WQ0002702_Regional Office Historical File Pre 2018 (15)

NQ0016388 Alchem
i
Subject: Re: WQ0016388 Alchem
Date: Fri, 22 Nov 2002 10:18:24 -0500
From: Ellen Huffman <[e-mail]>
Organization: NC DENR - Mooresville Regional Office
To: J R Joshi <[e-mail]>
CC: Peggy Finley <[e-mail]>
Hey JR,
Color me slow today. I pulled the permit ( and re -read it) to realize that this
was permitted to be used as structural fill - I have never seen another permit
like this. But anyway, I am still going to go for a site visit with Peggy (just
so I can see it for myself) but, I think that as long as they have gr.wtr.
issues pending and until they have some historical data on the new groundwater
wells (requested by groundwater) I would not grant a reduction in monitoring.
Maybe in another year.
Ellen
J R Joshi wrote:
> Thanks Ellen for the quick turn around. Based on your initial observations,
> would seem to me that maybe a site visit to the site may be appropriate some
> time soon? The contact person at Alchem is Ms. Phyllis Drye. Her phone
> number is 704-279-7908.
> Please let me know what you think.
> Ellen Huffman wrote:
> > Hello JR,
> > I pulled the file to find that ALCHEM has had some gr.wtr. issues
> > (aluminum for one). Peggy Finley has the scoop on the poop. I also have
> > reservations but, I was not here when this was permitted. Had I been
> > here, there would have been more land app. best management language in
> > it. I have never been to the facility but, Peggy tells me that they
> > dredge the material from teh permitted lagoons and just dump it (pile it
> > up in places) with no rhyme or reason and just leave it there.
> > Ellen
> > Ellen Huffman - [e-mail]
> > Environmental Specialist II
> > North Carolina Dept. of Environment & Natural Resources
> > Div. of Water Quality
> > 919 N. Main St.
> > Mooresville, NC 28115
> > Ph: 704.663.1699 Fax: [phone]
> J. R. Joshi
> North Carolina Division of Water Quality
> 1617 Mail Service Center
> Raleigh, NC 27699-1617 USA
> Phone: [phone] ext 363 Fax: [phone]
Ellen Huffman - [e-mail]
Environmental Specialist II
1 of 2 11/22/2002 10:18 AM
I

VQ0016388 Alchem
Subject: WQ0016388 Alchem
Date: Fri, 22 Nov 2002 09:15:23 -0500
From: Ellen Huffinan <[e-mail]>
Organization: NC DENR - Mooresville Regional Office
To: Jaya Joshi <Jaya. Joshi@ncmail. net>
Hello JR,
I pulled the file to find that ALCHEM has had some gr.wtr. issues
(aluminum for one). Peggy Finley has the scoop on the poop. I also have
reservations but, I was not here when this was permitted. Had I been
here, there would have been more land app. best management language in
it. I have never been to the facility but, Peggy tells me that they
dredge the material from teh permitted lagoons and just dump it (pile it
up in places) with no rhyme or reason and just leave it there.
Ellen
Ellen Huffman - [e-mail]
Environmental Specialist II
North Carolina Dept. of Environment & Natural Resources
Div. of Water Quality
919 N. Main St.
Mooresville, NC 28115
Ph: 704.663.1699 Fax: [phone]
Ellen Huffman <Ellen.HuffinanAncmail.net>
Environmental Specialist 11
NC DENR - Mooresville
Div. of Water Quality
l of 1 11/22/2002 9:19 AM

?.1/21/2002 14:35 919-715-6048
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. Klimek, P.E., Director
DWO NON DISCHARGE BR
-A LTW.
1 74 4
D E
Date
Division of Water Quality
Non -Discharge Branch/ Permits & Engineering
Location: 512 N Salisbury Street Suite 1219
Ralelgh, N.C. 27604
Mailing Address: 1617 Mail Service Center
Raleigh, N.C. 27699-1617
FAX: [phone]
FAX TO: �t� I FAX NUMBER /�//"
FROM: \­� ',,T6 SAI r
PHONE: cj - _73 - S-O P3 X-36 3
NO. OF PAGES INCLUDING THIS SHEET: Q
re 7�
PAGE 01
77.
V1 esc a
If you receive this fax by mistake call: Non -Discharge Branch @ 919 7313-5083, Ext. 556

rl/.21/2802 14:35 919-715-6048 DWQ NON DISCHARGE BR
ALC EM, INI
2042 BUIE PHILADELPRUS ROAD RED SPRINGS, N
910-843-2121 — FAX [phone] — EMAIL rfana sem
December 2, 2000
Mr. Kevin Barnett 9>
NC DIVISION OF WATER QUALITY
WATER QUALITY SECTION
Non -Discharge CoTpliance/Enforcement Unit -g
512 North Salisbury Street
9,h Floor
Raleigh, North Carolina 27626-0535
Dear Mr. Barnett:
Our permit number is WQ0016338. We would like to request that you allo,
company to start testing only once a year for the residual analysis in the yea
is in accordance with our permit. A copy of the affected page is enclosed.
hear from you.
Best regards,
ALCHEM, INC.
P'o
Randall Andrews,
President
Al
•
28377
our
2001. This
'lease let us
PAGE�-{ 02
o,3

1,1/21/2002 14:35 919-715-6048 DWO NON DISCHARGE BR PAGE 03
111. MQ1PU (JXLNU A1NU KLYVKI-IN i XhQUlKLMN'l'a ,
1. Any monitoring (including groundwater, surface water, residuals, soil, or plant tissue analyses)
deemed necessary by the'Division to insure protection of the environment will be established and
an acceptable sampling and reporting schedule shall be followed,`"`
2. Proper records shall be maintained by the .Permittee tracking all utilize iori activities. aThese
records shall include, but are not necessarily limited to the following information:
a. location of residuals utilization
b. volume of residuals utilized in tons
3. A residual analysis shall be conducted twice per year from the date of permi
issuance by the
Permittee. The results of all analysis shall be maintained on file by the Pern
ittee for a minimum
of five years. The residuals analysis shall include the following parameters:
Arsenic Nickel Magnesium
Cadmium Selenium Sodium
Chromium Zinc Manganese
Copper Barium p14
Lead Silver Phosphorus
Mercury Calcium Aluminum
�1' Msiduals have been moni[ored for two years at the above freguelicy
the Permittee may
e
ofthe euny of
submit a Division foicatonoereducio
monitoring for pollutant concentrations, but in no case shall the fre uenc
f monitoring a ass
than once per year.
4. A Toxicity Characteristics Leaching Procedure (TCLP) analysis all be, conducted by the
Permittee once every five years, with tie trst an utre �n 1999. The TCLP analysis shall
include the following parameters please note the.regulatory leve cn L in parentheses):
Arsenic (5,0)
Cadmium (1.0)
Chlorobenzene (100.0)
o-Cresol (200.0)
Cresol (200.0)
1,2-Dichloroethane (0.5)
Endrin (0.02)
Hexachlorobenzene (0.13)
Lead (5.0)
Methoxychlor (10.0)
Pentachlorophenol(100.0)
Silver (5.0)
Trichloroethylene (0.5)
2,4,5-TP (Silvex) (1,0)
Barium (100.0)
Benzene
Carbon tetrachloride (0.5)
Chlordar
Chloroform (6.0)
Chromiu
m-Cresol (200.0)
p-Cresol
2,4-D (10.0)
1,4-Dich
I,I-Dichloroethylene(0.7)
2,4-Dinii
Heptachlor (and its hydroxide) (0.008)
Hexachloro-1,3-butadiene (0.5)
Hexachlt
Lindane (0,4)
Mercury
Methyl ethyl ketone (200.0)
Nitroben
Pyridine (5.0)
Selenium
Teirachloroethylene (0J)
Toxaphei
2,4,5-Trichlorophenol (400.0)
2,4,6-Trii
Vinyl chloride (0.2)
5 Three copies of all require& monitoring and reporting requirements as specific
Ill 2, 111 3, and 1114 shall be submitted annually on or before March I of the
following address:
NC Division of Water Quality
Water Quality Section
Non -Discharge Compliance/Enforcement Unit
Post Office Box 29535
Raleigh, North Carolina 27626-0535
6 Noncompliance Notification:
0.5)
(0.03)
t (5.0)
200.0)
irobenzene (7.5)
)toluene (0.13)
(3.0)
0.2)
ene (2,0)
(1.0)
e (0.5)
hlorophenol(2,0)
I in conditions 111 I,
>Ilowing year to the
The Permittee shall report by telephone to the Mooresville Regional Offic , telephone number
[phone], as soon as possible, but in no case more than 24 hours or on t e next working day
following the occurrence or first knowledge of the occurrence of any of the fol owing:

..•:
r •..r -•■ ■•■�SPECIALIZED
ASSAYS, INC.
2960 Fosier Creighton Dr.
� n /� urr ■ro
1'L•�•' 'i Nashville, TN •:Phone [phone]
! `.c TPiI-IER I A I r•IC :3690
71111 hlr TFR
:)C.3 F•l. PINE R_;7rri: ET: :ATE r,
j At-CHEM, INC.
.:•3rnp 1 =r WAYraz.. DRYE
hrlcJ.g'e UKai aew1L Uu1tR
DWO NON DISCHARGE BR
wc%M1AL_1(-IF I C P„
PAGE 04
FZ 1E P 1C) FZ T
L-at) Number: 99 •A5
F3amP 1 c 10' I_AC-,UC;N
5ainpic, 'rypL. 1d uc1�.c•
Site IC•
Date
Collected:
,/99
Time
Collected.
7, c,Ci
Date
Receiverl.
F"
21111 i'
Time
ReCelved
9:
00
Report Auan
Lllfit Llnit factur
Pate 'riiie
R
al p.L M-ttiod Ifatal
�1',rtJ::UrI 152ti1 6 n /Ic
r J 9 Y. 9.T85 1 0�'31/99 7:37 (;. Jllls.ln 60100 1512
-7 sr-
i(U Na/kg 0.978 0.?76 1 Si3?/S9 i:i7 S.R'1i1,$)n 6010U M2
CdC1�1:1 12 667 r1g/{r,9 0,978 U.778 1 0: 31197 7: `7 1;,k i)i1,S:Jn 60:10C, L512
:-I rim i,.:, �S' }3V ng/I•.g U.F78 U.978 1 E.•'3'1,/99 7 it ;,h b11:5)n •'J010L' 1;1.2
167.515 q/ky 9.785 9.'85 1 8i31/99 7: 37 6.R b,ts�,n SU1UI 1512
10. 55y ng/Itg 0.978 U. 978 1 8/31/99 7: 37 6 3; bi rlsan 5010L( 1:'12
�1)ppe' g30p ND F11/kg 0.978 0.978 I 8;31/S9 7: `7 h R DinS,)n 601V L512
Lead rq 0 19.481 np:y 0.573 D. 1 bi i1/SS 7: 17 ;, f lil s )fi 601CG lil"c
9nk JU:1 79.7ii 1)g/kg 7.'785 Y.785 1 8/ 31/99 7' 37 9.r blr6•)n 6010V 1512
2.9 5 ngfb.g 0.978 0.978 7. 8131e99 7:'17 G.F Wi,$)ll G010L' 151?
•' `'J'� ' i 5 7 iVC' n /1r a
7 g 0. U, 7 U, 097 i 8:'26/Y9 9::59 l:.133b i lts )!t 7g71 916
3i•;{ E i tf L0 HU rar'kg D, 978 U.97U 1 V31-M 1; 37 9 h b i nsw, 601LID 1512
Hp 1;g/1,y 0.478 0.978 l V31/99 7::7 G.ft b;rs.-In 60IL111 L512
HD ng/fry 0.778 0.Mil 1 8/3i./99 1:37 G r b:r,5,ri 60'lUfr 11i11
:.ua1�I�1 lv9 02z ng/kg 9. 7U5 Y.73'; 1 8.91159 7' sl G. F4 b 1 r15-01; 6010(I 1512
:i n; � y®j 13G ngilig 9.78� Y.7� i 3. L':'3L/59 7: 37 G F I.-SJn 60LUC 1512
}EENE�fn CHE1115TRY PPIMMETC3,"K
3.8U Units 1 8f21/9Y 11:I10 J. I ro,=t 1045 83Li
P6asklsorus 15 P 16. 41 ng/ky 1.0 1.0 1 8, 2`/'/9 19:3C Clio 1,I�usu 365. Z 11 1131
L�
:1�Lim

11/21/2.002 1.4:35 919-715-6048 DWQ NON DISCHARGE BR
'1111, THE BEST LAD
17:2k3 7eutRncrrca Orlando
' TestAmerica
,■ a • r o N a l! o
March a, 2000
=L)BNT. TM IRRST LAB
1003 NORTH PLYE ST'R.6Sr
9DzT$ 7.
LUK9ZR2`0N, WC 2 B 3 513
A7-M • PAM ► ESTER
PAGE 05
202
esG odb P . 01./a2
order Number! 2367
P•rajecr Name. TBL-
031A
9aawlel IDI L.AC;o
K K.3
Lab Ntnb uar, 00-F.
8,02
Data collacZed; 02/2�/00
Title Collected: 07:0
Date liacelved, 02/:t /00
• . • •yam T.M.
Repo" OIL
Aryl Yte tpout t o Uhtte Lielt Fact or Once tlnw
"TEIAL.6-
AluYl nu.
4rYMlc
1/S00. u
w0/kp
Y.SOOD
1
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ICY
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S,000D
1
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Ki
[acml lan Q•s
�1.100 Ja
I®/kp
1.SD00
1
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U
Celclun
. O.Soo00 U
Ip/kp
0_50000
1
2/28/00
CA
Chrom;,n
f12.00
wwka
Lf.00o
1
Zraa/00
Kt
cupp�or D
�}
14.800 ac
ea/ko
o.y0D00
1
inaim
Ks
2.0200. 1
ae/ka
$.Cow
U?Y/Oq
ks
MM nealub 1
�6, 6A0
mg/kg
Y.DD00
�
I/m/00
CI
m°nw""'•'•
I
wwky
25. no
1
i/ZA/00
KSmer`iry
.SGDO
13000
2128100
U
Wickrl
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ap/YN
1
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0'400U
I�P?/ks
o.5u000
1
Z/20/DD
�
y
I'^c / ���
175.00
�a/k®
ts,oaD
1
alza/00
Ks
5.5300
W,G/ka
1.7DCK1
1
7JIA/60
K!
'6PWEAA1 r1AR.udr6A5- LI
L] 32
Pcrcank local pnofpflrD��
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K.W, vault, Client Warvlcea 1larug.r
[lfla-6ath A. Alen, a,A_ Ciffictr
Worth Caroi.in& A:crafffuclon INLO'be•; 6"317 YRONya ptlla7pa
4J 10 �;�r Ah1D£esaw Rdtu / U4) thlUt7, F'C 32R 12 /+074i51-2980 / PnI: 907.F1
1�IYe! wthod O.tch
60lo0 7a6Y
60109 Y46 7
60100 Y467
W1uD 7c67
60101 7c67
14109 7!67
WON 7i6)
60101 7467
60f011 7467
60106 7467
701 Y6ty
6010a 7[;7
60102 7067
6010a 7a67
601 oil 7" 7
6010" 1467
WAS rm9
7850

1,1/21/2002 14:35 919-715-6048 DWQ NON DISCHARGE BR PAGE 06
ATTN
TestAmerica
I n O 0 A 1 0 A• r E 0
,2000
THE.`'BEST LAB
,2003 NORTH PINE STREET
SUITE 2
LUMBERTON. NC 28358
PAM HESTER
Analyze
------------------------
Order Number: 5268
Project Name: TBL-1 643
Sample ID: LAG00 #3
Lab Number; 00-F1 646
Date Collected: 07/25 00
Time Collected: 08:00
Date Received: 07/28 Oo
LABORATORY REPORT
Report
Result 0 Units Limit
------ - ------ ......
01l
Factor
Date Time An lyst Method Batch
"METALS*
Aluminum
18740
J4
mg/kg
2,500
1
B/
4/00
14:50
KS
Arsenic
< 5.000
U
mg/kg
5.000
1
8/
4/00
14:50
KS
Barium
38.78
mg/kg
1.500
1'
8/
C/00
14:50
KS
Cadmium
< 0.5000
U
mg/kg
0.5000
1
8/
4/00
14:50
KS
calcium
115.0
mg/kg
25.00
1
8/
4/00
14:50
KS
Chromium
13.79
mg/kg
0.5000
1
8/
4/00
14:50
KS
Copper
< 5.000
U
mg/kg
5.000
1,
B/
4/00
14:50
KS
Lead
n1L0
12.22
mg/kg
5.000
1
8/
4/00
14:50
KS
Magnesium
i
50.60
mg/kg
25.00
1
8/
4/00
14:50
KS
Manganese
1.688
mg/kg
1,500
1
8/
4/00
14:50
KS
Mercury
< 0,01000
U
mg/kg
0.01000
1
8/
2/00
9:37
RD
Nickel
2.411
mg/kg
1.500
1
B/
4/00
14:50
KS
Selenium
< 5.000
U
mg/ke
5,000
1
8/
4100
14:50
KS
Silver
< 0.5000
U
mg/kg
0.5000
1
8/
4/00
14:50
KS
Sodium
157.0
mg/kg
25.00
1
B/
4/00
14:50
KS
®�
Zinc
'
9.815
mg/kg
1.500
1
B/
4/00
14:50
KS
'GENERAL PARAMETERSO
PH
��
3-4L
pH units
1
8/
1100
11:20
NF
Phosphate,
total as P�/
0.210
mg/kg
0.200
1
8/18/00
10:05
BJR
J4 qualifier Indicates the
matrix interfered
with the
ability
to make an
accurate
determinati
Approved By: Gt-
v,-�e
Mark Rusler, Director of Technical Services
K.R. Vault, Client Services Manager
Elizabeth A. Rich, O.A- officer
North Caroline Certificotion Number: ENV#327/DEHNR OU12708
6010E
60108
60105
6010B
60108
60108
60108
60108
6010E
60100
7L71A
6010E
60108
6010E
60108
6010E
9045C
7647
7647
7647
7647
761.7
7647
76C7
7647
7647
7647
7349
7647
7647
76C7
7647
7647
7333
8600
4310 EAsr ANDGRSoN ROAD / ORLANDO, FL 32812 / 407-851-2560 / FAX: [phone]

11/21/2-002 1.4:35 919-715-6048
ENVIRONMENTAL
SCIENCE CORP -
Ms. Pam Heacer
TBL Laboratory
2003 Norch Pine Street; Suite 2
LumberCon, NC 283SB
Date Received
Description
Sample ID
Collected By
Collection Date
Parameter
PH
Phosphorus,Total
Total Solids
Mercury
DWO NON DISCHARGE BR
REPORT OF ANALYSIS
PAGE 07
12065 Lebanan Rd.
Mc. Juliec, TN 31122
[phone]
1-800-767-5859
Pax [phone]
Tax I.D. 62-0814289
E8c. 1910
November 21, 2000
November 17, 2000 ESC Sample
Solid - Alchem, Inc. ESC Key
LAGOON 3
Site ID
Wayne Drye Project �!
11/13/00 08:00
Reault Det. Limit ilnirc Mori' -A
Aluminum
Arsenic
Barium
Cadmium
�
Calcium
Chromium
Copper
✓
1�00
Lead
✓
Magnesium
oY�
Manganeae
Nickel
Selenium
Silver
Sodium
Zinc
c
-7 S�
3.6
eu
9045C
0.71
0.025
mg/kg
365.2
75.
9,
2S40G
0.049
0,020
mg/kg
7471
10000
5.0
mg/kg
6010E
BDL
0-25
mg/kg
6010B
36.
0.10
mg/kg
60108
BDL
0.10
mg/kg
6010E
95.
5.0
mg/kg
6010B
5.5
0.10
mg/kg
6010E
1.2
0.50
mg/kg
6010B
8.9
0.25
mg/kg
6010B
27•
5.0
mg/kg
60108
0.61
0.50
mg/kg
6010B
BDL
0.50
mg/kg
601013
0.64
0.25
mg/kg
60106
BDL
0.10
N9/kg
601013
170
25.
mg/kg
60108
2.4
0.50
mg/kg
6010b
q : L29845-ol
TBLLAB-A.LCHEM
TBL-10842
Dace
11/17/00
11/21/00
11/18/00
11/21/00
11/2S/00
11/25/00
11/25/00
11/25/00
11/25/00
11/2S/00
11/25/00
11/25/00
11/25/00
11/25/00
11/25/00
11/2S/00
11/25/00
11/25/00
11/25/00
I
Dil.
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
BDL - Below Detection Limit Terrze Fu e, E C Rep esentative
Dec. Limit - Estimated Quantitation Llmit(EQL)
LaborA2LA - 1461-01, AZHA - 100789, AL - 40660atCA Certification Numbere:
KY 90010, KYUST - 0016, NC - ENV375,DW21704, ND232R-140,
Note. SC-018900497, EEB72006, VA -900109NC 12)301
The reported analytical results relate only to the sample aubmicted.
This report shall not be reproduced, except in full, without the written approval rom ESC.
Page 1 of 3

11/21/2002 14:35 919-715-6048
ENVIRONMENTAL
SCIENCE CORP.
Pam Hescer
TBL Laboratory
P.O. Box 589
Lumberton, NC 28359
Date Received
Description
Sample ID
Collected By
Collection Dace
Parameter
pH
Phosphorue,Tota
Total Solids
Mercury
Aluminum
Arsenic
Barium
Cadmium
Calcium
Chromium
Copper
Lead
Magnesium
Mangapese
Nickel
Selenium
Silver
Sodium
Zinc
October 10, 2001
11480 - Alchem, Inc.
LAGOON 3
Wayne Drye
10/04/01 09:45
DWQ NON DISCHARGE BR
REPORT OF ANALYSIS
October 22,
ESC Sample
ESC Key
Site ID
Project N
Result
Oat. Limit
Units
Metho
3.5
su
9045C
1
45.
0.42
mg/kg
365.2
79.0
%
2540G
0.038
0.020
mg/kg
7471
✓
10000
S.0
mg/kg
6010B
0.35
0.25
mg/kg
6010B
r
38.
0.10
mg/kg
6oloB
BDL
0.10
mg/kg
6010B
100
5.0
mg/kg
6010E
4.9
0.10
mg/kg
6010E
1.8
O.SO
mg/kg
6010B
%V
12.
0.25
mg/kg
6010B
28.
5.0
mg/kg
60108
�L
0.86
0.50
mg/kg
6010B
!�
BDL
O.SO
mg/kg
6010B
BDL
0.25
mg/kg
6010E
% 5DV
BDL
130
0.10
25.
m9/kg
6010B
mg/kg
60108
2.3
0.50
mg/kg
6010E
PAGE 08
12065 Lebanon Rd.
Mt. .Iuliec, TN 37122
[phone]
1-800-767-5859
Fax (615) 75B-5859
Tax I.D. 62-0814289
Est. 1970
2001
k : L56979-01
TBLLAB-ALCHEM
TBL-11480
e oil.
10/16/O1 1
10/18/O1 1
10/16/01 1
.10/15/01 1
10/21/01 1
10/21/01 1
10/21/01, 1
10/21/01 1
10/21/01 1
10/21/01 1
10/21/01 1
10/21/01 1
10/21/01 1
10/21/01 1
10/21/01 1
10/21/01 1
10/21/01 1
10/19/O1 1
10/21/01 1
BDL Below Detection Limit ierrie Fu ge, ESC Rreeencacive
Det. Limit - Estimated Quantitazion Limit(EQL)
Laboratory Certification Numbers;
A2LA - 1461-01, AIHA - 100789, AL - 40660, CA - I-2327, CT- PH-0197, FL - E87487, GA - 923, IN - C-TN-01
KY 90010, KYUST - 0016, NC - £Nv375,DW21704, ND - R-140, SC - 84004, TN - 2006, VA - 00109, WV - 233
Note:
The reported analytical results relate only to the sample submitted.
This report shall not be reproduced, except in full, without the written approval f_om ESC.
Page 1 of 3

11/21/2002 14:35 919-715-6048 DWO NON DISCHARGE BR
Atcachment A
List of Analyces Wich Qc Qualifiers
Sample 0 Analyre Qualifier
L56979-01 P$ T8
Calcium J9
Phcsphorus,Total J6
PAGE 09
Page 2 Of 3

1-1/21/2002 14:35 919-715-6048 DWO NON DISCHARGE BR
Attachment 8
Explanation of QC Qualifier Codes
PAGE 10
Qualifier Mean}ng
Ja The reported value failed to meet the established quality cc
for accuracy.
J6 The sample matrix interfered with the ability to make any ac
determination;.spike value is unacceptably low
TS (ESC) - Additional method/sample information: Sample(a) rec
holding time.
Qualifier Report Information
ESC recognizes and utilizes sample and result qualifiers as set forth by the EPA
Contract Laboratory Program. We firmly believe that information pertaining to
sample analysis should be made available to the ESC client. In addition to the
EPA qualifiers adopted by ESC, we have implemented ESC qualifiers to provide Mori
information pertaining to our analytical results. Each qualifier is designated
the qualifier explanation as either EPA or ESC.
Definitions:
Accuracy - The relationship of the observed value of a known sample to the true
value of a known sample. Represented by percent recovery and relevan
to samples such as: control samples, matrix spike recoveries, surroga
recoveries, etc.
Precision The agreement between a set of samples or between duplicate samples.
Relates to how close together the results are and is represented by
Relative Percent Differrence.
Surrogate - Organic compounds that are similar in chemical composition, extractlo ,
and chromotography to analyzes of interest. The surrogates are used o
determine the probable response of the group of analytes that are chem-
ically related to the surrogate compound. Surrogates are added to the
sample and carried through all stages of preparation and analyses.
TIC - Tentatively Identified Compound: Compounds detected in samples that are
not target compounds, internal standards, system monitoring compounds,
or surrogates.
1 criteria
e
ved beyond
Page 3 of 3

11/21/2002 14:35 919-715-6048
ENVIRONMENTAL
SCIENCE CORP.
Pam Hester
TBL Laboratory
P.O. Box 589
Lumberton, NC 28359
DWQ NON DISCHARGE BR
REPORT OF ANALYSIS
Date Received
January 23, 2002
Description
11697 - Alchem, Inc.
Sample ID
LAGOON 3
Collected By
Wayne Drye
Collection Date
01/21/02 08:00
PAGE 11
12065 Lcbanon Rd
Mc. Jullec. TN 37122
(615) 7$8-58S8
1-800-767-5859
Fax [phone]a59
Tax I.D. 62-0814289
BSc. 1970
January 30. 12002
ESC Sample L66052-01
ESC Key TBLLAB-ALCHEM
Site ID
Project 4 TBL-11697
Parameter Resulc Det. Limit Units Method
px
Phoephorus.Total
Total Solids
Mercury
Aluminum
.Arsenic
Barium
Cadmium
Calcium
Chromium
Copper
f30IV
Lead
Magnesium
Manganese
Nickel
Selenium
Silver
Sodium
zinc
BA�'z
3.2
su
9045C
43.
0.42
mg/kg
365.2
80.1
%
2540G
0.055
0.020
mg/kg
7471
13000
5.0
mg/kg
6010B
BDL
0.50
mg/kg
6010E
42,
0.2S
mg/kg
6010E
BDL
0.25
mg/kg
6010E
100
5.0
mg/kg
6010E
6.3
0.50
mg/kg
6010E
2.1
0.50
mg/kg
6010B
14.
0.2S
mg/kg
6010B
32.
5.0
mg/kg
60108
1.2
0.50
mg/kg
60108
BDL
0.50
mg/kg
6010E
BDL
0.50
mg/k9
6010B
SDL
0.25
mg/kg
60108
160
25.
mg/kg
6010a
3.3
0.50
rg/kg
60102
Dale Dil.
01/23/02 1
01/29/02 1
01/24/02 1
01/29/02 1
01/2S/02 1
01/25/02 1
01/25/02 1
01/25/02 1
01/25/02 1
01/25/02 1
01/25/02 1
01/25/02 1
01/25/02 1
01I25/02 1
01/25/02 1
01/25/02 1
01/25/02 1
01/25/02 1
01/25/02 1
BDL Below Detection Limit
rerrie eua e, ESu R73resentative
-
Dec. LIME - Estimated Quancicatlon Limit(EQL)
Laboratory Certification Numbers:
A2LA - 1461-01, AIRA - 100789. AL - 40660, CA - I-2327, CT- PH-0197, FL - E87487, A - 923, IN - C-TN-01
KY - 90010, KYUST - 0016, NC - ENV375.DW21704, ND - R-140, SC - 84004. TN - 2006, VA - 00109. WV - 233
Note:
The reported analytical results relate only to the sample submitted.
This report shall not be reproduced, except in full, without the written approval trom ESC.
Page 1 of 3

11/21/2002 14:35 919-715-6048 DWO NON DISCHARGE BR PAGE 12
Attachment A
Lxsc of Analytes with QC Qualifiers
Sample # Analyce Qualifier
L66052-01 PH T8
Page 2 of 3

11/21/2,002 1A:35 919-715-6048 DWQ NON DISCHARGE BR
PAGE 13
Attachment H
Explanation of QC Qualifier Codes
Qualifier Meaning
Te (ESC) - Additional mathod/sample 'information: Sample(a)
holding time.
Qualifier Report Infozmacion
ESC recognizes and utilizes sample and result qualifiers as sec forth by the EPA
Contract Laboratory Program. We firmly believe that information pertaining to
sample analysis should be made available to the ESC client. In addition co the
EPA qualifiers adopted by ESC, we have ,implemented ESC qualifiers to provide more
information pertaining to our analytical resulta. Each qualifier is designated
the qualifier explanation as either EPA or ESC.
Definitions:
Accuracy - The relationship of the observed value of a known Sample to the true
value of a known sample. Represented by percent recovery and relevan
co samples such as: control samples, matrix spike recoveries, surroga
recoveries, etc.
Precision - The agreement between a set of samples or between duplicate samples.
Relates to how close together the results are and is represented by
Relative Percenc Differrence.
Surrogate Organic compounds that are similar in chemical composition, extracti
and chromatography to analyzes of interest. The surrogates are used
determine the probable response of the group of analytes that are ch
ically related to the surrogate compound. Surrogates are added to t
sample and carried through all stages of preparation and analyses.
TIC - Tentatively Identified Compound: Compounds detected in samples that
not target compounds, internal standards, system monitoring compound
or surrogates.
ved beyond
Page 3 Of 3

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
AQUIFER PROTECTION SECTION
January 9, 2006
Memo To: David Goodrich
From: Ellen Huffman
Subject: Draft permit Alchem, Inc.
Permit No. WQ0016338
Mooresville Region
I have reviewed the draft WQ0016338 permit. I have just a few things that I would like to see added
or changed.
• The MRO would like to require the addition of 3 more monitoring wells to be located to
monitor groundwater around the newly named "fill" area.
• II-2, change "leached" to spent and add something like "from 3 spent bauxite lagoons". Clarify
what a -location of residuals utilization means. Add a pH requirement here (or somewhere in
the permit).
• II-3, specifically require this testing to be reported by a certain time at the issuance of the
permit.
II-4, can we add an aluminum number here?
• II-9, change "shall be utilized" to shall be disposed of.
• III-2 change "tracking all application activities" to tracking all monofill activities. Be specific
about documenting each lagoon cleanout, vol. Etc...
• III-2&3 refer these to all three lagoons 2x'a per year.
• III-4, typo. Change Cond. I.6 to Cond.II-2.
• III-5, specify information to include all three lagoons.
• Most importantly, the permit needs to require testing of the berm for structural credibility and
limit it's height to something like 15 ft. or whatever we can limit it to and to have the height
and credibility certified be an engineer.
Note: Do we want to add a request fro them to document that they can hold 24-hr/25year stormwater
volume in the unpermitted stormwater basin that is catching approximately a 5 acre area of run-off?
Please bold the annual report requirements in the permit and in the cover letter.
I am going to go back to the site Friday, January 13th and take Chet Whiting, Lab Cert., MRO, with me
to see if any other requirements may be needed, including test methods for the spent bauxite to monitor
if the bauxite has been washed enough to be land -filled and does not leach acid when wet. I will let
you know if the Lab folks advise us to add additional monitoring.
NorthCarol
Division of Water Quality ! Aquifer Protection Section / Mooresville Regional Office Phone: [phone] Fax: [phone] a,��d�t,Q/
610 East Center Street, Suite 301, Mooresville, NC 28115 Internet: http://gw.ehnr.state.nc.us f/ ► lj

AQUIFER PROTECTION REGIONALS *F PORT,'
Date:. _n1';OI�5I�4'
To: Aquifer Protection Central Office
Central Office Reviewer: David Goodrich
County: Rowan
Permittee: Mr. Randall Andrews
Project Name: Alchem, Inc.
Application No j4�g00�02f°z02WL,
---J
L GENERAL INFORMATION
1. This application is (check all that apply): ❑ New ® Renewal ❑ Renewal with mod.
❑ Minor Modification [] Major Modification
❑ Surface Irrigation ❑ Reuse ® Recycle ❑ High Rate Infiltration ❑ Evaporation/Infiltration Lagoon
❑ Land Application of Residuals ❑ Attachment B included ❑ 503 regulated ® 503 exempt
❑ Distribution of Residuals ® Surface Disposal
❑ Closed -loop Groundwater Remediation ❑ Other Injection Wells (including in situ remediation)
Was a site visit conducted in order to prepare this report? ® Yes or ❑ No.
a. Date of site visit: 10/21/2004
b. Person contacted and contact information: Wayne Drye 704/279-7908
c. Site visit conducted by: Ellen Huffman, Peggy Finley
d. Inspection Report Attached: ❑ Yes or ® No.
2. Is the following information entered into the BIMS record for this application correct?
❑ Yes or ® No. If no, please complete the following or indicate that it is correct on the current application.
For Treatment Facilities:
a. Location: 8135 Red Road, Rockwell. NC 28138
a. Driving Directions: From the intersection of Hwy 152 and Hwy 52 go north on Hwy 52 to Cornelius Road Go
west (left) on Cornelius Rd. to Red Road. Go north (right) on Red Road Facility will be on the right of Red
Road.
b. USGS Quadrangle Map name and number: E 17 SW
c. Latitude: 35033'52" Longitude:80°25'26"
d. Regulated Activities / Type of Wastes (e.g., subdivision, food processing, municipal wastewater):
Mining, chemical processing. The SIC code on file is 2819 It is unclear to the writer weather there needs to
be a stormwater permit required for this site
For Disposal and Iniection Sites:
a. Location(s): Same as above.
b. Driving Directions:
c. USGS Quadrangle Map name and number:
d. Latitude: Longitude:

AQUIFER PROTECTION REGIONAL STAFF REPORT
III. RENEWAL AND 14fODIFICATIONAPPLICATIONS (use previous section for new or major modification
s stems
Description Of Waste(S) And Facilities
1. Are there appropriately certified ORCs for the facilities? ❑ Yes or ❑ No. ® Not applicable
Operator in Charge: Certificate #:
Backup- Operator in Charge: Certificate #:
2. Is the design, maintenance and operation (e.g. adequate aeration, sludge wasting, sludge storage, effluent storage,
etc) of the treatment facilities adequate for the type of waste and disposal system? ❑ Yes or ® No. If no, please
explain: The facility was originally permitted by DENR Water Quality (WQ0002702 wastewater recycle) in 1990
only because it was discovered through a complaint from a neighbor concerning the neighbor's well The facility
was designed to process bauxite (a mixture of aluminum hydroxides) with sulfuric acid for production of
aluminum sulfate. The process creates a by-product of sand slurry left over from processing The sand is supposed
to be washed until the pH is elevated to a minimum of 4.0 and then pumped to drying lagoons The liquid from the
sand/sluny drying lagoons is returned to the processing water tank for reuse The sand/slurry is left in one of two
permitted lagoons to de -water. The two original lagoons were calculated to hold approximately 15 months of
residuals sand/slurry production. Information from the (Solid Waste Section) files indicates that the permittee
started producing the sand slurry sometime in 1985. The writer was informed by Wayne Drye Alchem Manager
(during the site visit 10/21/2004) that when the lagoons were full the residual sand was excavated by using a
backhoe. Back in 1985, it was hauled off site to be used by a fertilizer company as filler. The files also include
correspondence indicating that ALCHEM looked into landfilling the material as an alternate disposal option A
letter dated Aug. 6, 1984, from DEHNR Solid and Hazardous Waste Div informed the permittee that the residual
sand had to be adjusted a pH between 6.0 to 9.0 prior to landfilling It is not clear that ALCHEM ever hauled
material to the landfill. In 1993 the facility was permitted by DWQ to build three more lagoons for a total of five
To date, only three lagoons have been built the original lagoon and two more
Permit W00016338 (residuals reuse) was issued in 1999 to use the residual sand as structural fill on site There is
no pH limit in the permit issued in 1999. A landfill would require a pH adjustment of at least 6.0 prior to disposal
This residual sandy fill area failed in July 2003 when large amounts of the sandy fill (est volume unknown),
which is fairly light weight, were washed into the creek behind the facility by a rain event (see photos attached)
The material traveled for about 1 mile down stream; filling in the creek 12-18" thick in places and lowering the
stream pH from an average of 6.7 (upstream) to 3.8 and 4 7 effectively killing any stream life WQ0016338 was
issued an NOWNRE on August 19 2003 assessed $10 478 28 The fine was petitioned and reduced to $5 998 28
The facility has since built an earthen berm (8' deep by 8' wide at the bottom and 5' wide at the top) around the fill
material area to correct the problem as requested by MRO (in August 2003) and to keep the fill on site Drawing

AQUIFER PROTECTION REGIONAL STAFF REPORT
attached. Inspection of the berm on 10/21/2004 indicates that it is currently workingto o keep the residuals on site,
however, in places the fill is much higher than the berm and the topography of the site leads the writer to question
weather the berm is built high enough to keep the sandy fill in place. See photos attached. Review of the
sand/residuals analyses from 1999 2000 2001, 2002, all show pH of < 4.0. It is the opinion of the
writer that the material is not effectively washed (of the sulfuric acid) in the system before it stored in the
lagoon and ultimately used as on -site fill. Requested information from ALCHEM concerning stream pH
data leads the writer to believe there is a stormwater run-off issue. The data reflects a drop in pH after a
rain event. See data attached.
3. Are the site conditions (soils, topography, depth to water table, etc) maintained appropriately and adequately
assimilating the waste? ❑ Yes or ® No. If no, please explain: Inspection of this berm on 10/21/2004 indicates
that the berm is currently working to keep the residuals on site; however, in places the fill is much higher than the
berm and the topography of the site leads the writer to question weather the berm is built high enough to keep the
sandy fill in place See photos and copy of topographical survey map attached. The writer is concerned about the
area where the digester/reactors are located. It appears that there is always standing water at least 12' deep in a
ditch around the reactors. It also looks as if there is a lot of erosion around the cement pad that the digesters sit on.
This water is from washingthe spent bauxite sand that fell out of the overhead conveyors that take the spent
bauxite to the wash recycle system. This area drains to lagoon #1. This residual sand is basically never washed of
the residual sulfuric acid.
4. Has the site changed in any way that may affect permit (drainage added, new wells inside the compliance
boundary, new development, etc.)? If yes, please explain: The berm has changed the nature of non -discharge
permit WQQ016338 and should be reflected in the renewal currently in house. The fill disposal area is now
completely bermed and resembles an unlined surface disposal system Also noted was that the facility did not have
enough process water available from the on site water supply well and rain water. The facility recently piped in a 2
inch water supply line from the City (August 2004). This water line was placed RIGHT THROUGH THE FILL
AREA approximately 2 — 3 feet below the surface. The writer is concerned that the placement of this water line
and the use of heayyeq_uipment right over the line could possibly shift the material enough to crack, break a sealed
joint or rupture the water line A 2 '/z inch water line could deliver enough water to cause another residuals breach
if not caught in time This water line should be placed around the upper edge of the property effectively skirting
the residual fill area.
5. Is the residuals management plan for the facility adequate and/or acceptable to the Division?
❑ Yes or ® No. If no, please explain: The writer is concerned that the current fill area has a limited life and
appears to be 80% filled There is no long-range plan for the residuals once this area is filled to capacity. This
permit renewal should require a plan be submitted within 3 months of issuance of renewal.

AQUIFER PROTECTION REGIONAL STAFF REPORT
6. Are the existing application rates (hydraulic or nutrient) still acceptable? ❑ Yes or ❑ No. ® Not applicable
If no, please explain: There are no application rates. This facilijy now appears to be a permanent on -site storage
facility, a surface disposal system, or a surface landfill with no restrictions other than a disposal volume limit of
300 dry tons per year.
7. Is the existing groundwater monitoring program (number of wells, frequency of monitoring, monitoring
parameters, etc.) adequate? ❑ Yes ® No ❑ N/A. Attach map of existing monitoring well network if applicable.
Indicate the review and compliance boundaries. If No, explain and recommend any changes to the groundwater
monitoring program: Please see attached data and continents from Peggy Finley, MRO APS.
8. Will seasonal or other restrictions be required for added sites? ❑ Yes ❑ No ® N/A If yes, attach list of sites
with restrictions (Certification B?)
9. Are there any buffer conflicts (treatment facilities or disposal sites)? ❑ Yes or ® No. If yes, please attach a map
showing conflict areas or attach any new maps you have received from the applicant to be incorporated into the
permit:
10. Is the description of the facilities, type and/or volume of waste(s) as written in the existing permit correct? ❑ Yes
or ® No. If no, please explain: The residuals handling plan has changed since issuance of the permit. See
comments above in #2, #4, and #5.
11. Were monitoring wells properly constructed and located? ® Yes or ❑ No ❑ N/A. If no, please explain:
The APS may want to require more extensive groundwater monitoring of this site due to the history of and past
performance of this facility.
12. Has a review of all self -monitoring data been conducted (GW, NDMR, and NDAR as applicable)? ® Yes or ❑
No ❑ N/A. Please summarize any findings resulting from this review: There are concerns that the monitoring
well by lagoon 42 indicates that the lagoon liner may have been compromised_ perhaps during past cleaningof f the
sand fill (by a backhoe) from the lagoon The pH has dropped and the amount of aluminum has risen See data
attached.
13. Check all that apply: ❑ No compliance issues; ® Notice(s) of violation within the last permit cycle;
❑ Current enforcement action(s) ❑ Currently under SOC; ❑ Currently under JOC; ❑ Currently under
moratorium. If any items checked, please explain and attach any documents that may help clarify
answer/comments (such as NOV, NOD etc): Please note comments in #2.
14. Have all compliance dates/conditions in the existing permit, (SOC, JOC, etc.) been complied with? ❑ Yes
No ® Not Determined ❑ N/A.. If no, please explain: There is currently a third party lawsuit concerning the
events in August 2003) that has not been resolved. One of the complainants has refused to let ALCHEM finish
clean up of the affected stream on their property.
15. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
❑ Yes or 0 No ❑ N/A. If yes, please explain:

AQUIFER PROTECTION REGIONAL STAFF REPORT
V. EVALUATIONAND RECOMMENDATIONS
1. Provide any additional narrative regarding your review of the application:
Monitoring well violation 1/7/2001 for aluminum.
A trend of increasing aluminum concentrations is reflected in the data for monitoring well #2. See data attached.
A review of the Solid Waste files indicated that Alchem could take the sand to the landfill after the pH was
adjusted to 6.0 by mixing with lime. A similar pH adjustment of the residual fill should be required for permit
W00016338.
Concerns about the placement of a City supply water line through the fill area.
2. Attach Well Construction Data Sheet - if needed information is available. Attached.
3. Do you foresee any problems with issuance/renewal of this permit? ® Yes ❑ No. If yes, please explain briefly.
The writer questions the issuance of two permits for this system. Permit WQQ002702 regulates the recycle system
while permit WQ9016338 deals with the sand washed by the recycle system. The sand washed by the recycle
system should be incorporated into the recycle permit since it is a byproduct of the washlrec cy le system. A -review
of the non -discharge files reveals that this facility has had multiple problems over the years. Combiningthese
permits will make it easier to track their performance. There is now a berm that has been constructed around the
fill area. The writer questions the height of this berm. The rainwater is collected from the residual fill area storm -
water collection pond (inside the berm)and is pumped back to the recycleystem. It is not clear if a stormwater
permit needs to be applied for. The fill area has effectively become an unlined surface disposal landfill. This fact
should be reflected in the renewed permit and language should be added for maintenance of the berm.
4. List any items that you would like APS Central Office to obtain through an additional information request. Make
sure that you provide a reason for each item: None.
5. List specific Permit conditions that you recommend to be removed from the permit when issued. Make sure that
you provide a reason for each condition: None.
6. List specific special conditions or compliance schedules that you recommend be included in the permit when
issued. Make sure that you provide a reason for each special condition:
Within three months of issuance of permit renewal:
1. The recycle system should be required to keep the recycled water to a pH of not less than 6.0 as it leaves the
wash area and goes into the storage lagoon. This would effectively raise the pH of the residual sand slurry
stored in the lagoon until it is used as fill.
2. Submit a site life estimate for the fill area.
3. Submit a long-range plan for future residuals disposal.
4. Require monitoring of stream behind property — pH and other constituents?
5. During the next lagoon clean out, scheduled for the spring of 2005, a pH reading should be taken and
documented on every load removed and placed in the sand fill area.
6. After the next lagoon clean out, require inspection/testing of the clay liners by a certified engineer and require
repairs to be made as needed.

AQUIFER PROTECTION REGIONAL STAFF REPORT
7. The writer questions if groundwater monitoring is adequate (i.e. the number of monitoring wells, frequency of
sampling, and parameters).
1. Recommendation: ❑ Hold, pending receipt and review of additional information by regional office; ® Hold,
pending review of draft permit by regional office; ❑ Issue upon receipt of needed additional information; ❑
Issue; ❑ Deny. If deny, please state reasons:
It is recommended by MRO:
1- That the two separate permits issued for this facility be merged into one permit.
2- The permittee seek alternate disposal/re-use options for the fill produced at the facility.
3- After the next cleaning of lagoons one and two, scheduled for the spring of 2005, the clay liners be inspected
by a certified engineer. Any repairs need be made at that time.
4- That the City water supply line be moved to the upper perimeter of the.residual fill area.
2. Signature of report preparer(s): -
Signature of APS regional supervisor:
Date:
ADDITIONAL REGIONAL STAFF REVIEW ITEMS
None.
Attachments
Damage from the spill in August 2003.
I C) 1 2-6

AQUIFER PROTECTION REGIONAL STAFF REPORT
Damage from spill August 2003 Origin of runoff — August 2003
New berm around fill area -photo 10-2004 . Lagoon #2 to be cleaned in spring 2g 005-photo 10-2004
Berm in forground showing height of fill.Storm pond on left. Berm in background. Fill debris and stormwater pond.

ALCHEM, INC.
WO0002702
Rowan County
Groundwater Monitoring Data
Date
MW-1)
MW-2
Field
2/02
pH
lab
6.40
5.6
Al
.089
0.77
Field
5.7
5.3
7/02
pH
Lab
6.0
5.0
Al
.088
.137
Field
5.85
5.10
2/03
pH
Lab
7.06
5.62
AI
.034
.340
Field
5.8
5.6
7/03
pH
Lab
5.68
4.69
Al
.281
.178
Field
6.5
5.2
2/04
pH
Lab
6.08
4.99
Al
.062
.207
Field
6.0
5.2
8/04
pH
Lab
5.62
4.71
Al
.125
.596
These replacement wells were installed in January 2002.

Alchem, Inc.
Comments: Groundwater monitoring indicates a downward trend in pH and an upward
trend in aluminum for MW-2.
Recommendations:
Submit a scaled topographic map showing the facility, including
1. scale
2. north arrow
3. the location of the property boundary
4. the three lagoons
5. the two replacement monitoring wells (including a survey of the casing
elevations)
6. the fill area
7. the stormwater detention pond
8. the municipal water line
9. water supply wells within 500 feet

AQUIFER PROTECTION SECTION
APPLICATION REVIEW REQUEST
FORM
LU
Date: October 18, 2004
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To: ❑ Landon Davidson, ARO-APS
E] David May, WaRO-APS Lu� D
❑ Art Barnhardt, FRO-APS
❑ Charlie Stehman, WiRO- Lu �—
® Andrew Pitner, MRO-APS
❑ Sherri Knight, WSRO-APg Qa-' o
❑ Jay Zimmerman, RRO-APS
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From: David Goodrich, AFO Permitting and Compliance Unit
Telephone: [phone]
Fax: [phone]
E-Mail: [e-mail]
AW. Mr—flLII IFnmher� V+10� Od31t633
B. Owner: Alchem, Inc.
C. Facility/Operation: Alchem's Bauxite Residuals Reuse Program
❑ Proposed ® Existing
® Facility ® Operation
D. Application:
1. Permit Type: ❑
Animal
❑ Surface Irrigation ❑ Reuse
❑ H-R Infiltration
❑
Recycle
❑ FE Lagoon ❑ GW Remediation (ND)
❑
UIC - (5QW) closed loop water only geothermal
For Residuals:
®
Land App. ❑ D&M
❑ Surface Disposal
❑
503 ® 503 Exempt
❑ Animal
2. Project Type: ❑ New ❑
Major Mod. ❑ Minor Mod. ® Renewal
❑ Renewal w/ Mod.
E. Comments/Other Information: ❑ I would like to accompany you on a site visit.
Statutory Date is December 29, 2004
Attached, you will find all information submitted in support of the above -referenced application for your
review, comment, and/or action. Within 30 calendar days, please take the following actions:
® Return a Completed Form APSSRR.
❑ Attach Well Construction Data Sheet.
❑ Attach Attachment B for Certification by the LAPCU.
❑ Issue an Attachment B Certification from the RO*.
* Remember that you will be responsible for coordinating site visits, reviews, as well as additional
information requests with other RO-APS representatives in order to prepare a complete Attachment B for
certification. Refer to the RPP SOP for additional detail.
When you receive this request form, please write your name and dates in the spaces below, make a copy
of this sheet, and return it to the appropriate Central Office -Aquifer Protection Section contact person
listed above.
RO-APS Reviewer: IL Date: l U �� A
FORM: APSARR 09/04 Page 1 of 1
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10/12/04
Permit Number WQ0016338 Permit Tracking Slip
Program Category Status Project Type
Non -discharge In review Renewal
Permit Type Version Permit Classification
Distribution of Residual Solids (503 exempt) Individual
Primary Reviewer
david.goodrich
Permitted Flow
Facilit
Facility Name
Alchem Incorporated Residuals Reuse Program
Location Address
8135 Red Rd
Rockwell NC 28138
Owner
Owner Name
Alchem Incorporated
Dates/Events
Permit Contact Affiliation
Randall Andrews
8135 Red Rd
Rockwell NC 28138
Major/Minor Region
Minor Mooresville
County
Rowan
Facility Contact Affiliation
Owner Type
Non -Government
Owner Affiliation
Randall Andrews
8135 Red Rd
Rockwell NC 28138
Orig Issue App Received
03/01 /99 09/30/04
Regulated Activities
Scheduled
Draft Initiated Issuance
Public Notice Issue Effective Expiration
Requested/Received Events
Mining & material processing
RO staff report received
RO staff report requested
Additional information requested
Additional information received
Groundwater comments requested
Groundwater comments received
Outfall NULL
tJt� lenk 'f
/ -2/2 j7/0 y
Waterbody Name
Stream Index Number Current Class Subbasin

�OF w A rF9Q Michael F. Easley, Governor
�O G William G. Ross Jr., Secretary
r— North Carolina Department of Environment and Natural Resources
O C Alan W. Klimek, P.E. Director
Division of Water Quality
October 12, 2004
Randall F. Andrews
ALCHEM, Inc
8135 Red Road
Rockwell , NC 28138
Subject: Acknowledgement of Application No. WQ0016338
ALCHEM Inc Residuals Reuse Program
Distribution of Residual Solids
Rowan County
Dear Mr. Andrews:
NC DEPT. OF ENVIRONMENT
AND NATURAL RESOURCES
RECEIVED
O C i 15 2004
MOORESVILLE REGIONAL OFFICE
DWQ-GROUNmPvATER SECTION
The Aquifer Protection Section of the Division of Water Quality acknowledges receipt of your permit
application and supporting materials on September 30, 2004. This application package has been assigned
the number listed above and will be reviewed by David Goodrich
The reviewer will perform a detailed review and contact you with a request for additional information if
necessary. To ensure the maximum efficiency in processing permit applications, the Division requests
your assistance in providing a timely and complete response to any additional information requests.
Please be aware that the Division's Regional Office, copied below, must provide recommendations prior to
final action by the Division. Please also note at this time, processing permit applications can take as long
as 60 - 90 days after receipt of a complete application.
If you have any questions, please contact David Goodrich at 919-715-6162 or via e-mail at
[e-mail]. If the reviewer is unavailable, you may leave a message, and they will
respond promptly.
PLEASE REFER TO THE ABOVE APPLICATION NUMBER WHEN MAKING INQUIRIES ON THIS
PROJECT.
Sincerely,
00Y 2-Kim Colson, P.E.
Supervisor
cc: Mooresville Regional Office, Water Quality Section
Permit Application File WQ0016338
Aquifer Protection Section 1636 Mail Service Center Raleigh, NC 27699-1636 Phone [phone] Customer Service
Intemet: http://l12o.enr.state.ne.us 2728 Capital Boulevard Raleigh, NC 27604 Fax [phone]
Fax [phone]
An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10% Post Consumer Paper
No!r Karolina
,lVaiurally

Michael F. Easley, Governor
o�OF W ATFRQG
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Coleen H. Sullins, Deputy Director
Division of Water Quality
Randall Andrews
Alchem, Inc
8135 Red Road
Rockwell, NC 28138
September 28, 2004
Subject: Acknowledgement of Application No. WQ0002702
Alchem, Inc
Recycle System
Rowan County.
Dear Mr. Andrews:
The Non-Discharge'Permittirig Unit of the Division of Water Quality (Division) acknowledges receipt of
your permit application and supporting materials on September 23, 2004. This application package has
been assigned the number listed above and will be reviewed by David Goodrich.
The reviewer will perform a detailed review and contact you with a request for additional information if
necessary. To ensure the maximum efficiency in processing permit applications, the Division requests
your assistance in providing a timely and complete response to any additional information requests.
Please be aware that the Division's Regional Office, copied below, must provide recommendations prior to
final action by the Division. Please also note at this time, processing permit applications can take as long
as 60 - 90 days after receipt of a complete application.
If you have any questions, please contact David Goodrich at 919-715-6162 or via e-mail at
[e-mail]. If the reviewer is unavailable, you may leave a message, and they will
respond promptly.
PLEASE REFER TO THE ABOVE APPLICATION NUMBER WHEN MAKING INQUIRIES ON THIS
PROJECT.
Cols •
Supervisor
cc: Mooresville Regional Office, Water Quality Section
Wayne Drye
Plant Manager, ALCHEM, Inc.
8135 Red Road
Rockwell, NC 28138
c permit Application File _WQ0002702 .
Non -Discharge Permitting Unit Internet hftp://h2o.enr.state.nc.us/ndpu OEM
1636 Mail Service Center, Raleigh, NC 27699-1636 Telephone [phone] Fax [phone]
DENR Customer Service Center Telephone [phone]
An Eaual ODDortunity Action EmDIover 50% recvcled/10% Dost-consumer Daoer

` ALCHEM, INC
8135 RED ROAD
ROCKWELL, NC 28138
704-279-7908 fax [phone]
[e-mail]
September 21, 2004
c=
cn
NC DIVISION OF WATER QUALITY -rnv
NON -DISCHARGE PERMITTING UNIT
512 North Salisbury Street, Suite 1219,
RALEIGH, NC 27604=
0
RE: Permit #WQ0002702 ui
cn
Dear Sir:
I would like to submit our application for a permit renewal for Permit Number
WQ0002702. We understand there is not a fee for renewal.
If you have any questions regarding this permit renewal application, please let me know.
Best regards,
ALCHEM, INC
k()l'Q��
Randall F. Andrews,
President
pcd
Enclosures
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State of North Carolina
Department of Environment and Natural Resources
Division of Water Quality
WASTEWATER RECYCLE SYSTEMS
(THIS FORM MAY BE PHOTOCOPIED FOR USE AS AN ORIGINAL)
Application Number: (to be completed by DWQ)
I. GENERAL INFORMATION:
1. Project Name: ALCHEM, INC Renewal Permit #WQn002702
2. Applicant's name (Name of the owner of the facility. If a company or corporation it must be registered with
the Secretary of State): RANDALL F. ANDREWS
3. Name and complete mailing address of applicant: 8135 Red Road
City: Rockwell State: NC Zip: 28138
Telephone number: ( 704) 279-7908 Facsimile number: (704— ) 279-8418
Email Address: pdryeCalltel.net
4. Project name (name of the facility): ALCHEM, INC
5. Complete address of the physical location of the facility if different from mailing address of applicant:
City: same State: Zip:
6. County where project is located: Rowan
7. Name and complete address of engineering or consulting firm: n/a
City: State: Zip:
Telephone number: ( ) Facsimile number: ( )
8. Name and affiliation of contact person who can answer questions about project: Wayne Drye,
Plant Manager Email Address: wdryeCalltel.net
II. PERMIT INFORMATION:
1. Project is: new; modification; XXX renewal without modification
Note: Renewals without modifications should just fill out sections I & II; sign the applicants signature on Page 5.
2. Fee submitted: $ n/a (See Instruction C.)
3. If this application is being submitted as a result of a modification to an existing permit, provide:
existing permit number n/a and the issuance date
4. Applicant is: public, XX private
5. If project disturbs more than one acre, provide date when an erosion and sedimentation control plan was
submitted to the Division of Land Resources, or local delegated program, for approval:
n/a
6. If project includes any stream or wetland impacts, provide date when Nationwide 12 or 404 permit was
submitted for approval: n/a permit renewal
7. Provide buffers used to maintain compliance with any applicable river basin rules in 15A NCAC 213 .0200
(e.g., Neuse River basin buffer rules, etc.): n/a
FORM: RFA 0 1 -02 Page 3 of 5

Professional Engineer's Certification:
1, , attest that this application for
has been reviewed by me and is
accurate, complete and consistent with the information supplied in the engineering plans, calculations, and all other
supporting documentation to the best of my knowledge. I further attest that to the best of my knowledge the
proposed design has been prepared in accordance with this application and its instructions as well as all applicable
regulations and statutes. Although certain portions of this submittal package may have been developed by other
professionals, inclusion of these materials under my signature and seal signifies that I have reviewed this material
and have judged it to be consistent with the proposed design. Note: In accordance with NC General Statutes 143-
215.6A and 143-215.613, any person who knowingly makes any false statement, representation, or certification in any
application shall be guilty of a Class 2 misdemeanor which may include a fine not to exceed $10,000 as well as civil
penalties up to $25,000 per violation.
North Carolina Professional Engineer's seal, signature, and date:
Applicant's Certification:
I RANDALL F . ANDREWS , attest that this application for
renewal of
permit #WQ0002702 has been reviewed by me and is
accurate and complete to the best of my knowledge. I understand that any discharge of wastewater to surface waters
or the land will result in an immediate enforcement action which may include civil penalties, injunctive relief, and/or
criminal prosecution. I will make no claim against the Division of Water Quality should a condition of this permit be
violated. I also understand that if all required parts of this application are not completed and that if all required
supporting information and attachments are not included, this application package will be returned to me as
incomplete. Note: In accordance with NC General Statutes 143-215.6A and 143-215.613, any person who
knowingly makes any false statement, representation, or certification in any application shall be guilty of a Class 2
misdemeanor w ' h may include a fine not to exceed $10,000 as well as civil penalties up to $25,000 per violation.
Signature: Date: 9-21-04
FORM: RFA 01-02 Page 5 of 5

8fate• of North Carolina
'Oepartment of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
January 21, 1999
Mr. Randall F. Andrews
Alchem, Incorporated
8135 Red Road
Rockwell, NC 28138
4 •
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Subject: Permit No. WQ0002702
Alchem, Incorporated
Industrial Recycle-Bauxite_P_roee_s_s ___ _
Rowan County
Dcar Mr. Andrews:
In accordance with your application received October 23, 1998, we are forwarding herewith Permit No.
WQ0002702, dated January 21, 1999, to Alchem, Inc. for the continued operation of the three (3) lagoon recycle
s;-stem. As a separate issue, we are forwarding Permit No. WQ0016388 for the distribution of the recycle system
residuals.
This permit shall be effective from the date of issuance until December 31, 2004, shall void Permit No.
\V00002702 issued June 27, 1994, and shall be subject to the conditions and limitations as specified therein.
I'lense pay particular attention to the revised monitoring requirements in this permit.
If any parts, requirements, or limitations contained in this permit are unacceptable, you have the right to
request nn adjudicatory hearing upon written request within thirty (30) days following receipt of this permit. This
request mast be in the form of a written petition, conforming to Chapter 15013 of North Carolina General Statutes,
and filed wills the Office of Administrative Hearings, P.O. Drawer 27447, Raleigh, NC 27611-7447. Unless such
demands are made this permit shall be final and binding.
If you need additional information concerning this matter, please c tact Joe Pearce at [phone]
extension 544.
Si ce ,
A. reston Howard, Jr., P.E.
cc: Rowan County Health Department
Mooresville Regional Office, Groundwater Section
Groundwater Section, Central Office
Mooresville Regional Office, Water Quality Section
Teclinical Assistance and Certification Unit
Non -Discharge Compliance/Enforcement Unit
PO Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] Fax [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/10% post -consumer paper

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
RALEIGH
RECYCLE SYSTEM PERMIT
I n 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
Alchem, Inc.
Rowan County
FOR THE
continued operation of a wastewater recycle system consisting of 3 settling lagoons to serve Alchem, Inc., with no
discliar-c of wastes to the surface waters, pursuant to the application received October 23, 1998, and in conformity
witli the project plan, specifications, and other supporting data subsequently filed and approved by the Department
of f nvirortmcnt and Natural Resources and considered a part of this permit.
"lliis permit shall be effective from the date of issuance until December 31, 2004, shall void Permit No.
%VQ0002702 issued June 27, 1994, and shall be subject to the following specified conditions and limitations:
1. "I'Ilis permit shall become voidable unless the facilities are constructed in accordance with the conditions of
this permit, the approved plans and 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. 'I'llls permit is not transferable. In the event there is a desire for the facilities to change ownership, or there is
a iMrne change of the Permittee, a formal permit request must be submitted to the Division of Water Quality
( Division) accompanied by an application fee, documentation from the parties involved, and other supporting
imitcrials as may be appropriate. The approval of the request will be considered on its merits and may or may
not he approved.
5. In the event that the facilities fail to perform satisfactorily, including the creation of nuisance conditions, the
I'crimilce shall take immediate corrective action, including those actions that may be required by this
DiVIS1011, such as the construction of additional or replacement treatment or disposal facilities.
6. The t%,looresville Regional Office, telephone number [phone], shall be notified at least forty-eight (48)
Fours in advance of operation of the installed facilities so that an in -place inspection can be made. Such
notification to the regional supervisor shall be made during the normal office hours from 8:00 a.m. until 5:00
p.m. on i%1onday through Friday, excluding State Holidays.

7. The residuals generated from these treatment facilities must be disposed in accordance with General Statute
143-215.1 and in a manner approved by the,Division. (Z l � � v.i'✓f
8. 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.
9. The facilities shall be effectively maintained and operated as a iron -discharge system to prevent the discharge
of any wastewater resulting from,the operation of this facility.
10. Diversion or bypassing of untreated wastewater from the treatment facilities' is prohibited.
11. Freeboard in the all of the lagoons shall not be less than two feet at any time.
12. Any monitoring deemed necessary by the Division to insure surface and ground water protection will be
established and an acceptable sampling reporting schedule shall be followed.
13. Adequate inspection, maintenance, and cleaning shall be provided by the Permittee to insure proper operation
of the subject facilities.
14. 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 maintain 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 to the Division or other
permitting authority, upon request.
15. Any duly authorized officer, employee, or representative of the Division 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 maintained under the terms and conditions of this permit, and may obtain samples of
groundwater, surface water, or leachate.
16. 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 15A NCAC 2H .0205 (c)(4).
IT Failure to abide by the conditions and limitations contained in this permit may subject the Permittee to an
enforcement action by the Division in accordance with North Carolina General Statute 143-215.6A to 143-
215.6C.
18. 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.
19. A set of approved plans and specifications for the subject project must be retained by the Permittee for the
life of this project.
PA

20. Noncompliance Notification:
The Permittee shall report by telephone to the Mooresville Regional Office, telephone number (704)663-
1699, 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 flee facility, or any other unusual
circumstances;
Any process unit failure, due to known or unknown reasons, that renders 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; or
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 five (5)
days following first knowledge of the occurrence. This report must outline the actions taken orproposed to
be taken to ensure that the problem does not recur.
21. Upon classification of the facility by the Water Pollution Control Systems . Operators Certification
Commission (WPCSOCC), 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 WPCSOCC. The.Perniittee must also employ a certified back-up operator of the appropriate
type and grade to comply with the conditions of 15A NCAC 8A .0202. The ORC of the facility must visit
each Class I facility at least weekly and each Class II, III, 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 15A NCAC 8A .0202.
22. The recycle lagoons shall not be located within 100 feet of water supply wells.
23. Monitor wells MW-1 and MW-2, depicted on Attachment A, shall be sampled February and July for the
following parameters.
Water Level pH
Aluminum
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 ori the top of the casing.
The results of the sampling and analysis must be received on Form GW-59 (Groundwater Quality
Monitoring: Compliance Report Form) by the Groundwater Section, Permits and Compliance Unit, P.O. Box
29578 Raleigh, N.C. 27626-0578 on or before the last working day of the month following the sampling
month.
24. Any additional groundwater quality monitoring, as deemed necessary by the Division, shall be provided.

25. The COMPLIANCE BOUNDARY for the disposal system is specified by regulations in 15A NCAC 2L,
Groundwater Classifications and Standards. The Compliance Boundary is for the disposal system
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).
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 permittee.
26. 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 wenty-first day of January, 1999
NORTH C OL1NA EN O TAL MANAGEMENT COMMISSION
4.
�'. Preston Howard, Jr., P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission
Permit Number WQ0002702

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1
` AQUIFER PROTECTION REGIONAL;SCA E I PO rr____;`
t 10/2f04 — County: Rowan
- o: Aquifer Protection Central Office
Permittee: Mr. Randall Andrews
Central Office Reviewer: David Goodrich Project Name: Alchem,
Application No ' ? 0002702
aL00163SK—_ I-)
L GENERAL INFORMATION
1. This application is (check all that apply): ❑ New ® Renewal ❑ Renewal with mod.
❑ Minor Modification ❑ Major Modification
Surface Irrigation ❑ Reuse ® Recycle ❑ High Rate Infiltration ❑ Evaporation/Infiltration Lagoon
❑ Land Application of Residuals ❑ Attachment B included ❑ 503 regulated ® 503 exempt
❑ Distribution of Residuals ® Surface Disposal
❑ Closed -loop Groundwater Remediation ❑ Other Injection Wells (including in situ remediation)
Was a site visit conducted in order to prepare this report? ® Yes or ❑ No.
a. Date of site visit: 10/21/2004
b. Person contacted and contact information: Wayne Drye 704/279-7908
c. Site visit conducted by: Ellen Huffman, Peggy Finley
d. Inspection Report Attached: ❑ Yes or ® No.
2. Is the following information entered into the BIMS record for this application correct?
❑ Yes or ® No. If no, please complete the following or indicate that it is correct on the current application.
For Treatment Facilities:
a. Location: 81-35 Red Road, Rockwell NC 28138
a. Driving Directions: From the intersection of Hwy 152 and Hwy 52 go north on Hwy 52 to Cornelius Road Go
west (left) on Cornelius Rd. to Red Road Go north (right) on Red Road Facility will be on the right of Red
Road.
b. USGS Quadrangle Map name and number: E 17 SW — --
c. Latitude: 35033-52" Longitude:80°25'26"
d. Regulated Activities / Type of Wastes (e.g., subdivision, food processing, municipal wastewater):
Mining, chemical processing The SIC code on file is 2819 It is unclear to the writer weather there needs to
be a stormwater permit required for this site
For Disposal and Infection Sites:
a. Location(s): Same as above.
b. Driving Directions:
c. USGS Quadrangle Map name and number:
d. Latitude: Longitude:

AQUIFER PROTECTION REGIONAL STAFF REPORT
III. RENEWAL AND MODIFICA TIONAPPLICA TIONS (use previous section for new or major modification
systems)
Description Of Waste(S) And Facilities
L Are there appropriately certified ORCs for the facilities? ❑ Yes or ❑ No. ® Not applicable
Operator in Charge: Certificate #:
Backup- Operator in Charge: Certificate #:
2. Is the design, maintenance and operation (e.g. adequate aeration, sludge wasting, sludge storage, effluent storage,
etc) of the treatment facilities adequate for the type of waste and disposal system? ❑ Yes or ® No. If no, please
explain: The facility was originally permitted by DENR Water Quality (W00002702 wastewater recycle) in 1990
only because it was discovered through a complaint from a neighbor concerning the neighbor's well The facility
was designed to process bauxite (a mixture of aluminum hydroxides) with sulfuric acid for production of
aluminum_ sulfate. The process creates a by-product of sand slurry left over from processing The sand is supposed
to be washed until the pH is elevated to a minimum of 4.0 and then pumped to drying lagoons The liquid from the
sand/slurry drying lagoons is returned to the processing water tank for re -use The sand/slurry is left in one of two
permitted lagoons to de -water. The two original lagoons were calculated to hold approximately 15 months of
residuals sand/slurry production Information from the (Solid Waste Section) files indicates that the permittee
started producing the sand slurry sometime in 1985 The writer was informed by Wayne Drye Alchem Manager
(during the site visit 10/21/2004) that when the lagoons were full the residual sand was excavated by using a
backhoe. Back in 1985, it was hauled off site to be used by a fertilizer company as filler. The files also include
correspondence indicating that ALCHEM looked into landfilling the material as an alternate disposal option A
letter dated Aug. 6 1984 from DEHNR Solid and Hazardous Waste Div informed the permittee that the residual
sand had to be adjusted a pH between 6.0 to 9.0 prior to landfilling It is not clear that ALCHEM ever hauled
material to the landfill. In 1993 the facilijy was permitted by DWO to build three more lagoons for a total of five
To date, only three lagoons have been built the original lagoon and two more
Permit WQQQ16338 (residuals reuse) was issued in 1999 to use the residual sand as structural fill on site There is
no pH limit in the permit issued in 1999 A landfill would require a pH adjustment of at least 6.0 prior to disposal
This residual sandy fill area failed in July 2003 when large amounts of the sandy fill (est volume unknown),
which is fairly light weight were washed into the creek behind the facility by a rain event (see photos attached).
The material traveled for about 1 mile down stream filling in the creek 12-18" thick in places and lowering the
stream pH from an average of 6.7 (upstream) to 3.8 and 4 7 effectively killing any stream life W00016338 was
issued an NOWNRE on August 19 2003 assessed $10 478 28 The fine was petitioned and reduced to $5 998 28
The facility has since built an earthen berm (8' deep by 8' wide at the bottom and 5' wide at the top) around the fill
material area to correct the problem as requested by MRO (in August t 2003) and to keep the fill on site Drawing

AQUIFER PROTECTION REGIONAL STAFF REPORT
attached. Inspection of the berm on 10/21/2004 indicates that it is currently working to keep the residuals on site
however, in places, the fill is much higher than the berm and the topography of the site leads the writer to question
weather the berm is built high enough to keep the sandy fill in place See photos attached Review of the
sand/residuals analyses from 1999 2000 2001 2002 all show pH of < 4.0. It is the opinion of the
writer that the material is not effectively washed (of the sulfuric acid) in the system before it stored in the
lagoon and ultimately used as on -site fill. Requested information from ALCHEM concerning stream pH
data leads the writer to believe there is a stormwater run-off issue. The data reflects a drop in pH after a
rain event. See data attached.
3. Are the site conditions (soils, topography, depth to water table, etc) maintained appropriately and adequately
assimilating the waste? ❑ Yes or ® No. If no, please explain: Inspection of this berm on 10/21/2004 indicates
that the berm is currently workingto keep the residuals on site; however, in places, the fill is much higher than the
berm and the topography of the site leads the writer to question weather the berm is built high enough to keep the
sandy fill in place. See photos and copy of topographical survey map attached. The writer is concerned about the
area where the digester/reactors are located. It appears that there is always standing water at least 12' deep in a
ditch around the reactors. It also looks as if there is a lot of erosion around the cement pad that the digesters sit on
This water is from washing the spent bauxite sand that fell out of the overhead conveyors that take the spent
bauxite to the wash recycle system. This area drains to lagoon 41. This residual sand is basically never washed of
the residual sulfuric acid.
4. Has the site changed in any way that may affect permit (drainage added, new wells inside the compliance
boundary, new development, etc.)? If yes, please explain: The berm has changed the nature of non -discharge
permit W00016338 and should be reflected in the renewal currently in house The fill disposal area is now
completely bermed and resembles an unlined surface disposal system. Also noted was that the facility did not have
enough process water available from the on site water supply well and rain water. The facility recently piped in a 2
inch water supply line from the City (August 2004). This water line was placed RIGHT THROUGH THE FILL
AREA approximately 2 — 3 feet below the surface. The writer is concerned that the placement of this water line
and the use of heavy equipment right over the line could possibly shift the material enough to crack; break a sealed
joint, or rupture the water line. A 2 % inch water line could deliver enough water to cause another residuals breach
if not caught in time. This water line should be placed around the upper edge of the property effectively skirting
the residual fill area.
5. Is the residuals management plan for the facility adequate and/or acceptable to the Division?
❑ Yes or ® No. If no, please explain: The writer is concerned that the current fill area has a limited life and
appears to be 80% filled. There is no long-range plan for the residuals once this area is filled to capacity. This
permit renewal should require a plan be submitted within 3 months of issuance of renewal

AQUIFER PROTECTION REGIONAL STAFF REPORT
6. Are the existing application rates (hydraulic or nutrient) still acceptable? ❑ Yes or ❑ No. ® Not applicable
If no, please explain: There are no application rates. This facility now appears to be a permanent on -site storms
facility, a surface disposal system, or a surface landfill with no restrictions other than a disposal volume limit of
300 dry tons per year.
7. Is the existing groundwater monitoring program (number of wells, frequency of monitoring, monitoring
parameters, etc.) adequate? ❑ Yes ® No ❑ N/A. Attach map of existing monitoring well network if applicable.
Indicate the review and compliance boundaries. If No, explain and recommend any changes to the groundwater
monitoring program: Please see attached data and comments from Peggy Finley MRO APS
8. Will seasonal or other restrictions be required for added sites? ❑ Yes ❑ No ® N/A If yes, attach list of sites
with restrictions (Certification B?)
9. Are there any buffer conflicts (treatment facilities or disposal sites)? ❑ Yes or ® No. If yes, please attach a map
showing conflict areas or attach any new maps you have received from the applicant to be incorporated into the
permit:
10. Is the description of the facilities, type and/or volume of waste(s) as written in the existing permit correct? ❑ Yes
or ® No. If no, please explain: The residuals handling plan has changed since issuance of the permit See
comments above in #2 #4 and #5
11. Were monitoring wells properly constructed and located? ® Yes or ❑ No ❑ N/A. If no, please explain:
The APS may want to require more extensive groundwater monitoring of this site due to the history of and past
performance of this facility.
12. Has a review of all self -monitoring data been conducted (GW, NDMR, and NDAR as applicable)? ® Yes or ❑
No ❑ N/A. Please summarize any findings resulting from this review: There are concerns that the monitoring
well by lagoon #2 indicates that the lagoon liner may have been compromised erhaps during past cleaningof f the
sand fill (by a backhoe) from the lagoon The pH has dropped and the amount of aluminum has risen See data
attached.
13. Check all that apply: ❑ No compliance issues; ® Notice(s) of violation within the last permit cycle;
❑ Current enforcement action(s) ❑ Currently under SOC; ❑ Currently under JOC; ❑ Currently under
moratorium. If any items checked, please explain and attach any documents that may help clarify
answer/comments (such as NOV, NOD etc): Please note comments in #2.
14. Have all compliance dates/conditions in the existing permit, (SOC, JOC, etc.) been complied with? ❑ Yes
No ® Not Determined ❑ N/A.. If no, please explain: There is currently a third party lawsuit concerning the
events in August 2003) that has not been resolved One of the complainants has refused to let ALCHEM finish
clean up of the affected stream on their property.
15. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
❑ Yes or 0 No ❑ N/A. If yes, please explain:

AQUIFER PROTECTION REGIONAL STAFF REPORT
V. EVALUATIONAND RECOMMENDATIONS
1. Provide any additional narrative regarding your review of the application:
Monitoring; well violation 1/7/2001 for aluminum.
A trend of increasing aluminum concentrations is reflected in the data for monitoriM well #2. See data attached.
A review of the Solid Waste files indicated that Alchem could take the sand to the landfill after the pH was
adjusted to 6.0 by mixing with time. A similar pH adjustment of the residual fill should be required for permit
W00016338.
Concerns about the placement of a City supply water line through the fill area.
2. Attach Well Construction Data Sheet - if needed information is available. Attached.
3. Do you foresee any problems with issuance/renewal of this permit? ® Yes ❑ No. If yes, please explain briefly.
The writer questions the issuance of two permits for this system. Permit W00002702 regulates the recycle system
while permit WQQ016338 deals with the sand washed by the recycle system. The sand washed by the recce
system should be incorporated into the recycle permit since it is a byproduct of the wash/recycle system. A.review
of the non -discharge files reveals that this facility has had multiple problems over the years. Combiningthese
permits will make it easier to track their performance. There is now a berm that has been constructed around the
fill area The writer questions the height of this berm The rainwater is collected from the residual fill area storm -
water collection pond inside the berm) and is pumped back to the recycle system. It is not clear if a stormwater
permit needs to be applied for The fill area has effectively become an unlined surface disposal landfill. This fact
should be reflected in the renewed permit and language should be added for maintenance of the berm.
4. List any items that you would like APS Central Office to obtain through an additional information request. Make
sure that you provide a reason for each item: None.
5. List specific Permit conditions that you recommend to be removed from the permit when issued. Make sure that
you provide a reason for each condition: None.
6. List specific special conditions or compliance schedules that you recommend be included in the permit when
issued. Make sure that you provide a reason for each special condition:
Within three months of issuance of permit renewal:
1. The recycle system should be required to keep the recycled water to a pH of not less than 6.0 as it leaves the
wash area and goes into the storage lagoon. This would effectively raise the pH of the residual sand slurry
stored in the lagoon until it is used as fill.
2. Submit a site life estimate for the fill area.
3. Submit a long-range plan for future residuals disposal.
4. Require monitoring of stream behind property — pH and other constituents?
5. During the next lagoon clean out, scheduled for the spring of 2005, a pH reading should be taken and
documented on every load removed and placed in the sand fill area.
6. After the next lagoon clean out, require inspection/testing of the clay liners by a certified engineer and require
repairs to be made as needed.

. . ,
AQUIFER PROTECTION REGIONAL STAFF REPORT
7. The writer questions if groundwater monitoring is adequate (i.e. the number of monitoring wells, frequency of
sampling, and parameters).
1. Recommendation: ❑ Hold, pending receipt and review of additional information by regional office; ® Hold,
pending review of draft permit by regional office; ❑ Issue upon receipt of needed additional information; ❑
Issue; ❑ Deny. If deny, please state reasons:
It is recommended by MRO:
1- That the two separate permits issued for this facility be merged into one permit.
2- The permittee seek alternate disposal/re-use options for the fill produced at the facility.
3- After the next cleaning of lagoons one and two scheduled for the spring of 2005 the clay liners be inspected
by a certified engineer. Any repairs need be made at that time
4- That the City water supply line be moved to the upper perimeter of the residual fill area.
2. Signature of report preparer(s): L ,
Signature of APS regional supervisor:
Date:
ADDITIONAL REGIONAL STAFF REVIEW ITEMS
None.
Attachments
Damage from the spill in August 2003.
0
I D / ' b

AQUIFER PROTECTION REGIONAL STAFF REPORT
Damage from spill August 2003 Origin of runoff— August 2003
New berm around fill area -photo 10-2004 . Lagoon #2 to be cleaned in spring 2 005-photo 10-2004
Berm in forgound showing height of fill Storm pond on left. Berm in background. Fill debris and stormwater pond.

ALCHEM, INC.
W00002702
Rowan County
Groundwater Monitoring Data
Date
MW-1)
MW-2
Field
2/02
pH
lab
6.40
5.6
Al
.089
0.77
Field
5.7
5.3
7/02
pH
Lab
6.0
5.0
Al
.088
.137
Field
5.85
5.10
2/03
pH
Lab
7.06
5.62
AI
.034
.340
Field
5.8
5.6
7/03
pH
Lab
5.68
4.69
Al
.281
.178
Field
6.5
5.2
2/04
pH
Lab
6.08
4.99
Al
.062
.207
Field
6.0
5.2
8/04
pH
Lab
5.62
4.71
Al
.125
.596
These replacement wells were installed in January 2002.

. . . s
Alchem, Inc.
Comments: Groundwater monitoring indicates a downward trend in pH and an upward
trend in aluminum for MW-2.
Recommendations:
Submit a scaled topographic map showing the facility, including
1. scale
2. north arrow
3. the location of the property boundary
4. the three lagoons
5. the two replacement monitoring wells (including a survey of the casing
elevations)
6. the fill area
7. the stormwater detention pond
8. the municipal water line
9. water supply wells within 500 feet

Au
2003
ALCHEM SITE
this is not snow from
a freak snowstorm in
August.
run-off which triggered enf. act. by WQ.
August 2005
Oct.2004
berm in background. Now holding stormwater
for approx. 20 acres.
berm in background has grown significantly.

ALCHEM 08/04/05
Fill
Some erosion
control has been
put into place.
��A:. ._ -,� cam..•
w
I �
i
berm
Fill area looks higher than berm.

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Parcel 1D: 358 024
Owner:
ALCHEM INC
8135 RED RD
ROCKWELL NC 28138-0000
Rowan County GIS
Parcels
Property Address:
8135 RED RD
Legal Description:
32.69AC
Acreage: 32.69 acres
Deed Book: 597 Pg: 714
Deed Year: 2001
Other Attributes
at point 1576658, 664079
Date Sold:
Sale Inst.:
Sale Amt.: $0
Land FMV: $154,986
Assessed Land Value:$154,986
Building Value: $166,054
Total Assessed Value:$321,040
Jurisdiction: Soils: Townships:
None Soil ID: HeB Name: Gold Hill
Zoning (County):
District: Rockwell
DISCLAIMER: This information was prepared from the Rowan County, NC Geographic Information System. Rowan
County has made substantial efforts to ensure the accuracy of location and labeling information contained on this sit(
The information provided is a representation of various City and County data sources and does not serve as an offici.
map. Rowan County promotes and recommends the independent verification of any information contained on this sit
by the user.
Rowan County makes no warranty or other assertion as to the fitness of the maps for any particular purpose and
http://arcims2.webgis.net/nc/Rowan/printable.asp?process=id&x2=1576658.03448918&y2... 1 /6/2006

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tcOwan w, 1Nk, -- rMILUDie 1Viap
rage 1 Di
Parcel ID: 358 024
Owner:
ALCHEM INC
8135 RED RD
ROCKWELL NC 28138-0000
Rowan County GIS
Parcels
Property Address:
8135 RED RD
Legal Description:
32.69AC
Acreage: 32.69 acres
Deed Book: 597 Pg: 714
Deed Year: 2001
Date Sold:
Sale Inst.:
Sale Amt.: $0
Land FMV: $154,986
Assessed Land Value:$154,986
Building Value: $166,054
Total Assessed Value:$321,040
http://arciins2.webgis.net/nc/Rowan/printable.asp?process=idl &x2=1576688.0416875&y2... 1 /6/2006

c I - /
ov lv

ALCHEM SITE
August 2005

Rowan Co, NC -- Printable Map
.
Page 1 of 2
Parcel ID: 358 024
Owner: .
ALCHEM INC
8135 RED RD
ROCKWELL NC 28138-8557
Rowan County GIS
Parcels
Property Address:
8135 RED RD .
Legal Description:
32.69AC
Acreage: 32.69 acres
Deed Book: 597 Pg: 714
Deed Year: 2001
Date Sold:
Sale Inst.:
Sale Amt.: $0
Land FMV: $154,986
Assessed Land Value:$154,986
Building Value: $166,054
Total Assessed Value:$321,040
http://arcims2.webgis.netInelRowanlprintable.asp?process=idl &x2=1.576688.0525&y2=... 12/12/2006

Rowan Co, NC -- Printable Map
Page 2 of 2
DISCLAIMER: This information was prepared from the Rowan County, NC Geographic Information System. Rowar
County has made substantial efforts to ensure the accuracy of location and labeling information contained on this sit(
The information provided is a representation of various City and County data sources and does not serve as an offici,
map. Rowan County promotes and recommends the independent verification of any information contained on this sit
by the user.
Rowan County makes no warranty or other assertion as to the fitness of the maps for any particular purpose and
neither Rowan County nor it's agents or employees shall be liable for any claim alleged to have resulted from any us
thereof.
http://www.webgis.net Anderson & Associates, Inc. http://www.andassoc.com
http://arcims2.webgis.net/ne/Rowan/printable.asp?process=idl &x2=1576688.0525&y2=... 12/12/2006