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Home My WebLink AboutWQ0002702_Regional Office Historical File Pre 2018 (12)State of North Carolina. tf Department of Environment and Natural resources Division of Water Quality Michael F. Easley, Governor William G. Ross Jr., Secretary Alan W. Klimek, P.E. Director NCDENR DRAFT NON -DISCHARGE COMPLIANCE INSPECTION GENERAL INFORMATION City/Town/Owner: Alchem Inc. Permit No.: WQ0016`9 Last Amended Date: N/A SOC Issuance Date(if applicable): N/A Permittee Contact: Wane Drye ORC Name: ORC Cert.#: Reason for Inspection X ROUTINE, Type of inspection Collection System County: I Rowan county Issuance Date: 'March 1. 1999 Expiration Date: _December 31, 2004 Expiration Date: N/A Telephone No.: 704/ - Telephone No.: 704/ - B/U ORC: COMPLAINT x FOLLOW-UP OTHER Spray Irrigation Sludge _ X Other Inspection Summary • (additional comments may be included on attached pages) This permit is still in the adjudication process and was inspected using the permit conditions in the expired permit WQ0016338, dated March 1, 1999. David Goodrich, APS, Central Office, Andrew,Pitner, APS, MRO, Wes Bell, SWP, MRO, also attended this inspection. Physical readings of temperature and pH were taken in several locations. See map and readings attached to this inspection report. The earthen berm; surrounding the fill area, shows constant signs of seeping along the lower end of the berm impoundment. pH readings in this area were in the 3.08 SU range. Inside the bauxite fill area, pH readings were in the 3.8 3.9 SU range. The earthen berm was originally constructed due to a previous failure to keep the bauxite residuals on site. The berm was inspected by Boyle Consulting Engineers, in the summer of 2005. Continued on page 2 Is a follow-up inspection necessary X yes —no Inspector(s) Name(s)/Title(s) Ellen Huffinan / Env. Specialist II Telephone No. 704/663-1699 Fax No. 704/663-6040 Date of Inspection December 5, 2006 2-0 Water Recycle System'Inspection WQ0016338 ALCHEM, Inc. Inspection Summary Continued Pg 2 The MRO APS received the report. in March 1, 2006. The Boyle report reflected inconsistencies in the berm construction and probable failure. ALCHEM has not taken any action to repair/replace the berm. Currently there is a large amount of rainwater in the lagoon. This has increased the unstable conditions of bauxite area. This inspection included sampling of existing monitoring wells for permit # WQ0002712, which is the permit for the water recycling system used to wash the spent Bauxite which is stored in the lagoons prior to final use in the "fill" area. Type of System Bauxite residuals Reuse Record Keeping N Y`� opy of current permit available at residual generating site �urrent metals analysis (2 x's year) CLP analysis- 1 x per permit cycle, starting in 1999. } Hauling records (# gal and/or ton hauled during calendar year to date) .ill inspection log (records). Treatment (check treatment type(s) used) / C Wash Recycle System (WQ0002712)'� r' Transport NIA Spill control plan in transport vehicle? Does transport vehicle appear to be maintained? Comments - Operation & Maintenance records N/A v s'T /C-_ Disposal Reuse Area :Describe storage: Site condition adequate 12/06/2006 09:29 919-715-0588 NCDE&NRIWATER QUAL PAGE 02 Temperature and pH Readings taken at the Ax,CITOM Facility in Rockwell by APS Personnel on December 5, 2006 Site Water # Site Description Temp PH 1 Stormwater Drainage Ditch, downstream of railcar off-loading spot. 6.1°C 3.68 2 Approximately 50 feet downstream of Site # I. 6.2°C 3.52 3 Shallow wetland or seep from stormwater detention pond, outside berm. 6.1°C 3.16 4 Same area as Site # 3, near the base of the berm. 6.4°C 3.08 5 The "comer" of the bermed stozmwater detention pond. 9.7°C 3.80 6 Close to Site # 5. 9.7°C 3.82 7 Upstreanx location along the "boundary" stream. TOT 5.36 S Approximately 90 feet downstream of Site # 7. 6.0°C 5.44 9 Approximately 90 feet downstream of Site # 8. 6.7°C 5.56 10 Possible surface seep in. Bret area between "boundary" stream. and berm.. 9.8°C 5.66 11 "Elbow" of the "boundary" stream where it changes direction. 9.3°C 5.28 12 Apparent seep area below berm. Seeps noted on the berm itself. 8.4°C 3.04 . 13 Upper stormwater detention pond on northern side of isthmus. 9.2°C 14 Lower stormwater detention pond on southern side of isthmus. 9.1°C 15 Northwest corner of Lagoon, # 2_ 6.8°C 3.41 16 Northeast corner of Lagoon !# 3. 8.6°C 2.62 17 Southern edge of Lagoon # 1. 6.1°C 3.31 Note: All three Lagoons were essentially full of "sand" at the time of the field visit on December 5, 2006. J •.. - ,. CJ!w.�i:rrNL�. ��sasld�l,�� - � • , i .. aJC��►_T fj4 1 i9 �Ft` lie, �ouri� Y N� vz CD pie CD LO I*, W 4 4 n°. l lh; - f r1 r "-4 i�J 11—��i Y . 'i � ! LO '! -•) tf'.�'ct'b 41 YI. c 0 +. Its t I I� l s.lyd pal! 1r. 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Low (OF) Today Partly Dec'- Cloudy 63 /38 o 0 0 /o 14 Fri Dec Sunny 70°/38° 0 % 15 Sat Dec Sunny JWF 68°/40° 10 % 16 ' Sun Partly Dec "�IVACloudy o 0 69 /45 0 10 /o 17 Mon Dec Sunny jW 73°/47° 10 % 18 Tue Partly Deer Cloudy o 0 70 /40 0 10 /o 19 Wed Dec cloudy 610/39° 10 % 20 Thu Dec Showers 640/40° ! 40 % 21 Fri Dec Showers 590/340 60 % 22 Sat Partly Dec "' Cloudy 54°/310 10 % 23 Last Updated Dec 14 01:07 p.m. ET Print This Forecast Back to Previous Pale Bringing weather to life http://www.weather.com/weather/print/28115 12/14/2006 ALCHEM Inc Red Rd, Rockwell, NC August 2005 r �-=� �� \�'� , �� '}'"' ;ram' ,. .r• . t I yr, y�S"' �y �/�� /t • f � � 1 f v.a . , „y, � �`.,,.�. „� Y':w/YJi ✓ rs ✓ � ' J' ,y . � / �,! 7r , t"Q .� _.�7 s./ Z. i�r• .,N it.+ :'(sy �� 3'SKr ,!-rL'i�,•li-f• - 1 �� ,q{.\`41. '\-1�1*r .s �.�p�\ w �t�a d�l f••� r�, ,s�` �,b4�{1s:i.R``:'T D � �. 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Fri• ��-3\\,y...r f., r��,�� ,� ;{r r �o5 f�(, 'AA `.�Al.� !t •1r! f .� L l jr•� ti j.` ';r k t`+£ �f••r'� l \`� Jy�..y' } s5. S�y�^•a'`i1 C'''•h a \` !'r N' r• s �LT.^'i.e : a 1, r'i / "r ,,l. r { €r ti l Y�`� ✓�h[� ,��w Y . �5 }y� eriY�$a�� y tMr4�� ; J %d; .•: , , � \ '� — ! ^ & �.' W �y✓ x , r � � � �JFir) � ~ � •c.1 , r J 1 \� f f � ". y ll ffi �, `�Y��9 r.-.....�y .. ��.,-�� :. _. .r;�-if'< rs .l�tL<fil�•- '4P- s. 5 a�€dd: '�L�:.. '' ALCHEM Inc Red Rd, Rockwell, NC December 2006 ALCHEM Inc Red Rd, Rockwell, NC December 2006 water in berm Seep from berm a�3� \ a tv� 0 1 �, �'1 IL �'I. ��, . ',`z, � � t F- Wyk `T � •,.- �- �.,c�� - Y ALCHEM Inc Red Rd, Rockwell, NC November 2004 -� r ALCHEM Inc Red Rd, Rockwell, NC 12/05/2006 ALCHEM Inc Red Rd, Rockwell, NC October 2004 �!, fWt ' �r �n �`YpaxadJ�a a�e Rl yyG� 4 ALCHEM Field Visit on January 13, 2006 ALCHEM Bauxite Monofill Permit No. WQ0016338 ALCHEM Facilitv in Rockwell Rowan County Participants: Ellen Huffman and Chet Whiting from the Mooresville RO, APS/DWQ David Goodrich from the Central Office, APS/DWQ Staff from the Aquifer Protection Section met with Trent and Wayne of the ALCHEM staff at the industrial site on Red Road in Rockwell. Conditions observed at the site included the very full condition of Lagoons #1 and #2, which were filled with solid, spent bauxite material. Lagoon #3 was observed to be nearly empty, and has been recently cleaned out (by excavation). The site was toured during the field visit, and recent changes include the construction of a large berm around the "Stormwater Detention Pond" at the northeastern corner of the property. The berm is essentially a large, earthen dam which is more than 20 feet high in some portions. The "Stormwater Detention Pond" now extends from the central portion of the northern -most section of the property in an easterly direction, turns south towards Lagoon #2, and parallels the eastern boundary of the property for several hundred feet. The Pond essentially serves as a sump for the fill area (which contains spent bauxite material). The fill area is relatively flat, but additional fill can only be added in a vertical direction. A number of pH measurements were taken to ascertain the pH values of the surface water/ponds/wetland areas potentially impacted by the industrial operations of the facility. It was noted that the surface water in all locations where the pH measurements were taken (with the exception of the stream pH measurements) had a green or greenish - blue color that was chemically induced. The first reading was taken just to the north of the two digester tanks in some rainwater that had accumulated ui a low area near the structure housing the tanks. This area is reportedly pumped out on a regular basis. The measured pH at this location was 3.55. The second reading was taken near the southern end of the Stormwater Detention Pond. The measured pH at this location was 4.16. The third reading was taken at the confluence of a very minor tributary (from a wetland outside of the berm that was situated between the berm and the property boundary) and the stream which runs from north to south along the northern portion of the eastern property boundary (approximately 200 feet east of the reading taken at the southern end of the Stormwater Detention Pond). The measured pH at this location was 4.60. The fourth reading was taken in the same tributary (before it actually mixed with the streamwater), at the southern end of the wetland mentioned previously. The measured pH at this location was 4.46. The fifth reading was taken in the stream above its confluence with the wetland tributary mentioned earlier. The measured pH at this location was 5.72. The contrast between this reading and the (fourth) reading taken in the wetland tributary (between the stream and the berm) less than 20 feet to the west is believed to be largely the result of (affected) groundwater upwelling in the wetland area. The sixth reading was taken at the northwestern corner of Lagoon #2 (which is mostly full of material). The measured pH at this location was 3.99. It was apparent to the attending staff of the APS that the new permit for the monofill operation needs to include a requirement to promote the physical containment of the water in the Stormwater Detention Pond. The pH of this water was measured at 4.16; the wetland tributary outside of the berm and (apparently) hydraulically downgradient of the Pond was measured at 4.46; and the stream above the surface water confluence was measured at 5.72. From a hydraulic standpoint, the deeper the water is in the Stormwater Detention Pond, the more energy there is available for forcing affected groundwater (and stormwater) towards the east (downgradient), beneath the berm and into the wetland and adjacent stream. An impermeable liner installed in the Stormwater Detention Pond would eliminate the affected stormwater's impact on the groundwater (and subsequent wetland and adjacent stream), provided the surface runoff was introduced above the liner (so it would be "caught") and the stormwater level in the Pond itself did not overtop the liner. -� ` � `f '' ( �111' 111['J NC DEPT OF ENVIRONMENT & NATURAL, RESOURCES DIVISION OF WASTE MANAGEMENT HAZARDOUS WASTE SECTION 1. Facility Information: 2. Facility Contact: 3. Survey Participants: 4. Date of Inspection: Date of Report: 5• Purpose of Inspection: 6. Facility Descrintinn• RCRA INSPECTION REPORT Alchem, Inc 8135 Red Road Rockwell, N.C. 28145 Mr. Wayne Drye, Plant Manager 704-279-7908 Mr. Wayne Drye Mrs. Ellen Huffman, NC DWQ Mr. Andrew Pitner, NC DWQ Mr. Ed Robinette, NC DLR Mr. Sean Morris, Waste Management Specialist August 23, 2005 August 26, 2005 To determine compliance with 40 CFR 260-279 On August 23, 2005 I conducted a compliance evaluation inspection at Alchem, Inc. in Rockwell, NC. The inspection was conducted as a part of a join n the NC Division of Water Qualityand the NC I t 1 spection with Inc. does not have an EPA Identification Division Land Resources. Alchem, Number assignedd to the prpperty. Alchem, Inc. has been, in o currently is located on a 45 acrettoa atthe land current since production process. as 5-em to eeS19facility p The facility P Y sulfate, as a flocculent at municipal Y Primarily produces aluminum sulfate working with i�, Produces ferrous sulfate, which a'stu water anddrinkingwhich is used wastewater treatment lants Water Plants. The facility also adjustment at wastewater treat odor control ingredient in P ,and produces the summer at magnesium hydroxide the f -residential area within 200-500 feet of the tfacility. s. facilit Y is not fenced and there i�� The aluminum sulfate production process consists of sulfuric acid solution. The mixture is then cooked washing brick lined 12,000- at 260 degbees Fahrenheit gallon tanks, The liquid is um it in two tanks and checked for Pumped to aluminum sulfate storage quality control parameters. The sand remainingin the g &Vl is mixed with Water and a, polymer then cook pumped to One of three settlement basins. The rinse process is repeated several times until the cook tanks are clean and the process can restart. Mr. Drye stated that the facility does not generate any waste from the process other than the sand slurry sent to the settlement basins. The bauxite ore is delivered by rail to the facility in powder form. The bauxite is mined outside of Atlanta, GA. Sulfuric acid is also delivered by rail and is then pumped to a 10,000- gallon steel tank. The facility currently operates under a NC Division of Water Quality (DWQ) "Recycle System Permit — WQ0002702" and a "Residuals Reuse Permit — WQ0016338". The permit allows the facility to pump the slurry from the cook tanks to one of three settlement basins. The sand material settles to the bottom of the basin and the wastewater is pumped back into holding tanks for make-up water for the production process. The facility uses water from on -site wells, municipal water, and make-up water for production purposes. Approximately 70,000-gallons of water is used on a daily basis with the make-up water counting for about 10,000-gallons. The facility's DWQ permit also allows the facility to remove sand from the settlement basins and landfill the material on -site. The facility has one stormwater detention pond located adjacent to the landfill area. Water from the storm water detention pond is also pumped back to the facility and used as make-up water. Ellen Huffman and Andrew Pitner collected grab sand samples at Lagoon 43, Lagoon #2, and the "Residual Fill Area". Each sample will be analyzed for total metals and pH. During the facility tour several puddles of rainwater were noted on the outside of the stormwater containment pond. Mr. Drye stated that the facility conducts and documents periodic pH readings on the rainwater puddles and the stream that runs adjacent to the facility. A copy of the monitoring records was obtained at the time of the inspection. 3 7. Deficiencies: No violations of the NC Hazardous Waste Regulations were noted at the time of the inspection. 8. Recommendations: • It is strongly recommended that all spills of sulfuric acid, that occur during off loading of rail cars, be contained, neutralized, and cleaned immediately. In order to accomplish this it is recommended that a secondary containment system be used at the off-loading area. g I��los Inspector • cc: Jesse Wells, Western Area Compliance Supervisor Raleigh Files MRO files Wayne Drye, Alchem, Inc. Ellen Huffman, NC DWQ (Sent US Mail) Facility Contact State of North Carolina Department of Environment and Natural Resources Division of Water Quality Michael F. Easley, Governor William G. Ross., Jr. Secretary Alan W. Kimek, P.E. Director A 4 N *2 NCDENR NON -DISCHARGE COMPLIANCE INSPECTION GENERAL INFORMATION City/Owner ALCHEM, Inc. Permit # WQ 0002702 Issuance Date 12-28-2004 If applicable SOC Issuance Date N/A Permittee Contact Wayne Drye Alt. Permittee Contact Randall Andrews ORC N/A 24hr Contact Name Reason for Inspection County Rowan Expiration Date 11-30-2009 Expiration Date Telephone No.704/279-7908 Telephone No. 910/843-2121 B/U ORC N/A Telephone No. X ROUTINE COMPLAINT FOLLOW-UP OTHER Type of inspection Collection System Spray Irrigation _Drip Irrigation Sludge X Other Inspection Summary: (additional comments may be included on attached pages) Inspection on August 4, 2005, Accompanied by Wes Bell, MRO, Surface Water, who was there to check on the stream restoration efforts form the enforcement action May 2003. At the time of this inspection, Lagoon #1 was so full of bauxite residuals (with very little H20) that it appears that the last rain pushed the residuals to the low end of the lagoon, topped the berm and drained (thankfully) to lagoon #2. There is no freeboard space. Wayne Drye, onsite manager, was told that this bauxite needs to be removed immediately to create some sort of freeboard. The level indicators for the lagoons were not installed correctly at the lowest point of the berm of each lagoon. The pH in all three lagoons and the stormwater lagoon is as follows: lagoon #1- 1.13. lagoon #2- 1.09 and 1.2. Lagoon #3- 2.5. the stormwater basin- 2.12 and 2.01. This indicates that the wastewater recycle system is not keeping the washwater at a pH of 6 as required in permit condition # 13. The berm appears to be > 20 feet in places and the credibility is questionable. There were indications of cracks, sinks, erosion, etc. ALCHEM has placed what appears to be construction debris (huge cement slabs with rebar sticking out) in the bauxite fill area. Mr. Drye and Mr. Andrews wer informed that only bauxite was permitted to be disposed in the bauxite fill area and the debris needs to be removed asap. It was noted at the time of inspection that the City water line had been moved as required in the permit (item 19). N. - Inspection pg 2 Permit #-WQ0002702 Rowan County August 4, 2005 Is a follow-up inspection necessary _yes _no Inspector Name/Title Ellen Huffman /Environmental Specialist II Telephone No. 704/663-1699 Fax No. 704/663-6040 Date of Inspection August 4, 2005 Type Activated Sludge Spray, low rate Activated Sludge Spray, high rate Activated Sludge Drip, low rate Lagoon Spray, low rate Reuse (Golf Courses) Recycle /Reuse Single Family Spray, low rate Single Family Drip X Other- This facility is a process water recycle system. The permittee also has a non - discharge bauxite re -use permit (WQ0016338) which is currently in review. Treatment Yes Are treatment facilities consistent with those outlined in the current permit? No Do all treatment units appear to be operational? If no, note below. The pH in the lagoons are as follows: lagoon # 1 - 1.13. lagoon #2- 1.09 and 1.2. Lagoon #3- 2.5. This indicates that the wastewater recycle system is not keeping the washwater at a pH of 6 as required in the new permit, condition # 13. Debris in fill area stormwater and berm area MARCH 2O06 AERIAL PHOTOGRAPHY 1 inch equals 200 feet e Alchem history from MRO files pdhe ''l ut,_ y Ellen Huffinan Please note that the author has found files in several sections/divisions due to the different types of permits issued for the same process i.e., residuals, recycle, and groundwater. Dec. 6, 1984 — Complaint from City of Rockwell of white color in creek. May 9, 1985 — A memorandum concerning a complaint investigation of a spill/runoff into creek (investigated on Nov. 15, 1984) from the ALCHEM plant and drinking water well contamination. All stream samples showed high concentrations of Al, Fe, Na, and Zn. Dec. 30, 1985 — WQ MRO complaint investigation report summing up issues from multiple spills throughout the last 12 months since the Nov. 15, 1984 investigation. Jan. 2 & 7, 1985 — WQ samples the stream. Samples come back with extremely high concentrations of Al, Fe, Na, and Zn. (data in file) Feb. 28, 1985 — Stream samples still show high levels of Al, Fe, & Na. March 26, 1985 — WQ received another complaint from a resident in the ALCHEM area. April 1, 1985 - Soil samples showed high levels of Al, Fe, & Na. Well samples taken at the same time were high in Al & Na. Down stream samples showed high concentrations of Al, Fe, Na, and Zn. Upstream samples did not show high concentrations of Al, Fe, Na, and Zn. Also discovered the path of runoff from ALCHEM property to the stream. May 9, 1985 — A memorandum from Monty Payne & Jesse Wells, to Bill Jeter, concerning multiple complaints from neighbors of ALCHEM. June 11, 1985 —Stream samples, once again, show high levels of Al, Fe, & Na. Sept. 9, 1985 — During a meeting with WQ and ALCHEM, it was determined that the ponds need to be emptied and contaminated soil be removed or neutralized. If the lagoon was to be used it must be lined. They also must submit an application for a non -discharge permit. Jan. 3, 1986 — WQ staff report (Thulmon Horne) for ALCHEM (APN 005232) The facility has 2 existing (un-permitted) recycle lagoons. DEM & DHR have both conducted investigations regarding well and groundwater contamination. ALCHEM has had to replace one off site drinking water well, cleaned areas affected be run-off, and removing all liquid from the lagoons with the intention of removing the lagoons (excavating and removing contaminated soils). ALCHEM proposes to construct a new recycle system. The new process will involve mixing bauxite, sulfuric acid, and water in a reactor. The waste residuals (pH between 2.0 and 2.5) will be pumped to the proposed non -discharge recycle wastewater treatment facility. The residuals from the facility will be pumped to the retention pond where LIME will be added to raise the pH to 6 s.u. The applicant proposes to dispose of the ALCHEM file History Page 2 residuals in the county landfill. The applicant has failed to submit acceptable detailed engineering plans and specs as requested. Recommendations: Considering the past history of this facility; it is imperative that a thorough evaluation is made prior to permit issuance... Jan. 7, 1986 — A meeting in Rockwell between DEM & ALCHEM, concerning a need for a permit for the ALCHEM facility. Jan. 8, 1986 — DEM WQ MRO memorandum — WQ reviews an application and recommends that ALCHEM do a thorough investigation of the present subsurface conditions prior to issuance of the permit. Jan. 8, 1986 — MRO GW memo from Jesse Wells to Len Bramble. GW recommends that ALCHEM do a thorough investigation of the present subsurface conditions including directional flow and gradient of the groundwater, lithologic description and determination of the hydraulic conductivity of the soil, and sampling of the saturated zone as a requirement before issuance of the permit. Jan. 30, 1986 - A letter from DENR & Community Development, regarding insufficient data to process the permit application. April 10, 1986 — A letter from DENR to ALCHEM regarding Operation of an un-permitted non - discharge Waste Treatment System. May 5, 1986 ALCHEM submits a permit application for a tank spill containment area & a sand filter. May 14, 1986 — DEM Groundwater section memo from Len Bramble to Bill Crawford. Subject application of new permit APN 0076633 and GW 8680. "We have received copy of the above referenced application which was sent to your regional office for comment on or about May 12, 1986"... June 17, 1986 — A letter from ALCHEM to DENR Addendum to application APN007633. Sept. 12, 1986 — DEM GW — memo. Sub. Permit app. Review, ALCHEM, GW86080. Recommends issuance of permit with 2 conditions. 1- the sand filter bed must be lined with a geotech fiber and two layers of 6 mil. (12 mil. total) synthetic liner. 2- any groundwater monitoring deemed necessary by the department. September 22, 1986 — A note to file regarding a letter from ALCHEM to Thurmond Horne evaluating a vacuum filter. Note from staff suggests that the dept. hold the permit application for four weeks before returning the application to ALCHEM as incomplete. (what happened to 1987?) ALCHEM file History Page 3 Jan. 19, 1988 — A letter from DENR to ALCHEM —Subject: Project Return APN007633. In reference to application received May 7, 1986. Feb. 1988 — A etter from ALCHEM to DENR. " I did not realize that our non -discharge Permit was being held. We decided to put in a sand filter enclosed in a tank..." July 30, 1989 — A letter from DENR & Comm. Dev. regarding information needed for a review of ALCHEM Ind. Recycle (WQ0001987) permit to be completed. October 2, 1989 —A letter from DENR to ALCHEM. Subject: Project Return (WQ0001987). October 11, 1989 — A staff report from MRO recommends that the ERG and groundwater provide comments before permit issuance and possible cake sludge storage issues. (Allen Hardee, MRO staff). January 10, 1990 - DENR issues permit WQ0002702 after review of Nov. 17,1989 (permit) application. (cannot find copy of application in file for this date) May 4, 1990 — A letter from ALCHEM to DENR (Carolyn McCaskill) referencing permit WQ0002702 and regarding removal of a partition between two lagoons. May 21, 1990 A letter from ALCHEM to MR. Rex Gleason (MRO) referencing permit WQ0002702 and regarding installed facilities ready for inspection. October 25, 1990 — A Notice of Violation regarding a discharge of alum (?) into the creek. Oct. 8, 1992 — ALCHEM submits a permit application for a recycle system. Oct. 19, 1992 — An application from ALCHEM received by DEHNR (no application found in MRO files). March 11, 1993 — GW memo regarding modification of permit WQ0002702 (concerning) proposed sludge storage lagoons. GW recommends (two) monitoring wells. March 23, 1993 — A renewal application from ALCHEM received by DEHNR (no application found in MRO files). April 8, 1993 - The amended permit is issued to ALCHEM. April 20, 1993 — A letter from ALCHEM to DEHNR regarding amendment of permit WQ0002702 including monitoring well requirements and construction of only two lagoons rather than the original five. Sees no need for groundwater monitoring. April 20, 1993 — A letter from DEHNR to ALCHEM was conveying groundwater -monitoring guidance. ALCHEM file History Page 4 June 9, 1993 -A memo from Don Saffrit, P.E., Asst. Chief for Teck. Support to Ted Bush Asst. Chief, groundwater section regarding a petition (ALCHEM monitoring wells) with the Office of Administrative hearings. June 22, 1993 — A memo from MRO GW (David Eudy) to Jack Floyd regarding adjudication request - regarding concerns with sulfuric acid in large quantities and past history of non-compliance, there is ample justification for groundwater monitoring requirements. June 25, 1993 — A memo from Central GW to MRO GW, regarding adjudication request. "The groundwater section stands firm with its decision to recommend groundwater monitoring to remain a part of the permit". June 30, 1993 — A letter from DEHNR to ALCHEM, regarding groundwater monitoring to stay in the amended permit. Sept. 21, 1993 — A letter from ALCHEM to NC EMC asking permission to drop VOC testing requirements from the permit. April 6, 1994 — A memo from MRO GW to DEM GQ, acknowledging receipt of a permit renewal application for ALCHEM WQ0002702. April 27, 1994 — A memo to DEM GW Compliance Group from Barbara Christian, MRO GW Supervisor regarding a site inspection (for a permit renewal) on April 26, 1994 that raised several concerns. • Raw aluminum ore storage issues • Monitoring reports indicate that monitoring wells were not purged prior to sampling • Lack of chemical analyses of the lagoon wastewater • Inaccurate topographic site map May 23, 1994 — A memo from Cindy Boyles to Carolyn McCaskill, regarding ALCHEM permit renewal (permit WQ0002702) reads "run-off into a drainage way still poses a problem to the residents directly below grade ,,. June 27, 1994 — (renewed) permit WQ0002702 issued. July 11, 1994 — A letter from DEHNR to ALCHEM, regarding (groundwater) monitoring guidance. October 30, 1995 — A certified letter to ALCHEM from MRO GW regarding proper purging of monitoring wells prior to sampling (permit WQ0002702). October 20, 1998 — ALCHEM submits for a permit renewal and modification (permit WQ0002702). r� ALCHEM file History Page 5 Nov. 10, 1998 — A staff report by G.T. Chen includes very little comment. "pending final review and approval by the SERG and the Groundwater Section, it is recommended that the subject permit (WQ0002702) be renewed and modified to allow sand by-product to be mixed with clay. December 8, 1998 — Memo from Peggy Findley, MRO, to Dr. Ken Rudo. Request for Health Rick Evaluation for the public water supply well on the ALCHEM premises. December 30, 1998 — a memo from Brian Wootton (MRO) to Kim Colson WQS, regarding groundwater monitoring changes to the ALCHEM permit WQ0002702. Existing monitoring wells MW-1 & MW-2 shall be sampled Feb. & July for water level, aluminum, and pH. Jan. 21, 1999 — renewal permit WQ0002702 (industrial recycle bauxite process) is issued to ALCHEM. *****March 1, 1999 - Permit WQ00016338 is issued to ALCHEM for a bauxite (residuals) reuse Program "... for the operation of a bauxite residuals reuse program (as structural fill) on ALCHEM Inc.'s property at 8135 Red Road, Rockwell, NC..." April 25, 2000 — A letter from DEHNR, MRO, to ALCHEM, regarding (permit WQ0002702) field analysis data (section 4 of the groundwater G-59 form). Oct. 11, 2001 — A letter from Groundwater MRO, to ALCHEM, regarding an upward trend of aluminum in MW-1 and MW-2 (permit WQ0002702). Letter asks from ALCHEM to re -sample within 60 days, including the drinking water supply well that serves the office. October 17, 2001 — A letter from IAC (Ind. & Agri. Chem. Inc. -parent company of ALCHEM) regarding the Oct. 11, 2001 letter to ALCHEM...."Alchem manufactures aluminum sulfate. Both cation and anion are very water-soluable. We have noticed the increase in aluminum values but with no corresponding sulfate increase. Naturally, we are concerned. However, is it possible that the aluminum is coming from other sources since there is no increase in the sulfate anion? We are going to follow your instructions and will be in touch with you". Jan. 7, 2002 - A Notice of Violation letter, groundwater quality violations. March 15, 2002 — Notice of Violation for WQ0016338 concerning monitoring reports for sect. III, part 3&4. April 12, 2002 - A rescission of NOV letter from Peggy Finley, MRO, to ALCHEM. April 29, 2003 — A complaint received by MRO, from a downstream neighbor of large amounts of white substance being washed down the creek from ALCHEM property. Wes Bell, MRO investigated. Spent Bauxite is found to be over 2 feet think in parts of the stream. April 30 and May 8, 2003 — Investigations had determined that the run-off from ALCHEM had impacted up to 500 linear feet of a tributary to Second Creek. ALCHEM file History Page 6 May 12, 2003 — NOV/NRE for permit WQ0016338 regarding the above complaint investigation. May 14, 2003 — A letter from DENR MRO to ALCHEM, regarding the NOV stating that the NOV should have been issued against permit WQ0016338. May 23, 2003 — The TARA Group is hired to repair erosion control issues at ALCHEM. May 28, 2003 — A letter from ALCHEM to Rex Gleason, supervisor WQS, MRO in response to the May 12, 2003 NOV/NRE. ALCHEM sends an outline of a cleanup plan. August 8, 2003 — MRO photos reflect no clean up activity. August 18, 2003 — (WQ0016338) a penalty was assessed in the amount of $5,998.28 for the May 12, 2003 NOV. August 19, 2003 — A NOV (WQ0016338) was issued for failure to incorporate remedial actions/illegal discharge to surface water. Feb. 24, 2004 — ALCHEM submits the annual report for WQ0016338. ALCHEM reports "for the year 2003, we did not accumulate enough silica residual to land apply". July 29, 2004 — ALCHEM is on a payment plan with AGO for the May 12, 2003 NOV, per Janet Leach. Aug. 13, 2004 — A letter from DEHNR to ALCHEM, regarding withdrawal of permit application package for WQ0016338. Sept. 29, 2004 - MRO receives a request to renew WQ0002702. Sept. 20, 2004 — MRO receives a request to renew WQ0016338. October, 2004 — MRO photos show new berm built around fill area. Oct. 25, 2004 — A staff report by Ellen Huffman, MRO, for both permit renewals, requests that due to past confusion between the two permits that they be combined for better monitoring of a site with many compliance issues in the past. There were also many other changes requested. December 28, 2004 — A renewal permit for WQ0002702 (recycle) is issued with the many changes (as requested by MRO, but the other permit (WQ0016338, residuals) is not issued. It is currently being held in Central Offices until the confusion is cleared up. Permit WQ0016338 was not renewed until Dec. 28, 2006. 0 ALCHEM file History Page 7 Dec. 30, 2004 & Jan.5, 2005 — A follow-up investigation by Wes Bell, MRO, revealed stormwater run- off issues with low pH continuing to impact the stream. Jan. 12, 2005 — NOV/NRE issued due to continued problems found during the investigation on Dec. 30, 2004 and Jan. 5, 2005. Jan. 27, 2005 — A letter from ALCHEM to Rex Gleason, MRO, regarding further cleanup of stream. Letter states that their pH readings are not as low as the readings that Wes Bell had gotten. Feb. '9, 2005 - A letter from ALCHEM to Rex Gleason, MRO, regarding soils sampling, liming affected areas, hiring a tree expert, and repairing silt fences. Feb. 10, 2005 — A letter from ALCHEM to Div. Of WQ, Central Office, regarding the receipt of the new permit WQ0002702. The permit was dated Dec. 28, 2004 but ALCHEM says that they did not receive it until Jan. 28, 2005. This letter asks for an extension of 90 days to review the permit. To the writer's knowledge, Central Office did not reply to this letter. March 8, 2005 — A letter from ALCHEM to Div. Of WQ, Central Office, regarding many objections to the permit conditions of WQ0002702. To the writer's knowledge, no response received by Central Office. March 10, 2005 — A letter from ALCHEM to Non-Dis. Compliance conveys the annual report for WQ0016338. This letter states that they did not accumulate enough silica residual to land apply, just like the 2003 annual report. The writer recalls that ALCHEM stated that they plan to clean out a lagoon (or two) in the spring which is why the staff report asked for extra pH testing on excavated materials and an inspection of the lagoon liner. April 22, 2005 — A Notice of Regulatory Requirements for WQ0002702 was sent regarding the recently renewed permit. The MRO stated that they considered this permit enforceable as the adjudication period had passed without comment. June 8, 2005 — Central Office asks for additional information via registered letter, to be received by July 8, 2005. Additional information requested, included engineering documentation of the fill area and the berm. June 21, 2005 — A letter from DWQ MRO Supervisor regarding concern with the consistently low pH readings measured in the stormwater ditch adjacent to the railroad tracks by unloading station. July 8, 2005. — No additional information is received. August 2, 2005 - Email from David Goodrich regarding phone call from Mr. Nathan Cook of BOYLE Engineering, who has been retained by Randall Andrews (ALCHEM) to perform site evaluation of Red Rd. facility. ALCHEM file History Page 8 August 2, 2005 — Copy of Decision of Dismissal (dated July 29, 2005) is received by MRO via fax. August 4, 2005 — Inspection reflects poor conditions persist including; no freeboard in lagoons, burying construction debris in the fill area, low pH in recycle system water, and new water line places in fill area. August 15, 2005 — Mr. Andrews sends a letter to Shannon Thornburg, (Author of permit), asking for DWQ to relax the provision regarding pH in the spent bauxite lagoon water. August 24, 2005 — An email from Larry Ausley, DWQ Laboratory Section, emails results from an ad hoc experiment of 3 spent bauxite samples collected by Ellen Huffman from sand at the fill area August 23, 2005. See file for preservation and test method. Results were 3.7, 3.5, and 3.0, SUs respectively. September 20, 2005 — NOWNRE WQ0002702 was issued for the August inspection for permit WQ 0002702 renewed in December 2004, for permit conditions. A requested site life estimate for the fill area, and a long-range disposal plan were requested in the renewed permit. This NOWNRE was never assessed because the permit is still in the adjudication process. October 10, 2005 — A letter from ALCHEM stating that they are "sorry for the violations" and "we are committing the time and the money to correct any problems here" AND "our new permit remains under appeal". October 11, 2005 — A letter from Alchem contains a copy of the business card for Nathan Cooke, with BOYLE Consulting Engineering. The letter also states that James T. Hill, RLS, a surveying company in Salisbury is re -surveying the property at Red Rd. October 24, 2005 — ALCHEM receives the Geotechnical Exploration and Analyses report regarding the earthen berm built around the fill area. January 6, 2006 — NRE — for the renewed permit WQ0002702, was issued for the requested site life estimate for the fill area and a long-range disposal plan. This NOWNRE was never assessed because the permit was in the adjudication process. January 26, 2006 — Deficiencies are noted in initial Laboratory Certification Inspection for pH calibration. .P January 30, 2006 — A call to BOYLE Engineering confirms that ALCHEM has received the geotechnical report regarding the earthen berm and the fill area. The MRO requests a copy of this report from ALCHEM. March 1, 2006 — MRO receives the Boyle Engineering report. ALCHEM file History Page 9 November 16, 2006 — File note indicates that ALCHEM has hired DELTA Environmental for assistance with site issues. December 5, 2006 — An inspection reflects the same site conditions found in previous inspections, including low pH in all three lagoons, low pH in stormwater collected by the berm, and poor berm conditions as stated in earlier reports. December 20, 2006 — A NOWNRE was issued for permit (WQ0016338) conditions, pH issues, and apparent berm failure (water seeping). December 20, 2006 — A NOWNRE was issued for permit (WQ0002702) conditions, pH issues, groundwater, and freeboard. January 8, 2007 — A letter from Alchem regarding NOWNRE. Alchem states that they were unaware that the berm is seeping. Alchem also states "it is apparent that there is some very small amount of seepage under the retaining berm Alchem asks for a meeting between Alchem and MRO staff to discuss the issues. January 11, 2007 — Alchem responds to groundwater violations (WQ0002702 NOWNRE). January 16, 2007 — MRO emailed and faxed Randall Andrews regarding a date for the meeting originally scheduled for January 24, 2007 and now moved to January 31, 2007 at 10:30 AM, to accommodate Mr. Andrews schedule. January 19, 2007 — A certified letter from MRO responding to the January 8 letter from ALCHEM, reiterating conditions in the NOWNRE and the need for a alternative disposal plan for the residuals to be presented at the meeting scheduled for January 31, 2007, and a plan to correct current plant conditions. January 26, 2007 — A letter from Alchem, asking the MRO to consider allowing 500 tons of material to be moved and put into an area near the railroad (?). ALCHEM re -stated the desire to use the fill as structural fill for chemical mixing tanks. January 31, 2007 — Meeting held at MRO with Randall Andrews, ALCHEM. Mr. Andrews did not have an alternative disposal plan. Mr. Andrews said that he would have a plan by February 2, 2007. February 9, 2007 — A faxed letter from ALCHEM mentions disposal possibilities but no real plan. Asks again for permission to remove sand to fill area. February 14, 2007 — MRO letter to ALCHEM reminding ALCHEm that they are not to use the fill area. February 14, 2007 — A letter from ALCHEM stating that they have retained Delta Consultants to evaluate existing berm structure. Letter also states "current thoughts are to install a synthetic barrier..." February 19, 2007 — A letter from ALCHEM regarding NOV for permit WQ0002702. Note: the NOV was for groundwater violations. The letter did not offer any real solutions but again, requested permission to remove sand to the fill area that is permitted under WQ0016338. 10