WQ0008149_Regional Office Historical File Pre 2018 (3)

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Non -Discharge Branch Permitting
James B, Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
August 25, 1998
BARBARA E. RITCHIE
FM C CORP/LITHIUM DIV-KILN SCR
BOX 795
BESSEM`EIS CITY, NC 28016
low
Subject: PERMIT NO. WQ0008149
FMC CORP/LITHIUM DIV-KILN SCR
GASTON COUNTY
Dear Permittee:
Our files indicate that the subject permit issued on 1/17/95 expires on 5/31/99. We have not
received a request for renewal from you as of this date.
A renewal request shall consist of a letter asking for permit renewal, the appropriate permit
application processing fee, and four (4) copies of a completed application. For pernutted facilities with
treatment works, a narrative description of the residuals management plan, which is in effect at the
permitted facility, must also be submitted with the renewal application. Applications may be returned to
the applicant if not accompanied by the processing fee or are incomplete.
Please find attached a copy of the processing fee schedule, as found in 15 NCAC 2H .020 5 (c).
The processing fee for your facility is based on the type of facility and/or the permitted flow. Processing
fees for land application of residuals are based on the total acres of land permitted. The processing fee
does not apply to any fanner who submits an application which pertains to his/her farming operation.
The check or money order should be made payable to the North Carolina Department of Environment
and Natural Resources (DENR).
The Environmental Management Commission adopted rules on October 1, 1990, requiring the
payment of an annual fee for most permitted facilities. You will be billed separately for that fee if
applicable) after your permit is approved.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recydedf 10% post -consumer paper

Please be advised that this permit most not be allowed to expire. You must submit the renewal
request at bast 180 days prior to the permit's expiration date, as required by the 15 N A I .0211.
Renewal requests received less than 180 days prior to permit expiration will be required to pay the full
NEW APPLICATIONS/ MODIFICATION/ LATE RENEWALS fee rather than the reduced TIMELY
RENEWALS TROUT MODIFICATIONS fee. Failure to request a renewal at least 180 days prior
to the permit expiration dateand/or operation of a facility without a valid permit may result in the
assessment of evil penalties. NCGS 143-215.6 allows for the assessment of Civil penalties up to
$10,000 per violation per day.
e letter requesting renewal, along with the completed Non -discharge Permit Application and
the appropriate processing fee, must be sent to:
Pernifts andEngineering Unit
Division of Water Quality
Non -Discharge Branch Permitting
P. 0. Box 29535
Raleigh, North Carolina27626-0535
If you have any questions concerning this matter, please contact Ms. Thelma Williams a
g 1 / 7'33-5083 extension 574.
Sincerely,
Kim H. Colson, P.E., Supervisor
Non -Discharge Branch Permitting Unit
Mooresville, Regional,Office
Central Files

Jui
CERTIFIED MAIL
7
RETURN RECEIPT REQUESTED
July 14, 1998
North Carolina Department of Environment and Natural Resources
Division of Water Quality
P.O. Box 29535
Raleigh, NC 27626-0535
Arm- Ms. Colleen Sullins, Chief
Water Quality Section
-7
1908
JUL I
QUALM(
SECT10N
Dear Ms. Sullins:
Pursuant to the requirements of Non -Discharge Permit No, WQ0008149, FMC Corporation's
Lithium Division facility in, Bessemer City ("FMC") has operated a wastewater recycle system
consisting of t-,vo (2) parallel scrubbing towers, a scrubber surge tank, scrubber water processing
tattles and two (2) 1.1 acre kiln ponds. This wastewater recycle system was used to remove
solids collected scrubbing the decrepitation kiln dust exhaust in FMC's spodumene process.
in anticipation of the depletion of FMC's locally available spodumene ore source, FMC has built
a lithium processing facility in Argentina to develop a lithium resource in that country. FMC's
Argentine facility has been successfully started up and the spodumene mine was shutdown in
January. FMC now receives lithium carbonate and lithium chloride from the Argentine facility
for further processing and sale, rather than processing the are to produce these materials. On
approximately April 1, 1998, FMCled the last spodumene are to the decrepitation kiln and has
initiated decommissioning of the ore processing equipment.
With the shutdown of the decrepitation kiln, the associated wastewater recycle systent is no
longer operational. The two surface impoundments are being emptied and will he closed with
the adjacent solid waste landfill in accordance with the provisions of 15A NCAC 13B 0500 et
seq. Thus, Non -Discharge permit No. WQ0008149 should be canceled.
If you have any questions, or require additional information, please contact me at 704/868-0806.
Vel truly y rs,
Barb a hie
HSE/Re p sible Care Manager

State of North Carolina
Department of Environment
and Natural Resources
•
Division of ter Quality
4 Wa
James B. Hunt, Jr., Governor
N o",
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
NoRTH CAROLINA DF-PARTMENT OF
EwRONMENT AND NArURAL RESOURCES
September 28, 1998
BARBARA E. RITCHIF_
FMC CORP/LITHIUM D[V-KILN SCR
BOX 795
BESSEMER CITY NC 28016
3uriject- rescission or mate rerrint
Permit No. WQ0008149
FMC CORP/LITHIUM DIV-KILN SCR
GASTON County
Dear BARBARA E. RITCHIE,
Reference is made to your request for rescission of the subject State Permit. Staff of the
Mooresville Regional Office have confirmed that this Permit is no longer required. Therefore,
in accordance with your request, State Pertnit No. wq0008149 is rescinded, effective
immediately,
- If in the future you wish to again operate a nondischarge wastewater treatment sytem, you
must first apply for and receive a new State Perraft. Operating a wastewater facility without a
valid ,state -Pe pit will subject the responsible party to a civil penalty of up to $ 10,000 per day.
If it would be helpful to discuss this matter further, I would suggest that you contact Rex
Gleason - Water Quality Regional Supervisor, Mooresville Regional Office at [phone],
S incerely,
A, Preston Howard, Jr., P.E.
cc: GASTON County Health Department
Mooresville - Water Quality Regional Supervisor - w/attachmenu
Non Discharge Branch - Kim Colson
Operator Training and Certification
Non Discharge Compliance/Enforcerrient Unit- w/attachnients
Central Files-- w/attachinents
Fran McPherson, DWQ Budget Office
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] Fax [phone]
An Equal Opportunity Affirmative Action Employer 50 % recycled/I 0 % post -consumer pap r

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F FMB; Corporation
m..:i
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Box g
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
July 14, 1998
North Carolina Department of Environment and Natural resources ��` � � µ5 �1 A
Division of Water Quality e rl
P.O.o s 29535
Raleigh,, NC 27 2 -0 3
Attn: Ms. Colleen Sullins, Chief SECTION
Water Quality Section
l'tew FMC Corporation - Lithium Division - Bessemer City
Non�liscar e pd it Flo. tl�lil q - e it f"' cellation oast
Dear Ms. Sullins;
Pursuant to the requirements of Non -Discharge Permit No. WQ0008149, FMC Corporation's
Lithium Division facility in Bessemer City ("f ") has operated a wastewater recycle system
consisting of two 2) parallel scrubbing towers, ascrubber surge tank, scrubber water processing
tanks and two 2) t .1 acre kiln ponds. This wastewater recycle system was used to remove
solids collected scrubbing the decrepitation kiln dust exhaust in FMC's spodurnene process.
In anticipation of the depletion of FMC's locally available spodumene rare since, FMC has build
a lithium processing facility in Argentina to develop a lithium resource in that country. FMC's
's
Argentine facility has been successfully started up and the spodumene mine was shutdown in
January. FMC now receives lithium carbonate arid lithium chloride from the Argentine facility
for further processing and sale, rather than processing the ore to produce these materials, On
approximately April 1, 1998, FMC fed the last spodumene ore to the decrepitation kiln and has
initiated decommissioning of the ore processing equipment;
With the shutdown of the decrepitation kiln, the associated wastewater recycle system is no
longer operational. The two surface impoundments are being emptied d will be closed with
the adjacent solid waste landfill in accordance with the provisions of 1 A NCAC 1313 .0500 of
seq. Thus, Non -Discharge permit No. WQ0008149 should be canceled.
If you have any questions, or require additional information, please contact rite at 7 / g-0806,
'e truly y rs,
rbera a. ie/Ba
E/.esp sible Care Manager

Permit Respission Form
JrFacilityName VMC CORP/LITHIUMI I"V-KILN SCE
Permit Number qtI
NPDES Permit Type WQ Permit Type
Discharge:Code(s) 1098
Regional Office FP I
MEN '
County
Date Requested �` � Permit Expiration�" i
Original inal eq est Deceived by:
liance r xu I e io ai t. ffice l' E Unit
Request Recieved. in the Form cafe
10 ,Signed Annual Fee Invoice ice Letter 0 Other...
h rjtel
FOLS*,te V isit Performed Groundwater Monitoring Wells
jt
ro ]Ct Addressed (Should +e addressed unlessGroundwater
Monitoring is not required
eason for Denial
e of is Name
.t

RETURN RECEIPT REQUESTED
Mr, J. E. MeLtod, Plant manager
FMC Corporation/ Lithium Division
CERTIFIED MAIL
ost Office Box 795
Dear Mr.McLeod:
t
"S
h
' 19
Subject: Permit N.WQO(K)8149
FMC Corporation/ Lithium Division
Wastewater Recycle System
Gaston Count
objections expressed in your May 2, 1994 letter and the; Divisions position on those concerns are
discussed below:
M.
ActionAn Equal Opportunity Affirmwive

Page 2
Mr. McL&od
Permit No. WQ0008149
June 14, 1994
Objection I FMC requests that the description of the permitted system be modified to include,
"scrubber water processing tanks" as opposed to, "a scrubber makeup tank (water)"
as indicated in the November 29, 1993 and April 11, 1994 draft permit.
Response I The modification to the description is granted and reflected under the description
portion of this permit.
Objection I FMC believes that the issuance and expiration dates for this permit should be
revised to reflect the (future) date of resolution of FMC's petition for contested case
hearing.
Response 3: The issue date will be based on the date of resolution between FMC and the
Division, The expiration date of the permit will be five (5) years following
issuance.
Objection 4., The correct number of lagoons referenced on page 2, Itern 10 should now be two
(2) since the R&D pond has been removed from the permit.
Response 4-. This has been modified.
Objection 5: FMC has objection to the Groundwater Comments listed as items 20 thru 27 of the
April 11, 1994 draft permit.
Response 5: Based upon FMC's review of the Groundwater Comments faxed to FMC on May
17, 1994 and a response to those comments received May 24, 1994, the
Groundwater comments have been modified as agreed upon.
•

Page
r. McUod
Permit No. WQ0008149'
June 1, 199
1f y d need additional information concerning this utter, -please contact Ms. Angela Y. Griffin at
Sincerely,
m
re t �owaprd, Jr., P.E.
Q Mooresville Regions Office, Water Quality Section
Mooresville .e ion l Office, Groundwater Section
. Betsy Mosely, AttorneyGeneral's Office
Dave Goodrich, NPDES Group

NORTH CAROLINA
ENVIRONMENTAL MANAOEMINT COMMuSION
ARTMtNT 6V tNVIRONMENT1 HEALTH AND NATURAL kES0VRCES
RALEIGH
ktcy�(LE SYSTEM PERMIT
14t'
In accordance with the provisions of Article 21 of Chapter 143, General Statutes 0 1'
as amended, and other applicable Laws, Rules, and Regula*%% 1994
PERMISSION IS HEREBY GRANTED TO
FMC Corporation/ Lithium Division
Gaston County
FOR THE
1 11111211
MW appru VFT ly Lne LIFITarmw tit UY tmvlromuout, n rk'MUMON anu colmmmu 4 part 01
this pentit
This permit shall, void Permit No. WQQW�149 issued Noverriber 29,1993 antj �shall be, effective
from the date of issuanct tintil May 31, 19991 AW &hall be suh*t to; tfie following sp�� ebriditions
and litnitatious:
1

Y
lq

�ny pr the facility
of pum
c. Any failure of a pumping station, sewer line, or treatment facility resulting in a by-
pass directly to receiving waters without treament of all or arty portion of the
influent to sucii station or facHity. I
d Any time that self -monitoring information indicates that the facility is not in
compliance with its it limitations.
Persons reporting such occurrences by telephone shall also file a written report in letter
form within 15 days following first knowledge of the occurrence. This report must outline
the actions taken or proposed to be taken to ensure that the problem does not recur.
20. The following outline defines the events that will dictate the need for additional monitoring
wells.
(A) Within 90 days of permit issuance, RCRA Facility Investigation wells -1 and
DC-2 shall be sampled for the parameters listed in Condition 20 1 , achieving
detection limits as specified in 1. A NCAC 2L .02021bl: The results from this
sampling, a diagram showing construction details for each well, shall be
submitted to the Groundwater Section, Permits and Compliance Unit, P. 0. Box
29535, Raleigh, N.C. 27626-0535 within 30 days ofthe sampling,
f l If determined by the Division that no eatceedances of groundwater quality standards
are present in LAC -I or -2q then no further monitoring will be required under this
permit.
If any exceedances of the standards, specified in 1 A N AC 2L .0202 (g), are
detected as a result of groundwater sampling analyses in either DC-1 or LAC-2 glen
within 90 days of this detection, two (2) downgradient monitor wells -1 and
-2 shall be installed to monitor groundwater quality. The well(s) shall be
constructed such that the water level in the well is never above or below the
screened (open) portion of the well at any time during the year, The general
location and name for each well is marked on Attachment A. Each monitoring well
shall be constructed in accordance with this permit; and approved by the
Mooresville Regional Office.
21. Monitor wells -1 and + -2 shall be sampled initially after construction and thereafter
every April, August, and December for the following parameters:
Calcium Aluminum
TDS Sulfate
pH Water Level
Chloride Fluoride

Em
4.
Era

2 . Upon completion of all well construction activities, a certification must be received from a
professional engineer certifying that the monitoring wells are located and constructed in
accordance with the Well Construction Standards 1 A NCAC 2) and this permit. This
certification should be submitted with copies of the Well Completion Form (-1) for
each well, Mail certification and theassociated GW-I forms to the Permits and Compliance
Unit. Groundwater Section, P.0 Box 29535, Raleigh, h, N.C., 27626-0535w
r
28. Upon classification of the facility b the Certification Commission, the P rmittee shall
employ a certified wastewater treatment plant operator to be in responsible charge () of
the wastewater treatment facilities. The operator must hold a certificate of the type and
grade at least equivalent to or greater than the classification assigned to the wastewater
treatment facilities by the Certification Commission. The Pennittee must also employ a
certified back-up operator of the appropriate type and grade to comply with the conditions
f Title 15A, Chapter 8A, .0202. The ORC of the facility ,must visit each Class 1 facility at
least weekly and each Class 11,111, and lei facility at least daily, excluding weekends and
holidays, and must properly manage and document daily operation and maintenance of the
facility and must comply with all other conditions of Title 1 A, Chapter ., .02 2.
29. The permittee, at least sip: () months prior to the expiration of this permit, shall request it's
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 loth day of June, 1994
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
reston".nward, Jr , p,,, Director
Division of ironmenManagement
By Authority of the Environmental Management Commission
Permit No. WQ0008149
10

Stateof North Carolinarvtl I& �WA
Department of Environment,
r
P i
I"'lclth and Natural Resources
Division of Environmental Management 4 �►
James Hunt, Jr., Governor WK
py Jonathan B. Howes, Secretary mx..k
Am Freston Howard, Jr., P.., Director
. u
h � November 30, 1994 k
MS BCE. RITCHIE ,2ae w,l aeTli
BOX 79
ulaeett: Application No. WQ0008149
Kiln Scrubber
Recycle Facility
Gaston County
Dear MS RITCHIE:
The Division's Permits and Engineeringnit acknowledges receipt of your permit application and
supporting materials on November 29, 1994. This application has been assignedthe number listed
above. PLEASE REFER TO THE ABOVER QUALITY NUMBERWHEN NIAKING
INQUIRES ON THIS`.
Your project has been assigned to Michael Allen for a detailed engineering review, Should there be any
questions concerning project, the reviewer will contact you with an additional information letter,
Be aware that the Division's regional office, copied below, must providemeornmendations from the
Regional Supervisor or a Procedure Four Evaluation for this project, prig to final action by the
Division.
If you have questions, please contact "ehuel Allen at 919 733-5083.
Sincerely,
S C VCXI(A�sk(W��
u rvi r, Stag Engineering Review Group
Mooresville Regional Office
Pollution Prevention Pays
P.O. Box 29535, Raleigh, North Carolina 76 6-05 5 Telephone 1 -7 -7 1
An Equal Opportunity Affirmative Action Employer

M
FMC Corporation
161
Bc__�x 9
Ti
04 6 530 Fax [phone]
'pia Fedaa1�
November 28, 1994
State of North n Carolina
in
Department of Environmental Management
Water Quality Section
P.O. Box 29535
Raleigh, NC 27626-0535
Attn: Ms. Colleen Sullins, Supervise
Permits and Engineering
FMC Corporation - Lithium Division.
Bessemer City .. Non -Discharge Permit No. WQ0008149
Permit Modification Application
Dear Ms. Sullins®
• a► •
!"*: �� �� � �:• � w � .,.mow

Ms. Colleen Sul -ling
Non -Discharge permit No. WQ0008149
November 2, 14 - Page
"The results of 2, however, show eoedendes of the
.22(g) standards for only three parameters: phi, manganese
and iron...FMC thus believes that the pia observed in well
-2 is reflective of background condition, and that the
manganese and iron values may likely also reflect background
conditions. Thus,- requests that DEM approve the
following course of action which FMC, proposes with respect
to well. -2 and the eastern kiln scrubber recycle pond:
FMC proposes to arrange to have upgradient well W-
sampled within the next thirty days (by November l and
analyzed for pH, Iron and Manganese with the methodology
required under permit No. WQ0008149. These results will
be submitted to DEM within 30 days of sampling, b
December lath. if the levels of iron and manganese
observed in well W-7 approximate those observed in well
DC-2, then FMC would not be required to install an
additional well dow,gradient of the eastern kiln scrubber
recycle pond."
FMC has sampled upgradient well W-7 and is here providing a copy
of the laboratory report. The following table summarizes the
September 1994 DC-1 and -2 monitoring results for permit no
WQ0008149 parameters and the November 1994 sampling of i-7, where
a standard has been promulgated at 15A NCAC .0202., all values are
shown in mg "l, except pH:
-1 D-2 - " 2 Ltd
5 2300 ND Soo
phi 4.9 . 2 4.3 . 5 -- . 5
Chloride 280 2.7 25
Sulfate 1200 4.4 25
Fluoride 1 -ND 2
Chromium 0.0925 0.0106 0.05 (2
Iron 72.1 5.6 2.5 0.
Manganese 53.7 0.650 0.0480.05
(1) Standard from 1A 21" .0202(g) for "" class groundwaters
(2;) National Primary Drinking water Standard has been changed
from 0.05 mg/1 to 0.10 ( see 40 CFR Part 141)

s. Colleen Sullins
Non -Discharge permit No. WQ0 0 14
November 28, 1994 - Page
FMC believes that while the values observed for pH, iron, and
manganese .in well DC-2 do not duplicate those in -, they may
generally approximate background : conditions and further
assessment is difficultbased on the existence of only one data
point. Moreover, as FMC1s kiln scrubber water contains
fluorides, and as no fluorides were detected in , FMC
believes that these data do not support additional investigation
of the eastern kiln pond pursuant to the non -discharge permit.
FMC has contacted Mr. Brian Wagner, DEM Groundwater Section, b
telephone and discussed these results and FMC's evaluation.
It was agreed that. FMC would request a modification of
non -discharge permit No. WQ0008149 t0 eliminate the requirement
to install another well downgradient of the eastern kiln pond
and, rather, better characterize existing conditions b
continuing to monitor wells DC—DC-2 and W-7 for at Nast: one year.
Additionally, Mr. Wagner informed FMC of BM''s new computer
system to track groundwater monitoring results and the
limitations on well identification numbers inherent in the
programming.
Thus AMC is reqjulestinq that DEM modify non-dischar e permit No.
000 1 9 to reflect the followin c andif i ons .
Item 0 should be modified to state
"Within 90 days of the initial sampling of wells -1 and -,
downgradient monitor well. ( - shall be constructed to such °that
the water level in the well is never above or below the screened
(open) portion of the well at any time during the year. The
general location and name for the well i maned on attachment A.
Each monitoring well shall be constructed in accordance with this
permit:, and approved by the Mooresville Regional Office.
Item 21 should be modified to state:
"Monitor wells -1 , and W-7 shall be identified for
purposes of this permit as "WQ-1", 11 - AKA DC-2", and " AKA
'.. Monitor uwell. -1 shall be sampled initially after
construction. monitor well -1, and WQ-3 shall be sampled
every April., august', and December for the following parameters,
R

a
Colleen Sullins
Non -Discharge permi.t No. WQ0008149
November 28, 1 Page
The map included as 'Attachment A has been revised an is attached.
FMC has included the permit modification processing fee of
$400.00, a check is enclosed.
Lastly, FMC requests that this permit modification b < processed
as soon as possible but no later than January . 1995, the date
when the current permit would appear to require installation o
two downgradient monitor wells
Thank you for your prompt attention to and cooperation in this
smatter. if you have any questions, or require additional
information, please contact me at 704/868-0806.
y truly yours,
Barbara B itohi�e
nvironm Vnntal manager
cc.* Mr. Brian Wagner
DEHNR Groundwater Section
512 north Salisbury Street
Raleigh, NC 27604

NOV 18 "94 03:27PM RLST E&I HBG PA P.1
Post -It and tax transmft MOMO MrM of
.........
November 18,1994
Ms. Barbara Ritchie, Environmental Manager
FMC Corporation - Lithium Division
Highway 161
P.O. Box 795
Bessemer City, NC 28016
Re: Water Quality Permit N,o.W 8149
Analytical Rasults, - Monitorrell W-?
Dear Barbara:
At h d a ui� m the recent siiamp�fiing of (background) monitor well W-
s . # Id
�ncludcd a 1 log sheet s� g 0 par L 6, and the Chain of Custody (COC)
acccmp ia the water MpIc ch 'teed
�e '� tb� 's, w 1 were
r c d ed b submitted to IEA laboratory for analysis.
Please note that when 1 had arranged for IEA to ship bottles to the site, I had inforared Ms. Becky
Toisman that the iron and manganese sample wasto be analyzed using Method 3030C (as specified
in the water quality permit), She recorded this request in their computer system and indicated that
th,s is
- weld be a:lyzed ngly upon receipt. She had also asked that out field
w
h COC Jus
on t additional reminder. This was not indicated on the COC
-1 note rsoonp
at was subnuu�, and I r =tly that LEA analyzed the sarriplu one day beyond the three-
day retention time.
I compared the results of well W-7 with data from wells DC- I and DC-2 as well as historical data
for iron and manganese. However, there are few historical data available for a reasonable
comparison except for results of kila pond water analyses. These data were presented in our RE
Work Plan. I discussed the results of well and kUn pond water analyses with one of our chamists,
Mr. Tim Fahrenkopf, and it was his opinion that the results of the W-7 sample would not be
significantly difforint were the sample analyzed within the three-day retention dme, Therefore, It
appears that thic Mn concentration in well W-7 is below the 21, Standard of 0.05 mg/l, one order of
magnitude less than well DC-2 and three orders of magnitude less than DC-1.
If you have any questions or need additional information please contact Gerry Ahnell or me.
Sincerely,
Jeffrey J. Painter, P.G.
Project Hydrogeologist

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State of North Carolina
Department of Environment,
Health nfor l Resources 4 PA
nag
Diviio of nvironmental aa e t
JamesHunt, Jr., Governor
Jonathan B. Howes" Secretary
A Preston Howard, Jr., P.., Director
June 14, 199
CERTIFIED IL
RETURN RECEIPT REQUESTED
Mr. J. E. McLeod, Plant Manager
FMC Corporation/ Lithium Division
Post Office Box 795
Bessemer City, North Carolina 28016
Subject. Permit No. WQ0008149
FMC Corporation/ Lithium Division
Wastewater Recycle System
Gaston County
Dear Mr. McLeod. -
In accordance with your comments dated May 2, 1994 in reference to the April 11, 1994 draft
permit we are forwarding herewith Permit No.`WQ0008149, to FMC Corporation] Lithium Division.
objections expressed in your May 2, 1994 letter and the Divisions position on those concerns are
discussed below"
Objection 1; FMC seeks further clarification of the key to "'waste" as it pertains to it's
operation to better allow for continued compliance with applicable laws and
regulations.
Response 1. The North Carolina General Statute siting which specifies that air pollution control
systems are regulated and permitted under 15A NA is found in
sections 1-.I fall which define activities for which a permit is required.
This citing states that if a person constructs or operates- any sewer system,
"treatment works", or disposal system within the state a permit is required.
Furthermore, 14 - 1 17 defines a "treatment works" as any plant:, septic
disposal field, lagoon, pumping in station construction drainage ditch or surface
- p
water intercepting ditch, incinerator, area devoted to sanitary landfill, or other"
works not specifically; mentioned herein, installed for the purpose of treating,
equalizing; neutralizing, stabilizing or disposing of ""waste". Whereas, 14 -
1 (8b) defines ""Industrial waste" as any liquid, solid, gaseous, or other
waste substance or a combination thereof resulting from any processon industry,
manufacture, trade or business, or from the development of any natural source.
Based on the interpretation of these Statues, it has been determined that the
"waste" from this operation is the liquid stream being treated by settling out of
solids and recycled back into the process 'Therefore, FMC Corporation's kiln
scrubber operation d meet the criteria of a treatment work generating a waste,
therefore, requiring a permit under North Carolina General Statute.
P.O. Box 29535, Raleigh, Portia Carolina 27626-0535 Telephone t -7 -7 5FAX[phone]
AnEqual Opportun4 Aff irmative action Employer 0% recycled/ t 0% post -consumer paper

Page
r. McLeod
Permit No. WQ0008149
June 14, 1994
Objection 2
requests that the description of the permitted system be modified to include,
scrubber water processing opposed to, "a scrubber makeup tank (water)"
as indicated in the November 2, 1993 and April 11, 1994 draft permit.
Response 2:
The modification to the description is granted and reflected under the description
portion of this permit -
Objection :
FMC believes that the issuance and expiration dues for this permit should be
revised to reflect the (future) date of resolution of FMCs petition for contested case
hearing.
Response,
e issue date will be based on the date of resolution between FMC and the
Division. The expiration date of the permit will be five () years following
issuance.
Objection 4:
The correct number of lagoons referenced on pale 2, Item 10 should now be two
(2) since the R&D pond has been removed from the permit
Response 4:
is has been modified.
Objection :,
FMC has objection to the Groundwater Comments listed items 20 thru 27 of the
April 11, 1994 4 draft permit.
Response :
Based upon FMCs review of the Groundwater Comments faxed to FINK on May
17, 1994 and a response to those comments received May 24, 1994, the
Groundwater comments have been modified as agreed upon.
Objection 6:
FMC requests that it be notified of the classification of the facilityby the
Certification Commission and be granted a sufficient time period to locate, a certified
wastewater 'treatment operator.
Response t
All issues specific
accordingly and a draft pi
Division, and on June t, 111
permit was acceptable. Th
This permit shall
No. WQ0008149 issued 1
specified therein. Please p
this permit Failure to esta
information will result in f
MEM

Page
Mr. McLeod
Permit No. WQ0008149
June 14,1994
If yotfneed additional information concerning this matter, please contact Ms. Angela Y. Griffin t
1/ 33_03a
Sincerely,
rstn ard, Jr., P.E.
Mooresville iOffice, Water Quality Section
Mooresville regional Office, Groundwater Section
Ms. Betsy Mosel r, Attorney General's Office
Dave Goodrich, NPDES Group

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

swu vvatet� or
go
W.
17.
In
]IIIIII llllllljpq,llIlI�l!lllll 111111

19. Noncompliance Notification:
e Pertnittee shall report by telephone to the Mooresville Regional Office, telephone
number (7(4) 66 -16 , as soon as possible, but in no case more than 24 hours or on the
nest working day following the occurrence or first knowledge of the occurrence of any of
e following:
a y 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 ; the known passage of a slug of
hazardous substance through the facility; or any anther unusual circumstances.
b y process unit failure, due to known or unknown reasons, that render the facility
incapable of adequate wastewater treatment such as mechanical or electrical failures
of pumps, aerators, compressors, etc'
cn Any failure of a pumping station surer line, or treatment facilt res tin in a -
pass directly to receiving waters without treatment of all or any portion of the
influent to such station or facility,
d. Any, time that self -monitoring information indicates that the facility is not in
compliance with its permit limitations.
Persons reporting such occurrences by telephone: shall also file a written report in letter
form within 15 days following first knowledge of the occurrence. This report must outline
the actions taken or proposed to be taken to ensure that the problem does not recur.
0. The following outline defines the events that will dictate the need for additional monitoring
wells:
( Within 90 days of permit issuance, RCRA Facility Investigation wells -1 and
shall sampled for the parameters listed. in Condition 20 ((1, achieving
detection limits as specified in 15A NCAC 2L .0202(b). The results from this
sampling, =d a diagram showing construction details for each well, shall be
submitted to the Groundwater Section, Permits and Compliance Unit, P. 0. Box
29535, Raleigh, N.C. 27626-0535 within 30 days of the sampling.
(B)- if determined by the Division that no exceedances+ of groundwater quality standards
are present in -1 or DC- , then no further monitoring will be required under this
permit.
( If any exceedances of the standards, specified in 1 A NCAC 2L it ), are
detected as a result of groundwater sampling analyses in either -1 or DC- , then
within 90 days of this detection, two () d awwrn radient monitor wells 1 and
Qr shall be installed to monitor groundwater quality. The well(s) shall be
constructed such that the water level in the well is Bever above or below the
screened.. (open) portion of the well at any time during the year. The general
location and name for each wen is marked on Attachment A. Each monitoring warm
shall be constructed in accordance with this permit, and approved by the
Mooresville Regional Office.
1. Monitor wive -1 and WQ-2 shall be sampled initially after construction and thereafter
everyApril, August, and December for the following parameters:
Calcium Aluminum*
TDS Sulfate `
pal Water Level
Chloride Fluoride

Chromium*
Iron* -Lithium*
use method 30, preparation for metals, in Standards eth s, l7th edition.
e measurement of water levels must be made prior to sampling for the remaining
parameters. e depth of water in each well shall be measuredfrom e surveyed point on
e top of casing"
The measuring points (top of well casing) of all monitoring wells shall be surveyed to
provide relative elevations of the measuring point for each monitoring well.
e results of the sampling and analysis shall be sent to the Groundwater Section, N. C.
Division of Enviromirental Management, P. 0. Box29535, Raleigh, N. C. 27+62 -0635 on
form -6 [Compliance onito 'Report Form] every May, September, and January.
22. Ali ells that are constructed for purposes of groundwater monitoring shall constructed
in accordance with 16.E NCAC 2 .0108 (Standards of Construction for Wells Other Than
Water Supply) and any- other state and local laws and regulations pertaining to well
construction.
23. The Mooresville Regional Office, telephone number (7 i) 6+63-16shall notified at
least two weeps prior to the construction of any new monitoring well required under this
permit so that an inspection can be made of the monitoring well location. Such notification
to the regional groundwater supervisor shah be made during the normal office hours from
8:00 a.m. until 5:00 p.m. on Monday through Friday, excluding state holidays.'
24. Within sixty (0) ;days of completion of all new monitoring wells required under this
perrnit, the Permittee shall submit two original copies of a scaled topographic map (scale no
,greater than 1:1 signed and sealed by a professional engineer or a registered land
surveyor that indicates all of the following information:
a. the location and identity of each monitoring well,
b< the location of the waste disposal system,
C. the location of all property boundaries,
d. the latitude and longitude of each monitoring well,
e the relative elevation of the top of the well casing (which shall
own as the "measuring point"),
f the depth f water below the measuring point at the time the measuring
point is established"
e maps shall be sent to the Groundwater Section, N. C. Division of Environmental
Management, P" 0. Box 29535, Raleigh, N. " 27 2 -0 3 "

5. Upon completion of all well construction activities, a certification must be received from
professional engineer certifying that the monitoring wells are located and constructed in
accordance with the Well Construction Standards (15A NCA 2C) and this permit. This
certification should be submitted with copies of the Well Completion Form ( -1) for
each well. Mail certification and the associated "4 -1 forms to the Permits and Compliance
Unit, Groundwater Section, PO Box29535, Raleigh, N.C., 2 626-0 35:-
26. For the initial sampling of the well as specified elsewhere in the permit, the Permittee shall
submit a copy of the -1 form with the Compliance Monitoring Form ( -59) for that
well. Compliance Monitoring,Forms that do not include copies of the -1 form will
returned to the Permittee without being processed. Failure to submit these forms as
required by this permit may result in the initiation of enforcement activities pursuant to N
General Statutes 13-2156.
7. The +C1MPl I Y" for the disposal system (See Attachment ) is specified
by regulations in 15ANCAC 2I , Groundwater Classifications and Standards. Compliance
Boundary is established at either (1) 250 feet from the waste disposal area, or (2) 50 feet
within the property boundary. An exceedance of Groundwater Quality Standards beyond
e Compliance Boundary is subject to the penalty provisions applicable under General
Statute 143- 15"6(1)a.
Also in accordance with 15 A NCACL, a REVIEW B N ARY (See Attachment A) is
-established around disposal systems midway between the Compliance Boundaryd the
perimeter of the waste disposal area. Any exceedance of standards at the Review Boundary
shall require remediation action on the part of the Permittee.
28. Upon classification of the facility by the Certification Commission, the permittee shall
employ a certified wastewater, treatment plant operator to be in responsible charge (O1 ) of
the wastewater treatment facilities. The operator must hold a certificate of the type d
grade at least equivalent to or greater than the classification assigned to the wastewater
treatment facilities by the Certification Commission. The Permittee must also employ a
certified back-up operator of the appropriate type and grade to comply with the conditions
of Title 15A, Chapter 8A, .0202. The ORC of the facility trust visit each Class l facility at
least weekly and each Class 11,'Ill. and IV facility at least daily, excluding weekends and
holidays, and must ;properly manage and document daily operation and maintenance of the
facility and must comply with all other conditions of Title 15A, Chapter 8A, .020,2.
29. The Permittee, at least six (6) months prior to the expiration of this permit, shall request its
extension, Upon receipt of the request, the Commission will review the adequacy of e
facilities described therein, and if warranted, will extend the permit for such period oftime
d under such conditions and limitations as it may deem appropria
Permit issued this the 14th day of June, 199
NORTH CAROLINA ENVIRONMENTAL AGECOMMISSION
rest4ofnvZironmeTnitall
rd ., Director
Divisioncement
By Authority of the Environmental Management Commission
Permit No, WQ0008149

PRID7ECT,No
To P rr�its and Enrjineer4ng nl +,
Wa
ter .5. li r Cti i
Attention: Banes Jones
tltl.
NON-DISCHIkRGE STAFF REPOPT ANP P " �P l Tal
County: : Calton
mFO .:913-178
Perron Pic- wO14
P P I- C�TENEFRL INFORMATION
`
P � ity and r s Corporation
t . Lithium. Division
Post office B.,
Bessemer city, N.C. CI1
Dste of Investigation: N1A
rort P r + —
} j _ , x _ T
Mi�"hsel L. Parke
rontacted and Telephone Number.' m r Itou t hum
n to t The Lsth uM,Ch n c l plant rat
rirectioof the junction , 161 and ?, {. �.r��.th a .+ t
T �q ,2 of Bessemer i t y
Disposal it ; , List for all disposal Sites;
Latitude: 1 4 "
Longitude: 811 1
Attach a USGS Map Extract and indicate treatment. Plant � +
n rnap ;
,i land available for � expansion n 11p r dine '_ Tl�r
irpit d area available for expansion, if necessary.
S. Topography cation map or topographic indicating
relationship
hip 100 year flood plain included): The site
not located
this the 1 floe plain � t �� r ll`,.�
topography with slopes.
,R ny buffer conflicts with location nearest d l irs a
water supple well?

Page Two
1 . Watershed Stream Basin Information
a. Watershed Classification! C
i, River Basin and Subbasin No: C t airb? OlnPT7
C. Distance to surface water from disposal ::: T
existing ponds appear to be several hundred feet r r,
any surface waters r vin positive flow,
PARS" IDESCRIPTION WASTES AND TREATMENT WORKS
1,
a, Volume: 0.1872 MID (Kiln 'scrubber at : )
0.0073 MGD (Coaling "dater)
Residuals: tons per year
Types and quantities of industrial wastewater: The
kiln dust recirculation panda receive apt aat r from
scrubbers n the exhaust stack on a spoeumeneors
decrepitation M Both dust and fluorides are
removed, h cooling aat r pond receives water from on -
site cooling ,towvrsY
C. Pretreatment Program only)*: N11A2Treatment Facilities
Current rmitt d capsoity of the facility: /
Actual treatment capacity of the tac it tY(design
volume): ru + r ponds - .(storage v0l yl
Cooling water pond- . (storage volume)
. Description of existing or substantially constructed
WWT facilities: FMC operates two t l panda that are
carable of removing solids collected by sorubbensn
kiln exhaust stacks. only one pond is used t time
FMC also operates recirculation 'corgi for cooling
tower water.
Residuals handling and utilization/disposal scheme:
Residuals are removed from the kiln scrubber ponds and
,
d r used of in n on it landfill approved y t' Division
isio;n
solidof
4. Treatment Plant classification: Less Then 5 Points;
Rating (include rating sheet). Facility does not meet the
minimum for a class I "rating,
a sic code( .) : 2819,
wastewater Codes):.
Primary: 78
Secondary: 17
Main Treatment Unit Code: 50000

Page Three
PART III - OTHER "PERTINENT INFORMITIOV
1, Is this facility �� constructed with Construction Grant
�
Funds (municipals only)? N
a Special monitoring requests: None at this time
3. Imr.ortant SOC/joC or ComplianceSchedule pat /A
EAST Ili - EVALUATION AND pECoMMENDATIONS
issuance of a recycle permit - for the Operation
FMC t three requests
wastewater recycleponds, Two 2l of the
ponds are
� u �� water and the third ran is Wee t
used t r Ycl kiln � �' _
ran 'k�tL° ��3 � �= s�?a�0.
r c �a1 cooling tower grater. The pgall water from the
several bears. burin periods f high rainfall,
existing c���T
cooling water pond : directed d tn`' the n an 's _xistin�
facilities a tailings pond) and then discharge through an NE E
s rt all . a E should whether this and should
permitted a dart >ot the N E Permit r t (r
enewal al is in-house
ae i included
as as n r %n lu it as part the n nclis har
ng permit,
o the three pond are lined. will n to address
None that r�a.�
any concerns regarding Possible contamination
c,,;nt'Y exist'r-r to permit
issuance.
�t
pending a final� technical review w the sERG and r, r+
nt i is rnd that ndischar PermitGw ,
issues,
?.Sig—v6
turn n _port Ei°epa Date
'
T at r A y Regional pervisor Date

w
a
w...� pF
VI
t
�cu`_
_
m
6 ' rWT
� !..✓'" "� why k "a. �� � �4' � � s� � � AMx �.
`!4W
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sewa
it
21
'tea 851 70,
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- -'-
46
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4
A
lt'�4'C�4'E�° �,� 14dr #T hft
t r yrS r ter 73 4754$11 NE MILE

State of North Carolina
Department of Environment,
Health and Natural Resources
Jr.,14
Division of Environmental Management
James B. Hunt, �
,lorlihrl B, Howes, Secretary
, Preston Howard Jr.,P.E., Director
N
f S
July 14, 1993
BOX 795
BESSEMER CITY,' NORTH A 4 LII A, 28016
Subj eot: application No. WQ0008149
iln Scrubber Fonds
Recycle Facility
Gaston Count
Dear MR t
The Division's Permits and Engineering Unit acknowledges receipt of your permit application and
supporting materials on July 9, 1 is application has been assigned the number shown aboard,
Please refer to this number when making inquiries on this project.
Your project his been assigned to ela Griffin for detailed engineering review, technical
acknowledgement will beforthcoming,
Be aware that the Division's regional office, copied below, , must provide recommendations from the
Regional Supervisor or a Procedure Four evaluation for this project, prig to final action by the
Division:
If you have any questions, please contact Angela griffin of q - 0.
r
�' Orel
t
`} Donald , ' „ I.L,
r - Supervisor, errltit d Engineering Unit
r
cc: Mooresville Regional Office
Rust Environment & Infrastructure
Pollution Prevention Pays
P.O. Box 29535, Raleigh, North Carolina 76 6-0533 Telephone [phone]
n Equal Opportunity Affirmative Action Employer

Jury 0, a �
r . n y rjns
Permits and Engineering
Water Quality Section
Division of Environmental Management
P.O. Box 29535
Raleigh, NC, "7 -053
Dear Mr. Janes
Several months ago the water Qualify people in
Mooresville determined that the two re -circulating water
systems at our chemical. manufacturing plant need t be
permitted as non dischargerecycle snits. application
and four copies for this permitting is enclosed. This
should take care of th need for five copies of each
w.
engineering document.
Please note the following:
1,. These are two long -existing 'systems. Earlier
determinations by your Department were 'that such
permitting was not required because we do have here at
the plant an NPDES hermit No. N177 for the
treatment and discharge of process wastewater. We also
have pending an application for a stormwater permit.
;. One is a system of two ponds where air pollution
scrubber water at our are decrepitation kiln is
re -circled from the scrubber to one of the two ponds.
when one pond is filled with solids, the gather of
these two is switched in and the filled pond is
cleaned of solids.
3. The other is a Chemical Plant Water Recycle Lake.
. Analytical data; is presented for both of these
systems. we believe that this information is accurate
for our current usages.

Page 2
08-JUL-93
5. Following your telephoned suggestion on June 17, we
are sending only one check for $400.00 to cover the
permitting of these than ponds under a single permit.
Separate applications are filled out for the kiln
scrubber ponds and the chemical plant water recycle
pond because there are some differences in the two
systems. Please let us noif it is determined that
separate permitting and an additional $400.00 is
required.
Please contact me if you have questions.
Sincerely yours,
Arthur S. Gillespie, Jr.
Environmental Manager
cc. J. E. McLeod
G. W. Matthews
G. R. Scott
R. Ahuja
Rex Gleason- Mooresville

State of North Caroling
Department of Ens°irttnment, Health, and Natur2l Resources
l i,,.ision of Enviro cart a c cnt
Non-1 isclr t r lac ' t Application
RECYCLEUSE AS M ORIGNAL)
(VIIS FORM AfAY BE PHOTOCOPIED FOR
FACILITIES
GENERALINFORMATION: Kiln ''Scrubber Ponds
rnralcan„�r ��tlu lis�lutt
:. Prin, Owners or Signing Official's Narnc and I"itic (the-- ptrson who is Ic all
rc _nsiblc for the fr cihty and its compliancc � �-
3. lvILili r Address: u 7
�tll: a
.T cl plr rsc No.: 7t14 � 8- 400
rc t 1w{ r s slid #zsi as , f 11 t��, r csta lisi tot t rar e, - should conslsttnt with
„ �r sp c�r..�.
rj a on ��,r��t �t�
trnrrtical Manufacturing plank
22, 1 — Fcc Sub tt d: tlil-Uu
p cA: as rrn
17'
r itt�de pl f rccycle f cll ty $ ZnO
1PERMIT 11 `1°l'`1?
l .permit No. °ill be completed by
if r'crrc al, compictc only sccts trs 1 llk 11� a ill r,t st r st rc
(on pg,6). Submit only p s. 1. 2, 6 (original and �, cooks of caclt). Engin-e
sj nrt r not ti ~d f rrcnc 1. New application for existing ponds.
t is 13c rr rt l ;.i iii "+a:iil+ as s' rC,,, jt of a rcn wal 0 T�c�dcatr iEG to an
SU
i rcn
c rst rrl lam t, lrst t=h- ca: stun I a
s �P",�..e�i��a`` `'r'et �c L��wi ➢.3 ., uPP "-RnT 'S
FO RTAI :R r' A

A ,i
1 at-e of"astwatr: cstic;% CommcriadlP
1 Indusmall; � Other waste, (sptci `y):
Pl a. ,- provide a one of two word description specifying the origin of the wart --water;
such asschool, sr vision, hospital, c crcia , industrial, apartments, .tc.a
3.
Volume f" rezycle,,watcr gentrated by this project: 1 I ns per day
;. Explanation of how recycle water vtumt was dttt°r cd: Figure taker
from Air Scrubber sedllciu�t
l ct pr jcct dcscripLiow Dust and fluorides . are of r r bb d fr
exhaust stack from a s bdu ene ore decre itati n iln
------
IN'. DESIGN" INFORMATION
1, Pr vi r a bricf listoi f the components of the recycle farilat cs, includingd1mcnSions,
1:1capacities, and detention times of tanks, pumping facilities, high eater aia s filters,
ponds„ lazoons, ctc- The iMDoundments' consist of tw
recirculating scrubbing water- Only one is used of a time. When one of
other nhd while the filled end �s Bred ed.
Norm of closes: do,�,;,nslopc surface °at rs: Lribpt4ry t kern h Creek in the
frowders Creek and Catawba River Basin.,
+ :. lasslfficmion ofclostst dovinsl pc surface, w°atcrs: (as established
by t Gc Env r nrncntal Nlana crrt nt Commission & sptcificd on page, 4 of this
FDDI,ication).
4; I; a Power failure at the facility could impact waters classi � lttl as , SA, T3, or
;B, dtscnbc which of the mcas,res aurc, bf-ing iMp1c,=nttd to prcvcnt such impact, as
re uircd i i l A "%CA H .tl C" ; Power fai l jr �rul c� riu� ire
k
5. The facilities must conform to the follox�ing buffers (mod all otlitrapplicable buffs s
a) 400 feet b r , c a a la con and anv resi cnc um ,T scpazats ovcrzship°;
) l fc t lx'twc' — n a suzn"acc sand filter and n), resid ncc i7'dc7 s+--pan tc ov -nc ship;
c) 10 f.ct r--rt%;Pcen recycle t"aselttits anda water sUpply �,t� crt.c,

PAGE 3 1 )
- If any of th-- buffers p,®ificd in no. 5 aboNc arc no, wing rnct. pi sr, cx.plain how the
p
rases buffcrswill providt equal or l ti-,r protccnon of thew "at rs of the Statt wiIth
no in=d ptatcntial for nuisance conditions: Al I buffer
requirements are met.
7. Art any compontnts of tfic r
cic facility located widiin tht I yxca_r flood plain?
yes, no. lfycs, briefly describe- the protcctive tricasures being taken to protezi
against flooding.
THIS P ICATION' PACKAGE WILLACCEPTS Y THE
I IA'I ION OF ENV0,0NMENITAL MANAGEMENT UNLESS ALL OF
THE APPLICABLE ITENA ARE INCLUDED °I II THE SUBMITTAL
Requfred frern
One, or iginal and thrtc copies of zinc mmplemd w d appropriat ly c cdtttcd apptic t.::n form.
d, ac appr priatc pc -it pr ccss ' f c, in accordance with 15A NC C 21 .0205(c)(5).
C. Five sets of detailed plans and sp-c'fications sipta d and scaled by d North aro)ina
Professional En inccr. 'I"anc plans must includ- a gcrtcral locationmap, a site map which
inrt c titers �w°h}tacany borings - rat hand ayaC�cr sarnnlss ��� � tathcn} along.th buffers,
:striictta:n.s, and proper. ,y lints. Each sh zt of the plans and t1it first legs of tha spccifictuions
must bc si n, l a ad scakcdL
d. For industrial vastc%vatcr, a compIcte chemical analysis of the typical was€twat-
: test be proviticd, The analysis may includc, but shali = lac hr, ited'to, o, a tea
Carlon, BO , COD, hloridcs, phosphorus, Nitrates, Micnol, Total TrihalornErtxxancs,
TCLP analysis, T natal I-lalogenatcd Compounds, Total Colif rcls and '1 natal I issralw cd
Solids.
c. If laptions arc a part of the facilittcs and tnc rec cle svatcr is indust:ialy Provide
hyd�rovcolo is ricscnpti n f the sxu bsurfact to a depth serf ? l icct r d�' 1., vwPhs`chcw^cr is
lcss. Tiers number of borings shall be staffer icnt to dcfthc t following fear the area
undcrl.ving each major snail )'pc at the sits. significant chanpcs in litholopy°, the vertical
pcm,r isa it ty° of th i. nsaatura d zonr-, the hydraulic ondt,C`ti vi:)' of -,h a[uratc.d zone, and
the dcpth ofiCht t acan seasonal high ww'atcr Lablc,
p ' p upportin calculations, ctc- M ust fra
f. i��c cra��s f all rc trams, cy.a]uatcans, a r c�rract=ts, s
sub -ma d as a pan o,' the sptcifications which arc signed and scalcd by a l o-,th Carolina
Proof-ssionr l Enginctr, Although ccrtair portions of this rcouircd stalatnittal rnust do
} by rather profcssionals, inclusion f ttacsc rnatcnals ands- the stfna'Gt c any sc�
cif a h Carolina f' r�fcssirsnal rsl snc.r sinifas that h has raw icay *G is �r atcr=al and
heat: udgcd it to 6,; cortsismnt xjtla his proposcd dcsi n.
ivc err) eras `t a:z tand pc � t it a rcnc%Val or a r& c ificafion
.o
f 7

PAGE 4 )
. q
TO: REGIOINAL N�'ATER QUALITY SUPERVISOR
fcasc providt me with the classification of Lhc sorfaccvvaterSs iftntificd in nurnbcr
bclow and on Lhc attach map sc cnt-
c of s -fa eaters: Unnamed Tribot r to Abernathy Crook k
in the Catawba River: --Basin
Classification as cst blishcd by the Errs. n=ntal Managcment Commission):
Proposed Ciassification, if applicable:
Signaturt of regional office personncl:, Date.
INSTRUCTIONS TO ENGINEEIZ
In oiiicr to dctcrminc whsthcr provisions for dual or standby po,,mcr may bc required for the
subjtm facility, the classification of the closest doNvnsl pc surface, waters (thc surfacc watcrs that
any ovcrf low from the facility 1A,,ould flow to g ard) must bc dcter intdy. You are rcrltrircd to
submit this foroi, with itcrr-s 1 Lhrouph lfl dornplttcd, to the appropriate, Di -vision of E nvirorm,--ntal`
Manapcm.--rt Region,,! Wate., Quality Supervisor (set attached listing). At a t inirrturn, you must
include, an ,5" by l I" copy of the pomion of a 7.5 t mute, USG a Topo aphic Map v,,hich shows
Chc subject surface watcrs, You must identify the location of die facility an the closest d vmslor
surface Nvatcr (%»triers for which you are requesting the cl :ssif acti6on) on the submittccd map copy.
h application may riot-1 . ubmiite--d utj:.l ti'Lis f orni is complcted and included -,viTh the ub n tual,
I
Applicant (corporation, individual, ot- othcr) F C Cor oratron l tth�tt�t t � +��
2.
Narrc and Co plcic, Additss of n ,ntenrrg i; : m
and Infrastructure, Inc., 2 Market Playa
Warr
Mechanicsburg _S,tatC PA
Zip, - l C� _— —
I c1cph nt No. II 5-80 1I
.,,u. t n as e, i �l n Scr ber Ponds
w
4.
etc{a c lac lrt ° "'c urrsc. , 00,000
g each
of two,
„#4
pond` ps". y
A'4 umc v �M.+'i• Xw IMJ v�"iw kt 4.S t"✓4?'a"#k t r.��4a+ ..i��.ve �'S'�ir., v' nas ^taawdl
j $y' u p q ®# y
i I d b e 1 y 0.a .W� 09 M1'„�F
Creek: in the Catawba River Basins
6
at.3n y(s) whcrc prof-.-t and, surfact aatcrs arc l catcd. Gaston
d'�
nPiricu.e''w.d ds'.ii cam... ^-^' r'4.w R.
t:. _. ..._..�:.
V°
y�.�o �'+ nr Sr}:"�'p kw"r f, ,i`,ry �-0.' x n*'a! '*�^�.:4�'9 s^x ✓a. p�Y cg1: txit on .�`�. �+
' 5,.,+ a c.b �k .. k� aR a a , 4�,0 +.-,- a. b9. x ,.. yam, 4.
r , , k°P l
��r : i s X 'S %�.r� � sue+ '� �.... r� g a' rt 4a "ww,. m
.�..�...,.,,..,.,,,......_._._ .:.,�.,.,.,...�.e �--•-
iJ.
?c,:d and Signcy.: rnirw., ��»'S�`�• date):
4 of 1
435

DrVISION OF ENNIRONMENTAL MAINAGENIEN7'I
k e, OFFICES (4191)
A-shevi.11c Rcgional WQStier,
''shun loo Rc l n l WQ Sup r.
Raltigh Regionail WQ S r
91` P
lucvillc, NCB 28802
I507
r
31 BwTw Dr,, suit,-- 11
/7 1- 20
Washington, NC 27889Raleigh,
NC 27609
l a9,41-64 i
1 173 a23l
Btziz NICDONMU
:tit Ltnoir
camdcn Mar -tin
Durham Notes pion
altlry ll �Lchtll
Chowan Pamlico
Ed9ccombe Onngc
k:,li Pc mn
CI)tr&,= Polk
Clay Rut ord
Cray= Pasquotank
GranvDit Vancz .
'
Cuzitu& Paquintans
Halifax
Grahwn av r
T syl n i
Dam Pitt
Gattz
lcshnstdn WWTW
li nd--wn Yancy
T II
Grt=t NVashin ton
L= WiLson
Jazkaon
l- oral 781-rt
l-ly c
Faywcvillc Rtgional NVc.. r•
Wachov6 Buil(i ng, Suitc 714
l � rtsviHc Rcgiornil Sail s.
Wilmington Rogirin. NVQ Suj)cr_
ayc.ttcvielle, C 7.53 1
919Noah lriain Street
127 Cardiinal nnvtExt ;,sicn
r<l resvillc, sal 2 1 1
`ilrningtnn, r 5-35
Anson Moom
3 Rig; -start
plc jr Mccklcnburg
Brumwick New P n vc.,,
Curnbcz"1 nrl Ri hkni ntl
Cad Row
Catawba st:,InlyColumbus
rct Onslow
H--,Mtu Szarnpson
G as, on Union
Prn ,
1 tt lie
ok-t &mdand
I ell Cicvtland'
1"linnt mcr-Y
Limo! i
Winstrin-Sal= Rcgional a Super.
8025 Norrh Point Boulcvard, Stiit.^ ICE
19,,7 -?35 t
" Ro l:ir'4ghari
Allcg, 4any Randolph
1 - as o t. cs
to SLIM'
Dagidson
i
GldLford

, !:, 0
Nani't and comp!-'ts AdOws oAn-linwing Firw Rust Ervin qqprqmqenjt______
and Infrastructure, Inc., 2 Market Plaza, Q,
Gry: Mecha ni slaturg_ slac: PA Zip: -llD-i5----
poo, _(717) Qj- 001
Professional EngineeO Cer!m5cation.
I, atj-s, that this application for
has tntn by mt and is accuratc
zmd cornplctc to thc test of. my know1cdg, I fur hctr attest that to thee. L--st of my lmowltdgr, that:
proposc,d design has ly--cn prcparv-1 in accordanct with wc applicabic rtgulations. Al,,hough ccrta±
ponions of the sub-nnittaJ package may, have be -en dcvclopc° oih,r professionalls, inclusion of
ithts: mattrials undo my Agnature, and seal significs that I 1hilVC TtVit,NTftd thiS material and have
judgod it to & consiscm vAth the propowd deli
Nonh Cardina Mfessional, R.-guisYs Rghwatlor.,No. 77 6057
N
F�iin,z Narn,- of Enginccr L),A 1-1(,0 1L) &JU C
scal ajl� Sioz 'I"Llre (Spccify date): 1,Jo.-rH
T-193-5
If
ApplivnnA CeWcahon:
t J. E.ht yid Lutc-st tl,.at this •applicsion for -RERYEI--Water
has Wn rKe"wd by nws ,, and is accu:,-tc and comphte to the lost of my
that if all raquAd pans of Ws application a7c no: =npinDd and, that tf' T(,qi,n.rt!d suppo--,--n~
infwnwio" Z'TIO�yInjon:S are inn: incladmn this avylication package 01! b; rvurnsh ar
C
'10XV A K 771 WAT: APP I 77MA K
ISFOWTION AND AWE ALS, SHOULD BE SEN7 TO TUC FOLLOMW ADDRESS:
NI1IRTI-11 CAI',,C)L,I>;A DIVISQ)j' C)Y&Q'JP-,O�NIINJEN're
NVATER, QUA.1-TTYSECTI(�N
PUNATS AND ENGINEERING uNr,r
POST (ANCE 13031 2953S
51�� 'NOR-TH S,�,LISFWRY STRETT
RALEIGH, NORTH CAROLINA 27C�6-0535
'All-KNO)NE NUNWAR: 91103000
6 o F 7

PERMIT APPLICATION PROCESSING FEES
(effective October 1, 0)
T1
M l�r
1,1, e l'
Industrial
S400
Dotmstic/Cooling Watr
YM
��',,hhyy +�yy�,
10,001 - 1,000,M GPD
Industrial
Dornts&lCooag W'at r
1,11 - 10,000 GPI
Industrial .
4
a
d = +figy K G (�
S. PD and
, . ..
in lc Family Dwelling
40
$120,
Sludge < or 00 Acres
0
lud e > 300 acres
2 50
Se'v r Extensions
NOTE: The Fees for Seal Rernediation
Projects are the
same as for Sludges.
Under the Sewer Extension
only to thOse
Fee, "delegated to municipalities" applies,
governmental
,jurisdictions that
have specific delegation
rep°ae ° aUthorat , as
Manageanaerit.>••.
granted by the ivlsiori
of Environmental
7ot

m�
State of North Carolina
Department of Environment, Health, and l�laturalResources
Division f Enviror=tnW a t".rra ttt
Non-Dischargt Permit Application
(THIS FORM MAY8 E pHO7'OCOPIED FOR USE AS ORIGINAL
RECYCLE FACILITIES
GENERAL INFORMATION: Chemical Plant Water Recycle Lake
l : Applicant (coqvratior, individual, or ott r ): T fir° �t� ry � t��a q� j ara
Print n rs r Signijig_Official's Narne and Titl (tht p rscart who is .l ally
s sponsiblc for tht facility and its com,pl arsc J. E. McLeod�
P an . Manger
Mailing d ' ss� Box 79
its;,Bessemer i State. N.C. Zip: 1
° rj ct Name (s dda Nasis tt� facility° or stabl'i hrrm rsa a should l ct ras st rat with
p a µc= dark n pla.ds/sp cs, lts.tt f flow acc p ttc ., cratidt al A ;r rr tts, etc.;t
Chemical Plant Maser Becycle Lake
5. p 'plactiticast mate,
6-22-93 d, F .r, tibmia d: 0 -
00
our:ry wh r pr y t is l cat Gaston —
fi i7" raEit a e of recvcl faciti ° location
S. id;
pERNII-1, INFORMATION:
filer it No. (Neill be completed by NI):
r r�r� ra8 mcadi ac boor
Specify ,h thcr park t is: w,
to only s�cti as f f appli arrt si t a:tare
*lf r rte �al, Corot)
y pSubmit Ltnly pas. 1, 2, (original and � cop;,
ofa ch . rtEine r
signatum not rsqui> for r ntwal`.
New Permit for E is` ing Pond.
if ;his ap li ati rr a it subl mitt as a r stale f a ra pal car modification tea a
:s i pew t, lest t �C.ist'n p�rt�ra t nu , r
d issue dat _—
r-X
p ci rkhath r tl a applicants is ublic o
FOW& R FA ` 4191 page I oil
_w

PAGE 2 (4191)
ITT.: INFORNIATION'O;N'NN'!ATER:
I Nat urt of Wasttwater. — % Dom-.sdc; % Cot rimr-rciall;
100 % Industiial,
, _ % Othcrwaste specify):
2, pleas c provide a one or two word dcscription spccifying the. origin of the wart water
such as school, Subdivision, hospital, cornm creial, industrial, apartmcnts, r-tc.:
Chemical ufactttrrtt Plank
3. Vol umt of recyclt watch gerimted by this projtct: — 7,L-300— gallons Per day
4Explanation of how mcycle wattr volume was dtt'tied: Actual measured
5. Bric'fproj= description: Mostly cool ing tower water.
TV. DESIGN INFORMATION
1. Providc a brief listing of thcco-Tiponcnts of Lherecyc1cfacHifics, includingdime nsions,
capacifies, and dcttntion tunes of tan.s, PLI'llping facilities, high eater alarm, s, filters,
ponds, lagoons, 4 acre recycle lake de' th is thou to_araqt__
17.5 ft. The volume is therefore about 23 tags
Na,-nc of closcst downslopc surface v,,L tcrs: Unnamed tributary to Abernathy
and Crowders Creek in the Catawba River Basin.
3, Classification of closest downslopsurface, watcrs: (as established
by the Environirrie'rit-al Mianagcmcnt Commission & sp":Cificd 01-1 MCC 14 of , ,
cation),
4, It" a poA,cr failure at the facility, could impact %vattrs classified as WS' SA, P- or
SB, d-scrril awhich of 01-. mtasw-cs -ffc being implcm-Medc' to,7rcvcnt sudh impact, as
rcqu�zcd in 15A ",CAC 2H .02DD: N/A
5, Tnt fa-�Uitics mco ust nform to the follov"Ing bufftrs and all odic: applicable, bulEci—s):
a) 400 fect b--rw--cn a lagcoon and ar�y rcsid--n---- Undt-, separate wxmtrship;
1)) 1 DD feet bcM,ttr a sty fact sand f-Oztr and an), residence and--r separate ov ncrship;
c) ID) fcr-t bstwctin rccyclt ';'a-cilifics and a %vattr supply
d, SO fcc-, bc,,wccn -'h-- rccycl-' facihfi--s and property hn--s-,
2 oil 7

AP 3 t,51
. if any of the buffers cifi .d in no. 5 abovc arc not b,--irig rnct,pIcast txplain how, the
proposed buffc s will pr "�Yidc equal or betterprotcetion of theNVatcrs of the hate v•it
no incrcascd ptrtcnti l for nuisaact c ndi o= -U—f—f r
are met. The lake is very nearly 50 feet from Highway 1.51°
® Artany mpdncnts of the Tc--yclt faciEtY located within the 100-ycar floodplain?
ts1 no. If yes, britfly doscrik the protcodve Mcasures being taltcn to pr ttn`
against floodin&
THIS APPLICATION PACKAGE WILL NOT BE ACCErrED BY THE
DMS10NOF N RONMEN"I AL MANAGEMENT Ulu"EBBS ALL OF
THE APPLICABLE ITENIS ARE LNCLUDED WITH THE SUBNIITTAL
Required Derry
. One tdtri final aid thr= copies of the cornpltMd and approptiatelY cxccuted application ford
b. Iltc npprcpriate pe tt pr e-ssin tet4 in arccrdwtcc Nvith 1 A NCAC 2T- M05(r-)(5),
:. Five sets of dttailed plans and s tcjfications signed and scaled by a North Carolina
Professional Fn inter. The playas rust includes a en r al locatio€ map, a site reap which
indicates vs„here an), b rim, r hand auger sarttplt,s were talten, aping with buffers,
structures, and proper-,y lines. aach sheet of the plans and the lust page of the sp .n.ification
must bc, signed arid sezdee,
d. For industrial wastcwatcr, a complete chcrnlcal analysis of the tyTical
rnlust bt provided. The analysis may include, but shall not be limited to, Total OrgL111C
Carbon„ BCD, COD, Chlur�des, Phosphorus„ Nitrates, Phenol, Total Trihall a meth nos,
TC LP any ly° isTotal i ales e.nated Compounds, s, Total C:nl'i t- , and "1" sal l ls; olvtd
Solids,
e. if lagoons art a p-a t of the facilities and the, recycle W?-tc is indusuial, pro �id a
1,vd.rcpt logic d�scrtpticn cf the subsuri'act t a depth 0, fret or bt° 1:,whichever is
less. The n�urnbcr f borings shall be, sufficient t � de:t e the ftallot�„irap for the area
and rly°ing each rrlajtrr soil t4°pc at tht tc: significant ct,rn cs to litl-t lr�pY tltc �wr Kcal
Pc eaoility„ of the unsaturattd z- nc, the hydraulic conduct'# -arty f tilt saturatMd tons„ :Lnd
tilt dc�)tlh, trf tht mean was to l hgh water tabic:
f. Five copies of all reports, ts, cvaluatiorls> a' cemcnts, supponing calculations, c.tc., Mlust
bc
subrTuitmd as a p -t erf the speci5cations *hi-ch trre signsigncd and sealed by a le i,h C3TOhna:
Pr�ofcssi nzl Enggintcr, Althct=:th ccr,ain p rticsrs of this repttsre subsrtittal ttsust be
dta„elcp cd b „tether pr I . nals, inclusion of then,:. nlaternals under the: siunaturc and stal
of a North Ca;-ohna Professional Engin er signif t� s that ltc has r vicw:t d this material artd
t
has »< . It to be consistcnt ,vith h.s prorpost a cesi0n
.' Fivecones of the tsttt�g pt; ail tf a renew; . of a moJ-4s "a ion.
of
,,1

PAGE 4 (4/9 1)
TO-. REGIONAL WATER QUALITY SUPERVISOR
Plcasc, providr, me with the classification of the surface watr-rs ldtntiflicd in nutnb--r 5
klow and on the attached map scgmtnt-
Na,mcofsorfact,watcrs: Unnamed tributary to Abernattx-AnLorders r ek lrt
the Catawba River Basin.
Classificarion (a-s rstabhshed by the Environrncntal Majiagcmcnt cornmission):
P'mposc,d Classification, if applicable:
Signatu= of T-egional offict pc-,5c,nnc1- Dat-.:
INSTRUCTIONS TO ENGINEER
In order to d-.tcnr�nc'Whcth--r provisions for dual or suandt
subject facility, the classification of ffic, closest downslopc surfa
any ovcrflow from thc facility would flow tea "aid) roust N, r
S,A=il this forl"n, kpiui itcrns I O-Lrough 10 cornpl.-ted, to the appri
Managemcni Re--gional Wattr Quality Sup,-rvisor (scz attached
include an 8,5" by I I",cbpy of the portion teal a 7.5 minute. USG
uk" subj--Ct surfacc,,vatcrs. You niust identify th-. ladore ofthe
surface watcrs (wattrs for which You arercquesting the classific
The application may not tr- submitted Until this fo,,= is cornplttC4
powcr rnay bc requirtd for the
C, graters (the surfacr- waters that
.ttrmincd, You arc Tcquir--d to
iriatc Division of Environmcnml
sfing), At a rrunimurn, you 11-10st
Topographic Map which shoxs
ility and the. closest, do,,�vnslopc
dean) on the subn-fitted mnp copy,
and includf--d%vith the Sub-mittall.
I Applicant (corporation, individual, or other ): CCO
2 fait a.-idCoriiplctcAddress ofEn_pincci4inaF�,,—,,,: Rust Environmental ----.,.--
and Infrastructure, -Inc, 2 Market PlazaLya�__,
Mechanic PA Zi, p 17
Tc.,cphone No.
795-001
3. Flmlic-ct flan:-; Chemical Plant Water Recycle Lake
4Stee Facu' ny Volurnle-, --23-,OQO,900 gallons
5i a c(closest dcwnslopc- surTace waicrs., Unnamed Tributary to Abernathy and
Crowders Creeks in the Catawba River Basin.
6oun-,y(s) whcT-c proit-1, and", surface locate e': as
7. !tap narncacid date: lye--
8. N-th Carolma Pt'"isn-a6cri No.
9E'lin z Nam n Cif E n 'r in Cr
10l and Sign atLrr- (sp-Acify date):
iY3
4 of 7
ry e-Y
J j

P ION' 'IRON
"i . ?+IEN REGIONAL OFFICES"91
eville Regional Supcx.
Washington Regional wQ Supc,.-,
Ralcigh Regional WQ Su r w
9 "Aloodfin PLict
P 0 Box 1507
3800 Ba=t Dr., Suite 101
shs.vtllc, NC 2,8802
Vv`ashingLoa, NC 27889
Raltigh, NC 27609
704/ 51- 8
919/9A 6- 1
919/733-2314
May
Beaufort Jon-.S.'
Chatham Nash
McDowell
camdai ?,,Iartin
E4ccombo Orange
Caldwell Nfitchcll
Chowan Parnlico
Franklin Person
Chcrokm Polk
Craven Pasquotank,
Granville "Vance
May Ruthcrford
currituck P uis
Halffax Wake
Swain
Pitt
Johnst n
Transylvania
C atts Tymil
"9 i son
z tcrson "Y'ancy
Washington
Jackson
rG yt
ayc-ttcvillc Rc r nal wQ Su'ptr.'
Mooresvillt Regional WQ super.
Wilmington n Region, 'VIQ Sulxr.
Wacl ovia ButldLng, Suite 714
919 North Main Suet
127 Cardinal Drivt t—csision
S yctt s°tile, NC 283 1 1
?,,Ioamsvillt, NC 28115
Wilmington, NC 118405.3845
919/48 -1 1
7t /663-181'9
1 ,r395- 900
un n 1"1 re
,fluxand--r Meickltnburg
Brunswick tw a tr ytr
1 1 k1 -O i
4M.
abarrus 1'o,,;',,�Lt.. ..
pp��**s
CaL-'Mtonslow.
d Richmond
Cauiwha St n*"
C,',-,u nbus P deu-
1 a Sampson
Castors Union
Duplin
1ett
14"�,++ryr'Fyye,rye t1
..
: 1�+1%.,�.1"tycl and
-y
j
tgorncry
�y1 p5
Winston-Salem Pcgion t V*'Q Sorg Lw
8025 North Point Houle1vard, Suite IDO
' ,=s.rrSWT-, alern, NC 27106
9191'761,- 3 51
i Stokes
cas'ovc]]SUITy'
1 avoid. Watauga
§ Wilkcz
P ut "x -i n
Guillurd
of 7

Z' t'i k..! Z- Q 7
Naim,Complttc Ad!-4---ss o' Engin---rn� Rust Envi ronment and Inf Inc
2 Market Plaza Way
Mechanicsbur~ lats: PA
-j3Q-55—
Tcltpho:-:� No. [phone]
professional Engineer's Certif-I cation
0
td —(Joe-re!5 attest that this applicafion for
p tAD A 4 7' 10 I-J has b,--en rt,6cwcd by = and is aocuratc
and, 00-,,-�plctc ta, the bcst of my knowlc4gc, I fu�-,hccr attest that to the b--st of my 1-,.-nov,,1tdgc t1?--
proposc-d, design has L-,,-c:n prcp,=,d it aaccird,%.ncc ith tht applicable rtguL,6ons. Aithoug"I cart 111
n dcvclopc,� by otthu proftssionals, inclusion cif
onions of this submitta.1 packagc may havc b,-c
thcs.- rnattr-.alls undcr rp.), slgrat= and scal signifits teat I have rrviv,%v--ki this material and havc
Judge,d it to bc- consistent with the proposed dcsigr-
7- 14,35
Nort]h Carol;na FIrofe�
Pnint Narric off '',"n-in-tu
a.,-d Siplamure (sptzify datc): klblert,�
r-1 Cvj P- A R PeR ui T lq3
C
Applic.int's Certification:
J. E. McLeod amcsi that tit is application fo,- Non-DisOh
Permit for Chemical
has DV m iU'iO is accurpa,' a,.nd compicte, to t,,,jt b'
ion arC Cu
ou f k's anplica,,'
U U,`
aTc no: incl',,,u-,c�, z t' s, aT,.-,,, nLci.! 2,' v, ka,
1 4,1
Dat,.-
S
ITCOMP' TED SijrOULL RE SEA7 7-0 7-14'1-n FOLLOIVING ADDPL,SS:
NOR"TH CAP"OLINA DIVISTON OF -,N, E N VIR UN N I E N T A L, N A.-'k G T
WAT.1,R' QUALm, SECTION
PEF',N111"S 11AND ENGINEET"UNG, UNFI'
POST OFFICE BOX 29-5-35
5 12 N I ORTH S 1,1SBURY STREET
11"AI-EIGH, NORTH CARZOUNA 27626-0-5-35,
7
0 8 3
6

PERMITAPPLICATION PROCESSING FEES
(effective October- 1, 1990)
MQ1 �n N
1,000,000Q Li
lndustr� .
k
Domtsdc/cooling Water
1 ,001 - 1,000,E GPD
lndnstn .l
2 50
Domestic/cooling "dater
2 50
l X l - 10,000 GPD
Industrial
S400
$200,"
Do=sft/Cooling Y atcr
S400
$200
or = 1,WD GPD and
S in ie FD wellin
2 1
12
1udgc < or = 300 Acres
c,A,e: Exttnmns
(nondei- te,d
cwcr Extensions
Cl s le-
.a4 rafive
2DO
NOTE: The Fees for ,Soil Rernediation
Projects are the
some as for Sludges;
Under the Sewer Extension
Fee, "delegated to municipalities" applies
a tl to those governmental jurisdictions that
have specific delegation
review authority, as
granted by the Division
of Environmental
°la��a ;ei`nent„
7 of 7
�_

,?<~s#' �° • ..�"&.ice � Y` ,. �� * � ''�° i^'�,.�,t �, „r o-
•`ram'--•, �
't �"'•u I,°Y Y "``. w.; �. „ , • "—` ar"a,t "3' y , d ;" " '� as
�""`"�%—�.--.r�."�>" s ° s ,a r r"'�^" t. �' " � rr "a" " � •, �}t� . �' �. ^" '4 "• 5 �' � ` "'"say- ia*"�, .; �'" *,
1 s a
f ' � � � � � .� <� ., `A a �:-„� tb m .• �� ``""" � A #
$r `t,,o-®"q wg •..
w
'1 \ r" p
r *y x d
,r k" r "'-•'�"� 1 .� �"Y K. a s.t1':J k-.*1^ ' �S'af ru-,w, " �?...„x`i t t"m
`°��� 1 �• d� �'x`� ,�.»w.�%^�z v � �"���Y � .,` �`",��' � a * � k fit;, �"� � °a:��'$ d �°' ;�rti
k a 1 „ IN' Vp �"p S fa sue'
If,
` d..Boundary
4�.
`" +' `' 40
r4 ,7"C`
tt 7E1�� gg
Park a5'�`
r
r s t
.�
i
-# ��, �
rasrae`R,#, ". x'..,,.`�
� F.. ✓'`
r
! ¢
.w
NOTE: Map Derived From . _ .5 Minute
Togo. Qua& Bessemer City, N.C.
TT CORPORATION Site Location Map
En in ors, olo st , :r vir nt l Scientists � T-
t'tarkr! -1 ay, Mt aruu burg, PA 1
� N Phan : 717/ l Fax 717, -77954280 Bessemer City Facility

..1 SITE GEOLOGY
The natural geologic materials present on the site have been classified into four general groups.
These materials groups are soil, saaprolite-soil, saprol i te- weathered roc°:, and bedrock, Soil, from
the surface to a maximum depth of ;approximately six feet, is generally as well -drained sandy clay
loam. Underlying the 'soil and extending to the depth of bedrock is as saps lite material. Saaprofite
at the site has been subdivided according to the intensity of in -situ chemical w�^eaathering into
saaprolite-soil and saprdlite-weathered rock, Bedrock consists of alternating units of metamorphic
schist and gneiss and; is the parent material from -which the overlying saaprolite and soils were
derived.
L? SITE SOILS
The sail in the vicinity of the site has been mapped by the USDA SCS, as shown on Figure 1-5.
Because most ofthe site was used as an industrial manufacturing facility prior to mapping by the
Soil Conservation Service, the major soil classifications ;.are disturbed soil types, The area
surrounding the plant is mapped as Urban Land (Ur). This map unit consists of areas where
pavement, buildings, or other urban land uses prevented mapping of the natural soil cover.
small part of the northeast corner of the site was mapped as Cecil -Urban land complex ( f). This
map unit covers areas of mired Urban Land (Ur) and areas with Cecil sandy clay loam soil. The
Cecil snail is a well drained sail developed can p ednMont uplands with slopes ranging from 2 to 15
percent. Typically, these soils have to surface layer of 5 inches of sandy clay lo,-iri, and more than
5 inches of real c.laa: subsoil grading downwards to as red clay loam. "I'lle subsoil is underlain by
loam, saaprolite wid weathered granitic rock...
The dominant natural ; sail type in the site area is the Tatum silt loam (Ta). This soil is as well
drained soil developed on piedmont uplands with slopes ranging from 2 to 25 percent, Typically
these sails have a surface layer of inches of brown salt loam, and nearly 35 inches of red silt}
cl;av subsoil grading to as red siltyclay loam, underlain by a mottled brownish yellow, yellowish
red, and red saa route. Below � the saprolite is weathered sericite schist or phyllita rock at variable
depths:
1.3 SAPROLITE
as rolite is unconsolidated material which is derived from in -situ weathering of the: underlying
bedrock. The saaprohte is subdivided here into two gradational zones based on the intensity of the
eochernical alteration of the parent rock.: material, The upper None, saprolite-soil, consists of soil
that retains relict structures of the original parent rock. The lower zone, saprolite-weathered
rock., consists of friable weathered rock.. The Subsurface transitions between saprolite-soil,
saaprrolite-weathered rock, and bedrock hawse been defined by the mechanical properties of
penetration resistance obtained during drilling of existing tart -site. monitor wells, Standard
penetration resistance is as peotechnicaal t s; performed during drilling operations which is used to
measure the competence or m chaaaaical strength cX ns-situ deolog c material. . aprolite-soil here:
is defined as material having a penetration resistance of less than 100 blow daunts per foot,
l~ATCCorporaiiorr ,tray° 199

FMC Corporation
Description of Site Geolog�jlHvdrogeologv
Saprolite-weathered rock is defined as material overlying bedrock with a penetration resistance
greater than or equal to 100 blow count-, per foot, The top of bedrock at the saprolite-weathered'
roc k[bedrock contact is defined as the depth at which standard soils boring techniques can not
effectively penetrate the geologic material.
The thickness of saprolite is highly variable, For example, the depth to bedrock ranges from 27
feet in, boring Wl to greater than 100 feet in borings W4 and LI (Figure 1-4). As in most of the
Piedmont, thicker profiles of saprolite develop on slopes and in valleys while thinner profiles
develop on topographic highs aud ridges
The saprolite-soil material obtained in boring samples typically consisted of fir to stiff, grange
gray to red -brown, micaceous, fine sandy silt,. The standard penetration resistance generally
increases with depth, and typically ranged between 10 to 60 blow counts per foot.
The saprolite-weathered rock obtained in boring samples typically consisted of very stiff to hard,
tan -gray -brown, micaceous fine to coarse sandy silt with gravel size fragments of weathered
rock. Standard penetration resistance generally increased with depth from 50 blow counts per
foot to greater than 100 blow counts per inch,
Since bedrock is not exposed at the ground surface on the site, relict rock, structures within the
exposed saprolite were measured to obtain a general orientation of the site geology. Relict rock
structures within saprolite-soil exposed in a drainage ditch were measured to strike North 46'
East and dip 75' Southeast.
1.4 BEDROCK
Bedrock at the site is not exposed at the ground surface but the depth to bedrock has been
inferred from on -site drilling records (see Figure 1-4). Auger refusal and penetration resistance
t,
tests can be used to identify the top of bedrock, although refusal may also result froin
encountering boulders or lenses of relatively hard rock which do not represent the top of
continuous bedrock.
A core sample of bedrock, was obtained from boring WS, The rock was a moderately hard to
hard, slightly weathered, medium dark gray to light gray, fine-grained bioLite gneiss with quartz-
feldspar bands or intrusions, Joints and healed Joints were close to very closely spaced.
Foliation was variable but typically dipped approximately 70 degrees. Accessory minerals
included chlorite, calcite, pyrite and hornblende.
1.5 SITE HYDROGEOLOGY
1.5.1 Aquifer Characteristics
Presently at the FIMC facility there are seventeen (17) monitor wells which have been drilled ran
site rangin- in depths from 20 to over 100 feet deep, Based on water level information from
these, wells", -it single water tableas hbeen defined beneath the FMC site. This is best illustrated
at wells W-2, W-4, and W-8. These three wells are grouped closely together (Figure 1-4) but are
completed at different depth and in different materials, Wells W-2 and W-4 are completed in the
saprolite-soils, whereas W-8 is completed in bedrock. Water levels in these three wells are at
nearly the same elevation and the changes in water level over time have been uniform. This
uniformity of water levels demonstrates that these three wells intercept the same aquifer. Thus,
FMC Corporation July 1993

FAIC Corporation
Descri tion afSi1 fi t,� pa r r a la, •�e
the different geologic materials at the site within the upper 100 feet are not hydrogeolo iawaally ,
separate, but react as a single. aquifer,
To date, limited hydraulic conductivity values from slug'tests of wells in the four different
geologic materials present have been obtained. Overall, the geologic materials have lower
hydraulic conductivities with the increased degrees of weathering, The measured hydraulic
conductivities obtained at the site vary over an order of magnitude, ranging from I. -4 see
.4 ftiday) to 3AxIO-3 ctaats .c (.d ftlday), Four wells corm feted in the salarolite-soil zone had
hydraulic conductivities ranging from '1.5xlo- on se.c 0.4 ft/day) to 1.6xl`1-3 crra/sec (4.5
ft/day). The average hydraulic conductivity value. obtained from the saa route -soils of
5A0lfl_,a c ni sec (1.4 ft./day) is considered to be represL,ntative of this soil zone, One hydraulic
conductivity value was determined for each of the sa rolite-weathered rock and bedrock zones.
These were 1. x 1 . crai/sec (.8 ftlday) and 3.4x 1 t1-3 craajec (. 1`11da ), respectively. These
hydraulic conductivity values are considered to be representative for the geologic: materials found
at the site.
The difference in the hydraulic conductivities of than geologic rnaaterials underlying the site are
dues to the variations in the degree of weathering. When bedrock is broken down into sail, the
minerals in than rock are reduced in size to sand;; silt and clays size particles, The soil has a lower
permeability than the bedrock, because the finer grained size material in the, sail restricts the flow
of water through than material. The bedrock permeability is controlled by than openness and
interconnectiveness of the fractures. 'Thy~ soil forming processes can clam up these fractures with
fine gained size material,
The rare tailings placed cap°er large bares of tlae site have #a hydraulic conductivity that is
significantly higher than than aprolite-soils on which it was placed, 7'he ore tailings have an
average hydraulic conductivity of approximately 1.5xlO.3 cra/sec (4.2 May). This may cause as
preferential flow of water within the ore tailings rather than in the saalarohie-soils. For areas in
which the:: water table is within the tailings, groundwater would tend to flow within the dare:
tailings rather than within thaw•: saprolite-soil.
The depth, to groundwater at the site is closely related to the: topography. In the upland d areas the
depth to groundwater is typically from 20 to 30 feet below the round surfaace. The lowland
areas have grour1dwaater rrauch nearer to the surface, typically less than 10 feet. Wells located on
the slopes had depths to groundwater that were intermediate, typically ranging from 10 to 2 feet.
I `,t 1 atr � areit cart3 July 1993

FMC ..i¢taiJ Cif BESSEMER
Cr7t T C1`
T Ta
Ur_
„ QdL4.. .... Pf
C f
r
+ aT tl
f
v a
'•Ti
oin
T
�--
... s/'
f'
'FMC PropertyFMC Property
Boundary
}
Boundary 7
tr „
r,<
E PLANATiOtiPOND
t � «yam ,
'SOIL SVIIES
. 'Drr Cold Care Tailings L.
,a
' URBAN ND$Lap
i TATUM Isar LOAM rr+f
r
4
CECtL..—URE COMPLEX :dCiira
�:.. ., °°• •.. ,:.,,.,
"
_ AL+YMANCE GAAVFLL'Y LOAM (AR)
LrTHCO PROPERrY BOUNDARY ti e map derived from map prepared
x r are$; t yr serfy rvr r �fe �s r sa by FSI
r
a DUINTIN CORPORATION Site Soils Map
nginLmkrs, Geologists, FMC S'�PORALTION- ITHI r` DnTISION
NT FA 17055
� s � : Bessemer C it r Facility
+ " T Ot : 3112 -06194 �tAe . 3/s193 � ALE 1 =1 000' F6GURE .: 1.3
w
1 23-06194

Table
'Analyses of Chemical PlantWte
Recycle Lake
SWMU o. 1
(concentration in pprn, /
Date
Li,
N
8a
4 1
fSttry
anir
06/03/88
MO
21
9
22
0 0 4 200 9
6.7
06/22/88
8.5
20.6
8.2
12.0
0.11 3.6 3.1179.1" 110.0
9.3
345.1
3.7'
6.8
6/29/88
16.1
21.9
9.5
13.1
0.1 4.1 3.4 178.0 90.0
9.4
336.3
5.0
6.2
7/06/88
16.1
22
10
13
0.2 4 3 178 98
9.4
336.3
5.0
6.
07/13/ 8
21.9
19.1
3.4
17.2
0.2 2.9 4.0 170.3 110.0
8.8
35,4.0
5.8
6.7
09/07/88
18.4
34.8
13.4
29.4
9.0 3.6 3.1 180.1" MO
9.1
352,7
8.7
5.
09/25/88
22.7
29.5
12.3
17.8
0.2 3.5 2.8 180.4 110
8.9
359.
8.5
6.
average
19.7
24.1
10.1
17.8
0.1 3.1 3.3 178.0 35.7
9.2
350.9
5.6
5.4

Table, 1
B
Analyses of IOn Dust Particulate Scrubber Water.
1V W No, 1 and SVVMU No. 6
onct.ntratiurss in ppns (mg/1)
SAMPLE
Bate
Ai
As
so
Be
Ca
Cd
Cr Fc #V � li M
Nn
Ne .
tia"
Pk
Si
A
�
St
Sulfate
Kiln Scrubber
Pond (water)
5/85
980
NA
NA
NA
180
NA
1.5 330 NA, 87. NA 28t1
220
220
2.5
0.2
NA
NA
160D
WA
24DO WA
Kiln .Scrubber'
Pond (water)
11188
626
WD
t1 B9
0.78
8.27
MA
1.74 328 ND 105- 109 26.2
205
44.8
2.0
N2
396
NA
NA
NA
1015 3.1
Kiln Scrvbbef'
Pond (filtered)
11785
627
ND
0.09
0.78
8.46
NA
1.74 331 No 1D7 110 26.7
ZO8
44„9
2.0
N6
404
NA
NA
NA
1110 3.1
Kiln Scrubber
Discharge Pipe.
3189
836
NA
NA
1„0
68
NA
1.0 287 NA 114 121 45
242
72
2.8
NA
447
NA
NA
NA
1646 2.
NA Not .Anaiyted
No Not Detected
i

W2 W3 W4 WS wrl W7 WR Ars WIG WIi wI2 Ll LZ L3 L4 LS
9841 Vlij V11 R801
G RD U N 0 SU R PAC F.71'A 172,7
867.4
BOA
2 W'7
FA
127,3 A
'p,
Raring
847.9
..iN red
RMS
A.Wf T—iiauhl
-4
A'f—t 30
SCALE: I INCH 15 FEET
879.5 E.171
903.1 MI.
77
Ref —I
Tih.ivaled
go
VIM
T,1,4,v1td
at&
OR CC
TIAIUNGS SCTy Fine SAND, tight tan, very lonfre to Pent
Penetration Rayietance loss than or equal 10 10 Blows For I in -
root
FILL Clayey SILT,?ed, sIff 615.4-
Perwritualien Rganitance ies,% umn or equal to 20 Browo per
A09- 004,5
Foot swirl
Tftrwrattd
Fine to Carron Sway SILT with grave, I site lieoffirelt' 0
SAPROLITE 802.3 SOIL
weathered rock, rnicaccous, fed brown, tan, FM gray, stiff at sofirl
to hard G wxd GEOLOOIC INFORMATION ADAPTED FROM LAW
Penetration Assistance lrr,s. Lon 100 Slows per Foot 0, RI ctort To ENGINEERING REPORTS OF 615/85, 8114/87, S/13/88,
S, PROLITE- 9a a ar 8 xkAND 7131 P89.
VVFATHFAED Silty Fibs 1. pirdhim SAND with gravel site fraemms Of
ROCK roolcand mreXheIednyJ(, tin, Erased, and gray,, hard ALL MONITORING WELLS ARECONSTRUCTED OF 2 INCH
.W'O
ion
ponarrat Resistance greater than or equal to 100 Slows �J SCHEDULE 40 PVC PIPEAND 10 FOOT MANUFACTURED
per Foot
WELL SCREEN 17H 0.010 INCH WIDE OPENING*
' Rock Cored Saortrie (Boring Wil) -Fino-Gnant,d 00610
GNTISS wit) 03aozFofptqrm Brands or intrusions, medium 17 5 1
BEDROCK
dark gray to I�ght gray, modo-raloly handle hald-049110Y
w osad to very closety P
;
wramarod. jorrits and healed tternsare r l
spaced. FoRfation varies' but Miicaty dips about 70 degrees. T"mirwtd
Acresnory myfPnds hdude chfoate, Celdle, Pfrdlie, and
hornistenda a.kq
Chl. TV
Water sorean Irdervat
NOTE:
Sections dezivod frotil map prKpared
879�0� Water Level Mnasufod on Z12WO
by ES1. DUNN CORPORATION sluilmary Of Geulogic Inforzk1boll Froln
LnF EO'rrMr"""'d4 17,xistirrp, Ori-Sile Boreholes/WcHs
L
FMC CORPORAJIONIT 1111UM VJVTSIOJ
r^,"64N 1A

DIVISION OF ENVIRONMENTAL
March 1996
CERTIFIrdQ_MUL
E
FMC Corporation/Lithium Division
Highway 161
Post Office Box 795
Bessemer City, north Carolina 28016
Attention. Quentin G. Hopkins
Subject. Notice of Regulatory Requirements
Fmc corporation/Lithium Division
NO Permit W WQ0008149
Gaston County,
Dear Mr. Hopkins
The roun at Section of the Mooresville Regional Office
received the Design n Report: m d a ion of kiln Scrubber
Pond on February 15,; 1996. The report has been reviewed and will
remain on file in this office.
The following comments are based on a review of the report.
1 agrees with FMC's proposal to install
natural clay liner in the eastern kiln scrubber pond.
2. The "naturally -deposited clay" at the base of the
eastern kiln scrubber pond will be considered
sufficient if it meets the specifications outlined In
Commission - Rule 15A NCAC 2H . 21 ( Please note that
a certification must be received by this office from a
professional engineer er for the eastern pond . in
accordance with Commission Rule 155..0220.
. If there is insufficient clay on -site, FMC must
acquire a sufficient quantity of clay to complete the
project.
919 North Main; Street,
Mooresville, North Carolina 28115
Voice704-663-1699
mer; paper

�� � aa- «a • � � a a ffi
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a
a., • .»a a N � aa� * a aaa � a
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a a s � ;,, a • � r * a a �
a � • w a • � sa a � � a a .. � a «'
. a _ a wa a a-. a a • a
a a -a a a a ♦ � � a a s� •
r a a a a a * •

FMC Corporation/LithiumDivision'
March 5, 1996
Fagg Three
Your failure to respond within the time specified and to
voluntarily achieve compliance may result in a recommendation
from the Mooresville Office to the Director for the assessment of
civil penalties in accordance with G.S. 14 1 . until such
time that the above sated information is received in this
office, you will: remain in violation of North Carolina law. You
should note that any enforcement action, including assessment of
civil penalties, 'may begin from the original due date established
in the October 27, 1995 Notice.
Your questions should be directed to Steven Bbgrad, or me in
the Mooresville Regional office at 4663-1699.
sincerely,
Z2-C'-'4-
B. ith`rca h,P.E.
l Supervisor EEmcinal.ncr
cc .,,.l a cn';�- MRO Water Quality Section
Bob Cheer - permits and Compliance (Raleigh)
Gaston County Environmental Health
Barbara Ritchie c per tion ' ithiu-m Division

FState of North Carolina
Department of Environment,
Healthto l Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Dyne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
October 1 , 19'7 }
} t
z N Wt
Subject, permit No. WQ0014006
City of Bessemer City
FMC-Lithiurn
Sewer Extension
Gaston County
Dear Tr. Messera
In accordance with your application received June 17, 1997, we are forwarding herewith Permit
No. WQ0014006 dated October 15, 1997, to the Cavity of Bessemer City for the construction and operation
of the subject wastewater collection extension. ,
This permit shall be effective from the date of issuance until rescinded and sell be subject to the
conditions and limitations as specified therein. Please note condition number I I(a), which states that
pump on/off elevations should be located so that 2-8 pumping circles may be achieved per hour in the
pump station;
f and, parts, requirements, or limitations contained in this permit are unacceptable, you have the
right to request an a judicatory hearing upon written request within thirty (30) days following receipt of
this permit. This request must be in the forum of a written petition, conforming to Chapter 150B of the
North Carolina General Statutes, and filed with the Office of Administrative Hearings, P.0, Drawer
, Raleigh, NC 711-7 7. Unless such demands are made this permit shall be final and binding,
One set of approved plans and specifications is being forwarded to you. If you need additional
info ration concerning this matter, please contact Matt Williams at 919) 733-5083 extension 509.
sincerely
/,. Preston Howard, Jr., P.E.
Ralph S. l' tessera, City Manager
City of Bessemer City
132 West Virginia ini enue
Bessemer City, forth Carolina 01
Gaston County Health Department
M,00resville,Regiotud°, titer Quality tin
Hazen & Sawyer, P.C., Mr. Ralph L. Waters, P,E,
P,o, Box 29535, Raleigh, North Carolina 75 5-05 5 Telephone (91 ) 733-508 FAX �919) 33-071
n Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post. conurn r paper

ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
RALEIGH
WASTEWATER LLECT"IO PERMIT
In accordance with the provisions of Article 21 of Chapter 143, General Statutes of North Carolina as
amended, and other applicable Laws, Rules, and Regulations
PERMISSION IS HEREBY GRANTEDT
Clity of Bessemer Clity
Gaston County
FOR T14E
construction and operation of approximately 492 linear feet of 8, inch gravity sewer, a 122 GPMpump
station with duplex pumps, dual power sources from different electrical substations, on -site audible and
visual high water alarms, and approximately 1 linear feet of 4 inch fierce main to serve 45 employees
for FM -Lithium, and the discharge of 1,125 GPDof collected domestic wastewater into the City of
Bessemer City "s existing sewerage system, pursuant to the application received June 17, 1997, and in
conformity with the project plan, specifications, and other supporting data subsequently filed and
approved by the Department of Environment, health and Natural Resources and considered a part of this
permit.
This permit shall be effective from the date of issuance until rescinded and shall be subject to the
following specified conditions and i Cations:
I. This permit shall become voidable unless the facilities are constructed in accordance with the
conditions of this permit, the approved pans and specifications, and other supporting data
_.. 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 must be properly maintained and operated at all times.
4. The sewage and wastewater collected by this system shall be treated in the City�of Bessemer City
Wastewater Treatment Facility prior to being discharged into the receiving stream.
This permit is not transferable. In the event there is a desire for the facilities to change ownership,
or there is a name change of the Permitice, 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 materials as may be appropriate. The approvalof this
request will be considered on its merits and may or may not be approved.
6, Construction of the sewers, pump station(s) and force main shall be scheduled so as not to
interrupt service by the existing utilities nor result in an overflow or bypass discharge of
wastewater to the surface waters of the State.

7. Upon completion of construction and prior to operation of this pennitted facility, a certification
must be received from a professional engineer certifying that the permitted facility has been
installed in accordance with this permit, the approved plans and specifications, and other
supporting materials. Mail the Certification to the Non -Discharge isch e Permitting unit, P.O. Box
, Raleigh, NC 27626-0535,
copy of the approved plans and specifications shall be maintained on file by the Permittee for a
minimum of five years from the date of the completion of construction.
w 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 1
1. to 1-1.6.
10, 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) wf ch have jurisdiction.,
11. The, lie 'tree shall provide for the pump station and force rain the following items
a. Pump on/off elevations located so that 2-8 pumping cycles may be achieved per hour in the
pump station,
b. An air relief valve located at all high points along the force
c. A screened vent for the wet well,
d. Fillets located in the wet well at the intersection of the flooring and sidewalls,
e. Three feet of cover (minimum) over the farce gain or the use of ferrous material where three
feet cannot be maintained,
f', Sufficient devices which will protect the pump station from vandals, and
. Flood protection if the pump station is located below the 1 -year flood elevation.
12. In the event that the facilities fail to perform satisfactorily, including the creation of nuisance
conditions, the Permittee shall tale immediate corrective action, including those as mayberequired
by this Division, such as the construction of additional or replacement wastewater collection
facilities,
2

Permit issued this the 1 th day of October, 1997 Iq
NORT14 C INA ENVIRONMENTAL MANAGEMENT COMMISSION
A. Preston Howard, Jr., P,E., Director
Divisi n of Water Quality
By Authority of the Environmental Management ri of

Pe it 1 .l4006
Oct ' October 1 , 1997
s a duly registered Pr fess nal Engineer its <t e State of North
Carolina, having been authorized to observe (periodically, weekly, fall time) the construction of the
project, _ for the
Project NameLocation
Perm,ittee hereby state that, to the best of my abilities, due care and diligence was used in the observation
of the construction such that the construction observed to be built within substantial compliance d
intent of this permit, the approved plants and specifications, and othersupporting materials.
Signature Registration No.
Date
i

ppppp"-
State of North Carolina
Department of Environment,
Health and Natural Resources
Mooresville giona� Office
James B. Hunt, Jr. Governor
Jonathan B, Howes, Secretary
"�"
.. 4,1: y
NW'A
DIVISION OF ENVIRONMENTAL MANAGEMENT
December , 1995
P Notice of Violation
15A NCAC 2L Classifications and 'dater
Quality Standards Applicable to the
Groundwaters`
FMC Corporation/Lithium i i ica
Non -Discharge Permit W WQ0008149
Gaston County, N.C.
Dear Ms. Ritchie
On October 31, 1995, FMC Corporation/Lithium Division
received a Notice of Violation (NOV) of the North Carolina
groundwater standards. You were requested to install a monitor
well at the compliance boundary downgradient from MWI andsubmit
analytical results for a water sample collected from the
monitoring well. The results were due by December 15, 1995.
file the October 27, 1995 NOVoutlined steps necessary to bring
the subject site into regulatory compliance with Commission Rule
15A NCAC 2L . l (d), this Notice documents a violation of 1
c .0106(b).
Dearing two meetings between FMC Corporation/Lithium Division
and staff of the MooresvilleRegional Office :on November 9, 1995
and December 7, 1e9, it was demonstrated that the permitted
activities are a continuing source of contamination. In order to
control the source in accordance with Commission Rule 15A NCAC 2L_
. 1 (b), it was agreed that a schedule for lining the permitted
ponds was acceptable in lieu of submitting the analytical results
required in the October er , 1995 NOV. on December 15, 1995, FMC
919 hearth Main street, Moor sviCl . North Corolina 28115 Telephone [phone] FAX [phone]
An Eglu ai Opportunity Affirmative Acticn Etnpoyer Ci% recycfed/ icmx� Doo-consumer paper

FMC Corporation/Lithium Division
December 20, 1995
Page Two
Corporation/Lithium ivi ion verbally requested an extension for
submitting the schedule until February 15, 1996.
You are requested to submit a schedule for implementation o
the chosen method of abatement by no later than February ,
1996. The chosen method, of abatement shall completed by no
later than dune 15, 1996. Your failure e to respond within the
time specified and to voluntarily achieve compliance may result
in a recommendation from the Mooresville office to the Director
of the Division for the assessment of civil penalties in
accordance with G.S. 143-215.6A or in a request to the Attorney
General to institute an action for injunctive relief. Until such
time that the above requested information is received in this
Office, you will remain in violation of iotaCarolina lava. You
should note that and enforcement action, including assessment of
civil penalties, may begin from the original due date,established
in the October 7, 1995 Notice.
Your questions should be directed to Steven Bograd or me in
the Mooresville Regional office at ( .
Sincerely,
B. Keith 0
Regional supervisor
oo» Rex Gleason - Mooresville Water` ualit Section
BobCheek Permits and Compliance Unit, Raleigh
set

State of North Carolina
Department of Environment,
Health and Natural alResources
Mooresvil�e Regionai office
James B. bunt, Jr.. Governor
Jonathan B, Howes., Secretary
DIVISION OF EMIRONMENTAL MANAGEMENT
October , 1995
1i I
I ° U a
FMC corporation/Lithium Division
Past office Box795
Bessemer City, North Carolina 28016
Attention: Ms. Barbara Ritchie
Notice of Violation
A NCAC 2L Classifications and
Water Quali,ty Standards Applicable
to the Groundwaters
FMC Corporation/ Li s ►ivi .o
Non -Discharge Batt W wQO00814:9
Gaston County, N.C.
q ,�^..t 6 9 VAX 704 6 �-,, }04 i4
a r��it�- �"vfB'�ii t $e��. rv��7+" ark+ r�. �� t �k�?isil'� „�+� ? Telephone�.,
5ca r .: C:`y. led ..jai

FTC Corporation/Lithium Di i ion
Page Two
Specific constituents which are exceeding the groundwater
standards are as follows:
Constitute
Date SampjoC'; ne n ion ' i t °lnol a
sulfate 5/1/95 1,
sulfate 1,300 250
aluminum 5/1/95 15.8 BQ
aluminum 8/30/95 14.E BQL
calcium 8/30/95 80 BQL
iron 5/1/95 3.1
iron 8/30/95 1.18 0.3
manganese s / 1 / . l 0.05
manganese 8/30/95 36 0.05
flouri de 5/1/95 2.4 2.0
lithium 5/1/95 14.6 Q
lithium / 0/ 11.
"DS 8/30/95 2,10
*Concentrations reported in parts per million
D Total dissolved solid
BQ - Below olua tit tion limit
n accordance with Permit Condition W 11 and based on the
levels of contaminants reported in 1, the intent to continue
operating the western kiln pond until late 1997 and the fact that
the ponds are not lined, you are requested to install; one
monitoring well at the compliance boundary o wno r die t from
-1; This well shill be sampled and analyzed for the parameters
listed in the subject permit.
The analytical: results from the monitoring well at the
compliance boundary mist he submitted within forty five 4 s
of receipt of this letter:
Commission Rule 1 A NCAC 2L . 10 (d) states
Any erson conducting or controlling an activity which
results in an increase in the concentration of
substance in excess of the groundwater standards as
result of activities conducted under the authority of
permit 'issued by the state, shall, where such

Sincerely,
B. Faith Overcash, P.E.
Regional Supervisor
cc: Bob Cheek, Permits and Compliance ill
Rex Gleason, Mooresville Water Quality Section

i
State at North Carolina
Department at Environment,
Health and Natural Resources
Mooresville RegionalOffice
James B. Hunt, Jr- Governor
Jonathan B. Howes, Secretary`
Linda Diane Long, Regional Manager
DIVISION OFENVIRONMENTAL MANAGEMENT
July 17, 199i
ERIIE>h 1
RETURN RECEIPT ]REQUESTED
FMC Corporation/LithiumDivision
Fort Office Box 795
Bessemer City, North Carolina 28016
Attention . E. McLeod,` Plant Manager
E : Notice of Regulatory Requirements
of Permit Conditions
Permit WQ0008149/GW94251
Gaston County, N.C.
Dear Mr. McLeod
A review of the subject`pe it and results of compliance
monitoring data for December 8, 1994 and May 1, 1995 indicate
that the following parameters exceed standards established in 1
N A t
R
Total Dissolved Solids
Sulfate
Aluminum
Calcium
Iron
Manganese
Fluoride
Lithium
In addition, FMC suggested in two letters dated February r l
1995 and prune 2, 1999 that excessive levelof the parameters
listed above may be related to turbidity in both wells.
Please be aware that Permit Condition Number 20 states that,
"Each well shall be developed such that the level of turbidity o
settleable solids sloes not preclude accurate chemical analyses of
any fluid samples collected." Pursuant to this condition you are
required to reduce the turbidity in well WQ1 and WQ2 to levels
that will not affect the analyses. This may be accomplished by:
919 North Main street, Mooresville, North Carolina 28115 Telephone [phone] PAX ,663- 040
n Erna. d Opportunity Aftmative Action Employer 50 recycled/ 10 roost -consumer paper

FMC Corporation/Lithium Division
July 17, 1995
Page Two
1. Repairing the existing wells; or,
2. Adjusting sampling techniques.
A possible alternative is to abandon WQ1 and WQ2 and install
two new wells. If this, course of action is followed the
placement, construction and monitoring of new wells must be in
accordance with the subject permit.
,If the problem is not corrected, or August compliance
monitoring results indicate analyzed parameters continue to
exceed standards, a Notice of Violation of Permit Conditions will
be issued. Please be advised that FMC should not wait for the
completion of the RCRA Facility Investigation to be concluded
before addressing this matter.
It should be noted that the violations cited above and any
additional documented violations could result in the initiation
of an enforcement action by this Office in accordance with
General Statute 143.215.6A, which provides for a $10,000
assessment of civil penalties for each violation. Each day that
the violations continue may be considered a separate violation.
should you have any questions concerning this Notice,
contact Steven Bograd at [phone], ext. 241.
Sincerely,
B. eith Overcash, P.E.
it Re ional Supervisor
SEA
cc: Rex Gleason - Mooresville Water Quality Section
Bob Cheek - Permits and Compliance Unit, Raleigh

•
Mr. J. E. McLeod, plant Manager
January 1, 1 4,.
A .
Gaston County Health
Mooresville gi dal Office, Water Quality SeCtiOn
Mooresville gional office, Groundwater Section
Jack: Floyd, Groundwater Section, Central Office
`raining and Certification Unit no revised rating
Facilities Assessment Unit
p. . Box 29535, Raleigh, forth Carolina 27626-0535 Telephone [phone] F 919-733-249
n Equal Opportunity Affirmative ,fiction Employer 50% recyclecV 1 °lam p st n urrrer paper

FNORTH CAROLINA
ENVIRONMENTAL MANAGEM N"T COMMISSION
DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
RALEIGH
RECYCLE SYSTEM PERMIT
In accordance with the provisions of Article 21 of Chapter 143, General Statutes of North Carolina as
ended, and other applicable. Laws, Rules, and Regulations
PERMISSION IS HEREBY GRANTED
FMC Corporation / Lithium iv io
Gaston County
x
This permit shall be effective from the date
000814 + issued June 14, 1994, and sell be
limitations:
of issuance until May 31, 199% shall void Permit No.
subject to & "owing specified conditions and
In the event that the facilities fail to perform satisfactorily, including the creation of
nuisance conditions, the PermitPermittee shall take immediate corrective, action, including those as
may be required i Division, n, such as the construction of additional or replacement
wastewater treatment or disposal facilities..
t

6. The sludge generated from these treatment facilities must be disposed of in accordance with
General Statute 143-215.1 and in a manner approved by the, North Carolina Division of
Environmental Management.
9. Diversion or bypassing of untreated wastewater from the treatment facilities is prohibited.
10. Freeboard in the two (2) lagoons shall not be less than two feet at any time.
IL Any monitoring deemed necessary by the Division of Environmental Management to insure,
surface and ground water protection will be established and an acceptable sampling
reporting schedule shall be followed.
12. Adequate inspection, maintenance, and cleaning shall be provided by the Pertnittee to
insure proper operation of the subject facilities.
17. The issuance of this permit does not preclude the Permittee from complying with any and
all statutes, rules, regulations, or ordinances which may be imposed by other government
agencies (local, state, and federal) which have jurisdiction.
M A set of approved plans and specifications for the subject project must be retained by the
Permittee for the life of this project.
2

F
1,9. Noticompliance N6dfkkl6n.-
& My time that self�motmoting inframadori indicates dig the facility is not in compliance
With its permit limitations,
20�
2L Monitor wells WQ- I and WQ-7 shall be identified for purposes of this permit as "WQ-I ",
and "WQ-2" aka, W-7. Monitor well WQ-1 shall be sampled initially after construction.
Monitor wells WQ- I and WQ-2 shall be sampled every April, August, and December for
the following parameters:
Calcium Aluminum*
TDS Sulfate
pH Water Uvel
Chloride Fluoride
Chromium* Manganese*
Iron* Lithium*
* use method 3030C, preparation for metals, in Standards Methods, 17th edition
The measurement of water levels must be made prior to sampling for the remaining
parameters, The depth of water in each well shall be measured from the surveyed point on
the top of casing,
The measuring points (top of well casing) of all monitoring wells shall be surveyed to
provide relative elevations of the measuring point for each monitoring well.
3

22.
2,
4.
2.
the location and identity of each monitoring weU,
h. the location of the waste disposal system,
c � the location of all property boundaries,
d , the latitude and longitude of each monitoring Drell,
e. the relative. elevation f the top f the well casing (which shall be
�+rn as the
"rheas r" point"),
# . the depth of water below the measuring point at the time the measuring point
is
established,
Is

2& Upon classification of the facility by the Certification Commission, the Permittee shall
employ a certified wastewater treatment plant operator to be in responsible charge l of
the wastewater treatment facilities. The operator roust hold a certificate of the type and
grade at least equivalent to or greater than the classification assined to the wastewater
treatment facilities by the Certification Commission. :The Permittee roust also employ a
certified back-up operator of the appropriate type and grade to comply with the conditions
of "Tine I S. , Chapter 8A,.0202. e ORC of the facility roust visit each Class I facility at
least weekly and each Class 11, 1111, and IV facility at least daily, excluding weekends and
holidays, and roust properly manage and document daily operation and maintenance of the
facility and roust comply with all other conditions of Title 15 A, Chapter 8A, .22
29, The Permittee, at least six o months prior to the expiration of this permit, shall request its
extension. Ripon 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 seventeenth day of January, 1995
NORTH CAROLINAI AGE COMMISSION
— I L, cc"", ._ . >' _,
f A. FrestonOnvirot
ward,Jr., R , Director
ivision ofenttlanagement
y authority of the Environmental Management Commission
Permit Number WQ0008149

FState of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary 1111*4 F=1
A. Preston Howard, Jr., P.E., Director
May 6,1994
RNTVIRoNmi,"'O"
ONA',M1,"AL
To: Ted Bush
Assistant Chief for Operations
Groundwater Section
From: Coleen H. Sullii'S'
Supervisor, Permits and Engineering Unit
Water Quality Section
Subject. Adjudication for.
FMC Corporation/Lithium Division
WQ0008149
Gaston County
Attached are comments from FMC Corporation dated May 2, 1994 in reference to the draft permit
dated April 11, 1994. Please review the objections to the draft permit and forward comments to this office
no later than Friday May 13, 1994.
If you have any questions regarding this matter, please contact Angela Y. Griffin at (919) 733-
5083, ext. 554.
CC. Mooresville Regional office, Water Quality Supervisorl FYI
Attorney Generals Office, Kathy Cooper
Attorney Generals Office, Elizabeth R. Mosley
Permit File WQ0008149
P,O. Box 295,35, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Atfirmative Action Employer scyn/0 racycledi i a*/* poet -consurnet paper

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B
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VIA FAX & REGULARI
may 2, 1994
Department of Environment, Health
and natural Resources
Division of Environmental Management
Water Quality Section
P.O. Hoer 29535
Raleigh, NC 27626-0535
,Attn:: Colleen Sullins, .Supervisor '4
Permits and Engineering
e: FMC Corporation Lithium Division
Bessemer City, Gaston County
Comments on Draft Water Qualit Permit not WQ0008149
Dear Ms. Sullins
rMC Corporation'sLithium Division facility in Bessemer City
" mC" has received the north Carolina Department of
Environment- Health, and natural Resources „ n ") letter dated
April 11 14 which transmitted a draft of "dater Quality permit
No WQ0008149. This draft was issued following discussions
between FMC andnR which have occurred in response to 'n 's
Petition for Contested Case Hearing tiled pursuant to Water
Quality Permit No. wQ0008149 dated November 29, 1993. 3. take
this opportunity to thank DEHNR for its continued cooperation in
attempting to resolve this matter through informal conference i
accordance with NCGS 1B-.

DEHNR Water Quality Section
Comments on Draft Permit wQO008149
May 2, 14 Page
imp
w
m
w - « ��� a •�
m

DEHNR water Quality Section
Comments on Draft Permit wQO008149'
May 2, 14 - Page
parameters listed in draft permit No. wQO008149. However, the
analytical methods specified in the RFI work plan are not those
specified in draft permit No. w00008149. Specifically, the RFIa.
requires the followings
Parameter Analytical Method 'Reference
PH Method 940 (1y
Chloride Method 325.3
Chromium method 6010 (1)
Sulfate Method 375.4
Fluoride method 340.2 (2)
Lithium method 6010 (1)
1) Test. Methods for Evaluating
Analysis riteters (SW-84and stesrd d.
(% Methods for Chemical Ana
(EPA-600/4-79-020)
ater Quality Permit No. WQ0008149 specifies that all analytical
data he based on "'preparation for metals method. 3030C in Standard
methods, 17th edition," FMC requests that DEHNR review this
specification as the method cited is not applicable to all
parameters, i.e., physical: characteristics and nonmetallic
inorganic constituents, listed in water Quality Permit o. WQ
814_
FMC also requests clarification as to the applicability of this
permit condition to analytical results obtained under the RF1
using methods different than those specified in the permit.

DEHNR water Quality Section
Comments on Draft Permit WQ0008149
May 2, 1994 - Page 4
Second, it was rs understanding that previous environmental
staff had reviewedthelocation; of wells to be installed under
the RFI program with DEHNR staff developingthese permit
conditions; these locations had not been re -reviewed by current
staff. However, in assembling these comments, FMC has revisited
the review of locations for groundwater wells associated with the.
kilnponds: as described in the RF1 word plan, the wells
installed pursuant to that work plan, and the location of the
proposed wells referenced in this item._ Unfortunately, them
appears to have been some misunderstanding with respect to these
locations. The two wells which were installed in accordance with.
the R T program to investigate the kiln ponds, DC-1 and -2, are
located within 30-40 :feet of the ponds. A copyof a section n f
the site plan from the RFI work plan is included here as
Attachment 2 This site plan section is helpful inn<that the
predicted groundwater gradient is shown along with major
structures in the area. The locations of the two wells proposed
in WQ0008149, as shown on Attachment, are about 125 feet from the
ponds.
Third, the purpose of including 7 in this permit is unclear.
The well is too far removed from the ponds to be relevant and
hydroeology north of the ponds is not sufficiently defined to
even assure that this is upgradient of the ponds. Further, as
the permit is written to evaluate compliance via comparison of
downg adient water quality at specified boundaries versus NC
groundwater standards, the inclusion of monitoring requirements
for W 7 is not justified.
FMC proposes that the sketch included here as Attachment 3 be
considered as the appropriate locations for the "boundaries and
monitoring wells relevant to this permit any that references to
e removed from this permit. most be muted that the well
proposed as 2 has not been solaced directly on the Review
Boundary as at the dowrngradient point central most to the western
kiln pond, the Review Boundary falls on a major plant roadway.
w-2 has been moved beyond the roadway as is necessary for safety
and well easing integrity.) Further, if this proposal is
acceptable to DEHNR, FMC notes that the comments shown above for
Item 1.9d are directly relevant to data collected in the RFI
wells, TIC'-1 and -2

DEHNR rater Quality Section
Comments on Draft Permit w00008149
May 2, 19 - page
pace " item 1 - FMC suggests the following language:
""it, based on the monitoring programscribe in item 20,
above, the per ittee finds that ground
wates Boundary exceed the standards promulgated at 15A NCAC
.0202, the permittee shall follow the provisions for
Noncompliance Notification, as described in item 19, above.
Additionally, pe mitt e shall comply with the pr vtisions of
1 A NCAC 2L .0106 regarding Corrective ,fiction.
permittee's Corrective Action plan includes provisions for
the continued operation of one or both of the kiln ponds, a
schedule to install a liner in the pond(s) which complies
with the Minimum Design Requirements at 15A NCAc 2H .0219
small be included in the Corrective Action plan."
is e , item "M objects to this language as being overly
roa and dup icative of item S n this permit.
a es sand 5, Items l throu h 4hese items h commentserespoodnle
so long as FMC's 'propose ecr e
to '"Page , Item,"" is acceptable to �« �iR. lt�t is pe i u
were to reference wells previously installed, e.g ,
-, these conditions are inappropriate.
Page 5, item 29 - FmC requests that it be notified of the cla sitibatibn of the facility by the Certification Commission
and e granted a_sufficient time eriod to locate a certified
wastewater treatment plant operator, or, more lively, have one of
its employees with responsibility
r kiln
scrubber
rubbr r oiler bons`
ro.
historically` an air pollution co �
operation of a wastewater treatment system.
pmc otters to meet with you and your Matt to clarify these
comments and attempt to resolve any other isstes which could life
may
require further dialog. It you y g
to schedule such a meeting, please contact me at 868 06
ver I truly yours,
Barbara E. Ritchie
Environmental Manager
cc.- JE McLeod - FM
Rex Gleason - DEHNR, water Quality Section, Mooresville

- - - -- -----
F NI C C o r
T
orr
P 94
4FMC
VIA FAX & REGULAR MAIL
May 2, 1994
Department of Environment, Health,
and Natural Resources
Division of Environmental management
Water Quality Section
P.O. Box 29535
Raleigh, NC 27626-0535
Attn: Colleen Sullins, Supervisor
Permits and Engineering
Re: FMC Corporation Lithium Division
Bessemer City, Gaston County
Comments on Draft Water Quality Permit No. WQ0008149
Dear Ms. Sullins:
AS requested in the DEHNR transmittal letter, FMC is providing
comments on the draft permit to DEHNR by may 2. Unfortunately,
until the concerns enumerated in these comments are resolved, FMC
cannot withdrawal its Petition for Contested Case Hearing.
Nonetheless, the majority of these comments concerns
administrative issues with respect to the permit language and FMC
is still quite hopeful that this matter can be resolved without a
formal hearing.
The following comments are generally arranged to follow
sequentially through the DEHNR April 11 letter and the attached
draft permit.

r
DEHNR Water Quality Section
Comments on Draft Permit 'WQ0008149
may 2, 1994 - Page 2
Transmittal letter
"Response 11' - FMC understands that the DEHNR has interpreted the
cite-d —statues to apply to FMC1s kiln scrubber system, however,
FMC takes this opportunity to request further clarification of
NCGS 143-213(18b) where the definition of "industrial waste"
relies upon the term "waste." FM C has questioned the scope of
this definition as kiln scrubber water recirculates through the
system and it is not clear to FMC that this is a waste. Under
other statutory interpretations, the solids which precipitate in
the kiln ponds would not be considered a waste until removed from
the kiln ponds. FMC is not questioning DEHNR's authority to
interpret the cited statutes but rather seeks clarification of
this key term, "waste", in order to better allow for continued
compliance with applicable laws and regulations.
Draft Permit No. WQ0008149
?Age 1 - FMC requests that the the description of the permitted
system be modified as follows: "operation of a
wastewater recycle system consisting of two (2) —par—allel
scrubbing towers, scrubber water processing tanks, and two (2)
1.1 acre kiln ponds. , . 11 FM C has implam e ' o
nted varius projects to
return collected solids (product) to the kiln, most notably the
installation of a thickener tank upstream of the kiln ponds, and
requests that the identification of specific scrubber water
processing tanks be omitted to allow for the operational
flexibility which is necessary to pilot and implement such
projects in the future.
EAEe I - FMC believes that the issue and expiration dates for
this permit should be revised to reflect the (future) date of
resolution of FMC's petition for contested case hearing.
Page 2, Item 10 - The correct number of lagoons is two (2) now
that 'the k&D pond has been removed from this permit.
Page 3, Item 19d -'This condition refers to self -monitoring. As
DEHNR is aware, FMC is conducting a RCRA Facility Investigation
("RFI") under the direction of US EPA Region IV and DEHNR,
Division of Solid Waste. FMC is and will be sampling groundwater
wells at this site according to its approved RFI Work Plan and in
doing so, will sample wells near the kiln ponds for some of the

DEHNR Water Quality Section
Comments on Draft Permit WQ0008149
May 2, 1994 - Page 3
parameters listed in draf't permit No. WQ0008149. However, the
analytical methods specified in the RFI work plan are not those
specified in draft permit No. WQ0008149. Specifically, the RFI
requires the following:
Parameter Analytical method Reference
pH method 9040 (1)
Chloride Method 325.3 (2)
Chromium Method 6010 (1)
Sulfate Method 375.4 (2)
Fluoride Method 340.2 (2)
Lithium Method 6010 (1)
(1) Test methods for Evaluating Solid Waste (SW-846, 3rd ed.)
(2) methods for Chemical Analysis of Waters and Wastes
(EPA-600/4-79-020)
FMC also requests clarification as to the applicability of this
permit condition to analytical results obtained under the RPI
using methods different than those specified in the permit.
@

DEHNR Water Quality Section
Comments on Draft Permit WQ0008149
May 2, 1994 - Page 4

DEHNR Water Quality Section
Comments on Draft Permit WQ0008149
May 2, 1994 - Page 5
fAlt 3, item 21 - FMC suggests the following language:
Page 4, Item 22 - FMC objects to this language as being overly
broad end -duplicative of item 8 in this permit,
Pages 4_and 5,, Items 23 through 27 - These items are acceptable
so long as FMC's proposil, described in the comments responding
to "Page 3, Item 20," is acceptable to DEHNR. If this permit
were to reference wells previously installed, e.g., W-7, DC-1 or
DC-2, these conditions are inappropriate.
Page 5, Item 29 - FMC requests that it be notified of the
classification of the facility by the Certification Commission
and be granted a sufficient time period to locate a certified
wastewater treatment plant operator, or more likely, have one of
its employees with responsibility for kiln scrubber operations,
historically an air pollution control system, certified for
operation of a wastewater treatment system.
FMC offers to meet with you and your staff to clarify these
comments and attempt to resolve any other issues which may
require further dialog. If you have any questions or would like
to schedule such a meeting, please contact me at 704/868-0806.
Very truly yours,,
Barbara E. Ritchie
Environmental Manager
cc: JE McLeod - FMC
Rex Gleason - DEHNR, Water Quality Section, Mooresville

CO)
C') -z'
Vve
Ox
G)
C-oki tie Ito vir
lk
Vd

State of rtr lin
Department of Environment,
Health and Natural Resources
Division n iron ntal Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., ., Director
Dear Mr. Mc
-
,C. nwrr" o
IFTEALTIT
k.f } TUk,,u-, R, ,So pjq,,;re
P, 1
IVIS!Ilk R I R-UKtI=a T 151 1r [,
MI
1€ IRSVILLE IREGIGHAL OfFICE
Subject: Permit No. WQ0008149
FMC Corporation, Lithium Division
Wastewater Recycle ,System
Gaston County
Response 1 e North Carolina General ,Statute siting which specifies that air pollution control
systems are regulated and permitted cinder 1 CSC 2H .0200 is found in
sections 1 13- 1 . a which define activities for which a Permit isrequired-
This citing states that if a person constructs or operates any sewer system,
"'treatment works", or disposal system within the state a permit is required.
Furthennore, 13-2131 defines a "treatment works" as any plant, septic
tank, disposal field, lagoon, pumping station, construction drainage ditch or surface
water intercepting ditch, incinerator, area devoted to sanitary landfill, or other
works not specifiically mentioned herein, installed for the purpose of treating,
equalizing, neutralizing, stabilizing or disposing of "waste". Whereas, 13-
13118b defines "industrial waste" as any liquid, solid, gaseous, or other
waste substance or a combination thereof resulting from any process on industry,
manufacture, trade or business, or from the development of any natural source.
Based on the interpretation of these Statues, it has been deterinined, that the P
MC
Corporation's kiln scrubber operation does meet the criteria of a treatment works,
therefore, requiring a permit under North Carolina General Statute..
P.O.. Box 29535, Raleigh, North Carolina 27 25 Telephone 91 - 33-7015 FAX [phone]
An Equal opportunity Affirmative Action Employer (r/o recycled/ 1 % n ism r Paper

Page 2
Mr. McLeod
Permit No. WQ0008149 Draft
April 11, 1994
Objection 2: During periods of wet weather the level rises in the 4 acre R & D pond and is
interofittently pumped to FMCs Lower L*e and subsequently discharged to out all
001, in accordance with NPDES Permit No. NCO005177
Response 2: The 4 acre R & D pond has been deleted from this permit and NPDE S Perrnit No.
NCO005177 has been modified to incorporate this pond into the system description.
W1
ilia im 911 1
Ition 11T. Zu T
. . . . . . . . . .

Page
W. McLeod
permit No. WQ0008149 Draft
April 11, 1'
if you n do information ern `n his rn tt r, please contact1Griffin
1 733-5083.
ly,
t n ;'Jr., P.E.
Mooresvffle Regionaloffice, water Quahty Section
Mooresville Regional Office, Groundwater Section
s, Betsy M s ly, Attorney General's Office
Dare Goodrich, NPDES Group

STATE OF NORTH CAROLINA IN THE OFFICE OF
ADmiNisTRATivE HEARINGS
COUNTY F Gaston
FILE O.
FMC Corporation
e fione '
V. NOTICE IT A ALA
OF PETITION
DEPARTMENT OF VI INN NT
HEALTH,, AND NATURAL RESOURCES
DIVISION OF ENVIRONMENTAL
MANAGEMENT
Respondent.
Petitioner hereby withdraws its petition for a contested case hearing. No further proceedings
are needed or required to resolve the contested case captioned abovet
This the ' of 119-1
Petitioner/Authority for Petitioner
five of Administrative Hearings
Post Office Drawer 27447
Raleigh, North Carolina 27611-7447Carolina Department of Justice
post Office Box 629
Raleigh, North Carolina 27602-0629
Date. Petitioner/Attorney for Petitioner

NORTH LI A
pERMIsSION IS BY GRANTED TO
Corporation/FMC itDivision
Gaston County
FOR THE
•
constructedThis permit shall becOtht Voidable unless the facilities am in accordance with
the c6ndiriofts of thit permit, the apprcyved plant, specifiations, and other suppOrt4lg dam
2. This `permit is effective only with respect to the nature and volume of wastes described in
the application other supporting data.
DRAFT

14.
Im
•
DRAFT-

1 . Noncompliance Notification:
ation
e Permittee shall report by telepltnn to the Mooresville Regional Office, telephone
number o - , as soon as possible, -but In no ease more than 24 hours or on the
next working day following the occurrence or first ,knowledge of the occurrence of any
of
the following:
Calcium
S
H
Chloride
Chromium
Iron
Aluminum
Sulfate
Water Level
Fluoride
Manganese
Lithium
e measurement of water levels trust be made prior to sampling for the remaining
parameters, e depth of water in eachwell shall be measuredo the surveyed int on
the top of easing.
The measuring rots (top of well casing) of all monitoring ells shall be surveyed t
provide relative elevations of the measuring point for each monitoring well.

a. the location and identity of each monitoring well,
b. the location of the waste disposal system,
C. the location of all property boundaries,
d. the latitude and longitude of each monitoring well,
C. the relative elevation of the to of the well casing (which shall be
known as the "measuring point"),
f. the depth of water below the measuring point at the time the measuring
point is established.
. D* Won of Environment
The maps shall be sent to the GroundwatO Section, M C IVI
Management, P. 0. Box 24535, !Weio, N. C. 27616-0535i

R
1
« r
«
� a "
« i 4
s "XTV
" • f' !
ivi ion
By " •
i 5

s
r �
March 1l 1994
MORANDUM
To:: TedBush
� �
Assistant Chief for Operations
� z�
Groundwater Section
From. Coleen I . Sullins
V o,�
Supervisor, permits tan �Engifn-eering Unit
Water Quality Section
Subject: : orporation
Permit N14
Wastewater;Recycle System
Gaston County
In accordance with the agreed
Office ofAdministrativeH ru Hearings. Please ponevaluate the objections reviewrocedures, please It filed an Corporationpro vide
e with comments within ten 1 working days of your receipt of this package.
The items under adjudication concern are listed in Attachment I of the Petition. If you have any
questions regarding this matter, please contact Angela Y. Griffin at 1 -, eat. 554.
Mooresville Regional Water Quality Supervisor,'F
Attorney Generals Office, Kathy Cooper
Angela Y. Griffin
P.O. Box 29535, Raleigh, h, North Carolina27626-0535
An Equal Opportunity Affirmative Action Employer

brth Carolina
nt)6(trlytronment,
James B, Hunt, Jr., Governor
Jonathan . Howes, Secretary
A. Preston Howard, Jr., ., Director
Mt J. E Mcuod� Plant Manager
R4C Corporation/ Lithium DiAsion
Box 105
Bessemer City, North Carolina 28016
Dear Mr. McLeod:
MMMMMEMM
x
t
Subject: Permit No. W 0001 "
FDICCorporation/ Lithium Division
Chemical Plant Water Recycle Lake
Wastewater Recycle System
Gaston County
Sincerely,
ccc:j�&
e es Ord, ra, P.E.
Gaston County Health Department
Mooresville Regional Office, ee, water Quality Section
Mooresville Regional Office, Groundwater Secdon
Trwning and ertii"e ticrn'Unit
Rust Environment and Infrastructure, Inc.
Facilities Assessment Unit
F.O. Box 29535, Raleigh, North Carolina 27 25-0635 W phon p19-7 2-701 F, 1 -7 -249
n EquaG Opportunfty Affirmative tion Employer 5 % r cvciedl 10% posl-consumer paper

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOV
RALEI GH
RECYCLE SYSTEM PERMIT 13
Fikip
MAWWAPWITTANU *MW*MJ6*MW Wrlam
�licable Laws, Roks, and Regalatiolls
4 .
FMC Corporation/ Lithitito Division
Gaston County
operation of 187,200 GPD wa-tewater mc tie system consistipg of two (2) 1.1. acre t that are
III III I, I !I" v lI
Thi's perrnit shall be eftc&e ffomthe date of issuance until October 3 1, 1998, and shAll be suWw
to the following specified conditions and linihadons:
M
N
119=11111661111" �Nwglgil orting data.
all
ENT

9. Diversion or bypassing of Untreated wostevato fforn the ftatment facilities Is prohibit
M Reeboart! in the three (3) lagoons shall hot be less than two f�tt at afty time- I
17. The issuance of this permit does not preclude the Per-Mittee from complyyin g with any and
all statutes, rules, regulations, or ordinances which may be imposed by other government
agencies (local, state, and federal) which have jurisdiction.
M A set of approved plans and specifications for the subject project must be retained by the
Permittee for the life of this project.
N

19, Noncompliance Notification:
The Permittee shall report by telephone to the Mooresville Regional Office, telephone
number ) 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
e following:
a; any occurrence at the wastewater treatment facility which results the treatment of
sign t ounts of wastes which are abnormal in quantity characteristic, such
as the dumping ofthe contents of a basin, or tanks the known passage of a slug of
hazardous substance through the facility, of any other unusual circumstances.
b. . process unit failurej due , known or unknown reasons, that render the facility
iricapable, of adequate wastewater ..ment such as mechanica
l or electrical failures
of pumps, aerators, compres�sors, etc.
c Any failure of a pumping station, sewer line, or treatment facility resulting in a by-
pass directly to receiving waters without treatment of all or any portion of the
influent to such station or facility.
d. Any time that self -monitoring information indicates that the facility is not in
compliance with its permit limitations.
Persons reporting such occurrences by telephone shall also Tile awritten report in letter
form within 15 days following first knowledge of the occurrence. This report trust outline
the actions taken or proposed to be taken to ensure that the problem does not recur.
0. Within 90 days of permit issuance, three 3 monitor wells, down ra 'ent from the
lagoons, shall be installed to monitor groundwaterquality. The wells shall be constructed
such that the eater level in the well is never above or below the screen (open) portion of
the well at any time during the year.. The location and name for each well is marked on
Attachment A. approval to relocate any monitoring well shall be approved by the
Mooresville Regional Office. All monitoring wells shall"be constructed in accordance with
the conditions of thispermit,
1 The three ) down,gradient wells and W-7 shall be sampled initially after construction and
thereafter every April, August, and December for the following parameters:
Calcium Aluminum
IDS Sulfate
pll Water Level
Chloride Fluoride
. Chromium Manganese'
Iron Lithium
The measurement of water levels must be made prior to sampling for the remaining
parameters, Ile depth of eater in each well shall be measured from the surveyed point on
the top of casing:.
e measuring points (top of well casing) of all monitoringwells shall be surveyed to
provide relative elevations of the measuring point for each monitoring wen.
The results of the sampling and analysis shall ' : sent to the Groundwater Section, N. C.
Division on of Environmental Management, P. 0. Box 29535, Raleigh, N. C. ` 6 6-0 35 on
fo z - [Compliance Monitoring Report Form] every May, September, and January.

III, lilliggi 1111,111p1�11 1111111ppil liplillirg
ng state holidays.
4

w
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NORTH CAROLINA ENVIRONINENTALAGECOMNIISSION
A. Preston ow d, Jr., P.E Director
Division of nNironmental Management
By Authority of the Environmental mental i nr rrt Commission

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State of North Carolina
Deoartment of Environment,
'HedIth and Natural Resources 4 +
Division of Environmental Management
James B, Hunt, Jr., Governor
` Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E. hector
m Training Certification
Angola 'Y. Griffim, Stag Engineering Review Group
Subject.
Please be advisedthat no rating sheet is needed because
O, Box 217535, Rdeigh6 North Cuolina27626-0535l phon '1 -7 -7 1 F"i` ®
n � pportun�l y Affiym&ive Action tmp� y r $ y l d/ 10% Pce-consumer POPOr

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CERTIFIED MIL
RETURN RECEIPT RR �RSTRt
January 31, 1994 Aa42/11
r' cr
State of North Carolina
Department of Environment, Health
and Natural Resources
Division of Environmental Management �
Water Quality Section mm
R.O. Box 29535m
Raleigh, NCB 2 2Ca- 1S �
Attn: Ms. Colleen Sullins, Supervisor
Permits and Engineering
Re " C Corporation, ration Lithium Division
Bessemer' City, Gaston County
Baer Ms. Sullins:
Representatives of FMC Corporation's - Lithium Division facility
in Bessemer City (" C ") met with NCDEHNR Water Quality
Section staff at the NCDEHNR Mooresville office on January 20
199and, during that meeting, NCDEHNR recommended that FMC
contact you to further clarify issues relating to Permit
C 0 1 g, dated November 29, 1993. M had met with NC DEHfi R;-
Mo re ville to review FMC's petition for a Contested Case
Hearing on this permit (copy attached) and determine how best
to resolve FMCIs concerns with Permit No. WQ0008149, a
issued. FMC further explained that it desires to resolve
these concerns through informal conference with NCDEHNR
although it was necessary to file a petition for adudicatry
hearing as a protective measure to preserveFMC'srights and
suspend the effective date of the permit.
While at the conclusion of the January 20, 1994 meeting
NCDHENR-Mooresville and FMC were generally in agreement on the
optimal course e f action necessary to settle these issues to
the satisfaction of both parties, NCDEHNR advised FMC that
this proposed course of action would have to be presented to
representatives of NCDEHNR's 'dater Quality Section in Raleigh.

Colleen Sullins
NCDEHNR Water Quality Section
January 31, 19
Page
Thus, FMC is providing you with some background information
and is requesting that a meeting be scheduled as soon a
mutually convenient. At such a meeting, FMC would propose to
6laify the nature of grater management at its facility
relative t Permit No. Q 0 1 and FMC's N permit, Nib,.
N 0 177, °, evlew N DEHN inter-pr tation f key elements f
the non -discharge permit program "�°�o review the status of
groundwater inve tlgat ° pn at the F facility, and, following
attendant di a ion determine the steps necessary to
resolve FMC's concerns with Permit No. WQ0008149 and allow for
withdrawal of the request for adjudicatory hearing.
n girder to schedule such a meeting, or if you have any
questions or require additional information, please call me at
704/868-5417, or in my absence, Barbara Ritchie at
704/868-0806.
Very truly yours,
Arthur B. Gillespi6, r;'
Environmental Manage
cc: Mr. Rex Gleason - NCDEHNR, Mooresville office
r_, Janes E. McLeod FM
Barbara Ritchie N

Certif]ed mail
January 18, 1994
Office of Administrative Hearings
P.O. Box Drawer 27447
424 North Blount Street
Raleigh, NC 27611-7447
Attn: K4rti Hansen
Deputy Clerk
'Re: Form H-06 "Petition" and "Certificate of Service"
Dear Ms. Hausen:
As requested in your December 22, 1993 letter, FMC
Corporation's Lithium Division facility in Bessemer City,
("FMC") has completed the "Petition "For a Contested Case
Hearing" ' and is herewith providingt
your office with he
original and one copy of the completed form. Copies of this
form have also been provided to the Department of
Environment, Health, and Natural Resources (IINCDEHNRII), as
shown. FMC is pleased to provide this additional information
and initiate dialog on the subject, although FMC- believes
that its December 17, 1993 letter constituted sufficient
petition for a contested case.
Please! note 'that FMC desires to resolve this issue through
informal conference with representatives of NCDEHNR,
consistent with the provisions of NCGS 15OB-22. FMC has
prepareda statement of its concerns with Permit No.
WQ0008149, included here as Attachment 1 to the petition
which should provide a basis for discussion and resolution of
this issue. Nonetheless, this petition for adjudicatory
hearing is necessary as a protective filing to preserve FMC's
rights and suspend the effective date of the permit, in
accordance with NCGS 15OB-3(a).

Office of Administraive Hearings
January 1, 14
Page
If you have any questions,_ or require additional information,
please contact Art: Gillespie at 7 4/ 417, or myself t
704/868-0822.
Very truly your
,x
Jtimes E . McLeod
Plant manager
c: Richard S. Wisnant,
North Carolina Department of Environment,
Health, and Natural Resources
I N. Salishury Street

T F� CIF ,N 0 R,J, I I C.k IZ (') I IN THE OFFjcf�
o uvr)� o F- r ii, r aLs t o'n' OF
A�1�11,\�S­iRATIVF H I Ix
(2'
01 S
Bessemer City
(Your Narle)
PETITION
FOR ik
CONTE-STED CASE' HEARING
miN.0 De21__.CLf_LLi\L1rQnrnent, 2sI I tj,,
and Natural Resources
espon is,- r,
(The State Agency or Board ab,-,tjs ryujch ycw are
cornpainmg)
I hereby ask 'Orr a Contested
Care ncaring as Ctrovided for by G�S� '1508.23 because the�
.ient
e_� n o f v r i ct nr Health and Natural Resources
h2s:
('tare o ert c y)
(Bf.,-,Ey rrate tOu beheVe you have bsen harmed by the state agency or board.)
_A�tachmer'
vnore r is needed, 4se oddific ttit sheets d
tFa,, appM Be,,-_iuse of facts, -the trF,enc. has::
Y 4
Me Z,i
Ordered me ,o Y OT C;',, penllzy; failed to use Tproper procedt.,,e� ­o0lerwisc subsiantiaUt prejuaced my K arbararily'cr cajcrjcjousi), or
rigrl.s� -Ma ohese flc,s ',he agency _-7fitiJed to azi as requred by Jaw Or FUle,
has eXC-,eded i',s aut �sdrctron:
(6 Date: JaMlary 18 19tf4 pia Y Ourtslephone nuruer:
004
Print Your address: H"_[Pchy,'ayL
11,
LL,2_O�.B_ox 719�5, Be�saEEr
(9) Prim your n an-i e, Jame7j. McLeod I fit p,a, a
�7
P
(10) Your stvnawre:
You rinist, maH or deliver a rci to the State Agency riamed on fine (3) of this forni. Please indicate below,
CERTIFICATE Of SERVICE
I certify that this Penton has been served or, the State Agency cameo below by depositing a copy of jE tvith the Um,ed States
Postal Service ,vn,h sufficient postage OR by deHvitring is to the named agency„
Served oh
(It)_. Richard B. Wisnant
"El VircLnjrnent, Health and Natural Resource
(13) 512-.N. Salisbury Street, Raleigh, NC 27604-1148
(address)
(14)
M
When YOU have COMPlCned this [Orm, you MLST rn2il or r1chyer the ORlGINAL and one COPY to the 01TIce Of _\,JrTjinRs_
LraUve Hearintols, P,O Drawer 27447, R ateag,r7 �,c 276 11 -744T
H-06 (I 119 t )

Petition for a Contested Case Hearing
Permit No. WQ0008149
FMC Corporation, Lithiurri Division
Bessemer City, Gaston County
Attachment I
SummaLy
FMC Corporation's Lithium Division facility in Bessemer City,
Gaston County ("FMIC") received Permit 14o. WQ0008149, dated
November 29, 1993, from the State of North Carolina,
Department of Environment, Health and Natural Resources,
Division of Environmental Management ("DEM") for the
operation of three ponds at the FMC facility pursuant to the
requirements of 15A NCAC 2H.0200. FMC believes that these
ponds, the R&D pond and the two kiln ponds, are not in fact
subject to 15A NCAC 2H.0200 and Permit Nc. WQ0008149 should
be withdrawn or canceled. Issuance of this permit subjects
FMC to requirements which are not applicable to its
operations and imposes expenditures and actions neither
justified nor feasible in the time frai-r�e specified.
FMC here presents a statement of facts which support its
determination that these ponds are not subject to regulation
under ISA NC ACC 2H.0200. Discussion here is generally limited
to questions regarding applicability; FMC reserves its rights
to dispute individual requirements of the permit, as issued.
B a, c'.1-, q r c u n d
FMC discharges wastewaters to a tributary of Abernathy Creek
in accordance with the provisicns of NFDES Permit No.
NCO005177. Periodically, FMC" has engaged in discussions with
representatives of DEM concerning water management at the FMC
plant and on several occasions EEC reviewed the applicability
of regulations at 15A NCAC 2H.0200, titled "Waste Not
Discharged to Surface Waters," with representatives of DEM.
Such discussions had consistently led to the conclusion that
these regulations did not apply to FM C facilities. However,
the written report dated February 11, 1993 concerning the DEM
January 27, 1993 inspection at the FMC facility included a
statement that DEM believed that the two (2) "kiln ponds" and
the "R&D pond" at the FMC site should be permitted under 15A
NCAC 2H.0200. In response to this report, FMC prepared a
permit application, as directed by DEM. In FMC1s July 8,
1993 letter transmitting the permit application, FMC
described the apparent change in DEM interpretation of the
rules. FMC expected that, following DEM review of the permit
application, additional dialog would occur which would
clarify the nature and operation of the ponds described in

Petition for a Contested Cass. Heating
Permit No. WQ000814
Attachment I
Page ,
that application, relative tc the applicability of 15A NCA
2H.0200. However, Permit No. WQ0008149 was issued: on
November 29, 1993 without the benefit of further dialog o
this subject.
The following information is presented to clarify the nature
and operation of the ponds, supplementing P C"s permit
application, and demonstrate that the R&D pond: and the two
kiln ponds should not be subject to the requirements: of 15A
NCAC 2H.0200 and permit No. WQ0008149, as issued.
R&D Pond
In appro im,at ly 1957, a 4 acre pond was constructed to
collect stormwater run off from the western side of the FMC
facility for use as process makeup water. This pond has been
referred to as the "R&D pond" as it is near the R&D building
at the site. FMC purchases water for use in its processes
from the city of Bessemer City sand construction of this pond
provided the opportunity to reduce additional city water
purchase. As time progressed other waters were identified
which could also be directed to the R&D pond for subsequent
use elsewhere in the plant.. For example, cooling tower'water
is continuously circulated through this pond and R&D pond
water is routinely used as make up water in other plant
processes. Nonetheless, during periods of wet weather the
level rises in the pond and water is intermittently pumped to
FMC's Lower Lake ansubsequently discharged to outfall. 001,
in accordance with FMC1s NPDES Permit No. NCO005177. To the
extent that a permit is required, the R&D fond is included
within the provisions of FiC°s NPDES permit, No. NCO005177.
The purpose of the 15A NCAC 2H.0 fl0, as stated at part .0201,_
is to set forth the "the requirements... for the follow n
steams which do not da.schar e to surface graters of the.
state" jmphas s
( added . Not only oes_ 'NC"s &D pond
discharge to surface waters, subject to the, provisions of
NPDES Permit No. NCO005177 it is not included within the
definition of any of the six types of systems enumerated at
.01.
Kiln Ponds
In approximately 175 a particulate: scrubbing system was
installed to reduce emissions of off -gases associated with
the spodumene decrepitation kiln at the FMC facility. This

Petition for a Contested Case Hearing
Permit No. WQ0008149
Attach�,Kient I
Page 3
scrubber system utimately included two parallel scrubbing
towers, a scrubber surge tank, a scrubber media (water)
makeup tank and two kiln scrubber water recirculating ponds
("kiln ponds"). Water is sprayed into the scrubbing tower,
collecting particulates from the off -gases. The water drains
from the bottom of the tower, to the scrubber surge tank
where it then flows to a thickener. The solids concentrate
in the thickener and are fed back into the decrepitation
kiln. The water flows, from the thickener to the kiln pond
where additional capacity and residence time provides
additional collection of solids. Water is pumped from the
kiln pond into the scrubber make-up tank where volume lost to
evaporaticn is supplemented before being sprayed back into
the scrubber tower.
The two scrubbing towers and the two kiln ponds are installed
in parallel and only one of each is active at a time. after:
solids collect in the active unit, flows are redirected to
the other unit to allow for removal of the solids from the
,then inactive unit. Solids removed from the scrubbing towers
and the kiln ponds are both disposed elsewhere on the FMC
property in accordance with the provisions of Fmc,s E,andfill
Letter of Authorization No36-05.
FMC acknowledges that the kiln ponds do not discharge to
surface waters of North Carolina, excepting the potential for
emergency overflow if a record storm event were to occur as
one pond were almost filled or during other upset conditions.
Nonetheless, FMC believes that operation of the kiln ponds do
not constitute actions which require a permit, as delineated
at 15A NCAC 2H.0204 and NCGS 143-215.1(a)(1) thru (10).
Further, FMC: does not believe that the kiln ponds are
properly classified as one of the systems enumerated at 15A
NCAC 2H.0201- FMC provides the following discussion of issues
relevant to its interpretation in this matter.
It is unclear that the scrubber water directed to the kiln
ponds is a waste. Scrubber water continuously circulates
through the system, as is a requirement for scrubbing systems
of this type. The scrubber water is a process stream and the
ponds an integral part of the scrubber system, similar to the
scrubbing towers, surge tank, thickener, etc® Regardless,
the ponds are not used for waste treatment or disposal.
While separation of solids from the scrubber media occurs in
these ponds, this separation step is a critical step in the
scrubbing process.

Petition for acC-ontes--ed Case Hearing
Permi,4-
t No. WQO 08149
Attachment 1
Page 4
Further, the kiln ponds are not "residual and residue
disposal/utilization systems". The term "residualsql is
defined at 15A NCAC 211.0203 (31) as "solid or semi -solid
waste." Although the solids which collect in the ponds could
be included in this definition, they are neither being
disposed nor utilized while they collect in the ponds.
Permit No. WQ0008149 also includes a specific condition which
requires that a liner be installed in the two kiln ponds
within 180 days of issuance of the permit. If the kiln ponds
are to be regulated under the provisions of 15A NCAC 2H.0200,
the rrainimum design requirement at 15A NCAC 2H.0219(d), that
the hottcm of an eartl'ien impoundment shall be at least four
feet above the 1;,edrock surface, is fulfilled. The basis for
requiring a liner pursuant to ISA NCAC 2H.0219(f) in a pre
-
exIsting systeM is
s unclear. Further, given that these ponds
are. pre-ex:Lstinq J-Iits, ccr,,Iplying with the requirement for�
liner installation in the s-pecified time frame is not
feasible.
Grcun-lwater mo+-O
Permit No. WQ0008149 includes requirements that three
gro,,;ndwater Monitorinci wells be installed within 90 days of
permnitt issuance and that these wells be sampled initiall Y
after construction and thereafter every April, August, and
December. Fri C notes that the installation of the three
wells, whose locations are shown on a sketch, attached to the
permit, is an ex,:Lsting requirement of the RCRA Facility
Investigation ("RFI'l) Work Plan, required under Fri C1s
Hazardous Waste %la�nagement Permit, No. NCDO00771964, and
approved by DEM. The RFI Work Plan includes installation of
twelve new roundwater monitoring wells, along with the
collection of numerous other environmental samples. While
the field work associated with the RFI Work Plan will be
initiated in first quarter 1994, it is unclear that the
installation of the three wells identified in permit No.
WQ0008149 will be completed in the time frame specified.
All groundwater monitoring wells will be sampled quarterly
for at least one year and the samples analyzed for a
generally more extensive list of parameters. The RFI program
includes review of the results after the Work Plan
requirements are completed and additional work, if necessary.

Petition for a Contested Case Heari®n
Permit No. WQ0008149
Attachm,,ent 1
Page 5
Duplicating the requirements of FMC's RFI Work Plan does not
appear justified, as these activities are already subject to
review and approval by ITEM. Further, the requirements to
install and sample the wells on different schedules and
analyze those samples for a different parameter list does not
appear to be justified. A groundwater quality investigation
program is already required under a state permit; duplication
of such a program is unduly burdensome.
Conclusion
Thus, FMC believes that neither the R&D pond nor the kiln
ponds should be regulated under 15A NCAC 2H.0200 and that
permit No. WQ0008149 contains requirements which are not
applicable to its operations, impcsing expenditures and
actions neither justified nor feasible in the time -frame
specified. FMC requests that Permit No. WQ0008149 be
withdrawn or otherwise modified. FMC's submission of the
July 8, 1993 permit application package was an merely attempt
to engage the DEM in dialog which would resolve the status of
the ponds with respect to 15A NCAC 2H.0200 in a conclusive
manner. FMC appreciates this opportunity to initiate
discussions, albeit late in the process,

FMC Corporation
LthiL,,m DMsi�on
Hrgh,sway 161
Box 795
Bess&-'ier City Norlh Carolina 28016
704 868 5300 F'ax 704 868 5-486
CERTIFIED MAIL
RETURN RECEIPT,BE.QUESTE'D
February 25t 1994
State of North Carolina
Department of Environment, Health
and Natural Resources
Division of Environmental Management
Water Quality Section
P.O. Box 29535
Raleigh, NC 27626-0535
Attn: Ms. Colleen Sullins, Supervisor
Permits and Engineering
96: PMC Corporation, Lithium Division
Bessemer Cityt Gaston County:
Dear Ms. Sullins:
-I)CI
C)
AIIIC-
+t%s! k('
C_' C_C"4_ cl
4FFA
j N,!

Ms. Colleen Sullins
NCDEHNR Water Quality Section
February 25, 1994
Page 2

M. Colleen Sullins
NCDEHNR Water Quality Section
February 25, 1994
Page 3
from documented releases and, as necessary, support the
development of remedial actions. FMC and NCDEHNR agreed that
the requirements enumerated in Non -Discharge permit No.
WQ0008149 which relate to groundwater quality would appear to
be duplicative and inconsistent with those of the ongoing RFI
program.
If you have any questions or require additional information,
Maass call me at 704/868-0806, or in my absence, Mr. Art
Gillespie at 704/868-5417.
Ve truly ours,
B bar E. tchie
Enviro en 1 Manager

Rex Gleason NCDEHNR, Mooresville office
Caroline ill - NCDEHNR, Raleigh
. David+i NCDEHNR, Raleigh
James w McLeod FMC
Art Gillespie FMC
v

DUNN CORPORATION
Engineers, Geologists, EnvironmentAl Scientists 11400-0
2 Market Rua Way
Mechanicsburg, rnnsylvania 1705
Tel: r $ r 79 -800t
Fay: 717/795-8280
�w w
WORK PLC
Fi\'IC CORPORATION- LITHIUM DIVISION
Air
ut
is
e
PCB FACILITY INVESTIGATION
.�,,...<::�.
VL JE 1 - TECHNICAL PROGRAIVI
w
Prepared for.
FMC CORPORATION - LITHIUM DIVISION
HIGHWAY 161, BOX 795
BESSEMER CITY, NORTH CAROLINA 28016
Prepared by
DUNN CORPORATION
.m2 MARKET PLAZA WAY
Date::
APRIL 26,1993"
Offices in Mbana , NN, Atlanta, GA, Bul`Uo, NY, Chicago, IL Concord, NH, Derivcr, CO, Harrisburg, PA New York, : ', and Parsippany, N;
(Tinted an Rcxycicd Paper

TABLE OF CONTENTS
LIST OF FIC. U ..,.. .......
LIST OF TABLES.... ...........,. .. .................
.., i
LIST OF EXHIBITS.— ...,..;.........:. .........
LISTOF APPENDICES .................,..,.... a; ..........,...;,..............,,......,..... ,,......: ,....,,....,.:
1,3 WORK PLAN OBJECTIVES AND FACILITY BACKGROUND ... ....... .... ....... 1-1
1.1 Work Plan Objectives... ............. ............ .. 1-1
L2Site History ... ............ .......,.,..,.,........ ,.........
...........,..............>..,,. l �I
1.3 Site Environmental Sett` . ......... .... I-
13.1 Introduction.. tar.................. ............. ...... ...,........e,.....1- 1.3.3 Physiographic Setting and Land Use .........................................
1.303 Site Geology .................................... .........................:............. 1-
1.3.4 Site rail.
1,3.d
1.3.6 Bedrock..,....... ...
1.3. " Ore Tailings.... ...........e..,.,....
1.18 Fill Material........, ........ ......... 1-10
1,19 Regional Hydro e to y... ....................... 1 10
1.3,10 Leal Groundwater Availability and Ltae.,......M,,.......... .,...., ,..,. 1-11
1.3.11 Site y dr , e log .......;...., ..,.. .I ....... ................ ....... . ............ 1-11 aquifer Characteristics ......... ......... .......................... .:.... I-11.
13.11. Groundwater Flow ......, 1-1
1AClimatological Summary....... ................. .......k. 1 1
1.3 Overview of Former Site Waste Management Practices. ......... .... ..... ............. 1-15
1.5.1 Introduction ................... ........: ........:.... 1-13
1,3. EP 3 -'RCRA Fa
1.3.3 Descriptions of Solid Waste Management Units ..::...................... 1-1
L6 Background Chentical Data and Known Releases to the Environment ........... 1-3
1.7 Site Base Mapping.... ............: ......... ...... g......................-- ..................... 1-3
2.0 OVERVIEW OF TES CAL PROGRAM..,, ...... - ............ ..................-...........,...... -1
.1 Review f Planned cttivities.......... ....m......,.,::.......... ;,
.1.1 Project Personnel .... -'— .............. ................I ,...................2-3
2.1.2 Personnel Protection ......................... .......... -
.1.3 Equipment -
.1.4 Doc=e tation..........—.....................................
2.2 Technical Data Research
TAPI a ftc id
31123-06194

TABLE OF CONTENTS (Continued)
..1 Ob
jectives ...,,,..,® ......... .................. .n........... ....re ..,....;x ,.... -
2.2.2 General Approach ...
2-5
.23 Justification....
2.3 Field Reconnaissance, Verification and Confirmation............
...............
x..
..1 2-6
blcfies.... .....x re.,.x..a...t....a ...:. ......... ........ ...ts...t .....,,aa...t..
2-6
2.12 General Approach—.....— ........ ...., .......
114 Justification......:.a............ant..::........ ...x....t_ .,..,..,..........
. ........... -
. k bsurface ��aste and SoilSampling—.-......re .,.
. , l Objectives .....n.............:............ .,....:.. a.....,.....t......
2.4.2 General Approach ....
1. J .. ..,a
Justification---, . . .............. ...
2.5 Morn tor Well Construction and Testing...... ...:..:......... ........
2-8
2. .1 Objectives.,........® t.,........ . t.. ......e.... ,.a ..,,2-8
. .2 General Approach ........ ---- :. ........o ........, .t...x.n..,a,....2-9
15-3 Justification.. . ........... .... -....x..m ...,..x . ,..,m.... .....t.,..,..,.t... n.,..,:....nx.2-9
2. eater Quality- and Sediment Sampling., ........ .................. 2-1.
2 ;1 Objectives ., ....,..., 2-1
16.2 General Approach
2.6.3 Justification ..................,........ ..m . ..2-11
..
2.7 In S trearn Pie
zorneter Ins tall ation .t ,,...n re.. ,.,....,t .n,.x......a....a....,.....a x............. 2-I1
2t21 Objectives- .....,..a.x ....,-.. ..<.,.., ..xa.... 2-1.1
2. 2 General pproacl^i...x.... ......... ...a. -11
17.3 Justification...... .....,re..n........._.t. ,..a,x... 2-1 E
18 Soil as Landfill Gas Surveys.... ....... -- , .....A a.......n... ........... .......... ............ 2-12
2. .1 Obje
ctives ........... ......... ..a..,...a.m,.t,. ,.......t....a.. at..,....a .,t...,.......2-12
. .2 General Approach.... .... ,,a ta.,trea........ ..s...... .a..............R,........,.a. 2-12
2.83 Justification .t.xt.:.. sµ.a.......x...............r ......x:, ........ a........ a:P.... ax... 2-12
2.9 Landfill Gas Surveys 2-12
2..1. Objectives 2-1.2
2. , 2 General Approach 2-12
2.9.3 justification . 2-13
Ae Mareear.,a ...reapaa. s: a,m xn xau. ..as,e++:.a ♦�enn.a a... a.t...ar...e •uaa mm as s ;oas......... E
2.10 Data Analysis and Interpretation ..2-1 �
2.10.1 Objectives .m... 2-13 a.F �.
.1 .2 General ,Approach
1 °3 justification.............
TA13LE OF CONTENTS 31123t6*4

TABLE GE CONTENTS lC ntinued)
E L
LE-
2.11 A Objectives ........a ..... _ ...................... ......
.. 2-15
2.11.2 General Approach, . .... _........ ....................,......
2.11,3
,
_1
3.0 ENVIRONMENTAL ILL D ANALYSIS PL N..........
3.1 Introduction and Scope ................. ... ,,.. -1
12 Subsurface Soil and Waste Sampling...
3.2.1 Objective ............ ...... ..
3.2.2 General Approac..
3.2,3 Justification... ..
8
3.2,E
3
3.2.5 Personnel protection— .................... ..........................; .,..,.,;.......
3.2.6 Analytical,/Sarrrplin Methodology,
3-9
3-9
3.2. .1 Sample
3-9
Equipment......... ...... .....3-11
3.2. 6, 3 Method...........
3-11
3.2.6. -Total Number ..... ..,"................
1
3.2.6.5 Quality Control Procedures..,_......._—, ......... . ........ .....
3-12
3.2.6.6 Types of Analyses.....— ........___ ...........:. ..........
3-12
33 Surface Water and Sediment Sampli._"................,................................
3-13
3.11 Objective ........... ..4........n..................° ........
3.3:2 General Approach.. .............1 f
3-13
3 .3.3 Justification ,.... .....,., "<................ ..,.."..
3-1 i
3.3.4 Sampling Team
3.3.5 Personnel Protection .... ..,..".,......... ,..
3.3.6 Analytical/S plin ethodolo
3-1.
3-14
3.3.6.1 Sample Locations t1 tin
3.3.6.2 Equipment ..,
3-15 ,
3.3.6.3Method ................ .................... .. .............................
3-15
3.3.6.E Total Number ...... ......... ___ .............
3-16
3.3.6.5 duality Control Procedures ................. .."..:...,...,:R.....".......
3-16
3.3.6.E Types of Analyses
3. Groundwater Sampling . ..................................... ... .x.
16
3-1
' 3..
' Ctbjective.......,...:a .....................»,... ..,.............e.........., ......:...
3-13 r
3.442 General Approach .........: ................... ........,.....................,,........
3-13
1 ABLE O ONTENT 11 1 d
r

TABLE OF CONTENTS(Continued)
3.4.3 justification.
3.4A Sampling Team,.-., ... ... ---- ........; 3-1
3.4.5 Personnel Protection— ...... .......:.: 3-1
14,6 Analytical Sampling Methodology,...
3.4..6.1 Sample Lc cad ?rt .... ....
3-19
3.4.6.Equipment........ .............. ..... 3-21
3.4.6.3 Method— .................
14.6, Total Number-- .......: .......:........ ................... 3-22
3.4:6.5 Quality Control Procedures. ... .................. ....................... 3-22 6,6 Types of Analyses .......................................... .......a,..... - 3
3.5 Sail Gas S uney .,............ ............,.m... ,.,....3-24
3.5.1 Objective
3,5,2 General Approach ...... -
24
3,5 3 Justification-- .................:......... 3- 4
3.5.4 Sampling Team.. . ......... ...,.,..................,....................,,......,.. 3_34
Personnel prat
3-5.6 alytical/Sa lire
p g Methodology,---
, ....,...., 3-5
3.5. , 1 Sample
3.5 . 6.2 Equipment-
3,5.6.E Method—, ........ ................,.. 3-25
3,5.6.4 Total Number ..... ................. ...... ..--..... 3-26 Types of Analyses......., ...... ., -6
3.6 Landfill Gas urea...... ..... .. ...:..3-26
..........
3.6.1
3.6.2 General Approach-......... 3- 6
3.6.3 Justification..
3.6.4 Sampling Team ........................ ........... .................. ...... 3- 6
3.6.5 Personnel Pro tecti
16,6 aly i c�a I /Sampling Methodology .....................
16.6.1 Sample Luca ..............a... ................ , ..,,...,...,....... 3-27
3.6 , 6.2 Equipment......... --- ............::...............e,..,...,.......m,.. ,. 3-27 3 Method., ....... ...... :............... ............... ., ..... m.....>.,.:.. 3-2
3.6.6.4 Total Number. ....................... —-
3.6.6.5 Types of Analyses.......... 3-27

TABLE OF CONTENTS (Continued)
4.0 FIELD HEALTH AND SAFETY PLAN.
PAGE-
........
41 Introduction
4-1
........ ........ ......... ...... ................ .....
4-1
4.2 Designation of Responsibilities . ...... ......
...... ...... 4-1
43 Scope of Work.... ........
__ ................ ......... _ ............. ____
4-3
4,4 Site -Specific Health and Safety Concerns ...
................. ........ ... _.
4-3
4.4.1 Site History
..... ........................®. ....... ........ ...... ......
4-3
4A.2 Site Concerns
.... ...... .................. ...... .......
4-4
4.4.3 Suspect Chemicals... ...
........ ...... .......
4-4
4.5 Site -Specific Health and Safety Requirements.. �
- ­ ... ...... ........
4-4
4.5.1 Key Personnel .._ ..........
......... _ ........ ___ ... ......... 4-4
4.5.2 Training .... — ... ..........
........ ­­ ..... — .......... .............. ..........
4-7
4,5.3 Air Monitoring ....... .... __._ .........
— ........ ......... ..... ­­ .........
4-7
4.5A Personal Protective Equipment .....
.......... ­ ....... ­­ .........................
4-8
4.5.5 Other Protective Equipment.,
...... ......
4-8
4.5,6 Decontanunation Procedures
... ..... _ ...... — ....... ........ ......
4.6 Emergency Procedures........ ...........
4-8
....... _-__ ....... _ ...... ............... ........
4-11
4.6,1 Notification—,
............. ................. ............... .......
4-11
4.6.2 Personnel Injury .....
...... ..............
4-12
4.63 Fire/Explosion ...
..... ........... ........ __ ...... ..
4-12
4.A 6Heat Stress
......... .......... ........... ...... ........
4-12
4.6.5 Personal Protective Equipment Failure
.............. ........ .... * ..........
4.6.6 Other Equipment Failure
4-12
___ .......... ...... ...... ...... .......... ..
4-12
4.6.7 Site Control....-
....................... ....... ..... ___ ................
4-12
4.6:8 Emergency Services ........
......... ............. - ......... ...............
4-14
4.7 Appendices ....... — ......... _
..... ............ ...... ..... ........ ___ ........ __
5.0
4-17
PROJECT MANAGEMENT PLAN
............. ......... ......... 1_1 ......... .........
5-1
5.1 Background....„ . .........
.................... ................ _._ ....................... ....
5-1
5�2 Organization/Responsibilities ...
. __­ .................. — .................. ................... -
5-2
5,2A Personnel Responsibilities..
........... ....... ....... _ ...........................
5-2
5.2.2 Quality Assurance Project Plan (QAPP) ......... — ...........
5-4
_ .............
53 Quality Assurance/ Quality Control - Field Activities
......... .................
5.3.1 Training..
5-4
...... __ .............. ................ ............. - ....... ..................... —
5-4
53.2 Quality Control of Subcontractors ........ __ ..........................
5-5
. . .
5.3.3 Evaluation of Existing Data and Existing Sampling Points ...........
-6
ooadTo 1:
TABLE OF CONTE TS
Vil
31123-D6194

TABLE OF CONTENTS (Continued)
5.4
Quality Assurance/QualityAssurance/Quality Control
5.5
DocumentControl..,_.. Analytical
Laboratory .......... .,..,..... 5-
5.
C Control procedures and Chain- f-Custody....
..le
`
5. .1 ,Sample Identification..._
.....a:,
Chain -Of -Custody.....
Procedures
5-'
......,,;
,5.5.5 ,Meld
......... ............. 5-10
Soil Boring d i� fOnitor Well Construction
tern
5-1
5.8
....,....
Quality Assurance Samples—_
..».......................5-12
Sample Collection—
„ 5-13
5.5.E SamplePreservationd Shipment....5_l5
5
Meld.. Measure Measurement
.. ... ............ 5-15
5-10
Analytical Laboratory Quality Control
5-15
Project Scheduling.,
...... -15
5-1
TABLE OF C NTEON
N7°

TABLE OF CONTENTS Conti
15T OF FIGURES
1µ1 Site�ccat�cn Map..... ..,
1-2 Regional Geologic Map _. ..,. ®,.... ........ ..1-5
..
1_5 Site Soils Map
1- Sum -nary 1 Geologic Information From. x. is ... g On -Site ........., rhules/ ........... 1,
Wells,,, 1-9
1-5 rounds ater Table Map, February, 199 n ......... ...... ....
1-6 SWMLT
-1 On -Site Medical . ...... . ........................�.
... -�'
Facilities ...a. .....
4-2 Emergency Hospital Route . 1
Project "Team Organization Chart.... ...................... ,,.... 5-�
LIST OF TABLES
5-1
Sununary of Planned Activities (Grouped by Area).......
-2
Phase 1 RF1 Sample Media, Analytes and Frequency.,
3-3
phase l RFI Field Quality Control Samples, ..
3-4
Environmental, plin Plan_..
-1
Hazardous Substances Known or Suspected To present
4-2
e ................. ........_.
Unpublished Airborne Exposure Limits for Substances Known or
-5
Suspected T Bepresent .
e ...."
............ ......a„," ....
Protec
tion ction Levels
4-4
Task -Specific PEE
4-10
`-1
t Control...
..... ......... ........... _ ....__ ........ .....
5 e
5-2
DUNNStandard Operating
5-3
Field Measurement Equipment Quality Control
5-
Estimated Project" 5hedu.1e............
5-1
....., ..,.,...................z.x,;.
a1
TABLE ONT
NT
1t
s4

LIST OF EXIIIBITS
I FMCZ'rca .
raa g U Boundaries, virol a to
llr�g Stations
d %tr Tableca
.......
Map ow g � tars I}talitzF ..... T a l Pocket
FMC lr� t
pling
Envirorunenta, Sam
Stations and Water Ta l Contours... ,..L'I Back Pocket
LIST or, APPENDICES
Historical alb=tic

,"I"101r'

Table 3-1
(continued)
)stress 1 tnMeSC3 atlnn
Phase � r
Subsurface
Surface Water
Bonn . rilling
Planned Phase �
Potential Phase 2rl
NoihN4U a astelSollsu
acid Sediment
Groundwater
activities
,ls"1' U Greats Activities
SIVMU Gmun Activi h s
4 Clersttet Waste Sits=. None
Sample i surface water
5sample's
Soil C as Survey
Collect I surface water and 1 sediment sar ick
Utilize resents of soil gas survey, surface water
(writ gas
(SW-11) and 1 sediment
quarterly from
from rnarsttyarea east of S4as'MTJ 4, perform
and sediment sample analyses to site tip to
survey)
sample
existing monitor
2 times
new wells in SWMU U rea p Area Cross-
I surface water sample
swells (W-1. 2,4,
Monitor 5 existing wells 4 times
gradient /do wngradient to monitor boundaryr -
(S -12) and.. ]sediment
'' S, 9,10, 11 and 12)
Perform soil: gas survey to delineate extent
conditions
sample
of contamination
New wells would be installed, and slug tested
•Collect surface water and sediment sample
then Incorporated into existing monitoring
from Eastern Surface Drainage Channel
program to allow at least 2 rounds of analyses
downgraditurt of SGW fU 4, perform 2 times
prior to conclusion of RFI
a mist rations None
2 surface water (SW-9
2 samples from
1 new monitor
- Install t dowwngradiant well near ravine area,
Landfill
and SW-10) and 2
existing monitor
well (DCAd
sample 4 time$
sediment samples
wells ( 23 and:
- Collect 2 warfare water and sediment samples
W6) and 1 sample
from eastern drainage channel, sample 2 times
from new well:,
- Sample 2 existing monitor wells„ sample
4 times
14 Casten County School Norte
None
l sample from
None
. Sample: exislIng monitor well, sample 4 times
Possible abandonment of existing wells LA
Burial Site (Done "card)
existing monitor
and 1.-5 if in -stream pler:ameter and ground -
well (W.5)
water data indicate impart to these wells from
off -site source
No other lipase 2 work anticipated for this
SG* MLt roan
5 Industrial "rralfill None
2 surface water and 2
5 samples from
2 new monitor
Call 2 new wells on cast side of western
sediment samples
existing monitor
Wells:'((X-5 anal
drainage channel, sample 4 times
(SW-7 and SW-g)
welts ('f.-t. 2, 3i
-ta)
* Monitor 5 existing monitor wells, sample
4 and 5) and 2
4 times
samples from new
- Collect surface water and sediment samples
monitor wells
from western drainage channel,, perform
times
10 Uthene Resin Disposal None
None
Ns-ure
None
I- ndfrll
I2 role larndfill None
None
_ None
None

Table 3-1
(continued)
—Phase I Invest a 110
Subsurface
"t
Surface Water
h .9
arme d Murse I
Potential Phase 2
N o SWMU
Wastelsoils
as "Sol"
and Sediment
Groundwater
Activities
SWrOUGrou Activities
SWMU Gm Activities
7 Bessemer City Landfill
None
on,
I surface water sample
I '-fa
3 samples from
3newimmilor
Perform OVA gas survey to determine
No Phase 2 work anticipated, Initial Phase I
(FMC Property)
.V gas
(OVA gas
(SW-13) and 1 sediment
neramistrifor
wells (DC-7, DC-8
methane generation
first quartergroundivateranalyses will be for
me
survey)
sample
wells
and D(�-9)
Install I upgradiern and 2 downgeachent
Appendix IX parameters then reduced to typical
monitoring wells at ead� landfill, sample
site parameters and paraneners detected in
4 liTric—s
round I for subsequent sampling rounds
Collect surface water And sediment samples
from Western Stufare Drainage Channel,
perform 2 times
9 Old Bessemer City
None
I surface water (SW-10)
3 samples from
3 new mordtor
Landfill (BC Property)
(OVA gas
and 1 sediment sample
new monitor
wells (DC-10,
survey)
wells
-1 !1 —DC12)
13 Old Berenet Sump
2 samples
None
None
I soil boring
* Collect 2 subsurface soil samples from I boring
Utilize soil analytical results to deterrnir�v if
(S B - 2)
in vicinity of surnp (ccMected as surface and just
up to 2 additional moratorwel Is would be
abovewater table)
iaMalled in this SysMU group area
- Collect 5shallow subsurface sod samples from 5
barings near old bag house (collect at a maximum
of 5 feet beyond base of macadarn)
15 Bermet Bag Filter
5 samples
None
None
5 shallow soil
Any new wells would be installed, and slug test
House
borings (513-3, 4,
then incorporated into existing monitoring
5, 6 and 7)
program to allow at least 2 rounds of analyses
to conclusion of R'rI
Background
I sample near
None
I sample from
I soil boring
Collect I shallow soil si am frie in vicinity of site
well W-7
existing monitor
(SB-8)
background well
well (W-7)
Sample background well 4 times
NPDES Outfall
None
I surface water (SW-1 4)
None
None
Collect I surface water and sediment sample in
and I sediment sample I
_]Lidni
Potable Water Supply
None
None
None
Collect I sample from potable water supply used
for docontarmwition
bfcoes� - Water levels In all mordtor wells
and all ustrearn piezinneten constructed will occur quarterly,
- Instrearn piezometers will lit, installed
at each surface water/sediment sample station in the Eastern
and Western Drainage Channels (total of$ locations).
* All stations will be surveyed for horizontal and vertical control,

a
Table 9_
Phase i AF1
Sample Media, Anaiytes and Frequency
"
Ana eslSam irn cund*
Ar�t�oc ata uarlti /Round***
MATRIX LOCATIONS
First Second Thifd Fourth
plat Second Third Fourth
Soil/Waste (total)
SWMU No.1
B l
SWMU No.13
SW%4U No,1d
Each rcrourtd a'ier irwall °�^JA,B,C,i
mm
Surface "dater (14 total)
SWMU P°(os.25,,5,13,12
ABl
A.S,al
S S
SWMU No.11
A,S, ,D,E,I A,B, ,D,E,t
4 4
• SWMU No,4
A,B, ,F,l - A,E, ,F,l
1 1
hlo,14y
A,B, .D, ,I' ,B,C, �, ,1
1 1
[S��VygW#ygtwl #tJyy y
SWMU kYos.7, ,9
Hj ,F. H*,
,..
2
NPOES Outfall
..i
A Stt" l A S .l -
1 1
Sedliment (14 total)
,. .. .v ..3
�
.,. .:
SWMU Nos°2, ,5,9,10,12
� 1 u FG+N�.a,J'oSM1rAMie�m,N*;,e%daSw.l�.+ "�•
'eiil'' �
A,S, - A,S„
t Yavf{a "zW'aYduma <ap4"�Mh wws.K 9',sN+�.,.WMSa' �• ry
SWMU No,11
,l ,l
A,SRS,LI,E;I A,S,S, ,E,l
a S
4 4 r
S PAU No
A,B,S,F,„l A,S. ,F,l
1 1
SWM No.14
A,B,C,D, ,f A,B,C,D, ,l
l M 1
S4' MU Nos.7, 9
ft,l - *,I
2 2.
NPDES Outtall
--,..�,:•.�.,.
A,B, ,l Ae , Yl
1 1
ro u S N d a t e r * *
yl :^ 4 "'�"�? .� ? Aa..K: �, 5 . R y sA T
`G*.
^t ,i: ., y : 3 ..
(29 total:17 Existing Wells
l s a 1 a ;
�¢New Y
1w e 11 '.N' )
r
- h w ' ""�a•7g, r t" k2., -w '�` o °"'S`
: � �" w" "d aa."� a Y s¢^+: b �h a
a �,fi, wag* k r „e" w ,v.. a
TR
Ys.
k`'.nwa
l ¢ �`°`, aP dt >u •: x ,��� aw.,, fi ;�
!: v �'�°.i� w `, i ; �.��•' ,u
..v. .'" a::n. ,.`sw;�9°w`�w.w.s' a:'ww:4+a"k"rwk� "s ',.:: 4• :"
SWMU os. ,6,8,10,1
,l A,B, ,l A,E„ ,l A,S, A,E,C,l
12 12 12 12
Background
A,S,,i A,E,,l, A,E,S,I A,,,l
1 1 1 1
SWMU No,11
A,E, ,D,E,l A,S. , ,E,l A,S, , ,E,l A,E, ,D,E,l
1 1 1 1'
SWMU No,4
A,S, ,F„l A, , ,F,I A,S, ,F,l A,E, „F,l
S S 9 S
SWMU Pto,14
A,E,Rl9,,3 A,S,,19,1 A,S,,D,,1
1 1 1 1
SWMU Nos.7.9
�A,B,Lt,Ca,l
H I l l*,l H*,l I
S S S d
Analytical parameters for second, third and fourth round samples wfll depend to some degree upon, the first round results.
Appendix IX parameters, for e arnple,wiil be tested once, but will be analyzed in subsequent rounds based on the
parameters
detected,
Groundwater will be analyzed for both total and dissolved metals:
Anticipated quantity per sample round reflect total number associated with respective SWMU
r
A RCRA Metals
groups
S PPL Volatile Organics
,
0 PPL Semi-Volatiles (ENA`s)
E PPL Festicides/F 's
F Ethylene Dibromide (E E)
Cyanide (total)
H Appendix Ilat List
° t Ll,Cl-, F�, Sulfate

Table 3-3
Phase I RPJ
Field Quality Control Samples
Matrix'Pararneters
$/w
Oilaste
PPL Volailles
ROAA Metals
U'Cj-'F-,Suffato
Surface Water
PPUAppendix IX Volatiles
PPI-Serrrvolat4es
Round
Fourth
E ui went Blanks/Sam lin Round
First Second Third Fourth
7:
-----------------
PPL/Appendix IX SernivoWiles
7L Post, & PCBs
PPUAppendix IX Pest, & pCBs
Appendix IX Organophos, Pest,
Appendix IX Herbicides
Be
1
fi
RCRA Metals
Appendix IX Metals
Cyanide
ulfide
U,01-, F °' Sulfate
Sediment
PPL/Appendix iX Voiatiles
PPL'Appondix iX Sernivolatiles
PPL/Appendix IX Pest, & FCBs
Appendix IX Organophos. Pest.
Appendix IX Herbicides
Appendix IX Metals
Cyanide
Sulfide
U,Clm,F-,Sulfale
Groundwater
(29 total:17 Existing Well
12 New Wells)
PPL Volatiles
PPL/Appendix IX Volalfles
PPI-'Appendix IX Somrvolatiles
PPUAppendix IX Pest. & PCBs
Appendix IX Organophos. past.
Appendix IX Herbicides
Be
RCRA Metals
Appendix IX Metals
Cyanide
Sulfide
..........
I
V"fit r N 1", 714
K- 4� 9�h
'k 3"
1 1
fsoiest
1) Groundwater will be analyzed for both total and dissolved metals,
2) MSD applies only to organic parameters, For Inorganics a lab duplicate is performed,
3) Trip blanks will be analyzed for votablo organics each S'Npment of samples
4) The Potable water supply which will be used lot some of the equipment decontamination (via a steam cleaner) will be sampled and
analyzed for the pdooty pollutant organics. the RCRA metals, beryllium, lithium, ohloride, fluoride and sulfate,
6) Pflor to Installation, a onsets blank will be collected from a representative Wattera setup and analyzed for PPUAppendix IX volatiles
and $Ornivotalilles,
6) A rinSate blank will also be collected from one of thadisposable bailers which will be used 10 grab depth discrete surface water
samples. The blank wilt be analyzed for the priority pollutant organics, the RCRA metals, berytHum, lithium, chloride, fluoride and
sulfate,
7) 'PPtJAppendix IX- as used above means all parameters listed on the Priority Pollutant list and/or the Appendix IX List.
3-6
30956,06209

Table stitnated project Schedule
(in montbs pending U.S. EPA as indicated
1 2 3 4
5 6 7' 8 9 10 It 12 13 14 15 16 17 18 19 20 21 22 23
24 25
26 27 2 - 29
4-93 5-93 6-93 7-93
8'-93 -93 10-9311-931 -93 1-94 2-94 3-94 4-94 5-9 94 7-9 -9 9-9 0-9 11-9 12-94 1-95 2-95
-95 -95
-95 6-93 7-95 &-9
Work Plan Preparation
Draft Delivery to U.S. EPA (5-3-9 )
F NI / N/EPA Site Walkover (5-11-9)
■
A. (Phase d! enadifaed Work Plan, if needed)
ti 5,EPrt Review*- 2 months(estianated)
am
• Finalization -1 mondu (estimated)
. Final Delivery to 1J_5 EPA
A,
U,Sa EPA Approval
MMM(Phase 11 modified Work Plait, i needed)
Work Plan Implementation
• Technical Data Research
»: Field Pecannaim"nce
• Subs uface Explorations
NOM
• Monitoring Well Crtstallxtion/1n-Strearn Piezorneters
(Phase H, if needed)
• Environmental Sampling
• Soil ias/Landfill GasSurve
• Survey Controls
Data Analysis Validation and Interpretation
RFl Report Preparation
• Draft Delivery to D, & EPA
A
• U.S. EPA Review D montlis
• Finalia rt'ion (I rcaa>rtovs)
• Final Delivery to US. EPA
�
Database ManaRernent
= Date Deliverable
. Site visit
.:
1234

PROTECTION AGENCY
UN1,TED STATES ENVIRONMENTAL
REG10N I+
345 COURTLANO STREETN.E.
DOT 14 19S3 , TI-A TA. GE RGIA 30365
CERTIFIED 11
C.
�J EEI �tE L�EEE
4WD--
Arthur Gillespie
Environmental Manager
Lithium Corporation of America
Highway 1
Post Office Box 79
Bessemer City, Forth Carolina 28016
RE: RCRA Facility Investigation Work, Plan
Conditional Approval for Lithium Corporation of America
Bessemer City, North Carolina
Dear Mr. Gillespie
The Environmental Protection Agency (EPA) and the State North
Carolina have reviewed your RCRA Facility Investigation 1 Work
Plan, dated May 3, 1999, which you submitted as required
by
Condition II- C - 1 - of your permit which effective August 14,
1990. Based on out review, the work Galan has been approved
contingent upon the incorporation of the enclosed comments.,
Implementation of the RFI Work Plan and the contingent conditions,
must fallow the approved schedule in the Work Plan. Any deviation
from the a I Work Plan is a violation of the HSWA portion
of your permit. The first quarterly report should indicate the
requested changes as mentioned in the enclosed comments ninety 9
days from receipt of this letter.
Copies of the report should be mailed t
1 G. Alan Farmer
Chief, RCRA Branch
U.S. Environmental Protection Agency
9 Courtland Street, N.E.
Atlanta, Georgia 30365
Attention.* Channing Bennett, - E-2
Jerome Cad
Hazardous Waste Section
North Carolina Department of Environment,
Health, and Natural Resources:
Division Solid Waste Management
P.O. Box 27687
Attention: Bong Roberts

W.
wAb,
�r
t
if you have and questions concerningh matter, please contact
Charming Bennett of the RCRA PermittingSection at 4) 347-3433.
Sincerely our
2seph
R. Franzmathes
Director
Waste: Management Division
Enclosure

Q T. E. McLeod, Plant Manager
FMC Corporation/Lithium Division
Box 795
Bessemer City, Forth Carolina 28016
November 29, 1993
DEC
het
C .x. ix� + s
E
,� fC
4 k ��`�tl�L :,. W . 6
Subject. Permit No. W 000514
FMC Corporation. Lithium Division
Chemical Plant "`stater Recycle e
Wastewater Recycle, System
Gaston County
Dear Mr. Mc a
In accordance with your application received .July 9, 1 3, we are forwarding herewith Permit .No
WQ0008149, dated November 29, 1993, to FMC Corporation/ Lithium Division for the operation of the
subject recycle facility.
This permit shall be effective from the date of issuance until October 31, 1„ and shall be subject
o the conditions and limitations as specified therein. Please pay particular attention to the monitoring
requirements in this permit, failure to establish an adequate system for collecting and maintaining the
required operational inform ation will result in future compliance problems.
If any parts, requirements, or limitations contained in this permit are unacceptable, you have the
tight to request an adjudicatory heaving upon written request within. 30 days following receipt of this
permit. This request roust be in the form of a written petition, conforming to Chapter 150B of North
Carolina General Statutes, and filed with the Office of Administrative Hearings P.O. Drawer 27447,
Raleigh, NC 7 11-7447. Unless such demands are made this permit stall be final and binding.
One set of approved plates and specifications is being forwarded to you. If you treed additional
information concerning this matter, please contact lbs. Angela Y. Griffin at 19/ 733-5083.
Sincerely,
kj
0
Ad des ovvorird, Jr.,,RE;
4
cc: Gaston County Health lth Department
emit
Mooresville Regional Office, Water Quality Section
Mooresville Regional Office, Groundwater Section
Training and Certification Unit
Rust Environment and Infrastructure, Inc:
Facilities Assessment Unit
F.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
n Equal Opportunity Affirmative Action Employer % recycled/ t % po t--consurner paper

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
RALEIGH
RECYCLE SYSTEM PERMIT
In accordance with the provisions of Article 21 of Chapter 143, General Statutes of North Carolina
as amended, and other applicable Laws, Rules, and Regulations
PERMISSION IS HEREBY GRANTED TO
FMC Corporation/ Lithium Division
Gaston County
FOR T14E
dperAtibin of a 187,200 GPD wastewater recycle system consisting of two (2) 1.1. am pouds that are
ca able of removin solids colletted h scruhhe-e Wl"
This permit shall be effective from the date of issuance until October 31, 1998, and shall be subject
to the following specified conditions and limitations:
I This permit shall become voidable unless the facilities are constructed in accordance with
the conditions of this permit, the approved plans, specifications, and other supporting data®
2. This perrnit is effective only with respect to the nature and volume of wastes described in
the application and other supporting data.
3The facilities shall be properly maintained and operated at all times.
4. This permit is not transferable, In the event there is a desire for the facilities to change
ownership, or there is a name change of the Permittee, a formal permit request must be
submitted to the Division of Environmental Management accompanied by an application
fee, documentation from the parties involved, and other supporting materials as may be
appropriate. The approval of the request will be considered on its merits and may or may
not be approved,
5. In the event that the facilities fail to perform satisfactorily, including the creation of
nuisance conditions, the Permittee shall take irrarrediate corrective action, including those as
may be required by this Division, such as the construction of additional or replacement
wastewater treatment or disposal facilities.

6. The sludge generated from these treatment facilities must be disposed of in accordance with
General Statute 143-215.1 and in a manner approved by the North Carolina Division of
Environmental Management.
7. The issuance of this permit shall not relieve the Pe tree of the responsibility for damages
to surface or groundwaters resulting front the operation of this facility.
8. The facilities shall be effectively maintained and operated as a non -discharge system to
prevent the discharge of any wastewater resulting from the operation of this facility,
9Diversion or bypassing of untreated wastewater from the treatment facilities is prohibited.
10. Freeboard in the three (3) lagoons shall not be less than two feet at any time.
11. Any monitoring deemed necessary by the Division of Environmental Management to insure
surface and ground water protection will be established and an acceptable sampling
reporting schedule shall be followed.
12. Adequate inspection, maintenance, and cleaning shall be provided, by the Perrriittee to
insure proper operation of the subject facilities.
13. The Permittee or his designee shall inspect the wastewater recycle facilities to prevent
malfunctions and deterioration, operator errors and discharges which may cause or lead to
the release of wastes to the environment, a threat to human health, or a nuisance. The
Permittee shall keep an inspection log or summary including at least the date, and time of
inspection, observations made, and any maintenance, repairs, or corrective actions taken
by the lie rmittee. This log of inspections shall be maintained by the Perrnittee for a period
of three years from the date of the inspection and shall be made available upon request to
the Division of Environmental Management or other pen -tutting authority.
14. Any duly authorized officer, employee, or representative of the Division of Environmental
Management may, upon presentation of credentials, enter and inspect any property,
premises or place on or related, to the recycle system at any reasonable time for the purpose
of determining compliance with this permit; may inspect or copy any records that must be
Dept under the terms and conditions of this permit; or may obtain samples of groundwater,
surface water, or leachate.
15. The annual administering and compliance fee must be paid by the Permittee within thirty
(30) days after being billed by the Division. Failure to pay the fee accordingly may cause
the Division to initiate action to revoke this permit as specified by 15 NCAC 2H .0205
(c)(4).
16. Failure to abide by the conditions and limitations contained in this permit may subject the
Permittee to an enforcement action by the Division of Environmental Management in
accordance with North Carolina General Statute 143-215.6A to 1,43-215.6C.
17. The issuance of this permit does not preclude the Permittee from complying with any and
all statutes, rules, regulations, or ordinances which may be imposed by other government
agencies (local, state, and federal) which have jurisdiction.
18. A set of approved plans and specifications for the subject project must be retained by the
Pertruttee for the life of this project. A
2

1 . Noncompliance Notification:
e 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
to following.
a. Any occurrence at the wastewater treatment facility which results in the treatment of
significant ounts of wastes which are abnormal in quantity or characteristic, such
as the dumping of the contents of a basin or tank; the known passage of a slug of
hazardous substance through the facility; or any other unusual circumstances.
o Any process wait failure, due to known or unknown reasons, that render the facility
incapable of adequate wastewater treatment such as mechanical or electrical failures
f pumps, aerators, compressors, etc.
c. Any failure of a pumping station, sewer line, or treatment facility resulting in a by-
pass directly to receiving waters without treatment of all or any portion of the
influent to such station or facility.
d,. any time that self -monitoring information indicates that the facility is not in
compliance with its permit limitations..
Persons reporting such occurrences by telephone shall also file a written report in letter
form within 15 days following first knowledge of the occurrence. This report must outline
the actions taken or proposed to be taken to ensure that the problem does not recur.
•
2L The three (3) downgradient wells And W-7 shall be sampled inifially after construction and
thereafter every April, August,; and December for the following pararnerers:
calcium
lu n
TDS
Sulfate
pH
'Water Level
Chloride
F1 aaorde
hro um
Manganese
,Iron
Lithium
The measurement of water levels must be made prior to sampling for the remaining
parameters. The depth of water in each well shall be measured from the surveyed point on
the top of casing.
The treasuring points (top of well casing) of all monitoring wells shall be surveyed to
provide relative elevations of the measuring point for each monitoring well..
The results of the sampling and analysis shall e sent to, the Groundwater Section, N. C.
Division of Environmental Management, 1 P. 0. fox 29535, Raleigh, N. C. 76ti- 5 5 on
form "-5 ornpliance Monitoring Report Eo n] every May, September, and January.
3

*t
2, The two (2) lagoons that accept wastewater from the kiln scrubber shall be installed with
either a natural clay litter (as described below) or a synthetic liner (as described low)
,within 180 da s of ermit issuance.
•
For the synthetic liner, it shall be at least fl-mil thick and reinforced. It shall"be
photo -resistant, as the liner may be exposed during "downtime," Following
installation and inspection of the lagoon liner, and prior to waste disposal
operations, certification of the liners compliance with approved construction
specifications
and the liner"s integrity must be provided to the Division of
Management, Groundwater Section, by the project engineer.
21 any groundwater quality monitoring, as deemed necessary by the Division, shall b
provided,
2 � All wells that are constructed for purposes of groundwater monitoring shall be constructed
in accordance with 15A NCAC 2 .010 (Standards of Construction for ""ells Other Than.
Water Supply) and any other state and local laws and regulations pertaining to well
construction.
25. The Mooresville Regional Office, c , telephone number i ) 663-1699 shall be notified at
least two weeks prior to the construction of any monitoring well so that an inspection can
be made of the monitoring well location. Such notification to the regional groundwater
supervisor shall be made during the no al office hours from a.m. until 5:00 p.m. on
Monday through Friday, excluding state holidays.
26. Within sixty (0) days of completion of all monitoring wells, the P rmittee shall submit
two original copies of a scaled topographic map (scale no greater than 1:1) signed and
sealed by a professional engineer or a registered land surveyor that indicates all of the
following info ation:
a. the location and identity of each monitoring well
b the location of the waste disposal system,
C. the location of all property boundaries,
d, the latitude and longitude of each monitoring well,
e. the relative elevation of the top of the well casing (which shall be
krrown as the "measuring point")
f. the depth of water below the measuring paint at the time the measuring
point is established.
The maps shall be sent to the Groundwater Section, 1 . C. Division of Environmental
Management, P. 0. Box 29535, Raleigh, 1` . C. 27626-0535.
27. Upon completion ofall well construction activities, a certification must be received from a
professional engineer certifying that the monitoring wells are located and constructed in
accordance with the Well Construction Standards (1 A NCAC 2 ) and this permit. This
certification should be submitted with copies of the Well Completion Fort ( `-1) for
each well. Mail certification and the associated G -1 forms to the Penruts and Compliance
Unit, Groundwater Section, P. ► Box 29535, Raleigh, N.C., 27626-
4

For the initial sampling f the well as specified elsewhere in the pertnit, the, Permittee shall
submit a copy of the W-1 form with the Compliance Monitoring Porn, ( -5 for that
well. Compliance Monitoring Forms that do not include, copies of the W-1 form will be
returned to the initiation of enforcement activities pursuant to lei General Statutes 14 N
15 a_;
. The L - for the disposal system (See Attachment A) is specified
by regulations in 1 A NCAC 2L, Groundwater Classifications and Standards, Compliance
Boundary is established at either 1 50 feet from the waste disposal area, or 50 feet
thin the property boundary, An exceedance of Groundwater Quality Standards beyond
the Compliance Boundary is subject to the penalty provisions applicable under General
Statute l4 '- 15. a;
Permit issued this the 29th day of November, 1993
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
A. Freston award,Jr., p�.EDi
rector
Division of nwr nrnental Management
By Authority of the Environmental Management Commission
10

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1 Y�1,24000WLE

e
e 9 a C Or Ick-OTRAL
4
AFMC
�t july 8, 1993
ey Randy Jones
Permits and Engineering
t tqrter Quality Section
Division of Environmental Management
P.O. Box
Raleigh, NC, 27626-0535
Dear Mr. Janos
Several months ago they Water- Quality people in
moore~svillo determined that they two re-circul.atinrwater
systems at our chemical manufacturing plant need to b
permitted as non discharge recycle units. An application
and four copies for this permitting is enclosed., This
should takes cure of the need for firer copies of each
engineering document
Please note they following:
1- These are two long -existing xistin s. Earlier
determinations by your Department were that such
permitting was not required because we do have home aim
the slant: an NPDES Permit No. NCO005177 for the
treatment and discharge of process wastewater-. We also
have pending an application for a st rr w, ter permit.
7. One is a system of two ponds where air pollution
scrubber water at our ore decrepitation kiln is
re. -circled from the scrubber to one of the two ponds.
when one pond is filled with solids, the other` of
these two is switched in and the filled pond is
cleaned of solids.
3. The other is a Chemical Plant hater Recycle Lake.
4. Analytical data is presented for: troth of these
systems. We believe that this information is accurate
for our current usages.

�,
i

Page 2
08-JUL-93
5. Following your telephoned suggestion on June 17, we
are sending only one check for $400.00 to cover the
permitting of these three ponds under a single permit.
Separate applications are filled out for the kiln
scrubber ponds and the chemical plant water recycle
pond because there are some differences in the 'two
systems. Please let us know if it is determined that
separate permitting and an additional $400-00 is
required.
Please contact me if you have questions.
Sincerely yours,
4
advztl ,& IULt I
Arthur S. Gillespie, Jr.
Environmental Manager
cc. J. E. McLeod
G. W. Matthews
G. R. Scott
R. Ahuja
Rex Gleason- Mooresville

suite- orNorth Carolin3 ural ReSOUrceS
Depal-tment of Environmcnt7 Health,und Nat
DV� ision of E. nN,,jrorj=nta.1 MaLnagcmcnt
Non-Dischargc Pcrfflit Applica6on
(TIVS FORY MAYB t PHOTOCOPIED FOR USE AS AN ORIGINAL)
RECYCLE, FACILITIES
GENERAL INFORMATION: In Scrubber Ponds (2)
6 ridual, or otht�r):
1Appricant (corporanon, indi�
Print
-,wncrs o r Signing official's Nat= and Tiflt (thc� prrson v,,ho is .1cgally
2. 0
tjlt f.-cility 311d its c,*,)rnpliancc�):
ms-ponsible for
Box795
3, N,111 -Li tatter '
A d d rc s s
Tcicphonc No.: L.LO4 868-5400
4. y,rom�t ern cSxisionI cilily,ofr tstblislimi nomptr- titan oonualldlrc- connsinsttcs'metc'):
p,,*ct =tOn phans/spcCS., lCUMOF10arce, h Ghetto .cal Manufacturing, Plant
5A 'nll i 22 1993 6, Fcc Submivc& S,-M-0 -0-0
P., -cation Datc: _jqng
c 'ntv wh--rc t is locatt'd:
astrt
ou � 0 17 c 81 0 W of rtcycic- facifit)" location
1-a,;vude� Longitlildn8 I�
11. PERMIT 1Nj-1'0R-,N1,kTl0N-
ermit No. (will be corvipleted by DEM):
r,nc�_,
S
S: ncw; modificat, on,nl ,�--cify whvIlicr I
sections ,ppj:ant signatur"
11, 6 (oiiginand 3copits of eacl ). Eng
to ixrry
(on pg,6). Submit o pgs. al n New application for existing ponds.
s i g n a t urt nest-1--Q n, j r,,�j 110-, rc
IL of a rcncwal or m. od;ficafion to an
Itcj
applicatio-"'� is I
I f th; S
and issu
CX;Sfint, pcrmj-" list zhc )J
lw or prnv:�tc'
4 S publi-
FORNI- RFAC 4,191 o117
N

PAGZ�
H1. INFORMATION ON NNASTENNATER*
I Naturc of Wasttwattr: — 90 Domestic; % commCrcial.
_LO_O % Indusmal, _ % Othcrwastc (spczify):
Plewst provide a one, or two word description specifying the origin of thcwastr-wattr,
such as school, subdivision, hospital, comrncrcial, industrial, apartments, r-tc.-.
Lh_eryica1 Manuf
3. Volume of rwycic water generated by this project: 187,2 0 allons per day
9—g
4 planaEon of how mcyc1c, water volume was
from Air Scrubber _Et!njj_s
,5a Brief project description- Dust and fluorides Arg_yater bb
exhaust stack
IVDESIGN INFORMATION
I. Provide a bricf his,knig ofthe, compormnLs of the rticyclt facilities, including dimemsions,
capacities, and dctcntion tim.-s of tanks, purnping facilities, high wattr alarras, filters,
pond' la oons, etc,.-The-impoundrqtints. igQa!L st Qf two
AZLLd-Acre--PwWs--af
----
recirculating scrubbing water. Only one is used at a time. When one of
ether and whi l theJ
jri-bt tar to k rat Cree*—JR he
Crowders Creek and Catawba River Basin.
3} Classification of clost-si downslape sufface watcrs-1 _ :as establishce
by the Envieronnic'ntal Man agern-nnt Commission &- specified on page At of this
appication),
4 a powtr failuic, at the facill-Ly could impact waters clasffi--d as NN'S, SA, 11, or
des ac SC-r1l>-- "'whi�lh of 0,1t. =asurcs are being Implernc-ntcd to prcvem, such impL I, as
mquirtd in 15A NCAC 2H .0200.- Power fail —tbe—w&ter-
5, 'Phc facilitits must conform to the following, buffers (,and all 0t.1-r a-pplicablt, buffr-i-s):
2) 4DD fett bvtcln a lagoon and any rcsidcncc undl-,T scpanitt mxmcrship�
1)) 10,J ftc, l t cmn a surfacc- sand filtcr axed of �rcsidcnce undtr stparatc ov-ncrship;
c) 100 fcct b--twetri rexclycit facilifits and wattrsupply �-,oarcc;
d) 510 fl---, rcc,4,4.js facilitits and prop.x--rllincs;
2 of

T PAGE 3 3 1
If any of the buff rs sptcifimd in no. 5 abovc are not bc-ing met, l sc txplain homer the
propos i uff .rs will providc quaff car tt�.r protcctioc of the k`atcrs of the t tc Frith
no inema4sd potential for nui c conditions: Al I buff r•
__rtqqirements are met.
7. Are any components of the r cycle facility located vvithin the I year flood plain
ect
_ no. If es, brit fly scr l the -protectiveMeasures in crt to prat
against flooding.
a
to .
THIS
APPLICATION PACKAGE WILL NOT BE ACCEPTED 13, YTf
DWISION OF ENVIRONMENTAL MANAGEMENT UNLESS ,ALL OF
THE APPLICABLE ITEIMS Al',E ENCLUDED WIT11THE SMIMITTAL
Requircd Items
One onpirttll and tltrc- copics of tltc and appropriattly e ccutcd pplicat: rrfo
rM
The apr-opriate psm-dt processing fc,-, in acoordauicc. with 15A NCAC l-I ,0205 c (55),
Five sets of dctallcd plants ind slw--cific.ations signed and staled her a Forth Caro)ina
ch
Professional Engirtccr. tta plans must >irlurl.tt a c cral location warp, a sitcgtttal, v;�{ th buffers,
indicates h- c an), or-inl s or l and auger sarr7plc "arc takcn, along N
s ..art r s seed t rep r t lines, Each sheet of th plans and the first page of the spccificattot"
a
.- S t A i s u. 4..�s ,3 f 4 w a I ...k and w1'.=,a.m ci «„
For industrial wastc'� Ater, a compltrt chcmical analysis of the typical "a str":vvalcr
M. Use bc provided. The analysis rr¢ay in lud°c, but shall tto be iimited to, Total Organic
,anic
Carbon, BOD, COD, Chlorides, Phosphorus Nitralcs, phenol; J'otal '1`rihalomcthants,
'I,C� analysis, lysis Total l , o anatcd Compounds, Total Co'>klo,tip, and 1ea] Dissolved
Solids,
If la oon c a pa:,L of the facilities and the recycle gatcr is indus 'alm provide a
hydropcologic dcso.iption of the su sg,�rfaca to a depth of fast r (adl Ock, whiiht.ver is
lcss_. The nu cr of borings shall e suffi icnt to defuse the folio % it f, for the area
undcrlyin each major soli t �pc t the sit- sigrtifrcam char cs its.. litholo ' the vci ical
pcm,ta ilit), of the unr atttratcd zonc, the hydraulic ConduCtiVitY of the saturatcd zone, anri
the depth of thc_rrrcari seasonal high wattr tz 1c
1 i:r copses of Ali ray."o is cvaltrationsa agrccrcrtts, suppo:ir caicz.latio s, eta., cast l
sal` Itt"C as p of the spcaCfivattois �hrah arc• signed and scaled y '"`nor,h Carolina;
Iarofcssiora l Engineer. Although ccrtaidn portions of this mou red strhs­nittal retest bc,
do �."glop by other prof sstonals inclusion of thcsc ma:crials undcr the sign al,urrl a "Id sl-al
of a oxt't. Carolina professional rn signif"ics that he has reviv�+ez! tt"c:s material and
lt::s lt;of oat to hew consistc�t ykrtlt has proposed dcszprt;,
I ,fie° c.optes of th'. cxiswin j 3iSt 1i a:e Y �' l ;" a 17�t"d'fica c)n'

PAGEE4 (4,19 1)
TO: REGIONAL VVATER QUALITY SUPERVISOR
pa-se providc. mc with the classif5cation of tht surfacc watcrs idcntificd in number 5
bclo,x, and on Lht attachcd n-iap scgnicnt:
Nit= of stirfacf- watrrs- Unnamed 1! i V to Abernathy Cr
-Lme—k. CrawAers-lre
in 'the Catawba River Basin
ClassificaGon (as tstablishe-d by the EnNimn=rital Nianagerrtnt Corr un'scion ):
Ptopose d Classification, if applicable. ---- --
Signatum of rcgional officc ptrsonnel: Date-.
INSTRIJCTIONS TO ENGINEER
In ordcr to del rrtaane hethar Provisions for du,-1 or standby powcr n1i), Llx: required fO,- th,
subj= facility, the classification of Llic, closest downsiope surface. waters (the surface waters tht-t
anv ovcrflow from the facility would flow toward) MUst b,-- dctcrMinc-d- You are required to
SAIT,Tt t1iis foral, v'rith items I hrough 10 completed, to Lh-1 appro psate DI -vision, of Environ—mtnLal
!�Ianaqc,rrnent Rcgional Wat-s, Quality Supervisor (set attacheJ listing). At a nninirnwTi, you rilust
includr, an 85' by I I" copy of the por-tion of 17.5 minutc. USGS Topographic Map which shows
0-1- sutrjccl Suffacc watcrs. You must identify the lcx--adon of die facillty,xndl TI-ic closes[ elownslop-,
surfacc vvatcrs (waters for which you are rquesuna the classifica6on) on tht subrniitted reap copy,
tP -ted includtd wlLh thc, sub-niital.
The applicanton may not Lr- subnr�it,:,d until this fora-,i is compl-
1. Applicai*(cption,individtia],O-OLII,T_�prdratjonLithLqm --D--y5-jon 2, Narnc, and Compl= Address of Engin ecrinc, Firm:
and Infrastructure, Inc., 2 Market Plaza Way
C,,,j%- Mechanicsburg PA Zip:
I a tt: 17
Tcicphonc- No.
Kiln Scrubber Ponds
each
4. Stc-a;-�t 'FaHlity Volunic-
of two ponds.
5Nwnc of closcst downslopc Surfs cc waters: bnameA-Iribu-rnathy-And, Crowders,
Creek in the Catawba River Basin.
6, Counry(s) ,Oicrc Ix-pjtr-1 -jr�,j sul,fac- Gaston
7. Niap nw-nc azd date:
C�S --> (:-
S. No:-,,h C--rol;na ProfcVisional Engi�is:wr's Rt,gisnafion'No. I - I q
17-1�,,,,
9. 1�1-nn- N-�-nc ofEngjnscr U
M Sczl and ,dig mature (sptcify datc),
4 C) f 77
tf
1 rf -3

DIVISION OF ENV`IRONMEN-rAL MA-NAGEMENT REGIONAL OFFICES
(. 91)
A-shtvillt Regional WQ Soper.
'Washington Rcgional Suter,
Raleigh Regional ' ,, Si r,.
' Box 1507
S �t I °., Suitt lot
A-shtvillt.. %C 2,9802
Washington, NC 27889Blush;
NC 27609
7;/2S P 0
1 - 4 51
1 173 -231 p
on fonts
htliarti N
u nb-- MwdLson
Dwix McDowell
Bcrtit Ltnoir
Durham Nord.ampton
d rtll itthtli
Caaldcrt Marin
chowan Pamlico
F4w=bc Orange
chercAlec 'ttlk
v u
Franklin Ptrson
a vBlt V nc
ciay Rut rd
[tick F'�u° ns
Halifax
Graham Swain
l a Transylvania
Dart Pitt
G atts, Ty t ll
uhnsttar, WWTMI
1 t Washington
I -CC WiLson '...
J a " on
Hutford.. WayTe-
Hyd--
Faycttevillr l tgi nal WQ Slu r.
W'achov,L°i uildirig, Suitt
Mo rtsvil{t Rt tonal wQ au, r.
11min Lon Region. NYQ a r_
714
C S3;tll.
919l rtrh 14ain Street
M resvillt, N ` 8115
127 Ca.r'dinrtl Dnvt Exttnsion
'ilmingi
C19/486-1541
704/663-1699
a`aycliz,villt,
n, NC S dS-38
Anson Moore
y Robeson
Ali Mc� c~ l nbur
waswr,ck N*cw Hanov,r
Cwnbcrbund Richmond
CabarTus R0 wwl
C=wba st-Inly
rat onslow
liF>rnctt Sampson
Gaston Union
Columbus Il
lltuplsr
' At S dand
llydCll Ll "a,dand
Winslon-Sal*r'n cgio nal \VQ Super,
8025 North PcbrH Boultvaid, Suitt 11x
Winston -Salt., NC 27106
1 /761- 51
Plc hang #idolph
.Ash[: s lokc-3
Caswell sum
V Y{{
v
Lfard
of 7

Nargs and ::tit: Add:= I i din - ,gig F ;-- Rust Env ir ref.
and Infrastructure Inc..-2 Market Plaza-)
C:ity°.„ Mechnanicsbur Burr: PA zip�
n d t ttcst$ his fIhriiti i fir
It a � �f ��� Isrici°lt~icd f° hr�� � t�i csXic��t3 �P r:�c iiJ isiat"tc
grad comb s��. tis� c attest that to the ly- t of r y knowledge thc.
proposed dcsign has Men ywepued in accwdamce nOth the ttpplicab' regulations. It]oogh ccri iii
ftcanions of this sllhrniitnJ packay rnay have ktcn w' r-vclo d by 9 thcr pr fcsslcitisls, inclusion of
thtsti witha s 4.Indar inn stgna .Crt and sn', significs that I have T< vi—twe'd this niatcrial and have
judged it to to s: onr istc.rt with ihc Iirojwscd MAY.
o ih ° ✓w+»+ "++.'.s. Y+ !F�Ir "y4•d'tl K s4o.iiwd �a..., 4d_.t. i F yob Rci
tl »Y4i. }gG.�+�wu�n ,mod` o. ISO
Pt�i n t. #�a: i ��...+. "o f E e a..,. i f i ce ti�4^e 6" � b-
1, J. E. C Lod _ a,-tst unat t ,is i?ppliica-,ion c) _ ecy I Wate
rr_Ptr:. UjiScrubber.�
as k = e rc A C 4vA ty Inc1, S ";cC u :-'aI cgild Co I C t e 1 c, tin,,* txtss of ni IT, t v]-, t"+ C,.
,. ry
that it all rA. .,;,.�.,. d �;�xnS O wiiz» application �'..'°�`.nlei �.:%!a""iw-�:" S�",H,a A if i d r �F..' is±.�t�p0 , r
tn,'0:'��.._.?X � �X�,w°�T, '.�"� Wit:. 'not i'i" ��a �'"' t.: �� ��ii; �,i r, i �.� ,'i.e t� �xt w' "T, sX t.W
,. a �. m..
r
m
'�X I'�r Xm a� w..er.. 1 a .. �'' ,°5 a�g�rev�.,=- . 6 1 A ��. 1. 4 G E , hN %"fir #.0 ik)« i d "u_R A i St," Pl #0a . i � 0
Ia F& , IW, A-,1, D ,`,,A 'TEt`JAJ �, S+1tJULD a E S U 07 ,die t 1":t:: F{.r"t.lrO)V.Ii%G' A!)IiR,!-?:`
NORTH Ctl..I` O LI A DIVISION OF ENVIRONMENTAL MANAGEMt:..N se
PERMITS AND 1AGINEERITOG UNIT
PC)ST fit- IF T.t.. BOX 2.�� a
5I NORTH SALISBURY STREET
.M ENUMBER
6 F.
,, f su
r"

PERMIT "ION PROCESSING
FEES
effective t ber 1, 1990)
1,000,000 GPD
Industrial ..:w.
4 1
DOmtstic/Cooling Water
4
1,01 - 1,00,0,000 GPI
Industrial
400
$2 q
mtsti lin Water
4
$0
1„001 - 10,000 GPD
Industrial
4 +
m sti c ling Water
$400
$2
r = 1,000 GPD and
Sing -It Family Dwelling
$ 4
120
Slud < or = 300 Ares
4
Sludtge > 3040 Acres
54
2 11
Scorer Emcmions
�b (nT dcltgated)
$$400
Scw r Extensions
(dticgat d)
S2 d
Closed -Loop Recyclt
Crr Evaporative
4
NOTE: The Fees for SoilRem
diation Projects are the
same as for Sludges.
Under tie Sewer Extension
Fee, "delegated to miinicipalitics°" applies
onl�� to those 9OVerritnental
jurisdicticins that
have specific delegation
review aufhoritN,, as
granted by the
of Environmental
anagernen t.
7o
(J

state of North Carolina
Department of Environment, Health, and Natural l esoIUrces
Division of Environmtntal Nlartagtmcnt
Non- ischargt pc t Application
MUS FORM MAYBE PHOTOCOPIED FOR USE AS AN ORIGNAL)
RECYCLE FACILITIES
GENERAL INFORMATION: Chemical Plant Water Recycle Lake
1,. Applicamt (c ration, individual„ ar other): FMC Division
n
Cyr nr tt n Lit er
;, nt owners or Signing official's ial's Name and Title (the rson who is Jc ali p
resp rtsil le for the facilityend its c rrtpl ancc.) J. E. McLeod
P1 ant Tana r
. Mailing Addr ss: Box 7
95
its,•: Bessemer City
tote. N.C. 1p 1
Project liar (subdivision, facility, or establishrncnt namee- should
ho ldA cer consisteHunt with
p.oject narne can plara.s/speds.° letters rat flow accpcanc -, . g
chemical l Plant plater Recycle Lake _
. Anplic tion Date: - - 3
6, Fcc ubtnar-d: tlt; w fl(1
T Count %vhcr . Pr0j t is located; Gaston w m
rd 017' ; L n irudc 1e1 , of r cycle facility lc ation
S.LO� � ttmtl,�:
11. PER,NIIT IlIIFORNIA 'I N:
1 .Permit No. (will be completed by DENI):
X new; t-- c tal i rrac :iacat; ra.
pccify Nvh tliccr prc+lect is: III, III, � a lE °ant si natu:c
If rent •al, complete OnIN° se__ itti#al and 3 cc�p:es� f each). � it�eed
(tarn pg.6). Submit 0 r pis. ], �, 6 (�r� ,
signaturt not rtouirtd for mne °al,
New Permit for Existing Pond. an
a. If this application is ban- Sub- s`sttd as a result far nc al or� modification to
e istt t perrrut, list the )6stin per it nTamb r _ __
d is�ur d tc
applicant vublic tar pri�°atc.
�. l�.cifr° '�ah.thc.r the
� �pplaant'is

PAGE 2 ( �91)
111. INFORMATION'ON WAS�TENVATER:
I Naturr, of Wasttwatcr: % Domcstic; % Corim Mial;
100 % Industn—al;
, — % Othtr wastc (specify).
2 Pleasprovide, a on-, or two word description specifying the origin of the wasttwattr,
such as school, subdivision, hospital, conarntruial, industrial, apartmcrits, r-tc,:
Chemical Manufacturing Plant
3. Volunat of rezycle wamr gtntrnted by this project: 7,,300 Ions al �rday
g P,
4. Explanation of how rrc:ycIc,,A,attr volume was detenatined: Actual measured
recycle grater avers for Jan. -!a 1
5. Dricflproject description:
IN'. DESIGN INFORMATION
Provide a brief listing of the components of the recyc1c, facilities, including dirk risions,
capacities, and dctcntion times of tanks, pumping facilities, high$attr alarms, filters,
ponds, lagoons, ctc.: 4 acre reCY cle lake de pth is thou ht to aver
17.5 ft. The volume is therefore about 23 million gallons.
2, Name of closcst dovvnslope surface -,xL[crs: Unnamed tributary to AbernatE y__
and Crowders Creek in the Catawba River Basin.
Classification of closest downslorpt surface, waters: (as cstab is
bN, the En -viron rnc,,i t,,,.l 1�,Ianagemcnt Commission & sptcificd on page 4 of this
apoliatil on.
4, It' 2 pov,,cr failure at the facility could impact eaters classifitd as WS, SA, R-, or
SB, &SCTibe, ',V11iCh Of 01C Mtasur�,s ut bcing implcm-rated to re 1cr T such impact, as
ral)uircod in 15A NCAC 2H.0200N/A
I
-5. The faciliti-_s must conform to the follo%ving buffcrs (and all othci- applicable buffcrs):
a) 400 fcc, b-_twttn a lagoon and any rcsidcnct undcr scpajmts owncrship-1
b) 103 f= b t ccn a surface sand fid to and an), rcsidcnct tinder stparatt ov-n-,r-ship;
r J fo_-tt)�-_twtct1 rcc,,cJt -;�;,izs and a watt. s, pply soucc-,
d) '50 f b,-t wccn !, h� rccycl f aciliti,-s and propci L�, lin ts�
2 of 7

PAGE 3 0
6If any of tic buffcrs sptcificd in no. 5 abovt arc, not"bting mr-t, p1cast txplain how the
proposr,d buffers will prow do tqual or Nntcr'prottction Of thc "'A'zLcrs of the Statt'- with
no incrcascZ potcntial for nuisanec conditions:
are met. The lake is very nearly 50 feet from Highway 161.
7. Are any componcnts of rl�lc recycic faC.-Ity Iccated within tht 100-Year ficKXI Plait)?
YCS; — no. If ycs, b6cfly descrilx tile proteztiva measures in tak-cn to promcl
against floo<fing.
TMS APPLICATION PACKAGE NVILL NOT BE ACCEPTED UY TIJE
D IVISION OF F--NNrLRONIENTAI-,'NIANT UNLESS ALL OF
I'liE APPLICABLET M CLUDED WITIJ TI-TE SUB M ITT A 1,
Required hern-7.
a. o,igin2i and th,-= copieCif the aornplctad and appropritciv cxe-cuted appl3cationfo, 1.
bTait mar-propriatc pcTTPit processing f,,,-, in accordanct with 15A NCAC 21-1.0205(c)(5)
a
d.
0
f.
a
FiN,c sets of dciailtd plans and specif] c at ions signtd and scaled by ea North Caro ' )in ' a
ngi Prof tssional Enter, The p',znS n-just it-,��Iudt a general location inap, a site map
indicatts whcrc ap,,,,,, I)orinp; or hand auger samples WeTC taken, along w;th b0ffc-s,
Structures, and prop--r-ty E-ich sh,---t of the plans and -Ll�c 1-irst, PIge of tip fion S
mu st
fit signckl and sczltd.
For industrial wasIe,%xatcr, a complete chtmical analysis of the [Ypical wastcwatcl
includt, but shall rot r o, Total Organic
MILISIL lac pt-oviftd. The analysis may lac litylitt, t
Carbon, BOD, COD, Chlorides, Phosphoms, Nitrates, Phtmol, Total Tnihalomcihancs,
TCLII anallysis, Total 1-Ialogcnatcd Cc;rripolinds, Total Coliforms, and Total Dissolved
Solids,
a
if la arms p-rc a part of tht ftcillfics and the recycle wattcr is indust.r al, providt
tT whichcvcr is
1pfion or th facc o a depth o� 20 I-= 0
h v d pc o ]o c, i c- d c s Cn c sul b s u
less, The riumbcr of borings shall be sufficitnt, to defint the following for the area
uncitrlying cash major soil tYpc at Inc silt: significant changcs in li'ftjology, the 'v-1-nical
pm-incabillity of the unsaturated tuns, the hydraulic conduc,"IvIty of tilt saturated zont, and
the ftpth Of Lht rntan sc-asona-I high watcr tablc,
jt;o- -rits, slippor-ling calculations, rtc., M" ust
F-ivc' copics OIL' all rcpor-ts, cva
wh'ch art sine and stalcd by a Nonth Cazohna
suba-�tttd as a, pa�-t oi' tht spc�cffications I I
Professior.a! Engintcr. Although ccr-tain portions of this rcc,uiTc'd submittal must bc
ture and stal
is, inclusion of thcst matcrials undtr ffic sicn?
dcv-.Iop,-,d by other profcssion�l 11
o� a North Carolinz Professional Enginc�cr signifits that he has rcvicwt-d &iis rnalcria,J alld
has jud-btd it to lam. consisicnt \vith his plop A d-lsic"r-
Five copics of the cxisting PCrini, it rtnc%val or a
3 or

PPG - 4 (1)
TO: REGIONAL NVATER QUALITY SUPERVIS P%
Picasr, Providc mc with the classification of the surface v,,atcrs ldcritificd in numb r 5
klow a-nd on the attached map scgmtni:
Nanat of surfacr-wamrs: Unnamed tributary to Abernajq_±!jdC tr d s Cr l
the Catawba River Basin.
Classification as cstablishtd by tht EnvironrncnW Managcmcnt Commission .
Proposed Classification, if applicable:
Signature of regional officc p--sonnrl- Datc-
INSTRUCTIONS TO ENGINEEJ�'
In order to d=mn1nc'"�hcthcr provisions for dLial or standby po-,vtr T-nay bc rcquired for the
Subject, filCility, the classification of tale closest downslopc surface waters rtlra surface swat rs that
any overflow ftom thr- facility ,vould flow towaid) niiist be ftic-n-nincd. You are rcquircd to
subnrit Ous fort-ni, with itrts I thrmigh 10 cornplctM, to the approp-natt Division ofEnvironmcmal
lanai cun:rat Rcgjonal Water Qut,Jjty SupLnisor (s", attachtd lisrint,,,). At a minimum, Nou must
include an 8,5" by 11 ". copy of the peatpionofa 7,5 minutc. USG S Topog-,aphic IvIpp which shows
ti"it- subjsct surt"ace %vatcrs. You must iftntif), the location of the facility and th.- closest downslop-_
surface waters (vvattrs for which you we requMing the classifir-a6on) on thc subrniutd n-:ip copy.
Ine application may now be submittecl uTjji,1 tads fonn is cornplemd' and includM wvith the sub=Ial.
I Applicant (corpamrion, individual, Or MhCr): _ftCCesar P_0ratt0_n_._,__---
Rust Environmental
Na a,
and Infrastructure, Inc., 2 Market Plaza Wa ._
Cj� Zip. 1705
Mr: Mechan S t a c: PA
'I't1cphonc No. (7171795-8001
3 3 e
. llroj,­_c�t Name: Chemical _Plant Water clLake Recy
4Stcrag-_ 'Fac",lity Volut-,je: 23 000,000 zallo,-,s
5. N?j-,i-- of closest do,.vnslopc surf ace watcns: Unnamed Tributary to Abernathy and
Crowders Creeks in the Catawba River Basin.
6. Cmmty,(s) whe-rc proisct illd stjlacc waisrs art- locatcd:
7. M.ap name aund dam,
8` C—arolina Fltorate. ssiorj,:,' "'nc-int—'s Ptvistration No. 4-
- 9Pnin'Mu= of Engirl.Scr DAo�t)
M Sez�l and Siri at (st)tzifs, dat,0-
T

DIVISION OF MEN'TAL MAINAGEMENTREGIONAL F s;
Ashtrrillr. Regional WQ Suter.
'*VaShinglon Regional WQ Super,
Raleigh Rcgional WQ L,, r
S
1507'
tzt ,, Sant llli
hovill , NC 2850
rox
trrl�1C 7.75
� , NC 27609
7 / 1 5
It - 1
1%7 .231
Avery ?*Lacal
Beaufort fonts
C rath Nash
Buzxornbo. Madison
Etcrtic, Ltuoir'
taa r Northampton
McDowcll
Martin
e
Caldwa it'lr ll
?
Char lino
'!klin Person
Clerokm Polk I
Craven
May u t rtl
rnanHalifaxr
Graham Swain
Fitt
Johnston Warren
III Transylvania
Gates Tymll
Wilson
Hmd=son Yancy
Grccnt Washington
1 zn
limford alp
HY
ayCtttev°11l F, qional WQ Saps.
M r svillU Rcgi n l NVQ Suly- ,
Wilmington Region, MIQ Suprae.
WanlaovL% Building, Suite 714
`
919 Nnrth hi2nta SU Mt
12 7 Cardinal Drivc Emmas.tttt
aYc vili , NC 28301
M r svills, NC 11
`ilmingt n, ' ? "�� S S
rt a Moore
Blxkn
:l--xannd--;- Mecklenburg nbur
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Robeson
Cabarrus ow s."s
Cart".t' t rn lo'x
C Ltd Richmond
Catawba Siar,ly
"lurnitus PCJ16cr
Harn cz Sampson
Gaston Union
Duplin
110k Scotland
ll Clry artrl
jM oqR
nt yorrl�c,r y
rI,
Lincoln
NVinston-SaArz--n RcgioTial WQ Sur,.).-r.
025 NOTUt Point Boulevard, Saute 11�7
NC ly`�
WulMn-SalemX 4
'1J71_?1
Davy 'Wamuga
r
oy t
{

Nann� and Compltl� AddraSs W 10jrIctring Firmy Rust En vi Eqnmenj_ggd,,
_jgfrAj,trUjtUr,_ Inc.
2-Market Plaza Wa_y
gon KAMM Yaw 5-5—
urg TOP: AIM ------
Tcic-pho;,,­_ No, [phone]
Professional Enginver's CertificHow,
�_JD t _L) (_L�O_L- , alast Eli at tills applint ion for rlz I
CO /? /-'b A A -r ^J has by me, and is aczurate
and Conols: to the bnt, of Iny knowl-,rig, I furthcrattest that to tht Est of my Lnwvltdgc thc
Drop osc,d ftsign has k-tti, pre am in accordamcc,"i0i the appAicab1c. regulations, AJ,,hough ccriah"
ponions of As submitual packag: may havc l�cn sicycopod by ca,­,.r profcssionals, inclusion of
One roatmials undo my Agn-aturc and spa significs that I have mvicvvcA this mattfial and ha've-
judgc,d it to I>,- consisicrit with tht p-.olx)scd ftsigri.
Not-th, Carollin a Prof"wo an! Eng1mr's 0gis =0 a v ' too. 40031-5
w ✓Cd C
Print Narric of
,_J Signiatu7-c
A A A R 71113
I_
4,
ApplkanA Certificahon:
J,J. E. McLeod atint Wt this applicaLion for Non -DjXqhArqt____,
_fermjjjqr,Khemicgj
has tymen rMwed by, me wnd is a�:curatt and conVlne to
Chc 'rx--s! of tny
17 Undc-it,'ur'd
that if all rquAd of Us
apphcation no� carnpink
and, that if all
sup,,porfin ,,:
pans
Rummicnis
are noz indusick'l, 0 i� application packagwil; R
_4 /? /k/
murvoi as'
thE COAMETE.D AP1_1C,,,T10X PACKAGO MrLb%),V,G
BESEN7 TO ThE-
NORTH CAROUNADIVISTCK OF
QUALFFY SECTION'
PERNITTS i*,ND ENNC,1NEEF,',ENCx UINFF
POST OFFICTE BOX 2933'5,
512, NORTH S-kLIS11URY STREET
RALEIGH, NOR'TH CAp',OLLNA 277626-053S
TE1_F1_'H0N1,-_ NUMBER: 91W7330OS3

PERMITL C N PROCESSING FEES
(effective b r 1, 1990)
��W
1,000,000 GPI
Industrial...
Dormstir./CoolingWear
1
,1 - 1,000,000 GPI
ndusnial
Domcstic/Cooling Water
$ t
1.00 l - 10,000 GPD
Industrial
5400
$200' .
P rr
< o—
�yry pw1,000
) p S t
Jud9 < a = 300 Acres
NOTE: The Fees for Soil Remediati rr Projects are the
serge as for Sludges.
Under the Sewer Extension Fee, "delegated to municip litics" applies
Ot lv to those governmental
jurisdictions 'th It
have specific delegation
review authority, as
gr2nted by the Division
of Environmental
Management,
+ of ?
I

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1 NLI
NOTE: Map Derived From U.S,G.S, 7,5 Minute
'Topo. Quad, Bessemer City, N-C
k+
DUNN ORTOR TION Site Location Map
DUNIN Pha n,, 17 E001 Fax. 7171'77" `-82180 Bessemer City Facility
11 7619

FMC CORPORATION
LITHIUM DIVISION
ION
BE SSENIER CITY, NORTH CAROLINA
DESCMPTION OIL SITE GIB OLOG p/HYDR ` EOL Y
I.I. SITE GEOLOGY
The natural geologic materials present on the site have been classified into four general groups.
These materials groups are soil, folire-soil, saprolit -weat cored ro , and bedrock. Soil, frorn
the surface to a maximum depth ofapproximately six feet, is generally a well -drained sandy clay
foam, Ilraderlyring the soil and extending to tiae depth of bedrock is a saprolite material. Sralarolke.
rat the site: has been subdivided according to the intensity of in -sitar chernicaal weathering crates
saprolite-soil and saprolite-weathered rock, Bedrock consists of alternating units of nretarnorphie
schist and gneiss arid is the parent material froin which the overlying salarolhe and soils were.,
derived,
The soil in the vicinity of the site has been mapped by the USDA SCS, its shown on Figure 1- ;.
Bec.auscw Most Of the site Was used as an industrial rraaanufact urin facility prior to raaap ing by the
Soil Conservation Service the major snail classifications are disturbed wail types The area
surrounding the plant is inaa ped its Urban Land (Ur). This map unit consists of aareaas where
pavement,, buildings, or other urban land uses prevented mapping of the natural soil cover.
sraarall part of the northeast corner of the site was mapped asCecil-Urban land complex t f . This,
nrap unit covcrs areas of raaixed Urban I -and l'ri and areas with Cecil sandy clay loaarn sail. The
Cecil sail is ar well drained soil developed on p edniont Uplands with slopes ranging from 2 to 1
percent, FI y pic;all�', these soils have a surface. layer of 6 inches cal" dandy clay loarn, and more than
5 inches of red clay subsoil g.raadinY dcra;nwar•ds to as red clay loam, The subsoil is aanderfa n by
loam, saprolite, and \veathe.red granitic rock.
The dominant natural soil type in the site area is tire Taaturn milt loarr°r (Ta). This sail is as well
drained sail developed orgy piedmont uplands with slopes ranging from 2 toad percent. Typically
these soils have as surface laver of d incises of bream silt loans, and racaarly 35 inches of red silt
clay subsoil grading to a redsilty clay loana, underlain by a mottled bro\�,nish yellow, yellowish
red, and red aa rolitc, Below tl _- saprolite is weathered sericite schist or'phyllite rock- at variable
depths,
1.3 S,,�, P I.aLTE,
Saaprolite is unconsolidated material which is derived from in -situ weatbering of the underlying
bedrocks. The saprolite is subdivided here into two gradational zones Based on the intensity of the
reaache.rnical alteration of the parent racks rtaaateriaal. "l"he upper none, saaprohte-soil, consists of sail
that retains relict structures of the original parent rocks. The lower zone, saprolite-weathered
rock, consists of friable weathered rocks. The subsurface transitions between saprolite-soil,
saa rolite-we.aatl e.red rack;., and bedrock have been defined by the mechanical properties of
penetration resistance obtained during drilling of existing can -site monitor wells. Standard
penetration resistance, is as geotechnicarl test lacrforuie.d during drilling operations wh. ,It is used to
naeaasm', the competence or mechanical strengfh of in -situ geologic material, Saaproiite-soil Isere
is defined as rraateriaal having ar penetration resistance of less than 100 blare counts per foo°.

FAIC Corporation
Description oite geolr�
Saprol i te- weathered rock is defined as inaterial overlying bedrock with a penetration resistance
greater than or equal to 100 blow counts per foot. The top of bedrock at the saprolite-weathered
rock/bedrock contact is defined as the depth at which standard soils boring techniques can not
effectively penetrate the geologic material.
The thickness of saprolite is highly variable. For example, the depth to bedrock ranges frorn 27
feet in boring WI to greater than 100 feet in borings W4 and Ll (Figure 1-4). As in most of the
Piedmont, thicker profiles of saprolite develop on slopes and in valleys while thinner profiles
develop on topographic highs andridges,
The saprolite-soil material of in boring samples typically consisted of firm to stiff, orange -
gray to red -brown, irticaceous, fine sandy silt. The standard penetration resistance generally
increases with depth, and typically ranged between 10 to 60 blow counts per foot.
The saprol i Le -weathered rock obtained in boring samples typically consisted of very stiff to hard,
tan -gray -brown, micaccous fine to coarse sandy silt with gravel size fragments of weathered
rock. Standard penetration resistance generally increased with depth frorn 50 blow counts per
foot to greater than 100 blow, cotints per inch.
Since bedrock is not exposed at the ground surface on the site, relict rock structures within the
exposed saprolite were measured to obtain a general orientation of the site geology. Relict rock
structures within saprolite-soil exposed in as drainage ditch were measured to strike North 46'
East and dip 75' Southeast.
1.4 BEDROCK
Bedrock at the site is not exposed at tho ground surface but the depth to bedrock has been
inferred from on -site drilling records (sce Figure 1-4). Auger refusal and penetration resistance
tests can, be used to identify the top of bedrock, althotigh refusal may also result from
encountering boulders or® lenses of relatively hard rock which do not represent the top of
continuous bedrock.
A core sample of bedrock was obtained from boring W8, The rock was a moderately hard to
hard, slightly weathered, inediurn dark- gray to light gray, fine-grained biothe gneiss with quartz -
feldspar bands or intrusions. Joints and healed Joints were close to very closely spaced.
Foliation was variable but typically dipped approximately 70 degrees. Accessory minerals
included chlorite, calcite, pyrite and hornblende.
1.5 SITE HYDROGEOLOGY
1.5.1, Aquifer Characteristics
Presently at the FMC facility there are seventeen (17) monitor wells which have been drilled on -
site ranging in depths frorn 20 to over 100 feet deer). Based on water level information from
these wells, a single water table has been defined beneath the F?vIC site. This is best illustrated
at,wells W-22, WA, and W-8. These three wells are grouped closely together (Figure 1-4)taut , are
completed at different depth and in diffem-ra, materials. Wells W-2 and W-4 are completed in the
saprolite-soils, whereas W-8 is completed in bedrock. Water levels in these three wells are at
nearly the same elevation and the, changes in water level over time have been uniform. This
uniformity of water levels demonstrates that these three wells intercept the sarne aquifer. Thus,
FAIC Corlwration 2 July 1993

FAIC Corporevion
Description
the different geologic materials at the site within the tipper 100 feet are riot hydro geologically
separate, but react as a single aquifer.
To date, limited hydraulic conductivity values from slug tests of wells in the four different
geologic materials present have been obtained, Overall, the geologic materials have lower
hydraulic conductivities %vith the increased degrees of weathering, I rhe micas re hydraulic
conductivities obtained at the site vary over an order of magnitude, ranging from 1.5XIO-4 CIIVSCC
(0.4, ft1day) to 3.4xI0-cnVsec (9.6 fr/day). Four wells compIcLed in the saprolite-soil zone had
hydraulic conductivities ranging from 1.5xlo-4 cm/sec (0A ft/day) to LftlV crii/sec (4.5
ft/day), 'File average hydraulic conductivity value obtained front the saprollie-soils of
5,Ox 1()-4 CjjjjsCC (1.4 fUday) is considered to be representative of this soil zone. One hydraulic
conductivity value was determined for each of the saprolite-weathered rock and bedrock zones.
These Nvere I.OX10-3 Crictsec (2,8 ftJday) and 3,400-31 cm/sec (9.6 ft/day), respectively, These
hydraulic conductivity vairres are considered to be representative for (lie geologic materials found
at the situ,
The difference in the hydraulic conductivities of the geologic materials underlying the site are
due to the. variations in the degree of weathering, When bedrock is broken down into soil, the
minerals in the rock are reduced in size to sand, silt and clay size particles, Tile soil has as lower
permeability than the bedrock because the finer grained size material in the soil restricts the flow
of water through the material. The bedrock pernicability is controlled by the openness and
intercritinectivene-,ss of the fractures. The soil forming processes can clog up these fractures with
fine ,ralg 'tied size material.
Tile ore tailings, placed over large areas of the site have a hydraulic conductivity that, is
significantly higher than the saprolite-soils on which it was placed. The ore tailings have an
average hydraulic conductivity of approximately 1.5xl0-3 ciii/sec (4.2 ft/day), This may cause a
preferential flow of water within the ore tailings rather than in the saprolite-soils, For areas in
which the. water' table is within the tailings, ground\vater would rend to floe within the ore
tallin-,s rather than within the saprolue-soil,
I
The depth to groundwater at the site is closely related to the topography, In the upland areas the
depth to oroundwatcr is typically from 20 to 30 feet below the ground surface. Tile lowland
areas have groundwater much ne.trer to the surface, typically less than 10 feet. Wells located on
the slopes had depths to grOUndwater that were. intermediate, typically ranging from 10 to 20,feet.
1 Z7�
FAIC Cornorevion
3
JuIY,19,93

Plant -Area V
T, 6
m
1'
T��
t
r
a
w.
"
f
a
T
r
A d.
H
1 T
e
�d
(,t t
FMC Pro
prt
_. -
Boundary
.• yA
* FMC Property
Boundary
r - r
I :'.M
POND ,,� � �; •._ :_ � �� `�, . , ,
a T SOIL WqtS
* ..DCI Care Tailings Lake
mr ,
.��
URBAN LAND (Url N X.
ALAMANCE GRAVELLY LOAM (Arn)
u
'-- „�- etas:HaaMLOAM 4%al
CONGAREE MO NarE: SCALE IN FEET
Li" 4CO f'ROPERTY BOUNDARY g Base mapderived from .map prepared
.+W'M 1 �tiOM Ka"11_5roIV tiIUNTy,a*tilt. 5UI? fy GrCd.�I.ISHS�f"19 by ER
mm DUNN CORPOPkTION Site Soils Map
_
Engincers, Geologists, Environmental rk
kientists
_.. 2 Market Plaza Way, MeChaj„jc3b6r& PA 1055
T NN 1>ht: 717/ -8c a ray: 717/ 5-8290 Bessemer City acili
tea°
311 1' 4

Table
Analyses of Chemical Plant
Water Req Lake
SWMU No.1
(concentration in ppm, mg/L)
ampte
1ste
ii
SO4 CC
&
8
ett n
on
06/03/88
27�O
21
9
22
8 0 4 200 90
9.7
373.E
6.5
6w
06/22/88
8.5
M 6
8.2
12.0
0.0 3.6 3.1 179.1 118.0
9.3
345�1
3.7
6.8
06/29/88
16.1
21.9
9.5
13.1
0.1 4.1 3.4 1 M O 90.0
9.4
336.3
5.0
6.2
7106/88
16.1
22
10
13
8.2 4 3 178 90
9.4
336.3
5®8
6.
07/13/88
21>9
19,1
3.4
17.2
0.2 2.9 4.0 178.3 110.0
88
354.0
5.8
6.
9/07/88
18,4
34.8
13,4
29.4
9.0 3,6 3.0 I M 1 70.0
9.1
35Z»7
8.7
5.7
09725/88
22,.7
29.5
12.3
17.8
0.2 3.5 2.8 188.4 110
8.9
359.0
8.5
6.4
average
g
r
19.7
24,1
18.1
17.8
0.1 3.1" 3.3 178.0 35.7
9.2
350.9
5.6
5.4

15.,, t.:
x'M",`&;F S;F E;,ki' 'z
t "�
k°., y,"
I
Table 3
Analyses of Kfla Dust particulate Scrubber Water
fr'MUNta. p and SWMU No, 6
unC nttatrons in ppm (mg/1)
SAHPLN
Date
AI
A
Ba
aCrs
d
Cr F.e N :.. I.i Na Mn
Ha
Ni
Pb
Si
Aq
F
Cl
Sulfate pH ....
Xiln Scrubber
Pond 4waterl
5A83
980
sac
N'A
NA
18tt
NA
1,5 330 NA 87 NA 280 220
220
2.5
0,2
N,A
NA
1600 NA
21-00 NA
Kiln Scrubber
Pond (water)
11188
626
ND
0.09
M8
8,27
NA
1,74 328 No 10IOP 26,2 205
44.8
2.0
ND
396
NA
NA
MA
1015 3.1
Kt'tn Scrubber
Pond (faltered)'
11788
627
ND
0.99
038
8.46
NA
1.74 331 Np 107 110 26.7 208
44.9
Z,o
ND
404
NA
NA
WA
1110 3.1
K in Scrubber
tlrseararse Pipe.
i
3189
836
Na
VA
3.D
65
NA.
9.8 287 NA 114 121 45 242
72
2.0
NA
447
RA
MA
NA
1646 2.7'
NA - Net Analyzed
RD - Not Detected
i
1

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' » _
kM
.2 e'S? u3 p yi 9f=6R C'.. �$6.:.-:76,.. %..
gm
4.«
w
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m _
aeaar* = t
' .. 8P9.9 w `-_ :, :- SCALE• I INCH tS FEET
w
_ 0.rN6Rs.a a
�""p". eerong a Frt-1
arm
; 7
r C VuNGS SFCaY €"irate SAND, €igM Ian, vory kxr"a trta Rrrra
Pee mra6ap Rasrr;tfrari a Was to or erpW to I slows per ` Foot r t
ru Clayey MLT, red, off
,r'"" * Penctrafim Atemstance Bess f x.an of r,Val 10 20 FROwa PerFoot
f. . _ aTuC80431
Rdrdrq
SA.PRaJTE• Frns to CC rsa Sandy SILT with gravel s4xa fragments. wa,' ` � M
Si5f8. wwothom-. rock, rnkmaceous, red Nr>samm.,. tart, and gra)^,: stPit P.g€ar�..r
Aw
r
i- Owen
ID hard ' *v,.;w�a SEiiLCC3G#tiFCR AT#iNt[iA'TESFFJa LAW
Psets4rrakkacsfiesSs€amceiess#haniUil6Savrx,perFoot _,.. prkt So. To ENGINEE PING REP 0 RTS 0 F MISS, 1V37,9113188..
SAPROLITE Rr waak
YlEATTIEAFR2 s�ttp C nwn 1u kfedium FAND wd tr grey e8 Nze iragmer % deo§er+ak AND 7a'S fl195.
ROCK g ar ss weahaered rrw*, tan, tviwn and grail N ar
"* 6tatnffRrxtn;Tes;mangrawealrrLhanor 4iaalsaltXSC:awl ALL MONITORING WELLS ARE CONSTRUCTED OF2UICH
trer'FoM yx s SCHEDULE 4OPVC PIPE AND TC FOOT MANUE GT[ RED
WELL SCREEN WITH 0,010 INCH WIDE OP~ENINr&
R.'aa„k Cared Saanple ( ring Gi F"6 e r:nec. C4offle
BEDROCK C WEMS wfith Ouarts Fekr:sper Esser,& w tmtouarnrrs, ateda'sry
dark gray to agtu g mv, madeaaiefy hard sc ham. AghoN 7 r2
�g we�athorea. ' to and hoaIad J*Iut w-� rfc„+wml to very csctOy {rerFr g E4ram"s - LL
s-ladled. Foliatronmaar#eaNAryPkallaaaps.abotrtaadegmes. 7. muna d isrmreaa�3. .� _ d _
Accessary minerals tnaude chbrile, ca',wta pyflc. and
humblands
: Water Crcxeen trier*rep Aedr€�sk.
NOTE-
EaYg.ca. 4iaAssrF.evn#'atsaaart¢areadnetC,S'R.a'k:.:"'CG➢ons,dsriv'a.:r.�f7'G'.'a4➢."t.T'ilaT"+ 'I'i''>R%i'C�'r,"�. .__ ..�. ��».._.........�.,.�,,..�._,.._._... .._..: - .._._,. �.� ..�.�. _.... ....,.m........m_._,..
by ESL � DUNN CORPORATION °a.=iTIO E Mawr at .sue B E t r a4a ae Information E'rom
q Cr tt vv*rra C'e rF �nxta, F a vcnrrrasi*:Y S:ornasamr„s T x2"' Bixtr� Ltri-rfk TTtwr"d^11tai'�4f 2� r"tia
FMC(,0Rl'0ICCmS"I0N-I.T'MlU,,.iYSvI
DIJN'+ m. nrr^rwei rl,a a! .r. vte
m B sse ex 0tv P adbty
s a szaae dare av gsa^r� a , rs mar6r.er�sa
_ ' t .. a. ,^�
i
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