
mg/I
Sulfate
1900
mg/I
Specific Conductance
NA
uMhos
Total Ammonia
NA
mg/I
TKN as N
NA
mg/I
Nitrite (NO2) as N
N4
mg/I
Nitrate (NO3) as N
ii
mg/I
Phosphorus: Total as P NA
mg/I
Al - Aluminum
5 38
mg/I
Ba - Barium
>�
mg/I
Ca - Calcium
14n
mg/I
Cd - Cadmium
NA
mg/I
Chromium: Total
<n- 15
mg/I
Cu - Copper
NA
mg/1
Fe - Iron
<1.0
mg/I
Hg - Mercury
NA
mg/I
K - Potassium
NA
mg/I
Mg - Magnesium
NA
mg/I
Mn - Manganese
34.2
mg/I
Na - Sodium
NA
mg/I
Ni - Nickel 49
mg/1
Pb - Lead N
KA
mg/I
Zn - Zinc 1YA
mg/I
Pesticides/Herbicides
(Specify Compounds)
ug/I
ug/I
g/I
Other (Specify Compounds and
Concentration units) 9
-, o
�9
Fluoride 1-2 mg11 =
j
Lithium 11_9
'
NA - Analysis Not Required
I CERTIFY THAT THIS REPORT IS TRUE AND ACCURATE. Note: Values should reflect dissolved and
colloidal concentrations. (see #3 on back)
C- 13 ,.A, See back for instructions.
Signature of Permittee (or Authorized Agent*) bate ** Submit blue and yellow copies only to address above.
GW-59 REV. 11/95

COLLECTION AND ANALYSIS OF GROUNDWATER SAMPLES
1 Samples should be analyzed as soon as possible after collection. SAMPLES WHICH ARE NOTAKIALYSED WITHIN 7R­IE HOLDING TIME SPECI-
FIED FOR THE METHOD USED (SEE44. BELOW) MUST BE DISCARDED AND VIEW SArt4PLE_q COLLECTED.
2. Metais Analyses: Use Standard Method 3030C for sample preparation (mercury excluded%. DO NOT FILTER METAL -a 3AMPLES IN THE FIELD
Unfiltered samples Must be collected for metals,thon field acidified with 5 ml concentrated nitric acid per liter of sample, and should be submitted to the
lab within 24 hours.
Sample preparation in the laboratory (extraction and filtration) must be completed within 72 hours of collection,
3;: ANALYSES ARE TO BE MADE OF THE NIOBILE CONSTITUENTS (DISSOLVED AS WELL As COLLOIDAL) IN THE
GROUNDWATER, hLOT II THAT ARE A PART OF SEDIMENT LS%CIATED �%IJTH WELL CONSTRUcTiON OR SAMPLING E_RQ_QDJRES
CHECK WITH YOUR LABORATORY ON PROPER PROCEDURES FOR SAMPLE COLLECTION AND PRESERVATION,
4. Asper Title 15, Nlorth Carolina Administrative Code, Subchapter 2L, analytical procedures shall be in accordance with the methods described in one of
the following publications, or by other methods approved beforehand by the Director, Division of Environmental
fvlanagement:
(a) Standard Methods for the Examination of Water and Wastewater, 16th Edition, 1985 and 17th Edition, 1989, published jointly by
American Public Health Association, American Water Works Association and Water Pollution Control Federation;
(b) Methods for Chemical Analysis of Water and Waste, 1979, U.S. Environmental Protection Agency publication number
EPA-60014_70-020, as revised March 1983;
Test Methods for Evaluating Solid Wastes: Physical/Chemical Methods, 3rd Edition, 1986, U.S, Environmental Protection Agency
publication number SW-846;
(d) Test Procedures for the Analysis of Polluants Under the Clean Water Act, Federal Register Vol. 49, No. 209, 40 CFly Part 136,
October 26,1984;
5. Measure and record the depth of water in the well prior to pumping or bailing any water from the well.
6. At least 3 volumes of water in the well should be pumped or bailed prior to collecting a sample for analysis. If the well is pumped/bailed dry before 3 well
volumes are removed, samples can be collected as soon as the well recovers to the point where enough water is available to collect your sample.
7. Determination for pH, Specific Conductance, temperature, odor and appearance must be made in the field on unfiltered samples when the sample -is
co!lectea.
8. Field equipment must be calibrated in accordance with recommendations by the manufacturer.
9. Samples must be filtered through a 0.45 micron filter immediately after collection when a dissolved analysis is, required. (See #4. above)
10. The sample container should be labeled at the time of collection with the facility name, well identification number and date and time collected.
11. "Authorized agent" is any corporate officer or public official authorized by the company, corporation, or governmental body to sign official documents.

COW, ANC.E REPORT FORM please wri a or salt:
(919);733.32 1
Type or Use a ball-point pen and press firmly.
PERMIT NUMBER: (REQUIRED)
Facility Name F'MC Corproation — Lithium Division
Non -Discharge WQ0008149
Address Hwy 161, Box 795
NPDES
Bessemer City, NC 28016 County Gaston
TYPE OF DISPOSAL OPERATION BEING MONITORED
t f Co
rner orner opropery, 2000 feet upgradient
Well Location %
(REQUIRED)
Lagoon Septic Tank/Drain Field
Well Identification Number WQ 2 AKA W-7 Well Depth 38.5 Ft.
(Screened)
Well Diameter 2 in Sam le Screened Interval 28.5 Ft. To 5 Ft.
Spray Field Subsurface Low -Pressure
18 p5
Depth to Water Level ft. below measuring point (before sampling)
Piping (LPP)
Land Application of Sludge
Measuring point is 1.9 ft. above land surface
3
xx Other
Rotary Distributor Recycle Impoundment
Gallons of water pumped/bailed before sampling
4 87 989 20.2 0
Conductance
None Eield Turbidity
Appearance
Field Analysis: pH 8 1 96pecific uMhos Temp. 6C
Date Sample Collected Date Lab Sam le An I
Odor
�iTed Turbidity 5.0 NTU
zed
Lancater Laboratories, Lancastper, ��
Laboratory Name
521
Certificatix No.
SAMPLES FOR METALS WERE COLLECTED UNFILTERED AND FIELD ACIDIFIED
YES NO
COD
NA
mg/I
Coliform: MF Fecal
NA
/100ml
Coliform: MF Total
NA
/100ml
(Note: Use MPN method for highly
turbid samples)
Dissolved Solids: Total
60
mg/I
pH (when analyzed)
units
TOC
NA
mg/1
Chloride
17
mg/I
Arsenic
NA
mg/I
Grease and Oils
NA
mg/I
Hardness: Total
N
mg/1
Phenol
mg/I
Sulfate
ZZ
mg/I
Specific Conductance
uMhos
Total Ammonia
mg/I
TKN as N
mg/I
Nitrite (NO2) as N
NA
mg/I
Nitrate (NO3) as N
NA
mg/I
Phosphorus: Total as P
NA
mg/I
AI - Aluminum
0.20
mg/I
Ba - Barium
NA
mg/I
Ca - Calcium
0.20
mg/I
Cd - Cadmium
NAmg/I
Chromium: Total
4u.U3Umg/I
Cu - Copper
NAmg/I
Fe - Iron
10
mg/I
Hg - Mercury
mg/I
K - Potassium
mg/I
Mg - Magnesium _
NA
mg/I
Mn - Manganese
0.033
mg/I
Na - Sodium
NA
mg/I
Ni - Nickel NA mg/I
Pb - Lead N A mg/I
Zn - Zinc NA mg/I
Pesticides/Herbicides
(Specify Compounds)
NA ug/I
ug/I
u9 /I
Other (Specify Compounds and
Concentration units) - - -"
F1 oliride40. 1
NA — Analysis Not Required
I CERTIFY THAT THIS REPORT IS TRUE AND ACCURATE. Note: Values should reflect dissolved and
�7 colloidal concentrations. (see #3 on back)
' g' c ZZ, �''^� � P�` See back for instructions.
Signature of Permittee (or Authorized Agent*) Date ** Submit blue and yellow copies only to address above.
GW-59 REV. 11/95

1. Samples should beanalyzed assoon aopossible after collection. SAMPLES WHICH ARE NOT ANALYSED WITHIN THE HOLDING TI%0ESPECI.
FIED FOR THE METHOD USED (SEE #4. BELOW) MUST BE DISCARDED AMD NEW SAMPLES COLLECTED.
2. Metals Analyses: Use Standard Method 3030C for sample preparation (mercury excluded). DO NOT FILTER ME]IAL!j-S�AMPLES IN TkjE Elr-:LQL!I!
Unfiltered samples Must be collected for metals, then field acidified with 5 ml concentrated nitric acid per liter of sample, and should be submitted to the
lab within 24hours.
Sample preparation in the laboratory (extraction and filtration) must be completed within 72 hours of collection.
4. Asper Title 15,North Carolina Administrative Code, Subchapter 2L, analytical procedures shall be in accordance with the methods described in one of
the following publications, orbyother methods approved beforehand by the Director, Division of Environmental
Management:
(8) Standard Methods for the Examination of Water and Wastewater, 16th Edition, 1985 and 17th Edition, 1989, published jointly by
American Public Health Aauooiedon, American Water Works Association and VVn1er Pollution Control Federation;
(b) Methods for Chemical Analysis ofWater and Waste, 1079.U.S.Environmental Protection Agency publication number
EpA-600/4'79'020, as revised March 1983;
(n) Test Methods for Evaluating Solid Wastes: Physical/Chemical Methods, 3ndEdition, 198G.U.S. Environmental Protection Agency
publication number 8VV'846;
(d) Test Procedures for the Analysis of Polluants Under the Clean Water Act. Federal Register Vol. 49, No. 209, 40 CFR Part 136,
October 26,1984;
5. Measureznd record the depth of water in the well prior to pumping or bailing any water from the well.
G. At least 3volumes ofwater inthe well should bepumped orbailed priorkzcollecting asample for analysis. |fthe well ispumped/bailed dry before 3well
volumes are removed, samples can be collected as soon as the well recovers to the point where enough water is available to collect your sample.
7. Determination for pH. Specific Conductance, temperature, odor and appearance must be made in the field on unfiltered samples when.the sample is
8. Field equipment must be calibrated in accordance with recommendations by the manufacturer.
9. Samples must be filtered through a 0.45 micron filter immediately after collection when a dissolved analysis is required. (See #4. above)
10.Thesample container should belabeled at the time of collection with the facility name, well identification number and date and time collected.
11 . "Authorized agent" is any corporate officer or public; official authorized by the company, corporation, or governmental body to sign official documents.

FMC Corporation
Lithium Division
Highway 161
Box 795
Bessemer City North Carolina 28016
704 868 5300 Fax [phone]
fMC
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
�
T'
September 20, 1996
C/)
v
North Carolina Division of Environmental
Management
'=
Groundwater Section
P.O. Box 29535
_a
Raleigh, NC 27626-0535
Re: Non -Discharge Permit No. WQ0008149-
r:
-,
Groundwater Quality Monitoring - Compliance
Report Forms
Dear Sir or Madam:
In accordance with the requirements of item No. 21 of the
North Carolina Water Quality Permit No. WQ0008149 for the
Recycle System (kiln scrubber ponds) located at FMC '
Corporation's Lithium Division facility in Bessemer City, FMC
is submitting two Compliance Monitor Forms (GW-59) for the
sampling and analysis of groundwater monitoring wells WQ-1
and WQ-7 (A.K.A. W-7) on August 1, 1996. The results
reported here for aluminum, chromium, iron, lithium and
manganese were obtained using method 3030C in Standard
Methods, 17th edition for digestion and EPA method 200.7 for
analysis. The results for fluoride were obtained using EPA
method 340.2; for TDS using EPA method 160.1; for chloride
using EPA method 325.2; for sulfate using EPA method.375.4,
and for calcium using EPA method 200.7. Due to an error in
preparation of the laboratory request forms, pH was only
analyzed in the field. Laboratory report sheets and chain of
custody records are available upon request.
Modified sample collection procedures, as described in FMC's
September 29, 1995 letter to DEM, were used again during this
sampling event in attempts to reduce the turbidity of
collected groundwater. Again, while turbidity has been
reduced, the EPA guideline in SW-846 of five NTU could not
been achieved without filtering. All results represent
analysis of filtered samples, as recommended in FMC's letter
of September 29, 1995, to which DEM has not replied.
If you have any questions, or require additional information,
please contact me at 704/868-0806.
V t ou ,
rba a E.
Environme tal Manager
cc: B. Keith Overcash - DEHNR/Mooresville

r-i
FMC Corporation
Lithium Division
Highway 161
Box 795
Bessemer City North Carolina 28016 -N.C. DEPT. OF
704 868 5300 Fax [phone] gNVIRONl\,PNT, HEALTH fl
NATURAL RI SGiJFcCES +MC
CERTIFIED MAIL SEP 10,96
RETURN RECEIPT REQUESTED
September 20, 1996
North Carolina Division
Groundwater Section
P.O. Box 29535
Raleigh, NC 27626-0535
ri 1 LIs
@,41!JIEa4llli:
of Environmental Management
Re: Non -Discharge Permit No. WQ0008149
Groundwater Quality Monitoring - Compliance Report Forms
Dear Sir or Madam:
In accordance with the requirements of item No. 21 of the
North Carolina Water Quality Permit No. WQ0008149 for the
Recycle System (kiln scrubber ponds) located at FMC
Corporation's Lithium Division facility in Bessemer City, FMC
is submitting two Compliance Monitor Forms (GW-59) for the
sampling and analysis of groundwater monitoring wells WQ-1
and WQ-7 (A.K.A. W-7) on August 1, 1996. The results
reported here for aluminum, chromium, iron, lithium and
manganese were obtained using method 3030C in Standard
Methods, 17th edition for digestion and EPA method 200.7 for
analysis. The results for fluoride were obtained using EPA
method 340.2; for TDS using EPA method 160.1; for chloride
using EPA method 325.2; for sulfate using EPA method.375.4,
and for calcium using EPA method 200.7. Due to H an error in
preparation of the laboratory request forms, p y
analyzed in the field. Laboratory report sheets and chain of
custody records are available upon request.
Modified sample collection procedures, as described in FMC's
September 29, 1995 letter to DEM, were used again during this
sampling event in attempts to reduce the turbidity of
collected groundwater. Again, while turbidity has been
reduced, the EPA guideline in SW-846 of five NTU could not
been achieved without filtering. All results represent
analysis of filtered samples, as recommended in FMC's letter
of September 29, 1995, to which DEM has not replied.
If you have any questions, or require additional information,
please contact me at 704/868-0806.
Ve'
AEn
t ;u y�`you,
rbar'a E.vironm tal Manager
v ___ B. Keith Overcash - DEHNR/Mooresville

T
� IVISION OF;ENVIRONM ENTAL MANOGEME.NT G
P
GROUNDWATER QUALITY MONITORING
For additipnal forms RALIGH, NC 2762fi-057
COMPLLANCE REPORT FORM please write or call (919)sw
73�221
Type or Use a ball-point pen and press firmly. PERMIT NUMBER: (REQUIRED)
FMC Cor roation — Lithium Division Non -Discharge WQ0008149
Facility Name NPDES
Address Hwy 161, Box 795 TYPE OF DISPOSAL OPERATION BEING MONITORED
Bessemer City, NC 28016 Gaston
County (REQUIRED) T k/D Field
Well Location NE Corner of property, ? 2000 feet upgradient
WQ 2 AKA W-7 Well Depth 38.5 Ft.
Well Identification Number P
Well Diameter 2 in Sample (Screened) Interval 28.5 Ft. To 3 Ft.
Depth to Water Level 1.18. 5 ft. below measuring point (before sampling)
Measuring point is ft. above land surface 3
/bailed before sampling one
Lagoon
Septic an rain
Spray Field Subsurface Low -Pressure
Piping (LPP)
Land Application of Sludge
xx Other
Rotary Distributor Recycle Impoundment
Gallons of water pum ec87 20. 2 o A earance
H ecific Conductance uMhos Temp. C Odor PP eyed Turbidity 5.0 NTU
Field Analysis. p9P l6
Date Sample Collected Dateab Samtple Analyzed
Laboratory Name Lancater a oratories, ancas er, Certification No. 521
SAMPLES FOR METALS WERE COLLECTED UNFILTERED AND FIELD ACIDIFIED YES NO
COD NA mg/I
Coliform: MF Fecal NA /100m1
Coliform: MF Total NA /100ml
(Note: Use MPN method for highly turbid samples)
Dissolved Solids: Total 60 mg/I
pH (when analyzed) units
TOC NA mg/I
Chloride _ 17 mg/I
Arsenic NA mg/I
Grease and Oils NA mg!I
Hardness: Total NA mg
Phenol g/I
Sulfate mg/I
Specific Conductance uMhos
Total Ammonia mg�l
9
TKN as N
Nitrite (NO2) as N NA
mg/I
Nitrate (NO3) as N NA
mg/I
Phosphorus: Total as P NA
•mg/I
Al - Aluminum '� 0.20
mg/I
Ba - Barium
g
Ca - Calcium 0.20mg/I
NA
mg/I
Cd - Cadmium
Chromium: Total
mg/I
Cu -Copper
mg/I
Fe -Iron
mg/l
Hg - Mercury
mg/I
K - Potassium
mg/I
Mg - Magnesium NA
mg/I.
Mn - Manganese 0.033
mg/I
Na - Sodium NA
I CERTIFY THAT THIS REPORT IS TRUE AND ACCURATE.
Signature of Permittee (or Authorized Agent*)
Ni - Nickel NA mg/I
Pb - Lead N A mg/I
Zn - Zinc NA mg/I
Pesticides/Herbicides
(Specify Compounds) NA
u /l
ug/I
ug/I
Other (Specify Compounds and
Concentration units)
NA - Analysis Not Required
Note: Values should reflect dissolved and
colloidal concentrations. (see'#3 on back)
See back for instructions.
Date ** Submit blue and yellow copies only to address above.
GW-59 REV. 11/95

{ ;` r�DIVISION OF ENVIRONMENTAL, MANAGEMENT GROUNDWATER SECTION
P O BOX 29578
GROUNDWATER QUALITY �VIONITOR,ING. ForaddltianalCorms RALEIC3H,nta27s2s.o57a
p 19191733 3221
pieasa.wrlte orca
COMPLIANCE REPORT FORM ;.
•,.
Type or Use a ball-point pen and press firmly-
PERMIT NUMBER: (REQUIQF�FbDd8149
Non -Discharge
Facility Name FMC Corporation - Lithium Division
H��' 161, Box 795
NPDES
TYPE OF DISPOSAL
OPERATION BEING MONITORED
Address
Bessemer City, NC 28016 County Gaston
Kin Pon s
(REQUIRED)
Lagoon Septic Tank/Drain Field
Southern Review Boundary of
Spray Field Subsurface Low -Pressure
Well Location WQ— V,�leg Depth Ft.
ber
Well Identificatio�t in y
Well Diameter Sample (Screened) Interval Ft. To Ft.
Piping (LPP)
Land Application of Skoe
Depth to Water Level 31 - 99 it. below measuring point (before sampling)
—Ruz!y21� thh r Impoundment
Measuring point is 2.5 ft. above land surface
Rotary Distributor
Gallons of water pumped/bailed before sampling
�C
Odor None Appearance Fief d-Turbidity 94.5 NTU
Field Analysis: pH 4. 59 Specific Conductance 9238__ uMhos Temp..
Filtered Turbidity 5.0 NTU
Date Sample Collected 8/1/96 Date Lab Sample Analyzed 8/22/96
PA
Certification No. 521
Name Lancaster Laboratories Lancaster
YES X NO
Laboratory
WERE COLLECTED UNFILTERED AND FIELD ACIDIFIED
SAMPLES FOR METALS
COD �1 mg/I Nitrite (NO2) as N rTA
mg/I
m9/I
Ni - Nickel—�� —
Pb -Lead
mg/I
mg/I
Coliform: MF Fecal /100m1 Nitrate (NOg) as N ��A
/100ml Phosphorus: Total as P
— m/I
Zn - Zinc
mg/I
Coliform: MF Total N
mg/I
Pesticides/Herbicides
s �a
(Note: Use MPN method for highly turbid samples) Al - Aluminum 9s
mg/I Ba - Barium
_ mg/I
(Specify Compounds)
ug/I
Dissolved Solids: Total 9400
mg/I
�T
pH (when analyzed) units Ca - Calcium _ 4nNA
mg/l
ug/I
TOC N4 mg/I Cd - Cadmium �n
mg/I
ug/l
Chloride 4R mg/I Chromium: Total 1 5
mg/I
Other (Specify Compounds and
Arsenic NA — mg/l Cu -Copper NA
mg/I Fe - Iron NA'
mg/I
Concentration units)
Grease and Oils NA
Hardness: Total NA mg/I Hg - Mercury
mg/I
mg/I
F1 iinri r1P 1 9 mg/ 1
NA
Phenol NA mg/I K - Potassium NA
190o mg/I Mg -Magnesium
mg/I
TA Chi ii
Sulfate 34.2
Specific Conductance NA uMhos Mn -Manganese NA
mg/1
rpg/I
Total Ammonia NA mg/I Na -Sodium
NA Analysis Nat Required
/I
TKN as N NA mg
I CERTIFY THAT THIS REPORT IS TRUE AND ACCURATE. Note: Values should reflect dissolved and
colloidal concentrations. (see'#3 on back)
C- 1 ..L A-,, 4 2•, K * See back for instructions.
above.
ate ** Submit blue and yellow copies only to address
Signature of Permittee (or Authorized Agent'`)
GW-59 REV. 11/95

FMC Corporation N.C. DEFT. OF
Lithium Division BNM0,,,Tk,1BNT' HEALTH
H
Highway 161 & NATUFAt-
Box 795
Bessemer City North Carolina 28016 JUG! 41996
704 868 5300 Fax [phone]
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
June 3, 1996
North Carolina Division of Environmental Management
Groundwater Section
P.O. Box 29535
Raleigh, NC 27626-0535
Re: FMC Corporation - Lithium Division
Bessemer City Non -Discharge Permit No. WQ0008149
Groundwater Quality Monitoring - Compliance Report Forms
Dear Sir or Madam:
In accordance with the requirements of item No. 21 of the
North Carolina Water Quality Permit No. WQ0008149 for the
Recycle System (kiln scrubber ponds) located at FMC
Corporation's Lithium Division facility in Bessemer City, FMC
is submitting two Compliance Monitor Forms (GW-59) for the
sampling and analysis of groundwater monitoring wells WQ-1
and WQ-7 (A.K.A. W-7) on April 25, 1996. The results
reported here'for aluminum, chromium, iron, lithium and
manganese were obtained using method 3030C in Standard
Methods, 17th edition for digestion and EPA method 200.7 for
analysis. The results for fluoride were obtained using EPA
method 340.2;1for TDS using EPA method 160.1; for chloride
using EPA method 325.2; for sulfate using EPA method 375.4,
and for calcium using EPA method 200.7. Due to an error in
preparation of the laboratory request forms, pH was only
analyzed in the field. All results represent analysis of
unfiltered samples. Laboratory report sheets and chain of
custody records are available upon request.
Modified sample collection procedures, as described in FMC's
September 29, 1995 letter to DEM, were used again during this
sampling event in attempts to reduce the turbidity of
collected groundwater. Again, while turbidity has been
greatly reduced with the modification of sampling techniques,
the EPA guideline in SW-846 of five NTU has not been
achieved.
If you have any questions, or require additional information,
please contact me at 704/868-0806.
Znviro=meX/t4aana*qer
tru ou ,
ara E.i chie
tM

rj F
cc: Mr. B. Keith Overcash, P.E.
Regional Supervisor
DEHNR / Mooresville Office
919 North Main Street
Mooresville, NC 28115

Type or Use a ball-point pen and press firmly. PERMIT NUMBER: (REQUIRED)
Facility Name FMC Corporation - Lithium Division Non -Discharge WQ0008149
AddressHwy Box NPDES
TYPE OF DISPOSAL OPERATION BEING MONITORED
RPGGemer city, NC 28016 County Ga-,fan (REQUIRED)
Well Location Southern Review Boundary of Kiln Ponds Lagoon SepticTanklDrain Field
Well Identification Number WQ-1 Well Depth 49.5 Ft.
Spray Field Subsurface Low -Pressure
Well Diameter 2 in Sample (Screened) Interval 9.5 Ft. To 49.5 Ft. Piping (LPP)
Depth to Water Level 26.64 ft. below measuring point (before sampling) Land Application of Sludge
Measuring point is 2.5 ft. above land surface— other
Gallons of water pum ed/bailed before sampling
12 Rotary Distributor Re un ment
Field Analysis: pH �• 70 Specific Conductance 2270 uMhos Temp.16 oC Odor Nonp Appearance -S� i gr? y Turbid
Date Sample Collected 4/9S'g6 Date Lab Sample Analyzed4/�/10196
Laboratory Name Pace Analytical Certification No. 19
SAMPLES FOR METALS WERE COLLECTED UNFILTERED AND FIELD ACIDIFIED x YES NO
COD NA
mg/I
Coliform: MF Fecal
NA
/100ml
Coliform: MF Total
NA
/100ml
(Note: Use MPN method for highly turbid samples)
Dissolved Solids: Total
2500
mg/I
pH (when analyzed)
5.30
units
TOC
NA
mg/I
Chloride
42
mg/I
Arsenic
NA
mg/I
Grease and Oils
NA
mg/I
Hardness: Total
NA
mg/I
Phenol
NA
mg/I
Sulfate
mg/I
Specific Conductance
NA
uMhos
Total Ammonia
NA
mg/I
TKN as N
P7A
mg/I
Nitrite (NO2) as N
NA
mg/I
Nitrate (NO3) as N
NA
mg/I
Phosphorus: Total as P NA
mg/I
Al - Aluminum
18
mg/I
Ba - Barium
NA
mg/I
Ca - Calcium
180
mg/I
Cd - Cadmium
NA
mg/I
Chromium: Total
< 0.010
mg/I
Cu - Copper
NA
mg/I
Fe - Iron
2.5
mg/I
Hg - Mercury
NA
mg/I
K - Potassium
mg/I
Mg - Magnesium
NAmg/I
Mn - Manganese
30
mg/I
Na -.Sodium
NA
mg/I
Ni - Nickel NA mg/I
Pb - Lead NA mg/I
Zn - Zinc NA mg/I
Pesticides/Herbicides
(Specify Compounds)
NA ug/I
ug/I
ug/I
Other (Specify Compounds and
Concentration units)
F oride 2.50 mg/1
T i thJ um 10 8 mg/1
NA = Analysis not required
CERTIFY THAT THIS REPORT IS TRUE AND ACCURATE. Note: Values should reflect dissolved and
colloidal concentrations. (see 43 on back)
A, See �}/��� See back for instructions.
Signature of Permittee (orAuthorized Agent*) ate ** Submit blue, green, and yellow copies only to address above.
GW-59 REV. 6/93

Type or Use a ball-point pen and press firmly.
Facility Name FMC Corporation - Lithium Division
Address Hwy , Box 795
Bessemer City, NC 28016 aston
County
PERMIT NUMBER: (REQUIIR�E0008149
Non -Discharge
NPDES
TYPE OF DISPOSAL OPERATION BEING MONITORED
(REQUIRED)
Well Location NE Corner of property,- e 2000-fe`et upgradient
Well Identification Number ran ,-7 Well Depth 22 5 Ft.
Well Diameter 9 in Sample (Screened) Interval 9R - 5 Ft. To 38 5 Ft.
Depth to Water Level 1 5.64 ft. below measuring point (before sampling)
Measuring point is 1.9 ft. above land surface
Gallons of water pumped/bailed before sampling 5.5
Field Analysis: pH 5.82 Specific Conductance 77 uMhos Temp. 18 °C Odor
Date Sample Collected 4/25/96 Date Lab Sample Analyzed 4/27-5/ 10/96
Lagoon
Spray Field
Land Application of SludM
Rotary Distributor
Septic Tank/Drain Field
Subsurface Low -Pressure
Piping (LPP)
Other
None Appearance Slightly turbid
Laboratory Name Pace Analytical Certification No. 12
SAMPLES FOR METALS WERE COLLECTED UNFILTERED AND FIELD ACIDIFIED XX YES NO
COD NA
mg/I
Coliform: MF Fecal NA
/100ml
Coliform: MF Total NA
/100ml
(Note: Use MPN method for highly turbid samples)
Dissolved Solids: Total 60
mg/I
pH (when analyzed) 5.10
units
TOC NA
mg/l
Chloride 16
mg/I
Arsenic NA
mg/1
Grease and Oils NA
mg/I
Hardness: Total NA
mg/I
Phenol NA
mg/I
Sulfate 1
mg/I
Specific Conductance NA
uMhos
Total Ammonia NA
mg/I
TKN as N NA
mg/I
Nitrite (NO2) as N NA
mg/I
Nitrate (NO3) as N NA
mg/I
Phosphorus: Total as P NA
mg/I
Al - Aluminum 0.07
mg/I
Ba - Barium NA
mg/I
Ca - Calcium G1.0
mg/I
Cd - Cadmium NA
mg/I
Chromium: Total 40.010
mg/I
Cu - Copper NA
mg/I
Fe - Iron o.065
mg/I
Hg - Mercury
mg/I
K - Potassium A
mg/l
Mg - Magnesium NA,
mg/I
Mn - Manganese 0,031
mg/I
Na - Sodium NA
mg/l
Ni -Nickel N,A mg/I
Pb - Lead NA mg/I
Zn - Zinc ETA mg/I
Pesticides/Herbicides
(Specify Compounds)
NA u g/I
ug/I
ug/I
Other (Specify Compounds and
Concentration units)
F'lunride 4.0-9 mg/1
Tithiiim �(n-1 mg/1
NA = Analysis not required
I CERTIFY THAT THIS REPORT IS TRUE AND ACCURATE. Note: Values should reflect dissolved and
colloidal concentrations. (see #3 on back)
12, ,,M hl * See back for instructions.
ignature of Permittee (or Nuthorized Agent*) Date ** Submit blue, green, and yellow copies only to address above.
GW-59 REV. 6/93

Type or Use a ball-point pen and press firmly.
PERMIT NUMBER: (REQUIRED))
6149
Facility Name FMC Corporation — Lithium Division
Non -Discharge I ,
Address Hwy 161, Box 795
NPDES
Bessemer City, NG 28016 County Gaston
TYPE OF DISPOSAL OPERATION BEING MONITORED
(REQUIRED)
Well Location NECarn-er of preperty,T2080 feet: upgradient
Lagoon SepticTank/Drain Field
Well Identification Number WQ--2. AKA W-7 Well Depth 3,9 5 Ft.
Well Diameter 2 in Sample (Screened) Interval 28.E Ft. To 385 Ft.
Spray Field Subsurface Low -Pressure
Piping (LPP)
Depth to Water Level 15.64 ft. below measuring point (before sampling)
Land Application of Slue
Measuring point is 1.9 ft. above lard! surlaLe
Other
n> ^�, e,
Gallons of water pumped/bailed before s�pJin �� 5.5
Rotary Distributor
5.82
Field Analysis: pH Sptwcii��Odndl�ctance 77 uMhos Temp. 18 °C
Odor None Appearance Slightly turbid
Date Sample Collected 4/25te Lab Sample Analyzed 4/27-5/10/96
Laboratory Name Pace tical
Certification No. 12
r
SAMPLES FOR METALS W1 COL�4 tr ED UNFIh,T -RED AND FIELD ACIDIFIED
YES NO
3•;,-
COD NA E,� <,tcrrlg/I
Coliform: MF Fecal NA a JWL 7100ml
Coliform: MF Total NA o,`' �.�' /100ml
(Note: Use MPN method for highly turbid samples)
Dissolved Solids: Total 60
mg/I
pH (when analyzed) 5. to
units
TOC NA
mg/1
Chloride 16
mg/1
Arsenic NA
mg/1
Grease and Oils NA
mg/I
Hardness: Total NA
mg/I
Phenol NA
mg/1
Sulfate
mg/I
Specific Conductance NA
uMhos
Total Ammonia NA
mg/I
TKN as N NA
mg/I
Nitrite (NO2) as N NA
mg/I
Nitrate (NO3) as N NA
mg/I
Phosphorus: Total as P NA
mg/I
Al - Aluminum 0.07
mg/I
Ba - Barium NA
mg/I
Ca - Calcium 4.1.0
mg/I
Cd - Cadmium NA
mg/I
Chromium: Total 40.010
mg/I
Cu - Copper NA
mg/I
Fe - Iron 0.065
mg/I
Hg - Mercury NA
mg/1
K - Potassium NA
mg/I
Mg - Magnesium N
mg/I
Mn - Manganese 0.0111
mg/I
Na - Sodium NA
mg/I
Ni - Nickel NA
mg/I
Pb - Lead NA
mg/I
Zn - Zinc NA
mg/I
Pesticides/Herbicides
(Specify Compounds)
NA
a�
=__
'' ' ug/I
Other (Specify Compounds and
7._=
Concentration units)
- �
- i"PI
F]iinrirla S0.7 mg/l
r
T i f-Hiim <n J mgil
NA = Analysis not required
I CERTIFY THAT THIS REPORT IS TRUE AND ACCURATE. Note: Values should reflect dissolved and
colloidal concentrations. (see #3 on back)
X, See back for instructions.
Signature of Permittee (or Xuthorized Agent*) Date ** Submit blue, green, and yellow copies only to address above.
GW-59 REV. 6/93

1. Samples should be analyzed as soon as possible after collection. SAMPLES WHICH ARE NOT ANALYSED WITHIN THE HOLDING TIME SPECI-
FIED FOR THE METHOD USED (SEE #4. BELOW) MUST BE DISCARDED AND NEW SAMPLES COLLECTED.
2. Metals Analyses: Use Standard Method 3030C for sample preparation (mercury excluded). DO NOT FILTER METALS SAMPLES IN THE FIELD !!!
Unfiltered samples must be collected for metals, then field acidified with 5 ml concentrated nitric acid per liter of sample, and should be submitted to the
lab within 24 hours.
Sample preparation in the laboratory (extraction and filtration) must be completed within 72 hours of collection,
lafis go WINE
i •' lei. �! + •l�rr • .•� �r •. A 1 14*14 4
4. As per Title 15, North Carolina Administrative Code, Subchapter 2L, analytical procedures shall be in accordance with the methods described in one of
the following publications, or by other methods approved beforehand by the Director, Division of Environmental
Management:
(a) Standard Methods for the Examination of Water and Wastewater, 16th Edition, 1985 and 17th Edition, 1989, published jointly by
American Public Health Association, American Water Works Association and Water Pollution Control Federation;
(b) Methods for Chemical Analysis of Water and Waste, 1979, U.S. Environmental Protection Agency publication number
EPA-600/4-79-020, as revised March 1983;
(c) Test Methods for Evaluating Solid Wastes: Physical/Chemical Methods, 3rd Edition, 1986, U.S. Environmental Protection Agency
publication number SW-846;
(d) Test Procedures for the Analysis of Polluants Under the Clean Water Act, Federal Register Vol, 49, No. 209, 40 CFR Part 136,
October 26, 1984; r
5. Measure and record the depth of water in the well prior to pumping or bailing any water from the well.
6. At least 3 volumes of water in the well should be pumped or bailed prior to collecting a sample for analysis. If the well is pumped/bailed dry before 3 well
volumes are removed, samples can be collected as soon as the well recovers to the point where enough water is available to collect your sample.
7. Determination for pH, Specific Conductance, temperature, odor and appearance must be made in the field on unfiltered samples when the sample is
collected.
8. Field equipment must be calibrated in accordance with recommendations by the manufacturer.
9. Samples must be filtered through a 0.45 micron filter immediately after collection when a dissolved analysis is required. (See #4. above)
10.The sample container should be labeled at the time of collection with the facility name, well identification number and date and time collected.
11. "Authorized agent" is any corporate officer or public official authorized by the company, corporation, or governmental body to sign official documents.

Type or Use a ball-point pen and press firmly. PERMIT NUMBER: (REQUIRED)
Facility Name FMC Corporation — Lithium Division Non -Discharge WQ0008149
Address Hwy 161,Box 795 NPDES
Bessemer City, NC 28016 County Gas tan TYPE OF DISPOSAL OPERATION BEING MONITORED
Well Location Southern Review Boundary of Kiln Ponds (REQUIRED)
Lagoon Septic Tank/Drain Field
Well Identification Number WQ-1 Well Depth 49.5 Ft.
Spray Field Subsurface Low -Pressure
Well Diameter 2 in Sample (Screened) Interval 9.5 Ft. To 49.5 Ft Piping (LPP)
Depth to Water Level 26.64 ft. below measuring point (before sampling) Land Application of Sludge
Measuring point is 2. 5 ft. above land surface ]EN other
Gallons of water pumpped/bailed before sampling
12 Rotary Distributor Re u ment
Field Analysis: pH 5. 70 Specific Conductance 2270 uMhos Temp.16 oC Odor NnnP Appearance Slimy Turbid
Date Sample Collected 4125/96 Date Lab Sample Analyzed 4127 — 5/10196
Laboratory Name Pace Analytical Certification No. 12
SAMPLES FOR METALS WERE COLLECTED UNFILTERED AND FIELD ACIDIFIED x YES NO
COD NA
mg/I
Coliform: MF Fecal
NA
/100m1
Coliform: MF Total
NA
/100ml
(Note: Use MPN method for highly turbid samples)
Dissolved Solids: Total
2500
mg/I
pH (wh'rlanalyzed_-
5.30
units
NA
mg/I
Chlerida?
42
mg/I
Arseri'c `: `�
NA
mg/I
GreAs'e,and Rils
NA
mg/I
Hartdr5s: Total
NA
mg/I
Ph ft
NA20
mg/I
Sulfate -' 4
mg/I
Spedfi� Conductan&
A�
uMhos
Total Ammonia =I
NA
mg/I
TKN as N o
NA
mg/I
Nitrite (NO2) as N
NA
mg/I
Nitrate (NO3) as N
NA
mg/I
Phosphorus: Total as P NA
mg/I
Al - Aluminum
18
mg/I
Ba - Barium
NA
mg/I
Ca - Calcium
180
mg/I
Cd - Cadmium
NA
mg/I
Chromium: Total
4 0.010
mg/I
Cu - Copper
NA
mg/I
Fe - Iron
2.5
mg/I
Hg - Mercury
NA
mg/I
K - Potassium
NAmg/I
Mg - Magnesium
NA
mg/I
Mn - Manganese
30
mg/I
Na - Sodium
NA
mg/I
Ni - Nickel NA mg/I
Pb - Lead NA mg/I
Zn - Zinc NA mg/I
Pesticides/Herbicides
(Specify Compounds) (7: e-
NA { 7 C-.) U g/I
U g/I
- U g/I
Other (Specify Compounds and
Concentration units) "'} ' -
co.
Fluoride 2.50 mg/1
Lithium 10 R Mg/1
NA = Analysis not required
I CERTIFY THAT THIS REPORT IS TRUE AND ACCURATE. Note: Values should reflect dissolved and
n colloidal concentrations. (see #3 on back)
• �'. < / � �� CH See back for instructions.
Signature of Permittee (orAuthorized Agent*) Date ** Submit blue, green, and yellow copies only to address above.
�GW-59 REV. 6/93

dr.
1 . Samples should be analyzed as soon as possible after collection. SAMPLES WHICH ARE NOT ANALYSED WITHIN THE HOLDING TIME SPECI-
FIED FOR THE METHOD USED (SEE #4. BELOW) MUST BE DISCARDED AND NEW SAMPLES COLLECTED.
2. Metals Analyses: Use Standard Method 3030C for sample preparation (mercury excluded). DO NOT FILTER METALS SAMPLES IN THE FIELD !!!
Unfiltered samples must be collected for metals, then field acidified with 5 ml concentrated nitric acid per liter of sample, and should be submitted to the
lab within 24 hours.
Sample preparation in the laboratory (extraction and filtration) must be completed within 72 hours of collection.
_111*1111)"IR age];
W
" ill I L*J.f 40 M431610A I I W01 I 'a W
I'm ;K,#441 1 "90 0 1kIF,&, 111W Maw,
_ -44- ftfft ►1, 016 MiT 1112ro
4. As per Title 15, North Carolina Administrative Code, Subchapter 2L, analytical procedures shall be in accordance with the methods described in one of
the following publications, or by other methods approved beforehand by the Director, Division of Environmental
Management:
(a) Standard Methods for the Examination of Water and Wastewater, 16th Edition, 1985 and 17th Edition, 1989, published jointly by
American Public Health Association, American Water Works Association and Water Pollution Control Federation;
(b) Methods for Chemical Analysis of Water and Waste, 1979, U.S. Environmental Protection Agency publication number
EPA-600/4-79-020, as revised March 1983;
(c) Test Methods for Evaluating Solid Wastes: Physical/Chemical Methods, 3rd Edition, 1986, U.S. Environmental Protection Agency
publication number SW-846;
(d) Test Procedures for the Analysis of Polluants Under the Clean Water Act, Federal Register Vol. 49, No. 209, 40 CFR Part 136,
October 26,1984;
5. Measure and record the depth of water in the well prior to pumping or bailing any water from the well.
6. At least 3 volumes of water in the well should be pumped or bailed prior to collecting a sample for analysis. If the well is pumped/bailed dry before 3 well
volumes are removed, samples can be collected as soon as the well recovers to the point where enough water is available to collect your sample.
7. Determination for pH, Specific Conductance, temperature, odor and appearance must be made in the field on unfiltered samples when the sample is
collected.
8. Field equipment must be calibrated in accordance with recommendations by the manufacturer.
9. Samples must be filtered through a 0.45 micron filter immediately after collection when a dissolved analysis is required. (See #4. above)
10. The sample container should be labeled at the time of collection with the facility name, well identification number and date and time collected.
11. "Authorized agent" is any corporate officer or public official authorized by the company, corporation, or governmental body to sign official documents.

FMC Corporation
Lithium Division
Highway 161
Box 795
Bessemer City North Carolina 28016
704 868 5300 Fax [phone]
+MC
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Ln
June 3, 1996
C.
O fr
North Carolina Division of Environmental
Management
Groundwater Section
P.O. Box 29535
Raleigh, NC 27626-0535
Re: FMC Corporation - Lithium Division
r�
Bessemer City - Non -Discharge Permit
No. WQ0008149
Groundwater Oualitv Monitorina - Compliance
Report Forms
Dear Sir or Madam:
In accordance with the requirements of item No. 21 of the
North Carolina Water Quality Permit No. WQ0008149 for the
Recycle System (kiln scrubber ponds) located at FMC .
Corporation's Lithium Division facility in Bessemer City, FMC
is submitting two Compliance Monitor Forms (GW-59) for the
sampling and analysis of groundwater monitoring wells WQ-1
and WQ-7 (A.K.A. W-7) on April 25, 1996. The results
reported here for aluminum, chromium, iron, lithium and
manganese were obtained using method 3030C in Standard
Methods, 17th edition for digestion and EPA method 200.7 for
analysis. The results for fluoride were obtained using EPA
method 340.2; for TDS using EPA method 160.1; for chloride
using EPA method 325.2; for sulfate using EPA -method 375.4,
and for calcium using.EPA method 200.7. Due to an error in
preparation of the laboratory request forms, pH was only
analyzed in the field. All results represent analysis of
unfiltered samples. Laboratory report sheets and chain of
custody records are available upon request.
Modified sample collection procedures, as described in FMC's
September 29, 1995 letter to DEM, were used again during this
sampling event in attempts to reduce the turbidity of
collected groundwater. Again, while turbidity has been
greatly reduced with the modification of sampling techniques,
the EPA guideline in SW-846 of five NTU has not been
achieved.
If you have any questions, or require additional information,
please contact me at 704/868-0806.
Ve tru you ,
Invirornmm
r ara E. i chie
tal Manager

cc: Mr. B. Keith Overcash, P.E.
Regional Supervisor
DEHNR / Mooresville Office
919 North Main Street
Mooresville, NC 28115

I
Type or Use a ball-point pen and press firmly.
Facility Name FMC Corporation — Lithium Division
Address Hwy 161, Box 795161, Box 795
Bessemer City, NC 28016 County Gaston rla1V
Well Location Southern review boundary of kiln scrubber ponds N.
Well Identification Number WQ-1 Well Depth 49.Ft. I
Well Diameter 2 in Sample (Screened) Interval 9.5 Ft. To 49.5 Ft.
Depth to Water Level 28.41 ft. below measuring point (before sampling)
PERMIT NUMBER: (REQWIRFp(�8149
Non -Discharge ������
NPDES
OPERATION BEING MONITORED
1E0ULIRED)tLT�=ram
QURf_Lagoon
8 1996 Spray Field
Land Application of Slue
Measuring point is 2.5 ft. above land surface G';; ,L, 7 Rotary Distributor
10 5 I'
puu.,
Gallons of water pumped/balled before sampling
Field Analysis: pH 5.7 Specific Conductance 3250 uMhos Temp. 17 °C Odor None
Date Sample Collected 11/10/95 Date Lab Sample Analyzed 12/14-18/95
Laboratory Name Pace, Inc. Certification No.
SAMPLES FOR METALS WERE COLLECTED UNFILTERED AND FIELD ACIDIFIED X YES
COD
NA
mg/1
Coliform: MF Fecal
NA
/100ml
Coliform: MF Total
NA
/100ml
(Note: Use MPN method for highly turbid samples)
Dissolved Solids: Total
2570
mg/1
pH (when analyzed)
5.7 (field)
units
TOC
NA
mg/1
Chloride
47
mg/I
Arsenic
NA
mg/I
Grease and Oils
NA
mg/I
Hardness: Total
NA
mg/I
Phenol
NA
mg/I
Sulfate L7nn
mg/l
Specific Conductance
NA
uMhos
Total Ammonia
NA
mg/I
TKN as N
NA
mg/I
Nitrite (NO2) as N
NA
mg/I
Nitrate (NO3) as N
NA
mg/I
Phosphorus: Total as P
NA
mg/I
Al - Aluminum
10
mg/I
Ba - Barium
NA
mg/I
Ca - Calcium
180
mg/I
Cd - Cadmium
NA
mg/I
Chromium: Total less
than 0.010
mg/I
Cu - Copper
NA
mg/I
Fe - Iron
0.98
mg/I
Hg - Mercury
NA
mg/I
K - Potassium
NA
mg/I
Mg - Magnesium
NA
mg/1
Mn - Manganese
33
mg/1
Na - Sodium
NA
mg/l
I CERTIFY THAT THIS REPORT IS TRUE AND ACCURATE.
✓d-4
nature of Per tt (or uthorized Agent*) to
-59 REV. 6/93
Septic Tank/Drain Field
Subsurface Low -Pressure
Piping (LPP)
Other
vcle
Appearance slight turbidity (15 NTU)
NO
12
Ni - Nickel NA
mg/1
Pb - Lead NA
mg/I
Zn - Zinc NA
���
mg/I
Pesticides/Herbicides,?
(Specify Compounds)
2F-
NA
t
r
u g/I
ug/I
= r,
ug/I
Other (Specify Compounds and -_ r'g ;
Concentration units)-
fluoride 1.1 mg/1 n in
lithium 11 mg/1 cz
NA = Analysis Not Required
Note: Values should reflect dissolved and
colloidal concentrations. (see #3 on back)
* See back for instructions.
** Submit blue, green, and yellow copies only to address above.

r
COLLECTION AND ANALYSIS OF.OROUNDWATER SAMPLES
1.. Samples should be analyzed as soon as possible after collection. SAMPLES WHICH ARE NOT ANALYSED WITHIN THE HOLDING TIME SPECI-
FIED FOR THE METHOD USED (SEE #4.,BELOW) MUST BE DISCARDED AND NEW SAMPLES COLLECTED.
2. Metals Analyses: Use Standard Method 3030C for sample preparation (mercury excluded). DO NOT FILTER METALS SAMPLES IN THE FIELD if'
Unfiltered samples must be collected for metals, then field acidified with 5 ml concentrated nitric acid per liter of sample, and should be submitted to the
lab within 24 hours.
Sample preparation in the laboratory (extraction and filtration) must be completed within 72 hours of collection.
3. ANALYSES ARE TO BE MADE OF THE MOBILE CONSTITUENTS (DISSOLVED AS WELL AS COLLOIDAL) IN THE
GROUNDWATER, NOT THOSE THAT ARE A PART OF SEDIMENT ASSOCIATED WITH WELL CONSTRUCTION OR SAMPLING PROCEDURES.
CHECK WITH YOUR LABORATORY ON PROPER PROCEDURES FOR SAMPLE COLLECTION AND PRESERVATION.
4: As per Title 15, North Carolina Administrative Code, Subchapter 2L, analytical procedures shall be in accordance with the methods described in one of
the following publications, or by other methods approved beforehand by the Director, Division of Environmental
Management:
(a) Standard Methods for the Examination of Water and Wastewater, 16th Edition, 1985 and 17th Edition, 1989, published jointly by
American Public Health Association, American Water Works Association and Water Pollution Control Federation;
(b) Methods for Chemical Analysis of Water and Waste, 1979, U.S. Environmental Protection Agency publication number
7 EPA-600/4-79-020, as revised March 1983;
(c) Test Methods for Evaluating Solid Wastes: Physical/Chemical Methods, 3rd Edition, 1986, U.S. Environmental Protection Agency
publication number SW-846;
(d) Test Procedures for the Analysis of Polluants Under the Clean Water Act, Federal Register Vol. 49, No. 209, 40 CFR Part 136,
October 26, 1984;
5. Measure and record the depth of water in the well prior to pumping or bailing any water from the well.
6. At least 3 Volumes of water in the well should be pumped or bailed prior to collecting a sample for analysis. If the well is pumped/bailed dry before 3 well
volumes are removed, samples can be collected as soon as the well recovers to the point where enough water is available to collect your sample.
7. Determination for pH, Specific Conductance, temperature, odor and appearance must be made in the field on unfiltered samples when the sample is
collected.
8. Field equipment must be calibrated in accordance with recommendations by the manufacturer.
9. Samples must be filtered through a 0.45 micron filter immediately after collection when a dissolved analysis is required. (See #4. above)
10,The sample container should be labeled at the time of collection with the facility name, well identification number and date and time collected.
11. "Authorized agent" is any corporate officer or public official authorized by the company, corporation, or governmental body to sign official documents.

Type or Use a ball-point pen and press firmly.
Facility Name FMC Corporation - Lithium Division
Address Hwy 161, Box 795
Bessemer City, NC 28016 County Gaston
Well Location NE Corner of property, greater than 2000 ft upgradient
Well Identification Number W-7 AKA WQ-7 Well Depth 38.5 Ft.
Well Diameter 2 in Sample (Screened) Interval 28.5 Ft. To 38.5 Ft.
Depth to Water Level 15.78 ft. below measuring point (before sampling)
Measuring point is 1.9 ft. above land surface
Gallons of water pumped/bailed before sampling 5
Field Analysis: pH 4. 93 Specific Conductance 80 uMhos Temp. 18 °C
Date Sample Collected 11/30/95 Date Lab Sample Analyzed 12/4-18/95
Laboratory Name Pace, Inc.
SAMPLES FOR METALS WERE COLLECTED UNFILTERED AND FIELD ACIDIFIED X
COD NA
mg/I
Coliform: MF Fecal
NA
/100ml
Coliform: MF Total
NA
/100m1
(Note: Use MPN method for highly
turbid samples)
Dissolved Solids: Total
60
mg/I
pH (when analyzed)
4.9 (field)
units
TOC
NA
mg/I
Chloride
is
mg/I
Arsenic
NA
mg/I
Grease and Oils
NA
mg/I
Hardness: Total
NA
mg/I
Phenol
NA
mg/I
Sulfate
4.4
mg/I
Specific Conductance
NA
uMhos
Total Ammonia
NA
mg/I
TKN as N
NA
mg/I
PERMIT NUMBER: (REQUIRED)
Non -Discharge WQ00091 49
NPDES
TYPE OF DISPOSAL OPERATION BEING MONITORED
(REQUIRED)
Lagoon Septic Tank/Drain Field
Spray Field Subsurface Low -Pressure
Piping (LPP)
Land Application of Sludge
X Other
Rotary Distributor Recvcle Imnoundmei
Odor None Appearance slight turbidity (30 NTU)
Certification No.
YES
Nitrite (NO2) as N
NA
mg/I
Nitrate'(NO3) as N
NA
mg/I
Phosphorus: Total as P
NA
mg/I
AI - Aluminum
0.14
mg/I
Ba - Barium
NA
mg/I
Ca - Calcium less than 1.0
mg/I
Cd - Cadmium
NA
mg/I
Chromium: Total less
than o pi
mg/I
Cu - Copper
NA
mg/I
Fe - Iron
0.59
mg/I
Hg - Mercury
NA
mg/I
K - Potassium
NA
mg/I
Mg - Magnesium
NA
mg/I
Mn - Manganese
0.029
mg/I
Na - Sodium
NA
mg/I
I CERTIFY THAT THIS/REPORT IS TRUE AND ACCURATE.
ature of
Authorized Agent*)
/4�
.Plate
NO
12
Ni - Nickel NA mg/I
Pb - Lead NA mg/I
Zn - Zinc NA mg/I
Pesticides/Herbicides
(Specify Compounds)
NA Ug/I
Ug/I
Ug/I
Other (Specify Compounds and
Concentration units)
f1 uorld P 1Pss than 0 1 mg/1
lithium less than 0.01 mg/1
Note: Values should reflect dissolved and
colloidal concentrations. (see #3 on back)
* See back for instructions.
** Submit blue, green, and yellow copies only to address above.
GW-59 REV. 6/93

1. Samples should be analyzed as soon as possible after collection. SAMPLES W_ HICH ARE NOT ANALYSED WITHIN THE HOLDING TIME SPECI-
FIED FOR THE METHOD USED (SEE #4: BELOW) MUST BE DISCARDED AND NEW SAMPLES COLLECTED.
2. Metals Analyses: Use Standard Method 3030C for sample preparation (mercury excluded). DO NOT FILTER METALS SAMPLES IN THE FIELD.!!!
Unfiltered samples must be collected for metals, then field acidified with 5 ml concentrated nitric acid per liter of sample, and should be submitted to the
lab within 24 hours.
Sample preparation in the laboratory (extraction and filtration) must be completed within 72 hours of collection.
3. ANALYSES ARE TO BE MADE OF THE MOBILE CONSTITUENTS (DISSOLVED AS WELL AS COLLOIDAL) IN THE
GROUNDWATER, NOT THOSE THAT ARE A PART OF SEDIMENT ASSOCIATED WITH WELL CONSTRUCTION OR SAMPLING PROCEDURES.
CHECK WITH YOUR LABORATORY ON PROPER PROCEDURES FOR SAMPLE COLLECTION AND PRESERVATION.
4. As per Title 15, North Carolina Administrative Code, Subchapter 2L, analytical procedures shall be in accordance with the methods described in one of
the following publications, or by other methods approved beforehand by the Director, Division of Environmental
Management:
(a) Standard Methods for the Examination of Water and Wastewater, 16th Edition, 1985 and 17th Edition, 1989, published jointly by
American Public Health Association, American Water Works Association and Water Pollution Control Federation;
(b) Methods for Chemical Analysis of Water and Waste, 1979, U.S. Environmental Protection Agency publication number
EPA-600/4-79-020, as revised March 1983;
(c) Test Methods for Evaluating Solid Wastes: Physical/Chemical Methods, 3rd Edition, 1986, U.S. Environmental Protection Agency
publication number SW-846;
(d) Test Procedures for the Analysis of Polluants Under the Clean Water Act, Federal Register Vol. 49, No. 209, 40 CFR Part 136,
October 26, 1984;
5. Measure and record the depth of water in the well prior to pumping or bailing any water from the'well.
6. At least 3 volumes of water in the well should be pumped or bailed prior to collecting a sample for analysis. If the well is pumped/bailed dry before 3 welf
volumes are removed, samples can be collected as soon as the well recovers to the point where enough water is available to collect your sample.
7. Determination for pH, Specific Conductance, temperature, odor and appearance must be made in the field on unfiltered samples when the sample is
collected.
8. Field equipment must be calibrated in accordance with recommendations by the manufacturer.
9. Samples must be filtered through a 0.45 micron filter immediately after collection when a dissolved analysis is required. (See #4. above)
10.The sample container should be labeled at the time of collection with the facility name, well identification number and date and time collected.
11."Authorized agent" is any corporate officer or public official authorized by the company, corporation, or governmental body to sign official documents.

FMC Corporation
Lithium Division
Highway 161
Box 795
Bessemer City North Carolina 28016
704 868 5300 Fax [phone]
fMC
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
January 3, 1996
North Carolina Division of Environmental Management
Groundwater Section
P.O. Box 29535
Raleigh, NC 27626-0535
Re: FMC Corporation - Lithium Division
Bessemer City - Non -Discharge Permit No. WQ0008149
Groundwater Quality Monitoring - Compliance Report Forms
Dear Sir or Madam:
In accordance with the requirements of item No. 21 of the
North Carolina Water Quality Permit No. WQ0008149 for the
Recycle System (kiln scrubber ponds) located at FMC
Corporation's Lithium Division facility in Bessemer City, FMC
is submitting two Compliance Monitor Forms (GW-59) for the
sampling and analysis of groundwater monitoring wells WQ-1
and WQ-7 (A.K.A. W-7) on November 30, 1995. The results
reported here for aluminum, chromium, iron, lithium and
manganese were obtained using method 3030C in Standard
Methods, 17th edition for digestion and EPA method 200.7 for
analysis. The results for fluoride were obtained using EPA
method 340.2; for TDS using EPA method 160.1; for chloride
using EPA method 325.2; for sulfate using EPA method 375.4,
and for calcium using EPA method 200.7. Due to an error in
preparation.of the laboratory request forms, pH was only
analyzed in the field. All results represent analysis of
unfiltered samples. Laboratory report sheets and chain of
custody records are available upon request.
Modified sample collection procedures, as described in FMC's
September 29, 1995 letter to DEM, were used again during this
sampling event in attempts to reduce the turbidity of
collected groundwater. Again, while turbidity in the samples
has been greatly reduced with the modification of sampling
techniques, the EPA guideline in SW-846 of five NTU has not
been achieved. Given that observed turbidity in the
upgradient, background well WQ-7 is generally higher than
that in WQ-1 which is downgradient of the monitored units,
0
Z�S ^�

NCDEM = Groundwater Section
Permit No. WQ0008149
January 3, 1996 - Page 2
FMC believes that the turbidities are simply characteristic
of wells installed in the native silty clay saprolite, the
upper -most geologic feature in the area and spodumene ore
tailings landfilled on site pursuant to solid waste permit
No. 36-05.
Lastly, FMC notes that the groundwater monitoring program for
wells associated with the solid waste landfill requires
monitoring during the month of May and November and that the
groundwater monitoring for Permit No. WQ0008149 stipulates
monitoring in April, August and December. Historically, FMC
has coordinated the spring and fall monitoring events under
the two programs to occur on the last day of one month and
the first day of the next month so as to more effectively
manage mobilization of the sampling technicians.
Nonetheless, on November 30, 1995, the sampling technicians
completed the sampling of the wells associated with the
landfill and proceeded with sampling the wells associated
with Permit No. WQ0008149, believing that FMC would
appreciate the economies of a single days labor. If the
calendar month variation poses a problem, please advise.
Finally, due to Christmas holidays, the receipt and
subsequent submittal of the sampling results was slightly
affected.
If you have any questions, or require additional information,
please contact me at 704/868-0806.
Ver truly yours,-
/arbara E. itchie
Environme tal Manager
cc: Mr. B. Keith Overcash, P.E.
Regional Supervisor
DEHNR / Mooresville Office
919 North Main Street
Mooresville, NC 28115

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Type or Use a ball-point pen and press firmly. PERMIT NUMBER: (REQUIRED) JIM 8 199
Facility Name FMC- C.oe-P— 1-11'17$1 uM �> V /'S)O /✓ Non -Discharge VJ62 000 T�
& 1 _ I� d � 9 �— NPDES
Address TYPE OF DISPOSAL OPERATION BEING MONITORi011 OF fR;r�1Yt,7tFfFAI !;!(
GAS �12 %t �l County G� f (REQUIRED) �'f0DPESYlia4 p�P,ayl �F ;
Well Location �a v1#5 +� � � �"'� �l 2� Dr- Kt L � � jeUA61� st l5 Lagoon Septic Tank/Drain FLX"
Well Identification Number Well Depth 157 Ft. Spray Field Subsurface Low -Pressure
Well Diameter o h Sample (Screened) Interval Ft. To Ft. Piping (LPP)
Depth to Water Level ,30 ° 2-f ft. below measuring point (before sampling) Land Application of sledge
Measuring point is 2­5_ ft. above land surface _ _L other
cL Rotary Distributor
Gallons of water pumped/bailed before sampling 7
Field Analysis: pH 4-`I'5_ Specific Conductance 2050 uMhos Temp. `'L °C Odor Appearance M - f�—���- 1a►
Date Sample Collected IkA w 1 199 5- Date Lab Sample Analyzed A4611 4- )% l9`7S
LaboratoryName •PA-Cr— , ) AJL Certification No. J Z"
SAMPLES FOR METALS WERE COLLECTED UNFILTERED AND FIELD ACIDIFIED AYES NO
COD
NA
mg/I
Coliform: MF Fecal
N'k
/100ml
Coliform: MF Total
IQA"
/100ml
(Note: Use MPN method for highly
turbid samples)
41011°®'
Dissolved Solids: Total
mg/I
pH (when analyzed)
+j 5LP units
TOC
NA
mg/1
Chloride
Sq
mg/I
Arsenic
Ns
mg/I
Grease and Oils
NA-
mg/I
Hardness: Total
N4
mg/I
Phenol
NA
mg/I
Sulfate
Kam
mg/1
Specific Conductance
Na
uMhos
Total Ammonia
N&
mg/I
TKN as N
IV A-
mg/I
Nitrite (NO2) as N
" &
mg/I
Nitrate (NO3) as N
Nlk
mg/I
Phosphorus: Total as P Npr
mg/I
Al - Aluminum
Avawkw mg/I
Ba - Barium
tJ nr
mg/I
Ca - Calcium
111SPEW
mg/I
Cd - Cadmium
NA
mg/I
Chromium: Total
{ 0. 01 ©
mg/I
Cu - Copper
NA-
mg/I
Fe - Iron
mg/I
Hg - Mercury
mg/I
K - Potassium
/VA
mg/I
Mg - Magnesium
/Upt-
mg/I
Mn - Manganese
N@wg
mg/I
Na - Sodium
1JA
mg/I
I CERTIFY THAT THIS REPORT IS TRUE AND ACCURATE.
ature of Permittee (ofVAuthorized Agent*)
Ni - Nickel NA
mg/I
Pb - Lead 0A_
t-Ag/I
Zn - Zinc PA
Pesticides/Herbicides;
,
(Specify Compounds) NAr
©m
t
tit
Other (Specify Compounds and
r �y
Concentration units)
at
rn
RA-- NNA�! srS Ni7T P —IN
Note: Values should reflect dissolved and
colloidal concentrations. (see #3 on back)
`� �✓U �, �JS See back for instructions.
Date Submit blue, green, and yellow copies only to address above.
E
,JRC::,S
GW-59 REV. 6/93

COLLECTION AND ANALYSIS OF GROUNDWATER SAMPLES
1 - Samples should be analyzed as soon as possible after collection. SAMPLES WHICH ARE NOT ANALYSED WITHIN THE HOLDING TIME SPECI-
FIED FOR THE METHOD USED (SEE #4. BELOW) MUST BE DISCARDED AND NEW SAMPLES COLLECTED.
2. Metals Analyses: Use Standard Method 3030C for sample preparation (mercury excluded). DO NOT FILTER METALS SAMPLES IN THE FIELD H!
Unfiltered samples must be collected for metals, then field acidified with 5 ml concentrated nitric acid per liter of sample, and should be submitted to the
lab within 24 hours.
Sample preparation in the laboratory (extraction and filtration) must be completed within 72 hours of collection.
3. ANALYSES ARE TO BE MADE OF THE MOBILE CONSTITUENTS (DISSOLVED AS WELL AS COLLOIDAL) IN THE
GROUNDWATER, NOT THOSE THAT ARE A PART OF SEDIMENT ASSOCIATED WITH WELL CONSTRUCTION OR SAMPLING PROCEDURES.
CHECK WITH YOUR LABORATORY ON PROPER PROCEDURES FOR SAMPLE COLLECTION AND PRESERVATION.
4. As per Title 15, North Carolina Administrative Code, Subchapter 2L, analytical procedures shall be in accordance with the methods described in one of
the following publications, or by other methods approved beforehand by the Director, Division of Environmental
Management:
(a) Standard Methods for the Examination of Water and Wastewater, 16th Edition, 1985 and 17th Edition, 1989, published jointly by
American Public Health Association, American Water Works Association and Water Pollution Control Federation;
(b) Methods for Chemical Analysis of Water and Waste, 1979, U.S. Environmental Protection Agency publication number
EPA-600/4-79-020, as revised March 1983;
(c) Test Methods for Evaluating Solid Wastes; Physical/Chemical Methods, 3rd Edition, 1986, U.S. Environmental Protection Agency
publication number SW-846;
(d) Test Procedures for the Analysis of Polluants Under the Clean Water Act, Federal Register Vol-. 49, No. 209, 40 CFR Part 136,
` October 26, 1984;
5.-,Measure and record the depth of water in the well prior to pumping or bailing any water from the well.
6. At least 3 volumes of water in the well should be pumped or ba"iled"prior to collecting a sample for analysis. If the well is pumped/bailed dry before 3 well
volumes are removed, samples can be collected as soon as the well recovers to the point where enough water is available to collect your sample._
7. Determination for pH, Specific Conductance, temperature, odor andrappearance must be made in the field on unfiltered samples when the sample is
collected.
8. Field equipment must be calibrated in accordance with recommendations by the manufacturer.
9. Samples must be filtered through a 0.45 micron filter immediately after collection when a dissolved analysis is required. (See #4. above)
10.The sample container should be labeled at the time of collection with the facility name, well identification number and date and time collected.
11."Authorized agent" is any corporate officer or public official authorized by the company, corporation, or governmental body to sign official documents.

Type or
Facility Name M C_ Cc P-P —
Address 1+1 Cr141i1rA jd II
a ball-point pen and press firmly. PERMIT NUMBER: (REQUIRED)
1lJi�)'1 �1 i/I <>% O/J Non -Discharge
—F? NPDES
Count �T1�� TYPE OF DISPOSAL OPERATION BEING MONITORED
QR-�1�2 OF Pf� Zoeo° UPtiLr}b �
Well Location N C' (RF�InRFrn
Well Identification Number IU-V Vv Well Depth 36-5- Ft.
Well Diameter 7- in - Sample (Screened) Interval 30 0 5 Ft. To 3645'­Ft.
Depth to Water Level 18 - 2- ft. below measuring point (before sampling)
Measuring point is 1. 9 ft. above land surface
Gallons of water pumped/bailed before sampling
Field Analysis: pH '1- l0 3 Specific Conductance i z7— uMhos Temp. 18 °C Odor
Date Sample Collected AAA! I 1 R!R 57 Date Lab Sample Analyzed M" 19115"'
Lagoon Septic Tank/Drain Field
Spray Field Subsurface Low -Pressure
Piping (LPP)
Land Application of Sludge
X Other
Rotary Distributor (2rr, x c i—s- %ti1 PevND"
N°&�%- Appearance MOD ►�T� 1 v2B�l%Wj1 015- N7-44—)
LaboratoryName _?A Cr , I N c Certification No.
SAMPLES FOR METALS WERE COLLECTED UNFILTERED AND FIELD ACIDIFIED __t/ YES NO
COD
V
mg/I
Coliform: MF Fecal
tJA
/100ml
Coliform: MF Total
1!A-
/100ml
(Note: Use MPN method for highly turbid
samples)
Dissolved Solids: Totals
mg/I
pH (when analyzed)
5101 P
units
TOC
N/3
mg/I
Chloride
ib
mg/I
Arsenic
NA
mg/l
Grease and Oils
rjA
mg/I
Hardness: Total
NA
mg/I
Phenol
N
mg/I
Sulfate
5,10
mg/I
Specific Conductance
NA
uMhos
Total Ammonia
NA
mg/I
TKN as N
0 Pr
mg/I
Nitrite (NO2) as N
tJA
mg/I
Nitrate (NO3) as N
NA
mg/I
Phosphorus: Total as P
NA-
mg/I
Al - Aluminum
0.110
mg/I
Ba - Barium
NPT
mg/I
Ca - Calcium_
3;03
mg/I
Cd - Cadmium
t4A
mg/I
Chromium: Total
0.01
mg/I
Cu - Copper
NPr
mg/I
Fe - Iron
�� °�"if�
mg/I
Hg - Mercury
mg/I
K - Potassium
N
mg/I
Mg - Magnesium
N
mg/I
Mn - Manganese
mg/I
Na - Sodium
Kik
mg/I
I CERTIFY THAT THIS REPORT IS TRUE AND ACCURATE.
ature of Pe
orized Agent*)
Ni - Nickel
IIJA
C7 mg/I
Pb - Lead
�"�
�'
mg/I
Zn- Zincfg/I
Pesticides/Herbicides
(Specify Compounds)
°
Other'(Specify Compounds and
Cn C.
U)
Concentration units)
Fw©ra—i 0,
�tY� tvy►1 zo � Vic°
NA.;- /ANAW `."15 o-r— kf_-Ovpela�
Note: Values should reflect dissolved and
colloidal concentrations. (see #3 on back)
t1N-- z1 115 S See back for instructions.
Date ** Submit blue, green, and yellow copies only to address above.
GW-59 REV. 6/93

COLLECTION AND ANALYSIS OF GROUNDWATER SAMPLES
1. Samples should be analyzed as soon as possible after collection. SAMPLES WHICH ARE NOT ANALYSED WITHIN THE HOLDING TIME SPECI-
FIED FOR THE METHOD USED (SEE #4. BELOW) MUST BE DISCARDED AND NEW SAMPLES COLLECTED.
2. Metals Analyses: Use Standard Method 3030C for sample preparation (mercury excluded). DO NOT FILTER METALS SAMPLES IN THE FIELD !!!
Unfiltered samples must be collected for metals, then field acidified with 5 ml concentrated nitric acid per liter of sample, and should be submitted to the
lab within 24 hours. -
Sample preparation in the laboratory (extraction and filtration) must be completed within 72 hours of collection.
3. ANALYSES ARE TO BE MADE OF THE MOBILE CONSTITUENTS (DISSOLVED AS WELL AS COLLOIDAL) IN THE
GROUNDWATER, NOT THOSE THAT ARE A PART OF SEDIMENT ASSOCIATED WITH WELL CONSTRUCTION OR SAMPLING PROCEDURES.
CHECK WITH YOUR LABORATORY ON PROPER PROCEDURES FOR SAMPLE COLLECTION'AND PRESERVATION.
4. As per Title 15, North Carolina Administrative Code, Subchapter 2L, analytical procedures shall be in accordance with the methods described in one of
the following publications, or by other methods approved beforehand by the Director, Division of Environmental
Management:
(a) Standard Methods for the Examination of Water and Wastewater, 16th Edition, 1985 and 17th Edition, 1989, published jointly by
American Public Health Association, American Water Works Association and Water Pollution Control Federation;
n (b) Methods for Chemical Analysis of Water and'Waste, 1979, U.S. Environmental Protection Agency publication number
EPA-600/4-79-020, as revised March 1983;
.• (c) Test Methods for Evaluating Solid Wastes: Physical/Chemical Methods, 3rd Edition, 1986, U.S. Environmental Protection Agency
publication number SW-846;
(d) Test Procedures for the Analysis of Polluants Under the Clean Water Act, Federal Register Vol. 49, No. 209, 40 CFR Part 136,
October 26, 1984;
5. ;measure and record the depth of water in the well prior to pumping or bailing any water from the well.
6. Adeast 3 volumes of water in the well should be pumped or bailed prior to collecting a sample for analysis. If the well is pumped/bailed dry before 3 well
volumes are removed, samples can be collected as soon as the well recovers to the point where enough water is available to collect your sample.
7. Determination for pH, Specific Conductance, temperature, odor and appearance must be made in the field on unfiltered samples when the sample is
collected.
8. Field equipment must be calibrated in accordance with recommendations by the manufacturer.
9. Samples must be filtered through a 0.45 micron filter immediately after collection when a dissolved analysis is required. (See #4. above)
10.The sample container should be labeled at the time of collection with the facility name, well identification number and date and time collected.
11."Authorized agent' is any corporate officer or public official authorized by the company, corporation, or governmental body to sign official documents.

FMC Corporation
Lithium Division
Highway 161
Box 795
Bessemer City North Carolina 28016
704 868 5300 Fax [phone]
+MC
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
_fs�
June 2, 1995�
North Carolina -Division of Environmental Management u,
Groundwater Section `r
P.O. Box 29535
Raleigh, NC; 27626-0535
Re: FMC Corporation - Lithium Division
Bessemer City - Non -Discharge Permit No. WQ0008149
Groundwater Quality Monitoring - Compliance Report Forms
Dear Sir or Madam:
In accordance with the requirements of item No. 21 of the North
Carolina Water Quality Permit No. WQ0008149 for the Recycle
System (kiln scrubber ponds) located at FMC Corporation's Lithium
Division facility in Bessemer City, FMC is submitting two
Compliance Monitor Forms (GW-59) for the sampling and analysis of
groundwater monitoring wells WQ-1.and WQ-7 (A.K.A. W-7) on May 1,
1995. As agreed with North Carolina Department of Environment,
Health and Natural Resources staff in Mooresville, the sampling
schedule for these wells was adjusted by one day to allow -for
sampling concurrent with that required under FMC's industrial
waste landfill permit.
The results reported here for aluminum, chromium, iron, lithium
and manganese were obtained using method 3030C in Standard
Methods, 17th edition, as required in Permit No. WQ0008149 for
digestion and EPA method 200.7 for analysis. The results for
fluoride were obtained using EPA method 340.2; for TDS using EPA
method 160.1; for pH using EPA method 150.1; for chloride using
EPA method 325.2; for sulfate using EPA method 375.4, and for
calcium using EPA method 200.7. All results represent analysis
of unfiltered samples. Laboratory report sheets and chain of
custody records are available upon request.
Additionally, as initally discussed in FMC's February 10, 1995
letter, the results reported here for both WQ-1 and WQ-7 exceed
the standards promulgated at 15A NCAC 2L .0202 for pH, iron and
manganese and in WQ-7 only, for total dissolved solids, sulfate,

NCDEHNR - Groundwater Section
NDP No. WQ0008149
June 2, 1995 - Page 2
and marginally for fluoride. Although significant efforts were
made to further develop the well, turbidity remains high and FMC
believes that the turdidity is very much related to many of these
results. The report which FMC is preparing for the RCRA facility
investigation (RFI) conducted pursuant to work plan approved by
the NCDEHNR Division of Solid and Hazardous Waste Managment will
address this phenomena site wide as metals were analyzed in both
filtered and unfiltered samples during that study. As discussed
previously, the RFI report, which will discuss this issue, as
well as site wide hydrogeology, will be made available to DEM
Groundwater section when finalized.
FMC will again sample wells WQ-1 and WQ-2 AKA W-7 in August 1995,
as specified in item 21 of Permit No. WQ0008149, as amended
January 17, 1995. If you have any questions, or require
additional information, please contact me at 704/868-0806.
Ve y truly you s,
Barbara itchie
Environ ental Manager
cc: Mr. Brian Wagner
DEHNR - Groundwater Section
512 North Salisbury Street
Raleigh, NC 27604

Type or Use a ball-point pen and press firmly.
Facility Name FMC Corporation — Lithium Division
Address Hwy 161, Box
795
Well Location North
Well Identification Num
Well Diameter 2 in
Depth to Water Level -
County carton
Well Depth 38.5 Ft.
.5 Ft. To 38.5 Ft.
r_...t (before sampling)
PERMIT NUMBER: (REQUIR�())08149
Non -Discharge W
NPDES
TYPE OF DISPOSAL OPERATION BEING MONITORED
(REQUIRED)
Measuring point is 1.9 ft. above land surface
Gallons of water pumped/bailed before sampling 6
Field Analysis: pH 4.93 Specific Conductance 200 uMhos Temp. 20 oC Odor None
Date Sample Collected 8 30/95 Date Lab Sample Analyzed 8/30-9/18/95
Lagoon Septic Tank/Drain Field
Spray Field Subsurface Low -Pressure
Piping (LPP)
Land Application of Slu e
_ Other
Rotary Distributor Recvdl•6- Vtnvoundmenti
Appearance Low Turbid"x?fKP-11
Laboratory Name Pace Inc. Huntersville, NC Certification No. _
SAMPLES FOR METALS WERE COLLECTED UNFILTERED AND FIELD ACIDIFIED _YES NO
COD
mg/I
Nitrite (NO2) as N
mg/I
Ni - Nickel a r��s:�[i1lll� i-;I'i;�°=13'°�Lmg/I
Coliform: MF Fecal
/100ml
Nitrate (NO3) as N
mg/I
Pb - Lead
mg/I
Coliform: MF Total
/100ml
Phosphorus: Total as P
mg/I
Zn - Zinc
��_;'mg/I
(Note: Use MPN method for highly turbid samples)
Al - Aluminum 0.163
mg/I
Pesticides/Herbicides
Dissolved Solids: Total 56
mg/I
Ba - Barium
mg/I
(Specify Compounds)
A�
-
pH (when analyzed) 4.98
units
Ca - Calcium 0.23
mg/I
- ug/I
TOC
mg/I
Cd - Cadmium
mg/I
=
"`` ug/I
Chloride
mg/I
Chromium: Total less than 0.010
mg/I
`-'-' = ug/I
Arsenic
mg/I
Cu - Copper
mg/I
Other (Specify Compounds and,n
Grease and Oils
mg/I
Fe - Iron 0.304
mg/I
Concentration units)
Hardness: Total
mg/I
Hg - Mercury
mg/I
fluoride 0.22 mg/1
Phenol
mg/I
K - Potassium
mg/I
lithium less than 0.1
mg/1
Sulfate less than 1 mg/I Mg - Magnesium mg/I
Specific Conductance uMhos Mn - Manganese 0.035 mg/I
Total Ammonia mg/I Na - Sodium mg/I
TKN as N mg/I
I CERTIFY THAT THIS REPORT IS TRUE AND ACCURATE. Note: Values should reflect dissolved and
1� colloidal concentrations. (see #3 on back)
D
gn,hture of Permittee (or
rized Agent*)
* See back for instructions.
** Submit blue, green, and yellow copies only to address above.
REV. 6/93

COLLECTION AND ANALYSIS OF GROUNDWATER SAMPLES
11. Samples.should be analyzed as soon as possible after collection. SAMPLES WHICH ARE NOT ANALYSED WITHIN THE HOLDING TIME SPECI-
FIED FOR THE METHOD USED (SEE #4. BELOW) MUST DE DISCARDED AND NEW SAMPLES COLLECTED.
2. Metals Analyses: Use Standard Method 3030C for sample preparation (mercury excluded). DO NOT FILTER METALS SAMPLES IN THE FIELD !!!
Unfiltered samples must be collected for metals, then field acidified with 5 ml concentrated nitric acid per liter of sample, and should be submitted to the
lab within 24 hours.
Sample preparation in the laboratory (extraction and filtration) must be completed within 72 hours of collection.
OMA, 107041
`• ��, "� �. i.., al�, z N
4. As per Title 15, North Carolina Administrative Code, Subchapter 2L, analytical procedures shall be in accordance with the methods described in one of
the following publications, or by other methods approved beforehand by the Director, Division of Environmental
Management:
(a) Standard Methods for the Examination of Water and Wastewater, 16th Edition, 1985 and 17th Edition, 1989, published jointly by
American Public Health Association, American Water Works Association and Water Pollution Control Federation;
(b) Methods for Chemical Analysis of Water and Waste, 1979, U.S. Environmental Protection Agency publication number
EPA-600/4-79-020, as revised March 1983;
(c) Test Methods for Evaluating Solid Wastes: Physical/Chemical Methods, 3rd Edition, 1986, U.S. Environmental Protection Agency
publication number SW-846;
(d) Test Procedures for the Analysis of Polluants Under the Clean Water Act, Federal Register Vol. 49, No. 209, 40 CFR Part 136,
October 26, 1984;
5. Measure and record the depth of water in the well prior to pumping or bailing any water from the well.
6. At least 3 volumes of water in the well should be pumped or bailed prior to collecting a sample for analysis. If the well is pumped/bailed dry before 3 well
volumes are removed, samples can be collected as soon as the well recovers to the point where enough water is available to collect your sample.
7. Determination for pH, Specific Conductance, temperature, odor and appearance must be made in the field on unfiltered samples when the sample is
collected.
8. Field equipment must be calibrated in accordance with recommendations by the manufacturer.
9. Samples must be filtered through a 0.45 micron filter immediately after collection when a dissolved analysis is required. (See #4. above)
1 O.The sample container should be labeled at the time of collection with the facility name, well identification number and date and time collected.
11. "Authorized agent" is any corporate officer or public official authorized by the company, corporation, or governmental body to sign official documents.

Facility Name
Type or Use a ball-point pen and press firmly.
FMC Corporation — Lithium Division
Address Hwy 161, Box 795
Bessemer City, NC 28016 County Gaston
Well Location Southern boundary of kiln scrubber ponds
Well Identificatioy Number WQ-1 Well Depth 49.5 Ft.
Well Diameter in Sample (Screened) Interval 9.5 Ft. To 49.5 Ft.
Depth to Water Level 33.63 ft. below measuring point (before sampling)
Measuring point is 2.5 ft. above land surface
Gallons of water pumped/bailed before sampling 8.25
Field Analysis: pH4.5 Specific Conductance 2400 uMhos Temp 18 oC
Date Sample Collected 8/30/95 Date Lab Sample Analyzed 8 30-9 18/95
LaboratoryName Pace Inc. Huntersville, NC
SAMPLES FOR METALS WERE COLLECTED UNFILTERED AND FIELD ACIDIFIED
COD
Coliform: MF Fecal
Coliform: MF Total
(Note: Use MPN method for highly turbid samples)
_ mg/I
/100ml
/100ml
Dissolved Solids: Total 2100
mg/I
pH (when analyzed) 4.41
units
TOC
mg/I
Chloride 59
mg/I
Arsenic
mg/I
Grease and Oils
mg/I
Hardness: Total
mg/I
Phenol
mg/I
Sulfate 1300
mg/I
Specific Conductance
uMhos
Total Ammonia
mg/I
TKN as N
mg/I
PERMIT NUMBER: (REQUIRED)
Non -Discharge WQ0008149
NPDES
TYPE OF DISPOSAL OPERATION BEING MONITORED
(REQUIRED)
Odor None
Certification No.
YES
Lagoon
Septic Tank/Drain Field
Spray Field Subsurface Low -Pressure
Piping (LPP)
Land Application of Sludge
x Other
Rotary Distributor Recvcle Impoundments
Appearance Low Turbidity
707
12
Nitrite (NO2) as N
mg/I
Ni - Nickel
p'
mg/I
Nitrate (NO3) as N
mg/I
Pb - Lead
u,
mg/I
Phosphorus: Total as P
mg/I
Zn -Zinc
va
'DT?
mg/I
Al - Aluminum 14.8
mg/I
Pesticides/Herbicides
—�
r;
Ba - Barium
mg/I
(Specify Compounds)
v
-
Ca -Calcium 80
m /I
"d
u /I
Cd - Cadmium
mg/I
: r ;
ug/I
Chromium: Total less than 0.010
mg/I
ug/I
Cu - Copper
mg/I
Other (Specify Compounds and
•f'
ct)
Fe - Iron 1.18
mg/I
Concentration units)
r.
Hg - Mercury
mg/I
Fluoride 2.6 mg/1
K - Potassium
mg/I
lithium 11.8 mg/l
Mg - Magnesium
mg/I
Mn - Manganese 36.0
mg/I
Na - Sodium
mg/I
CERTIFY THAT THIS REPORT IS TRUE AND ACCURATE.
re of Permittbe (;f Authorized Agent*)
Dat
Note: Values should reflect dissolved and
colloidal concentrations. (see #3 on back)
See back for instructions.
** Submit blue, green, and yellow copies only to address above.
REV. 6/93

COLLECTION AND ANALYSIS OF GR0UNDWATER SAMPLES -
Samples should be analyzed as soon as possible after collection. SAMPLES WHICH ARE NOT ANALYSED WITHIN_ THE HOLDING TIME SPECI-
FIED FOR THE METHOD USED (SEE.#4..BELOW) MUST BE DISCARDED AND NEW SAMPLES COLLECTED.
2. Metals Analyses: Use Standard Method 3030C for sample preparation (mercury excluded). DO NOT FILTER METALS SAMPLES IN THE FIELD !9!
Unfiltered samples most be collected for metals,-th-en field acidified with 5 ml concentrated nitric acid per liter of sample, and should be submitted to the
lab within 24 hours.
Sample preparation in the laboratory (extraction and filtration) must be completed within 72 hours of collection.
3. ANALYSES ARE TO BE MADE OF THE MOBILE CONSTITUENTS (DISSOLVED AS WELL AS COLLOIDAL) IN THE
GROUNDWATER, NOT THOSE THAT ARE A PART OF SEDIMENT ASSOCIATED WITH WELL CONSTRUCTION OR SAMPLING PROCEDURES.
CHECK WITH YOUR LABORATORY ON PROPER PROCEDURES FOR SAMPLE COLLECTION AND PRESERVATION.
4. As per Title 15, North Carolina Administrative Code, Subchapter 2L, analytical procedures shall be in accordance with the methods described in one of
the following publications, or by other methods approved beforehand by the Director, Division of Environmental
Management:
(a) Standard Methods for the Examination of Water and Wastewater, 16th Edition, 1985 and 17th Edition, 1989, published jointly by
American Public Health Association, American Water Works Association and Water Pollution Control Federation;
(b) Methods for Chemical Analysis of Water and Waste, 1979, U.S. Environmental Protection Agency publication number
EPA-600/4-79-020, as revised March 1983;
"- (c) Test Methods for Evaluating Solid Wastes: Physical/Chemical Methods, 3rd Edition, 1986, U.S. Environmental Protection Agency
publication number SW-846;
(d) Test Procedures for the Analysis of Polluants Under the Clean Water Act, Federal Register Vol. 49, No. 209, 40 CFR Part 136,
October 26, 1984;
- f
5. Measure and record the depth of water in the well prior to pumping or bailing any water from the well.
6. At least 3 volumes of water in the well should be pumped or bailed prior to collecting a sample for analysis. If the well is pumped/bailed dry before 3 we,11
volumes 'are removed, samples can be collected as soon as the well recovers to the point where enough water is available to collect your sample.
7. Determination for pH, Specific Conductance, temperature, odor and appearance must be made in the field on unfiltered samples when the sample is
collected.
8.- Field equipment must be calibrated in accordance with recommendations by the manufacturer.
9. Samples must be filtered through a 0.45 micron filter immediately after collection when a dissolved analysis is required. (See #4. above)
10.The sample container should be labeled at the time of collection with the facility name, well identification number and date and time collected.
11. "Authorized agent" is any corporate officer or public official authorized by the company, corporation, or governmental body to sign official documents.

i
FMC Corporation
Lithium Division
Highway 161
Box 795 0
-
Bessemer CityNorth Carolina 28016 1�`• H rYr H� r'�Y'
704 868 5300 Fax [phone]
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
September 29, 1995
vcT ¶ 0 1995 f MC
oIJ►sIN �E u �iia��1An�� cc 1�lt
j940 -
North Carolina Division of Environmental Management
Groundwater Section
P.O. Box 29535
Raleigh, NC 27626-0535
U0
CA
7.
iV
Re: FMC Corporation - Lithium Division
Bessemer City - Non -Discharge Permit No. WQ0008149
Groundwater Quality Monitoring - Compliance Report Forms
Dear Sir or Madam:
In accordance with the requirements of item No. 21 of the
North Carolina Water Quality Permit No. WQ0008149 for the
Recycle System (kiln scrubber ponds) located at FMC
Corporation's Lithium Division facility in Bessemer City, FMC
is submitting two Compliance Monitor Forms (GW-59) for the
sampling and analysis of groundwater monitoring wells WQ-1
and WQ-7 (A.K.A. W-7) on August 30, 1995. The results
reported here for aluminum, chromium, iron, lithium and
manganese were obtained using method 3030C in Standard
Methods, 17th edition for digestion and EPA method 200.7 for
analysis. The results for fluoride were obtained using EPA
method 340.2; for TDS using EPA method 160.1; for pH using
EPA method 150.1; for chloride using EPA method 325.2; for
sulfate using EPA method 375.4, and for calcium using EPA
method 200.7. All results represent analysis of unfiltered
samples. Laboratory report sheets and chain of custody
records are available upon request.
Sample collection procedures were modified in attempts to
reduce the turbidity of collected groundwater, in accordance
with Permit Condition No. 20 which states that "[e]ach well
shall be developed such that the level of turbidity or
settleable solids does not preclude accurate chemical
analyses of any fluid samples collected and with the
Department of Environmental Management, Mooresville Office
("DEM") letter dated July 17, 1995.

NCDEHNR - Groundwater Section
Permit No. WQ0008149
September 29, 1995 - Page 2
For this round of sampling, more than three well volumes were
removed from both WQ-1 and WQ-7 using a teflon bailer and
samples were collected directly from the bailer for all
specified analytes except metals. After a period of
approximately three hours, the bailer was again gently
lowered into the well beneath the top of the water column and
a groundwater sample retrieved for metals analyses.
Field ar' `'` turbidity was made in the bailer from which
the met,` __`'—collected: 24 NTU in WQ-1 and 43 NTU
in WQ-7 "rl the samples has been greatly
reduce" !� ion of sampling techniques, the EPA
guide] 1 a NTU has not been achieved. Given
that {i Lard �8 �i the upgradient, background well
WQ-7;' �' {� than that in WQ-1 which is
downy` bored units, FMC believes that the
turbidifr�_� iaracteristic of wells installed in
the native sili-, prolite, the upper -most geologic
feature in the area 4-__ spodumene ore tailings landfilled on
site pursuant to solid waste permit No. 36-05.
Whether the turbidities affect the chemical analysis as
discussed in Permit Condition No. 20 does not appear to be
relevant to the extent that the inherent turbidity is a
background condition and the main reason that drinking water
wells in the region are screened in the significantly deeper
bedrock formations. Such conditions are not uncommon
throughout the country and EPA Region III has published a QA
Directive (Bulletin No. QAD009, April 23, 1990) which states
that "Filtered samples represent dissolved metal
concentrations are often more representative of mobile
contamination..." except where "...geologic conditions
transport large particles (e.g.'., karst terrain or clean
gravel facies . " AThus3FMCrecommendstYiatutrr=e groundwa=ter
DEM's.July 17, 1995 letter also states that the following
parameters exceed standards established in 15A NCAC 2L: pH,
Total Dissolved Solids, Sulfate, Aluminum, Calcium, Iron,
Manganese, Fluoride, and Lithium. While it must be noted
that (1) standards have not been promulgated nor has research
been done to establish an interim standard for several of
these compounds and (2) the upgradient, background well also

NCDEHNR - Groundwater Section
Permit No. WQ0008149
September 29, 1995 - Page 3
exceeds the standards for some compounds, FMC acknowledges
that the TDS, sulfate, fluoride and lithium levels may
represent the influence of its operations; the RCRA Facility
Investigation has identified these parameters with other
onsite waste management units, such as the industrial
landfill, and they not necessarily reflect the impact of the
permitted units (kiln scrubber ponds).
Nonetheless, FMC has undertaken the following course of
action:
- The Eastern Kiln Pond has been taken out of service and the
accumulated solids are drying. The solids will be removed
after they are sufficiently dry to allow for access by heavy
equipment. The Western Kiln Pond will be used until that
time. Nonetheless, FMC anticipates final closure of both
ponds in late 1997 when the decrepitation kiln (and a
substantial portion of the operations at this facility) are
closed due to relocation of the lithium source from locally
mined spodumene ore to a South American source.
- FMC has conducted additional review of solid waste
management units at this facility under the RCRA Facility
Investigation program and concluded that the review boundary
and compliance boundary associated with the kiln ponds
actually are located within older areas of the plant's solid
waste landfill. The applicability of the groundwater
standards within a permitted waste management unit is
inappropriate and of questionable basis. FMC will continue
to investigate and.request a meeting with DEM staff to
discuss the matter and the modification of Permit No.
WQ0008149. Coordination of the RCRA Facility Investigation
and the conditions of Permit No. WQ0008149 would also be
addressed.
DEM's July 17, 1995 letter advises against waiting for the
completion of the RCRA Facility Investigation for before
addressing Permit No. WQ0008149. FMC explicitly reiterates
that it has recommended actions to coordinate the two
programs which both provide for investigation of the kiln
ponds, rather than sequentially addressing the two regulatory
programs. Any suggestion to address the programs in series,
regardless of which is first, represents inefficiencies and
potentially significant errors; the programs must be
addressed in parallel to ensure that all applicable
requirements are satisfied.

NCDEHNR - Groundwater Section
Permit No. WQ0008149
September 29, 1995 - Page 4
If you have any questions, or require additional information,
please contact me at 704/868-0806.
Very truly yours,
/4Barbar E. Ritchie
Environmental Manager
cc: Mr. Brian Wagner
DEHNR - Groundwater Section
512 North Salisbury Street
Raleigh, NC 27604
Mr. B. Keith Overcash, P.E.
Regional Supervisor
DEHNR / Mooresville Office
919 North Main Street
Mooresville, NC 28115

tU/ y.
FMC Corporation
Lithium Division
Highway 161
Box 795
Bessemer City North Carolina 28016
704 868 5300 Fax [phone]
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
September 29, 1995
North Carolina Division of Environmental Management
Groundwater Section
P.O. Box 29535
Raleigh, NC 27626-0535
N.0 T,
or
ENV' IR
` ,�AI'fI,ZtZt
C.,'
OCT 21995
D'111SIVN OF .
Re: FMC Corporation - Lithium Division
Bessemer City - Non -Discharge Permit No. WQ0008149
Groundwater Quality Monitoring - Compliance Report Forms
Dear Sir or Madam:
In accordance with the requirements of item No. 21 of the
North Carolina Water Quality Permit No. WQ0008149 for the
Recycle System (kiln scrubber ponds) located at FMC
Corporation's Lithium Division facility in Bessemer City, FMC
is submitting two Compliance Monitor Forms (GW-59) for the
sampling and analysis of groundwater monitoring wells WQ-1
and WQ-7 (A.K.A. W-7) on August 30, 1995. The results
reported here for aluminum, chromium, iron, lithium and
manganese were obtained using method 3030C in Standard
Methods, 17th edition for digestion and EPA method 200.7 for
analysis. The results for fluoride were obtained using EPA
method 340.2; for TDS using EPA method 160.1; for pH using
EPA method 150.1; for chloride using EPA method 325.2; for
sulfate using EPA method 375.4, and for calcium using EPA
method 200.7. All results represent analysis of unfiltered
samples. Laboratory report sheets and chain of custody
records are available upon request.
Sample collection procedures were modified in attempts to
reduce the turbidity of collected groundwater, in accordance
with Permit Condition No. 20 which states that "[e]ach well
shall be developed such that the level of turbidity or
settleable solids does not preclude accurate chemical
analyses of any fluid samples collected'- and with the
Department of Environmental Management, Mooresville Office
("DEM") letter dated July 17, 1995.

NCDEHNR - Groundwater Section
Permit No. WQ0008149
September 29, 1995 - Page 2
For this round of sampling, more than three well volumes were
removed from both WQ-1 and WQ-7 using a teflon bailer and
samples were collected directly from the bailer for all
specified analytes except metals. After a period of
approximately three hours, the bailer was again gently
lowered into the well beneath the top of the water column and
a groundwater sample retrieved for metals analyses.
Field analyses of turbidity was made in the bailer from which
the metal samples were collected: 24 NTU in WQ-1 and 43 NTU
in WQ-7. While turbidity in the samples has been greatly
reduced with the modification of sampling techniques, the EPA
guideline in SW-846 of five NTU has not been achieved. Given
that observed turbidity in the upgradient, background well
WQ-7 is generally higher than that in WQ-1 which is
downgradient of the monitored units, FMC believes that the
turbidities are simply characteristic of wells installed in
the native silty clay saprolite, the upper -most geologic
feature in the area and spodumene ore tailings landfilled on
site pursuant to solid waste permit No. 36-05.
Whether the turbidities affect the chemical analysis as
discussed in Permit Condition No. 20 does not appear to be
relevant to the extent that the inherent turbidity is a
background condition and the main reason that drinking water
wells in the region are screened in the significantly deeper
bedrock formations. Such conditions are not uncommon
throughout the country and EPA Region III has published a QA
Directive (Bulletin No. QAD009, April 23, 1990) which states
that "Filtered samples represent dissolved metal
concentrations are often more representative of mobile
contamination..." except where "...geologic conditions
transport large particles (e.g.'., karst terrain or clean
gravel facies." Thus, FMC_recommends that future groundwater
samples from onsite wells -.be field filtered -prior to
preservation.,
DEM's July 17, 1995 letter also states that the following
parameters exceed standards established in 15A NCAC 2L: pH,
Total Dissolved Solids, Sulfate, Aluminum, Calcium, Iron,
Manganese, Fluoride, and Lithium. While it must be noted
that (1) standards have not been promulgated nor has research
been done to establish an interim standard for several of
these compounds and (2) the upgradient, background well also

NCDEHNR - Groundwater Section
Permit No. WQ0008149
September 29, 1995 - Page 3
exceeds the standards for some compounds,:FMC_acknowledgeys
that_ the TDS, sulfate, -ffluoride _.and lithium. levels -may,^_
represent tfi crib l eenc� t�f« �ts=F per:atlonsi the RCRA Facility
Investigation has identified these parameters with other
onsite waste management units, such as the industrial
landfill, and they not necessarily reflect the impact of the
permitted units (kiln scrubber ponds).
Nonetheless, FMC has undertaken the following course of
action:
- The Eastern Kiln Pond has been taken out of service and the
accumulated solids are drying. The solids will be removed
after they are sufficiently dry to allow for access by heavy
equipment. The Western Kiln Pond will be used until that
time. Nonetheless, FMC anticipates final closure of both
ponds in late 1997 when the decrepitation kiln (and a
substantial portion of the operations at this facility) are
closed due to relocation of the lithium source from locally
mined spodumene ore to a South American source.
- FMC has conducted additional review of solid waste
management units at this facility under the RCRA Facility
Investigation program and concluded that the review boundary
and compliance boundary associated with the kiln ponds
actually are located within older areas of the plant's solid
waste landfill. The applicability of the groundwater
standards within a permitted waste management unit is
inappropriate and of questionable basis. FMC will continue
to investigate and request a meeting with DEM staff to
discuss the matter and the modification of Permit No.
WQ0008149. Coordination of the RCRA Facility Investigation
and the conditions of Permit No. WQ0008149 would also be
addressed.
DEM's July 17, 1995 letter advises against waiting for the
completion of the RCRA Facility Investigation for before
addressing Permit No. WQ0008149. FMC explicitly reiterates
that it has recommended actions to coordinate the two
programs which both provide for investigation of the kiln
ponds, rather than sequentially addressing the two regulatory
programs. Any suggestion to address the programs in series,
regardless of which is first, represents inefficiencies and
potentially significant Errors; the programs must be
addressed in parallel to ensure that all applicable
requirements are satisfied.

NCDEHNR - Groundwater Section
Permit No. WQ0008149
September 29, 1995 - Page 4
If you have any questions, or require additional information,
please contact me at 704/868-0806.
Very truly yours,
BarbarE. Ritchie
Environmental Manager
cc: Mr. Brian Wagner
DEHNR - Groundwater Section
512 North Salisbury Street
Raleigh, NC 27604
Regional Supervisor
DEHNR / Mooresville Office
919 North Main Street
Mooresville, NC 28115

Type or Use a ball-point pen and press firmly.
Facility Name RIC Corporcition -- Lithium Division
Address Hwy 161, Box 795
Apnstmmpr Cit;,, NC 28016 County cogto,
Well Location Nnrthwastern, j2ronert-y brnindnry, more than 7000 ft „ igracl_
Well Identification Number WQ-7 • AkA IV 7 Well Depth 38,5 Ft.
Well Diameter 2 inc Sample (Screened) Interval 28.5 Ft. To 38, 5 Ft.
Depth to Water Level 17.929 ft. below measuring point (before sampling)
Measuring point is 1.9 ft. above land surface
Gallons of water pumped/bailed before sampling 6
Field Analysis: pH 4.93 Specific Conductance 200 uMhos Temp. 20 oC
Date Sample Collected 39/95 Date Lab Sample Analyzed 8/30-9/18/95
Laboratory Name Pare Inc l4untersville, Nr:
PERMIT NUMBER: (REQUIRED)
Non -Discharge WQO 05149
NPDES
TYPE OF DISPOSAL OPERATION BEING MONITORED
(REQUIRED)
Lagoon
Septic Tank/Drain Field
Spray Field Subsurface Low -Pressure
Piping (LPP)
Land Application of Sludge
_T Other
Rotary Distributor Rerurl n Ttr.nntinrlmeilt'e
Odor 14011c, Appearance Low Turb4dity (43 NTU)
Certification No.
SAMPLES FOR METALS WERE COLLECTED UNFILTERED AND FIELD ACIDIFIED YES
COD mg/I
Coliform: MF Fecal /100ml
Coliform: MF Total /100ml
(Note: Use MPN method for highly turbid samples)
Dissolved Solids: Total 56
mg/I
pH (when analyzed) 4.98
units
TOC
mg/I
Chloride
mg/I
Arsenic
mg/I
Grease and Oils
mg/I
Hardness: Total
mg/1
Phenol
mg/I
Sulfate less than i
mg/1
Specific Conductance
uMhos
Total Ammonia
mg/I
TKN as N
mg/1
NO
Nitrite (NO2) as N
mg/I
Nitrate (NO3) as N
mg/1
Phosphorus: Total as P
mg/1
Al -Aluminum 0.163
mg/I
Ba - Barium
mg/1
Ca - Calcium 0.23
mg/1
Cd - Cadmium
mg/I
Chromium: Total less than 0.010
mg/1
Cu - Copper
mg/l
Fe•- Iron o.304
mg/1
Hg - Mercury
mg/I
K - Potassium
mg/1
Mg - Magnesium
mg/I
Mn - Manganese 0.035
mg/I
Na - Sodium
mg/1
I CERTIFY THAT THIS REPORT IS TRUE AND ACCURATE.
,S'ign^re of Permittee (or
orized Agent*)
Dat4
Ni - Nickel mg/I
Pb - Lead mg/1
Zn - Zinc mg/1
Pesticides/Herbicides
(Specify Compounds)
ug/I
ug/I
u g/I
Other (Specify Compounds and
Concentration units)
fluoride 0.22 rm,11
lithium, less than 0.1 rue;/l.
Note: Values should reflect dissolved and
colloidal concentrations. (see #3 on back)
* See back for instructions.
** Submit blue, green, and yellow copies only to address above.
-59 REV. 6/93

Type or Use a ball-point pen and press firmly.
Facility Name RqC Coyporat3_on -- Lit:biuite Div_tsi.oti
Address Hwy 161, Bo-.: 795
Bessemer City, NC 28016 County Gastcn.
Well Location Southern boundary of kiln scrubber ponds
Well Identification Number WQ--1 Well Depth 49.5 Ft.
Well Diameter 2 in Sample (Screened) Interval 9.5 Ft. To 49.5 Ft.
Depth to Water Level 33.63 ft. below measuring point (before sampling)
Measuring point is 2.5 ft. above land surface
Gallons of water pumped/bailed before sampling 8.25
PERMIT NUMBER: (REQUIRED)
Non -Discharge 1JQ( r'e0A11kQ
'NPDES
TYPE OF DISPOSAL OPERATION BEING MONITORED
(REQUIRED)
Field Analysis: pH4.5 Specific Conductance 2400' uMhos Temp. 1a oC Odor Non`'''
Date Sample Collected 8/30/95 Date Lab Sample Analyzed 8/30--19/ 18/95
Laboratory Name pace Inc- Huntersv-ille, NC Certification No
SAMPLES FOR METALS WERE COLLECTED UNFILTERED AND FIELD ACIDIFIED YES
COD
mg/I
Coliform: MF Fecal
/100ml
Coliform: MF Total
/100ml
(Note: Use MPN method for highly turbid samples)
Dissolved Solids: Total 2100
mg/I
pH (when analyzed) 4.41
units
TOG
mg/I
Chloride S9
mg/I
Arsenic
mg/I
Grease and Oils
mg/I
Hardness: Total
mg/I
Phenol
mg/I
Sulfate 1300
mg/I
Specific Conductance
uMhos
Total Ammonia
mg/I
TKN as N
mg/I
Lagoon
Septic Tank/Drain Field
Spray Field Subsurface Low -Pressure
Piping (LPP)
Land Application of Sludge
�_ Other
Rotary Distributor Recycle 7mpoti[11dincnit:S
Appearance !,ow 'rurbidi.t:y (24 K11)
NO
Nitrite (NO2) as N
mg/I
Nitrate (NO3) as N
mg/I
Phosphorus: Total as P
mg/I
Al - Aluminum 14,8
mg/I
Ba - Barium
mg/I
Ca - Calcium 80
mg/I
Cd - Cadmium
mg/I
Chromium: Total less tb-al 0.010
mg/I
Cu - Copper
mg/I
Fe - Iron 1• ls,
mg/I
Hg - Mercury
mg/I
K - Potassium
mg/I
Mg - Magnesium
mg/I
Mn - Manganese 36.0
mg/I
Na - Sodium
mg/I
I CERTIFY THAT THIS REPORT IS TRUE AND ACCURATE.
re of Permitted (or"Authorized Agent*)
J
D at
/
12
Ni - Nickel mg/I
Pb - Lead mg/I
Zn - Zinc mg/I
Pesticides/Herbicides
(Specify Compounds)
ug/I
u g/I
ug/I
Other (Specify Compounds and
Concentration units)
Fltt"Vide 2.6 nng/l
lithium 11.8 rg/l
Note: Values should reflect dissolved and
colloidal concentrations. (see #3 on back)
* See back for instructions.
'* Submit blue, green, and yellow copies only to address above.
-59 REV. 6/93

DC() r
Please use ink pen and press
Facility Name P 44 C Co LP s 1. ill f U QU i Si
Address NEW A I & I ,, P-;,Oi< +9 S_
!i7
�G County L2a-=�f UI
Well Location 911-t
Well Identification Number 'ITV a —1 Well Depth �6_3 Ft.
Well Diameter A WN Sample -(Screened) Intervals Ft To Ft.
Depth to Water Level 3p 9(0 ft. below measuring point (before sampling)
Measuring point is z, ft. above land surface ,4� 5,
Gallons of water pumpedbailed before sampling '
Field Analysis: pH �' Specific Conductance ( 9 -S uMhos
Date Sample Collected �?� Date Lab Sample Ana
Laboratory NameAN
COD
N A-
mg/I
Coliform: MF Fecal
N
/100ml
Coliform: MF Total
. IVIN-
/100ml
(Note: Use MPN method for
highly turbid samples)
Dissolved Solids: Total )SOP
mg/I
pH (when analyzed)
15'' O
units
TOC
NAs
mg/I
Chloride
(aka
mg/I
Arsenic
NX
mg/I
Grease and Oils
NA.
mg/I
Hardness: Total
N k
mg/I
Phenol
N
mg/I
Sulfate
q
mg/I
Specific Conductance ^'N
uMhos
Total Ammonia
NAr
mg/I
Temp.
PERMIT NUMBER: (REQUIRED) Non -Discharge 00c) 13) ,,11T 9
NPDES
TYPE OF DISPOSAL OPERATION BEING MONITORED
(REQUIRED)
Lagoon Septic TanWDrain Field
Spray Field Subsurface Low -Pressure
Piping (LPP)
Land Application of Sludge
_X Other
Rotary Distributor MLi Co., Im A"WbA'r.
o Odor A110 Appearance AI�yT__Tbr-isih,,"
Certification No.
Nitrite (NO 2) as N
Nip
mg/I
Ni - Nickel IVA
mg/I
Nitrate (NO 3) as N
N fr
mg/I
Pb -Lead >v
Ong/I
Phosphorus: Total as
P N /k
mg/I
Zn. - Zinc N K
mg/I
AI - Aluminum
90
mg/I
Pesticides/Herbicides
M
Ba - Barium
Mkt
mg/I
(Specify Compounds)
cs
Ca - Calcium
?2
mg/I
/V ►�
t_
g/I
Cd - Cadmium
NA-
mg/I'�g/I
Chromium: Total
0, OI
mg/I
�,Ig/I
Cu - Copper
►�A
mg/I
Other (Specify Compound and
ry
M?
Fe - Iron
mg/I
CQBq�rRtiw ccunits)
`''
Hg - Mercury
NA
mg/Ir,,NV:R0NM1 FT -TT,
K - Potassium
/�A-
mg/I &
NA9106AE% YID
Mg - Magnesium
N
mg/I
I(►r1
Mn - Manganese
mg/I
FY Is
Na - Sodium
mg/I
TKN as N f4 A- mg/I UtjilSiOti ^ ,,,,,.i'.E� 4Hr,I:I.151T
..ca
I CERTIFY THAT THIS REPORT IS TRUE AND ACCURATE.
�- ( 13, J
Sig ature of Permittee (o Authorized Agent*) at
G�W-59 REV. 9/92
Note: Values should reflect dissolved and
colloidal concentrations. (see #2 on back)
* See back for instructions.
'* Submit blue, green, and yellow copies only to address above.

COLLECTION AND ANALYSIS OF GROUNDWATER SAMPLES
1amVes should be analyzed az soon as possible aftOr coileiction. SAMPLES WHICH ARE NCT ANALYSED WTrHIN THE
'69IM SPECIMED FOR 71E MET -HOD USED, (SEE 43. BELOW) MUST BE MSCARDED AND NEW SAMIPLES C0LL!1r:CT:1__;7:'
2. ANALYSES ARE TO, BE fi�ADNIT_ OF THE MOBILE ICONS-FTUEtrlS (DISSOLVED.As WELL AS COLLOWAL, *1� iN THE
GROUNDVVATER, NOT THOSE THAT ARE A PART OF SEDIMEWE CHECK- ViftTF YOUR LABORA-102%, CON, PROPE",".1,
PROCEDURES FOR SAII.IPLE COLLECTION AND PRESERVNrION.
1 As per Title .1.5, North Caroiina Administrative Code, Subchapter 2L, anah res -shall be in �ccordanoa with the mett�i�',G'S yticJ procedu
described in one of the followirg publications, or by other methods approved beforehand by the Director, Division of —Environmental
Management:
Standard Methoris or the Examination of Water and Wastewater.
.a) 16th Edition, 1985 and 17th Edition,..1989, publ;sined
jointly by Annerin Pub4c Health Association, American Water .Works Association and Water Poliution Control F-ederaition;
(b) Methods for. Ch'emical Analysis of Water and Waste, 1979, U.S.. Environmental Protection Age.nqv publicaatio,-'! number
Er-A-600/4-79-020, as revised March 1983;
(c) Test Methods for Evaluating Solid Wastes: Plhysical/Chem'ical Mlethods,; 3rd Edition, '11986, U.S. Environmental
'rote ion Agency publication number SW-W.;
(0, Procedures for the Ana lysis of Polluants Under fhR Clean. Water Act, Federal Register Vol. 49,. No. 209, 40 CH"I
arL 1-K. Gclober 26, 1984.
4. Measu're rid record the derAh 6 �.Nrater in the well prior to pumping or bailing any w�.ater from the viell.
5. 'A.", °e.a-st 03_volumes of water in the well should be pumped or bailed prior to co;lectiinq a- sample for analysis. i1 ti, is pum;,.-3u,,"nailed ddr�t
before S volunnes are removed, sarr 1ples ran be collp,-11G-d, as sonn as the well r8covers to the point Where enough wa-tic,' we ladle to
3. SaMPH
6, Deters --nin-ation fo?, pfl, Specific, 0�,�,'Jb,_Ttancel, ter nperz#_ure, odor and appearance Must ter made in the field on unfi2ered sa- 'ne
sarnple is c6�ecled.
7.
Fisid equipment must iYs_ ca�jbrated
in accc%rd;xmoe with recommiendations by, the
manufacturer.
8.
Sarnip"I's rnust ba, filtered lhrooLih a
0.45 micron filter immediately aft r collection
-wher, a dissolved analysis'i3 a-Ellquired. (See above"
9. The sample container should. be labo!cd at the time of collection With the facility ranne, weil identification numcrzc a date anir- ii7l'Pe; cok
lected.
1O."Authorized agent" is any corpi; ;ate office,, or public official aulthorized" by the oompany, Corpration, or over nn''er-ci.- ' boy to official
U i c-I,
documents.

Al
FMC Corporation
N.C. DEPT. OF
ENVIRONMENT, HEALTH,
& NATURAL RESOURCES
Lithium Division
Highway 161
Box 795
Bessemer City North Carolina 28016
704 868 5300 Fax [phone]
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
FEB 1995,
DIVISION OF ENVIRONnIENTAL fIANAGEIBENT
oFMCEGIONAL OFFICE
v
January 31, 1995 _0 rn
North Carolina Division of Environmental Management rn
Groundwater Section
P.O. Box 29535 - cater;
Raleigh, NC 27626-0535 zt-`
Re: FMC Corporation - Lithium Division
Bessemer City - Non -Discharge Permit No. WQ0008149 w
Groundwater Oualitv Monitorinq - Compliance Report Forms h
Dear Sir or Madam:
In accordance with the requirements of item Nos. 21, 24, 25 and
26 of the North Carolina Water Quality Permit No. WQ0008149 for
the Recycle System (kiln scrubber ponds) located at FMC
Corporation's Lithium Division facility in Bessemer City, FMC is
submitting the following information:
1. Well Completion Form (GW-1) for the installation of monitor
well WQ-1 on December 6, 1994, including the certification
that the well was constructed in accordance with the
applicable requirements. As agreed to with Mr. Robert Krebs,
Department of Environment, Health; and Natural Resources
("DEHNR") Mooresville office, the certification has been made
by a professional geologist as the P.G. prepared the well
application and supervised the installation of the well.
2. Compliance Monitor Form (GW-59) for the sampling and analysis
of newly installed monitor well WQ-1 on December 8, 1994.
3. Two versions of the facility base map which has been developed
pursuant to the RCRA Facility Investigation underway. The
blue -print version has been provided since it contains the
signed land surveyor seal as discussed in item 24 of the
permit. However, the permit item also specifies that a map of
scale no greater than 1:100 be provided. The 100-scale map
included here has been adapted from the original base map, and
therefore, contains no PE or land surveyor certification.
Both maps also identify well and sample locations unique to
the RFI and outside of scope of Permit WQ0008149. Wells WQ-1
and WQ-2 AKA W-7 are highlighted. If these maps do not
fulfill DEHNR's requirements, please advise.
4. A standard Test Boring/Well Construction Log for well WQ-1.

A
DEHNR - Groundwater Section
Permit No. WQ0008149
January 31, 1995 - Page 2
The results reported here for aluminum, chromium, iron, lithium
and manganese were obtained using method 3030C in Standard
Methods, 17th edition, as required in Permit No. WQ0008149 for
digestion and EPA method 200.7 for analysis. The results for
fluoride were obtained using EPA method 340.2; for TDS using EPA
method 160.1; for pH using EPA method 150.1; for chloride using
EPA method 325.2; for sulfate using EPA method 375.4-, and for
calcium using EPA method 200.7. All results represent analysis
of unfiltered samples. Laboratory report sheets and chain of
custody records are available upon request.
FMC will sample -wells WQ-1 and WQ-2 AKA W-7 in April 1995, as
specified in item 21 of Permit No. WQ0008149, as amended January
17, 1995.
If you have any questions, or require additional information,
please contact me at 704/868-0806.
Ver truly yours,
B rbara E. R 1e
Environment 1 Manager
cc: Mr. Brian Wagner
DEHNR- Groundwater Section
512 North Salisbury Street
Raleigh, NC 27604

TOC WATER
WELL LONG. LAT. ELEV. LEVEL (12/94)
DC-1 81° 18'27.5" 35° 16'30.6" 929.01 19.84
DC-2 81018'23.4" 35016'30.6" 920.90 32.81
WQ-1 810 18'27" 35016'29.6" 929.71 33.56
1 NOTES:
kAL - 1
. TOC Elevations -Top of Casing in Feet Above Mean Sea Level
• Water Levels Are in Feet From TOC
C
�F
L0
929.3
\ 929.1
x
x
929.0
DC-1
A
WQ-1
�O
Elevations And Well Locations Surveved by Robinson & Sawver Inc.
FMC Corporation, Lithium Division
-FMC Highway 161 Box 795
ENVIRONMENT 8& Bessemer City, NC 28016
INFRASTRUCTURE KILN SCRUBBER POND
MONITOR WELLS
PROJECT NUMBER 38632.100 DRAWN: JFM DATE 1/18/95
CAD FILE NAME: 8632CO01 CHECKED: JJP I SCALE: V=100'

JHN-51-1��� 1I0;.=� KUSI t & I tibia rH 1 rlr -r7O dedu r.Ioe/104
&
RMENVIRONMENT
INFRASTRUCTURE
Test BoringlWell Construction Log
2 M"br Plaza Way (717) 795.e00►
Mechmic6ure. PA 17055 (7I7) 79s_ano (Rnx)
Project: FMC - Water Quality Permit
Boring No. WQ-1
Client: FMC Corporation - Lithium Division
Shut 1 of 1
Purpose: Monitor Well - Water Quality Permit
Job No. 38632.I00
Drilling Contractor: McCall Brothers, Inc. Driller: K. McDonald
Total Depth 53'
Geologist: Jeff Painter
root '°aC° Type rh„m,u
In.
Daze Starteil 1 J6/94
Time Log: Begin Finish Depth .
Casing
Notes: 2" PVC scJc-q
Date Finished 12/6/94
slot sire�1.01"
Bore
Auger.
10.5"
S.W.L. 17' TOC1_ L
Well
PVC
2"
Elevation TOC
929.91
Surface
927.41
Sampler
Depth
Sample
Blow
Sample
Val Lo
Description
Lithologic Description
Notes
(Foot)
Numbers
Counts
Recovery
0.6" Brown topsoil, grass
Well materials:
6"-24' Light brown ore tailings,
silty, damp to moist
PVC Riser-
+1.5'-9.5'
10
PVC Sarcen-
_= r
9.5-49.5'
Bentonite/Gmut-
ti ---
0•-6.5'
.: �
Bentonite
17' wet
6.5-7.5'
20
---
Sandpack(#3)
,:. ,
• • �
75-53'
X-53' Silty clay, red, very small
= -
rock (quartz and schist)
fragmensts
30
==
40
Bentonite/Grout
Bentonite
--=
Sandpack
50
---
---
49.5' Bottom of well
� Screened PVC
53' Bottom of borehole
Soil Classifications:
•,• Ore tailings
60
Clay

Facili
PERMIT NUMBER: (REQUIRED)
Non -Discharge VJ(�L 00
NPDES
TYPE OF DISPOSAL OPERATION BEING MONITORED
Well Location 130VAJ bi4R_1A 6 F i.nl K I Irnd Sp_. cUA8 0,AJQ (REQUIRED)
Well Identification Number _b C — 2— Well Depth �'4 Ft.
Well Diameter 7— t n , Sample (Screened) Interval 142 Ft To *%Ft.
Depth to Water Level eft. below measuring point (before sampling)
Measuring point is z - `- 3 ft. above land surface _
Gallons of water pumped ailed before sampling I
ty
Please use ink pen and press finmly.
Name 0,01pPOPA-1 d®tJ —. Ll —1 if I U (0 d 1 S
Address- F-t 1 & I+IAi A- U 1401 . '_io K
Lagoon
Spray Field
Land Application of
Rotary Distributor
Sepk
®
a 3
l
oo
Tari4)rain
Field
[-6 '
?
Subsurface Low -Pressure
Piping (LPP)
Other
{ Gl I Al Paura� #7
Field Analysis: pH S, 14 Specific Conductance '3 '3 uMhos Temp. 163-5 C Odor Appearance TOM- /MTY
Date Sample Collected Date Lab Sample Analyzed 14,—Z1O 0qM
Laboratory Name lev us k_ /�nl � Certification No. g ? _Zy
COD
N a
mg/I
Coliform: MF Fecal
N A
A 00ml
Coliform: MF Total
N A
A 00ml
(Note: Use MPN method for highly turbid samples)
Dissolved Solids: Total
Z L_ L= UA mg/I
pH (when analyzed)
S',
units
TOC
m A
mg/I
Chloride
2_ --7-
mg/I
Arsenic
NPC
mg/I
Grease and Oils
NA
mg/I
Hardness: Total
IVA
mg/I
Phenol
mg/I
Sulfate
mg/l
Specific Conductance
NA
uMhos
Nitrite (NO 2) as N
HA -
mg/I
Nitrate (NO 3) as N
N A
mg/I
Phosphorus: Total
as P N A
mg/I
AI - Aluminum
- 4 S o
mg/I
Ba - Barium
N a
mg/I
Ca - Calcium
q' 1+b v
mg/I
Cd - Cadmium
NA
mg/I
Chromium: Total
0,010(0
mg/I
Cu - Copper
N A
mg/I
Fe - Iron
5, (00®
mg/I
Hg - Mercury
N14
mg/I
K - Potassium
NA
mg/I
Mg - Magnesium
NA
mg/I
Mn - Manganese
®, (06-0
mg/I
Ni - Nickel
Pb - Lead N � g/I
Zn - Zinc
Pesticides/Herbicides
(Specify Compounds)
r s'
ug/I
ug/I
ug/I
Other (Specify Compounds and
Concentration units)
FLUolt.I bF - & L- QL = oo 1
Lr�+Oun'1 D�®/Qi� jn�I.Q
Total Ammonia
01-N-
mg/I Na - Sodium WA
mg/I. To'rA l Cif
PAI tsM i&j F i i_ &)5
IrsLb
TM as N
N&
mgA
5A M P t"i-
L- L =
/' �✓`��f �R
I CERTIFY THAT THIS REPORT IS TRUE AND ACCURATE. Note: Values should reflect dissolved and
�j colloidal concentrations. (see #2 on back)
see back for instructions.
Signature of Permittee (or AlStlibrized Agent*) D- a ** submit blue, green, and yellow copies orgy to address above.
GW-59 REV. 9/92
14 k = A K ARr LLf,; S 1 RIELl U D P_ __B iSk (L z _i3E JW 4 f WTP ri cA-poi 3 L(A4 rT- (�vA-AST l FB ch:)-) ofi LM e7-

�pgu :1 rn !Ooq ".AAWIICXI OQ -,o -,,a'p!jjo
qi'p� 00'appmora
-GLJ'V.
-'J 1;3§ @j Lq GjM3U
be oue .�up--.-
112 100A pwv-.
-�d
�u.;: qj qoAr 1,7
rq
lot Q Q04 "c'u!"dwnd jc�!Jd I;am u44 ili
t-' 6� '9F v
-D:", 'jov Ja!
-201�) 8-1 Jl&'PI-117" To Apu 1 p) p V aq MI SPI a
jaqwnu uoj=jjqnd Aouab',,7�
:C.�3,5L qJX" PA-S!A0-] Sle
i",;:'03�0�d F0Iu3W-UG.IIALi:7- 'SVI
"lei" ;)ula y) rspk'
po,-qn
"ALz
IQ i
'--
s L Wc!i.I eAA PP4K4
l�pj�cDjO;ciiu!W3W�)q.nLm
`-r�joaj!(] 041 Aq
parv-3"ddip, J&'-i1c Aq jo �'J!,von!!q 4'��.' ;o'
Sug U!
�Ajj "p'pv� ui! GG i:'eqs
po!,4.4sci�e GA�;6�JS!-J!ILI 'jjo; I
up'i
ied SV
'NCM!WA8HG'-38d fJNV
V0"10A 40 LbVd V A"A-,-&,-)Hi ION '63.JMi-
obol1-9-
-C-
A_3flMW 'lVV--) 3' iiI1E01 MWSgSN
-0fiM M 1103 M9N ONE' AMVSlo '�-A' �rlivj "MM38 V ]IMS) -bsn 3:''1 tiw �Liwcis- asm
MMVV Iv AMTdWVS p-'4!EA11? 6-C! f­�1-10-�sHliNON MSACo.

Please use ink pen and press
Facility Name FM IC e,oPr PnP_FT-t01J — Lo7v1 t,
Address I4I G14W Ato 0461 . 130X '7-9 �
-iEs45 EM k C- C—1 TT N C County <S/4ST© 1,1
Well Location SOu f'ltl W &S tra✓ 13f� tit
Well Identification Number- DC — 1 Well Depth 5_9 Ft.
Well Diameter 2 it)• Sample (Screened) Interval— Ft To _" Ft.
Depth to Water Level 13LE, 03 ft. below measuring point (before sampling)
Measuring point is 2- i Z ft. above land surface
Gallons of water pumped/bailed before sampling 4 Z
PERMIT NUMBER: (REQUIRED) �y q a
Non -Discharge Q O®o 8!~ f
NPDES
TYPE OF DISPOSAL OPERATION BEING MONITORED
(REQUIRED) P2
Lagoon Septic Tar rain
Spray Feld
Land Application of
Rotary Distributor
H
ran
o� 0
Field
Subsurface Low -Pressure
Piping (LPP)
Other
9
Field Analysis: pH N, 12 Specific Conductance TZzO uMhos Temp. 18,Z oC Odor NONE Appearance MOA ,47!5 '710k 9lb 1'ry
Date Sample Collected 9//3 MY Date Lab Sample Analyzed N/110"7-6l94y
Laboratory Name
A A0
It Ne Certification
No. 2ol
COD NA
mg/I
Nitrite (NO � as N
NA
m g /I
Ni - Nickel �A .—r
'`''
c-a mg/I
';
Coliform: MF Fecal NA
/100ml
Nitrate (NO 3) as N
NA
mg/I
Pb - Lead NA,
rt
���mg/I
Coliform: MF Total NA
/100ml
Phosphorus: Total as P NA,
mg/I
Zn - Zinc 11 A
mg/I
(Note: use r4Pnt method for highly turbid samples)
AI -Aluminum
Z5,4, 00o
mg/I
Pesticides/Herbicides
Dissolved Solids: Total 7-300
m /I
Ba -Barium
NA
m /I
S Compounds)
( )
pH (when analyzed) q, 8
—units
Ca - Calcium
NO, 000
mg/I
�� y ug/I
TOC /y A
mg/I
Cd - Cadmium
NA
mg/I
r;, ug/I
Chloride -z80
mg/I
Chromium: Total
0,0
mg/I
ug/I
Arsenic NA
mg/I
Cu - Copper
N A
mg/I
Other (Specify Compounds and
Grease and Oils NA'.
mg/I
Fe - Iron
- -. 00
mg/I
Concentration units)
Hardness: Total N A
mg/I
Hg - Mercury
NA
mg/I
Phenol 14A
mg/I
K -'Potassium
_N A
mg/I
E-vo /
Sulfate 1-2-00
mg/1
Mg - Magnesium
NA
mg/I
L►-rj4 so'
y
Specific Conductance NA
uMhos
Mn - Manganese
5-3 , '4- o O
mg/I
'
Total Ammonia "A
mg/I Na - Sodium N
Ar mg/I TdEALG C HAc2M1yrA
IN Fi F_i_b F1 a_T-i246
TM as N N
A mg/I
5Nm r LIr_ — C I_
I CERTIFY THAT THIS REPORT IS TRUE AND ACCURATE. Note: Values should reflect dissolved and
colloidal concentrations. (see #{2 on back)
;/ See back for instructions.
Signature of Permittee (or Auth rued Ag nt*) Date " Submit blue, green, and yellow copies only to address above.
GW-59 REV. 9/92
A = 90A1-1s1,e> c10T e-GZ v RL�=I;i3OIJ
/ im 1-1—
�.= 1iA 1�Tt G� E�!-` ►� % l M f

COLLECTION AN' ANALYSIS OF, GROUN,11,7,WATE`
U01. E ARE N077 J:-­
ia3 .,poctsblp, dert;or. -SAMIPL S VP-fll'
I FI ISECI"C7177'USE*SE -EVT MUS7 BDi " NEVYSP! 'C`4FIPMETF-n Ee� (P;T1DOE AN5 .7.
_N Tl _t. A A _-H TO BE fvl&AL:E C;F 1"HE MOBILE MNlSJff'UEU`;,3 (DISSiLVE-1
_'O
D G R, 0 'V4 D-WA7TI P., NOT TH-IC"C' ARE A PAR" 0,F ESEK HNVIRCIF,
PROCEDURES FOF ',`AULECTION X­Z '13VE
1
"O!na dm-is, 4;e.COaalhZrM.
tv&, EX"
.
Lf ,Qar!
inn o n e of -.o�-iq. foliuwir`�g, p�jblicatbons, cr by thee method"s b�,; the Dirk-c-lor, Envirunmi-­
a
o, .��'tamard fir h llo, tne Exam':,;r-rion Wo.`-` antl '71
c,
Jointly{ Arm,.i�c n Publ'�'c Health Ar,-; oau vlr VV..k_s 'I'ssociation arld Ws­)i l'-i
x
��kssodiatibn�.
_J
�b` �Nlelllh�,,, AkT-la,`lYSlil; �� li Water anc,' Wasite, 1197.,�_D. Flrole­lli�,n
iml lr)�
T, F"
."Inmemit-1
EP �t �, C as re.,v;5-eld mam,-,983,;
(C., ;est i0r r-valuating Solid Wastes: IN E�mo,,,Ls5 3r11 Edirliu-'.I-i, P98­­>; U �i.
-i ­,40 1- A
pub I k�al In n Li rT
0 t lcl` `7;�st for thp AriQys:!s -t Clea,n Federa' kedst
Par- 0Ct(,7)r-,­
4.
to Oumpirn:.�
ie well prior fron- he
and rem,*," Cqc�i�iJi 'D, �,�,atev 4, # �__,aixig any
5
'.'V 11 ibe pui­qpov-� baill, 'f�3, anaiy:;i­ t,­ n­-,i:
Oet-)ce, L� V3!unne�,- WE, �F:-'S Mfl tle to tile 0CMIT IN"oEl J(,.! V,
Ce, iDe` rn�ilntion for Tol'plpp Tzz; ii o r an- a a r:,, i made, r, I UP71il
7,
r m:
n.anu-n cf-�Ura Ov :he 7,pJ­
l �
letfidIn Mrn . CCaf-
9. slloulc� bl a� 1181 "., n -,
d c� *,"JI-is tirm � : C,:-:Jtt-
As
bv `h­� �,,OVa, �J71% cl:t�er pu il„

�U
w
°FMC Corporation
z
T
Lithium Division
g
0
Highway 161
Box795
,._
Bessemer City North Carolina 28016
a o
m 704 868 5300 Fax [phone]
z
TIFIED MAIL
TURN RECEIPT REQUESTED
October 13, 1994
FeF7GE EI/ rINR
Of-M. G�0 irj VfiA ER SEA:.
,,1} OCT 1 ? AM l0' 12
WMC
North Carolina Division of Environmental Management
Groundwater Section
P.O. Box 29535
Raleigh, NC 27626-0535
Re: FMC Corporation - Lithium Division
Bessemer City - Non -Discharge Permit No. WQ0008149
Groundwater Quality Monitoring - Compliance Report Forms
Dear Sir or Madam:
In accordance with the requirements of item no. 20 of the North
Carolina Water Quality Permit No. WQ0008149 for the Recycle
System (kiln scrubber ponds) located at FMC Corporation's Lithium
Division facility in Bessemer City, FMC is submitting the
Groundwater Quality Monitoring Compliance Report Forms (form no.
GW-59) for the September 13, 1994 sampling of well nos. DC-1 and
DC-2. Also included are the Test Boring/Well Construction Log
sheets for well nos. DC-1 and DC-2. These two wells were
installed in March 1994 as required in the RCRA Facility
Investigation ("RFI") Work Plan approved by the North Carolina
Division of Solid and Hazardous Waste Management pursuant to the
provision of RCRA permit no. NCD000771964. The well logs
included here are marked "draft" and some information has been
handwritten on the forms; final versions of these well logs will
be developed concurrently with the final RFI report in 1995.
The results reported here for aluminum, chromium, iron, lithium
and manganese were obtained using method 3030C in Standard
Methods, 17th edition, as required in Permit No. WQ0008149. The
results for fluoride were obtained using EPA method 340.2; for
TDS using EPA method 160'.1; for pH using EPA method 150.1; for
chloride using EPA method 325.2; for sulfate using EPA method
375.4, and for calcium using SW-846 protocols. All results
represent analysis of unfiltered samples, except as otherwise
noted for a second chromium analysis, made using SW-846
protocols. Laboratory report sheets and chain of custody records
are available upon request.
If you have any questions, or require additional information,
please contact me at 704/868-0806.
Ve, truly ours,Z
i
r ara E ./ itchi'e
Environmental Manager

¢�D
Ox'on o
w
Q�a Q
UZ r
Z 0.� C
�z
w�
a
7
Twi:
ENVIRONMENT &
INFRASTRUCTURE
Test Boring ell Construction Loa
a '!'li4 irket Plaza Way (717) 795-NMI
a Njechanicsburp. PA 17055 (717) 795-82Nt1 (FAX)
P_-ri 'ect : FMC - RFI
Boring No. DC -I
91 ent : FMC Corp. Lithium Division
sheet 1 of I
v
Purpose: MonitorWells
Job No. 35586
Drilling Contractor :McCall Brothers Inc. Driller: J. Carter
Total Depth 60:0'
Geologist Joseph J. Ozog, Jr.
Specifications
Type Diameter
Hammel
Vcight: lbs.
Date Started 3/3/94
Time Log: Begin Finish Depth
Casing
Notes: 2" PVC -
Screen slot size -
Date Finished 3/3/94
Bore
Auger
8.0"
.01"
S.W.L 15.87' TOC/GL
Well
PVC
2„
Elevation TOC
qzq, o f
Surface
117-1p,07
sampler
Fr msf(
Fr rn5
Depth
Sample
Blow
Sample
Visual
Log
Lithologic Description
Notes
(Feet)
Numbers
Counts
Recovery
Descri
tion
0.0" - 6.0" Brown topsoil.
Well materials:
..
6.0" - 18.0' Light brown oi e tailings
wet, & silty.PVC
Riser -
+2.0' - 29.0'
PVC Screen -
��
29.0' - 59.0'
10
„
Bentonite/Grout -
%
X
�%
0.0' - 23.0'
.
,.
Bentonite -
��
23.0' - 25.0'
.�
.,
�•
Sandpack -
"
18.0' - 26.0' Darker brown ore
25.0' - 59.0'
20
"
tailings, wet.
.
.'
26.0' Groundwater was
_
-
encountered.
_
=
26.0' - 60.0' Silty clay - natural soil,
30
=
_
=
oranuish-red.
_
=
37.0' Silty clay - as above,
—
=
but material is softer.
40
=
_
_
=
=
44.0' Silty clay - as above,
_
=
=
material is very soft.
50
=
=
=
Bentonite/Grout
Bentonite
_
-
0 Sandpack
59.0' Bottom of well.
60
--
- =
59.0' - 60.0' Collapse.
Screened PVC
- -

ENVIRONMENT&
ICMI'INFRASTRUCTURE
2 Market Plaza way (717) 795.8(M)I
Mechanicsburg, PA 17055 [phone] (PAX)
el' "'`� '•
Test Boring C6nstruction Log
(r�
o-
Project: FMC-RFI
Boring No. DC-2
Client: FMC Corp. Lithium Division
shoot I or
Purpose: MonitorWells
Job No. 35586
Drilling Contractor :McCall Brothers Inc. Driller : J. Carter
Total Depth 46.0'
Geologist : Jeff Painter
Specifications
Type Diantrter
1am111Cf
'cight: ,h,.
Date Started 3/4/94
Tune Log: Begin Finish Depth
Casing
Notes: 2" PVC -
Screen slot size -
01"
Date Finished 3/4/94
Bore
Augcr
g,p"
S.W.L 16.58' TOC/GL
Well
PVC
2"
Elevation TOC
170, `)O
!� 1 M 5,Q
Surface
Cl i .0, 41-
�'•�— A7 5�
Sampler
Depth
(Feet)
Sample
Numbcrs
Blow
Counts
sal» ple
Recovery
visual
Descri
_
=
_
-
_
-
=
_
_
_
=
_
_
_
=
-
-
Log
lion
Lithologic Description
Notes
_
_
_
=
=
10
20
30
40
50
60
=
-
=
=
-
=
=
=
=
-
=
_
=
=
=
_
=
-
0.0" - 6.0" Top soil.
6.0" - 6.0' Light brown, silty ore
tailings, damp.
6.0'- 47.0' Clay - red -brown, silty,
damp, occasional light
grey to olive grey,
severly weathered mica
schist and grayish dark
quartz fragments.
21.0' Cuttings are moist,
slightly darker red,
moisture content
increases slightly with
depth.
36.0' As above, but cuttings
slightly harder.
37.0' - 47.0' Cuttings soft, damp.
46.0' Bottom of well.
47.0' Bottom of borehole.
Well materials:
PVC Riser -
+1.5' - 17.0'
PVC Screen -
1 CO Ja'0' - 46.0'
Bentonite/Grout -
0.0' - 11.0'
Bentonite -
1 1.0' - 13.0'
Sandpack -
13.0' - 47.0'
Bentonite/Grout
Bentonite
0 Sandpack
El Screened PVC

Id
U(o If h•ORM APPROVED
OMB NO. 158-S78004
1
DATE PREPARED
f
SERIAL NUMBER
U.S. ENVIRONMENTAL PROTECTION AGENCY
MONTH
DAY
YEAR
SURFACE IMPOUNDMENT ASSESSMENT (SIA)
=
LOCATION AND COUNT OF IMPOUNDMENTS M NTS
75 76
77 78
7 9 So
SECTION 1
FACILITY IDENTIFICATION
How many impoundments are
STATE IDENTIFICATION NO. (Optional)
t�>
STATE
CNTY„CITY
PLACE
CATEGORY
SIA SITE NUMBER
located at this site?
l
1
2
3 - 5
6 `-
tb
11 - 13
14 - 18
... ;.
22
23 - 25
: 26
_- -- - - - 37
STANDARD INDUSTRIAL
SITE LOCATION
NPDES NUMBER
CLASSIFICATION (SICCOie
...........
DEGREES
M NUTESSECON
DS
DEGREES
MINUTES
E S
5F ON S
-
t
A
L D ELONGITUDE TITU—�
—�
:i
-
r
P
i.
96.
_ N
46
47 50
51 2
5
_
3
5 5 4
55 5 6
_
57 59
0 6 61
62 63
OWNER
NAME OF OWNER
59
OWNER'S MAILING ADDRESS (Street No. or P.O. Box)
22
_
59:
CITY OR TOWN
STATE
ZIP CODE f1
22
_
52
53 54
55 - 59
!'
OPERATOR
NAME OF OPERATOR
c
S
E
22
-
59
7<
9
OPERATOR'S MAILING ADDRESS (Stree,t No. or P.O. Box)
22
_
59
CITY OR TOWN
STATE
ZIP CODE
'7
22
_
52
53 54
55 - 59
EPA Form 7500-44 (6-78)
STATE COPY

W
GROUND WATER DIVISION GSP 079
OFFICE OF WATER AND AIR RESOURCES Q71 q
35 16 00
DEPARTMENT OF NATURAL AND ECONOMIC RESOURCES
81 1810
RECORD OF GROUND WATER POLLUTION SOURCE
RECORD BY: Michael S. Marsh DATE 1/76 W.D. PERMIT NO.2123
TOWN: Bessemer City COUNTY: Gaston
LOCATION (SKETCH ON BACK) : west side of Bessemer City south of Jct. 161 and SR 1403
OWNER(S) OF FACILITY OR INSTALLATION: Lithium Corp
TYPE SOURCE: (LAND FILL, LAGOON, ETC) lagoon (tailings pond)
CHARACTER AND QUANTITY OF POLLUTANTS: 750,000 gpd industrial waste
DESCRIPTION OF FACILITY (SKETCH ON BACK) : settling pond for lithium ore
processing plant
HYDROGEOLOG I C CONDITIONS AT SITE: sandy clay saprolite and sandy stream alluvium,_
uvi umF
mica gneiss bedrock ± 10 feet to water table
POLLUTION CONFIRMED BY ANALYSIS? no DATE ANALYST:
MONITORING FACILITIES INSTALLED: no
SAMPLING SCHEDULE: none
NEAREST STREAM: UT Abernathy Creek DISTANCE
NEAREST WATER SUPPLY WELL: unknown DISTANCE
ANALYSES AND OTHER DATA AVAILABLE:
REMARKS:
FORM GW-46
I ID 1-M
G0
�MLEIGHQ N, �$
y�

c4dG7' : ?ti 2
ISO -
Par
_ Jl� r
Ir
f1 'y •" _ fit. ' •.i.:. �•• ''��.. .. _ .� !� - -. _
Ci
'•-•7•'��.i. •.� a' .t 1 .}• •,;�• +•fit �l:�. - '.. �. � ,•�.:i �' .., . • .• -
� �•!•.�•, LT ,t.' Tyr •"r•.••7'',. .•0•�",. 't o:.�•�,. 'r' �•.. �h .. ., .� .
..,',.'.�. '•.,. 'l'+•,., t 1`. ,r �'.• '.7a .� i C � •'.l .'', i'd„ :1�1 '� ., f1i. •' "' 1�w, • ;• ! ' ' � '�'."��i.t' .. ..�. � . ... _.
�' 4 '.��i�l:: '�� •,� •! . '1, +. fie, 1 `� ;r. � ';s'!• �'1 °ti, 1:;.
� f .. .i-' z C �^•o apt �•c ��•

0
FACILITY•. Lithium Corporation of America
COUNTY: Gaston
SUB -BASIN: 03-08-37
PERMIT DATA: NPDES
OWNERSHIP: Lithium Corporation of America
Individual in Charge: Operator in Charge:
Arthur S. Gillespie, Jr.
Pollution Control Administration
Lithium Corp. of America
Box 795
Bessemer City, N.C. 28016
DISCHARGE POINT:
Latitude - 35015'45" Longitude - 81017'50"
Directions - UT of Abernathy Creek at a point
0.61 mile NW of intersection of Hwy
I-85 SR 1302 and Abernathy Creek
HYDROLOGIC:
Receiving Stream -
Name -
Class -
Drainage Area -
Average Discharge -
7/10 Low Flow -
Stream System -
FACILITY DATA:
Type -
Class -
Design Capacity -
Influent Flow -
Percent Industrial -
Priority Number -
Date in Operation -
Population Served -
Number - NC0005177
Effective - 8-26-73
Expiration - 6-30-78
UT of Abernathy Creek
C
UT Abernathy Creek-1.0 mi
Abernathy Creek - 1.7 mi
Crowders Creek - 21.9 mi
to NC -SC Line
1.8 mgd
12-31-71
STATE
2123
8-23-71
Effluent Limits -
Interim
Final
Parameter
Daily
Avg. Daily Max.
Daily Avg. Daily Max.
Flow (mgd)
1.5
5.7
1.5 2.0
TDS (lbs/day)
40,307
167,534
12,510 18,765
Fluroide (lbs/day)
7.5
28.5
7.5 10
Lithium (lbs/day)
475
1806
375 563
Turbidity
13-15 JTU
Not to exceed 50 JTU's over
pH
6.0-8.5
6.0-8.5 background
OPERATION AND MAINTENANCE:
SYSTEM MODIFICATIONS PROPOSED BY DISCHARGER: Schedule of Compliance:
1. Report of ConstructionProgress September 30, 1975
2. Completion of Construction March 31, 1916
3. Attainment of operational Level September 30,1976
STATE OF NORTH CAROLINA - DEPARTMENT OF NATURAL AND ECONOMIC RESOURCES
ORIGINAL FIRST UPDATE PAGE SECOND UPDATE THIRD UPDATE
8-21-75 1 I-Vr8 fM^I I CTB37-V-33

INDUSTRIAL CLASSIFICATIONS ASSIGNED TO SEWAGE
Process from Which 4-D1 i—t Approximate Daily*
Name of Establishment Wastewater Is Disc ar ed SIC No. Wastewater Vo ui me
Lithium Corporation Plant Extraction of lithium from 2818 1,800,000
spodumene ore by a a sulfuric
acid roasting process
*Gallons per day.
FFGI IIFNT hATA
TESTS REQUIRED BY MONITORING ACT
DATA CURRENTLY AVAILABLE
PARAMETER
UNITS
STORET
NO.
SAMPLE
FREQUENCY
NO.
SAMPLE
MEAN
MAX
MIN
BEG
DATE
END
DATE
pH
S.U.
00403
Monthly
2
7.6
6.2
7-18-74
7-19-74'
Temperature
of
00011
Settleable Matter
ML L
00545
Weekly
Turbidity
JTU
00070
Weekly
Residual Chlorine
MG/L
50060
BOD, 5-day, 200C
MG/L
00310
Annually
COD
MG/L
00335
Annually
Color, true
PT -CO
00080
Formaldehyde
MG L
71880
Grease & Oil
MG L
00550
Dt K' ldahl Nitro
MG L
00625
Phenols
32730
Total Phosphorous
00665
Total Residue
MG/L
00500
Monthly
2
3560
115
7-18-74
7-19-74
Total Sus . Res.
MG/L
00530
Monthly
2
8
6
7-18-74
7-19-74
Detergents (MBAS)
MG/L
38260
OTHERS:
Lithium
Annually
Fluoride
Annually
CTB37-V134

FACILITY —Lithium Corporation of :Ame:r�ica:)
COUNTY:( Gaston
SUB-BASIN:03-08-37
L.td
275
DAIUS
\ nl lL•%•
A
- •.Y
'+ ,...�-":...-. ..'.BESSEM-
yWeolt N !ti
taa G
UNw
/
4. 991
80
o r
tp
1
.
15
`
o u
3
1 t
Mtn
n�,
tP
OIoWms,t'..
•.
'platy.
s
le^�
�/
NGSAMM./ tiP
PINNACLE J�
EIEy. 1705
' 3y a BmOertown
SOUTH
0 / y i^,1 \
kGA
>
JACKSON ;+•'
fi5
KNOB
VI
1 C—de
fA5
.2,
a. ° —° _4 __ _
•LmIM jai l_ —
Jt
�Aa
Crgk
`•_
0. .i= NSn
-
OWNERSHIP: The Lithium Corporation of America
Individual in Charge: Operator in Charge:
H.E. Uhlend
Vice -President
Lithium Corporation of America
Bessemer City, N.C.
DISCHARGE.POINT:
Latitude - 35015'45" Longitude - 81017'50"
Directions - Approximately 0.6 miles upstream of
I-85 and SR 1302 intersection.
HYDROLOGIC:
Receiving Stream -
Name - UT Abernathy Creek
Class = C
Drainage Area -
Average Discharge -
7/10 Low Flow -
Stream System -
UT Abernathy Creek- 1.0 mi.
Abernathy Creek - 1.7 mi.
Crowders Creek - 21.9 mi.
to NC -SC Line
FACILITY DATA:
Type -
Tertiary
Class -
I
Design Capacity -
0.010 mgd
Influent Flow -
Percent Industrial -
Domestic only
Priority Number -
Date in Operation -
2-1-75
Population Served -
Components - Flow measurement Chlnrina ion facilities
Screening Storage ponds
Extended aeration plant
PERMIT DATA: NPDES STATE
Number - 80288-20-74
Effective - 6-30-79
Expiration -
Effluent Limits Interim Final
Parameter Daily Awn Daily Max Dailv Avg. Daily Max.
Flow 8,750 gpd .
BOD,5 day 200C (mg/1) 30 45
Total Suspended solids (mg/1) 30 45
Fecal coliform (no. per 100 ml) 100 150
OPERATION AND MAINTENANCE:
SYSTEM MODIFICATIONS PROPOSED BY DISCHARGER:
0
STATE OF NORTH CAROLINA - DEPARTMENT OF NATURAL AND ECONOMIC RESOURCES
ORIGINAL FIRST UPDATE PAGE I SECOND UPDATE THIRD UPDATE
8-ZI-7S Nx�n f�°' CTB37-V-27

INDUSTRIAL CLASSIFICATIONS ASSIGNED TO SEWAGE
Process from Which 4-D11 it_ Approximate Dail
Name of Establishment _Wastewater Is Dischar ed SIC No. Wastewater Vo ume
Lithium Corporation Domestic 9999 10,000
of America
*Gallons per day.
FFFI IIFNT nATA
. TESTS REQUIRED BY MONITORING ACT
DATA CURRENTLY AVAILABLE
PARAMETER
UNITS
STORET
NO.
SAMPLE
FREQUENCY
NO.
SAMPLE
MEAN
MAX
MIN
BEG
DATE
END
DATE
pH
S.U.
00403
Quarterlv
Temperature
of
00011
Dail
Settleable Matter
ML L
00545
Dailv
Turbidity
JTU
00070
Residual Chlorine
MG/L
50060
Daily
BOD, 5-day, 200C
MG/L
00310
Quarterly
COD
MG/L
00335
Ouarterlv
Color, true
PT -CO
00080
Formaldehyde
MG L
71880
Grease & Oil
MG L
00550
Tot K'eldahl Nitro
MG L
00625
Annually
Phenols
32730
Total Phosphorous
00665
Total Residue
MG/L
00500
Annually
Total Sus . Res.
MG/L
00530
Annually
Detergents (MBAS)
MG/L
38260
OTHERS:
CTB37-V-28

ER
FORFIT APPROVED
OUB NO. 158—S78004
I
DATE PREPARED
SERIAL NUMB
EFA Form 75UO-44 (6-76) STATL LUVY

i
GROUND WATER DIVISION GSP 079
^. ,!D AIR RESOURCES OFFICE OF WATER ES Q71 q35 16 00
DEPARTMENT OF NATURAL AND ECONOMIC RESOURCES 81 1810
RECORD OF GROUND WATER POLLUTION SOURCE
DATE l/76 W . D . PERMIT NO.21?—_
RECORD BY: Michael S . Marsh
COUNTY* Gastnn
TOWN: Bessemer Cit
(SKETCH ON BACK) : west side of Bessemer City south of Jct. 161 2.n.d SR 140_
LOCATION
OWNER(S) OF FACILITY OR INSTALLATION: Lithium Co
TYPE SOURCE: (LAND FILL, LAGOON, ETC) lagoon
tailings vond) - ---
CHARACTER AND QUANTITY OF POLLUTANTS: 750,QOO Qvdndustxial waste
DESCRIPTION OF FACILITY (SKETCH ON BACK:
'n for 1 i thivaa oxP
processing plant
� .��,�'
HYDROGEOLOGIC CONDITIONS AT SITE: s v
o
sa�rc+ i tand
mica gneiss bedrock �0 feet to 'at r table
POLLUTION CONFIRMED BY ANALYSIS? no
---------------
DATE _ ANALYST:
MONITORING FACILITIES INS-TALLED:
SAMPLING SCHEDULE: none
NEAREST STREAM: UT Ab�reath�k —
--- DISTANCE _
NEAREST WATER SUPPLY WELL: unknown
DISTANCE
ANALYSES AND OTHER DATA AVAILABLE:
REMARKS:
,'1,i L1� Ui rlVl/j�
•
-,.RALEIGH,
FORM GW-46

22 3 — �;� < 27 28 2 24 25
IV. GROUND —WATER MONITORING
a. Number of moni— b. FREQUENCY OF GROUND —WATER QUALITY SAMPLING FROM a. HAVE SIGNIFICANT CHAT
toring wells asso— MONITORING WELLS. OBSERVED IN ANALYSIS'
ciated"with this and describe below how thi
'impoundment (if `0'
enter and go to 1. None 4. Monthly 7. Yearly 1. Yes 2. No
question V.b.), EXPLAIN: _ 2. Daily 5. Quarterly 8. Other (Specify in blocks 50 thru 61.)
3. Weekly 6. Semi —Annually
47 48 49 50
i.
T7T D A TT-1 llT. Tci .n�
STEP 1
STEP 2
STEP 3
STEP 4
UNSAT. ZONE
CONFIDENCE
G.W. AVAIL.
CONFIDENCE
G.W. QUAL.
CONFIDENCE
WASTE
CONFIII
1
22
2 3 24
2 5
?
»i
2 6 2 7
28
`"
2 9
30
31
32
trA-1-orm /DUU-44A (6—/B)

I�
GR0UND1-DATER POLLUTION SOURCE EVALUATION
R A N K I N G C R I T E P I A '
THREAT TO GROUNDWATER
Probability of Groundwater Violations
3 Violations documented or highly probable
2 Default
0 Violations unlikely .
Extent of Groundwater Contamination
3 Mappable, migrating plume
2 Default
1 Insignificant contamination expected
Seriousness of Groundwater Threat
3 One of most serious in DEM region
2 Default
DNot considered a serious problem
( FEASIBILITY FOR TAKING ACTION
Feasibility for Remedial Action
3 Remedial action both feasible and desirable
2 Default
10 No remedial action recommended
Desirability of Remedial Action
3 One of top regional office priorities
//2'' Default
�l) Not a priority incident
THREAT TO PEOPLE OR ECONOMY
How Hazardous to Health/Economy
3 People or business advised of contamination
2 Default
� l No expected impacts on people or business
Number of People at Risk
3 4 or more family units, or $10,000 loss
2 Default
1 No people or other interests at risk
Seriousness of People Threat
3 Strong DEM concern over threat to people
2 Default
.0 No threat to people or economy
FEASIBILITY OF RECLASSIFYING GROUNDWATER
Need to Reclassify Groundwater
3 Groundwater should be relassified RS or GC
2 Default
0 No reclass. nor remedial action recommended
Desirability of Reclassification
3 One of top reclassification priorities
2 Default
Not a priority incident
/ THREAT OF POLLUTANTS
How Toxic are Pollutants (use .Sax)
3 High value
2 Mod value
OLow or None value
Quantity of Pollutants in Ground
3 Reportable quantity of hazardous material
(CERCLA def.) or quantity of real concern
2 Default
Y Not of concern to regional office
Seriousness of Pollutant Threat
3 One of most serious in DEM region
61 Default
Not a serious threat
RANK SCORE:
Source Name.
�T
Control Number: „jo2oZ
County:
Ranker:
Date:

Control Nu
Numb
County Number
aa,
GROUNDWATER POLLUTION SOURCE INVENTORY
o (e
Source Name
'OWNERSHIP
2 Private
2 Municipal
Source Address
3 County
4 State
C11�6
County
Region
Jy
erstr�+er (,;-
ti
5 Federal
6 Military
Owner/Operator
71Qua ame
__Tu
ip a Sources a Site
County ource s
YES NO
POTENTIAL SOURCE OF GROUNDWATER POLLUTION
LOCATION
OPERATION TYPE
TYPE OF WASTE
DISPOSAL FACILITY
OTHER SOURCE
© Facility
1 Municipal
1 Gasoline/diesel
© Lagoon, etc.
1
Agricultural Activity
2 Highway
® Industrial
2 Other oil
2 Landfill-contro.
2
Salt water intrusion
3 Railroad
3 Agricultural
3 Solvents
3 Landfill-uncont.
3
Chemical stock pile
4 Waterway
4 Oil and gas
4 -Corrosives
4 Land application
4
River infiltration
5 Pipeline
5 Mining
(5, Other chemical
5 Abandoned site
5
Mine drainage
6 Dumpsite
6 Other Source
6 Sewage/septage
6 Sewer system,
6
Intentional dump
7 Other
7 Sludge
7 Septic tank
7
Spill
8 Leachate
8 Injection well
8
Leak --above ground
9 Other solids
9 Disposal well
9
Leak --underground
Q In use
10 Gas
WASTE:
STATUS OF SOURCE: 2 Inactive
11 Pest/herbicides
feJ1J-*•f 514mes Crea{ed ;y -F/ofAvab4 pvscedf
3 Other
12 Fertilizers
-fir recover y of f/0 p1neMe .
POLLUTION STATUS AND CROSS-REFERENCES
GROUNDWATER POLLUTION
FACILITY PERMITTED: Yes No
1 Confirmed IV Rank
1 NPDES
6 Mining
0 Potential 2 Tabulate
No: NW a 6 Q 517
2 DEM Nondischaargee
rJ No:
7 Hazardous Waste (RCRA)
MONITORING WELLS
,, � ZZ No:
No: `L�
1 No monitoring
vL
2 State has data
3 Well Construction
8 Solid Waste
(Landfill)
3 Data at facility
No:
No:
Q Status unknown
4 Capacity Use
9 Oil Terminal
Registration
DATABASE CROSS-REFERENCE
No:
No:
1 ERRIS (CERCLA) list
5 UIC
I Air Quality
ID: NCDDDD`t71�'il.,�
No:
No:
2 Surface Impoundment (SIA)
Comments
ID: 607
Severn( (a?voMy
3 GW Pollution Source Inv.
Date:
4 Other DEM investigation
Date:
Compiler:
Date:

o F, e ewe oNl: 5. t3-oqr �D N C_vv sz FORM
nAl I I ITInN imrin;NVU-S_T. LEAK REPORTING F
Resources
Confirm. GW Contamination (Y/N)--4-
Incident # % Jc$CJ
)epartment of Environment, Health, Natural
)ivislon of Environmental Management
Major Soil Contamination (Y/N)
;ROUNDWATER SECTION
Date Incident Occurred
Minor Soil Contaminatin (Y/N)
or Leak Detected S 9. '
INCIDENT DESCRIPTION
Incident Location/Name
Address
Clty/Town jag
County
Region t4 ros% Ie.
11
d
Briefly Describe Incident
,.
JkA
OWNER -OPERATOR
POTENTIAL I1S-OURCpE Telephone
Potential Source Owner -Operators _G
F a
Company
Street Address
City
County
State
Zip Code
OWNERSHIP
0. N/A 1. Municipal
2. Military 3, Unknown 5.Federal 6. County 7. State
OPERATION TYPE
0. N/A 1. Public Service
2. Agricultrural 3. Residential 4. Educational/Relig. 5. Industrial 6. Commercial Q. Mining
POLLUTANTS INVOLVED
MATERIALS INVOLVED
AMOUNT LOST AMOUNT RECOVERED
T.D.S
SOURCE OF POLLUTION
PRIMARY SOURCE OF POLLUTION
PRIMARY POLLUTANT TYPE LOCATION SETTING
(Select one)
(Select on-)
t.
1. Intentional dump
13. Well 1, Pesticide/herbicide 1. F 1. Residential t:;+
2. Pit, pond, lagoon
14. Above -ground 2. Radioactive waste 2. Railroad 2, Industrioh ; F ,
3. Leak -underground
Storage Tank
3. Gasoline/diesel 3. Waterway 3. Urban`
.c�
4. Spray Irrigation
15. Nonpoint source 4. Heating oil 4. Pipeline 4. Rural 6 9
5. Land application
5. Other petroleum prod. S. Dumpsite
6. Animal feedlot
6. Sewage/septage 6. Highway
7, Source unknown
7. Fertilizers 7. Residence r
8. Septic tank
8. Sludge 8, Other `'�
9. Sewer line
olld waste leac
10. Stockpile
eta Site Priority
11. Landfill
11. Other inorganics Ranking
i0
12. Spill -surface
12, Other organics
D.E.M. Regional Contact
Sign ur Date
1
i /
GW-61 Revised 2/95

IMPACT ON DRINKING WATER SUPPLIES
WELLS AFFECTED 1. YES
NUMBER OF WELLS AFFECTED
Well(s) Contaminated: (Users Name)
1,
2,
3.
4.
5.
Circle Appropriate Responses
Lob Samples Taken By:
1. DEM 2. DHS 3. Responsible Part 4.Other 5. None
Samples Taken Include:
1. Groundwate 2. Soil
LOCATION OF INCIDENT
7 1 /2 Min. Quad Name
LgL: Deg: Min: Sec:
5 Min. Quad Number
Lg2g.: Deg: Min: Sec
r
-900
. N 9/
etch of Area or Attach Additional Mops
Draw Sketch
1403
860— , ,r
y I
y 11
r �
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•p - F' ra
Pant
' (
9
00 b � O •4b
tr
1 ld
l
/ �• 11
• 3 �_
_001401
•r•
um In
°
Site.100
iv
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