WQ0082821_Complete File - Historical_20171231 (2)

D EC E OWE
APR 24 2008
NC DENR MRO
DWQ - Aquifer Protection
2007 Annual Ground Water Monitoring and
Treatment System Effectiveness Report
Southern States Cooperative, Inc.
Statesville Fertilizer Plant
Statesville,.North Carolina
Prepared For
Mr. Vance Dann
Southern States Cooperative, Inc.
Post Office Box 26234
Richmond, Virginia 23260
- [phone]
Submitted To
North Carolina Department of Environment and Natural Resources
Division of Water Quality, Aquifer Protection Branch
Mooresville Regional Office
610 East Center Avenue
Suite 301
Mooresville, North Carolina 28115
Prepared By
Duncklee & Dunham, P.C.
511-102 Keisler Drive .
Cary, North Carolina.27511
i
DUNCKLEE & DUNHAM, P.C.

DUNCKLEE
�} &DUNHAM
f"J
April 15, 2008
Mr. Andrew Pitner
North Carolina Department of Environment and Natural Resources
Division of Water Quality, Aquifer Protection Branch
Mooresville Regional Office
610 East Center Avenue, Suite 301
Mooresville, North Carolina 28115
ENVIRONMENTAL CONSULTANTS
511 KEISLER DRIVE — SUITE 102
CARY, NORTH CAROLINA 27518
OFFICE: (919) 858 — 9898
• FACSEVULE: (919) 858 — 9899
IEr-E°diD
APR 2 4 2008
Reference: 2007 Annual Ground Water Monitoring and Treatment System Effectiveness Report
Southern States Cooperative, Inc.
Statesville Fertilizer Plant, Statesville, North Carolina
Ground Water Incident Number 5038
Dear Mr. Pitner:
As requested by Southern States Cooperative, Inc. (Southern States), Duncklee & Dunham, P.C. is
pleased to submit this 2007 Annual Groundwater Monitoring and Treatment System Effectiveness Report
for the above referenced site. This report discusses the work scope performed and the conclusions
derived from sampling and monitoring performed during this period.
If you have any questions or require additional information, please do not hesitate to contact Mr. Tom
Dunham at [phone] ([e-mail]) or Mr. Vance Dann of Southern States
at [phone] ([e-mail]).
Sincerely,
DUNCKLEE & DUNHAM, P.C.
C—P -�:'
Chris Fay
Project Geologist
r%' i= 1924
om�,s S. Dunha'?�i�, 5�;o�`z
Senior Geologist '�•�9
Licensed Geologist #i9�, gColl ��••`+
Senior Peer Review:
G
Jay ennett, P.G., R Mior Project Manager/Hydrogeologist
c: Mr. Vance Dann — Southern States Cooperative, Inc. (e-copy)
P:\Southem States\Statesville Fertilizer - 50200\Reports\2007 Annual Report\Teat and Tables\2007 Annual GW Monitoring Report - 07170.doe
MAILING ADDRESS — POST OFFICE BOX 33366 — RALEIGH, NORTH CAROLINA 27636

Table of Contents
1 Introduction
1.1 Site Location, Description and History
1.2 Summary of Remedial Actions
2 Ground Water Sampling and Treatment System Monitoring Activities
2.1 Ground Water Sampling Methodology
2.2 Groundwater Treatment System Activities
3 Ground Water and Treatment System Sampling Results
3.1 Results of May 2007 Sampling Event
3.2 Results of October 2007 Sampling Event
3.3 Nitrate Trends in Ground Water
3.4 2007 Remediation System Operation Effectiveness and Maintenance Activities
3.4.1 Treatment System Sampling Results
3.4.2 Treatment System Effectiveness and Maintenance
4 Conclusions
5 Recommendations
DUNCKLEE & DUNHAM, P.C.
1
1
1
2
2
2
3
3
4
4
5
5
5
r
6

Figures
Figure Title
1
Site Location Topographic Map
2
Site Plan
3
Shallow Aquifer Ground Water Contour Map May 2007
4
Shallow Aquifer Ground Water Contour Map October 2007
5
Shallow Aquifer Nitrate Isoconcentration Map May 2007
6
Deep Aquifer Nitrate Isoconcentration Map May 2007
7
Shallow Aquifer Nitrate Isoconcentration Map November 2007
8
Deep Aquifer Nitrate Isoconcentration Map November 2007
Tables
Table Title
1 Summary of 2007 Well and Water Level Gauging Data
2 Summary of 2007 Ground Water Analytical and Field Parameter Results
3 Summary of 2007 Treatment System Effluent Discharge Results
Appendices
Append iz Title
A May and October 2007 Field Data Sampling Forms and System Check Sheets
B May and October 2007 Laboratory Analytical Reports
C Effluent Sample Laboratory Results
D Nitrate in Ground Water Trend Graphs
DUNCKLEE & DUNHAM, P.C.
�J

2007 Annual Ground Water Monitoring and
Treatment System Effectiveness Report
Southern States Cooperative, Inc.
Statesville Fertilizer Plant
Statesville, North Carolina
April 15, 2008
Introduction
1.1 Site Location, Description and History
The Southern States Cooperative, Inc. (Southern. States) fertilizer plant (i.e., the site) is located at 2582
Salisbury Highway (US Highway 70) approximately six miles east of Statesville, North Carolina (see
Figure 1). The site consists of several buildings including a fertilizer manufacturing building, an office
building, and several small support buildings. This site also has several aboveground storage tanks and a
—� railroad spur (see Figure 2). The site is utilized for the manufacturing, storage, and distribution of liquid
and dry fertilizers.
- The site is bordered to the north by US Highway 70, commercially developed parcels to the east, and an
undeveloped parcel to the west. The US Highway 70 Bypass bisects east to west through the southern
portion of the site and separates approximately 13 acres from the main property.
,GroundLwate� at: the site has;been impacted from a release, of 1,igw d oniumanit - � from__ s_eueb rah
wormerz cer�w�ater m�oundmentrsF., Two impoundments were located approximately 1,000-feet
_ southwest of the main plantTwogg
additional surface water impoundments (i.e.; Former Pond A and B,
Figure 2) were located east and southeast of the main plant. These impoundments are referenced in the
`I Corrective Action Plan (CAP) dated January 28, 1994, submitted by Canonie Environmental to the North
Carolina Department of Environment and Natural Resources (NCDENR), Division of Water Quality,
Aquifer Protection Section (APS). In 1994 the APS subsequently approved the CAP with stipulations
that certain modifications be met that involved certain sampling requirements, RW-2 modifications, and
identification of additional potential off -site contamination sources. Based on the CAP the assessment
and impact of ground water contamination has been defined with reasonable certainty.
The objective of the CAP is to remediate ground water beneath the site and to prevent off -site migration
of the ground water contamination plume. To monitor the effectiveness of the CAP, a ground water
sampling plan was developed that established semiannual (May and October) ground water monitoring
and scheduled monitoring and maintenance of the ground water treatment system.
1.2 Summary of Remedial Actions
To reduce the levels of ammonia and nitrate in the ground water, three recovery wells were installed at
the site (RW-2, RW-5 and RW-6) as part of the CAP requirements. However, RW-5 was taken out of
service due to low or no flow and is currently not in service. Therefore, the ground water treatment
system is operating two recovery wells that pump ground water into a wet well, where the pH is adjusted
with a caustic prior to being discharged into Fourth Creek at outfall 001. Fourth Creek is located in the
Pee Dee-Yakin River Basin.
DUNCKLEE & DUNHAM, P.C.

Southern States Cooperative, Inc. — Statesville Fertilizer Plant
2007 Annual Groundwater Monitoring Report
April 15, 2008
Page 2 of 7
The ground water treatment system is permitted under the National Pollution Discharge Elimination
System (NPDES) program. Under the program, weekly site visits are conducted when the system is
operational to monitor and determine if the treatment system is operating within the discharge limits.
Effluent water samples from the treatment system are collected bi-monthly prior to the permitted outfall.
The effluent discharge data are reported to North Carolina Department of Environment and Natural
Resources -Division of Water Quality on monthly Discharge Monitoring Reports (DMR).
2 Ground Water Sampling and Treatment System Monitoring Activities
2.1 Ground Water Sampling Methodology
Semiannual sampling events were conducted on May 1 and 2, and October 15 and 16, 2007. Ground
water samples were collected from seven (K65W6"A", K65W6`B", K65W6"B", K65W7"D",
K65W7"J", K65W7"K', and K65WT L') of the eleven monitoring wells (see Figure 2). The remaining
monitoring wells K65W6"D' ; K65W7"F", K65W7"G", and K65W7" C" were dry during this event and
were not sampled. Due to an extremely low water table during the October 2007 sampling event, ground
water samples were not collected from K65W6`B" and K65W7"D" in addition to the four dry wells
previously mentioned.
Prior to well purging and sampling, the depth to water was measured using a decontaminated electric
water level probe and the data recorded on field sampling sheets (see Appendix A). The ground water
level measurement data is summarized on Table 1. The sampling process consisted of inserting a
decontaminated two-inch submersible electric PVC pump with new polyethylene tubing in to each well to
purge and withdraw the samples from each well. The ground water samples were collected immediately
after purging using conventional sampling techniques that consisted of removing three to five well screen
volumes prior to sample collection. During the purging process field measurements for dissolved oxygen
(DO), oxidation reduction potential (ORP), pH, temperature, turbidity and conductivity were also
collected. The field measurements collected during each sampling event is summarized in Table 2.
Ground water samples were collected and placed directly in to laboratory -provided containers, labeled,
recorded on a chain -of -custody form, and transported to the analytical laboratory in an insulated cooler
filled with ice. The samples were submitted to Pace Analytical Services (Pace) in Huntersville, North
Carolina and analyzed for nitrate according to EPA Method 353.2 and ammonia as N (ammonia)
according to EPA Method 350.1. The chain of custody record and laboratory sample results for both
events are included in Appendix B.
2.2 Groundwater Treatment System Activities
The ground water treatment system operated during January and the first week of February 2007. The
treatment system was shut down the remainder of the year due to mechanical problems and compliance
issues related to ammonia. Additionally, recovery well RW-6 was operational during this time while
RW-2 was not operational. RW-2 was shut down in early 2006 due to NCDOT cutting the electrical and
water supply line to the treatment system. While the system was operational, weekly site visits were
conducted to monitor the system and sample the system effluent. During the months the system was shut
down, work was ongoing to correct the problems so that the system could be re -started. During the
compliance reporting period for 2007, NPDES reporting sheets were submitted each month as required by
the NCDENR.
TDUNCKLEE & DUNHAM, P.C.

Southern States Cooperative, Inc. — Statesville Fertilizer Plant
2007 Annual Groundwater Monitoring Report
April 15, 2008
Page 3 of 7
Effluent samples were collected on January 9 and 26, 2007, and submitted for laboratory analysis to Pace
Laboratories, a North Carolina certified waste water analytical laboratory. Effluent water samples were
collected by grab methods prior to the discharge and analyzed for total suspended solids (TSS) (via EPA
Method 160 series), copper (via EPA Methods 3000/6000 series), ammonia, chlorides, nitrates, total
nitrogen and total phosphorus (all by EPA Method 300 series). No effluent samples were collected the
remainder of this reporting period. Field sampling and monitoring data were recorded and are included in
Appendix A. The laboratory data results for the effluent samples collected are included in Appendix C.
3 Ground Water and Treatment System Sampling Results
The May and October 2007 ground water and treatment system analytical results are summarized in the
following sections. The ground water and effluent sample results are summarized in Tables 2 and 3,
respectively. Ground water flow maps illustrating shallow ground water aquifer flow for the May and
October sampling events are shown on Figures 3 and 4, respectively. Ground water plume maps
illustrating nitrate distribution in the shallow saprolite and deep bedrock aquifer for these sampling events
are presented on Figures 5 through 8. The graphs in Appendix D illustrate nitrate trends overtime for
each of the compliance monitoring wells.
3.1 Results for May 2007 Sampling Event
i'
Ground water level measurements were taken from each of the wells sampled to create the shallow
aquifer ground water flow map shown on Figure 3. Ground water flow during this period was measured
to be to the southwest under a hydraulic gradient of 0.078 feet per foot (ft/ft).
During this sampling event the following was noted regarding the results with respect the ground water
impact and extent of the nitrate plume.
• Sampling data indicated that nitrate was present in the monitoring wells sampled at concentrations
exceeding the North Carolina 2L ground water standard of 10 mg/L.
• Nitrate concentrations in the shallow saprolite aquifer monitoring wells ranged from 31 micrograms
per liter (mg/1) in K65W6"B" to 140 mg/L in K65W6"A". Based on the results, the nitrate ground
water plume is at the southwest property line.
• Nitrate in the deep bedrock monitoring wells ranged from 89 mg/l in K65W7"K"to 150 mg/1 in
K65W6"E".
• Ammonia was detected at low to trace concentrations in six of the eight wells above the laboratory
method detection (MDL) limit of 0.1 mg/l Since there is no 2L ground water standard for ammonia,
the MDL becomes the 2L ground water clean up level for the site. Ammonia in ground water ranged
from below the MDL in well K65W6"B" to 11.0 mg/L in K65WT
• As stated earlier in this report, downgradient wells K65W7"C", K65W7"G" and K65W7"F" were dry
and could not be sampled. Well K65W7"D" was not measured during this event.
DUNCKLEE & DUNHAM, P.C.

Southern States Cooperative, Inc. — Statesville Fertilizer Plant
2007 Annual Groundwater Monitoring Report
April 15, 2008
Page 4 of 7
3.2 Results for October 2007 Sampling Event
Ground water level measurements were taken from each of the wells sampled to create the ground water
flow map shown on Figure 4. Ground water flow during this period was measured to be to the southwest
under a hydraulic gradient of 0.043 ft/ft. Due to drought that began in the summer of 2007, shallow
saprolite water table levels have dropped up to five feet in central piedmont of North Carolina. As such,
many of the site monitoring wells went dry as the water table dropped below the level of the well screen.
During this sampling event the following was noted regarding the results with respect the ground water
impact and extent of the nitrate plume. The data are summarized in Table 2.
• Sampling data indicated that nitrate was present in the sampled monitoring wells at concentrations
exceeding the North Carolina 2L ground water standard of 10 mg/L.
• Nitrate concentrations in the shallow saprolite aquifer monitoring wells ranged from 14.4 mg/1 in
K65W7"J" to 30.9 mg/L in K65W6"A". The lower nitrate levels in the ground water may be,
attributed to the drought conditions.
• Nitrate in the deep bedrock monitoring wells ranged from 14.2 mg/l in K65W6"E" to 30.5 mg/l in
K65W7"L".
• Ammonia was detected at low to trace concentrations in several wells above the laboratory method
detection (MDL) limit of 0.1 mg/l. Since there is no 2L ground water standard for ammonia, the
MDL becomes the 2L 'ground water clean up level for the site. Ammonia in ground water ranged
from below the MDL in well K65W6"E" to 12.9 mg/L in K65WTV'.
• As stated earlier in this report, downgradient wells, K65W7"C", K65W7"D", K65W7"G", and
K65W7"F", were dry and could not be sampled.
3.3 Nitrate Trends in Ground Water
Based on data trends (see ' Appendix D) observed for-- nitrate impact to ground water, the following
observations can be made at this time with respect to the ground water treatment system effectiveness;
• Nitrate trends in shallow ground water background monitoring well K65W6 `B" have remained
consistent since October 2003 with nitrate levels ranging from 44 to 31 mg/l. However, the overall
trend for nitrate levels in this well is upward.
• Nitrate levels in the shallow ground water aquifer have steadily declined in monitoring well K65W6
"A" since the treatment system became operational in October of 1990. However, nitrate levels have
increased over time in the deep monitoring well K65W6 "B". These wells are located near recovery
well RW-5, which is not operational at this time. .
• Shallow monitoring well K65W7 "J" and deep well K65W7 "K", located near recovery well RW-6,
have shown steady nitrate reductions since October 2004. However, deep well K65W&"L" shows an
increasing trend in nitrates.
• No nitrates trends can be reported at this time from shallow monitoring wells located near RW-2.
Declining water levels and dry well conditions at K65W7 "C", "G" and "F" have prevented short
term analysis of nitrate trends. Additionally, RW-2 has not operated since early 2006, because the
NCDOT cut the water discharge line to the treatment system. Therefore, no data is available to
evaluate the effectiveness of nitrate removal in the area.
DUNCKLEE & DUNHAM, P.C.
�J

Southern States Cooperative, Inc. — Statesville Fertilizer Plant
2007 Annual Groundwater Monitoring Report
April 15, 2008
Page 5 of 7
3.4 2007 Remediation System Operation Effectiveness and Maintenance Activities
During the 2007 operation period, the treatment system operated in January and the first week of
February and then was taken offline due to system mechanical and compliance issues related to ammonia
concentrations. During operation of the system and in accordance with the NPDES permit #
NCD0082821, site visits were conducted weekly to monitor the treatment system operation and to
monitor and collect discharge effluent samples from outfall 001.
3.4.1 Treatment System Sampling Results
Treatment system effluent samples were collected prior to the discharge point at outfall location 001. The
sample results are summarized on Table 3. On January 9 and 26, 2007 effluent water samples were
collected and analyzed for ammonia and the required analysis suite in accordance with the NPDES
permit. Based on the sample results, ammonia concentrations were detected above the effluent limit of
7.8 mg/L. Several attempts were made to adjust the treatment system to correct the ammonia discharge,
but the attempts failed. Therefore, on February 6, 2007 the treatment system was taken off line and
remained off line in order to evaluate options for bringing the system back into compliance.
3.4.2 Treatment System Effectiveness and Maintenance
During the operational period (January and February 2007), RW-6 was the only extraction well in
operation. In February 2007, NCDOT construction activities for the US Highway 70 Bypass that bisects
the southern part of the property resulted in the power and water supply lines being severed from recovery.
well RW-2 to the treatment system. Over a 19 month period since RW-2 was shut down, and over a
seven month period following the treatment system shut down, Duncklee & Dunham negotiated with the
NCDOT to construct an access road and install a conduit beneath the road to reconnect the severed power
and water lines to RW-2. Subsequently, Duncklee and Dunham contracted G. C. Campbell Construction
of Mooresville, N C to complete a horizontal boring beneath the road bed. An 18 inch horizontal bore
hole was completed on October 9, 2007 using a Ditch Witch horizontal rotary drill rig. Upon completion
of the bore hole, a 10 inch conduit was installed and Geologic Exploration of Statesville, N C was
contracted to complete the connection of the water and power lines. On November 14 and 15, 2007 the
water and power lines to RW-2 were reconnected. However, the system was not immediately brought
back on-line due to water metering problems.
In December 2007 and January 2008, treatment system modifications were completed to replace the
existing discharge metering system with a batch pH metering system.
DUNCKLEE & DUNHAM, P.C.
_li

Southern States Cooperative, Inc. — Statesville Fertilizer Plant
2007 Annual Groundwater Monitoring Report
April 15, 2008
Page 6 of 7
4 Conclusions
Based on the results of the semi -annul groundwater samplingevents and treatment system activities for
the 2007 reporting period, the following conclusions can be made at this time.
• During the May and October 2007 sampling event, ground water elevation data indicated water levels
have been declining as evidence by monitoring wells K65W6"D", K65W7"C", K65W7"F", and
K65W7"G" going dry during one or both sampling events. The piedmont region on North Carolina
has been experiencing a server drought for several years. As such, monitoring well K65W6"D" has
been dry since July 18, 2005. Shallow ground water flow direction continues to be to the southwest.
• The shallow aquifer ground water samples collected during the May 2007 sampling event indicate
nitrate concentrations to be consistent with historical data. However, ground water samples collected
- in October 2007 showed significant decrease in nitrate concentrations. The reduced nitrate levels in
ground water may be attributed to the recent drought conditions. As such, the nitrate concentration
L' reduction may be a limitation of the monitoring wells, which may no longer intersect highly
permeable water bearing soil or fracture zones that transport the nitrates.
j • Nitrate concentrations in deep bedrock aquifer ground water samples also declined from May to
October 2007. These reductions may be in part due to the ground water recovery well RW-2 and
RW-6 being shut down during most of 2007.
• The nitrate trends over time in the shallow ground water aquifer have remained consistent or have
shown steady declines since the recovery system has been in operation. This indicates the ground
water recovery and treatment system has been effective. Additionally, nitrate levels have decreased
over time near recovery wells RW-2 and RW-6 but have increased over time near recovery well RW-
5, which was shut down due to lack of flow.
• The ground water treatment system was shut down in early 2007 due to mechanical and compliance
related issues with ammonia. Since February 2007 modifications have been made to the flow
metering and pH adjustment systems and the discharge and power lines to recovery well RW-2 were
repaired in September 2007. The ground water treatment system is operational as of the date of this
report.
5 Recommendations
Based on the information presented above, Duncklee & Dunham recommends the following regarding the
ground water remediation system.
• Continue to operate the ground water treatment system throughout the spring and summer for as long
as the aquifer levels are sufficient.
• Perform semi-annual ground water sampling events in May and October 2008.
• Evaluate RW-5 with regards to well depth, past flow rates, and condition of the pump. Perform
repairs necessary to increase the well depth at RW-5 so the well can be used to recover nitrate
impacted ground water.
• Install a deep monitoring well near the southwest property line (i.e., near K65W7 "F") to monitor the
bedrock aquifer for potential off -site migration of nitrates. Since the drought conditions have forced
shallow ground water levels to decline, currently no compliance well exists in this area of the site.
- DUNCKLEE & DUNHAM, P.C.

Southern States Cooperative, Inc. —'Statesville Fertilizer Plant
2007 Annual Groundwater Monitoring Report
April 15, 2008
Page 7 of 7
• Install two shallow compliance monitoring wells on either side of the currently mapped groundwater
plume to determine the horizontal compliance boundaries of the nitrate plume to the east and west of
the plume center. Previously installed compliance wells have either been destroyed or no longer exist
j due to site modifications from the US Highway 70 Highway Bypass. These new wells should be
added to the sampling plan and installed prior to the next scheduled event.
• Re-evaluate the NPDES discharge requirements of treated ground water to Fourth Creek to determine
if the permit can be canceled. This evaluation will consist of performing a treatment system
evaluation to determine if the discharge water (i.e., ground water) can be reused on the Southern
States property. This modification would discontinue requirements to maintain the NPDES permit
and the plant would gain non -potable water resources (i.e., gray water) for pant operations.
• Conduct an evaluation to determine the reported historical locations of the two former plant waste
water ponds located east of and 300 feet southeast of the main plant (as stated in the corrective action
plan). This evaluation will assist in determining if these areas are contributing residual impact to the
ground water and if additional corrective action is needed.
DUNCKLEE & DUNHAM, P.C.

Table 1. Summary of 2007 Well and Water Level, Gauging Data
Southern States, Statesville, North Carolina
Aquifer
` TOC
Total Well
Depth to
,
Ground Water
Wells
Code
Date
Elevation
Depth (ft)„
Water
Elevation
Z.
ff blm"
at MSL ; ..
K65W6A
Sap
05/01/07
864.52
58
21.48
843.04
838.61
10/15/07
25.91
K65W6B
Sap
05/01/07
871.55
30
21.67
849.88
DRY
10/15/07
DRY
K65W6D
Sap
05/01/07
846.37
38
DRY
DRY
DRY
10/15/07
DRY
K65W6E
BR
05/01/07
864.89
133
21.83
843.06
838.95
10/15/07
25.94
K65W7C
Sap
05/01/07
809.72
22
DRY
DRY
788.62
10/15/07
21.10
K65W7D
Sap
05/01/07
800.64
23
NM
NM
DRY
DRY
10/15/07
K65W7F
Sap
05/01/07
796.15
28
DRY
DRY
DRY
DRY
10/15/07
K65W7G
Sap
05/01/07
795.98
15
DRY
DRY
DRY
DRY
10/15/07
K65W7J
Sap
05/01/07
851.25
60
40.76
810.49
42.09
809.16
10/15/07
K65W7K
BR
05/01/07
852.30
121
41.52
810.78
43.37
808.93
10/15/07
K65W7L
BR
05/01/07
851.14
200
39.77
811.37
10/15/07
43.01
808.13
TOO=To of Casing is the mertsunng point (rrtp) to feet Mean Sea Level {MShj for the well
P
ry= Wel was
dry during this
sampling event and no sample collected
M=we11 not.measured prtor-'rosampling
t bmp�et below measuring point
-.
.
qulfer Cgde -
Reptese"nts aquifer being monitored at this well location (Sap=Saprohte and BR=Bedrock)
Ii nieasurinents dre. ineel
CI
PASouthern States\Statesville Fertilizer - 50200\Reports\2007 Annual Report\Text and Tables\Annual Analytical Tables 2007_final
�l Table 1- Summary of WL

Table 2. Summary of 2007 Ground Water Analytical and Field Parameter Results
Southern States, Statesville, North Carolina
2L Standard
10
NES
6.5 to 8.5
NES
NES
NES
NES
05/01/07
140.0
0.1
5.45
17.4
274
96
0.09
K65W6A
10/15/07
30.9
0.25
5.72
16.6
276
299
0.57
05/01/07
31.0
<0.10
5.33
16.8
900
127
5.92
K65W6B
10/15/07_:
=`
:.
„DRY^
.
05/01/071
39.0
2.1
NM
NM
NM
NM
NM
K65W6D
10/15/07
05/01/07
150.
<0.10
5.60
17.7
259
75
2.60
K65W6E
10/15/07
14.2
<0.10
7.40
16.8
268
279
4.69
IC65W7C
05/01/07
DRY
10/15/06
.
05/01/07
39.0
2.1
NR
NR
NR
NR
NR
K65W7D
10/15/07
_._.
DRY
K65W7F
05/01/07
DRY
10/15/07
K65W7G
05/01/07
10/15/07
05/01/07_
140.0
0.1
5.83
16.9
192
87
0.20
K65W7J
10/15/07
14.4
0.6
6.04
15.6
207
299
0.79
05/01/07
89.0
4.5
5.74
15.9
156
96
0.68
K65W7K
10/15/071
5.9
4.2
5.92
16.1
152
235
0.44
05/01/071
99.0
11.0
5.59
15.4
155
70
0.08
K65W7L
10/15/071
30.5
12.9
5.78
15.7
160
291
0.36
^ro=se
�Ir-vol
P:\Southern States\Statesville Fertilizer - 50200\Reports\2007 Annual Report\Text and Tables\Annual Analytical Tables 2007_final
Table 2- Lab Results GW

Table 3. Summary of 2007 Treatment System Effluent Discharge Results
Southern States, Statesville, North Carolina
Copier
Chloride
Atnmoniia' , N
TKN, N
Nitrate
' Phosphours
N><trogen, N
�.
�
TSS
I�ocatio"
Sa><nple�# '
Bate
(mg/1)
��g/i)
��gn)
tmg�)
� gn)_ ,
(mga) ;
Discharge Limit
45
7
250
7.8
NES
10
NES
10
EFF010907
1/9/2007
1.7
NS
NS
12
NS
NS
NS
NS
Outfall001
EFF012607
1/26/2007
21
ND
65
13
9
50
ND
59
EFF020607
2/6/2007
52
NS
NS
12
NS
NS
NS
NS
tes:
'd value indicates exceedance to the dischage limit established for NPDES permit #WC0082821
Not Detected above the laboratory methoddetection limit:
S-Aro Established Standard
not Sampled
ltrriper ter4- miul
l- micro grams perliterT
charge Limit Established under 15A NCAC 2B"surface Water Standards for Class C Waters of the. State
P:\Southem States\Statesville Fertilizer - 50200\Reports\2007 Annual Report\Text and Tables\Annual Analytical Tables 2007_final
Table 3- Lab Results Effluent

DUNCKLEE & DUNHAM, P.C.
ENVIRONMENTAL CONSULTANTS
I�
I.
511 KEISLER DRIVE -SUITE 102
CARY, NORTH CAROLINA 27511
1 Source Mao: U.S. G.S. Statesville East 7.5-Minute puadranAle. North is Towards Top o(Page.
Approximate Scale: Title: Site Location Map
1" = 2000' USGS Topographic Map
Figure: Project:
1 Southern States Fertilizer Plant
Statesville, North Carolina

I \
I
rth Creek Se e
ITreatment PI
/ I \
I J �
I �
�6p
-N r f lk.South�;,1„R
Approximate
Location of
Outfall 001
Southern States
Inches 1
0 1 2
0 0.25 0.5
Miles
ISource of base map: Canonie Environmental Corrective Action Plan January 1994
mom
Nlghw
Discharge Point
to Creek
Treatment System
Discharge Line
Highway 70 Bypass
DUNCKLEE
ENVBtONMENTAL CONSULTANTS
SIIKEISLERDRIVC SUITE102
0. T 77�T� T
Z:> pI, DUNHAM
CARY, NORTH CAROLINA 27518
OFFICE (919) 858A898
WEB DUNCK=uNHAM.COM
Job Number
Layers
50200
0,2
Drawing
igure
50200-3
2
Scale
ate
1 "=0.25 miles
April 1, 2008
Title
Treatment System Discharge Line Outfall
Project Southern States Fertilizer Plant
Statesville, North Carolina

DUNCKLEE
ENVIRONMENTAL CONSULTANTS
511 KEISLER DRIVE - SUITE.102
CARY, NORTH CAROLINA 27518
OFFICE: (919) 858' -9898
I:ACSRv1M& (91.9)W-9899
DA
71lo-Ip
JOB NO
PROJECT_7[ � ' %� i Fef6 r
NAME: C7 (w' 1j
LOCATION:
�## �+•
E...
PRESENT
AT SITE:
WEATHER:
TEMPERATURE
& TIME:
ARRIVAL
TIME
AM
'PM:
DEPARTURE AM
TIME PM
THE FOLLOWING WAS -NOTED:
TO -RE RT
Pap of SIGNED_
N lAll.,NG ADDRESS -,Posl*rOFFlCi 'I3f: X 3366 - .Rftt L;iEiil. NORHI (:AROI.,INA 2:d63'6

ENVIRONMENTAL CONSULTANTS
51 I Keisler Drive - Suite 102
Raleigh, North Carolina 27518
Office: [phone]
Facsimile: [phone]
DATE: &14
116 -7
JOB NO-:
0 011b0
PROJECT & LOCAT I9.
LL NO, c DEYM:
�v,g—
WA
�,
EVFL:
17,L�%
SCREEN LENGTI-F
WELL DIAMETER & CASING TYPF
Pvc
PERSONNEL
EQUIPMENT:
TYPE OF SAMPLES COLLFCI'FD:

11.1mull Le Willy,
ENVIRONMENTAL CONSULTANTS
51.1. Keisler Drive - Suite 102
Raleigh, North. Carolina 275.18
Office: [phone]
Facsimile: [phone]
DATE:
JOB ' NO.:
PROJFC74E LN'-AT'0%6
WE U NO & DEPTH-
WATER LEVM-:
SCREEN LENGTH:
WELL DIAMETER & CASING TYPE:
PERSONNEL
EQUIPMENT:
TYPE OF SAMPLES COT LFCTED:
11111 IL, -T T 1--T i M &---f
PAGE 3 OF -7 SIGNED

- r
k
ENVIRONMENTAL CONSULTANTS
511 Keisler Drive - Suite 102
Raleigh, North Carolina 2151-8
Office: [phone]
Facsimile: (9I9) 858-9899
DATE: , � �
JOB NO.: tJ�
tJ
PROJECT & LOCXHON:
LL NO. & DEPTH:
WATER LEVE :
e
SCREEN LENGTH:
WELL DiA. ;(T�aE,R & CASING TYPE:
{ 1 RUC=
PERSONNEL
EQUIPMENT:
TYPE OF SAMPLES COLLECTED:
Time PH Temp Goad. ORP � DO Tuirbitiify Notes
10) 7-7
f\j (''j�� (M/� }�+Jy
ffjj
M+Sf'�jf, ';Y�{
!E ffgp .r��/yy�j
4.
.........
...... . - ...... . .... . ...... .
r%r .

r .t
- - - - - - - - - . . . . . . . . .
ENVIRONMENTAL CONSULTANTS
511 Keisler Drive; - Sdite 102
Raleigh, North Carolina 275 t 8
Office: (.919) 858-9898
Facsimile: [phone]
DATE: � �
JOB NO.: &N OO
PROIEG"r & LOCf1'I'IC3N: Za6
V t"IL,'
WELL NO: & DEPTH:
WATER LEVEL:
"C" 90 -
7 7
SCREEN LENGTIL
WELL DIAMETER & CASING TYPE,:
PERSONNEL
EQUIPMENT:
TYPE OF SAMPLES COLLECTED:
Time ply
Temp Coed.
OOP
DO
Turbidity
I Notes
i+�4
, tY4j t
i
d
i
;
`
70
6 - .� 1
�
�� � �
--kG' 1� I t,/ :✓ t ,� 1
_ � tr' ..
_ �_�jfjj�_...!'"
f�j
1
_..... ........ ..
!
_..._._._._._....._..__._....... ............... _....
i 1
3
i
FF
. �.._
...__..............__....__
--------i
-_ ._.._._.____........_.—._.
Ji
i
(
i
�
1
I
3
i
t
....,.._...._
.,.�.—._...__......._� .__.......__ ....._._
.. .........
1
.......................
3i
i
I'
3
i
j
;
:
ir`v�►T T1 "I /�I T !'R /��
2" = 617 inllft, 4" = 2470 mllft
PAGE__& OF 7
- a 1, 1
�� r

ENVIRONMENTAL CONSULTANTS
511 Keisler Drive - Suite 102
Raleigh, North Carolina 27518
Office: (9.19) 858-9998
Facsimile: (919),858-9899
DATE: �Z67
JOB NO.:
PROJECT & LOCATION: 66
6hLk5vJ1v
WELL NO. & DEPTH:
t7^�Aj) -T
WATER LEVEL:
SCREEN LENGTH:
WEL&DIAMETER & CASING TYPE:
PERSONNEL
EQUIPMENT:
T'VPE OF SAMPLES COLLECTED:
Time pH Temp Cond. I ORP DO Turbidity Notes
. ...........
�bo
..... ........... ..
23 1
i R/
2" = 617 ml/ft, 4" = 2470 Inl/ft
PAGE (9 OF
7
a PM

ENVIRONMENTAL CONSULTANTS
511 Keisler Drive. - Suite 102
Raleigh, North Carolina 27518
Office: [phone]
Facsimile: [phone]
DATE: e /
A -1
OB NO.:
'
150300
PROJECT & OCATION'
6Aqkt',A11)(,
WELL NO. & DE Lli:-
WATER LEVEL:
SORE VN'LENGT1,I:
WELL DIAMETER & CASING TYPE:
L
PERSONNEL
EQUIPMENT:
TYPE OF SAMPLES COLLECTED:
Time PH Temp I Cond. ORP DO Turbidity
t?
--:)I . . ...... ........
... . .. ... ... . ............
n
L/
V
0,0
....... . . . ....... . .....
(3Z5
-7
Notes
211 617 ml/ft, 4" 2470,ml/ft GROUND WATER SA LING OG
L
PAGE SIGNED

ENVIRONMENUAL CONSI.IL I'ANtiTS
511 KE.ISLERDRIVE -- SUI F 102
CARP, NORTH CAROLIN A 27518
OFT -ICE: (9I9) 858.- 9898
FACS.IMIL.E: (919) 858 -- 9899
DATE:
JOB NO,
PROJECT
t!
f e 6
NAME:
LOCATION:
XIO- /Tc9 t �'� % j� '
PRESENT
AT SITE:
WEATHER:
TEMPERATURE
&TiiMF:
ARRIVAL: AM
DEPARTURE Alvt
TIME /vo ; Xebl?G}oo PM
TIME
THE FOLLOWING WAS NOTED:
f
—_µ .....__
COPIES TO r ! IELD REPORT
Page of _ f SIGNED�-
�,f
S;1i€ r .rr Ai31.3i i:ss Po8 -Y OF't ICE Elf) 3 z66 -- RALI U 1. N(Q 1H i ARUI..:?,NA 63)6

CHAIN -OF -CUSTODY / Analytical Request Document
The Chain -of -Custody is a LEGAL DOCUMENT. All relevant fields must be completed accurately.
Page: of
(Section A Section B
'Required l Cient inforrnafion� Required
Section C
1020562
k, P.,koject Information:
Company Report To:
.W�j ...... . ......
Address py To:
Co
invoice Information:
Attention:
. . . . .
Company Name:
. ........... ....... . . -------- NPDES
GROUND WATER
FJ' DRINKING WATER
UST
1 RCRA
D"Other
—41
Erriail -fb: t, Purchase Order No.:
411
AddrpsS:
I pace Quote Reference:
�GA r, IL 0 IN
i-QH [I SO F) WI
!D.Ml, D MN '.-,NC
[-]OTHER
Phone Project Name
Fax
jL
Pack Project Managee,
Filtered (YIN) j
Requested Due Date/TAT. Project Number:
1Vf& I
Pace Profile #c
Requested
-VaIld Matrix Codes
SectionD Re'uireddlien'tInformation MIKINIX- CODE
DRINkii�G.VOXER —Dw
U.,
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Preservatives
0-7-
AnA�ysjs:
WAn-R WT
SAMPLE ID WASTE WATER W4.
PRODUCT P
SOILISOLID SL
0
0
ca
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0
0
if
COLLECTED
Sl-
One Character per box, OL OIL
mc�
- — -----
(A-Z, 0-9 1 .�) WIPE. WP
w AR AIR
§�
:C.OMPOSITE START COMPOSITE ENDIGRAB
0< 1:
Pnea Projett Number
Samples IDS MUST BE UNIQUE. OTHER OT
< S,
z L)
oh
TISSUE T$
DATE TliyiE TIME
N
z z z
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Lab LD
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SAMPLE CONDITION
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SEE REVERSE SIDE FOR INSTRUCTIONS
f
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AIJ.0020rw-3,31mar05
2 ............ . .................

I
Section
Required C€.ent Inforo,ation.jcompany
gg
Ai
AddrQ� �
,erg
Phone Fox
....... , _, w_, _
Requested flue Datet'CAT. %,
s
Section (: Required Client InformationVVA
( S A T- L @ D *vet:
i rink
firs
One Chatoclai peir'box. OIL
3 V111
(A Z, 0-9 1,)
i Samples IDs MUST BE UNIQUE eT<
Tf$i
Additional Comments;
SEE REVERSE SIDE FOR INSTRUCTIONS
CeHAIN-OF-CUSTODYi Analytical Request - t
The Chain -of -Custody is a LEGAL DOCUMENT All relevant fields must be completed accurately.
Page. of
Section B Section C
Required Frigject Infurrr»tiun � InvGiaQ in€Grmatnir 10,20561
4t port TG Attention ^� o -
EJ NP€IES GROUNDWATER DRINKING WATER 1
Qopy To: Company Name:
UST RGRA Citlzer
Address: _
GA ,IL i i rra Ml I MN �::If}C
_ _ __�__ _ .____
Purchase Older No.; €pace Quote Reference C9 1 iSC s li W„ iWI _OTHER
Project Name j Price project manager:
Fi tered (YIN)
Proje,4 (dumber: Pace e Profile M Requested
I�(C8K CCt8�9
h—td i3.
J fOL
tC)rtidPOv1T£.STr�RT ICOrJIS7
AM�lyeis; � r
FFF ffr _ %
ervutrvcs ff�� ?f i
Puce ProjeCt Number
o r I r f/ Lb ID 1
j CAt F 4iclrlcci ;R"t� ({)�7 , r
SAMPLE CONDITION
r
Z
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t
._,......._.. _
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- Y
2
y:
?
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....._....._.r
.,-
-• S V
�
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DUNCKLEE
gNVjpoNMENTAL COMVLTANTS.
511KEISLER.DkIVE - SUITE 102.
p.
tARY, NORTH CARbLJNA,275,18
(9.191858-9898,
FAICS.MLE: (919) &58 - 9.899
DATE:
JOBXO.-r
51
PROJECT
NAME: p:>
LOCATION-.
PRESENTS-
AT SITV�
WEATHER: ,
74"r-
TEMPERATIJR
& TIME:
'ARRIVAL
W
DEP"vRr'IJM_E
TIME
PM
THETOL LOWING. WAS NOTED-;.
MAILINQ ADDR!'--ss - POTF OF-Fia:, Bc�)x 3366 -RA[-,ElGKN,0R7r!J cAROIANA �27636

e
ENVIRONMENTAL CONSULTANTS
511 Keisler Drive - Suite 102
Raleigh, North Carolina 27518
Office: [phone]
Facsimile: [phone]
Time PH Tem
Std. Units °C
.....
I V
is
;-7�
DATE:
JOB NO.:
d6 0
PROJECT (&' LOCATION: j) j
W'EL,L NO. & DEPTH:
WATER LEVEL:
SCREEN LENGTH:
WELL DIAMETER & TYPE`.
�Cr+1^SING
PERSONNEL ,
EQUIPMENT:
S00v 1
TYPE OF SAMPLES. COLLECTED:
Conn.
ORP
DSO
T'sCm.__
MV
._�
...
J
` fit. '
1
1.3�
/L
0-
.... ........... ................
.
_.....
....
...--....
_.... 7
Dg�
sL
......... . ... . ... . ........
t-i
i(0
all
b-SL
Dotes
GROUND WAMTERAIMPLINGLOG

DUNCKLEE
&DUNHAM
ENVIRONMENTAL C ONSUtTANTS.
DATE,
NO.:
PROJECT & LOCATION.
jje�1A
_tC
WELLNO. & DEPTH.,
mu'7 vc .
WATER LEVEL:
�S37
SCREEN LENGTH:
WELL DIAMETER & CASING TYPE:
PERSONNEL
EQUIPMENT:
511 JWster'Drive - Suite 162.
Raleigh, North Carolina 275,18 TYPE OF
Office? $58-99981 Facsimile: (99) 858-9899 A
Time pH I Temp Cond. ORP 1 DO
0
M nIN7
Std. Units. c ps/c .-Ing/L
........... . .... .... . . ......
L
... . . . ..................................
.............
N6 )32 IV
I IS, )S3
. . . ................
33 L
. ................. . ......... .
................
5 )s
.Notes
GROUND WATER SAIL4PLING
VXAL
211 = 617 ml/ft, 4'Y=2470 itl/ft
PAGE OF SIGNED

ENVIRONMENTAL CONSULTANTS
51.1 Keisler Drive - Suite 102
Raleigh ' North Carolina 27518
Office: [phone]
Facsimile: [phone]
DATE:
JOB NO::
PROJECT & LOCATION:
WELL NO. & DEPTH:
KUb-07"Yk ("0'
)WATER LEVEL:
q4169
SCREEN LENGTH:
NW-LL DIAMETER & CASING TYPE:
PERSONNEL
EQUIPMENT:
TYPE OF SAMPLES COLLECTED:,
0 ii%kY5
I
2" = 617 ml/ft, 4" = 2470 ml/ft GROUND WATER S GL G
PAGE a OF SIGNED

DUNCKLEE
>' & DUNHANt
ENVIRONMENTAL CONSULTANTS
511 Keisler Drive -:Suite 102
Raleigh, North Carolina 27518
Office: (919.) 858=9898
Facsimile:. (919) 85:8-9899
DATE:
JOB NO.;
PROJECT & LOCATION:
e(�f�c
�S�%lf� i
!r:
LLNO, &DEPTH:
WATER LEVEL..
SCREEN LENGTH:
IKELL, DIAMETER.& CASING, TYPE:
PERSONNEL A���?�'�
EQUIPMENT-
TYPE OF SAMPLES "COLLECTED:
Time
pH Temp
Cond.
ORP
DO
Turbidity ; Notes
._.....
o
Sta units. .. _
PS/cm:
mZT
�_
_ mg/L
-
;:_ 1\iTL _..._
f
!
{� t Cr) r
j
c1
..........-- —.... _�
................... :
2 rf �
V
t i r 1 IS
--- —
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e 2 ._..
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.................... Ji ....... _..._.... --... _ ................
(}"kits....- !t�?�
#
UaJ f !g, ....... —....... _...__._.,.
•
PAGE wSIGNED. •`

ENVIRONMENTAL CONSULTANTS
511 Keisler Drive - Suite 102
Raleigh, North Carolina 27518
Office: (.919) 858-9898
Facsimile: [phone]
DATE: I /1
0L A 7
rB NO.
PROJECT & LOQUION-
WELL NO. & DEPTH:
WATER LEVEL:
SCREEN LENGTH:
WELL DIAMETER & CASING TYPE -
In
PERSONNEL
EQUIPMENT:
TYPE OF SAMPLES COLLECTED:
2" = 617 nil/ft, 4" = 2470 ml/ft GROUND WATER LING 0 G
PAGE OF (62 SIGNED

K65W W ,
GARAGE
f STORAGE
',0FFI'E _
MAIN
PLANT
ED
(5K65W7"A' .Monitoring W01 Liications
t Kecovery We'!
T Property Line:
llllNCKLEE_ s n`°
R D_ U � ^ -HAM—kii#'JkM fRP�
. .�ts o+nxrseet�u
Purina Feed Mill Property
K65W6'E
a ovn
K655WW6"A" wr N' ITAirowMR XT6
.:
LAO�p�MMUACf vl..�_,_��� }-, �ta+9 lB+Y1AFi
m"U"sts
K65w6'
Southern States Cooperative Inc:
Statesville Fertilizer Plant
Residential.
Properties
II I
K65W7
K15AW7 C
8 K65W7"D: jb
lob :aye u e Title Access Road Request
N.O.50200 8/312005
7luwing -,gore cafe- PrWecr
50200 1 "-166 Southern States Fcaerlizer Plant; Statesville, North Carolina Source of base map: Law Engineering and Environmental Services

V
LY� r, n A ni If rfh—j
CHAIN -OF -CUSTODY / Ana! ytical Request Document
The Chain -of -Custody is a LEGAL DOCUMENT. All relevant fields must be completed accurately.
;
(Section A
wor,
fienOnform4tion: k,
Section B
Required Prqject Informatiow
Section C
Invoice Information:
Page: of
1-0 4 7 6 3
_Lequ,�ej.,�,
A
C pan Report To
i - b
-14 ... ........ tI
Address
1-
. . . ......
Attention:
.............. . . . . . . ......... ............ NPDES ��-ROUND WATER DRINKING WATER
y Name:
7] UST ['J RCRA Other
Email To- Purchase Order No.:
Address:
1 Pace Quote Reference:
DGA DIL
E]OH F. SC
_;IN - JM1 L) MN C
0 Wl DOTHER
PITFax Project Nam pace Project Manager:
I TA�
Requested Due DatefTAT.' Project Number: Pace Profile
Vatid Matrix CDdes
Section DRequilid Client Infofmation MATRIX Cqqf.
DRINKINOWATER DW w U:� 1
WATER "Ai 0 —Z —
SAMPLE ID WAS1 E WATER VM 0
PRODUCT P 0
SOIUSOLID SL x COLLECTED ssu u
One Chara cter per box. OIL OK
WIPE WP 0 COMPOSITE COMPOSITEENDiGRAB
(A-ZR
AIR AR 10
.OTHER or 11
samples JE)s �UST BE UNIQUE DATE TIME TIMr-
TISSUE TS I . ,
Filtered,(YIN)
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z 0
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Additional Comments'
. ...... ...... ..... ....... .. . .......
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SEE REVERSE SIDE FOR INSTRUCTIONS
2
PRINT NampofSAMPLER:
SK,NATURF. 5, I 1A T F, S 1 1 Nt, 7c", i M
. ........... .

CHAI _. U TODY 1 Anaiytical Request Document-$
p
+
The Ghui'1 of-C uStody i ,:a LEGAL DOCUMENT, All releevant field,, rfiu ii be C:Dmp
t)ted xE3 cun'SgE"y,
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Section, B
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Section C
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Inwice" {niormatiOS�l
.
Compan>; y k
t1137953
, i,.,
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Report to g
M1
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Copy Io:
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RE(aULATtSFCYA PjGY
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NPDES aftClUAtC) WATER
a DRINKING WATER
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Email i o; >
Purchase OrderNri::
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ace Prot
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...
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,`
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13"iNp Water DW
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WT
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11
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SIGNATURE of
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'ImPnrtant not.; Sy signing this. farm you ara'aaceptnq Pace's NET Se day A rent tcma, and agraetng
tG laity UkirAas Oil TX, per Inoo to for any-i ' ices not paid w thb 30d" - j
� -
FALL-Q-(120fev.07,
15-K4ay-2007

Date: Z(1C,O -7
Certification # q1q
Facility Name: S&c;;� EEkg, -rcl�
permit#, N CI 0 2a-
,-Illyw ?,A I --
plIAnalysis
Reference Method:
Cal, Tirne
Calibration Buffer 4.0
Calibration Buffer 10.0
*Check Buffer 7.0
Comments
(100
*PH buffer checks are to be within,± UPH units of the standards true value
FacilitylSample location
Thne-An!t " do
PH Result
10-1 Buffer Check value
Comment
I So
+ If sample is measured in directly in the stream only time analyzed would be recorded.
IV indicates a recommended drift check (Use Buffer 7.0) Should be within ti: 0.1 units of the buffer's true value)
Callbr2tion drift check is recommended when performing'sualysis at multiple sampling locations,
*All results in PH units.
ATC Annual Check Date:. i Annual Tempmture Sensor Check Date:
Certification N G'Y
Facility Nome: -::, S - Z �z V
Permit# ucl�tz- t
Daw Analyst:
PH Analysis
V.f--MPthnd-
Cal. Time
CafibraticnBuftbr4.0
Calibration Buffer 10.0.
*CheckBuffer 7.0
Comments
Ocf 00
*pIf buffer checks are to be within± 0.1 pH units of the standards true value
Facility/S=ple location
Time Samp +
Time d+
P. Result
h Suffer Cfreckvalne
* if sample is measured in directly to the stream only time,anabrzed would be ruorde&
10- Indicates a recommended drift check. (Use Buffer 7.0) Should be witbln:Ml I units of the buffer's true value)
Calibration drift check is recommended when performing Analysis at multiple sampling locations,
*All results in pit units. fLPb
ATCAnnual Check Date:Annual Temperature Sensor Check Date.

T.
Analytical
vw nv. pace/abs.com
May 04, 2007
Mr. Dave Duncklee
Duncklee & Dunham
P.O. Box 33366
Raleigh, NC 27636
Pace Analytical Services, Inc.
9800 KinceyAvenue, Suite 100
Huntersville, NO 28078
Phone: [phone]
Fax. [phone]
RE: Lab Project Number: 92143493
Client Project ID: SS Statesville 1
Dear Mr. Duncklee:
Enclosed are the analytical results for sample(s) received by the laboratory on May 1, 2007. Results reported
herein conform to the most current NELAC standards, where applicable, unless otherwise narrated in the body of
the report.
Inorganic Wet Chemistry and Metals Analyses were performed at our Pace Asheville laboratory and Organic testing
was performed at our Pace Charlotte laboratory unless otherwise footnoted.
If you have any questions concerning this report please feel free to contact me.
Sincerely,
Kevin Herriag
kevin.herring®pacelabs.com
Project Manager
Enclosures
Asheville Certification IN
NC Wastewater 40
NG Drinking Water 37712
SC Environmental 99030
FL NELAP E87648
REPORT OF LABORATORY ANALYSIS
This report shall not he reproduced, except In full,
without the written consent of Pace Analytical Services, Inc.
"m
Charlotte Certification IDs
NC Wastewater 12
NG Drinking Water 37706
SC 99006
FL NELAP E87627

— 4vinvpacetabs.com
Lab Sample No: 928321900
Client Sample ID: R65W7"J"
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Huntersville, NC 28078
Phone: [phone]
Fax: [phone]
Lab Project Number: 92143493
Client Project ID: SS Statesville 1
Project Sample Number: 92143493-001 Date Collected: 05/01/07 14:52
Matrix: Water Date Received: 05/01/07 15:35
Parameters Results units Report Limit Analyzed By CAS No. Oual ReQLmt
Wet Chemistry
Ammonia Method: EPA 350.1
Nitrogen, Ammonia 0.11 mg/l 0.10 05/02/07 18:30 SAJ 7727-37-9
48 Hour NO3 / NO2 / NOX
Nitrate as N
Date: 05/04/07
Method: EPA 353.2
140 mg/1 2.0 05/02/07 10:11 JMW
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS Charlotte Certification IDs
NO Wastewater 40 This report shall not be reproduced, except in full, NO Wastewater 12
NO Drinking Water 37712 without the written consent of Pace Analytical Services, Inc. NC Drinking Water 37706
SC Environmental 99030� SC 99006
FL NELAP E87648FL NELAP E87627
Page: 1 of 7

aceAnalytical '
m%v. pacelabs.com
Lab Sample No: 928321918
Client Sample ID: K65W7"K"
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Huntersville, NC 28078
Phone: [phone]
Fax: [phone]
Lab Project Number: 92143493
Client Project ID: SS Statesville 1
Project Sample Number: 92143493-002 Date Collected: 05/01/07 13:58
Matrix: Water Date Received: 05/01/07 15:35
Parameters Results Units Report Limit Analyzed By CAS No. Qual ReaLmt
Wet Chemistry
Ammonia Method: EPA 350.1
Nitrogen, Ammonia 4.5 mg/l 0.10 05/02/07 18:30 W 7727-37-9
48 Hour NO3 / NO2 / NOX
Nitrate as N
Date: 05/04/07
Method: EPA 353.2
89. mg/l 2.0 05/02/07 10:11 JMW
Asheville -Certification IDs REPORT OF LABORATORY ANALYSIS Charlotte Certification 10s
NC Wastewater 40 This report shall not he reproduced, except in full, NC Wastewater 12
NC Drinking Water 97712 without the written consent of Pace Analytical Services, Inc. NC Drinking Water 37706
SC Environmental 99030 SC 99006
FL NELAP E87648 W�'``� ' I' FL NELAP E87627
Page: 2 of 7

1�aceAnalyticaf
e�srwrac{1ac8ief:s.exam
1
Lab Sample No: 928321926
Client Sample ID: R65W7"D"
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Huntersville, NC 28078
Phone: [phone]
Fax., 704.875,9091
Lab Project Number: 92143493
Client Project ID: SS Statesville 1
Project Sample Number: 92143493-003 Date Collected: 05/01/07 11:50
Matrix: Water Date Received: 05/01/07 15:35
Parameters Results Units Report Limit Analyzed By CAS No. Oual RegLmt
Wet Chemistry
Ammonia Method: EPA 350.1
Nitrogen, Ammonia 2.1 mg/1 0.10 05/02/07 18:30 SAJ 7727-37-9
48 Hour NO3 / NO2 / NOX
Nitrate as N
Date: 05/04/07
Method: EPA 353.2
39. mg/1 1.0 05/02/07 10:11 JMW
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS Charlotte Certification IDs
NO Wastewater 40 This report shall not be reproduced, except in full, NO Wastewater 12
NO Drinking Water 37712 without the written consent of Pace Analytical Services, Inc. NO Drinking Water 37706
SC Environmental 99030 $C 99006
FL NELAP E87648 �,, ;��` FL NELAP E87527
Page: 3 of 7

Pace Analytical Services, Inc.
9860 Kincey Avenue, Suite 100
Analyticaf` Hunfersville, NC 28078
Phone: [phone]
w:mw. pacelabs.com Fax: [phone]
Lab Project Number: 92143493
Client Project ID: SS Statesville 1
PARAMETER FOOTNOTES
Method 9071B modified to use ASS.
All pH, Free Chlorine, Total Chlorine and Ferrous Iron analyses conducted outside of EPA recommended immediate
hold time.
Depending on the moisture content the PRLs can be elevated for all soil samples reported on a dry weight basis.
2-Chloroethyl vinyl ether has been shown to degrade in the presence of acid.
ND Not detected at or above adjusted reporting limit
NC Not Calculable
J Estimated concentration above the adjusted method detection limit and below the adjusted reporting limit
MDL Adjusted Method Detection Limit
Date: 05/04/07
Asheville Gertification IDs REPORT OF LABORATORY ANALYSIS Charlotte Certification IDg
NC Wastewater 40 This report shall not be reproduced, except in full, NC Wastewater 12
NC Drinking Water 37712 without the written consent of Pace Analytical Servlces, Inc. NG Drinking Water 37706
SC Environmental 99030 $C 99006
FL NELAP E87648 aJ_ FL NELAP E87627
Page: 4 of 7 .

Lsiiigii 3d1jica1-w
tnr:rtcpacetabs a om
r
t
QUALITY CONTROL DATA
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Huntersville, NC 28078
Phone: [phone]
Fax: [phone]
Lab Project Number: 92143493
Client Project ID: SS Statesville 1
QC Batch: 187559
Analysis Method:'EPA 353.2
QC Batch Method: EPA 353.2
Analysis
Description: 48
Hour NO3 / NO2 / NOX
Associated Lab Samples:
928321900
928321918
928321926
METHOD BLANK: 928323864
Associated Lab Samples:
928321900
928321918
928321926
Blank
Reporting
Parameter
Units
Result
Limit
Footnotes
Nitrate as N
mg/1
ND
0.10
LABORATORY CONTROL SAMPLE:
928323872
Spike
LCS LCS
Parameter
Units
Conc.
Result Rec
Footnotes
Nitrate as N
mg/l
5.000
5.210 104
MATRIX SPIKE: 928323880
928322718 Spike MS MS
Parameter Units Result Conc. Result % Rec Footnotes
Nitrate as N mg/l 2.730 5.000 7.560 97
SAMPLE DUPLICATE: 928323898
Parameter Units
Nitrate as N mg/1
Date: 05/04/07
928321900 DUP
Result Result RPD Footnotes
140.0 140.0 1
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS
NO Wastewater 40 This report shall not be reproduced, except in full,
NO Drinking Water 37712 without the written consent of Pace Analytical Services, Inc.
SC Environmental 99030
FL NELAP E87648
�LLt
Charlotte Certification IDs
NO Wastewater 12
NG Drinking Water 37706
$C 99006
FL NELAP E87627
Page: 5 of 7

acamalytical
m%v. pacelabs_com
1
I
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Huntersville, NC 28078
Phone: 704,875.9092
Fax: [phone]
QUALITY CONTROL DATA
Lab Project Number: 92143493
Client Project ID: SS Statesville 1
QC Batch: 187614 Analysis Method: EPA 350.1
QC Batch Method: EPA 350.1 Analysis Description: Ammonia
Associated Lab Samples: 928321900 928321918 928321926
METHOD BLANK: 928326917
Associated Lab Samples: 928321900 928321918 928321926
Blank Reporting
Parameter Units Result Limit Footnotes
Nitrogen, Ammonia mg/l ND 0.10
LABORATORY CONTROL SAMPLE: 928326925
Spike LCS LCS
Parameter Units Cone. Result % Rec Footnotes
Nitrogen, Ammonia mg/1 5.000 5.043 101
MATRIX SPIKE: 928326933
928280627 Spike MS MS
Parameter Units Result Conc. Result % Rae Footnotes
Nitrogen, Ammonia mg/l 125.6 5.000 126.9 26 1
SAMPLE DUPLICATE: 928326941
Parameter Units
Nitrogen, Ammonia mg/1
Date: 05/04/07
928320761 DUP
Result Result RPD
ND ND NC
Footnotes
Asheville Certification.iDs REPORT OF LABORATORY ANALYSIS Charlotte Certification IDs
NC Wastewater 40 This report shall not be reproduced, except in full, NC Wastewater 12
NC Drinking Water 37712 without the written consent of Pace Analytical Services, Inc. NC Drinking Water 37706
SC Environmental 99030 .,. $C 99006
FL NELAP E87648 W,�£ FL NELAP E87627
Page: 6 of 7

vs rwpacelabs.com
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Huntersville, NC 28078
Phone. 704.875,9092
Fax: [phone]
Lab Project Number: 92143493
Client Project ID: SS Statesville l
QUALITY CONTROL DATA PARAMETER FOOTNOTES
Consistent with EPA guidelines, unrounded concentrations are displayed and have been used to calculate Rao and RPD values.
LCS(D) Laboratory Control Sample (Duplicate)
MS(D) Matrix Spike (Duplicate)
DUP Sample Duplicate
ND Not detected at or above adjusted reporting limit
NC Not Calculable
J Estimated concentration above the adjusted method detection limit and below the adjusted reporting limit
MDL Adjusted Method Detection Limit
RPD Relative Percent Difference
[1] The spike recovery was outside acceptance limits for the MS and /or MSD due to matrix interference. The LCS
and/or LCSD were within acceptance limits showing that the laboratory is in control and the data is
acceptable.
Date: 05/04/07
Asheville Certification IDs
NC Wastewater 40
NC drinking Water 37712
SC Environmental 99030
FL NELAP E87648
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced. except In full,
without the written consent of Pace Analytical Services, Inc.
Charlotte Certification IDs
NC Wastewater 12
NC Drinking Water 37706
SC 99006
FL NELAP E87627
Page: 7 of 7

2aceAnalvtkal'
CnAN-vr'-C _;TUul(/ Analytical Kequest Document
The Chain -of -Custody is a LEGAL DOCUMENT. All relevant fields must be completed accurately.
•
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REGULATORY
AGENCY
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SITE LOCATION
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SAMPLEID
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WT
WASTE WATER VVW
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PRODUCTWATER
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OIL OL
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COMPOSITE STARAIR
Samples IDS MUST BE UNIQUE
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TISSUE TS
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RELINQUISHED
BY 1 A.FFILIA.ION DATE TIME
RE11111111111111
ACCEPTED
BY I AFFILIATION
DATE
■�■
TIME
SAMPLE CONDITION
SAMPLER NAME AN') SIGNATURE

aceAnalytical '
tnnv.pacelabs.com
r
May 08, 2007
Mr. Dave Duncklee
Duncklee & Dunham
P.O. Box 33366
Raleigh, NC 27636
RE: Lab Project Number: 92143571
Client Project ID: SS STATESVILLE 2
Dear Mr. Duncklee:
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Huntersville, NC 28078
Phone: 704.875,9092
Fax: [phone]
Enclosed are the analytical results for sample(s) received by the laboratory on May 2, 2007. Results reported
herein conform to the most current NELAC standards, where applicable, unless otherwise narrated in the body of
the report.
Inorganic Wet Chemistry and Metals Analyses were performed at our Pace Asheville laboratory and Organic testing
was performed at our Pace Charlotte laboratory unless otherwise footnoted.
If you have any questions concerning this report please feel free to contact me.
Sincerely,
Ravin Herring
kevin.herring®pacelabs.com
Project Manager
Enclosures
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS Charlotte Gertification IDs
NO Wastewater 40 This report shall not be reproduced, except in full, NO Wastewater 12
NO Drinking Water 37712 without the written consent of Pace Analytical Services, Inc. NO Rrinking Water 37706
SC Environmental 99030 «,,> $C 99006
FL NELAP E87648,{�{�s}`� �i`, FL NELAP E87627
"Ll�.l3

. al a/'�
us s-Axpacefabsxam
Lab Sample No: 928325729
Client Sample ID: K65W6"B"
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Huntersville, NC 28078
Phone: [phone]
Fax: [phone]
Lab Project Number: 92143571
Client Project ID: SS STATESVILLE 2
Project Sample Number: 92143571-001 Date Collected: 05/02/07 12:54
Matrix: Water Date Received: 05/02/07 13:00
Parameters Results Units Report Limit Analyzed By CAS No. Qual ReoLmt
Wet Chemistry
Ammonia Method: EPA 350.1
Nitrogen, Ammonia ND mg/1 0.10 05/04/07 20:36 SAJ 7727-37-9
48 Hour NO3 / NO2 / NOX
Nitrate as N
Date: 05/08/07
Method: EPA 353.2
31. mg/l 0.50 05/03/07 09:04 JMW
Asheville Certification IDs
REPORT OF LABORATORY ANALYSIS
NC Wastewater 40
This report shall not be reproduced, except in full,
NC Drinking Water 37712
without the written consent of Pace Analytical Services, Inc.
SC Environmental 95030
FL NELAP E87648
Charlotte Certification
IDs
NC Wastewater
12
NC Drinking Water
37706
$C
99006
FL NELAP
E87627
Page: 1 of 8

Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
aceAnalytieal'
HPhone:70 ,8 29092
Phone: 704.B75.9092
wvlw pacelabs.com
i
Fax [phone]
ILab
Project Number:
92143571
Client Project ID:
SS STATESVILLE 2
Lab Sample No: 928325737
ProjectSampleNumber: 92143571-002 Date Collected: 05/02/07 12:20
Client Sample ID: X65W6°Ea
Matrix: Water
Date Received: 05/02/67 13:00
Parameters
Results
Units
Report Limit Analyzed By
CAS No. Qual Reg_Lmt
Wet Chemistry
Ammonia
Method: EPA
350.1
Nitrogen, Ammonia
ND
mg/l
0.10 05/04/07 20:36 SAJ
7727-37-9
48 Hour NO3 / NO2 / NOX
Method: EPA
353.2
Nitrate as N
150
mg/1
2.0 05/03/07 09:04 JMW
Date: 05/08/07
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS Charlotte Certification IDs
NC Wastewater 40 This report shall not be reproduced, except In full, NC Wastewater 12
NC Drinking Water 37712 without the written consent of Pace Analytical Services, Inc. NC Drinking Water 37706
SC Environmental 99030 c S.0 99006
FL NELAP E87648 ` °a s FL NEAP E87627
Page: 2 of 8

Analj&afo
Vanntcpacaiabs.com
Lab Sample No: 928325745
Client Sample ID: R65W6"A"
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Huntersville, NC 28078
Phone. [phone]
Fax.[phone]
Lab Project Number: 92143571
Client Project ID: SS STATESVILLE 2
Project Sample Number: 92143571-003 Date Collected: 05/02/07 10:50
Matrix: Water Date Received: 05/02/07 13:00
Parameters Results Units Report Limit Analyzed By CAS No. ual ReuLmt
Wet Chemistry
Ammonia Method: EPA 350.1
Nitrogen, Ammonia 0.13 mg/l 0.10 05/04/07 20:36 SAJ 7727-37-9
48 Hour NO3 / NO2 / NOX
Nitrate as N
Date: 05/08/07
Method: EPA 353.2
140 mg/l 2.0 05/03/07 09:04 JMW
Asheville Certification IDs
NC Wastewater 40
NO Drinking Water 37712
SC Environmental 90030
FL NELAP E87648
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc.
"Ll1�LlS.I`'c
Charlotte Certification
IDs
NO Wastewater
12
NO Drinking Water
37706
Sc
99006
FL NELAP
E87627
Page: 3 of 8

aceAna1X cal:w
wtnv.pacelabs.com
t
t
Pace Analytical Services; Inc.
9800 Kincey Avenue, Suite 100
Huntersville, NC 28078
Phone: [phone]
Fax: [phone]
Lab Project Number: 92143571
Client Project ID: SS STATESVILLE 2
Lab Sample No: 928325752 Project Sample Number.: 92143571-004 Date Collected: 05/02/07 10:05
- Client Sample ID: K65W6"L" Matrix: Water Date Received: 05/02/07 13:00
Parameters Results Units Report Limit Analyzed By CAS No. Oual RecLmt
Wet Chemistry
Ammonia Method: EPA 350.1
Nitrogen, Ammonia 11. mg/1 0.20 05/04/07 20:36 SAJ. 7727-37-9
48 Hour NO3 / NO2 / NOR
Nitrate as N
Date: 05/08/07
Method: EPA 353.2
99. mg/1
1.0 05/03/07 09:04 JMW
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS . Charlotte Certification IDs
NC Wastewater 40 This report shall not be reproduced, except in full, NC Wastewater 12
NC Drinking Water 97712 without the written consent of Pace Analytical Services, Inc. NC Drinking Water 37706
SC Environmental 99030 $C 99006
FL NELAP E87648 (,� ,,�a 9 FL NELAP E87627
Page: 4 of 8

Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
r���C��=w Huntersville, NC 28078
Phone: [phone]
wznrpacdabs.com Fax: [phone]
Lab Project Number: 92143571
Client Project ID: SS STATESVILLE 2
PARAMETER FOOTNOTES
Method 9071B modified to use ASE.
All pH, Free Chlorine, Total Chlorine and Ferrous Iron analyses conducted outside of EPA recommended immediate
hold time.
Depending on the moisture content the PRLs can be elevated for all soil samples reported on a dry weight basis.
2-Chloroethyl vinyl ether has been shown to degrade in the presence of acid.
ND Not detected at or above adjusted reporting limit
NC Not Calculable
J Estimated concentration above the adjusted method detection limit and below the adjusted reporting limit
MDL Adjusted Method Detection Limit
Date: 05/08/07
Asheville -Certification IDs REPORT OF LABORATORY ANALYSIS Charlotte Certification IDs
NO Wastewater 40 This report shall not be reproduced, except In full, NO Wastewater 12
NO Drinking Water 37712 without the written consent of Pace Analytical Services, Inc. NO Drinking Water 37706
SC Environmental 95030 $C 99006
FL NELAP E87648 z FL NELAP E87627
Page: 5 of 8

_ aceAna�ytical V
wow pacelabs.com
i
_i
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Huntersville, NC 28078
Phone. [phone]
Fax 704.875,9091
QUALITY CONTROL DATA
Lab Project Number: 92143571
Client Project ID: SS STATESVILLE 2
QC Batch: 187642 Analysis Method: EPA 353.2
QC Batch Method: EPA 353.2 Analysis Description: 48 Hour NO3 / NO2 / NOX
Associated Lab Samples: 928325729 928325737 928325745 928325752
METHOD BLANK: 928328798
Associated Lab Samples: 928325729 928325737 928325745 928325752
Blank Reporting
Parameter Units Result Limit Footnotes
Nitrate as N mg/l ND 0.10
LABORATORY CONTROL SAMPLE: 928328806
Spike LCS LCS
Parameter Units Cone. Result % Rec Footnotes
Nitrate as N mg/1 5.000 5.080 102
MATRIX SPIKE: 928328814
928321181 Spike MS MS
Parameter Units Result Cone. Result % Rea Footnotes
Nitrate as N mg/1 0.09000 5.000 5.260 103
SAMPLE DUPLICATE: 928328822
Parameter Units
Nitrate as N mg/l
Date: 05/08/07
928323955 DUP
Result Result RPD Footnotes
3.800 3.800 0
Asheville•Gertiffl0ion REPORT OF LABORATORY ANALYSIS Charlotte Certification IDs
This report shall not be reproduced, except in full, NC Wastewater 12
without the written consent of Pace Analytical Services, Inc. NG Drinking Water 37706
$C 99006
,��11,�~���� FL NELAP E87627
IDS
NG Wastewater
40
NG drinking Water 37712
SC Environmental
99030
FL NELAP
E87648
Page: 6 of 8

,Anal iCal `"
m,,w oacefabs.com
QUALITY CONTROL DATA
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Wuntersville, NC 28078
Phone. [phone]
Fax [phone]
Lab Project Number: 92143571
Client Project ID: SS STATESVILLE 2
QC Batch: 187832
Analysis Method: EPA 350.1
QC Batch Method: EPA 350.1
Analysis
Description: Ammonia
Associated Lab Samples:
928325729
928325737
928325745 928325752
METHOD BLANK: 928340512
Associated Lab Samples:
928325729
928325737-
928325745 928325752
Blank
Reporting
Parameter
Units
Result
Limit Footnotes
Nitrogen, Ammonia
mg/l
ND
0.10
LABORATORY CONTROL SAMPLE:
928340520
Spike
LCS LCS
Parameter
Units
Conc.
Result Rec Footnotes
Nitrogen, Ammonia
mg/l
5.000
5.009 100
MATRIX SPIKE: 928340538
928327253
Spike MS MS
Parameter
Units
Result
Conc. Result $ Rec Footnotes
Nitrogen, Ammonia
mg/1
0
5.000 4.940 99
SAMPLE DUPLICATE: 928340546
928327360 DUP
Parameter Units Result Result RPD Footnotes
Nitrogen, Ammonia mg/l ND ND NC
Date: 05/08/07
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS
NC Wastewater 40 This report shall not he reproduced, except In full,
NG Drinking Water 37712 without the written consent of Pace Analytical Services, Inc.
SC Environmental 99030 ....�ct
FL NELAP E87648 Ya=
Charlotte Certification IDs
NG Wastewater 12
NC Drinking Water 37706
SC 99006
FL NELAP 07627
Page: 7 of 8 .

Analytical w
wrrw. pacefabs.com
QUALITY CONTROL DATA PARAMETER FOOTNOTES
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Huntersville, NC 28078
Phone: [phone]
Fax: [phone]
Lab Project Number: 92143571
Client Project ID: SS STATESVILLE 2
Consistent with EPA guidelines, unrounded concentrations are displayed and have been used to calculate % Rec and RPD values.
LCS(D) Laboratory Control Sample,(Duplicate)
MS(D) Matrix Spike (Duplicate)
DUP Sample Duplicate
ND Not detected at or above adjusted reporting limit
NC Not Calculable
J Estimated concentration above the adjusted method detection limit and below the adjusted reporting limit
MDL Adjusted Method Detection Limit
RPD Relative Percent Difference
Date: 05/08/07
Asheville -Certification IDs
NC Wastewater 40
NC Drinking Water 37712
SC Environmental 95030
FL NELAP E87548
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except In full,
without the written consent of Pace Analytical Services, Inc.
Charlotte Certification
IDs
NC Wastewater
12
NC Drinking Water
37706
S.0
99006
FL NELAP
E87627
Page: 8 of 8

CnMiN• _ _ '-CuSTaDY 1 Analytical Request Document
/� ® The Chain -of -Custody is a LEGAL DOCUMENT. All relevant fields must bm
CICP/`'II la���CC�� e completed accurately.
.ction A S
. Page: of
ection �B Section C.
quired Client Information: Required ect Information: Invoice Information: O 0 5.6
-
mpany Report To: V
Attention:
__2% 4"tV Lol • - AGENCY
dress Copy To: ❑ NPDES El GROUND WATER ❑ DRINKING WATER
Company Name:
` r ,�^ _ ❑_..U.ST- --,.. - ❑. RCRA _ ... ❑ -Other
_ ..
a 1JI� Address:
ail To: Purchase Order No.: a a ❑GA ❑ IL ❑ IN ❑ MI ❑ MN ❑ NC
. Pace Quote Reference:
` DON ❑SC El WI ❑OTHER
me Fax Project Name:
7 �Gt Pace Project Manager:
guested Due Date/TAT Project Number: Filtered (YIN)
Pace Profile #: 1
Requested
Section b, Required CI'ient Information MATRrA Codes CODE . ' . Arnlyala: .
DRINKING WATER DW w tiJ� Preservatives' '
SAMPLE I D WASTE WATER WATER WW O r a M Oz (0
PRODUCT P U t4
SOILISOLID SL x w� COLLECTED W LL z I
One Character per box. OIL " OL ii'9 J OP •o \ "�
�a J
(A-Z, 0-9 / :) WIPE W' COMPOSITE START COMPOSITE END/GRAB U # O "' —
Samples IDs MUST BE UNIQUE OTHER AR
`"0 uJ ¢ 0 o� x a°o ('�
TISSUE TS DATE TIME DA 77ME a M Z - m o o� \ a r Jeet Number
C�/ rJ x x x z `2 � � � Lab LID
rr `
b j� 11 t
I` l
aa• a� e_ ai aaa� aaa� aaaaw ar
RELINQUISHED PY ' AFFILIATION DATE TIME ACCEPTED BY / AFFILIATION DATE " TIME
• . •
SAMPLER NAME ANC SIGNATURE ®®®

aceAnalytical
www.pacelabs.ccm
October 18, 2007
Mr. Chris Fay
Duncklee & Dunham
P.O. Box 33366
Raleigh, NC 27636
RE: Project: SS STATESVILLE FERT
Pace Project No.: 925787
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
Pace Analytical Services, Inc.
9800 KinceyAve. Suite 100
Huntersville, NC 28078
Dear Mr. Fay:
Enclosed are the analytical results for sample(s) received by the laboratory on October 16, 2007.
The results relate only to the samples included in this report. Results reported herein conform to the
most current NELAC standards, where applicable, unless otherwise narrated in the body of the
report.
Inorganic Wet Chemistry and Metals analyses were performed at our Pace Asheville laboratory and
Organic testing was performed at our Pace Huntersville laboratory unless otherwise footnoted. All
Microbiological analyses were performed at the laboratory where the samples were received.
If you have any questions concerning this report, please feel free to contact me.
Sincerely,
Kevin Herring
[e-mail]
Project Manager
Enclosures
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
,OWN PGCpgO'
c
[phone]
Page 1 of 10

1eAnalXical
www.pacelabs.com
r
Project: SS STATESVILLE FERT
Pace Project No.: 925787
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
CERTIFICATIONS
Pace Analytical Services, Inc.
9800 KinceyAve. Suite 100
Huntersville, NC 28078
[phone]
Charlotte Certification IDS
Florida/NELAP Certification Number: E87627 North Carolina Field Services Certification Number: 5342
Kansas Certification Number: E-10364 South Carolina Certification Number: 990060001
Louisiana/LELAP Certification Number: 04034 South Carolina Bioassay Certification Number: 990060003
North Carolina Drinking Water Certification Number: 37706 Tennessee Certification Number: 04010
North Carolina Wastewater Certification Number: 12 Virginia Certification Number: 00213
Asheville Certification IDs
Florida/NELAP Certification Number: E87648
Louisiana/LELAP Certification Number: 03095
New Jersey Certification Number: NC011
North Carolina Drinking Water Certification Number: 37712
North Carolina Wastewater Certification Number: 40
North Carolina Bioassay Certification Number: 9
Eden Certification IDs
North Carolina Drinking Water Certification Number: 37738
Virginia Drinking Water Certification Number: 00424
Pennsylvania Certification Number: 68-03578
South Carolina Certification Number: 990300001
South Carolina Bioassay Certification Number: 990300002
Tennessee Certification Number: 2980
Virginia Certification Number: 00072
North Carolina Wastewater Certification Number: 633
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
Page 2 of 10

aceAnalylical
www.pacelaftoom
l ,
Project: SS STATESVILLE FERT
Pace Project No.: 925787
Method: EPA 350.1
Description: 350.1 Ammonia
Client: Duncklee & Dunham
Date: October 18, 2007
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
PROJECT NARRATIVE
General Information:
3 samples were analyzed for EPA 350.1. All samples were received in acceptable condition with any exceptions noted below.
Hold Time:
The samples were analyzed within the method required hold times with any exceptions noted below.
Initial Calibrations (including MS Tune as applicable):
All criteria were within method requirements with any exceptions noted below.
Continuing Calibration:
All criteria were within method requirements with any exceptions noted below.
Method Blank:
All analytes were below the report limit in the method blank with any exceptions noted below.
Laboratory Control Spike:
All laboratory control spike compounds were within QC limits with any exceptions noted below.
Matrix Spikes:
All percent recoveries and relative percent differences (RPDs) were within acceptance criteria with any exceptions noted below.
Duplicate Sample:
All duplicate sample results were within method acceptance criteria with any exceptions noted below.
Additional Comments:
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
p, ACCORO'
ULL�Ix
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
Page 3 of 10

Z�?KceAnalXicals`
Iwww.pacelabs.com
i
Project: SS STATESVILLE FERT
Pace Project No.: 925787
Method: EPA 353.2
Description: 353.2 Nitrogen, NO2/NO3 unpres
Client: Duncklee & Dunham
Date: October 18, 2007
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
PROJECT NARRATIVE
[phone]
General Information:
3 samples were analyzed for EPA 353.2. All samples were received in acceptable condition with any exceptions noted below.
Hold Time:
The samples were analyzed within the method required hold times with any exceptions noted below.
Initial Calibrations (including MS Tune as applicable):
All criteria were within method requirements with any exceptions noted below.
Continuing Calibration:
All criteria were within method requirements with any exceptions noted below.
Method Blank:
All analytes were below the report limit in the method blank with any exceptions noted below.
Laboratory Control Spike:
All laboratory control spike compounds were within QC limits with any exceptions noted below.
Matrix Spikes:
All percent recoveries and relative percent differences (RPDs) were within acceptance criteria with any exceptions noted below.
QC Batch: WETA/1385
A matrix spike and matrix spike duplicate (MS/MSD) were performed on the following sample(s): 925743002
MO: Matrix spike recovery was outside laboratory control limits.
• MS (Lab ID: 28781)
• Nitrogen, Nitrate
Duplicate Sample:
All duplicate sample results were within method acceptance criteria with any exceptions noted below.
Additional Comments:
This data package has been reviewed for quality and completeness and is approved for release.
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
��r�C N ACCCAU�
� LLtY�J s
Pace Analytical Services, Inc.
9800 KinceyAve. Suite 100
Huntersville, NC 28078
[phone]
Page 4 of 10

® Pace Analytical Services, Inc. Pace Analytical Services, Inc.
1�7aceMalyiical 2225 Riverside Dr. 9800 Kincey Ave. Suite 100
wwwpacelabs com Asheville, NC 28804 Huntersville, NC 28078
ANALYTICAL RESULTS
Project: SS STATESVILLE FERT
Pace Project No.: 925787
[phone] [phone]
Sample: K85W7'J' Lab ID: 925787001 Collected: 10/16/07 08:50 Received: 10/16/07 11:26 Matrix: Water
Parameters Results Units Report Limit DF Prepared Analyzed CAS No. Qual
350.1 Ammonia Analytical Method: EPA 350.1
Nitrogen, Ammonia 0.68 mg/L 0.10 1 10/17/07 11:51 7764-41-7
353.2 Nitrogen, NO2/NO3 unpres Analytical Method: EPA353.2
Nitrogen, Nitrate, 14.4 mg/L 0.10 1 10/17/07 07:30
Date: 10/18/2007 04:41 PM
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc.. .
Page 5of10

,/�ZeAnalocal
AWWpacelabs.own
1
Project: SS STATESVILLE FERT
Pace Project No.: 925787
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
ANALYTICAL RESULTS
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
Sample: K65W6 'A' Lab ID: 925787002 Collected: 10/16/07 09:20 Received: 10/16/0711:26 Matrix: Water
Parameters Results Units Report Limit DF Prepared Analyzed CAS No. Qual
350.1 Ammonia Analytical Method: EPA350.1
Nitrogen, Ammonia 0.26 mg/L 0.10 1 10/17/07 11:53 7764-41-7
353.2 Nitrogen, N021NO3 unpres Analytical Method: EPA 353.2
Nitrogen, Nitrate 30.9 mg/L 0.10 1 10/17/07 07:30
Date: 10/18/2007 04:41 PM REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
Page 6 of 10

ac"Analylical
www.pacelabs.com
Project: SS STATESVILLE FERT
Pace Project No.: 925787
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
ANALYTICAL RESULTS
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
ISample: K65W6 'E' Lab ID: 926787003 Collected: 10/16/07 10:00 Received: 10/16/07 11:26 Matrix: Water
Parameters Results Units Report Limit DF Prepared Analyzed CAS No. Qual
350.1 Ammonia Analytical Method: EPA350.1
Nitrogen, Ammonia ND mg/L 0.10 1 10/17/0711:53 7764-41-7
353.2 Nitrogen, NO2/NO3 unpres Analytical Method: EPA 353.2
Nitrogen, Nitrate 14.2 mg/L 0.10 1 10/17/07 07:30
Date: 10/18/2007 04:41 PM
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
tO µACCCq'
4LLJ�.f�tl�! x
Page 7 of 10

Pace Analytical Services, Inc. Pace Analytical Services, Inc.
r cn lir+�l4ir}cal 2225 Riverside Dr. 9800 KinceyAve. Suite 100
% C! GG�Jt p JaS[sjLd Asheville, NC 28804 Huntersville, NC 28078
WWW(/ [phone] [phone]
QUALITY CONTROL DATA
Project: SS STATESVILLE FERT
Pace Project No.: 925787
QC Batch: WETA/1385
Analysis Method:
EPA 353.2
QC Batch Method: EPA 353.2
Analysis Description:
353.2 Nitrate + Nitrite, Unpres.
Associated Lab Samples: 925787001, 925787002, 925787003
METHOD BLANK: 28775
Associated Lab Samples: 925787001, 925787002, 925787003
Blank Reporting
Parameter
Units
Result Limit
Qualifiers
Nitrogen, Nitrate
mg/L
ND 0.10
LABORATORY CONTROL SAMPLE:
28776
Spike LCS
LCS
% Rec
Parameter
Units
Conc. Result
% Rec
Limits
Qualifiers
Nitrogen, Nitrate
mg/L
5 4.9
98
90-110
MATRIX SPIKE SAMPLE:
28781
925743002 Spike
MS
MS
% Rec
Parameter
Units
Result Conc.
Result
% Rec
Limits Qualifiers
Nitrogen, Nitrate
mg/L
25.9
5 29.4
70
75-125 MO
SAMPLE DUPLICATE: 28782
925851001 Dup
Parameter
Units
Result Result
RPD
Qualifiers
Nitrogen, Nitrate
mg/L
7.7
7.7 .1
Date: 10/18/2007 04:41 PM
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
•Coo,,'
Page 8 of 10

aceAnalytical QD
wmpacelabscom
Project: SS STATESVILLE FERT
Pace Project No.: 925787
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28604
[phone]
QUALITY CONTROL DATA
QC Batch: WETA/1390 Analysis Method: EPA 350.1
QC Batch Method: EPA 350.1 Analysis Description: 350.1 Ammonia
Associated Lab Samples: 925787001, 925787002, 925787003
METHOD BLANK: 28863
Associated Lab Samples: 925787001, 925787002, 925787003
Blank Reporting
Parameter Units Result Limit Qualifiers
Nitrogen, Ammonia mg/L ND 0.10
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
LABORATORY CONTROL SAMPLE:
28864
Spike
LCS LCS
% Rec
Parameter
Units
Conc.
Result % Rec
Limits
Qualifiers
Nitrogen, Ammonia
mg/L
5
5.1 102
90-110
MATRIX SPIKE SAMPLE:
28865
925792001
Spike MS
MS
% Rec
Parameter
Units
Result
Conc. Result
% Rec
Limits Qualifiers
Nitrogen, Ammonia
mg/L
0.46
5 5.8
106
75-125
SAMPLE DUPLICATE: 28866
925792002
Dup
Parameter
Units
Result
Result RPD
Qualifiers
Nitrogen, Ammonia
mg/L
0.66
0.67
.9
Date: 10/18/2007 04:41 PM
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
ti n
Page 9 of 10

wWW.s__
i
QUALIFIERS
Project: SS STATESVILLE FERT
Pace Project No.: 925787
DEFINITIONS
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
DF - Dilution Factor, if reported, represents the factor applied to the reported data due to changes in sample preparation, dilution of
the sample aliquot, or moisture content.
ND - Not Detected at or above adjusted reporting limit.
J - Estimated concentration above the adjusted method detection limit and below the adjusted reporting limit.
MDL -Adjusted Method Detection Limit.
S - Surrogate
1,2-Diphenylhydrazine (8270 listed analyte) decomposes toAzobenzene.
Consistent with EPA guidelines, unrounded data are displayed and have been used to calculate % recovery and RPD values.
LCS(D) - Laboratory Control Sample (Duplicate)
MS(D) - Matrix Spike (Duplicate)
DUP - Sample Duplicate
RPD - Relative Percent Difference
NC - Not Calculable..
Pace Analytical is NELAP accredited. Contact your Pace PM for the current list of accredited analytes.
ANALYTE QUALIFIERS
Mo Matrix spike recovery was outside laboratory control limits.
[phone]
Date: 10/18/2007 04:41 PM REPORT OF LABORATORY ANALYSIS Page 10 of 10
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
o N �CCCHCI
? o
z

E A ll,
aceAnalvtical
- 1r.- —zo— --)y - --nzWcz1k1wq - :-Ot— m it
The Chain -of -Custody is LEGAL DOCUMENT. All relevant fields must be completed accurately.
Page: of
(Section A
Section B
Section C
1-1
%
Required ,Cl ient Information: i�
Required Project
Information:
Invoice Information:
1 0 4 16 3 (3`
Company
Report To:
A
Attention:
REGULATORY AGENCY
Address
Copy To:
Company Name:
El NPDES
171'"GROUND WATER
El DRINKING WATER
0 UST
0 RCRA
0 Other
Address:
t
EIGA EIIIL I-] IN
El MI 0 MN
Email To:
Purchase Order No.:
Pace Quote Reference:
.2pC
A!
E ❑
30
]OH EIS C OWI
0 OTHER
PNne Fax
Project Name;"
Pace Project Manager:
Pace Project Manager:
Requested Due Date/TAT: 1, 1
A
Project Number:
Pape
Pace Proffle#:
61,z,
Filtered (YIN)
Requested
� C
4,,
Section D Required Client Information
Valid Matrix Codes
MATRIX CODE
0-
Preservatives
Analysis:
DRINKING WATER DW
WATER WT
w LU�
CLO
CL Z
2
SAMPLE ID
WASTE WATER WW
0
0 �u
11
LU
Q�
PRODUCT P
SOILISOLID SL
0 LU 0
X
COLLECTED
LU
z
One Character per box.
OIL OL
z
M
(A-Z, 0-9 /.-)
LU
WIPE WP
AIR AR
2 <0
wil
COMPOSITE START COMPOSITE
END/GRAB <
U)
0
'D 0
2! 0 In J: N
Samples IDS MUST BE UNIQUE
OTHER OT
U) 0 0 W
Pace Project Number
TISSUE TS
DATE E DAJE
I
TIME
C,4 Z
y X: z z 2
0
Lab I.D
7)
io
I I
V
, , , . . I �3.j 14
1XI
II
Additional Comments:
ACCEPTEP
BYJ AFFILIATION'
SAMPLE CONDITION
Pl.: J
z
z
5:
z
z
z
z
PLER.NAME AND
SIGNATURE
PRINT Name of SAMPLER:
-6
SEE REVERSE SIDE FOR INSTRUCTIONS
SIGNATURE of.SAMPLER,,;
DATE
Signeq CMM DQ I YY)
E
9
.
of o
. w
0 U)
w 'E
u)

aceAnalyircal
www.pacelabs.com
October 18, 2007
Mr. Chris Fay
Duncklee & Dunham
P.O. Box 33366
Raleigh, NC 27636
RE: Project: SS STATESVILLE 50200
Pace Project No.: 925743
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
Dear Mr. Fay:
Enclosed are the analytical results for sample(s) received by the laboratory on October 15, 2007.
The results relate only to the samples included in this report. Results reported herein conform to the
most current NELAC standards, where applicable, unless otherwise narrated in the body of the
report.
Inorganic Wet Chemistry and Metals analyses were performed at our Pace Asheville laboratory and
Organic testing was performed at our Pace Huntersville laboratory unless otherwise footnoted. All
Microbiological analyses were performed at the laboratory where the samples were received.
If you have any questions concerning this report, please feel free to contact me.
Sincerely,
Kevin Herring
[e-mail]
Project Manager
Enclosures
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
1 � AEI
aLLJ�J x
Page 1 of 9

aceAnalytical
www.pacelabs.com
Project: SS STATESVILLE 50200
Pace Project No.: 925743
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
CERTIFICATIONS
Pace Analytical Services, Inc.
9800 KinceyAve. Suite 100
Huntersville, NC 28078
Charlotte Certification IDs
Florida/NELAP Certification Number: E87627 North Carolina Field Services Certification Number: 5342
Kansas Certification Number: E-10364 South Carolina Certification Number: 990060001
Louisiana/LELAP Certification Number: 04034 South Carolina Bioassay Certification Number: 990060003
North Carolina Drinking Water Certification Number: 37706 Tennessee Certification Number: 04010
North Carolina Wastewater Certification Number: 12 Virginia Certification Number: 00213
Asheville Certification IDs
Florida/NELAP Certification Number: E87648
Louisiana/LELAP Certification Number: 03095
New Jersey Certification Number: NC011
North Carolina Drinking Water Certification Number: 37712
North Carolina Wastewater Certification Number: 40
North Carolina Bioassay Certification Number: 9
Eden Certification IDs
North Carolina Drinking Water Certification Number: 37738
Virginia Drinking Water Certification Number: 00424
Pennsylvania Certification Number: 68-03578
South Carolina Certification Number: 990300001
South Carolina Bioassay Certification Number: 990300002
Tennessee Certification Number: 2980
Virginia Certification Number: 00072
North Carolina Wastewater Certification Number: 633
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
Acco"7
uLLLrfI�aS�J i
[phone]
Page 2 of 9

aceAnalyti61'
www.pocalabs.com
Project: SS STATESVILLE 50200
Pace Project No.: 925743
Method: " EPA 350.1
Description: 350.1 Ammonia
Client: Duncklee & Dunham
Date: October 18, 2007
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
PROJECT NARRATIVE
General Information:
2 samples were analyzed for EPA 350.1. All samples were received in acceptable condition with any exceptions noted below.
Hold Time:
The samples were analyzed within the method required hold times with any exceptions noted below.
Initial Calibrations (including MS Tune as applicable):
All criteria were within method requirements with any exceptions noted below.
Continuing Calibration:
All criteria were within method requirements with any exceptions noted below.
Method Blank:
All analytes were below the report limit in the method blank with any exceptions noted below.
Laboratory Control Spike:
All laboratory control spike compounds were within QC limits with any exceptions noted below.
Matrix Spikes:
All percent recoveries and relative percent differences (RPDs) were within acceptance criteria with any exceptions noted below.
Duplicate Sample:
All duplicate sample results were within method acceptance criteria with any exceptions noted below.
Additional Comments:
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
ACCpq
�11r9if?�[1s
Pace Analytical Services, Inc.
9800 KinceyAve. Suite 100
Huntersville, NC 28078
[phone]
Page 3 of 9

/117paceAnalytcaI�
�I wympms1abs.wm
i
Project: SS STATESVILLE 50200
Pace Project No.: 925743
Method: EPA 353.2
Description: 353.2 Nitrogen, NO2/NO3 unpres
Client: Duncklee & Dunham
Date: October 18, 2007
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
PROJECT NARRATIVE
[phone]
General Information:
2 samples were analyzed for EPA 353.2. All samples were received in acceptable condition with any exceptions noted below.
Hold Time:
The samples were analyzed within the method required hold times with any exceptions noted below.
Initial Calibrations (including MS Tune as applicable):
All criteria were within method requirements with any exceptions noted below.
Continuing Calibration:
All criteria were within method requirements with any exceptions noted below.
Method Blank:
All analytes were below the report limit in the method blank with any exceptions noted below.
Laboratory Control Spike:
All laboratory control spike compounds were within QC limits with any exceptions noted below.
Matrix Spikes:
All percent recoveries and relative percent differences (RPDs) were within acceptance criteria with any exceptions noted below.
QC Batch: WETA/1385
A matrix spike and matrix spike duplicate (MS/MSD) were performed on the following sample(s): 925743002
MO: Matrix spike recovery was outside laboratory control limits.
• MS (Lab ID:.28781)
• Nitrogen, Nitrate
Duplicate Sample:
All duplicate sample results were within method acceptance criteria with any exceptions noted below.
Additional Comments:
This data package has been reviewed for quality and completeness and is approved for release.
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
o H �CCCgC'
4 x
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
Page 4 of 9

® Pace Analytical Services, Inc. Pace Analytical Services, Inc.
/7
1aneMaYical 2225 Riverside Dr. 9800 Kincey Ave. Suite 100
www.pacelabs.com Asheville, NC 28804 Huntersville, NC 28078
ANALYTICAL RESULTS
Project: SS STATESVILLE 50200
Pace Project No.: 925743
[phone] [phone]
Sample: K65W7 L Lab ID: 925743001 Collected: 10/15/07 13:44 Received: 10/15/07 16:15 Matrix: Water
Parameters Results Units Report Limit DF Prepared Analyzed CAS No. Qual
350.1 Ammonia Analytical Method: EPA 350.1
Nitrogen, Ammonia 12.9 mg/L 0.50 5 10/17/07 12:18 7764-41-7
353.2 Nitrogen, NO2/NO3 unpres Analytical Method: EPA 353.2
Nitrogen, Nitrate 30.5 mg/L 0.10 1 10/17/07 07:30
Date: 10/18/2007 04:43 PM
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
t
Page 5 of 9

aCeAnalyi►JcaJ
/ www.paceiabs.car+i
r
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
ANALYTICAL RESULTS
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
Project: SS STATESVILLE 50200
Pace Project No.: 925743
Sample: K65W7 K Lab ID: 925743002 Collected: 10/15/07 15:35 Received: 10/16/07 16:15 Matrix: Water
Parameters Results Units Report Limit DF Prepared Analyzed CAS No. Qua[
350.1 Ammonia Analytical Method: EPA350.1
Nitrogen, Ammonia 4.2 mg/L 0.10 1 10/17/07 11:46 7764-41-7
353.2 Nitrogen, NO2/NO3 unpres Analytical Method: EPA 353.2
Nitrogen; Nitrate 25.9 mg/L 0.10 1 10/17/07 07:30
Date: 10/18/2007 04:43 PM
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
CccAo�
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Page 6 of 9

aceAnalytical
www.pacelabs.com
Project: SS STATESVILLE 50200
Pace Project No.: 925743
QC Batch: WETAM 385
QC Batch Method: EPA 353.2
Associated Lab Samples: 925743001, 925743002
METHOD BLANK: 28775
Associated Lab Samples: 925743001, 925743002
Parameter Units
Nitrogen, Nitrate mg/L
LABORATORY CONTROL SAMPLE: 28776
Parameter Units
Nitrogen, Nitrate mg/L
MATRIX SPIKE SAMPLE: 28781
Parameter Units
Nitrogen, Nitrate mg/L
SAMPLE DUPLICATE: 28782
Parameter Units
Nitrogen, Nitrate mg/L
Date: 10/18/2007 04:43 PM
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
QUALITY CONTROL DATA
Analysis Method: EPA 353.2
Analysis Description: 353.2 Nitrate + Nitrite, Unpres.
Blank Reporting
Result Limit Qualifiers
ND 0.10
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
Spike LCS LCS % Rec
Conc. Result % Rec Limits Qualifiers
5 4.9 98 90-110
925743002 Spike MS MS % Rec
Result Conc. Result % Rec Limits Qualifiers
25.9 5 29.4 70 75-125 MO
925851001 Dup
Result Result RPD Qualifiers
7.7 7.7 .1
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
L µ µCCa,o
Page 7 of 9

/7�alceAnalXical'
mvw.pace+abs.a;om
1
i
Project: SS STATESVILLE 50200
Pace Project No.: 925743
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
QUALITY CONTROL DATA
QC Batch: WETA/1390 Analysis Method: EPA 350.1
QC Batch Method: EPA 350.1 Analysis Description: 350.1 Ammonia
Associated Lab Samples: 925743001, 925743002
METHOD BLANK: 28863
Associated Lab Samples: 925743001, 925743002
Parameter Units
Nitrogen, Ammonia mg/L
LABORATORY CONTROL SAMPLE: 28864
Parameter Units
Nitrogen, Ammonia mg/L
Blank Reporting
Result Limit Qualifiers
ND 0.10
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
Spike LCS LCS % Rec
Conc. Result % Rec Limits Qualifiers
5 5.1 102 90-110
MATRIX SPIKE SAMPLE: 28865
925792001 Spike MS MS % Rec
Parameter Units Result Conc. Result % Rec Limits Qualifiers
Nitrogen, Ammonia mg/L 0.46 5 5.8 106 75-125
SAMPLE DUPLICATE: 28866
Parameter
Nitrogen, Ammonia
Date: 10/18/2007 04:43 PM
925792002 Dup
Units Result Result
mg/L 0.66 0.67
RPD Qualifiers
.9
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
capo' x
Page 8 of 9

aceAnalytical
www.pacelabs.com
i
QUALIFIERS
Project: SS STATESVILLE 50200
Pace Project No.: 925743
DEFINITIONS
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
DF - Dilution Factor, if reported, represents the factor applied to the reported data due to changes in sample preparation, dilution of
the sample aliquot, or moisture content.
ND - Not Detected at or above adjusted reporting limit.
J - Estimated concentration above the adjusted method detection limit and below the adjusted reporting limit.
MDL-Adjusted Method Detection Limit.
S - Surrogate
1,2-Diphenylhydrazine (8270 listed analyte) decomposes to Azobenzene.
Consistent with EPA guidelines, unrounded data are displayed and have been used to calculate % recovery and RPD values.
LCS(D) - Laboratory Control Sample (Duplicate)
MS(D) - Matrix Spike (Duplicate)
DUP - Sample Duplicate
RPD - Relative Percent Difference
NC - Not Calculable.
Pace Analytical is NELAP accredited. Contact your Pace PM for the current list of accredited analytes.
ANALYTE QUALIFIERS
MO Matrix spike recovery was outside laboratory control limits.
Date: 10/18/2007 04:43 PM ' REPORT OF LABORATORY ANALYSIS Page 9 of 9
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
<' Cpgd
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%IN ICU DY flyt Re(. t Di -ien
PaceAnalyfical`
www.pacelabs.cDatt
The Chain -of -Custody is a LEGAL DOCUMENT. All relevant fields must be completed accurately.
Section A Section B Section C
Page: of
Required. I Client Information: Required Project Information: Invoice Information:
Company: Report To: i Attention,
11 07 `3
Address: v.,
Copy To:
Company Name:
REGULATORY AGENCY
Address:
NPDES,.r'v, ..a, GROUND WATER DRINKING WATER
LIST F RCRA r OTHER
Email To:
Purchase Order No.:
Pace Quote
A k^,
Reference:
...
Fax,
Project Name: P
Pace Project
Manager:
Site Location
Requested D a DaterrAT:
Project Number.
Pam Profile 0:
STATE:
Requested
Analysis
Filtered
Y/N)
Section D Matrix Codes
ZF
z
RequiredClient Information MATRIX I CODE
2
2
COLLECTED
Preservatives
1
Drinking Water DW
2
0
z
Water WT
0
0
s WW Waste Water
COMPOSITE
COMPOSTTE
Product P
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START
END/GRAB
Lu
S oil/Solid SL
0
SAMPLE ID oil OL
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Sample IDS MUST BE UNIQUE Tissue TS
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ADDITIONAL COMMENTS
RE 'Y' AFFILIATION
LjNQUI%HEP
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TIME
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ACCEPTED BY/ AFFILIATION
....
DATE
TIME
SAMPLE CONDITIONS
LNI
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SAMPLER NAME AND SIGNATURE
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PRINT Name of SAMPLER:
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SIGNATURE of SAMPLER:Signed
DATE
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o' � V,.I,.y y— are accepting 1-a- S Nt I ju cay payment terms and agreeing to iate Charges of 1.5% per month for any ihvbices not paid within 90 dis. F-ALL-Q-020rev.07, 15-May-2007

aunc A I l 1>cai y
a�ty�t: pacestabs. cam
January 16, 2007
Mr. Chris Fay
Duncklee & Dunham
PO Box 33366
Raleigh, NC 27636
RE: Lab Project Number: 92135554
Client Project ID: SS Statesville 50400
Dear Mr. Fay:
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Huntersville, NC 28078
Phone: [phone]
Fax 704.875, 9091
Enclosed are the analytical results for sample(s) received by the laboratory on January 9, 2007. Results
reported herein conform to the most current NELAC standards, where applicable, unless otherwise narrated in the
body of the report.
Inorganic Wet Chemistry and Metals Analyses were performed at our Pace Asheville laboratory and Organic testing
was performed at our Pace Charlotte laboratory unless otherwise footnoted.
If you have any questions concerning this report please feel free to contact me.
Sincerely,
Kevin Herring
[e-mail]
Project Manager
Enclosures
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS
NC Wastewater 40 This report shall not be reproduced, except in full,
NC Drinking Water 37712 without the written consent of Pace Analytical Services, Inc.
SC Environmental 99030
FL NELAP E87648
ail .1�.1�1.C'S
Charlotte Certification IDs
NC Wastewater
12
NC Drinking Water
37706
SC
99006
FL NELAP
E87627

Lab Sample No: 927873000
Client Sample ID: EFF010907
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Nuntersville, NC 28078
Phone: [phone]
Fax: 704.875.909 i
Lab Project Number: 92135554
Client Project ID: SS Statesville 50400
Project Sample Number: 92135554-001 Date Collected: 01/09/07 09:50
Matrix: Water Date Received: 01/09/07 10:35
Parameters Results Units Report Limit Analyzed By CAS No. Oual RecfLmt
Wet Chemistry
Total Suspended Solids Method: EPA 160.2
Total Suspended Solids 1.7 mg/l 1.7 01/15/07 14:12 JDA1
Ammonia
Nitrogen, Ammonia
Date: 01/16/07
Method: EPA 350.1
12. mg/l 1.0 01/13/07 09:12 JDA1 7727-37-9
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS
NC Wastewater 40 This report shall not he reproduced, except in full,
NC Drinking Water 37712 without the written consent of Pace Analytical Services, Inc.
SC Environmental 99030
FL NELAP E87648
aCA'
Charlotte Certification IDs
NC Wastewater
12
NC Drinking Water
37706
SC
99006
FL NELAP
E87627
Page: 1 of 5

C,icue!'ti lalXica
vrtrrv. pamiabs.com
i
PARAMETER FOOTNOTES
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Nuntersville, NC 28078
Phone: [phone]
Fax [phone]
Lab Project Number: 92135554
Client Project ID:.SS Statesville 50400
Method 9071B modified to use ASE.
All pH, Free Chlorine, Total Chlorine and Ferrous Iron analyses conducted outside of EPA recommended immediate
hold time.
Depending on the moisture content the PRLs can be elevated for all soil samples reported on a dry weight basis.
2-Chloroethyl vinyl ether has been shown to degrade in the presence of acid.
ND Not detected at or above adjusted reporting limit
NC Not Calculable
J Estimated concentration above the adjusted method detection limit and below the adjusted reporting limit
MDL Adjusted Method Detection Limit
Date: 01/16/07
Asheville Certification IDS REPORT OF LABORATORY ANALYSIS Charlotte Certification IDS
NC Wastewater 40 This report shall not he reproduced, except in full, NC Wastewater 12
NC Drinking Water 37712 without the written consent of Pace Analocal Services, Inc. NC Drinking Water 37706
SC Environmental 99030 :" SC 99006
FL NELAP E87648 FL NELAP E87627
Page: 2 of 5

QC Batch: 177904
QC Batch Method: EPA 160.2
Associated Lab Samples:.
927873000
METHOD BLANK: 927895839
Associated Lab Samples: 927873000
Pace Anaiolcal Services, Inc.
9800 Kincey Avenue, Suite 100
Hunters ville, NC 28078
Phone: [phone]
Fax 704,875.9091
QUALITY CONTROL DATA
Lab Project Number: 92135554
Client Project ID: SS Statesville 50400
Analysis Method: EPA 160.2
Analysis Description: Total Suspended Solids
Blank Reporting
Parameter Units Result Limit Footnotes
Total Suspended Solids mg/1 ND 1.0
LABORATORY CONTROL SAMPLE: 927895847
Spike LCS LCS
Parameter Units Conc. Result % Rec Footnotes
Total Suspended Solids mg/1 250.00 212.0 85
SAMPLE DUPLICATE: 927895854
Parameter Units
Total Suspended Solids mg/1
Date: 01/16/07
927881409 DUP
Result Result RPD Footnotes
7.000 11.00 42
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS Charlotte Certification IDs
NO Wastewater 40 This report shall not be reproduced, except in full, NO Wastewater 12
NO Drinking Water 37712 without the written consent of Pace Analytical Services, Inc. NO Drinking Water 37706
SC Environmental 99030 SC 99006
FL NELAP E87648 FL NELAP E87627
Page: 3 of 5

tvivbv.paoalabs com
QC Batch: 177879
QC Batch Method: EPA 350.1
Associated Lab Samples:
927873000
METHOD BLANK: 927895037
Associated Lab Samples: 927873000
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Huntersville, NC 28078
Phone: [phone]
Fax: [phone]
QUALITY CONTROL DATA
Lab Project Number: 92135554
Client Project ID: SS Statesville 50400
Analysis Method: EPA 350.1
Analysis Description: Ammonia
Blank Reporting
Parameter Units Result Limit Footnotes
Nitrogen, Ammonia mg/l ND 0.10
LABORATORY CONTROL SAMPLE: 927895045
Spike LCS LCS
Parameter Units Conc. Result % Rec Footnotes
Nitrogen, Ammonia mg/l 1.000 1.100 110
MATRIX SPIKE: 927895078
927859413 Spike MS MS
Parameter Units Result Conc. Result % Rao Footnotes
Nitrogen, Ammonia mg/l 20.06 1.000 20.98 93
SAMPLE DUPLICATE: 927895086
Parameter Units
Nitrogen, Ammonia mg/l
Date: 01/16/07
927859421 DUP
Result Result RPD Footnotes
0.1600 0.1000 43
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS Charlotte Certification IDs
NC Wastewater 40 This report shall not be reproduced, except in full, NC Wastewater 12
NC Drinking Water 37712 without the written consent of Pace Analytical Services, Inc. NC Drinking Water 37706
SC Environmental 99030 Sc 99006
FL NELAP E87648 FL NELAP E87627
�rr.e=
Page: 4 of 5

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QUALITY CONTROL DATA PARAMETER FOOTNOTES
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Huntersville, NO 28078
Phone: 704,875.9092
Fax., 704.875.9091
Lab Project Number: 92135554
Client Project ID: SS Statesville 50400
Consistent with EPA guidelines, unrounded concentrations are displayed and have been used to calculate % Rec and RPD values.
LCS(D) Laboratory Control Sample (Duplicate)
MS(D) Matrix Spike (Duplicate)
DUP Sample Duplicate
ND Not detected at or above adjusted reporting limit
NC Not Calculable
J Estimated concentration above the adjusted method detection limit and below the adjusted reporting limit
MDL Adjusted Method Detection Limit
RPD Relative Percent Difference
Date: 01/16/07
Asheville Certification Ms REPORT OF LABORATORY ANALYSIS
NC Wastewater 40 This report shall not be reproduced, except in full,
NC Drinking Water 37712 without the written consent of Pace Analytical Services, Inc.
SC Environmental 99030
FL NELAP E87648
Charlotte Certification IDs
NC Wastewater
12
NC Drinking Water
37706
SC
99006
FL NELAP
E87627
Page: 5 of 5

aceAnalytical
Section A
Required Client Information:
Section B
Required Project Information:
Copy To:
Purchase Order No.:
ax �� �a l�
�i�1
Proj act Name: C A'
Requested Due Date/TAT: 1 A
Project Numbe"5V`'
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Section D Required Client Information
Valid Matex Codes
MATRIX CODE
DRINKING WATER DW
SAMPLE I D
WATER VVT
WASTE WATER V
PRODUCT P
One Character per box.
SOIIJSOLID SL
OIL OL
(A-Z, 0-9 / .)
WIPE WP
AIR AR
Samples IDs MUST BE UNIQUE
OTHER OTT
TISSUE TS
-E
If: li=o,oct
1,,
Additional Comments:
SEE REVERSE SIDE FOR INSTRUCTIONS
ORIGINAL
CHAIN -OF -CUSTODY / Analytical Request Document
The Chain -of -Custody is a LEGAL DOCUMENT. All relevant fields must be completed accurately.
Section C
Invoice Information:
Attention:
Company Name:
Address:
Pace Quote Reference:
Pace Project Manager:
Pace Profile X:
le: of
1043851
NPDES ❑ GROUNDWATER ❑ DRINKING WATER
❑. UST.._...._ ... ❑ RCRA ❑ Other
—GA ❑IL ❑IN ❑MI ❑MN NC
❑OH ❑SC ❑ WI ❑OTHER
Filtered (YIN)
Requested
Analysis:
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Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Nuntersville, NC 28078
Phone: [phone]
Fax [phone]
February 05, 2007
Mr. Chris Fay
Duncklee & Dunham
PO Box 33366
Raleigh, NC 27636
RE: Lab Project Number: 92136883
Client Project ID: SS Statesville/50400
Dear Mr. Fay:
Enclosed are the analytical results for sample(s) received by the laboratory on January 26, 2007. Results
reported herein conform to the most current NELAC standards, where applicable, unless otherwise narrated in the
body of the report.
Inorganic Wet Chemistry and Metals Analyses were performed at our Pace Asheville laboratory and Organic testing
was performed at our Pace Charlotte laboratory unless otherwise footnoted.
If you have any questions concerning this report please feel free to contact me.
Sincerely,
^'V1
Kevin Herring
[e-mail]
Project Manager
Enclosures
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS
NC Wastewater 40 This report shall not he reproduced, except in full,
NC Drinking Water 37712 without the written consent of Pace Analytical Services, Inc.
SC Environmental 99030
I FL NELAP E87648 C
Charlotte Certification IDs
NC Wastewater
12
NC Drinking Water
37706
SC
99006
FL NELAP
E87627

Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
�SrCr./'lilat ical "' HPhonev7D NC28078
t Phone: [phone]
urt. au. pacelabs cam Fax: [phone]
i
Lab Project Number: 92136883
Client Project ID: SS Statesville/50400
Lab Sample No: 927941476 Project Sample Number:'92136883-001 Date Collected: 01/26/07 11:30
Client Sample ID: EFF0126077 Matrix: Water Date Received: 01/26/07 12:20
Parameters
Results
Units Report
Limit
Analyzed
By CAS No. Qual RegLmt
Metals
Metals by Trace ICP
Prep/Method:
EPA 3010 / EPA
6010
Copper
ND
ug/l
5.0
01/31/07
21:26 SHB 7440-50-8
Date Digested
01/30/07 12:40
01/30/07
12:40
Wet Chemistry
Total Suspended Solids
Method: EPA
160.2
Total Suspended Solids
21.
mg/1
1.7
02/02/07
17:10 JMW
Chloride (Mercuric Nitrate)
Method: EPA
325.2
Chloride
65.
mg/l
25.
02/01/07
18:10 SAJ 16887-00-6
Ammonia
Nitrogen, Ammonia
Total Kjeldahl Nitrogen
Nitrogen, Kjeldahl, Total
48 Hour NO3 / NO2 / NOX
Nitrate as N
Phosphorus, Total
Phosphorus
Nitrogen, Total
Nitrogen
Date: 02/05/07
Method: EPA 350.1
13. mg/1
Method: EPA 351.2
9.0 mg/1
Method: EPA 353.2
50. mg/1
Method: EPA 365.2
ND mg/1
Method:
59.
mg/l
0.10 01/31/07 10:05 EWS 7727-37-9
0.50 02/02/07 13:40 JMW
0.10 01/26/07 20:21 EWS
0.100 01/29/07 16:15 JMW 7723-14-0
0.60 02/05/07
WWB 7727-37-9
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS Charlotte Certification IDs
NO Wastewater 40 This report shall not he reproduced, except in full, NO Wastewater 12
NO Drinking Water 37712 without the written consent of Pace Analytical Services, Inc. NO Drinking Water 37706
SC Environmental 99030 SC 99006
FL NELAP E87648 FL NELAP E87627
Page: 1 of 10

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PARAMETER FOOTNOTES
Method 9071B modified to use ASE.
Pace Anaiyticai Services, Inc.
9800 Kincey Avenue, Suite 100
Huntersviiie, NC 28078
Phone: 704,875.9092
Fax [phone]
Lab Project Number: 92136883
Client Project ID: SS Statesville/50400
All pH, Free Chlorine, Total Chlorine and Ferrous Iron analyses conducted outside of EPA recommended immediate
hold time.
Depending on.the moisture content the PRLs can be elevated for all soil samples reported on a dry weight basis.
2-Chloroethyl vinyl ether has been shown to degrade in the presence of acid.
ND Not detected at or above.adjusted reporting limit
NC Not Calculable
J Estimated concentration above the adjusted method detection limit and below the adjusted reporting limit
MDL Adjusted Method Detection Limit
Date: 02/05/07
Asheville Certification IDs
REPORT OF LABORATORY ANALYSIS
Charlotte Certification IDs
NO Wastewater 40
This report shall not be reproduced, except in full,
NO Wastewater
12
NO Drinking Water 37712
without the written consent of Pace Analytical Services, Inc.
NO Drinking Water
37706
SC Environmental 99030
Cep9
SC
99006
FL NELAP E87648
?C't eh
FL NELAP
E87627
Page: 2 of 10

4A ce 1+ alWi of `
J3$•/CL'/23�kS.C4t7J
QC Batch: 179231
QC Batch Method: EPA 3010
Associated Lab Samples:
927941476
METHOD BLANK: 927949727
Associated Lab Samples: 927941476
Pace Anaiylical Services, Inc.
9800 Kincey Avenue, Suite 100
Hunters ville, NC 28078
Phone: [phone]
Fax [phone]
QUALITY CONTROL DATA
Lab Project Number: 92136883
Client Project ID: SS Statesville/50400
Analysis Method: EPA 6010
Analysis Description: Metals by Trace ICP
Blank Reporting
Parameter Units Result Limit Footnotes
Copper ug/l ND 5.0
LABORATORY CONTROL SAMPLE: 927949735
Spike LCS LCS
Parameter Units Conc. Result % Rec Footnotes
Copper ug/l 500.00 551.0 110
MATRIX SPIKE: 927949743
927941476 Spike MS MS
Parameter Units Result Conc. Result % Rec Footnotes
Copper ug/l 0 500.00 499.0 100
SAMPLE DUPLICATE: 927949750
Parameter Units
Copper mg/1
Date: 02/05/07
927942854 DUP
Result Result RPD Footnotes
ND ND NC
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS Charlotte Certification IDs
NO Wastewater 40 This report shall not be reproduced, except in full, NO Wastewater 12
NO Drinking Water 37712 without the written consent of Pace Analytical Services, Inc. NO Drinking Water 37706
SC Environmental 99030 SC 99006
FL NELAP E87648 FL NELAP E87627
Page: 3 of 10

t ceAnal call'
+i�+eau, pacetabs corn
QC Batch: 179646
QC Batch Method: EPA 160.2
Associated Lab Samples:
927941476
METHOD BLANK: 927963959
Associated Lab Samples: 927941476
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Hunters ville, NC28078
Phone: [phone]
Fax [phone]
QUALITY CONTROL DATA
Lab Project Number: 92136883
Client Project ID: SS Statesville/50400
Analysis Method: EPA 160.2
Analysis Description: Total Suspended Solids
Blank Reporting
Parameter Units Result Limit Footnotes
Total Suspended Solids mg/1 ND 1.0
LABORATORY CONTROL SAMPLE: 927963967
Spike LCS LCS
Parameter Units Conc. Result % Rec Footnotes
Total Suspended Solids mg/l 250.00 216.0 86
SAMPLE DUPLICATE: 927963975
Parameter Units
Total Suspended Solids mg/l
Date: 02/05/07
Asheville Certification IDs
NC Wastewater 40
NC Drinking Water 37712
SC Environmental 99030
FL NELAP E87648
927938621 DUP
Result Result RPD Footnotes
190.0 180.0 5
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc.
Charlotte Certification IDs
NC Wastewater
12
NC Drinking Water
37706
SC
99006
FL NELAP
E87627
Page: 4 of 10

QC Batch: 179077
QC Batch Method: EPA 353.2
Associated Lab Samples:
927941476
METHOD BLANK: 927943399
Associated Lab Samples: 927941476
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Huntersville, NC 28076
Phone: [phone]
Fax [phone]
QUALITY CONTROL DATA
Lab Project Number: 92136883
Client Project ID: SS Statesville/50400
Analysis Method: EPA 353.2
Analysis Description: 48 Hour NO3 / NO2 / NOX
Blank Reporting
Parameter Units Result Limit Footnotes
Nitrate as N mg/l ND 0.10
LABORATORY CONTROL SAMPLE: 927943407
Spike LCS LCS
Parameter Units Conc. Result % Rec Footnotes
Nitrate as N mg/l 5.000 5.390 108
MATRIX SPIKE: 927943415
927939595 Spike MS MS
Parameter Units Result Conc. Result % Rec Footnotes
Nitrate as N mg/l 0 5.000 5.650 113
SAMPLE DUPLICATE: 927943423
Parameter Units
Nitrate as N mg/l
Date: 02/05/07
927939603 DUP
Result Result RPD Footnotes
ND ND NC
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS Charlotte Certification IDs
NO Wastewater 40 This report shall not he reproduced, except in full, NO Wastewater 12
NO Drinking Water 37712 without the written consent of Pace Analytical Services, Inc. NO Drinking Water 37706
SC Environmental 99030 SC 99006
FL NELAP E87648.. FL NELAP E87627
J J�[LC'S
Page: 5 of 10

I(iettna1j i a :«
tAAv PaCelabS.Com
Pace Analylicai Services, Inc.
9800 Kincey Avenue, Suite 100
Huntersville, NC 28078
Phone: [phone]
Fax [phone]
QUALITY CONTROL DATA
Lab Project Number: 92136883
Client Project ID: SS Statesville/50400
QC Batch: 179189 Analysis Method: EPA 365.2
QC Batch Method: EPA 365.2 Analysis Description: Phosphorus, Total
Associated Lab Samples: 927941476
■
. METHOD BLANK: 927948620
Associated Lab Samples: 927941476
Blank Reporting
Parameter Units Result Limit Footnotes
Phosphorus mg/1 ND 0.100
LABORATORY CONTROL SAMPLE: 927948638
Spike LCS LCS
Parameter Units Conc. Result % Rec Footnotes
Phosphorus mg/l 1.000 0.9080 91
MATRIX SPIKE: 927948646
927930388 Spike MS MS
Parameter Units Result Conc. Result % Rec Footnotes
Phosphorus mg/l 0.06200 1.000 0.8870 82
SAMPLE DUPLICATE: 927948653
927930396 DUP
Parameter Units Result Result RPD Footnotes
Phosphorus mg/l ND ND NC
Date: 02/05/07
Asheville Certification IDs
NC Wastewater 40
NC Drinking Water 37712
SC Environmental 99030
FL NELAP E87648
REPORT OF LABORATORY ANALYSIS
This report shall not he reproduced, except in full,
without the written consent of Pace Analocal Services, Inc.
Charlotte Certification IDs
NC Wastewater
12
NC Drinking Water
37706
Sc
99006
FL NELAP
E87627
Page: 6 of 10

Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Hunters ville, NC28078
Phone. [phone]
Fax., 704.875.9091
QUALITY CONTROL DATA
Lab Project Number: 92136883
Client Project ID: SS Statesville/50400
QC Batch: 179294
Analysis Method: EPA 325.2
QC Batch Method: EPA 325.2
Analysis
Description: Chloride (Mercuric Nitrate)
Associated Lab Samples:
927941476
METHOD BLANK: 927951384
Associated Lab Samples:
927941476
Blank
Reporting
Parameter
Units
Result
Limit Footnotes
Chloride
mg/l
ND
5.0
LABORATORY CONTROL SAMPLE:
927951392
Spike
LCS LCS
Parameter
Units
Conc.
Result % Rec Footnotes
Chloride
mg/l
20.00
21.86 109
MATRIX SPIKE: 927951400
927928507
Spike MS MS
Parameter
Units
Result
Conc. Result % Rec Footnotes
Chloride
mg/l
20.98
20.00 41.74 104
SAMPLE DUPLICATE: 927951418
Parameter Units
Chloride mg/l
Date: 02/05/07
927917260 DUP
Result Result RPD Footnotes
16.00 16.00 0
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS Charlotte Certification IDs
NC Wastewater 40 This report shall not he reproduced, except in full, NC Wastewater 12
NC Drinking Water 37712 without the written consent of Pace Analytical Services, Inc. NC Drinking Water 37706
SC Environmental 99030 SC 99006
FL NELAP E87648 FL NE LAP E87627
Page: 7 of 10

acre naljd ca M
tart nr. paceiabs. com
I
QC Batch: 179382
QC Batch Method: EPA 350.1
Associated Lab Samples:
927941476
METHOD BLANK: 927955096
Associated Lab Samples: 927941476
Pace Anaiyticai Services, Inc.
9800 Kincey Avenue, Suite 100
Huntersville, NC 28078
Phone: 704,875.9092
Fax 704,875.9091
QUALITY CONTROL DATA
Lab Project Number: 92136883
Client Project ID: SS Statesville/50400
Analysis Method: EPA 350.1
Analysis Description: Ammonia
Blank Reporting
Parameter Units Result Limit Footnotes
Nitrogen, Ammonia mg/l ND 0.10
LABORATORY CONTROL SAMPLE: 927955104
Spike LCS LCS
Parameter Units Conc. Result % Rec Footnotes
Nitrogen, Ammonia mg/l 1.000 1.060 106
MATRIX SPIKE: 927955112
927930339 Spike MS MS
Parameter Units Result Conc. Result % Rec Footnotes
Nitrogen, Ammonia mg/l 0.09000 1.000 0.9100 82
SAMPLE DUPLICATE: 927955120
Parameter Units
Nitrogen, Ammonia mg/l
Date: 02/05/07
927930354 DUP
Result Result RPD Footnotes
0.1300 0.1100 17
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS Charlotte Certification IDs
NC Wastewater 40 This report shall not he reproduced, except in full, NC Wastewater 12
NC Drinking Water 37712 without the written consent of Pace Analytical Services, Inc, NO Drinking Water 37706
SC Environmental 99030 SC 99006
FL NELAP E87648 „ FL NELAP E87627
Page: 8 of 10

a V Al l/Rl ca '
asn�nu pacslabs,com
I
QC Batch: 179567
QC Batch Method: EPA 351.2
Associated Lab Samples:
927941476
METHOD BLANK: 927960401
Associated Lab Samples: 92.7941476
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Huntersville, NC28078
Phone: [phone]
Fax, 704.8759091
QUALITY CONTROL DATA
Lab Project Number: 92136883
Client Project ID: SS Statesville/50400
Analysis Method: EPA 351.2
Analysis Description: Total Kjeldahl Nitrogen
Blank Reporting
Parameter Units Result Limit Footnotes
Nitrogen, Kjeldahl, Total mg/l ND 0.50
LABORATORY CONTROL SAMPLE: 927960419
Spike LCS LCS
Parameter Units Conc. Result % Rec Footnotes
Nitrogen, Kjeldahl, Total mg/1 5.000 4.604 92
MATRIX SPIKE: 927960427
927916205 Spike MS MS
Parameter Units Result Conc. Result % Rec Footnotes
Nitrogen, Kjeldahl, Total mg/l 333.7 50.00 336.2 5 1
SAMPLE DUPLICATE: 927960435
Parameter Units
Nitrogen, Kjeldahl, Total mg/1
Date: 02/05/07
927916239 DUP
Result Result RPD Footnotes
29.00 27.00 6
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS Charlotte Certification IDs
NC Wastewater 40 This report shall not be reproduced, except in full, NC Wastewater 12
NC Drinking Water 37712 without the written consent of Pace Analytical Services, Inc. NC Drinking Water 37706
SC Environmental 99030 SC 99006
FL NELAP E87648 �,,,,AA..,„ FL NELAP E87627
l l�dC`
Page: 9 of 10

1�aceAnalXicaf"
WV'%V. pacelabS.com
t
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Huntersville, NO 28078
Phone: [phone]
Fax: [phone]
Lab Project Number: 92136883
Client Project ID: SS Statesville/50400
QUALITY CONTROL DATA PARAMETER FOOTNOTES
Consistent with EPA guidelines, unrounded concentrations are displayed and have been used to calculate % Rec and RPD values.
LCS(D) Laboratory Control Sample (Duplicate)
MS(D) Matrix Spike (Duplicate)
DUP Sample Duplicate
ND Not detected at or above adjusted reporting limit
NC Not Calculable
J Estimated concentration above the adjusted method detection limit and below the adjusted reporting limit
MDL Adjusted Method Detection Limit
RPD Relative Percent Difference
Ell The spike recovery was outside acceptance limits for the MS and/or MSD due to an analyte concentration in the
sample at four times greater than the spike concentration. The QC batch was accepted based upon LCS and/or
LCSD recoveries within acceptance limits.
Date: 02/05/07
Asheville Gedfication IDs REPORT OF LABORATORY ANALYSIS
NC Wastewater 40 This report shall not 6e reproduced, except in full,
NC Drinking Water 37712 without the written consent of Pace Analytical Services, Inc.
SC Environmental 99030
FL NELAP E87648
Charlotte Certification IDs
NC Wastewater
12
NC Drinking Water
37706
SC
99006
FL NELAP
E87627
Page: 10 of 10

aceAnalytical
Section A
Required Client Information:
Email To:
Requested Due Date/TAC�
Section D Required "Clli�e'nttInformation
SAMPLE ID
One Character per box.
W (A-Z, 0-9
t Samples IDs MUST BE UNIQUE
FT4�� I C M �
Additional Comments:
CHAIN -OF -CUSTODY / Analytical Request Document
The Chain -of -Custody is a LEGAL DOCUMENT. All relevant fields must be completed accurately.
Page: of
Section B
Section
Required Project Information:
Invoice Information: c
100372
Report To:
LI.V, 1:;,J
v
Attention: 1
REGULATORY AGENCY
l I S
Copy To:
Company Name: NPDES ❑ GROUNDWATER ❑ DRINKING WATER IFIV
❑ UST ❑ RCRA ❑ Other
Address:
Purchase Order No.:
Pace Quote Reference: !!N�
Ml f0GA❑IL❑IN ❑Mt ❑ MN �(NC
❑SC ❑ WI ❑OTHER
Project Name:
Pace Project Manager:
Project Number: S y>'
Filtered (YIN)
Pace Profile #:
`-' `!' c,
' Requested
atrbc Codes
CODE
Analysis: r
DRINKING WATER DW
W
WM
z
WATER WT
❑
o O
O
0
WASTE WATER WW
O
U
y}O
F
W
PRODUCT P
SOIUSOL D SL
x
Lum
COLLECTED
j J
LL
O Q
OIL OL
WIPE VVP
�
aJO
a O
*Z
AIR AR
<0
START
COMPOSITE ENDIGRAB
o
OTHER OT
�DATE
TIME
DATE
I TIME
TISSUE TS
Ce
t i r_u
11-2-0.
.. n
r
Preservatives
941 134 .11
o c' �•
U p m da Pace Project Number
x z z i5 Lab I.D
. �. .�.�+� ��+.� wm 1 " I 1 nn" I ri�.�.Mr- I cU t3T / AhFILIA 1 IUN I DATE I TIME - •Nalkli•
F MORM&NIMIUM �MVWJT
SAMPLER
NAME AND SIGNATURE
"--VERSr--'---ORINf--------ONS OF - -i_

vm .pac-elabs cor-0
February 16, 2007
Mr. Chris Fay
Duncklee & Dunham
PO Box 33366
Raleigh, NC 27636
RE: Lab Project Number: 92137397
Client Project ID: SS STATESVILLE 50400
Dear Mr. Fay:
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Huntersville, NC 28078
Phone: [phone]
Fax [phone]
Enclosed are the analytical results for sample(s) received by the laboratory on February 6, 2007. Results
reported herein conform to the most current NELAC standards, where applicable, unless otherwise narrated in the
body of the report.
Inorganic Wet Chemistry and Metals Analyses were performed at our Pace Asheville laboratory and Organic testing
was performed at our Pace Charlotte laboratory unless otherwise footnoted.
If you have any questions concerning this report please feel free to contact me.
Sincerely,
Kevin herring
[e-mail]
Project Manager
Enclosures
Asheville Certification IDs Charlotte Certification IDs
NC Wastewater 12
NC Drinking Water 37706
SC 99006
FL NELAP E87627
REPORT OF LABORATORY ANALYSIS
NC Wastewater 40"
This report shall not he reproduced, except in full,
NC Drinking Water 37712
without the written consent of Pace Analytical Services, Inc.
SC Environmental 99030
FL NELAP E87648

Lab Sample No: 927973925
Client Sample ID: EFF 020607
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Huntersville, NC 28078
Phone. [phone]
Fax [phone]
Lab Project Number: 92137397
Client Project ID: SS STATESVILLE 50400
Project Sample Number: 92137397-001 Date Collected: 02/06/07 09:15
Matrix: Water Date Received: 02/06/07 10:00
Parameters Results Units Report Limit Analyzed By CAS No. Oual ReaLmt
Wet Chemistry
Total Suspended Solids Method: EPA 160.2
Total Suspended Solids 52. mg/l 1.8 02/13/07 12:25 TMR
Ammonia
Nitrogen, Ammonia
Date: 02/16/07
Method: EPA 350.1
12. mg/1 0.10 02/12/07 18:02 JMW 7727-37-9
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS Charlotte Certification IDs
NC Wastewater 40 This report shall not he reproduced, except in full, NC Wastewater 12
NC Drinking Water 37712 without the written consent of Pace Analytical Services, Inc. NC Drinking Water 37706
SC Environmental 99030 Sc 99006
FL NELAP E87648 _Al! „ FL NELAP E87627
Page: 1 of 5

aceAnaVicaf:
mvw,pace/abs.conn
PARAMETER FOOTNOTES
Pace Analytical Services, Inc.
9800 KinceyAvenue, Suite 100
Huntersville, NC 28078
Phone: [phone]
Fax [phone]
Lab Project Number: 92137397
Client Project ID: SS STATESVILLE 50400
Method 9071B modified to use ASE.
All pH, Free Chlorine, Total Chlorine and Ferrous Iron analyses conducted outside of EPA recommended immediate
hold time.
Depending on the moisture content the PRLs can be elevated for all soil samples reported on a dry weight basis.
2-Chloroethyl vinyl ether has been shown to degrade in the presence of acid.
ND Not detected at or above adjusted reporting limit
NC Not Calculable
J Estimated concentration above the adjusted method detection limit and below the adjusted reporting limit
MDL Adjusted Method Detection Limit
Date: 02/16/07
Asheville Certification IDS REPORT OF LABORATORY ANALYSIS
NO Wastewater 40 This report shall not be reproduced, except in full,
NO Drinking Water 37712 without the written consent of Pace Analytical Services, Inc.
SC Environmental 99030
FL NELAP E87648
J .I�d4C'.=
Charlotte Certification IDs
NO Wastewater
12
NO Drinking Water
37706
SC
99006
FL NELAP
E87627
Page: 2 of 5

5aa,'juceAnalytcaI "
1 wtnv. par,�tabs,cDrrt
i
QC Batch: 180385
QC Batch Method: EPA 160.2
Associated Lab Samples:
927973925
METHOD BLANK: 927999755
Associated Lab Samples: 927973925
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Hunters ville, NC 28078
Phone: [phone]
Fax: 704.875,9091
QUALITY CONTROL DATA
Lab Project Number: 92137397
Client Project ID: SS STATESVILLE 50400
Analysis Method: EPA 160.2
Analysis Description: Total Suspended Solids
Blank Reporting
Parameter Units Result Limit Footnotes
Total Suspended Solids mg/l ND 1.0
LABORATORY CONTROL SAMPLE: 927999763
Spike LCS LCS
Parameter Units Conc. Result % Rec .Footnotes
Total Suspended Solids mg/l 250.00 242.0 97
SAMPLE DUPLICATE: 927999821
Parameter Units
Total Suspended Solids mg/1
Date: 02/16/07
927979492 DUP
Result Result RPD Footnotes
3300 3400 2
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS Charlotte Certification IDs
NC Wastewater 40 This report shall not he reproduced, except in full, NC Wastewater 12
NC Drinking Water 37712 without the written consent of Pace Analytical Services, Inc. NC Drinking Water 37706
SC Environmental 99030 Sc 99006
FL NELAP E87648 FL NELAP E87627
Page: 3 of 5

anF /: tal j6cat •a
vrvn&u, pacelabs corn
t
QC Batch: 180366
QC Batch Method: EPA 350.1
Associated Lab Samples:
927973925
METHOD BLANK: 927998229
Associated Lab Samples: 927973925
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Huntersville, NC 28078
Phone: [phone]
Fax [phone]
QUALITY CONTROL DATA
Lab Project Number: 92137397
Client Project ID: SS STATESVILLE 50400
Analysis Method: EPA 350.1
Analysis Description: Ammonia
Blank Reporting
Parameter Units Result Limit Footnotes
Nitrogen, Ammonia mg/l ND 0.10
LABORATORY CONTROL SAMPLE: 927998237
Spike LCS LCS
Parameter Units Conc. Result % Rec Footnotes
Nitrogen, Ammonia mg/l 5.000 4.890 98
MATRIX SPIKE: 927998252
927957688 Spike MS MS
Parameter Units Result Conc. Result % Rec Footnotes
Nitrogen, Ammonia mg/l 0 5.000 4.980 100
SAMPLE DUPLICATE: 927998245
Parameter Units
Nitrogen, Ammonia mg/l
Date: 02/16/07
927957688 DUP
Result Result RPD Footnotes
ND ND NC
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS Charlotte Certification IDs
NC wastewater 40 This report shall not he reproduced, except in full, NC Wastewater 12
NC Drinking Water 37712 without the written consent of Pace Analytical Services, Inc. NC Drinking Water 37706
SC Environmental 99030 «, SC 99006
FL NELAP E87648 FL NELAP E87627
Page: 4 of 5

unrtcpacelaUs.com
t
QUALITY CONTROL DATA PARAMETER FOOTNOTES
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Huntersville, NC 28078
Phone: [phone]
Fax [phone]
Lab Project Number: 92137397
Client Project ID: SS STATESVILLE 50400
Consistent with EPA guidelines, unrounded concentrations are displayed and have been used to calculate % Rec and RPD values.
LCS(D) Laboratory Control Sample (Duplicate)
MS(D) Matrix Spike (Duplicate)
DUP Sample Duplicate
ND Not detected at or above adjusted reporting limit
NC Not Calculable
J Estimated concentration above the adjusted method detection limit and below the adjusted reporting limit
MDL Adjusted Method Detection Limit
RPD Relative Percent Difference
Date: 02/16/07
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS
NO Wastewater 40 This report shall not be reproduced, except in full,
NO Drinking Water 37712 without the written consent of Pace Analytical Services, Inc.
SC Environmental 99030
FL NELAP E87648
Aida&
Charlotte Certification IDs
NO Wastewater
12
NO Drinking Water
37706
SC
99006
FL NELAP
E87627
Page: 5 of 5

77ace Analvticalm
CHAIN. _ _-CuSTOuy / Analytical Request Document
The Chain -of -Custody is a LEGAL DOCUMENT. All relevant fields must be completed accurately.
Page: of1048168
ection A
Section B
Section C
squired Client Information:
Required Project Information:
Invoice Information:
y✓^ y r , C� Re ort To: a
Attention:
REGULATORY AGENCY
Idles
U
Copy To:
Company Name:
NPDES
❑ GROUNDWATER
❑ DRINKING WATER
❑ UST
❑ RCRA
❑ Other
. c� �
�c
Address:
nail To: Purchase Order No.;
Pace Quote Reference:
❑GA OIL ❑IN
❑MI ❑MN 5kNC
%•t n UJ1)o�^
❑OH ❑SC ❑ WI
❑OTHER
` t4 Q 8 q �5 Q 1 go Project acme:
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Pace Project Manager:
)quested Due Date/TAT :' Project bars
7 �C�
Pace Profile #: ���(� I
Filtered (YIN)
Requested
Valid Matrix Codes
Section D Required Client lnformation MATRIX CODE
o_
7»
Preservatives
Analysis:
y
SAMPLE ID
DRINKING WATER DW W
WATER VvVrW p
WASTE WATER WVII O
w0
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DATE TIME DATE TIME
N z v m m o$
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DATE Signed (MM7 DD I YY)
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Oct-90
Oct-91
Oct-92
Oct-93
Oct-94
Oct-95
Oct-96
Oct-97
Oct-98
v
CD
Oct-99
Oct-00
Oct-01
Oct-02
Oct-03
Oct-04
Oct-05
Oct-06
Oct-07
Z
X
r
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300
250
-' 200
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c
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w
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—� K65W6"B"
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Date

II®
300
MIJ
6 200
8
C
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50
Nitrate Plot for K65W6 "E"
K65W6"E"
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Linear (2L Standard)
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300
250
J
200
c
c
0
cu
L_
c 150
0
0
U
m
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300
250
J
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Nitrate Plot for K66W7 "K"
2L Standard
Linear (2L Standard)
Log.
j 2L Standard
ti
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O O
O O O O
Date

300
250
J
200
c
c
0
0
150
m
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v
m
100
KA
50
Nitrate Plot for K65W7 "L"
co
0
O U U
O O O
Date
2L Standard
Linear (2L Standard)
— —Log. K65W7"L"
0
t
U
O

Michael F. Easley, Governor
William G. Ross Jr., Secretary
�0 py North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
AQUIFER PROTECTION SECTION
February 19, 2007
Southern States Cooperative, Inc.
P.O. Box 26234
Richmond, Virginia 23260
Attention: Vance Dann
RE: Acknowledgement of Receipt & Review
Annual Monitoring Report 2006
Southern States (Wayside Estates)
GW Incident No. 5038
Site Priority Rank: 90B
Iredell County
Dear Mr. Dann:
On January 25, 2007, 1 received the above -referenced monitoring report. I have reviewed the report
and it has been placed on file with the Aquifer Protection Section at the Mooresville Regional Office.
.Should you have any questions, please feel free to contact me at [phone] extension 2182 or by
email at amber. lindon(cDncmail.net.
Sincerely, l
Amber R. Lindon, P.G.
Hydrogeologist
cc: Thomas Dunham, P.G. — Duncklee & Dunham, PO Box 33366, Raleigh, NC 27636
Division of Water Quality / Aquifer Protection Section / Mooresville Regional Office
610 East Center Avenue, Suite 301, Mooresville, NC 28115
Phone
One
[phone] Fax: [phone] NOTt11CaT011lla
Internet: www.ncwaterouality.org �aturall�

p EOWE
JAN 2 5 -2001
NC DENR MRO
DWQ -Aquifer Protection
Annual ,Ground Water Monitoring .Report
Southern States Cooperative, Inc.
Statesville Fertilizer Plant
Statesville, North Carolina
January 23, 2007
Prepared For
Mr. Vance Dann
Southern States Cooperative, Inc.
Post Office Box 26234
Richmond, Virginia 23260
[phone] -
Submitted To
Ms. Amber Lindon .
North Carolina Department of Environment and Natural Resources
Division of Water Quality, Aquifer Protection Branch
Mooresville Regional Office
919 North Main Street
Mooresville, North Carolina 28115
Prepared By
Duncklee & Dunham, P.C.
511-102 Keisler Drive
Cary, North Carolina 27511
DUNCKLEE & DUNHAM, P.C.

D
& DUNHAMUNCKLEE
January 23, 2007
Ms. Amber Lindon
North Carolina Department of Environment and Natural Resources
Division of Water Quality, Aquifer Protection Branch
Mooresville Regional Office
919 North Main Street
Mooresville, North Carolina 28115
Reference: 2006 Annual Ground Water Monitoring Report..
Southern States Cooperative, Inc.
Statesville Fertilizer Plant, Statesville, North Carolina
Ground Water Incident Number 5038
Duncklee & Dunham Job No. 50200
Dear Ms. Lindon:
ENVIRONMENTAL CONSULTANTS
511 KEISLER DRIVE — SUITE 102
CARY, NORTH CAROLINA 27518
OFFICE: (919) 858 — 9898
FACSWILE: (919) 858 — 9899
D 0 W E
JAN 2 5 2007
-]
NC DENR MRO
DWQ - Aguiter Protection
As requested by Southern States Cooperative, Inc. (Southern States), Duncklee & Dunham, P.C. is
pleased to submit this 2006Annual Groundwater Monitoring. Report for the above referenced site. This
report discusses the technical services performed, describes field procedures, and presents the results of
ground water analytical testing.
If you have any questions or require additional information, please do not hesitate to contact Mr. Tom
Dunham at [phone] ([e-mail]) or Mr. Vance Dann of Southern States
at [phone] ([e-mail]).
Sincerely,
DUNCKLEE & DUNHAM, P.C.A'RoR
i
0, 0 ......,. ` ••i
Thomas ZSum; P.G. L 3 ?
Senior. Geologists
7Sen ' r Peer Review
avid L. Duncklee, P.G.
Senior Hydrogeologist
c: Mr. Vance Dann — Southern States Cooperative, Inc. (2)
P:\Southern States\Statesville Fertilizer - 50200\Reports12006 annual groundwater monitoring report-06198.doe
MAILING ADDRESS — POST OFFICE BOX 33366 — RALEIGH, NORTH CAROLINA 27636

Table of Contents
IIntroduction......................................:............................................................... I
1.1 Site Description......... .............................. ..........::......... .....:.......................1
1.2 Summary of Remedial Actions............................................................ .... ... 1
2 Ground Water Monitoring....................................................................................2
2.1 Methodology................................................................................................. 2
2.2, Analytical Results.......................:................a..................... ...I.... ..............
2.2.1 April 2006 Sampling Event.................................:.................................... 2
2.2.2 October 2006 Sampling................................................................ .. .. .3
2.3 Hydrogeologic Conditions........................................................................ 4
3 2006 Remediation System Maintenance and Remediation Activities.............................
...........................4
4 Conclusions.........................................................:.............................................4
5 Recommendations ................................... :........................................................ :................................ 5
Figures
Figure Title
1 Site Location Topographic,Map
2 Site Plan
3 Nitrate Results with Shallow Plume Isoconcentration (April 2006)
4 Nitrate Results with Shallow Plume Isoconcentration (October 2006)
5 Shallow Ground Water Contour Map (April 2006)
6 Shallow -Ground Water Contour Map (October 2006)
Table
1
2
3
Appendix
A
Tables
Title
Top of Casing and Ground Water Elevations
Summary of Field Parameters Measurements
Historical Ground Water Analytical Results
Appendices -
Title
April 2006 and October 2006 Laboratory Analytical Reports
DUNCKL.EE & DUNHAM, P.C.

Annual Ground Water Monitoring Report
Southern States Cooperative, Inc.
Statesville Fertilizer Plant
Statesville, North Carolina
January 23, 2007
1 Introduction
1.1 Site Description
The Southern States Cooperative, Inc. (Southern States) fertilizer plant .is located at 2582 Salisbury
Highway (US Highway 70) approximately six miles east of Statesville, North Carolina (see Figure 1).
The site contains a fertilizer manufacturing building, an office building, several small support buildings,
several aboveground storage tanks., and a railroad spur (see Figure 2). The site is utilized for the
manufacturing, storage, and distribution of liquid and dry fertilizers.
The property is bordered to the north by US Highway 70, commercially developed parcels to the -east, and
an undeveloped parcel of land to the west. The North Carolina Department of Transportation (NCDOT)
is currently constructing a, bypass to US Highway 70 through the southern portion of the site. The bypass
will separate approximately 13 acres from the main property. -
1.2 Summary of Remedial Actions
Ground water at the site has been impacted from a release of liquid ammonia nitrate from a former
surface. impoundment. Assessment activities have generally determined the extent of contaminants in the
ground water. In an effort to reduce the levels of ammonia and nitrate in the ground water, three recovery
wells were installed at the site-(RW-2, RW-4 and RW-5). Due to the construction of the bypass, recovery
well RW-4 was.abandoned and replaced by RW-6. In addition, kW-5 was reportedly taken off-line due
to low flow.
NCDOT construction activities severed the power and water supply lines from RW-2 to the treatment
system in late February 2006. Due to the 30 foot high road bed above the power and supply lines at the
time the lines were severed, repairs have not been made and EW-2 remains off-line. Duncklee &
Dunham has been working with NCDOT for their construction of an access road to the southern portion
of the property and for the installation of a horizontal boring/conduit beneath the bypass to reinstall the
power and water lines to RW-2. According to the NCDOT, the access road is scheduled for construction
in the spring of 2007.
Current remedial activities include the removal of ground water from recovery well RW-6. Water is
- piped to a holding tank where the pH is adjusted for discharge to Forth Creek in compliance with the
National Pollutant Discharge Elimination System (NPDES) Permit obtained for this system. The system
operates annually from October to March. The system is shut down from May through October due to a
-- seasonal drop in the water table.
ij; ■� DUNCKLEE & DUNHAM, P.C.
�II�I `ssJ�

Southern States Cooperative, Inc.'- Statesville Fertilizer Plant
Annual Groundwater Monitoring Report
January 23, 2007
Page 2 of 5
i In accordance with the January 1994 Corrective Action Plan (CAP), ground water samples are collected
- from monitoring wells biannually as part of the annual sampling period. In the Ground'Water Monitoring
Report dated December 2, 2005, it was requested to. amend the CAP to exclude nitrites from the sampling
and analysis plan. In a correspondence dated January 6, 2005, the North Carolina Department of
Environment and Natural Resources (DENR) agreed to remove nitrites from the monitoring plan.
2 Ground Water Monitoring
l 2.1 Methodology
Semiannual sampling events were performed on April 25 and 26, and October 23 and 24, 2006. Ground
water samples were collected in K65W6"A", K65W6"B", K65W6"E", K65W7"D", K65W7"F",
K65W7"G", K65W7"J", K65W7"K", and K65WTV' (See Figure 2). Monitoring wells K65W67'D" and
K65W7"C" were dry during the 2006 sampling period and were therefore not sampled.
Prior to purging and sampling; the depth to water .was recorded at each monitoring well using a
decontaminated electric water level probe (see Table 1). A decontaminated two-inch submersible electric
PVC pump and new polyethylene tubing (changed between wells) were used to purge and withdraw the
samples from each well. The ground water samples were collected immediately after purging.
All samples were collected in" laboratory -provided containers, labeled and logged onto a chain-of=custody
j form, and transported to the analytical laboratory.in an insulated cooler filled.with ice. The samples were
submitted to Pace Analytical Services (Pace) in Huntersville, North Carolina and analyzed for nitrate
according to EPA Method 353.2 and ammonia as N (ammonia) according to EPA Method 350.1.
Field measurements for dissolved oxygen (DO), oxidation reduction potential (ORP), pH, temperature,
turbidity and conductivity were also collected. The field measurements collected. during each sampling
event is summarized in Table 2.
2.2 Analytical Results
Data collected during the 2006 sampling period showed only minor fluctuations in nitrate and ammonia
concentrations. The April 2006 and October 2006 ground water analytical results are summarized in the
following sections and table below (see following page). The attached Table"3 includes the current and
historical ground water data for each well. Copies of the current laboratory analytical reports are include_ d
in Appendix A.
2.2.1 April 2006 Analytical Results
During the April 2006 sampling event, analytical data show nitrate at concentrations exceeding the North
Carolina 2L ground water standard of 10 mg/L in all of the monitoring wells sampled, except
downgradient well K65W7"D The highest concentrations of nitrate were in core wells K65W6"A",
K65W6'E", K65W7"J", K65W7K7, and K65WTV', ranging from 100 mg/L in K65W7K" (parts per
million, ppm) to 160 mg/L in K65W7"A" The downgradient wells, K65W7"C", K65W7"G", and
K65WTV' showed nitrate concentrations significantly lower than the core wells at a range of 16 mg/L in
K65W7"G" to 31 mg/L in K65W77".
-� � DUNCKLEE & DUNHAM, P.C.

i�
Southern States Cooperative, Inc. — Statesville Fertilizer Plant
Annual Groundwater Monitoring Report
January 23, 2007
Page'3 of 5
Similar to the nitrate results, ammonia concentrations during the April 2006 sampling event showed only
-' minor fluctuations compared to previous testing results (see Table 3). Among the wells sampled,.core
wells K65W7"K" and K65WTV' and downgradient well K65WTT"..showed ammonia concentrations
above the laboratory detection limits ranging.from 0.12 mg/L in K65W7"F" to 7.4 mg/L in K65W7"L".
_I Analytical data showed ammonia below laboratory detection limits in all other wells sampled.
2.2.2 October. 2006 Analytical Results
During -the October-2006 sampling event, analytical data showed nitrate at concentrations exceeding the
North Carolina 2L. ground water standard of 10 mg/L in all of the monitoring wells sampled. The highest
concentrations of nitrates continued to be in core wells K65W6"A", K65W6"E", K65W7"J'.', K65W7"K",
and K65W7"L" ranging from 120 mg/L in K65W7"K" and K65W7"L" to 180 mg/L in K65W7")
` The downgradient wells, K65W7"C' , K65W7"G", and K65W7"F", showed nitrate concentrations just
- above the 2L standard, ranging from 15 mg/L in K65W7"F" to 29 mg/L in K65W7".G". Downgradient
well K65W7"D" showed nitrate concentrations above the 2L standard for the first time since August 1990
at a concentration of 15 mg/L.
Lj
Ammonia was detected in three_ core wells and three downgradient wells during this sampling event.
Overall the -ammonia concentrations increased slightly from the previous sampling event. Most notable,
core well K65W7"K" went from 3.7 mg/L in April to 11 mg/L in October.
Sample ID
Nitrate
Ammonia as N
April 06
Oct 06
April,06
Oct 06 .
K65W6"A"
160
150
<0.1
0.14
K65W6" B"
28 .
23
<0.1
<0.1
K65W6"D"
NS
NS
NS
NS
K65W6"E"
140
150
<0.1
<0.10
K65W7"C" .
NS
NS
NS
NS
K65W7"D"
1.1
15
<0.1
1.1
K65W7"F"
31
15
0.12
f.1
K65W7G"
16
29
<0.1
4.1
K65W7"J"
150
180
<0.1
<0.10
K65W7"K"
100
120
3.7
11
K65WTV'
130
120.
7.4
11
2L Standard
10
Results in mg/L (parts per million) Bold = Exceeds Endpoint NS = No Sample
r- DUNCKLEE & DUNHAM, P.C.

Southern States Cooperative, Inc. — Statesville Fertilizer Plant
Annual Groundwater Monitoring Report
January 23, 2007
Page 4 of 5
j 2.3 Hydrogeologic Conditions
The water levels collected on April 26, 2006 and October 23, 2006 (see Table 1) were used to create a
shallow ground water contour -map for each date (see Figures 5 and 6). The April and October 2006 data .
shows shallow ground .water flow to the south-southwest in response to an approximate hydraulic
gradient- of 0.05 ftlft. The shallow ground water flow direction for the 200.6 sampling period is consistent
with data previously collected.
3 2006 Remediation System Operation and Maintenance Activities
Electrical problems caused the treatment system to go off-line between December 22, 2005 and January
26, 2006. The problem was diagnosed and corrected. On February 17, 2006, an NCDOT contractor
severed .the power and water lines from EW-2 to the treatment system. Due to backflow from RW-6 to
the severed water lines, the system was not restarted before the scheduled seasonal shutdown at the end of
April 2006.
The treatment system was activated on November 1, 2006 for the winter season. The system began
operation approximately one month late due to repairs and recalibration of the flow meter. RW-6 is the
only extraction well currently pumping. According to the NPDES permit, site visits are conducted
weekly to insure the system is functioning properly and to monitor the treatment system effluent.
4 Conclusions
Duncklee & Dunham and Southern States have obtained an access agreement from an adjoining property
owner for the construction of the access road to RW-2. Duncklee & Dunham has also obtained bids from
contractors.to bore beneath the bypass to reconnect RW-2 to the treatment system and obtained a contract
from the NCDOT to complete the work. The NCDOT reports the access road will not be completed until
the spring of 2007.
Duncklee & Dunham concludes the following for the 2006 reporting period.
�_ ` • The overall magnitude and extent of the nitrate plume in 2006 has changed significantly from
the 2005 monitoring period.
• The April 2006 monitoring data shows nitrate concentrations above the 2L standard in all the
wells sampled with the exception of downgradient well K65W7"D". The highest nitrate
concentrations detected during this sampling event were in the core wells. Overall, the nitrate
concentrations decreased in a majority of the wells sampled compared to the previous sampling
event.
• The October 2006 monitoring data shows nitrate concentrations above the 2L standards in all the
wells sampled. The highest concentrations continue to be detected in the core wells. Overall the
nitrate concentrations were similar to the April 2006 sampling event with the most significant
change being an increase in nitrate from 1.1 mg/L to 15 mg/L in downgradient well K65W7"D".
r DUNCKLEE & DUNHAM, P.C.

Southern States Cooperative, Inc. Statesville Fertilizer Plant
Annual. Groundwater Monitoring Report
January 23, 2007
Page 5 of 5
• Ammonia concentrations from April and October 2006 showed minor fluctuations in comparison
to the 2005 sampling period. During the 2006 monitoring period, the highest concentrations of
ammonia were detected in core wells K65W7'W' and K65WT L'.
• , The ground water contour maps are consistent with previous data. -
5 Recommendations
Based on the information presented above, Duncklee &Dunham recommends the following regarding the
groundwater remediation system.
• - Continued operation of the treatment system and ground water extraction from RW-6.
• Perform semi- annual,groundwater sampling events in April and October 2007.
Evaluate RW-5 with regards to well depth, past flow rates, and condition of the pump. Perform
repairs necessary to get RW-5 back online if feasible.
Duncklee & Dunham will continue to work with the NCDOT to get the access road installed and
reconnect RW-2 to the treatment system when feasible.
DUNCKLEE & DUNHAM, P.C.

DUNCKLEE & DUNHAM, P.C.
ENVIRONMENTAL CONSULTANTS
1 511 KEISLER DRIVE - SUITE 102
CARY. NORTH CAROLINA 27511
1 Source Man: U.S.G.S. Statesville East 7.5-Minute Ouadranzle. North is Towards Top ofPaze.
Approximate Scale: Title: Site Location Map
1" = 2000' USGS Topographic Map
Figure: Project:
1 Southern States Fertilizer Plant
Statesville, North Carolina

Table 1. Top of Casing and Ground Water Elevations
Southern States Cooperative, Inc. - Statesville Fertilizer Plant
Well ID
Top of Casing
Elevation
Date
Depth to Water
Ground Water Elevation
K65W6"A"
864.52
4-25-2006
22.21
842.31
10-23-2006
22.43
842.09
K65W6"B"
-
_ 871.55
4-25-2006
10-23-2006
22.51
22.76
849.04
848.79
K65W6"D"
849.37
4-25-2006
DRY
_
10-23-2006
DRY
K65W6„E„
864.89
4-25-2006
22.47....................._...........
...... _...........................--842.42.................. _--._._
...._._..... ........._._ --..
_..__ _
10-23-2006
_
22.69
842.20
K65W7"C"
_......._....._.._..__.._._.....__........-._......._._
809.72
................... -----.......... ---
4-25-2006
................... _........... -_.--......... _........
10-23-2006
DRY
_-_ ._....._......
DRY
K65W7"D"
800.64_
4-25-2006
9.50
7_91.14 _
_
10-23-2006
9.74
790.90
K65W7"F"
_ .........-- ...............__.
796.15
_............._..........._....._---.................._-..........................._.._.__._.._......_........._.
4-25-2006
10-23-2006
11.49
_.._____..................................._..._
11.78
784.66
__._........ _.................. ..................
784.37
K65W7"G"
795.98
4-25-2006
11.29
784.69
10-23-2006
11.39
784.59
K65W7"J"
851.25
725-2006
41.32
_ 809.93
10-23-2006
41.51
809.74
K65W7"K'
_..-_............_.._._..............
852.30
-........................................__..._.........................._......................................_._....................................
4-25-2006 -
10-23-2006
42.02
----...............................................................__....._.....
42.30
810.28
_.....------...__........____.................................--.._.._......._.
810.00
K65W7"L"
851.14
4-25-2006
41.23
809.91
-�
10-23-2006
41.54
809.60
All measurements in feet
NM = Not Measured
DUNCKLEE & DUNHAM, P.C.

Table 2. Summary of Field Parameter Measurements
Southern States Cooperative, Inc. - Statesville Fertilizer Plant
Wells
Date
pH
Standard
Temp.
Celsius
Conductivity
µs
ORP
my
DO
mg/L
K65W6A
4/26/2006
5.28
16.5
99.9
163
1.60
10/24/2006
5.98
13.6
632
97
2.12
K65W6B
4/26/2006
4.23
16.8
1340
291
6.41
10/24/2006
4.61
13.5
1178
301
6.03
K65W6D
4/25/2006
NM/Dry
NM/Dry
NM/Dry
NM/Dry
NM/Dry
10/23/2006
NM/Dry
NM/Dry
NM/Dry
NM/Dry
NM/Dry
K65W6E
4/26/2006
5.86
16.7
676
103
2.50
10/24/2006
5.32
13.2
999
109
1.98
K65W7C
4/25/2006
NM/Dry
NM/Dry
NM/Dry
NM/Dry
NM/Dry
10/23/2006.
NMMry
NM/Dry
NM/Dry
NM/Dry
NM/Dry
K65W713
4/25/2006
4.87
13.5
99.9
262
1.86
10/23/2006
4.92
13.50
104
258
1.71
K65W7F
4/25/2006
5.71
14.4
97
187
0.67
10/23/2006
5.63
14.4
99.9
197
0.89
K65W7G
4/25/2006
5.89
12.4
222
155
8.94
10/23/2006
5.94
13.7
196
178
7.63
K65W7J
4/26/2006
5.21
15.3
432
98
0.22
10/24/2006
5.36
12.9
382
93
0.18
K65W7K
4/25/2006
5.81
15.8
195
125
0.17
10/23/2006
5.72
13.4
192
114
0.04
K65W7L
4/25/2006
5.78
15.7
194
144
0.14
10/23/2006
5.64
13.2
171
136
0
BlanK cell =A14 not sampled
P:ISouthern StateslStatesville Fertilizer-50100EYcellField Parameter Measurements

Table 3. HISTORICAL GROUND WATER ANALYTICAL RESULTS
Well
Identification
Sample
Date
Nitrate
(-)(-911)
Nitrite
K65W6"A"
2/13/1990
370
NA
8/1/1990
NS
NA
1/22/1992
252
0.19
4/16/1992
360
< 0.01
7/27/1992
360
0.08
10/21/1992
311
0.62
2/10/1993
30
< 0.01
4/8/1993
210
< 0.01
8/3/1993
340
0.096
10/7/1993
330
0.092
3/8/1994
250
0.11
9/27/1994
260
0.10
8/2/1995
250
NA
11/8/1995
180
0.085
2/8/1996
240
0.086
5/9/1996
260
0.12
11/15/1996
210
< 0.01
5/20/1997
106
0.130
11/18/1997
243
0.0770
5/19/1998
121
0.120
11/19/1998
199
0.104
3/30/1999
236
0.105
11/3/1999
240
< 0.01
3/28/2000
220
< 0.01
11/16/2000
200
< 0.01
4/5/2001
180
0.050
10/24/2001
190
< 0.01
3/29/2002
235
< 0.50
10/18/2002
170
<0.10
5/2/2003
140
< 2.7
10/17/2003
84
< 0.050
4/16/2004
200
NA
10/28/2004
150
<0.10
7/18/2005
170
<0.10
10/27/2005
190
<0.10
4/26/2006
160
<0.10
10/23/2006
150
0.140
NOTES
1. NS = Not Sampled
2. NA = Not Analyzed
3. mg/1= milligrams per liter
K65W6"A"
300
m
E 250
c
ii 200
c 150
a
V
0 100
U
50
z 0
O N t+I ? N f0 IOD O> O N M R N f0
m m m m m m O� m rn m o 0 0 o O o O
u ii 0 u 0 0 u 0 0 u u ii 0
O 0 0 0 0 O O O O O O O O O O O O
Date
Page 1 of 11

Table 3. HISTORICAL GROUND WATER ANALYTICAL RESULTS
Well
Identification
Sample
Date
Nitrate
m
Nitrite
m
K65W6'B"
2/13/1990
22
NA
8/1/1990
NS
NA
1/22/1992
22
< 0.01
4/16/1992
15
< 0.01
7/27/1992
26
< 0.01
10/21/1992
16
< 0.01
2/9-10/93
7.6
< 0.01
4/8/1993
6.8
< 0.01
8/3/1993
28
< 0.01
10/7/1993
29
< 0.01
3/8/1994
19
< 0.01
9/27/1994
18
< 0.01
8/2/1995
NS
NS
11/8/1995
NS
NS
2/8/1996
NS
NS
5/9/1996
NS
NS
11/15/1996
NS
NS
5/20/1997
NS
NS
11/18/1997
NS
NS
5/19/1998
NS
NS
11/19/1998
NS
NS
3/30/1999
89.4
< 0.01
11/3/1999
140
< 0.01
3/28/2000
NS/DRY
NS/DRY
11/16/2000
NS/DRY
NS/DRY
4/5/2001
NS/DRY
NS/DRY
10/24/2001
78
< 0.010
3/29/2002
NS/DRY
NS/DRY
10/18/2002
NS/DRY
NS/DRY
5/2/2003
92
< 0.010
10/17/2003
40
< 0.050
4/16/2004
41
NA
10/28/2004
44
<0.10
7/18/2005
33
<0.10
10/27/2005
35
<0.10
4/26/2006
28
<0.10
10/23/2006
23
<0.10
NOTES
1. NS = Not Sampled
2. NA = Not Analyzed
3. mg/l = milligrams per liter
K65W6 "B"
300
E 250
e
0 200
N
� 150
m
o 100
U
a
� 50
s
z 0
rn rn rn rn rn m `8i m rn m o 0 0 0 � o 0
u 0 S 0 L u S U u o 0 0 u 0 u
O O O O O O 0 0 O O O O O O O O O
Date
Page 2 of 11

Table 3. HISTORICAL GROUND WATER ANALYTICAL RESULTS
Well
Identification
Sample
Date
Nitrate
m
Nitrite
m
K65W6"D"
2/13/1990
NS
NA
8/1/1990
0.63
NA
1/22/1992
0.17
< 0.01
4/16/1992
NS
NS
7/27/1992
NS
NS
10/21/1992
NS
NS
2/9-10/93
0.25
< 0.01
4/8/1993
NS
NS
8/3/1993
NS
NS
10/7/1993
NS
NS
3/8/1994
NS
NS
9/27/1994
NS
NS
8/2/1995
NS
NS
11/8/1995
NS
NS
2/8/1996
NS
NS
5/9/1996
NS
NS
11/15/1996
NS
NS
5/20/1997
NS
NS
11/18/1997
NS
NS
5/19/1998
NS
NS
11/19/1998
NS
NS
3/30/1999
NS/DRY
NS/DRY
11/3/1999
NS/DRY
NS/DRY
3/28/2000
NS/DRY
NS/DRY
11/16/2000
NS/DRY
NS/DRY
4/5/2001
NS/DRY
NS/DRY
10/24/2001
NS/DRY
NS/DRY
3/29/2002
NS/DRY
NS/DRY
10/18/2002
NS/DRY
NS/DRY
5/2/2003
NS/DRY
NS/DRY
10/17/2003
NS/DRY
NS/DRY
4/16/2004
NS/DRY
NS/DRY
10/28/2004
NS/DRY
NS/DRY
7/18/2005
NS/DRY
NS/DRY
10/27/2005
NS/DRY
NS/DRY
4/26/2006
NS/DRY
NS/DRY
10/23/2006
NS/DRY
NS/DRY
NOTES
1. NS = Not Sampled
2. NA = Not Analyzed _
3. mg/l = milligrams per liter
K65W6"D"
0.7
0.6
c 0.5
a
0.4
c
m
� 0.3
0
U
d 0.2
m
Z 0.1
0
1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006
Date
Page 3 of 11

1
Table 3. HISTORICAL GROUND WATER ANALYTICAL RESULTS
Well
Identification
Sample
Date
Nitrate
m
Nitrite
m
K65W6"E"
2/13/1990
NS
NS
8/1/1990
7.3
NA
1/22/1992
37
< 0.01
4/16/1992
NS
NS
7/27/1992
NS
NS
10/21/1992
NS
NS
2/9-10/93
27
< 0.01
4/8/1993
NS
NS
8/3/1993
NS
NS
10/7/1993
NS
NS
3/8/1994
NS
NS
9/27/1994
NS
NS
8/2/1995
4.4
NA
11/8/1995
5.0
< 0.01
2/8/1996
56
< 0.01
5/9/1996
7.9
< 0.01
11/15/1996
8.5
< 0.01
5/20/1997
11.7
< 0.01
11/18/1997
24.1
<0.01
5/19/1998
30.9
< 0.01
11/19/1998
49.9
< 0.01
3/30/1999
50.4
< 0.01
11/3/1999
56
< 0.01
3/28/2000
67
< 0.01
11/16/2000
68
< 0.01
4/5/2001
62
< 0.01
10/24/2001
78
< 0.10
3/29/2002
81
< 0.50
10/18/2002
76
< 0.10
5/2/2003
62
< 0.010
10/17/2003
60
<0.050
4/16/2004
90
NA
10/28/2004
100
<0.10
7/18/2005
120
<0.10
10/27/2005
150
<0.10
4/26/2006
140
<0.10
10/23/2006
150
<0.10
NOTES
1. NS = Not Sampled
2. NA = Not Analyzed
3. mg/l = milligrams per liter
K65W6"E"
300
E 250
c
c 200
0
150
a
100
U
d
� 50
z
0
m rn rn m m m �i m rn m o 0 0 4 � o 0
8 Fa Fi Tea Yi S
O O O O O O O O O O O O O O O O O
Date
Page 4 of 11

Table 3. MSTORICAL GROUND WATER ANALYTICAL RESULTS
Well
Identification
Sample
Date
Nitrate
m
Nitrite
m
K65W7"A"
2/13/1990
53
NA
8/1/1990
NS
NS
K65W7"A"
1/22/1992
23
0.17
Abandoned8/18/2004
4/16/1992
29
<0.01
and replaced with
7/27/1992
31
0.15
K65W7"J"
10/21/1992
37
0.21
2/9-10/93
34
0.33
4/8/1993
52
0.42
8/3/1993
66
0.74
10/7/1993
80
1.0
3/8/1994
75
0.58
9/27/1994
140
0.90
8/2/1995
210
NA
11/8/1995
15
0.62
2/8/1996
190
0.50
5/9/1996
190
0.32
11/15/1996
140
0.30
5/20/1997
106
0.570
11/18/1997
165
0.172
5/19/1998
109
0.344
11/19/1998
NS/DRY
NS/DRY
3/30/1999
NS/DRY
NS/DRY
11/3/1999
46
< 0.01
3/28/2000
NS/DRY
NS/DRY
11/16/2000
170
< 0.01
4/5/2001
NS/DRY
NS/DRY
10/24/2001
170
< 0.10
3/29/2002
NS/DRY
NS/DRY
10/18/2002
NS/DRY
NS/DRY
5/2/2003
230
< 0.010
10/17/2003
14
< 0.050
4/16/2004
19
NA
K65W7 "7"
10/28/2004
100
0.3
7/18/2005
140
<0.10
10/27/2005
74
<0.10
4/26/20006
150
<0.10
10/23/2006
180
<0.10
NOTES
1. NS = Not Sampled
2. NA = Not Analyzed
3. mg/1= milligrams per liter
K65W "A"
250
E 200
c
c
° 150
w
c
°
c 100
°
U
d
50
z
0
g0 g'` Oti g� gp, O5 g6 g'� g0 gg 00 O'� Off. O^� gd 06 00
Foy Qey F F0� Fey Q°,d Fey F0� 1< Fe,C Fey 1<61 Feo Feo �0,d fed fed
Date
Page 5 of 11

Table 3. HISTORICAL GROUND WATER ANALYTICAL RESULTS
Well
Identification
Sample
Date
Nitrate
m
Nitrite
m
K65W7"C"
2/13/1990
93
NA
8/1/1990
NS
NS
1/22/1992
130
0.057
4/16/1992
NS
NS
7/27/1992
NS
NS
10/21/1992
NS
NS
2/10/1993
13
< 0.01
4/8/1993
NS
NS
8/3/1993
NS
NS
10/7/1993
NS
NS
3/8/1994
NS
NS
9/27/1994
NS
NS
8/2/1995
NS
NS
11/8/1995
NS
NS
2/8/1996
NS
NS
5/9/1996
NS
NS
11/15/1996
NS/DRY
NS/DRY
5/20/1997
NS/DRY
NS/DRY
11/18/1997
NS/DRY
NS/DRY
5/19/1998
NS/DRY
NS/DRY
11/19/1998
NS/DRY
NS/DRY
3/30/1999
NS/DRY
NS/DRY
11/3/1999
NS/DRY
NS/DRY
3/28/2000
NS/DRY
NS/DRY
11/16/2000
NS/DRY
NS/DRY
4/5/2001
NS/DRY
NS/DRY
10/24/2001
NS/DRY
NS/DRY
3/29/2002
NS/DRY
NS/DRY
10/18/2002
NS/DRY
NS/DRY
5/2/2003
NS/DRY
NS/DRY
10/17/2003
82
< 0.050
4/16/2004
NS/DRY
NS/DRY
10/28/2004
NS
NS
7/18/2005
33
<0.10
10/27/2005
53
<0.10
4/25/2006
NS/DRY
NS/DRY
10/23/2006
NS/DRY
NS/DRY
NOTES
1. NS = Not Sampled
2. NA = Not Analyzed
3. mg/1= milligrams per liter
K65W7" C'
140
120
E
100
0
m 80
c
u 60
0
V 40
m
A
Z 20
0
90 ON Oti cp 41 50 06 c1 00 00 00 O� Oti O`5 D°' Oh
�mv imp• �0p �sv �00 0, Imo 0, "o fed �0c �eC fed �0C �md �md
Date
Page 6 of 11

Table 3. HISTORICAL GROUND WATER ANALYTICAL RESULTS
Well
Identification
Sample
Date
Nitrate
m
Nitrite
(m
K65W7D"
2/13/1990
NS
NS
8/1/1990
11
NA
1/22/1992
2.0
0.054
4/16/1992
NS
NS
7/27/1992
NS
NS
10/21/1992
NS
NS
2/9-10/93
0.57
0.10
4/8/1993
NS
NS
8/3/1993
NS
NS
10/7/1993
NS
NS
3/8/1994
NS
NS
9/27/1994
NS
NS
8/2/1995
NS
NS
11/8/1995
NS
NS
2/8/1996
NS
NS
5/9/1996
NS
NS
11/15/1996
NS
NS
5/20/1997
NS/DRY
NS/DRY
11/18/1997
NS/DRY
NS/DRY
5/19/1998
NS
NS
11/19/1998
NS
NS
3/30/1999
0.775
0.051
11/3/1999
< 2.0
< 0.01
3/28/2000
1
< 0.01
11/16/2000
< 2.0
< 0.01
4/5/2001
1.1
< 0.01
10/24/2001
<0.10
< 0.01
3/29/2002
1.1
< 0.01
10/18/2002
2.4
<0.10
5/2/2003
1.4
< 0.010
10/17/2003
< 0.050
< 0.050
4/16/2004
1.3
NA
10/28/2004
2.4
<0.10
7/18/2005
0.48
<0.10
10/27/2005
2.2
<0.10
4/25/2006
1.1
<0.10
10/23/2006
15
1.1
NOTES
1. NS = Not Sampled
2. NA = Not Analyzed
3. mg/1= milligrams per liter
K65W "D"
16
14
c 12
0 10
e 8
u
cc 6-
4-
2-
0
o N M V N �O fm O N M a N fD
m m m m m rn m rn m rn o 0 0 0 0 o O
m of of m of of o m m in of a of of m � �
¢ ¢ ¢ ¢ ¢ ¢ ¢ ¢ ¢ ¢ ¢ ¢ ¢ ¢ ¢ ¢ ¢
Date
Page 7 of 11

Table 3. HISTORICAL GROUND WATER ANALYTICAL RESULTS
Well
Identification
Sample
Date
Nitrate
m
Nitrite
m
K65W7"F"
2/13/1990
NS
NS
8/l/1990
99
NA
1/22/1992
100
0.055
4/16/1992
109
< 0.01
7/27/1992
79
< 0.01
10/21/1992
79
< 0.01
2/9-10/93
110
< 0.01
4/8/1993
100
< 0.01
8/3/1993
100
< 0.01
10/7/1993
96
< 0.01
3/8/1994
1.6
< 0.01
9/27/1994
94
< 0.01
8/2/1995
NS
NS
11/8/1995
NS
NS
2/8/1996
150
< 0.01
5/9/1996
6.1
< 0.01
11/15/1996
NS/DRY
NS/DRY
5/20/1997
NS/DRY
NS/DRY
11/18/1997
NS/DRY
NS/DRY
5/19/1998
NS/DRY
NS/DRY
11/19/1998
NS/DRY
NS/DRY
3/30/1999
NS/DRY
NS/DRY
11/3/1999
NS/DRY
NS/DRY
3/28/2000
5.1
< 0.01
11/16/2000
0.52
<0.01
4/5/2001
NS/DRY
NS/DRY
10/24/2001
20
<0.10
3/29/2002
33
< 0.50
10/18/2002
17
<0.10
5/2/2003
3
< 0.010
10/17/2003
21
< 0.050
4/16/2004
8.5
NA
10/28/2004
<0.10
<0.10
7/18/2005
20
<0.10
10/27/2005
NS
NS
4/26/2006
31
0.12
10/23/2006
15
1.1
NOTES
1. NS = Not Sampled
2. NA = Not Analyzed
3. mg/1= milligrams per liter
K65W7"F
160
140
c 120
100
e0
d
60
U
v 40
z 20
0
m rn o� m m m m rn m o 0 0 0 0 0
rn
Q ¢ ¢ Q 6 ¢ Q Q Q Q Q Q 6 Q Q Q 6
Date
Page 8 of 11

Table 3. HISTORICAL GROUND WATER ANALYTICAL RESULTS
Well
Identification
Sample
Date
Nitrate
m
Nitrite
m
K65W7"G"
2/13/1990
NS
NS
8/1/1990
1.7
NA
1/22/1992
1.9
0.055
4/16/1992
NS
NS
7/27/1992
NS
NS
10/21/1992
NS
NS
2/9-10/93
2.6
< 0.01
4/8/1993
NS
NS
8/3/1993
NS
NS
10/7/1993
NS
NS
3/8/1994
NS
NS
9/27/1994
NS
NS
8/2/1995
NS
NS
11/8/1995
NS
NS
2/8/1996
3.5
< 0.01
5/9/1996
NS
NS
11/15/1996
NS/DRY
NS/DRY
5/20/1997
NS/DRY
NS/DRY
11/18/1997
NS/DRY
NS/DRY
5/19/1998
NS/DRY
NS/DRY
11/19/1998
NS/DRY
NS/DRY
3/30/1999
NS/DRY
NS/DRY
11/3/1999
2.9
< 0.01
3/28/2000
NS/DRY
NS/DRY
11/16/2000
3.6
< 0.01
4/5/2001
NS/DRY
NS/DRY
10/24/2001
2.8
<0.10
3/29/2002
31
< 1.0
10/18/2002
32
<0.10
5/2/2003
1.3
< 0.010
10/17/2003
0.4
< 0.050
4/16/2004
NS/DRY
NS/DRY
10/28/2004
4.4
<0.10
7/18/2005
1.7
<0.10
10/27/2005
NS
NS
4/25/2006
16
<0.10
10/23/2006
29
4.1
NOTES
1. NS = Not Sampled
2. NA = Not Analyzed
3. mg/l = milligrams per liter
K65W "G"
35
m 30
E
25
0
20
c
u 15
0
m 10
z 5
0
OI
9 999
O O O O
A m
> W
J
Q Q Q Q
Q Q Q Q Q Q
Q Q Q Q Q Q Q
Date
Page 9 of 11

Table 3. HISTORICAL GROUND WATER ANALYTICAL RESULTS
Well
Identification
Sample
Date
Nitrate
m
Nitrite
m
K65W7"H"
2/13/1990
NS
NS
8/1/1990
280
NA
K65W7"1i"
1/22/1992
160
0.059
Abandoned on 8/18/200
4/16/1992
160
0.106
and replaced with
7/27/1992
150
0.06
K65W7"K"
10/21/1992
150
0.07
2/9-10/93
12
0.067
4/8/1993
74
0.17
8/3/1993
100
0.13
10/7/1993
89
0.12
3/8/1994
84
0.05
9/27/1994
79
< 0.01
8/2/1995
58
NA
11/8/1995
42
0.05
2/8/1996
61
0.060
5/9/1996
53
0.058
11/15/1996
39
< 0.01
5/20/1997
16.6
0.100
11/18/1997
47.3
< 0.01
5/19/1998
33.5
< 0.01
11/19/1998
42.6
< 0.01
3/30/1999
47.8
< 0.01
11/3/1999
47
< 0.01
3/28/2000
44.0
< 0.01
11/16/2000
48
< 0.01
4/5/2001
42
0.020
10/24/2001
41
< 0.10
3/29/2002
48
< 0.50
10/18/2002
45
< 0.10
5/2/2003
52
0.054
10/17/2003
44
< 0.050
4/16/2004
57
NA
K65W7"K"
10/28/2004
81
0.78
7/18/2005
89
0.83
10/27/2005
190
0.19
4/25/2006
100
3.7
10/23/2006
120
11
NOTES
1. NS = Not Sampled
2. NA = Not Analyzed
3. mg/1= milligrams per liter
K65WT'H"
300
E 250
c 200
e 150
u
c
V 100
d
50
Z
0 p
QP O� pi O� T O O O O O
A T A
Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q
Date
Page 10 of 11

Table 3. HISTORICAL GROUND WATER ANALYTICAL RESULTS
Well
Identification
Sample
Date
Nitrate
m
Nitrite
m
K65W7"I"
2/13/1990
NS
NS
8/1/1990
NS
NS
K65W7"I"
1/22/1992
37
0.78
Abandoned on 8/14/2004
4/16/1992
NS
NS
and replaced with
7/27/1992
NS
NS
K65W7"L"
10/21/1992
NS
NS
2/9-10/93
2.9
9.0
4/8/1993
NS
NS
8/3/1993
NS
NS
10/7/1993
NS
NS
3/8/1994
NS
NS
9/27/1994
NS
NS
8/2/1995
27
NA
11/8/1995
19
< 0.01
2/8/1996
27
< 0.01
5/9/1996
27
11/15/1996
21
< 0.01
5/20/1997
46.6
< 0.01
11/18/1997
27.8
< 0.01
5/19/1998
16.1
< 0.01
11/19/1998
25.5
< 0.01
3/30/1999
18.3
< 0.01
11/3/1999
24
< 0.01
3/28/2000
14.0
< 0.01
11/16/2000
22
0.11
4/5/2001
11
< 0.01
10/24/2001
15
< 0.01
3/29/2002
12
< 0.01
10/18/2002
13
< 0.10
5/2/2003
11
< 0.010
10/17/2003
11
< 0.050
4/16/2004
12
NA
K65WTV'
10/28/2004
22
<0.10
7/18/2005
98
0.1
10/27/2005
110
<0.10
4/25/2006
130
7.4
10/23/2006
120
11
NOTES
1. NS = Not Sampled
2. NA = Not Analyzed
3. mg/l = milligrams per liter
K65WN1"
140
m 120
E
100
0
80
c
60
0
0 40
r 20
Z
0
m m rn m m m rn m m �i m m m m T T o 0 0 0 0 0 0 0 g o o
Date
P:ISouthem StateslStat-ille FertllizerlF-AD&D Historical Data with Chart
Page 11 of 11

(�.5acieAnalXicaf`
wtnv. pacelabs.com
April 27, 2006
Mr. Chris Fay
Duncklee & Dunham
PO Box 33366
Raleigh, NC 27636
RE: Lab Project Number: 92117961
Client Project ID: SS Statesville Pert
Dear Mr. Fay:
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Hunters ville, NC28078
Phone: [phone]
Fax., 704.875.9091
Pace Analytical Services, Inc.
2225 Riverside Drive
Asheville, NC 28804
Phone: [phone]
Fax- 828.252.4618
Enclosed are the analytical results for sample(s) received by the laboratory on April 25, 2006. Results reported
herein conform to the most current NELAC standards, where applicable, unless otherwise narrated in the body of
the report.
Inorganic Wet Chemistry and Metals Analyses were performed at our Pace Asheville laboratory and Organic testing
was performed at our Pace Charlotte laboratory unless otherwise footnoted.
If you have any questions concerning this report please feel free to contact me.
Sincerely,
0�1�-
Richard Swartz
[e-mail]
Project Manager
Enclosures
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS Charlotte Certification IDs
NO Wastewater 40 This report shall not be reproduced, except in full, NO Wastewater 12
NO Drinking Water 37712 without the written consent of Pace Analytical Services, Inc. NO Drinking Water 37706
SC Environmental 99030 '$c 99006
FL NELAP E87648 ��` FL NELAP E87627

aceAnalyttical
6vinv. pacelabs. coin
Lab Sample No: 926906975
Client Sample ID: K65W7D
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Huntersville, NC 28078
Phone: [phone]
Fax: 704.875,9091
Pace Analytical Services, Inc.
2225 Riverside Drive
Asheville, NC 28804
Phone: [phone]
Fax. [phone]
Lab Project Number: 92117961
Client Project ID: SS Statesville Fert
Project Sample Number: 92117961-001 Date Collected: 04/25/06 10:05
Matrix: Water Date Received: 04/25/06 15:10
Parameters Results Units Report Limit Analyzed By CAS No. Qual ReaLmt
Wet Chemistry
Ammonia Method: EPA 350.1
Nitrogen, Ammonia ND mg/l 0.10 04/26/06 11:38 BMF 7727-37-9
48 Hour NO3 / NO2 / NOX
Nitrate as N
Date: 04/27/06
Method: EPA 353.2
1.1 mg/l 0.10 04/25/06 22:32 CD1
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS Charlotte Certification IDs
NC Wastewater 40 This report shall not be reproduced, except in full, NC Wastewater 12
NC Drinking Water 37712 without the written consent of Pace Analytical Services, Inc. NC Drinking Water 37706
SC Environmental 99030 $C 99006
FL NELAP E87648 FL NELAP E87627
"1"s
Page: 1 of 10

(�5a'cie Analytical "
wtvw. pacelabs.com
Lab Sample No: 926906983
Client Sample ID: X65W7F
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Huntersville, NC 28078
Phone: [phone]
Fax. [phone]
Pace Analytical Services, Inc.
2225 Riverside Drive
Asheville, NC 28804
Phone: [phone]
Fax. [phone]
Lab Project Number: 92117961
Client Project ID: SS Statesville Fert
Project Sample Number: 92117961-002 Date Collected: 04/25/06 11:14
Matrix: Water Date Received: 04/25/06 15:10
Parameters Results Units Report Limit Analyzed By CAS No. Oual ReaLmt
Wet Chemistry
Ammonia Method: SPA 350.1
Nitrogen, Ammonia 0.12 mg/l 0.10 04/26/06 11:38 BMF 7727-37-9
48 Hour NO3 / NO2 / NOX
Nitrate as N
Date: 04/27/06
Method: EPA 353.2
31. mg/l 1.0 04/25/06 22:32 CD1
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS Charlotte Certification IDS
NC Wastewater 40 This report shall not he reproduced, except in full, NC Wastewater 12
NG Drinking Water 3771.2 without the written consent of Pace Analytical Services, Inc. NC Drinking Water 37706
SC Environmental 99030 SC 99006
FL NELAP E87648t s FL NELAP E87627
Page: 2 of 10

;aneAna1j4Jlca1""
wivm.pacelabs.com
Lab Sample No: 926906991
Client Sample ID: X65W7G
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Huntersville, NC 28078
Phone: [phone]
Fax: [phone]
Pace Analytical Services, Inc.
2225 Riverside Drive
Asheville, NC 28804
Phone: [phone]
Fax. [phone]
Lab Project Number: 92117961
Client Project ID: SS Statesville Fert
Project Sample Number: 92117961-003 Date Collected: 04/25/06 11:32
Matrix: Water Date Received: 04/25/06 15:10
Parameters Results Units Report Limit Analyzed By CAS No. Oual ReaLmt
Wet Chemistry
Ammonia Method: SPA 350.1
Nitrogen, Ammonia ND mg/l 0.10 04/26/06 11:38 BMF 7727-37-9
48 Hour NO3 / NO2 / NOX
Nitrate as N
Date: 04/27/06
Method: SPA 353.2
16. mg/l 0.20 04/25/06 22:32 CD1
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS Charlotte Certification IDs
NO Wastewater 40 This report shall not he reproduced, except in full, NO Wastewater 12
NO Drinking Water 37712 without the written consent of Pace Analytical Services, Inc. NO Drinking Water 37706
SC Environmental 99030 $C 99006
FL NELAP E87648�,t�'�,�,,.. FL NELAP E87627
�11.1�CL�Y
Page: 3 of 10

aceAnalj cal "o
vnnv. pacelabs.com
Pace Analytical Services, Inc.
9800 KinceyAvenue, Suite 100
Huntersville, NC 28078
Phone: [phone]
Fax: [phone]
Pace Analytical Services, Inc.
2225 Riverside Drive
Asheville, NC 28804
Phone: [phone]
Fax. • 828.252.4618
Lab Project Number: 92117961
Client Project ID: SS Statesville Fert
Lab Sample No: 926907007
Project Sample
Number: 92117961-004
Date Collected: 04/25/06 13:42
Client Sample ID: K65W7L
Matrix: Water
Date Received: 04/25/06 15:10
Parameters
Results
Units
Report Limit
Analyzed By
CAS No. Oual ReaLmt
Wet Chemistry
Ammonia
Method: EPA
350.1
Nitrogen, Ammonia
7.4
mg/l
1.0
04/26/06 12:51 BMF
7727-37-9
48 Hour NO3 / NO2 / NOS
Method: EPA
353.2
Nitrate as N
130
mg/l
2.0
04/25/06 22:32 CD1
Date: 04/27/06
Asheville Certification IDs
REPORT OF LABORATORY ANALYSIS
NC Wastewater 40
This report shall not he reproduced, except in full,
NC Drinking Water 37712
without the written consent of Pace Analytical Servlces, Inc.
SC Environmental 99030
FL NELAP E87648'�`
1Jt�lb.l
Charlotte Certification IDs
NC Wastewater 12
NC Drinking Water 37706
$C 99006
FL NELAP E87627
Page: 4 of 10

(�5a'neAnalj4ical`
tn,v, .v.pacelabs.com
Lab Sample No: 926907015
Client Sample ID: X65W7X
Pace Analytical Services, Inc.
9800 KinceyAvenue, Suite 100
Huntersvilie, NC 28078
Phone: [phone]
Fax: [phone]
Pace Analytical Services, Inc.
2225 Riverside Drive
Asheville, NC 28804
Phone: [phone]
Fax. • 828.252.4618
Lab Project Number: 92117961
Client Project ID: SS Statesville Fert
Project Sample Number: 92117961-005 Date Collected: 04/25/06 15:08
Matrix: Water Date Received: 04/25/06 15:10
Parameters Results Units Report Limit Analyzed By CAS No. Qual RegLmt
Wet Chemistry
Ammonia Method: EPA 350.1
Nitrogen, Ammonia 3.7 mg/l 1.0 04/26/06 12:51 BMF 7727-37-9
48 Hour NO3 / NO2 / NOX
Nitrate as N
Date: 04/27/06
Method: EPA 353.2
100 mg/l 2.0 04/25/06 22:32 CD1
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS Charlotte Certification IDs
NO Wastewater 40 This report shall not he reproduced, except in full, NO Wastewater 12
NO Drinking Water 37712 without the written consent of Pace Analytical Services, Inc. NO Drinking Water 37706
SC Environmental 99030 $C 99006
FL NELAP E87648 ��` FL NELAP E87627
Page: 5 of 10

aceAnalXical
vrtnv.pacelabs.com
PARAMETER FOOTNOTES
Method 9071E modified to use ASE.
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Huntersville, NC 28078
Phone: [phone]
Fax:[phone]
Pace Analytical Services, Inc.
2225 Riverside Drive
Asheville, NC 28804
Phone: [phone]
Fax., 828.252.4618
Lab Project Number: 92117961
Client Project ID: SS Statesville Fart
All pH, Free Chlorine, Total Chlorine and Ferrous Iron analyses conducted outside of SPA recommended immediate
hold time.
Depending on the moisture content the PRLs can be elevated for all soil samples reported on a dry weight basis.
2-Chloroethyl vinyl ether has been shown to degrade in the presence of acid.
ND Not detected at or above adjusted reporting limit
NC Not Calculable
J Estimated concentration above the adjusted method detection limit and below the adjusted reporting limit
MDL Adjusted Method Detection -Limit
Date: 04/27/06
Asheville Certification IN
REPORT OF LABORATORY ANALYSIS
NC Wastewater 40
NC Drinking Water V712
This report shall not he reproduced, except in full,
without the written consent of Pace Analytical Services, Inc.
SC Environmental 99030�
FL NELAP E87648
'
Charlotte Certification IDS
NC Wastewater 12
NC Drinking Water 37706
SC 99006
FL NELAP E87627
Page: 6 of 10

(�5a'cieAnalj&af"
wn%:v.pace/abs.com
QC Batch: 155561
QC Batch Method: EPA 353.2
Associated Lab Samples:
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Nuntersville, NC 28078
Phone: [phone]
Fax. [phone]
QUALITY CONTROL DATA
Pace Analytical Services, Inc.
2225 Riverside Drive
Asheville, NC 28804
Phone: [phone]
Fax: [phone]
Lab Project Number: 92117961
Client Project ID: SS Statesville Fert
Analysis Method: SPA 353.2
Analysis Description: 48 Hour NO3 / NO2 / NOX
926906975 926906983 926906991 926907007 926907015
METHOD BLANK: 926908484
Associated
Lab Samples:
926906975
926906983
926906991 926907007 926907015
Blank
Reporting
Parameter
Units
Result
Limit Footnotes
Nitrate as
N
mg/1
ND
0.10
LABORATORY
CONTROL SAMPLE:
926908492
Spike
LCS LCS
Parameter
Units
Conc.
Result Rec Footnotes
Nitrate as
N
mg/l
5.000
4.980 100
MATRIX SPIKE: 926908500
926905043
Spike MS MS
Parameter
Units
Result
Conc. Result Rec Footnotes
Nitrate as
N
mg/l
4.220
5.000 9.390 103
SAMPLE DUPLICATE: 926908518
Parameter Units
Nitrate as N mg/1
Date: 04/27/06
926905050 DUP
Result Result RPD Footnotes
1.000 1.000 1
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS Charlotte Certification IDs
NO Wastewater 40 This report shall not he reproduced, except in full, NO Wastewater 12
NO Drinking Water 37712 without the written consent of Pace Analytical Services, Inc. NO Drinking Water 37706
SC Environmental 95030 SC 99006
FL NELAP E87648 ,{{��1�1' �f`, FL NELAP E87627
5LLI�dCt�..l`'s
Page: 7 of 10

i
Pace Ana&ffcal Services, Inc.
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
2225 Riverside Dive
aceAllalytical.w
Huntersville, NC 28078
Phone: [phone]
Asheville, NC 28804
Phone: [phone]
MIM pacelabs.com
Fax [phone]
Fax [phone]
QUALITY CONTROL DATA .
_
Lab Project Number: 92117961
Client Project ID: SS Statesville Fert
QC Batch:.155580 q
Analysis Method: EPA.350.1
QC Batch Method: EPA 350.1
Analysio.Description:, Ammonia
Associated Lab Samples:
926906975
926906983 926906991
METHOD BLANK: 926909151-
Associated Lab Samples: 926906975
926906983 926906991
Blank - Reporting
Parameter
units
Result Limit Footnotes
Nitrogen, Ammonia
mg/1
ND 0.10 .
LABORATORY CONTROL SAMPLE: 926909169
-
Spike LCS LCS
Parameter
Units
Conc. Result Rec Footnotes
Nitrogen, Ammonia
mg/1
1.000 0.9170 92
MATRIX SPIKE: 926909177
926896382 Spike MS. MS
Parameter
Units
Result Cone. Result Rec Footnotes
Nitrogen, Ammonia
mg/1
0.07630 1.000 0.8351 76
SAMPLE DUPLICATE: 926909185
926904269 DIIP
Parameter
Units
Result Result RPD Footnotes
Nitrogen, Ammonia
j
i
mg/l
6.000 6.100 1
i
I
Date: 04/27/06
Page: 8 of 10 -
Asheville Certification IDs
NO Wastewater 40
NCDrinking Water 9771.2
SC Environmental 99030
FL NELAP E87648
REPORT OF LABORATORY ANALYSIS Charlotte Certification IDs
This report shall not he reproduced, except in full, NO Wastewater 12
without the written consent of Pace Analytical Services, Inc. NO Drinking Water 37706
$C 90006
y FL NELAP E87627

aceAnaljdical }"
vinnvpacelabs.com
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Nuntersville, NC 28078
Phone: [phone]
Fax- 704.875,9091
Pace Analytical Services, Inc.
2225 Riverside Drive
Asheville, NC 28804
Phone: [phone]
Fax. [phone]
QUALITY CONTROL DATA
Lab Project Number: 92117961
Client Project ID: SS Statesville Fert
QC Batch: 155581 Analysis Method: SPA 350.1
QC Batch Method: SPA 350.1 Analysis Description: Ammonia
Associated Lab Samples: 926907007 926907015
METHOD BLANK: 926909193
Associated Lab Samples:
926907007 926907015
Blank
Reporting
Parameter
Units
Result
Limit Footnotes
Nitrogen, Ammonia
mg/l
ND
0.10 .
LABORATORY CONTROL SAMPLE:
926909201
Spike
LCS LCS
Parameter
Units
Conc.
Result Rec Footnotes
Nitrogen, Ammonia
mg/l
1.000
0.9403 94
MATRIX SPIKE: 926909219
926907007
Spike MS MS
Parameter
Units
Result
Conc. Result Rec Footnotes
Nitrogen, Ammonia
mg/l
7.429
1.000 8.172 74 1
SAMPLE DUPLICATE: 926909227
926907015 DIIP
Parameter Units Result Result RPD Footnotes
Nitrogen, Ammonia mg/l 3.700 3.600 1
Date: 04/27/06
Asheville Certification IDs
NO Wastewater 40
NO Drinking Water 37712
SC Environmental 99030
FL NELAP E87648
REPORT OF LABORATORY ANALYSIS
This report shall not he reproduced, except in full,
without the written consent of Pace Analytical Servloes, Inc.
otte Certificati
NO Wastewater 12
NO Drinking Water 37706
S.0 99006-
FL NELAP E87627
Page: 9 of 10

Pace Analytical. Services, Inc: Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100 2225 Riverside Drive
2a ,w Huntersville, NC 28078 Asheville, NC 28804
Phone: [phone] Phone: [phone]
m%v.pacelabs.com Fax. [phone] fax [phone]
Lab Project Number: '92117961
Client Project ID: SS Statesville Fart
QUALITY CONTROL DATA PARAMETER FOOTNOTES
Consistent with SPA guidelines, unrounded concentrations are displayed and have been used to calculate % Rea and RPD values.
i
LCS(D) Laboratory Control Sample (Duplicate)
MS(D) Matrix Spike (Duplicate)
DUP Sample Duplicate
ND Not detected at or above adjusted reporting limit
NC Not Calculable
J Estimated concentration above the adjusted method detection limit and below. the adjusted.reporting limit
MDL Adjusted Method Detection Limit
RFD Relative Percent Difference .
[11 The spike recovery was outside acceptance limits for the MS and /or MSD due to matrix interference. The LCS
and/or LCSD were within acceptance limits showing that the laboratory is in control and the data is
acceptable.
i
Date: 04/27/06 Page: 10 of 10
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS Charlotte Certification IDs
-- NO Wastewater 40 This report shall not be reproduced, except in full, NO Wastewater 12
NO Drinking Water 9771.2 without the written consent of Pace Analytical Services, Inc. NC Drinking Water 37706
SC Environmental 99030 �c SC 99006
FL NELAP E87648 FL NELAP E87627

Z2f� 'a AnnIll ifinnl
t;mAIN-uF-cuSTUOY, .,.J,alyrical Kequest Document
The Chain -of -Custody is a LEGAL P6CUMENT. All relevant fields must be completed accurately.
I uvv I Ofrury r.svcu
i
Pager of
Section A
Section B
Section-
0998522
Required Client Information: .
Required Project Information:
- Invoice Information;-' .
Company t + l
Report To:
Attention:
- • -AGENCY
❑ NPDES
I�(3ROUND WATER
❑DRINKING WATER
Addres
Copy To:
Comppny Natne:
,�
:J ❑ UST
❑ RCRA
❑ Other
dress:
M
TIME]
t\l"
SITE LOCATION
❑IN
❑MI ❑MNOCC
Email To: yl i j Purchase Order No.:
••� V1R T'• W�. l.0 tA.
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Pace Quote Reference:
DOH ❑ SC ❑ WI
❑ OTHER
Phopg F
Project f t
Pace Project Manager:
I
Filtered (YIN)
Requested. Due Date/TAT: _
Project Number:
Pace Profile #:
1 +
Requested
Valid Maft Codes
Section D Required Client Information MATRIX CODE
d
0 0
PreservaBves
Analysis:
rs
SAMPLE ID
DRIN19NG WATER DW
WASTEWATER WW
w
U
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a- o
U U
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One Character per bo
PRODUCT P
SOIU OLID SI,
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(A-Z, 0-9 / -)..
�R E R
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a.g
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U
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-
Yaa Pace Project Number
W Samples IDs MUST BE UNIQ1JE
~ p
OTHER OT
0
DATE
TIME DATE TIME
¢
j = 2 Z Z
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TISSUE TS
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Lab LD
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Additional Comments:
•
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SAMPLE CONDITION
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SAMPLER
NAME • SIGNATURE
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PRINT Name of S ER: ..
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SEE REVERSE SIDE FOR INSTRUCTIONS
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acmnalytical °
www.pacelabs.com
May 01, 2006
Mr. Chris Fay
Duncklee & Dunham
PO Box 33366
Raleigh, NC 27636
RE: Lab Project Number: 92118055
Client Project ID: SS Statesville Fer
Dear Mr. Fay:
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Huntersville, NC 28078
Phone: [phone]
Fax., 704.875.9091
Pace Analytical Services, Inc.
2225 Riverside Drive
Asheville, NC 28804
Phone: [phone]
Fax., 828.252.4618
Enclosed are the analytical results for sample(s) received by the laboratory on April 26, 2006. Results reported
herein conform to the most current NELAC standards, where applicable, unless otherwise narrated in the body of
the report.
Inorganic Wet Chemistry and Metals Analyses were performed at our Pace Asheville laboratory and Organic testing
was performed at our Pace Charlotte laboratory unless otherwise footnoted.
If you have any questions concerning this report please feel free to contact me.
[e-mail]
Project Manager
Enclosures
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS
NC Wastewater 40 This report shall not be reproduced, except in full,
NO Drinking Water 37712 without the written consent of Pace Analytical Services, Inc.
SC 99030
FL NELAP E87648 E° N ACC UF�9i
Charlotte Certification IDs
NO Wastewater 12
NO Drinking Water 37706
SC 99006
FL NELAP E87627

Analytical °
www.naceiabs.com
Lab Sample No: 926912379
Client Sample ID: K65W7J
Parameters
Wet Chemistry
Ammonia
Nitrogen, Ammonia
48 Hour NO3 / NO2 / NOX
Nitrate as N
Comments : c
Date: 05/01/06
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Huntersville, NC 28078
Phone: [phone]
Fax, 704.875.9091
Pace Analytical Services, Inc.
2225 Riverside Drive
Asheville, NC 28804
Phone: [phone]
Fax., 828.252.4618
Lab Project Number:
92118055
Client Project ID:
SS Statesville Fer
Project Sample
Number: 92118055-001 Date Collected: 04/26/06 09:24
Matrix: Water
Date Received: 04/26/06 12:40
Results
Units
Report Limit
Analyzed By
CAS No. Qual RegLmt
Method: EPA
350.1
ND
mg/l
0.10
04/28/06 07:04 TMR
7727-37-9
Method: EPA
353.2
150
mg/l
5.0
04/26/06 22:10 CD1
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS
NC Wastewater 40 This report shall not be reproduced, except in full,
NC Drinking Water 37712
SC 99030 without the written consent of Pace Analytical Services, Inc.
FL NELAP E87648 N
a nei
Page: 1 of 8
Charlotte Certification IN
NC Wastewater 12
NC Drinking Water 37706
SC 99006
FL NELAP E87627

Analytical °
www.pacelahs.com
Lab Sample No: 926912387
Client Sample ID: K65W6B
Parameters
Wet Chemistry
Ammonia
Nitrogen, Ammonia
48 Hour NO3 / NO2 / NOX
Nitrate as N
Date: 05/01/06
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Huntersville, NC 28078
Phone: [phone]
Fax: [phone]
Pace Analytical Services, Inc.
2225 Riverside Drive
Asheville, NC 28804
Phone: [phone]
Fax: [phone]
Lab Project Number:
92118055
Client Project ID:
SS Statesville Fer
Project Sample
Number: 92118055-002 Date Collected: 04/26/06 09:50
Matrix: Water
Date Received: 04/26/06 12:40
Results
Units
Report Limit
Analyzed By
CAS No. Qual RegLmt
Method: EPA
350.1
ND
mg/l
0.10
04/28/06 07:04 TMR
7727-37-9
Method: EPA
353.2
28.
mg/l
0.50
04/26/06 22:10 CD1
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS
NC Wastewater 40 This report shall not be reproduced, except in full,
NC Drinking Water 37712 without the written consent of Pace Analytical Services, Inc.
SC 99030
FL NELAP E87648
elact.
Page: 2 of 8
Charlotte Certification IDs
NC Wastewater 12
NC Drinking Water 37706
SC 99006
FL NELAP E87627

Analytical °
www.pacelabs.com
Lab Sample No: 926912395
Client Sample ID: K65WBE
Parameters
Wet Chemistry
Ammonia
Nitrogen, Ammonia
48 Hour NO3 / NO2 / NOX
Nitrate as N
Date: 05/01/06
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Huntersville, NC 28078
Phone: [phone]
Fax: [phone]
Pace Analytical Services, Inc.
2225 Riverside Drive
Asheville, NC 28804
Phone: [phone]
Fax: [phone]
Lab Project Number:
92118055
Client Project ID:
SS Statesville Fer
Project Sample
Number: 92118055-003 Date Collected: 04/26/06 11:34
Matrix: Water
Date Received: 04/26/06 12:40
Results
Units
Report Limit
Analyzed By
CAS No. Qua] RegLmt
Method: EPA
350.1
ND
mg/l
0.10
04/28/06 07:04 TMR
7727-37.9
Method: EPA
353.2
140
mg/l
5.0
04/26/06 22:10 CD1
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS
NC Wastewater 40 This report shall not be reproduced, except in full,
NC Drinking Water 37712
SC 99030 without the written consent of Pace Analytical Services, Inc.
FL NELAP E87648
Tact-.
Page: 3 of 8
Charlotte Certification IDs
NC Wastewater 12
NC Drinking Water 37706
SC 99006
FL NELAP E87627

Analytical °
www.pacelabs.com
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Huntersville, NO 28078
Phone: [phone]
Fax: [phone]
Pace Analytical Services, Inc.
2225 Riverside Drive
Asheville, NO 28804
Phone: [phone]
Fax: [phone]
Lab Project Number:
92118055
Client Project ID:
SS Statesville Fer
Lab Sample No: 926912403
Project Sample
Number: 92118055-004 Date Collected: 04/26/06 12:17
Client Sample ID: K65W6A
Matrix: Water
Date Received: 04/26/06 12:40
Parameters
Results
Units
Report Limit
Analyzed By
CAS No. Qual RegLmt
Wet Chemistry
Ammonia
Method: EPA
350.1
Nitrogen, Ammonia
ND
mg/l
0.10
04/28/06 07:04 TMR
7727-37-9
48 Hour NO3 / NO2 / NOX
Method: EPA
353.2
Nitrate as N
160
mg/l
5.0
04/26/06 22:10 CD1
Date: 05/01/06
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS
NC Wastewater 40 This report shall not be reproduced, except in full,
NC Drinking Water 37712
SC 99030 without the written consent of Pace Analytical Services, Inc.
FL NELAP E87648 N "�
C�
Page: 4 of 8
Charlotte Certification IDs
NC Wastewater 12
NC Drinking Water 37706
SC 99006
FL NELAP E87627

aceAnalytical °
www.pacelabs.com
PARAMETER FOOTNOTES
Method 9071E modified to use ASE.
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Huntersville, NC 28078
Phone: [phone]
Fax., 704.875.9091
Pace Analytical Services, Inc.
2225 Riverside Drive
Asheville, NC 28804
Phone: [phone]
Fax: [phone]
Lab Project Number: 92118055
Client Project ID: SS Statesville Fer
All pH, Free Chlorine, Total Chlorine and Ferrous Iron analyses conducted outside of EPA recommended immediate
hold time.
Depending on the moisture content the PRLs can be elevated for all soil samples reported on a dry weight basis.
2-Chloroethyl vinyl ether has been shown to degrade in the presence of acid.
ND Not detected at or above adjusted reporting limit
NC Not Calculable
J Estimated concentration above the adjusted method detection limit and below the adjusted reporting limit
MDL Adjusted Method Detection Limit
Date: 05/01/06
Asheville Certification IN REPORT OF LABORATORY ANALYSIS
NC Wastewater 40. This report shall not be reproduced, except in full,
NC Drinking Water 37712 without the written consent of Pace Analytical Services, Inc.
SC 99030
FL NELAP E87648 N q0 -,
Page: 5 of 8
Charlotte Certification IN
NC Wastewater 12
NC Drinking Water 37706
SC 99006
FL NELAP E87627

Pace Analytical Services, Inc. Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100 2225 Riverside Drive
Huntersville, NC 28078 Asheville, NC 28804
Analytical o Phone: [phone] Phone: [phone]
Fax: [phone] Fax: [phone]
www.pacelabs.com QUALITY CONTROL DATA
Lab Project Number: 92118055
Client Project ID: SS Statesville Fer
QC Batch: 155666 Analysis Method: EPA 353.2
QC Batch Method: EPA 353.2 Analysis Description: 48 Hour NO3 / NO2 / NOX
Associated Lab Samples: 926912379 926912387 926912395 926912403
METHOD BLANK: 926914706
Associated Lab Samples: 926912379 926912387 926912395 926912403
Blank Reporting
Parameter Units Result Limit Footnotes
Nitrate as N mg/l NO 0.10
LABORATORY CONTROL SAMPLE: 926914714
Spike LCS LCS
Parameter Units Conc. Result Rec Footnotes
Nitrate as N mg/l 5.000 5.200 104
MATRIX SPIKE: 926914722
926912379 Spike MS MS
Parameter Units Result Conc. Result % Rec Footnotes
Nitrate as N mg/l 146.8 5.000 151.9 101 1
SAMPLE DUPLICATE: 926914730
Parameter Units
Nitrate as N mg/l
Date: 05/01/06
926912387 DUP
Result Result RPD Footnotes
28.00 28.00 1
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS
NC Wastewater 40 This report shall not be reproduced, except in full,
NC Drinking Water 37712
SC 99030 without the written consent of Pace Analytical Services, Inc.
FL NELAP E87648
act.
Page: 6 of 8
Charlotte Certification IDs
NC Wastewater 12
NC Drinking Water 37706
SC 99006
FL NELAP E87627

Pace Analytical Services, Inc. Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100 2225 Riverside Drive
Huntersville, NC 28078 Asheville, NC 28804
Analytical o Phone: [phone] Phone: [phone]
Fax: [phone] Far. 828.252.4618
www.pacelabs.com QUALITY CONTROL DATA
Lab Project Number: 92118055
Client Project ID: SS Statesville Fer
QC Batch: 155857 Analysis Method: EPA 350.1
QC Batch Method: EPA 350.1 Analysis Description: Ammonia
Associated Lab Samples: 926912379 926912387 926912395 926912403
METHOD BLANK: 926920844
Associated Lab Samples: 926912379 926912387 926912395 926912403
Blank Reporting
Parameter Units Result Limit Footnotes
Nitrogen, Ammonia mg/l NO 0.10
LABORATORY CONTROL SAMPLE: 926920851
Spike LCS LCS
Parameter Units Conc. Result % Rec Footnotes
Nitrogen, Ammonia mg/l 1.000 0.9577 96
MATRIX SPIKE: 926921404
926913633 Spike MS MS
Parameter Units Result Conc. Result % Rec Footnotes
Nitrogen, Ammonia mg/l 2.890 1.000 3.690 80
SAMPLE DUPLICATE: 926921412
Parameter Units
Nitrogen. Ammonia mg/l
Date: 05/01/06
926913690 DUP
Result Result RPD Footnotes
ND NO NC
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS
NO Wastewater 40 This report shall not be reproduced, except in full,
NO Drinking Water 37712 without the written consent of Pace Analytical Services, Inc.
SC 99030
FL NELAP E87648 N
0
- F
a nemc_=
Page: 7 of 8
Charlotte Certification IDs
NO Wastewater 12
NO Drinking Water 37706
SC 99006
FL NELAP E87627

ace Analytical °
www.pacelabs.com
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Nuntersville, NC 28078
Phone: [phone]
Fax: [phone]
Pace Analytical Services, Inc.
2225 Riverside Drive
Asheville, NC 28804
Phone: [phone]
Fax: [phone]
Lab Project Number: 92118055
Client Project ID: SS Statesville Fer
QUALITY CONTROL DATA PARAMETER FOOTNOTES
Consistent with EPA guidelines, unrounded concentrations are displayed and have been used to calculate % Rec and RPD values.
LCS(D) Laboratory Control Sample (Duplicate)
MS(D) Matrix Spike (Duplicate)
DUP Sample Duplicate
ND Not detected at or above adjusted reporting limit
NC Not Calculable
,l Estimated concentration above the adjusted method detection limit and below the adjusted reporting limit
MDL Adjusted Method Detection Limit
RPD Relative Percent Difference
Ill The spike recovery was outside acceptance limits for the MS and /or MSD due to matrix interference. The LCS
and/or LCSD were within acceptance limits showing that the laboratory is in control and the data is
acceptable.
Date: 05/01/06
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS
NC Wastewater 40 This report shall not be reproduced, except in full,
NC Drinking Water 37712 without the written consent of Pace Analytical Services, Inc.
SC 99030
FL NELAP E87648 N
0
a nla=
Page: 8 of 8
Charlotte Certification IDs
NC Wastewater 12
NC Drinking Water 37706
SC 99006
FL NELAP E87627

rP,An,alvtical
Ur A1N-Ur-Vua i vuv / Anaiyticai Kequest Document
The Chain -of -Custody is a LEGAL DOCUMENT. All relevant fields, must be completed accurately.
_-- J
Page: of
Section A
Section B
Section C
Required Client Information:
Required Project
Information:
Invoice Information:
7
Company,'- a, t4,�
Report To:: a ';
"'
Attention:
REGULATORY
AGENCY
a" 101 V1.1
AddressNp�*�p✓• w
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Copy To:
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Company Name:
❑ NPDES i ROUND WATER
❑DRINKING WATER
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❑ UST
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Project Number:
Pace Profile #: ,'
Requested
Section D Required Client Information
Valid Matrix Codes
MATRIX CODE
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5ac ie A na ly fica / ;u
wrrv.pacelabs.com
October 30, 2006
Mr. Chris Fay
Duncklee & Dunham
PO Box 33366
Raleigh, NC 27636
RE: Lab Project Number: 92130609
Client Project ID: SS STATESVILLE
Dear Mr. Fay:
- Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Nuntersville, NC 28078
Phone: [phone]
Fax: [phone]
Pace Analytical Services, Inc.
2225 Riverside Drive
Asheville, NC 28804
Phone: [phone]
Fax.• 828.252.4618
Enclosed are the analytical results for sample(s) received by the laboratory on October 24, 2006. Results
reported herein conform to the most current NELAC standards, where applicable, unless otherwise narrated in the
body of the report.
Inorganic Wet Chemistry and Metals Analyses were performed at our Pace Asheville laboratory and Organic testing
was performed at our Pace Charlotte laboratory unless otherwise footnoted.
If you have any questions concerning this report please feel free to contact me.
Sincerely,
0 �- '�4-
Richard Swartz
[e-mail]
[phone] ext. 237
Project Manager
Eaclospes
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS Charlotte Certification IDs
NO Wastewater 40 This report shall not be reproduced, except in full, NO Wastewater 12
NO Drinking Water 97712 without the written consent of Pace Analytical Services, Inc. NO Drinking Water 37706
SC Environmental 99030 \� SC 99006
FL NELAP E87648 FL CAP E87627

(�5a'cieAna/Xicaf'
www.pacelabs.com
Lab Sample No: 927591784
Client Sample ID: K65W7 'J'
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Huntersville, NC 28078
Phone: [phone]
Fax [phone]
Pace Analytical Services, Inc.
2225 Riverside Drive
Asheville, NC 28804
Phone: [phone]
Fax. • 828.252.4618
Lab Project Number: 92130609
Client Project ID: SS STATESVILLE
Project Sample Number: 92130609-001 Date Collected: 10/24/06 08:48
Matrix: Water Date Received: 10/24/06 13:00
Parameters Results Units Report Limit Analyzed By CAS No. Oual ReaLmt
Wet Chemistry
Ammonia Method: EPA 350.1
Nitrogen, Ammonia ND mg/l 0.10 10/25/06 18:26 NIW 7727-37-9
48 Hour NO3 / NO2 / NOX
Nitrate as N
Date: 10/30/06
Method: EPA 353.2
180 mg/l 10. 10/25/06 07:20 TMR
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS
NO Wastewater 40 This report shall not he reproduced, except in full,
NO Drinking Water 37712 without the written consent of Pace Analytical Services, Inc.
SC Environmental 99030
FL NELAP E87648
Charlotte Certification IDs
NO Wastewater 12
NO Drinking Water 37706
SC 99006
FL NELAP E87627
Page: 1 of 8

(�5a'ne Analjftal "
wi%v.pacelabs.com
Lab Sample No: 927591792
Client Sample ID: K65W6 'A'
Pace Analytical Services, Inc.
9800 KinceyAvenue, Suite 100
Huntersville, NC 28078
Phone: [phone]
Fax: [phone]
Pace Analytical Services, Inc.
2225 Riverside Drive
Asheville, NC 28804
Phone: [phone]
Fax. • 828.252.4618
Lab Project Number: 92130609
Client Project ID: SS STATESVILLE
Project Sample Number: 92130609-002 Date Collected: 10/24/06 09:52
Matrix: Water Date Received: 10/24/06 13:00
Parameters
Results
Units
Report Limit Analyzed By CAS No. Oual RegLmt
Wet Chemistry
Ammonia
Method: EPA
350.1
Nitrogen, Ammonia
0.14
mg/l
0.10 10/25/06 18:26 NIW 7727-37-9
48 Hour NO3 / NO2 / NOX
Method: EPA
353.2
Nitrate as N
150
mg/1
10. 10/25/06 07:20 TMR
Date: 10/30/06
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS Charlotte Certification IN
NC Wastewater 40 This report shall not he reproduced, except in full, NC Wastewater 12
NC Drinking Water 37712 without the written consent of Pace Analytical Services, Inc. NC Drinking Water 37706
SC Environmental 99030 $C 99006
FL NELAP E87648 ,(��,,�h,.�'% FL NELAP E87627
Page: 2 of 8

(�5a'neAnalXicaf'
Knrv.pacelabs.com
Lab Sample No: 927591800
Client Sample ID: K65W6 'E'
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Huntersville, NC 28078
Phone: 704,675.9092
Fax [phone]
Pace Analytical Services, Inc.
2225 Riverside Drive
Asheville, NC 28804
Phone: [phone]
Fax. • 828.252.4616
Lab Project Number: 92130609
Client Project ID: SS STATESVILLE
Project Sample Number: 92130609-003 Date Collected: 10/24/06 11:40
Matrix: Water Date Received: 10/24/06 13:00
Parameters Results Units Report Limit Analyzed By CAS No. Oual RevLmt
Wet Chemistry
Ammonia Method: EPA 350.1
Nitrogen, Ammonia ND mg/l 0.10 10/25/06 18:26 NIW 7727-37-9
48 Hour NO3 / NO2 / NOX
Nitrate as N
Date: 10/30/06
Method: EPA 353.2
150 mg/l 10. 10/25/06 07:20 TMR
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS Charlotte Certification IDs
NC Wastewater 40 This report shall not he reproduced, except in full, NC Wastewater 12
NC Drinking Water 37712 without the written consent of Pace Analytical Services, Inc. NC Drinking Water 37706
SC Environmental 99030 Sc 99006
••,,
FL NELAP E87648 FL NELAP E87627
5 l`
Page: 3 of 8

(���ace Analytical'"
tvt'Av.Pacelabs.com
Lab Sample No: 927591826
Client Sample ID: K65W6 'B'
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Huntersville, NC 28078
Phone: [phone]
Fax., 704.875.9091
Pace Analytical Services, Inc.
2225 Riverside Drive
Asheville, NC 28804
Phone: [phone]
Fax. • 828.252.4618
Lab Project Number: 92130609
Client Project ID: SS STATESVILLE
Project Sample Number: 92130609-004 . Date Collected: 10/24/06 12:18
Matrix: Water Date Received: 10/24/06 13:00
Parameters Results Units Report Limit Analyzed By CAS No. Oual ReaLmt
Wet Chemistry
Ammonia Method: SPA 350.1
Nitrogen, Ammonia ND mg/l 0.10 10/25/06 18:26 NIW 7727-37-9
48 Hour NO3 / H02 / NOX
Nitrate as N
Date: 10/30/06
Method: EPA 353.2
23. mg/l 0.50 10/25/06 07:20 TMR
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS Charlotte Certification IDs
NC Wastewater 40 This report shall not he reproduced, except in full, NC Wastewater 12
NC Drinking Water 97712 without the written consent of Pace Analytical Services, Inc. NC Drinking Water 37706
SC Environmental 99030 S.0 99006
...
FL NELAP E87648 ; �j ��;; j FL NELAP E87627
Page: 4 of 8

aceAnalyfical '
wtnv. pacelabs.com
PARAMETER FOOTNOTES
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Huntersville, NC 28078
Phone: [phone]
Fax: 704.875,9091
Pace Analytical Services, Inc.
2225 Riverside Drive
Asheville, NC 28804
Phone: [phone]
Fax. • 828.252.4618
Lab Project Number: 92130609
Client Project ID: SS STATESVILLE
Method 9071E modified to use ASH.
All pH, Free Chlorine, Total Chlorine and Ferrous Iron analyses conducted outside of EPA recommended immediate
hold time.
Depending on the moisture content the PRLs can be elevated for all soil samples reported on a dry weight basis.
2-Chloroethyl vinyl ether has been shown to degrade in the presence of acid.
ND Not detected at or above adjusted reporting limit
NC Not Calculable
J Estimated concentration above the adjusted method detection limit and below the adjusted reporting limit
MDL Adjusted Method Detection Limit
Date: 10/30/06
heville Certification IDs REPORT Of LABORATORY ANALYSIS
NO Wastewater 40 This report shall not he reproduced, except in full,
NO Drinking Water 37712 without the written consent of Pace Analytical Services, Inc.
SC Environmental 99*
FL NELAP E87648
Charlotte Certffication
IDs
NO Wastewater
12
NC Drinking Water
37706
$C
99006
FL NELAP
E87627
Page: 5 of 8

Pace Analytical Services, Inc. Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100 2225 Riverside Drive
(�5a'neAnalj6dal'"Hunters villa, NC28078 Asheville, NC28804
Phone: [phone] Phone: [phone]
vnAxpacelabs.com Fax: [phone] Fax.' 828.252.4618
QUALITY CONTROL DATA
Lab Project Number: 92130609
Client Project ID: SS STATESVILLE
QC Batch: 171147
Analysis Method: EPA 353.2
QC Batch Method: EPA 353.2
Analysis
Description: 48 Hour NO3 / NO2 / NOX
Associated Lab Samples:
927591784
927591792
927591800 927591826
METHOD BLANK: 927593996
Associated Lab Samples:
927591784
927591792
927591800 927591826
Blank
Reporting
Parameter
Units
Result
Limit Footnotes
Nitrate as N
mg/l
ND
0.10
LABORATORY CONTROL SAMPLE:
927594002
Spike
LCS LCS
Parameter
Units
Conc.
Result Rec Footnotes
Nitrate as N
mg/1
5.000
5.217 104
MATRIX SPIKE: 927594200
927586495
Spike MS MS
Parameter
Units
Result
Conc. Result % Rec Footnotes
Nitrate as N
mg/l
1.733
5.000 5.411 74
SAMPLE DUPLICATE: 927594218
Parameter Units
Nitrate as N mg/l
Date: 10/30/06
927586511 DUP
Result Result RPD Footnotes
0.2300 0.2200 1
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS Charlotte Certification IDs
NC Wastewater 40 This report shall not he reproduced, oxcept in full, NC Wastewater 12
NC Drinking Water 37712 without the written consent of Pace Analytical Services, Inc. NCDrinking Water 37706
SC Environmental 99�030 SC 99006
,•.
fL NELAP E87648 � FL NELAP E87627
Page: 6 of 8

aceAna1j&a1
winncpacelabs.com
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Huntersville, NC 28078
Phone: 704.875,9092
Fax [phone]
QUALITY CONTROL DATA
Pace Analytical Services, Inc.
2225 Riverside Drive
Asheville, NC 28804
Phone: [phone]
Fax. [phone]
Lab Project Number: 92130609
Client Project ID: SS STATESVILLE
QC Batch: 171223 Analysis Method: EPA 350.1
QC Batch Method: EPA 350.1 Analysis Description: Ammonia
Associated Lab Samples: 927591784 927591792 927591800 927591826
METHOD BLANK: 927597450
Associated Lab Samples: 927591784 927591792 927591800 927591826
Blank Reporting
Parameter Units Result Limit Footnotes
Nitrogen, Ammonia mg/l ND 0.10
LABORATORY CONTROL SAMPLE: 927597468
Spike LCS LCS
Parameter Units Conc. Result Rec Footnotes
Nitrogen, Ammonia mg/l 1.000 1.058 106
MATRIX SPIKE: 927597484
927572156 Spike MS MS
Parameter Units Result Conc. Result % Rec Footnotes
Nitrogen, Ammonia mg/l 0.06740 1.000 1.375 131 1
SAMPLE DUPLICATE: 927597476
Parameter Units
Nitrogen, Ammonia mg/l
Date: 10/30/06
927572156 DUP
Result Result RPD Footnotes
ND ND NC
Asheville Certification ID s REPORT OF LABORATORY ANALYSIS Charlotte Certification IDs
NO Wastewater 40 , This report shall not he reproduced, except in full, NO Wastewater 12
NC -Drinking Water 97712 without the written consent of Pace Analytical Services, Inc. NO Drinking Water 37706
SC Environmental 99030 ,�� � $C 99006
FL NELAP E87648 ,((,,I,,.,,��'�;;; FL NELAP E87627
"111GKL�!
Page: 7 of 8

Pace Analytical Services, Inc. Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100 2225 Riverside Drive
5aceAnalytical " Huntersville, NC 28078 Asheville, NC 28804
Phone: [phone] Phone: [phone]
vn nv pacelabs.com Fax: [phone] Fax. [phone]
Lab Project Number: 92130609
Client Project ID: SS STATESVILLE
QUALITY CONTROL DATA PARAMETER FOOTNOTES
Consistent with EPA guidelines, unrounded concentrations are displayed and have been used to calculate % Rec and RPD values.
LCS(D) Laboratory Control Sample (Duplicate)
MS(D) Matrix Spike (Duplicate)
DUP Sample Duplicate
ND Not detected at or above adjusted reporting limit
NC Not Calculable
J Estimated concentration above the adjusted method detection limit and below the adjusted reporting limit
NDL Adjusted Method Detection Limit
RPD Relative Percent Difference
(1) The spike recovery was outside acceptance limits for the MS and /or MSD due to matrix interference. The LCS
and/or LCSD were within acceptance limits showing that the laboratory is in control and the data is
acceptable.
Date: 10/30/06
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS Charlotte Certification IDs
NC Wastewater 40 This report shall not be reproduced, except in full, NC Wastewater 12
NG Drinking Water 37712 without the written consent of Pace Analytical Services, Inc. NC Drinking Water 37706
SC Environmental 99030 $C 99006
FL NELAP E87648 `°`` ; FL NELAP E87627
Page: 8 of 8

lor:2_ n __•_ter__•
CHAIN -OF -CUSTODY/ Analytical Request Document
The Chain -of -Custody is a LEGAL DOCUMENT. All relevant fields must be completed accurately.
Page:
.
i.
REGULATORY AGENCY
T � �
-
: •WMET07M.
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• • •
Additional Conimiints:
I
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SAMPLER
NAME AND SIGNATURE
PRINT Name of SAMPLER*
i�
—
.• ■.

(�5a'neAnalXical*`
wtnv. pacelabs.com
October 30, 2006
Mr. Chris Fay
Duncklee & Dunham
PO Box 33366
Raleigh, NC 27636
RE: Lab Project Number: 92130547
Client Project ID: SS Statesville
Dear Mr. Fay:
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Huntersville, NC 28078
Phone: [phone]
Fax., 704.875.9091
Pace Analytical Services, Inc.
2225 Riverside Drive
Asheville, NC 28804
Phone: [phone]
Fax.[phone]
Enclosed are the analytical results for sample(s) received by the laboratory on October 23, 2006. Results
reported herein conform to the most current NELAC standards, where applicable, unless otherwise narrated in the
body of the report.
Inorganic Wet Chemistry and Metals Analyses were performed at our Pace Asheville laboratory and Organic testing
was performed at our Pace Charlotte laboratory unless otherwise footnoted.
If you have any questions concerning this report please feel free to contact me.
Sincerely,
�J
Richard Swartz
[e-mail]
[phone] ext. 237
Project Manager
Enclosures
Asheville Certification IN REPORT OF LABORATORY ANALYSIS
NC Wastewater 40 This report shall not be reproduced, except in full,
NC Drinking Water 37712 without the written consent of Pace Analytical Services, Inc.
SC Environmental 99030
FL NELAP E87648
Charlotte Certification
IN
NC Wastewater
12
NC Drinking Water
. 37706
sC
99006
FL NELAP
E87627

hnrv. pscelabs.com
Lab Sample No: 927588558
Client Sample ID: X65W7D
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Huntersville, NC 28078
Phone: [phone]
Fax: [phone]
Pace Analytical Services, Inc.
2225 Riverside Drive
Asheville, NC 28804
Phone: [phone]
Fax.[phone]
Lab Project Number: 92130547
Client Project ID: SS Statesville
Project Sample Number: 92130547-001 Date Collected: 10/23/06 10:50
Matrix: Water Date Received: 10/23/06 15:40
Parameters Results Units Report Limit Analyzed By CAS No. Oual ReaLmt
Wet Chemistry
Ammonia Method: EPA 350.1
Nitrogen, Ammonia 1.1 mg/l 0.10 10/25/06 16:36 NIW 7727-37-9
48 Hour NO3 / NO2 / NOX
Nitrate as N
Date: 10/30/06
Method: EPA 353.2
15. mg/l 0.50 10/25/06 07:20 TMR
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS
NO Wastewater 40 This report shall not he reproduced, except in full,
NO Drinking Water 37712 without the written consent of Pace Analocal Services, Inc.
SC Environmental 99030
FLNELAP E87648
"LIJI
Charlotte Certification IDs
NO Wastewater
12
NC Drinking Water
37706
$C
99006
FL NELAP
E87627
Page: 1 of 10

(�5aneAnalyfical'"
wrnv pacelabs.com
Lab Sample No: 927588566
Client Sample ID: R65W7F
Pace Analytical Services, Inc.
9800 KinceyAvenue, Suite 100
Huntersville, NC 28078
Phone: [phone]
Far 704.875.9091
Pace Analytical Services, Inc.
2225 Riverside Drive
Asheville, NC 28804
Phone: [phone]
Fax. • 828.252.4618
Lab Project Number: 92130547
Client Project ID: SS Statesville
Project Sample Number: 92130547-002 Date Collected: 10/23/06 12:00
Matrix: Water Date Received: 10/23/06 15:40
Parameters Results Units Report Limit Analyzed By CAS No. Oual RecLmt
Wet Chemistry
Ammonia Method: SPA 350.1
Nitrogen, Ammonia 1.1 mg/1 0.10 10/25/06 16:36 NIW 7727-37-9
48 Hour NO3 / NO2 / NOX Method: EPA 353.2
Nitrate as N 15. mg/1 0.50 10/25/06 07:20 TMR
Date: 10/30/06
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS Charlotte Certification IDs
NO Wastewater 40 This report shall not be reproduced, except in full, NO Wastewater 12
NO Drinking Water 37712 without the written consent of Pace Analytical Services, Inc. NO Drinking Water 37706
SC Environmental 99030 S.0 99006
FL NELAP E87648 �„` ; FL NELAP E87627
Page: 2 of 10

(�5a'ceAnalXical'4
vvvrv. pacetabs.com
Lab Sample No: 927588574
Client Sample ID: K65W7G
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Huntersville, NO 28078
Phone: [phone]
Fax: [phone]
Pace Analytical Services, Inc.
2225 Riverside Drive
Asheville, NC 28804
Phone: [phone]
Fax. • 828.252.4618
Lab Project Number: 92130547
Client Project ID: SS Statesville
Project Sample Number: 9213'0547-003 Date Collected: 10/23/06 12:34
Matrix: Water Date Received: 10/23/06 15:40
Parameters Results Units Report Limit Analyzed By CAS No. Qual ReaLmt
Wet Chemistry
Ammonia Method: EPA 350.1
Nitrogen, Ammonia 4.1 mg/1 0.50 10/25/06 17:04 NIW 7727-37-9
48 Hour NO3 / NO2 / NOX
Nitrate as N
Date: 10/30/06
Method: EPA 353.2
29. mg/l 0.50 10/25/06 07:20 TMR
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS
NC Wastewater 40 This report shall not he reproduced, except in full,
NC Drinking Water 37712 without the written consent of Pace Analytical Services, Inc.
SC Environmental 99030 c
FL NELAP E87648
"l�Cl
Charlotte Certification IDs
NC Wastewater
12
NC Drinking Water
37706
&C
99006
FL NELAP
E87627
Page: 3 of 10

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I
Lab Sample No: 927588582
Client Sample ID: K65W7L
Pace Analytical Services, Inc.
9800 KinceyAvenue, Suite 100
Huntersville, NC 28078
Phone: [phone]
Fax: [phone]
Pace Analytical Services, Inc.
2225 Riverside Drive
Asheville, NC 28804
Phone: [phone]
Fax: [phone]
Lab Project Number: 92130547
Client Project ID: SS Statesville
Project Sample Number: 92130547-004 Date Collected: 10/23/06 14:25
Matrix: Water Date Received: 10/23/06 15:40
Parameters Results Units Report Limit Analyzed By CAS No. Qual RegLmt
Wet Chemistry
Ammonia Method: SPA 350.1
Nitrogen, Ammonia 11. mg/l 0.50 10/25/06 17:10 NIW 7727-37-9
48 Hour NO3 / NO2 / NOX Method: SPA 353.2
Nitrate as N 120 mg/l 10. 10/25/06 07:20 TMR
Date: 10/30/06
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS
NO Wastewater 40 This report shall not he reproduced, except in full,
NO Drinking Water 9771.2 without the written consent of Pace Analytical Services, Inc.
SC Environmental 99030
FL NELAP E87648
Charlotte Certification IDs
NO Wastewater 12
NO Drinking Water 37706
so 99006
FL NELAP E87627
Page: 4 of 10

(�5aneAnal6caf"
wirv.pac✓✓elabs.com
Lab Sample No: 927588590
Client Sample ID: X65W7R
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Huntersville, NC 28078
Phone: [phone]
Fax: [phone]
Pace Analytical Services, Inc.
2225 Riverside Drive
Asheville, NC 28804
Phone: [phone]
Fax: [phone]
Lab Project Number: 92130547
Client Project ID: SS Statesville
Project Sample Number: 92130547-005 Date Collected: 10/23/06 15:30
Matrix: Water Date Received: 10/23/0.6 15:40
Parameters Results Units Report Limit Analyzed By CAS No. Qual ReaLmt
Wet Chemistry
Ammonia Method: SPA 350.1
Nitrogen, Ammonia 11. mg/l 0.50 10/25/06 19:30 NIW 7727-37-9
48 Hour NO3 / NO2 / NOX
Nitrate as N
Date: 10/30/06
Method: EPA 353.2
120 mg/l 10. 10/25/06 07:20 TMR
Asheville Certification Us REPORT OF LABORATORY ANALYSIS Charlotte Certification IDs
NO Wastewater 40 This report shall not he reproduced, except in full, NO Wastewater 12
NO Drinking Water 97712 without the written consent of Pace Analytical Services, Inc. NO Drinking Water 37706
SC Environmental 99030 SC 99006
FL NELAP E87648 ((���,,,,,.., FL NELAP E87627
"IlJC�C0,6..1
Page: 5 of 10

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PARAMETER FOOTNOTES
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Huntersville, NC 28078
Phone: [phone]
Fax., 704.875.9091
Pace Analytical Services, Inc.
2225 Riverside Drive
Asheville, NC 28804
Phone: [phone]
Fax- 828.252.4618
Lab Project Number: 92130547
Client Project ID: SS Statesville
Method 9071B modified to use ASE.
All pH, Free Chlorine, Total Chlorine and Ferrous Iron analyses conducted outside of EPA recommended immediate
hold time.
Depending on the moisture content the PRLs can be elevated for all soil samples reported on a dry weight basis.
2-Chloroethyl vinyl ether has been shown to degrade in the presence of acid.
ND Not detected at or above adjusted reporting limit
NC Not Calculable
J Estimated concentration above the adjusted method detection limit and below the adjusted reporting limit
MDL Adjusted Method Detection Limit
Date: 10/30/06
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS Charlotte Certification IDs
NO Wastewater 40 This report shall not be reproduced, except in full, NO Wastewater 12
NG Drinking Water 9771.2 without the written consent of Pace Analytical Services, Inc. NO Drinking Water 37706
SC Environmental 99030 $C 99006
FL NELAP E87648 FL NELAP E87627
Page: 6 of 10

,_5a'ceAnalXical`
wivmpacelabs.com
QC Batch: 171147
QC Batch Method: EPA 353.2
Associated Lab Samples:
METHOD BLANK: 927593996
Associated Lab Samples:
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Huntersville, NC 28078
Phone: [phone]
Fax: [phone]
QUALITY CONTROL DATA
Pace Analytical Services, Inc.
2225 Riverside Drive
Asheville, NC 28804
Phone: [phone]
Fax: [phone]
Lab Project Number: 92130547
Client Project ID: SS Statesville
Analysis Method: EPA 353.2
Analysis Description: 48 Hour NO3 / NO2 / NOX
927588558 927588566 927588574 927588582 927588590
927588558 927588566 927588574 927588582 927588590
Blank Reporting
Parameter Units Result Limit Footnotes
Nitrate as N mg/l ND 0.10
LABORATORY CONTROL SAMPLE: 927594002
Spike LCS LCS
Parameter Units Conc. Result Rec Footnotes
Nitrate as N mg/l 5.000 5.217 104
MATRIX SPIKE: 927594200
927586495 Spike MS MS
Parameter Units Result Conc. Result % Rec Footnotes
Nitrate as N mg/l 1.733 5.000 5.411 74
SAMPLE DUPLICATE: 927594218
Parameter Units
Nitrate as N mg/l
Date: 10/30/06
927586511 DUP
Result Result RPD Footnotes
0.2300 0.2200 1
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS Charlotte Certification IDs
NO Wastewater 40 This report shall not he reproduced, except in full, NO Wastewater 12
NO Drinking Water 37712 without the written consent of Pace Analytical Services, Inc. NO Drinking Water 37706
SC Environmental 99030 sC 99006
FL NELAP E87648 "1111, FL NELAP E87627
Page: 7 of 10

(�5aneAnalXicaf-
wi,Av.pacelabs.com
Pace Analytical Services, Inc.
9800 KinceyAvenue, Suite 100
Huntersville, NC 28078
Phone: [phone]
Fax., 704.875.9091
QUALITY CONTROL DATA
Pace Analytical Services, Inc.
2225 Riverside Drive
Asheville, NC 28804
Phone: [phone]
Fax. • 828.252.4616
Lab Project Number: 92130547
Client Project ID: SS Statesville
QC Batch: 171222 Analysis Method: SPA 350.1
QC Batch Method: EPA 350.1 Analysis Description: Ammonia
Associated Lab Samples: 927588558 927588566 927588574 927588582
METHOD BLANK: 927397401
Associated Lab Samples: 927588558 927588566 927588574 927588582
Blank Reporting
Parameter Units Result Limit Footnotes
Nitrogen, Ammonia mg/l ND 0.10
LABORATORY CONTROL SAMPLE: 927597419
Spike LCS LCS
Parameter Units Conc. Result Rec Footnotes
Nitrogen, Ammonia mg/1 1.000 1.067 107
MATRIX SPIKE: 927597427
927591305 Spike MS MS
Parameter Units Result Conc. Result % Rec Footnotes
Nitrogen, Ammonia mg/l 10.26 1.000 11.52 126 1
SAMPLE DUPLICATE: 927597435
927595801 DDP
Parameter Units Result Result RPD Footnotes
Nitrogen, Ammonia mg/l 6.300 6.500 3
Date: 10/30/06
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS Charlotte Certification IDs
NC Wastewater 40 This report shall not he reproduced, except in full, NC Wastewater 12
NC Drinking Water 37712 without the written consent of Pace Analytical Services, Inc. NC Drinking Water 37706
SC Environmental 99030`c $C 99006
FL NELAP E87648j�,s FL NELAP E87627
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Knrupacetabs.com
Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Huntersville, NC 28078
Phone: [phone]
Fax: [phone]
QUALITY CONTROL DATA
Pace Analytical Services, Inc.
2225 Riverside Drive
Asheville, NC 28804
Phone: [phone]
Fax: [phone]
Lab Project Number: 92130547
Client Project ID: SS Statesville
QC Batch: 171223 Analysis Method: SPA 350.1
QC Batch Method: SPA 350.1 Analysis Description: Ammonia
Associated Lab Samples: 927588590
METHOD BLANK: 927597450
Associated Lab Samples: 927588590
Blank Reporting
Parameter Units Result Limit Footnotes
Nitrogen, Ammonia mg/l ND 0.10
LABORATORY CONTROL SAMPLE: 927597468
Spike LCS LCS
Parameter Units Conc. Result Rec Footnotes
Nitrogen, Ammonia' mg/l 1.000 1.058 106
MATRIX SPIKE: 927597484
927572156 Spike MS MS
Parameter Units Result Conc. Result % Rec Footnotes
Nitrogen, Ammonia mg/l 0.06740 1.000 1.375 131 1
SAMPLE DUPLICATE: 927597476
Parameter Units
Nitrogen, Ammonia mg/1
Date: 10/30/06
927572156 DUP
Result Result RPD Footnotes
ND ND NC
Asheville Certification IDs REPORT OF LABORATORY ANALYSIS Charlotte Certification IDs
NC Wastewater 40 This report shall not he reproduced, except in full, NC Wastewater 12
NC.Drinking Water 37712 without the written consent of Pace Analytical Services, Inc. NC Drinking Water 37706
SC Environmental 99030 SC 99006
FL NELAP E87648 � `` FL NELAP E87627
Page: 9 of 10

I
Pace Analytical Services, Inc. Pace Analytical Services, Inc.
I 9800 Kincey Avenue, Suite 100 2225 Riverside Drive
5aneAna9 jCC7I.w Hunters ville, NC28078 Asheville, NC28804
Phone: [phone] Phone: [phone]
wvrv.pacelabs.com Fax: [phone] Fax[phone]
Lab Project Number: 92130547
Client Project ID: SS Statesville
QUALITY CONTROL DATA PARAMETER FOOTNOTES
Consistent with EPA guidelines, unrounded concentrations are displayed and have been used to calculate % Rec and RPD values.
LCS(D) Laboratory Control Sample (Duplicate)
MS(D) Matrix Spike (Duplicate)
DUP Sample Duplicate
ND Not detected at or above adjusted reporting limit
NC Not Calculable
J Estimated concentration above the adjusted method detection limit and below the adjusted reporting limit
MDL Adjusted Method Detection Limit
RPD Relative Percent Difference
ill The spike recovery was outside acceptance limits for the MS and /or MSD due to matrix interference. The LCS
and/or LCSD were within acceptance limits showing that the laboratory is in control and the data is
acceptable.
Date: 10/30/06
Asheville Certification IDs
NO Wastewater 40
NO Drinking Water 97712
SC Environmental 99030
FL NELAP E87648
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc.
Charlotte Certification IDs
NO Wastewater 12
NO Drinking Water 37706
se 99006
FL NELAP E87627
Page: 10 of 10

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Section A
CHAIN -OF -CUSTODY / Analytical Request Document
The Chain -of -Custody is a LEGAL DOCUMENT. All relevant fields must be completed accurately.
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SAMPLER NAME AND SIGNATURE
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W- C. DEFT. OF NATURAL
RESOURCES AND
POMAlUNMDEVELOPMEW
LAW ENVIRONMENTAL, INC.
OCT 3 0 1992
4333 WILMONT ROAD, SUITE 300
CHARLOTTE, NORTH CAROLINA 28217
DIVISION OF ENVIUBIENTAL ?1A.q r11ENT
P.O. BOX 240674
CHARLOTTE, NORTH CAROLINA 28224-0674
WRESVILLE REGIXI l OFFICE
704-357-1747 704-357-1622 (FAX)
September 10, 1992
e '3
State of North Carolina
= ' ''-
Department of Environment, Health, and Natural Resources
Division of Environmental Management
P.O. Box 27687
=
Raleigh, North Carolina 27611
Attention: Mr. M. Dale Overcash, P.E.
- -e
Supervisor, NPDES Permits
Subject: Short Form C-GW - Application for Permit to Discharge
National Pollutant Discharge Elimination System
Southern States Fertilizer Plant to Third Creek
Statesville, North Carolina
LEI Job No. 56-1570.94
Gentlemen:
On behalf of our client, Southern States Cooperative, Inc., Law Environmental Inc. and Canonie
Environmental Services Corporation herewith submit three copies of Short Form C-GW:
Application for Permit to Discharge, and supporting documents.
The ground water underlying the Southern States Fertilizer Plant in Statesville, North Carolina
is impacted `with nitrates. Southern States Cooperative, through its _ consultants, Law
Environmental, Inc. and Canonie Environmental Services Corp., is in the process of preparing
a formal Corrective Action Plan (CAP) which will be submitted to the North Carolina
Department of Environment, Health and Natural Resources (NCDEHNR) for approval. The
CAP will propose the installation of ground -water pumping wells and discharge of the extracted
water into Fourth Creek.
This document constitutes the application for a National Pollution Discharge Elimination System
(NPDES) permit to discharge ground water impacted with nitrates into Fourth Creek. Discharge
limitations are requested for the proposed discharge location.
Printed on Recycled Paper

State of North Carolina
Department of Environment, Health,
and Natural Resources
September 10, 1992
Page 2
The following attachments are included as part of the NPDES permit application:
Attachment I: , Completed Short Form C-GW - Application for Permit to Discharge.
II: A summary of background information concerning the site.
III: A brief summary of the Corrective Action Plan concurrently being
prepared for the. site.
IV: An engineering proposal conforming to the requirements of 15 NCAC
2H.0105(c).
V: An engineering alternatives analysis conforming to the relevant
NCDEHNR Guidance Document.
A check for $400 made payable to the North Carolina Department of Environment, Health, and
Natural Resources is also attached to cover the permit application processing fee for this project.
Should you have any questions or require additional information, please contact Law
Environmental at [phone].
Sincerely,
LAW ENVIRONMENTAL, INC.
ohn P. Driscoll, P.E.
Se 'or Engineer
/Thomas F. Beggs, P.E. =
Principal -
Registered NC No. 13807
Attachments
cc: Ms. Christine DeRoller
NCDEHNR Mooresville Office

ApplicationATTACHMENT 1: Completed Short Form C-GW
Discharge
1Background Information
V: Engineering Alternatives ,analysis

d, � �

SITE BACKGROUND INFORMATION
in support of
APPLICATION FOR PERMIT TO DISCHARGE - SHORT FORM C-GW
Southern States Fertilizer Plant
Statesville, North Carolina
LEI Job No. 56-1570.94
The Southern States Fertilizer Plant is located on U.S. Highway 70 approximately six miles east
of Statesville, North Carolina. The facility was constructed in the 1950s. Southern States
purchased the plant from W. R. Grace & Co. in February 1988.
The manufacturing facility is currently self-contained; process water is recirculated within the
plant without exterior discharge. This is possible because air scrubbers are used to reduce stack
emissions. The scrubbers use a "wet" system, and the scrubber water is consumed in the
granulation process.
Prior to changes in scrubber design approximately 10 years ago, process water was discharged
from time to time. Drainage was to the former ponds located approximately 1,000 feet
southwest of the plant. Modifications to plant processes have been implemented over the past
several years, and waste products appear to be appropriately contained within the manufacturing
facility.
A spill control review was conducted by Law Environmental in February 1990. The report
concluded that the plant possessed adequate spill containment facilities, and the likelihood of a
significant spill appeared to be low.
On December 12, 1989, the NCDEHNR issued a Notice of Violation for the site. The notice
stated that excessive concentrations of nitrate and/or nitrite (expressed as nitrogen) had been
discovered in two NCDEHNR wells at the site. Combined nitrate/nitrite as nitrogen
concentrations were greater than the threshold value of 11 mg/1 set forth in Title 15, Subchapter
2L, Section .0202(g) of the North Carolina Administrative Code (15A NCAC 2L). The notice
required submission of specific technical and field data documenting the ground water
conditions.
On January 19, 1990, representatives of Southern States and Law Environmental met with
Messrs. Jesse Wells and Jeff Lautier at the NCDEHNR Mooresville office. All parties agreed
that Law Environmental would construct six ground -water monitoring wells at the site. Two of
the monitoring wells would be extended to bedrock (defined as auger refusal), and four would
be shallow monitoring wells intended to address the lateral extent of nitrogen content. This
initial well installation work was conducted during the period of January 30 through February
7, 1990. A response to the December 12, 1989 Notice of Violation was presented in Law
Environmental's "Phase I Ground -Water Assessment Report" dated March 29, 1990. Additional
ground water assessment (Phase II) was recommended.

NPDES Permit Application
Attachment II: Site Background Information
Page 2
The Phase II ground -water assessment activities were completed and a "Phase H Ground -Water
Assessment Report" was submitted to NCDEHNR on September 25, 1990. Analytical results
from Phase II analyses indicated that subsurface nitrate/nitrite concentrations had migrated along
a path following surface drainage features. In addition, the holding ponds on -site appeared to
have been the source of the impact on ground water at the site. At the time of the Phase H
report submittal, neither the horizontal nor vertical extent of nitrate/nitrite impact had been
defined.
After submission of the Phase II report, permission to drill off -site to the east of the plant was
obtained from the owner of the adjacent property. An off -site monitoring well was installed and
sampled, and the ground water was analyzed for nitrate and nitrite concentrations. The results
of the laboratory analysis of the ground water indicated a nitrate/nitrite level significantly below
the NCDEHNR threshold value. These results were submitted to NCDEHNR on November 19,
1990.
On December 12, 1990, NCDEHNR issued a letter to Southern States requesting additional
(Phase III) site assessment. The letter requested that a deep monitoring well be installed and that
a well survey of surrounding property be conducted.
On April 16, 1991, Law Environmental issued a Phase III -A assessment report describing well
installation and sampling activities conducted at the site. The NCDEHNR responded on May
14, 1991 with a letter stating that site assessment was approved. The NCDEHNR letter required
submission of a CAP within 60 days, as well as installation of one additional monitoring well
south of the property.
On June 26, 1991, representatives of Southern States met with Ms. Barbara Christian and Ms.
Christine DeRoller of NCDEHNR. At the meeting, NCDEHNR agreed to grant a 45-day
extension of the submittal date. The NCDEHNR also agreed that the submittal should present
a work plan outlining the steps necessary for the preparation and submittal of a CAP.
On August 30, 1991, the CAP work plan was submitted to NCDEHNR. The work plan
identified specific tasks necessary for the completion of the CAP, along with a schedule for
completion. The tasks included completion of an aquifer pump test and development of a
hydraulic control and ground -water treatment and/or disposal strategy.

NPDES Permit Application
Attachment II: Site Background Information
Page 3
On October 9, 1991, NCDEHNR issued a letter to Southern States proposing a Special Order
by Consent (SOC) which contained proposed terms under which the CAP preparation and
submittal were to proceed. These terms included the identification of specific tasks, along with
due dates and associated penalties. On October 31, 1991, representatives of Southern States met
with Ms. Barbara Christian and Ms. Christine DeRoller of NCDEHNR to discuss the terms of
the SOC. In the meeting, it was agreed that Southern States would initiate the NPDES permit
application process prior to completion and submittal of the CAP, and no later than January 2,
1992. This approach was intended to facilitate assessment of the practicality of the CAP from
an NPDES permit standpoint prior to the submittal of the CAP. This approach was also
intended to minimize NPDES permit related delays in starting site remediation once the CAP
is approved.
Short Form C - Application for Permit to Discharge was submitted to the NCDEHNR by Law
Environmental and Canonie Environmental on December 31, 1991: On January 7, 1992, the
NCDEHNR returned the application and requested that it be resubmitted using the recently
developed Short Form C-GW and guidance documents for NPDES engineering proposal and
engineering alternatives analyses.
During the spring and summer of 1992, Law contacted property owners along the route of the
proposed ground -water discharge line to Fourth Creek. All necessary authorizations have been
obtained from property owners to allow placement of the discharge line. Also during this
period, Law obtained encroachment permits for the proposed pipeline from the North Carolina
Department of Transportation and the Norfolk Southern Railroad. Copies of these documents
are included herein (Attachment V).
The completed Short Form C-GW is included as Attachment I, as requested in the January 7,
1992 letter from the NCDEHNR.

North Carolina Dept. of Environment, Health, and Natural Resources
Division of Environmental Management, P.O. Box 29535, Raleigh, NC 27626-0535
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM APPLICATION NUMBER
APPLICATION FOR PERMIT DISCHARGE SHORT FORM C-GW Fidoltd 9'1 Z
Date Received
To be filed by persons engaged in groundwater I '? 0 17 1 Zi
remediation projects. Year month Day
(DEM USE ONLY)
Do not attempt to complete this form before reading accompanying instructions.
(Please print or type) CK, G f-3 5-?7
$ V6D. a'D
1. Name, address, location; and telephone number of facility producing discharge
A. Name SOUTHERN STATES COOPERATIVE, INC.
B. Mailing address
1.Street address 6606 WEST BROAD STREET
2. City RICHMOND 3. State VIRGINIA
4. ZIP 23230
C. Location:
1. Street U.S. HWY. 70 (SIX MILES EAST OF STATESVILLE)
2. City STATESVILLE 3.5tate NORTH CAROI.INA
4. County IREDELL
D. Telephone No. ( 704)- 872-6361
E.Nature of business FERTILIZER MANUFACTURING
2. Facility contact
A. Name MR. HILTON M. WITHERS
B. Title MANAGER/ENVIRONMENTAL AFFAIRS C. Telephone No. (804) - 281-1158
s0
rt•5
N
3. The application is for ©a new permit, []permit renewal, ❑permit modification.
SIC . 2 8 7 5 (if known). If application is for renewal or modification, please indicate permit
number: NC00
4. Product(s) recovered GROUND WATER IMPACTED BY NITRATES AND NITRITES (AS NITROGEN) AT INITIA
CONCENTRATIONS OF APPROXIMATELY 140 MG PER LITER.
[Diesel fuel, leaded or unleaded fuel, solvents, etc.]
This application must also include the following:
A) A report of alternatives to surface water discharge as outlined by N.C. Permit and Engineering Unit's
"Guidance for Evaluation of Wastewater Disposal Alternatives." [Required by 15A NCAC 2H .0105 (c)].
B) An engineering proposal detailing the remediation project. [Required by 15A NCAC 2H .0105 (c)].
C) A listing of any chemicals found in detectable amounts with the maximum observed concentration
reported. The summary of analytical results containing this maximum value should also be
submitted (i.e. the listing, not the graphical scan). The most recent sample must be no older than
one year previous to the date of this application.
For fuel remediation projects, volatile organic compounds should be scanned along with any
suspected fuel additives. The following compounds should be included: benzene*, toluene*,
ethylbenzene*, xylene*, lead , methyl tert-butylether (MTBE), dibromoethane (EDB),
1,2-dichloroethane, isopropyl ether, naphthalene, phenol.
* An EPA approved method capable of detection levels to 1 ppb should be used to detect these
compounds

For solvents or unidentified products, an EPA Method 624/625 analysis should be provided,
with the 10 largest peaks, not identified as one of the targeted compounds and not present in
the procedural blank, identified and approximately quantitated. (As per the same guidance
stipulated on NCDEM's "Annual Pollutant Analysis Monitoring (APAM) Requirement - Reporting
Form A," Revised June 19901.
If metals or pesticides are suspected to be present, these should be analyzed to the same detection
level as presented in the NC APAM.
D) The removal efficiency of each compound detected for the proposed project should be provided,
if known. .
5
Name of receiving water FOURTH CREEK
Attach a USGS topographical map with all discharge points clearly marked.
6. Is potential discharge directly to the receiving water? If not, state specifically the discharge point.
YES
Mark clearly the pathway to the potential receiving water on the site map. [This includes tracing
the pathway of the storm sewer to its discharge point, if a storm sewer is the only viable means of
discharge.]
7. Amount of treated groundwater to be discharged in gallons per operating day: 144,000
8. Describe the duration and frequency of the discharge (continuous, intermittent, seasonal)
Including the months of discharge, number of days per week of discharge, volume treated
(monthly average flow in gallons per day).
YEAR ROUND — CONTINUOUS
AVERAGE MONTHLY FLOW WILL BE APPROXIMATELY 4.3 MILLION GALLONS
I certify that I am familiar with the information contained in the application and that to the best
of my knowledge and belief such information is true, complete, and accurate.
SAM KOON
PRINTED Name of Person igning
C7d-�
SIGNATURE of Applicant
OPERATIONS MANAGER, CROPS, FARM, AND HOME DIVISION
Title
I?-
Date Application Signed
North Carolina General Statute 143-215.6 (b) (2) provides that:
Any person who knowingly makes any false statement; representation, or certification in any application,
record, report, plan or other document files or required to be maintained under Article 21 or regulations
of the Environmental Management Commission implementing that Article, or who falsifies, tampers with
or knowingly renders inaccurate any recording or monitoring device or method required to be operated
or maintained under Article 21 or regulations of the Environmental Management Commission implementing
that Article, shall be guilty of a misdemeanor punishable by a fine not to exceed $10,000, or by imprison-
ment not to exceed six months, or by both. (18 U.S.C. Section 1001 provides a punishment by a fine of not
more than $10,000 or imprisonment not more than 5 years, or both, for a similar offense.)

ATTACHMENT ENT III
bps ■ r _ "i y' � � y, � s' ; � 1p_ '< S.

CORRECTIVE ACTION PLAN
in support of
APPLICATION FOR PERMIT TO DISCHARGE - SHORT FORM C-GW
Southern States Fertilizer Plant
Statesville, North Carolina
LEI Job No. 56-1570.94
The corrective action plan, details of which are currently under development, is based on
pumping impacted ground water from the site and discharging the extracted ground water into
Fourth Creek.
The location of the discharge point and the pipeline route are shown on the enclosed map
(Drawing 1). Authorizations have been obtained from property owners along this route.
Encroachment permits have also been issued by the North Carolina Department of
Transportation and the Norfolk Southern Railroad (refer to Attachments IV and V).
The total flow rate of extracted ground water from the site is not expected to exceed 100 gallons
per minute. Initial nitrate/nitrite concentrations are expected to be approximately 140 mg/liter
(as nitrogen). Concentrations are expected to decrease with time from the initial values.
On December 26, 1991, water samples were collected from Fourth Creek near the proposed
discharge point. The samples were sent to Law Environmental National Laboratories and
analyzed for nitrate and nitrite (as nitrogen). The concentration of nitrate (as nitrogen) in the
sample from Fourth Creek was 2.7 mg/l. Nitrite was not detected above the 0.05 mg/l detection
limits.
The United States Geological Survey has calculated a 7Q10 flow rate for Fourth Creek at the
State Road 2316 bridge of 7.3 cubic feet per second (approximately 3,300 gallons per minute).
Based on this flow rate, and the low nitrate/nitrite (as nitrogen) concentrations identified by
recent sampling, it appears that the stream could accommodate the proposed effluent.
A copy of the Fourth Creek surface water laboratory analyses results and USGS 7Q10
calculations are attached.

1
Corrective Action Plan Supporting Documents
1. Laboratory Analyses for Surface Water from Fourth Creek
2. USGS 7Q10 Calculations for Fourth Creek

Laboratory Analysis for Surface Water from Fourth Creek

LAW ENVIRONMENTAL, INC:
112 TOWNPARK DRIVE
KENNESAW,GEORGIA 30144-5599
404-421-3400 -
December 30, 1991
Law Environmental, Inc
LakePoint Office Park
r 4333 Wilmont Road, Suite 300
Charlotte, NC. 28217
Attention: Tom Beggs
I
LE Job Number: 56-1570 T92
Subject: Chemical analysis of samples received on 12/27/91.
Dear Mr. Beggs:
Law Environmental National Laboratories has completed its analysis
of your samples and reports the results on the following pages.
;.� These results relate only to the contents of the samples as
submitted. This report shall not be reproduced except in full
without the approval of Law Environmental National Laboratories.
1 If there are any questions, please do not hesitate to contact us.
Sincerely,
LAW ENVIRONMENTAL NATL LABS
Cliffor H. MCB ide
QC Coordinator
.Attachment: Data Report
Invoice

LAW ENVIRONMENTAL NATIONAL LABORATORIES
TEST DATA REPORT
Date 12/30/91
Page 1
--- Project Information ---
Lab Number : 91-1678-03
Project No. : 56-1570 T92 Cust. No.
Project Name : SOUTHERN STATES
Manager: TOM BEGGS
Sample Information
Station ID : 4TH CR. BELOW POTW DISC. Sampled Date/Time : 12/26/91 15:05
Matrix : W Received Date/Time : 12/27/91 09:25
Type : GRAB Received From/By : PGG/LD
Collector : PGG Chain of Custody : 8098
Number of Containers : 1
Remarks :
--- Test Data ---
Parameter .............................. Method.... Units PQL....... Results... Test Date Anal
-- INORGANIC CHEMISTRY RESULTS --
Nitrogen, Nitrate EPA 353.2 mg/l 0.05 2.7 12/27/91 OR
Nitrogen, Nitrite EPA 353.2 mg/l 0.05 ND 12/27/91 OR
Signed �, V

LAW ENVIRONMENTAL, INC. CHAIN OF CUSTODY RECORD 8098
C NATIONAL LABORATORY
C = 112 TOWNPARK DRIVE
KENNESAW, GEORGIA 30144
��� [phone] y� _ j �d'D - v/ � ��3
SAMPLING
NAME OF FACILITY: Jl0c.rT/fF-/'�JV -574r657 S ���JU•�E�-- f'�✓9iLiT
INFORMATION-
NPDES NUMBER STREET ADDRESS: f} t✓y / /ti • ___
PROJECT NAME
Sou H -iz 5 fC
JOB NO.
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SA LER (SIGN
SAMPLING E
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TIME U CODE SAMPLE STATION DESCRIPTION
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RELINQUI HED BY:
DATE / TIME
RECEIVED BY:
DATE / TIME
RELINQUISHED BY:
RECEIV D BY LABO TORY:
SIGN17. ATUR)
DATE / TIME
SIGNATUR
(SIGNATURE)SIGNATURE
)ISTRIBUTION: ORIGINAL AND YELLOW COPIES ACCOMPANY SAMPLE SHIPMENT TO LABORATORY.
PINK COPY RETAINED BY SAMPLERS. YELLOW COPY RETAINED BY LABORATORY.
IEMARKS
SFC fj7r46,Y,5D 011'E .
"SOURCE CODES
RECOVERY WELL - RW NPDES DISCHARGE - ND
RCRA MONITORING WELL - MW DRINKING WATER - DW
SOIL / SEDIMENT - SO HAZARDOUS WASTE - HW
SLUDGE -SL SURFACE WATER - SW
NON-AOI IFOLIS - NA

USGS 70! 10 Calculations for Fourth Creek

��FjIT OFTy
United States Department of the Interior°
� a
GEOLOGICAL SURVEY!
Water Resources Division �ck041AL513
3916 Sunset Ridge Road
Raleigh, NC 27607
January 10, 1992
Mr. P. Greg Garrett
Law Environmental, Inc.
P.O. Box 240674
Charlotte, North Carolina 28224-0674
Dear Mr. Garrett:
JAN13l?
J 't L
-----------------------------
In response to your request for low -flow data, the U.S. Geological
Survey does not have site -specific data for Third Creek at SR 2362 near
Elmwood, North Carolina (station ID 0212001000) or Fourth Creek at SR 2316
near Statesville, North Carolina (station ID 0212060665). The statistics
that are provided on the,attached sheet have been computed by techniques
described in U.S. Geological Survey Open -File Report 90-399, "Low -Flow
Characteristics Of Streams In North Carolina." They reflect natural
streamflow conditions and do not account for the effects of any diversion
or regulation that may be present.
The U.S. Geological Survey provides timely water -resources
information and data through a variety of scientific and technical
publications and data reports. For many years, the Survey also has
processed special requests for water -resources information free of charge.
Because of the increase in volume of special requests along with budget
reductions imposed by the Gramm -Rudman -Hollings Budget Deficit Reduction
Act, the Survey will no longer be able to process special requests free of
charge.
A charge for accessing and processing information has been assessed
to partially offset these costs. Your requested data and an invoice
covering processing costs for these data are attached. Please forward the
original bill with your check to the U.S. Geological Survey, Joint Funding
Agreement, P.O. Box 100706, Atlanta, GA 30384.
These data are preliminary and subject to revision pending approval
for publication by the Director of the U.S. Geological Survey, and are
made available through our cooperative program of water -resources
investigations with the North Carolina Department of Environment, Health,
and Natural Resources.

P. Greg Garrett, January 10, 1992 Page 2 of 2
If you have any questions regarding this information, please
contact us.
Sincerely,
3obo 7V(-a
ert R. Mason
Hydrologist
3 Enclosures
Copy to: John N. Morris, Director, DWR, DEHNR
Raleigh, North Carolina
RRM/aef

REQUEST REQUEST NO: 91536 SITE NO: 2 DATE: 1/10/92
SOURCE: CONSULTANT ACTION: EXISTING STREAMFLOW CONDITION:
STATION NUMBER: 0212060665 TYPE STATION: 20
STATION NAME: FOURTH C AT SR2316 NR STATESVILLE, NC
LOCATION: AT SR 2316 AND 4 MI E OF STATESVILLE, NC
LATITUDE: 354633 LONGITUDE: 804745
QUADRANGLE NUMBER: D15SE
COUNTY CODE: 097 STATE CODE: 37 DISTRICT CODE: 37
HYDROLOGIC UNIT CODE: 03040102 NRCD BASIN CODE: 030706
DRAINAGE AREA: 45.5
AVERAGE FLOW: 46. RANGE: cfs to cfs Percent (B]
7Q10 MIN FLOW: 7.3 RANGE: cfs to cfs Percent [ ]
(SUMMER)
30Q2 MIN FLOW: RANGE: cfs to cfs Percent [ ]
7Q10 MIN FLOW: RANGE: cfs to cfs Percent [ ]
(WINTER)
7Q2 MIN FLOW: RANGE: cfs to cfs Percent [ ]
NOTES:
[A] Estimate is based on records collected at or near the site. The range
indicates approximate interval in which the actual value may lie
[B] Estimate is based entirely on runoff observed at nearby streams.
[C] Because of the probable degree of inaccuracy of the estimate only
a range is given.
[D] Approximately.
Streamflow Condition Codes [R] Regulated (N] Natural
***** These data are provisional pending approval by the Director,USGS ******
EMARKS:
EQUESTOR--LAW ENVIRONMENTAL, INC.
ata Index -- Entered by: AF
ee charged: 125

ATTACHMENT ENT IV:

- ENGINEERING PROPOSAL
in support of
APPLICATION FOR PERMIT TO DISCHARGE - SHORT FORM C-GW
Southern States Fertilizer Plant
Statesville, North Carolina
LEI Job No. 56-1570.94
The following information fulfills the seven requirements of regulation 15 NCAC 2H .0105 (c).
1. ORIGIN, TYPE AND FLOW OF WASTE TO BE DISCHARGED
The proposed discharge effluent will be ground water pumped from an aquifer underlying
the Southern States Fertilizer Plant. This ground water has been impacted with nitrates and
nitrites (as nitrogen) at concentrations which exceed North Carolina drinking water standards.
The expected discharge flow rate will be t,4 g j ans per?muiut� ':impig iepa.ei
tdlafs� upt'o1Cl�ears total yield will therefore be approximately 500 million gallons.
2. WASTE TREATMENT AND DISPOSAL OPTIONS
Disposal options were considered in accordance with the NCDEHNR Guidance for
Evaluation of Wastewater Disposal Alternatives. Four discharge disposal alternatives were
considered, as summarized below.
A. Discharge to a Publicly Owned Treatment Works.
B. Discharge to a Subsurface Disposal System.
C. Discharge through a Spray Irrigation System.
D. Discharge to a Flowing Stream.
Information concerning each of these alternatives is presented on the following pages.

i
NPDES Permit Application
_ Attachment IV: Engineering Proposal
Page 2
A. Discharge to a Publicly Owned Treatment Works.
- A publicly owned wastewater treatment plant is located approximately one mile northeast of the
' site. This facility (The Fourth Creek Water/Wastewater Treatment Plant, see Figure 1) accepts
municipal sewage from the city of Statesville.
On February 5, 1992, Law Environmental submitted a letter to the Director of the Fourth Creek
Plant, Mr. Joe Hudson. The letter formally requested that the plant accept ground water
discharged from the nearby Southern States site. Laboratory analyses of representative ground
water samples were included in support of the request. A copy of the letter is attached.
As outlined on the attached response from Mr. Hudson dated February 11, 1992, the Fourth
Creek Water/Wastewater Treatment Plant agreed to consider acceptance of the proposed
discharge. However, the treatment plant set forth several requirements which must be met prior
to final acceptance.
On February 26, Law responded to the plant with the following questions:
1. Does the Fourth Creek Treatment Plant have denitrification equipment?
2. Would the Fourth Creek plant treat the Southern States effluent to reduce the nitrate
concentrations prior to discharge to Fourth Creek?
3. Would it be necessary for Southern States to pre -treat the ground water prior to
discharge? If so, what method(s) of pre-treatment would be required?
A meeting between Law Environmental and Mr. Hudson was held on April 1, 1992. During
- the meeting, Mr. Hudson indicated that:
1. The plant does not possess denitrification equipment.
2. The plant would not attempt to reduce nitrate or nitrite concentrations prior to
- discharge into Fourth Creek.
- - 3. Pretreatment might be necessary to reduce suspended solids.
A summary of the meeting discussion (dated April 8) is attached.
In summary, the Fourth Creek Water/Wastewater Treatment Plant does not possess
denitrification equipment. Therefore passage of water through the plant would not enhance
environmental quality. Accordingly, this option of discharge was dropped from further
consideration.

NPDES Permit Application
Attachment IV: Engineering Proposal
Page 3
J
B. Discharge to a Subsurface Disposal System.
As outlined in the Background Information section of this document, former holding ponds at
the site appear to have been the source of nitrate/nitrite impact on ground water. The holding
ponds have now been closed. The goal of remediation at this site will be to extract ground
water and thereby remove impacted water from the site, reducing nitrates/nitrites (as nitrogen)
to concentrations acceptable to the NCDEHNR.
To accomplish this goal, it will be necessary to remove ground water from the site. Reinjection
of the water on -site would be counterproductive to this goal. Moreover, the water could not be
reinjected on -site because on -site soils are fine grained and therefore low in permeability. There
is insufficient open land available (either on -site or on surrounding properties) to accommodate
the anticipated 100 gallon per minute flow rates.
Discharge to a subsurface disposal system, or infiltration gallery, was determined to be
environmentally infeasible. This option was therefore dropped from further consideration.
C. Discharge through a Spray Irrigation System.
___ On June 13, 1991, the NCDEHNR issued non -discharge Permit No. WQ0004556 to Southern
States Cooperative, Inc. The permit authorized spray irrigation of approximately 2.5 million
gallons of water from two former holding ponds at the site. The permit was effective from the
date of issuance through May 31, 1992.
Spray irrigation was conducted at the site on a once -a -week basis during the period of July 11
through August 27, 1991. An area covering approximately 10 acres received the discharge, and
grasses in the area were periodically harvested during the spray cycles to remove nitrogen from
the site. The water in both holding ponds was successfully removed, and the ponds were closed
by removing the former dams and using soil from the dams to backfill low areas.
The spray operation was limited to four hours per week to avoid runoff. The maximum
allowable spray volume was 255,000 gallons per week, and the maximum allowable nitrogen
loading rate was 250 pounds of nitrogen per acre per year.

NPDES Permit Application
Attachment IV: Engineering Proposal
Page 4
As previously noted, concentrations of approximately 140 mg/1 nitrate/nitrite (as nitrogen) are
anticipated in the ground -water discharge. Given the permit restrictions (runoff, nitrogen
loading) outlined above, we have determined that the previously permitted 10-acre spray
irrigation system could accommodate flow of only approximately five gallons per minute.
Approximately 200 to 300 acres of usable open land would therefore be required to allow
continuous spray irrigation. This land area is not available either on -site or on surrounding
properties.
Discharge through a spray irrigation system was found to be environmentally infeasible, and this
- option was therefore dropped from further consideration.
D. Discharge to a Flowing Stream.
Since the non -discharge alternatives mentioned above were found to be environmentally
infeasible, discharging the Southern States ground water to a flowing stream was evaluated.
Fourth Creek flows west -to -east about 1.5 miles north of the Southern States site. The stream
is classified Class C - aquatic life propagation and survival, fishing, wildlife, and secondary
recreation. Based on 7Q10 flows calculated by the United States Geological Survey, Fourth
Creek meets the requirements for classification as a flowing stream. The 7Q10 flow for Fourth
Creek is sufficient to dilute the nitrate/nitrite (as nitrogen) concentrations to levels commensurate
with Class C standards.
The proposed point of discharge is shown on the attached Figure 1. This discharge point was
- chosen because it is at the most easily accessible point on Fourth Creek relative to the Southern
States plant.
A four -inch diameter discharge line could be constructed from the plant eastward along Highway
70 to State Road 2313 (John Long Road). The pipe could then be routed northward, under
Highway 70 and the Norfolk Southern Railroad tracks to State Road 2312 (Buckbee Road), and
northeastward on Buckbee Road to private property adjoining Fourth Creek.
Right -of -Way Encroachment Agreements for this route have -been issued by the Department of
Transportation and the Norfolk Southern Railroad (copies attached). In addition, the private
property owner (Mr. James W. Davidson) has given written consent for the project. Please refer
to Drawing 1 for a detailed route map. Copies of property owner consent forms for the
proposed route are included in the Engineering Alternatives Analysis, Attachment V of this
submittal.
Summary of Waste Treatment and Disposal Options
In our opinion, discharge to a flowing stream using an NPDES permit is the most
environmentally sound alternative for this project. Non -discharge options have been found to
be environmentally infeasible as outlined above.

NPDES Permit Application
Attachment IV: Engineering Proposal
Page 5
3. DESCRIPTION OF PROPOSED TREATMENT WORKS
The proposed effluent will not be treated prior to discharge into Fourth Creek. As previously
noted, the 7Q10 flow. of 3,300 gpm will be sufficient to fully assimilate a direct discharge of 100
gpm of ground water without treatment.
4. GENERAL LOCATION MAP
A USGS topographic map showing the location of the Southern States Facility, as well as the
proposed discharge point at Fourth Creek, is attached as Figure 1.
5. SCALE PLAN OF SITE AND PROPOSED TREATMENT WORKS
A scale plan of the site is attached as Figure 2. The plan shows the proposed ground -water
recovery well locations. Effluent pipes will connect the wells and lead to Highway 70, then
eastward to State Roads 2313 and 2312 and north across private property to Fourth Creek. The
proposed point of discharge is shown on the attached Figure 1. The route is shown in detail on
Drawing 1.
6. ENVIRONMENTAL IMPACT MODELING
The Division of Environmental Management has not indicated that requirements of 15 NCAC
2H .0105 (c) (6) are necessary for the purposes of this application.
7. STATEMENT OF FINANCIAL QUALIFICATION
In accordance with North Carolina Statute 143-215.1 (4)b, Southern States Cooperative has
prepared a Statement of Financial Qualification. The letter demonstrates Southern States'
financial ability to complete the activities proposed in this NPDES application, and provides an
annual report to verify financial stability. A copy of the letter is attached.

Engineering Proposal Support Documents
1. Figures
2. Correspondence with Fourth Creek Publicly Owned Treatment Works
3. Department of Transportation Right -of -Way Encroachment Permit
4. Norfolk Southern Railroad Encroachment Permit
5. Statement of Financial Qualification

1. Figures

Ito
70(
co
� -_�.�_--.sue � •\ I ,i-�� �.__ ��. J �-
ID I FOURTH (CREEK \ V ! 3 �'�= I f �� g F - � 't-4
WATER/WASTEWATER ✓ ,q )
TREATMENT PLANT' B50 - `• �-' \ / _ - ; I __- _ \
.SOUTHERN STATES,
FERTILIZER PLANT
I^ _ �=�`_�a�_ _ _ __� SITE' � r �J`� �/.-- ,� � \ _ �� •�
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0 2000
EXPLANATION LAW ENVIRONMENTAL, INC.
APPROX. SCALE, FT.
PROPERTY BOUNDARY CHARLOTTE, NORTH CAROLINA
® PROPOSED NPDES DISCHARGE POINT PROPOSED NPDES DISCHARGE LOCATION
FOURTH CREEK
SOUTHERN STATES FERTILIZER PLANT
TATE VILLE NORTH CAROL( A
REF.: 1969 U.S.G.S. 7.5 MIN. TOPOGRAPHIC MAPS:
STATESVILLE EAST, AND SHEPHERDS. NORTH,CAROLINA NOTE: ALL LOCATIONS ARE APPROXIMATE. JOB NO. 56-1570.94 FIGURE 1

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LAW ENVIRONMENTAL, INC.
CHARLOTTE, NORTH CAROLINA
PROPOSED RECOVERY WELL LOCATIONS
SOUTHERN STATES FERTILIZER PLANT
STATESVILLE, NORTH CAROLINA
JOB No. 56-1570.94 1 FIGURE 2

2. Correspondence with Fourth Creek Publicly Owned Treatment Works

LAW ENVIRONMENTAL, INC.
4333 WILMONT ROAD, SUITE 300
CHARLOTTE, NORTH CAROLINA 28217
P.O. BOX 240674
April 8 1992 CHARLOTTE, NORTH CAROLINA 28224-0674
p 704-357-1747 704-357-1622 (FAX)
Fourth Creek Wastewater Treatment Plant
P. O. Box 1111
Statesville, North Carolina 28677
Attention: Mr. Lenwood F. "Joe" Hudson, Jr.
Director
Subject: Summary of Discussion
April 1, 1992 Meeting
Proposed Discharge from Southern States
Fertilizer Plant to the Fourth Creek
Wastewater Treatment Plant
Statesville, North Carolina
LEI Job No. 56-1570.94
Gentlemen:
On April 1, 1992, Mr. Thomas Beggs of Law Environmental and Mr. Scott Smith of Canonie
Environmental Services Corporation met with Mr. Hudson and Ms. Carol Rogers, Fourth Creek
Wastewater Pretreatment Coordinator. The purpose of our meeting was to discuss several issues
related to discharge of ground water from the Southern States Fertilizer Plant. This letter serves
to summarize the discussion.
PROJECT BACKGROUND
Law and Canonie are continuing to evaluate the feasibility of discharging ground water from the
Southern States property to the Fourth Creek plant. We anticipate that the site will yield a
maximum of 100 gallons per minute, or approximately 50- million gallons per year. Initial
nitrate/nitrite (as nitrogen) concentrations are expected to be 150 mg/l. Concentrations should
decrease with time, and the project is expected to continue for up to ten years.
On February 5, 1992, Law submitted a formal request for authorization to discharge nitrogen -
impacted water to the Fourth Creek plant. Detailed inorganic laboratory analyses of the
proposed discharge were included with the request.
��(J Printed an Recwded Parter

Fourth Creek Wastewater Treatment Plant
April 8, 1992
page 2
The Fourth Creek plant responded to our request in a letter dated February 11. The letter set
forth the following minimum requirements for discharge:
1. Extra -Territorial Agreement to discharge must be executed.
2. Permit to discharge would include the City's option to discontinue acceptance upon
due notice to discharger.
3. Discharger would be billed at current outside sewer rates; $14.32 for the first 300
cubic feet and $4.70 per 100 cubic feet thereafter.
4. Discharger must bear all costs associated with tie-ins.
On February 26, 1992, Law submitted a request for additional information regarding treatment
plant operations. The request was discussed in detail during our April 1 meeting.
DISCUSSION OF PROPOSED DISCHARGE
Mr. Hudson indicated that the Fourth Creek Wastewater Treatment Plant does not possess
denitrification capability. However, minimal denitrification of nitrogen -impacted water may
occur as a secondary benefit of aeration/clarification processes. The plant does not specifically
attempt to remove nitrates or nitrites. If the Southern States effluent is accepted by the plant,
denitrification would not be attempted by the plant prior to discharge of the water into Fourth
Creek.
The Fourth Creek plant is currently experiencing difficulty with solids in the waste stream. The
policy of the plant is therefore to require pretreatment of effluent accepted from outside sources.
The purpose of pretreatment is to minimize the suspended solids content. Carbon filtration or
similar technology would be acceptable for this purpose.
Mr. Beggs noted that the previously submitted inorganic laboratory analyses may not accurately
represent production well effluent. The previous water samples were drawn from small -diameter
monitoring wells. Production wells pumping continuously for extended periods should produce
less turbid ground water.
Production wells have not yet been installed at the site. Therefore, in an effort to simulate
production conditions, the monitoring wells were resampled using a 45 micron nylon filter to
screen suspended solids. The samples were again analyzed for the inorganic parameters, and
the results have been summarized on the attached table. A copy of this table was provided to
Ms. Rogers for review during the meeting.

Fourth Creek Wastewater Treatment Plant
April 8, 1992
page 3
Mr. Hudson indicated that the Fourth Creek plant would adhere to the policy of pretreatment
by carbon filtration and would reserve the right to inspect pretreatment facilities at any time.
The plant would also require that an access valve be provided at the main treatment plant. The
purpose of the valve would be to give plant personnel immediate flow control if unauthorized
constituents are detected in the effluent.
Trenching procedures for tie-in to the plant were briefly discussed during the meeting. Mr.
Hudson indicated that ` the tie-in sewer line from Southern States should be routed around the
Fourth Creek facility to the east. The plant has an extensive network of underground utilities,
and installation of a sewer line through the plant could be disruptive. Mr. Hudson suggested
that Mr. Wayne Lambert, Director of Public Works for the City of Statesville, be contacted
prior to sewer line installation.
The meeting was adjourned with the understanding that Law would issue a letter to document
the discussions. We note that a final determination regarding discharge to the Fourth Creek
plant may be delayed several months, pending review of our plans by the North Carolina
Division of Environmental Management.
If there are any questions regarding this letter, or if our understanding of the topics discussed
is inaccurate, please contact us.
Sincerely,
LAW ENVIRONMENTAL, INC.
Thomas F. Beggs, P.E.
Principal
attachment
cc: Mr. Scott Smith
Canonie Environmental Services Corporation

GROUNDWATER INORGANIC RESULTS
SOUTHERN STATES FERTILIZER PLANT
STATESVILLE, NORTH CAROLINA
LEI JOB NO. 56-1570.94
INORGANICS
Calcium, Total
Filtered
1100
Unfiltered
1470
Filtered
37
Unfiltered
ND
Filtered
14
Unfiltered
370
Filtered
110
Unfiltered
142
Filtered
--
Unfiltered
18.2
Filtered
360
Unfiltered
--
Filtered
850
Unfiltered
11
Filtered
412
Unfiltered
335
Copper, Total
ND
ND
ND
ND
ND
ND
ND
ND
--
0.03
ND
--
ND
0.03
ND
0.01
Iron, Total
ND
4.18
ND
0.14
ND
6.88
ND
ND
--
0.10
ND
--
ND
0.32
ND
1.94
Potassium, Total
10
ND
120
155
2.4
9
17
19.7
--
6.6
5.1
--
30
31.6
30.8
37
Magnesium, Total
120
153
7.9
9.55
2.2
30.5
34
38.8
--
5
37
--
81
11
47
41
Manganese, Total
0.7
1.04
4.8
3.07
0.05
1.77
ND
ND
--
0.02
0.3
--
1.5
0.23
1.225
1.02
Sodium, Total
81
8.86
10
ND
5.5
ND
25
ND
--
6.4
21
--
50
50
32.1
11
Alkalinity
46
32
ND
3.5
1.3
14.5
78
56
--
58
13
--
25
28
27.2
32
Chloride
1200
1270
110
129
26
203
110
110
--
ND
220
--
560
597
371
385
Ammonia, As N
1.1
1.5
57
79.2
ND
ND
0.15
ND
--
ND
0.04
--
19
14.4
12.9
15.9
Nitrite, As N
ND
0.23
0.09
0.17
ND
ND
0.38
13.8
--
ND
ND
--
0.08
ND
0.09
2.37
Nitrate, As N
370
455
160
29.9
8.5
1 163
37
34.7
--
2.4
26
--
37
230
106
153
Phosphate, As P
0.05
0.14
0.09
ND
0.05
1.2
0.13
ND
--
0.34
0.1.
--
0.39
0.3
0.14
0.33
Sulfate
340
653
260
327
ND
345
160
189
--
ND
440
--
1400
1620
433
522
Total Dissolved
Solids
5300
6890
580
637
120
2530
740
757
--
136
1800
--
4100
4760
2106
2618
Total Suspended
Solids
19
1650
ND
33
ND
3490
ND
24
--
6
ND
--
ND
32
3.2
873
pH'
5.8
5.5
4.8
5
5.1
5.4
7.8
7.5
--
8.8
5.8
--
5.7
5.4
5.83
6.27
Specific
Conductivity"
5400
6880
850
1350
150
1810
840
915
--
135
2200
--
4300
4860
2290
2656
Turbidity'"
8.60
1000
ND
14
ND
1840
ND
2
--
0.57
ND
--
ND
4
1.43
477
Notes:
` pH units
• units in umhos/cm
"` units in NTU
Unfiltered samples gathered on October 2, 1991.
Field filtered samples gathered on February 13, 1992. Nylon 45-micron filters used.
1570-TFB/syh

v -
LAW ENVIRONMENTAL, INC.
4333 WILMONT ROAD, SUITE 300
CHARLOTTE, NORTH CAROLINA 28217
P.O. BOX 240674
Feb 26 1992 CHARLOTTE, NORTH CAROLINA 28224-0674
February 704-357-1747 704-357-1622 (FAX)
Mr. Joe Hudson, Director
Fourth Creek Water/Wastewater Treatment Plant
P.O. Box 1111
Statesville, North Carolina 28677
Subject: Request for Additional Information
Proposed Discharge from Southern States
Fertilizer Plant to the Fourth Creek
Wastewater Treatment Plant
Statesville, North Carolina
LEI Job No. 56-1570.94
Dear Mr. Hudson:
We have received your February 11, 1992 correspondence; thank -you for responding so quickly
to our Request for Authorization to Discharge Nitrogen -Impacted Ground Water (letter dated
February 5, 1992).
Law Environmental is continuing to evaluate the feasibility of discharging ground water from
the Southern States property to the Fourth Creek treatment plant. As you recall, we anticipate
that the site will yield a maximum of 100 gallons per minute, or approximately 50 million
gallons per year. Initial nitrate/nitrite (as nitrogen) concentrations are expected to be 150 mg/l.
Concentrations should decrease with time, and the project is expected to continue for up to ten
years.
To assist in our efforts to evaluate the option of discharge to the Fourth Creek Treatment Plant,
we would greatly appreciate your response to the following questions:
1. Does the Fourth Creek Treatment Plant have denitrification equipment?
2. Would the Fourth Creek plant treat the Southern States effluent to reduce the nitrate
concentrations prior to discharge to Fourth Creek?
3. Would it be necessary for Southern States to pre -treat the ground water prior to
discharge? If so, what method(s) of pre-treatment would be required?

Mr. Joe Hudson
February 26, 1992
Page 2
We appreciate your continuing assistance and look forward to hearing from you on these
matters.
Sincerely,
LAW ENVIRONMENTAL, INC.
P. Greg Garrett, E.I.T
Staff Engineer
Thomas F. Beggs, P.E.
Principal

Cntf = -
���t��e� utll�
P. @. +Nux 1111 • -_9+tatesuille. adnrtll Tarulina 28677
February 11, 1992
Mr. Gre- G^—e+t
Law Environmental, Inc.
P. O. Box 240674
Charlotte, NC 28224-0674
Re: Request to Discharge
Southern States Fertilizer Plant
Dear Mr. Garrett:
33ater/gastewater 01reatment Plants
704-878-343 B
Consideration has been given to your request to discharge the referenced water to the
Fourth Creek Wastetreatment Plant.
We are open to considering this favorably after further discussions with you.
In order to assist you in further discussions the following are the minimum requirements
at this time:
1. Extra- i erritorial Agreement to discharge must be executed.
2. Permit to discharge will be issued and include the Citys option
to discontinue acceptance upon due notice to discharger.
3. Discharger will be billed at current outside sewer rates which are
at this time $14.32 for the first 300 cu.ft. and $4.70 per
100 cu. ft. after that.
4. Discharger will have to bear all costs associated with tie-ins
(taps, meters, etc.)

If you would like to continue these discussions please call me at 704-878-3438.
Sincerely,
L. F. "Joe" Hudson, Jr., Director
Water/Wastewater Treatment
LFH/sg
cc: Jack King

c
v —
LAW ENVIRONMENTAL, INC.
4333 WILMONT ROAD, SUITE 300
CHARLOTTE, NORTH CAROLINA 28217
P.O. BOX 240674
CHARLOTTE, NORTH CAROLINA 28224-0674
704-357-1747 704-357-1622 (FAX)
February 5, 1992
Mr. Joe Hudson, Jr.
Director
Fourth Creek Water/Wastewater Treatment Plant
P.O. Box 1111
Statesville, North Carolina 28677
Subject: Request for Authorization to Discharge
Nitrogen -Impacted Ground Water
Southern States Fertilizer Plant
- Hwy. 70 East, Statesville, North Carolina
LEI Job No. 56-1570.94
Dear Mr. Hudson:
As discussed during our January 21, 1992 meeting, Law Environmental is evaluating
alternatives for disposal of nitrogen -impacted ground water from the Southern States
Fertilizer Plant. The plant is located near your facility on Hwy. 70 East, Statesville, North
Carolina.
This letter serves as a request for authorization to discharge ground water recovered from
the Southern States site to the Fourth Creek Water/Wastewater Treatment Plant.
The ground water removal project is being conducted in cooperation with the North
Carolina Department of Environment, Health, and Natural Resources (NCDEHNR). The
NCDEHNR will establish guidelines for the removal of ground water which has been
impacted by nitrates and nitrites.
Southern States plans to begin ground -water extraction from three recovery wells during
1992. Based on the results of an aquifer pump test, we estimate that the site will yield a
maximum of 100 gallons per minute (approximately 50 million gallons per year). Initial
nitrate/nitrite (as nitrogen) concentrations are expected to be approximately 150 mg/1.
Concentrations are expected to decrease with time, and the project is anticipated to continue
for up to ten years.
1570-PGG/syh
��( / Prinfwrl nn Rwrvrlwrl Panwr

Fourth Creek Treatment Plant
- February 5, 1992
Page 2
In addition to nitrates and nitrites, we have analyzed representative ground -water samples
for a broad range of inorganic parameters. Laboratory test results are attached for your
review. We note that the samples were collected from monitoring wells at the site. In our
opinion, the Total Suspended Solids results are not representative of water which will be
drawn from properly designed and fully developed recovery wells.
In an effort to obtain representative ground -water samples to assist you in evaluating our
request, our technicians will resample each monitoring well. The samples will be filtered
in the field using Nalgene pressurized filters (45 micron nylon filter media) to remove
suspended solids. Inorganic parameters will again be analyzed, and laboratory results will
be forwarded to you as they become available.
We hope that the information presented herein will allow you to determine whether ground
water from Southern States can be discharged to the Fourth Creek Treatment Plant. If you
have any questions or require additional information, please do not hesitate to contact us.
Thank -you for your assistance on this project.
Sincerely,
LAW ENVIRONMENTAL, INC.
i
P. Greg Garrett, E.I.T.
Staff Engineer
Thomas F. Beggs, P.E.
Principal
PGG:TFB:syh
1570-PGG/syh

GROUNDWATER INORGANIC RESULTS
STATESVILLE, NORTH CAROLINA
INORGANICS
Sample Identifications
Concentrations
and
in mg/L
6"A"
7"A"
7" F"
7" 1"
6" E"
7° H"
Average
Calcium, Total
1470
ND
370
142
18.2
11.2
335
Copper, Total
ND
ND
ND
ND
0.025
0.025
0.0083
Iron, Total
4.18
0.14
6.88
ND
0.1
0.32
1.94
Potassium, Total
ND
155
9
19.7
6.58
31.6
37.0
Magnesium, Total
153
9.55
30.5
38.8
5
11
41.3
Manganese, Total
1.04
3.07
1.77
ND
0.015
0.226
1.02
Sodium, Total
8.86
ND
ND
ND
6.39
50.3
10.9
Alaklinity
32
3.5
14.5
56
58
28
32.0
Chloride
1270
129
203
110
ND
597
385
Ammonia, as N
1.5
79.2
ND
ND
ND
14.4
15.9
Nitrite, as N
0.23
0.17
ND
13.8
ND
ND
2.37
Nitrate, as N
455
29.9
163
34.7
2.4
230
153
Phosphate, as P
0.14
ND
1.2
ND
0.34
0.3
0.330
Sulfate
653
327
345
189
ND
1620
522
Total Dissolved Solids
6890
637
2530
757
136
4760
2618
Total Suspended Solids
1650
33
3490
24
6
32
873
pH*
5.5
5
5.4
7.5
8.8
5.4
6.27
Specific Conductivity* *
6880
1350
1810
915
135
4860
2656
Turbidity * * *
1000
14
1840
1 2
1 0.57
1 4
477
Note:
pH units
* * units in umhos/cm
* * * units in NTU
Sampling Date = October 2, 1991
ND = Not Detected
1570/syh

3. Department of Transportation Right -of -Way Encroachment Permit

TES: Sep 01 92
14:33 No.044 P.02
„AMFS G. MARTIN
GOVERNOR
T HOMAS J. HARRELSON
SE CRI-1 ARY
COUNTY: lredell
nod
STATE OF NORTH CAROLINA
DEPARTMENT OF TRANSPORTATION
P. 0. BOX 47
SHELBY, NC 28150
August 26, 1992
SUBJECT: Right of Way Encroachment Agreement
US 70, SR 2313, SR 2312
DIVISION OF HIGHWAYS
WILLIAM G. MARLEY. in.. P.E,
STATE HIGHWAY ADMINISTRAZ (')! i
Southern states Cooperative, Inc.
P. 0. Box 26234
Richmond, Virginia 23260
Gentlemen:
Attached is approved Right of Way Encroachment Agreement cover-
ing installation of 2000' of 4" PVC SDR21 pipe on US 70, 1200' of 4" PVC
SDR21 pipe on SR 2333, 2900' of 4" PVC SDR21 pipe on SR 2312, as shown on the
attached map and plan sketch in Iredell County.
Approval is given subject to provisions in the Agreement and
attachments thereto which are made a part; of the Agreement.
It would be appreciated if you would advise our District Office
It Statesville prior to the date of beginning work on this installa-
tion.
The Department of Transportation does not: guarantee the right
of way on this road, nor will it be responsible for any claim for
damages brought by any property owner by reason of the installation.
Please advise, in writing, when this -work has been completed.
Yours very truly,
-rtd
R. W. SPAN DER
DIVISION ENGINEER
TWELFTH DIVISION
: lj
cc, Mr. Doug Allison (Attachments)
Mr. J. W. Rand (Attachments)
An Equal Opportunity/Affirmative Action Employer

STA.JE OF NOPTH CAROL W
CCVWTY OF __jg'=f3j_
PALMATE •
m
Dum.,PrEwT of imrspon�rpcw RIGHT OF ImY L'HCP.W?"ENT ncittumm
Pg'rbiRY hKo SECDHOMY HIGIfw"
-mo-
IHC-
F:JchoV-. Tj,timt. 230
TPII5 AMEthElT. "It, and Into this the 2L d4r of
Q
Department of party of t Tj:D he �jt tart: a- S(HrTHK
by am lbetw� the
pa, ty mf the second part,
wp';*E5SETH1
desires to C. tt-, right of .wry
THAT WKII.EAS. V'le party of the second pqrt
or the p,,&iis rwd bes Ignored as P.s.Ie 7,_
9.4
Mcul
of d,,tjwjty conferrederrd
'JilFFIM. 11 Ill to tI, otstertal Aid ... ta:e of tf,e party of the s.c,,,d oart to effectthis%
encr�omnt, and the party of the I 1tt varL In theearei ae
the lrolits Of the right
by statute, ;.& ,,1111AT e. mmit the ocro"Inent within
&object to The ccndjt,'o,ns of thls mgrearentj
of 3 mic I.
TW_PEFOq. IT 15 Arv.T.ED that III oarty of th� First part h-reby grants to the
Y
mow,
tart the r1uht and itrz,,l I,,qv this nclo�tm-t as she"I" on
part party or Ism second
�e t W. speclflcatlmi awd Sp eCial h;cb are nade
mtlacj�ed Ilan -
hereof upon I hse.'"Falle-i.9 oondllll . to At:
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4. Norfolk Southern Railroad Encroachment Permit

NORFOLK
SOUTHERN
Norfolk Southern Corporation
Transportation Department
1120 W. Washington Street
Greenville, South Carolina 29601
803 255-4335
August 12, 1992 HN/sa
4-6-3-Elmwood, NC
Mr. Thomas F. Beggs
Law Environmental, Inc.
4333 Wilmont Road, Suite 300
Charlotte, NC 28208
Dear Mr. Beggs:
D. N. Zureich
Superintendent
Piedmont Division
Please refer to yours of May 8, 1992 making application
for a pipeline crossing located at Milepost S-20 plus 1107 feet
to point of switch plus 445.6 feet on spur track, Elmwood, NC.
This is to advise that the subject crossing has now
been approved by our Engineering Department and an agreement to
cover will be furnished in the near future.
We ask that you notify the following at least one week
prior to making the installation:
Ms. Sheila M. Howie
[phone]
Mr. A. D. Felty
[phone]
Track Supervisor, J. L. Manning
[phone] or [phone]
With insurance requirements met, an emergency i need to
install prior to executing the agreement will be considered by
this office; however, a letter of intent to execute the
agreement must be received. A letter of intent cannot be
accepted if you desire to participate in Norfolk Southern's
Master Railroad Protective Liability Insurance Program.
v truly yours,
a
. N. Z reic
AA
Superintend
Operating Subsidiaries: Norfolk Southern Railwav Company / North American Van Lines, Inc.

5. Statement Of Financial Qualification

Southern States
Cooperative, Inc.
6606 West Broad Street
Post Office Box 26234
Richmond, Virginia 23260
Telephone [phone]
9J
Southern
States
August 28, 1992
State of North Carolina
Department of Environment, Health and Natural Resources
Division of Environmental Management
512 N. Salisbury Street
Raleigh, NC 27611
Dear Sir:
In accordance with North Carolina Statute 143-215.1 (4)b, this
letter and the enclosed annual report are submitted to
demonstrate Southern States Cooperative's financial abilitv to
complete the activity proposed in our application for a permit
to discharge ':taste water into waters of the state.
The anticipated costs to construct the proposed system is
approximately S510,000, and the projected annual costs of
operation are not expected to exceed S100,000 per year.
Favorable consideration cf the permit for which this letter is
furnished will be appreciated.
Siptcer ly,
a an A. Hawkins
enior Vice President
Chief Financial Officer

rd
7u�rcalyta teHre�ts
Consolidated Balance Sheet, June 30, 1991 and 1990
Southern States Cooperative, Inc. and Subsidiaries
Assets
1991
1990
Current assets:
Cash
$ 5,296,340
$ 9,509,825
Receivables, net (Notes 4 and 6)
42,432,339
51,445,751
Inventories (Notes lb and 5)
97,890,788
92,304,911
Refundable income taxes
298,662
755,861
Prepaid expenses
5,800,814
5,144,810
Deferred income taxes
3,972,741
2,103,678
Deferred charges
592,607
26,605
Total current assets
156,284,291
161,291,441
Investments and other assets:
Investments:
Finance company (Notes la and 6)
9,922,703
9,877,820
Other (principally cooperatives) (Notes ld and 7)
44,742,800
42,516,741
Receivables (Notes 4 and 6)
1,860,928
1,200,500
Industrial revenue construction fund
3,483,399
Deferred charges
410,943
372,935
Total investments and other assets
60,420,773
53,967,996
Property, plant and equipment (Notes lc and 8)
190,512,534
179,748,234
Less accumulated depreciation
107,911,737
98,668,561
Property, plant and equipment, net 82,600,797 81,079,673
$ 299,305,861 $ 296,339,110
%8

SOUTHERN
STATES
Liabilities and Stockholders' and Patrons' Equity
1991
1990
Current liabilities:
Short-term notes payable (Note 9)
$ 2,500,000
Current maturities of long-term debt (Note 10) $
2,064,795
970,332
Accounts payable
48,755,152
45,893,255
Accrued expenses:
Environmental remediation (Note 15b)
1,815,495
1,679,194
Payrolls, employee benefits, related taxes and other
14,861,694
16,035,352
Accrued income taxes
10,209
54,907
Dividends payable
677,645
761,586
Patronage refunds payable in cash
1,594,591
1,347,338
Advances from managed member cooperatives (Note 3)
9,294,704
10,333,006
Common stock called for redemption
37,842
Total current liabilities 79,074,285 79,612,812
Long-term debt (Note 10) 86,282,428 85,177,959
Other noncurrent liabilities:
Deferred compensation 1,688,306 1,544,769
Deferred income taxes (Notes le and 13) 4,096,250 3,305,065
Environmental remediation (Note 15b) 483,408 461,486
Miscellaneous 48,742 318,779
Total other noncurrent liabilities 6,316,706 5,630,099
Stockholders' and patrons' equity:
Stockholders' equity:
Capital stock (Note 11):
Preferred 13,382,900 15,319, 700
Common 10,398, 740 10,532, 741
Total stockholders' equity 23,781,640 25,852,441
Patrons' equity 103,850,802 100,065,799
Total stockholders' and patrons' equity 127,632,442 125,918,240
$ 299,305,861 $ 296,339,110
See accompanying notes to consolidated financial statements.
19

e�'tate�re�rts
Consolidated Statement of Operations
for the years ended June 30, 1991 and 1990
1991
1990
Sales and other operating revenue:
Net purchases by patrons (Note 3)
$861,644,711
$ 788,077,881
Net marketing for patrons
80,644,968
86,438,994
Other operating revenue
2,944,290
2,855,295
945,233,969
877,372,170
Cost of products purchased and marketed
and other operating costs (Notes lb, 7
and 15b)
793,285,711
7371525,282
Gross margin
151,948,258
139,846,888
Selling, general and administrative expenses
137,113,716
127,668,468
Savings on operations
14,834,542
12,178,420
Other deductions (income):
Interest expense (Notes 6, 9 and 10)
12,152,349
11,884,108
Interest income and service charges
(Note 3)
(3,707,408)
(3,272,422)
Miscellaneous income, net
(2,939,413)
(3,501,046)
5,505,528
5,110,640
Savings before income taxes
9,329,014
7,067,780
Income taxes (Notes le and 13)
2,125,917
1,457,537
Net savings
$ 7,203,097
$ 5,610,243
See accompanying notes to consolidated financial statements
20

f JrF,
LLd
SOUTHERN
STATES
Consolidated. Statement o f Patrons' Equity
for the years ended June 30, 1991 and 1990
1991 1990
Patronage refund allocations:
Balance, beginning of year $ 46,731,115 $ 45,183,881
Allocation from net savings for the year 2,294,656 1,938,851
Adjustments to prior year's allocation (96,719) (35,824)
Redemptions (363,386) (355,793)
Balance, end of year 48,565,666 46,731,115
Operating capital:
Balance, beginning of year
53,334,684
51,447,369
Savings from operations
7,203,097
5,610,243
Patronage refunds payable in:
Cash
(1,594,591)
(1,347,338)
Patronage refund allocations
(2,294,656)
(1,938,851)
Adjustments to prior year's estimated patronage
refunds, net of income taxes
96,065
41,283
Reduction in common stock and debentures
called for redemption
314,911
1,435,376
Dividends on capital stock:
Preferred, principally $7.50 per share
(1,151,359)
(1,278,490)
Common, $.06 per share
(623,015)
(634,908)
Balance, end of year 55,285,136 53,334,684
Total patrons' equity $103,850,802 $100,065,799
See accompanying notes to consolidated financial statements.
21

0
/51tciaIsta& wo&
Consolidated Statement of Cash Flows
for the years ended June 30, 1991 and 1990
1991
1990
Operating activities:
Net savings
$ 7,203,097
$ 5,610,243
Adjustments to reconcile net savings
to cash provided by operating activities:
Depreciation and amortization
12,289,376
11,869,722
Deferred income taxes
(1,077,878)
(1,598,252)
Gain on sale of property and equipment
(794,015)
(326,212)
Undistributed earnings of finance company
(44,883)
(55,926)
Noncash patronage refunds received
(1,630,079)
(2,589,828)
Cash provided by current assets and liabilities
(Note 16)
2,085,243
949,026
Cash provided by operating activities
18,030,861
13,858,773
Investing activities:
Additions to property, plant and equipment
(14,632,681)
(10,501,974)
Proceeds from disposal of property and equipment
1,616,196
2,101,183
Acquisition of The Wetsel Seed Co., Inc.
(net of $98,204 cash acquired)
(2,530,355)
Payments received from TCR
2,000,000
Additional investments in other companies
(124,461)
(295,420)
Industrial revenue construction fund
(3,483,399)
Redemption of investments in other companies
26,562
1,015,722
Cash used in investing activities
(16,597,783)
(8,210,844)
Financing activities:
Net decrease in short-term notes payable
(2,500,000)
(1,025,000)
Proceeds from long-term debt
8,168,000
11,500,000
Repayment of long-term debt
(5,969,068)
(9,615,650)
Cash dividends paid
(1,840,385)
(1,992,117)
Patronage refunds paid in cash
(1,347,338)
(1,362,868)
Redemption of patrons' equity
(2,195,706)
(2,033,733)
Proceeds from sale of capital stock
37,934
32,207
Cash used in financing activities
(5,646,563)
(4,497,161)
(Decrease) increase in cash
(4,213,485)
1,150,768
Cash at beginning of year
9,509,825
8,359,057
Cash at end of year
$ 5,296,340
$ 9,509,825
See accompanying notes to consolidated financial statements.
22

1.Sumrnary or Significant Accounting Policies:
a. Basis of Presentation - The consolidated financial state-
ments include the accounts of Southern States Cooperative,
Inc. ("Southern States") and its wholly owned subsidiaries
(the "Company"). Upon consolidation, all significant
intercompany accounts and transactions have been elimi-
nated. Southern States' investment in Statesman Financial
Corporation, a 50%-owned finance company, is accounted
for by the equity method (see Note 6).
b. Inventories and Cost o f Products Sold - Inventories, except
grain, are stated at the lower of cost or market. Cost is
determined on various bases, including average, first -in, first -
out, and specific- identification. Inventories of grain are
stated at net market, as adjusted for unrealized gains and
losses on hedged open purchase and sales contracts. Grain
inventories are substantially hedged to minimize risks arising
from market fluctuations. Patronage refunds from supplier
cooperatives in the form of qualified written notices of
allocation are recorded as received and are accounted for as
reductions of cost of products purchased. Nonqualified writ-
ten notices of allocation are not recorded until the cash is
received.
c. Property, Plant and Equipment - Property, plant and
equipment is recorded at cost. The costs of property addi-
tions, major renewals and betterments are capitalized while
the costs of ordinary maintenance and repairs are charged to
operations as incurred. The costs of property additions in-
clude interest capitalized during major plant construction.
Depreciation is determined principally by the straight-line
method based on estimated useful lives (buildings and im-
provements - 20 to 40 vears; machinery and equipment - 4 to
20 years). Gains and losses on disposition or retirement of
assets are reflected in income as incurred.
d. Investments - Investments, principally in supplier coop-
eratives, are stated at cash invested plus unpaid qualified
written notices of allocation.
e. Income Taxes - For income tax purposes, Southern States
is a nonexempt agricultural cooperative. Accordingly, the
Company does not pay income taxes on that portion of
savings paid in qualified written notices of allocation arising
from sales to members, patrons eligible for membership and
certain other patrons; such savings are included in the
taxable income of these members and patrons. Deferred
income taxes are provided on amounts resulting from timing
differences between financial statement and income tax
reporting of certain income and expenses (principally depre-
ciation, future employee benefits, environmental remediation
costs, inventory costs and bad debts).
f. Employee Retirement Plan - The employees of the Com-
pany are covered under a multiemployer defined benefit
plan. The Company's policy is to fund and expense an
amount equal to the Company's share of the actuarially
determined funding requirement of the plan.
g. Common Stock and Patronage Re funds Payable - South-
ern States is an agricultural cooperative operating for the
benefit of its stockholders/members and other patrons. Pur-
suant to its bylaws, Southern States is obligated to return all
patronage sourced savings for each year, after payment of
dividends on capital stock and reasonable additions to capital
reserves, to such members, patrons eligible for membership
and certain other patrons in proportion to the volume of
business transacted with them during the year. See Note 11
with respect to requirements for membership and common
stock ownership.
li.Reclassi fications - Certain reclassifications have been made
to the 1990 financial statements to conform to the 1991
presentation.
2. Acquisition:
Pursuant to an Agreement and Plan of Merger (the "Agree-
ment") dated November 30, 1989, a wholly owned subsidiary
of Southern States (the "Subsidiary") acquired, in a purchase
transaction, all of the outstanding common stock of The
Wetsel Seed Companv, Incorporated ("Wetsel") on January 2,
1990 in exchange for the following consideration:
a. $1,813,900 in cash and $1,736,100 in the Subsidiary's
Series 1 Class A cumulative redeemable 9% preferred stock
($100 par value; see Note 11) ("9% Redeemable Preferred");
b. $537,600 in cash and S512,600 in the Subsidiarv's 9%
Redeemable Preferred, placed in escrow and subject to charges
for certain expenses, fees and losses (e.g., losses arising from
environmental matters) ("Losses"), with any remaining bal-
ance payable to Wetsel's stockholders on December 31, 1991;
and
c. Up to $2,400,000 in cash and/or the Subsidiary's 9%
Redeemable Preferred, if any, if the Subsidiary achieves cer-
tain financial results in the five fiscal years subsequent to July
1, 1989 ("Earnout Merger Consideration").
The Agreement stipulates that Losses in excess of the total
funds available in escrow will reduce the Earnout Merger
Consideration. The Agreement further provides remedies to
the Company or its subsidiaries from Wetsel's stockholders
for any Losses in excess of any of the Earnout Merger Consid-
eration. The Subsidiary's 9% Redeemable Preferred is redeem-
able at par value plus any accrued and unpaid dividends, at
the option of either the Subsidiary or the holder, five years
after its issuance.
Effective with the acquisition, the name of the Subsidiary was
changed to The Wetsel Seed Company, Inc. The Company's
consolidated financial statements include the operating re-
sults of the Subsidiary since January 2, 1990.
3. Managed Member Cooperatives:
Under management agreements, Southern States performs
various financial, accounting and management services for
other agricultural cooperatives ("managed member coopera-
tives"). There were 75 and 76 such cooperatives at June 30,
1991 and 1990, respectively. These managed member coop-
eratives are owned entirely by their stockholders and patrons
and thus are associated with Southern States solely by man-
agement agreements (the "Agreements"). For services per-

N�
formed, Southern States was reimbursed in the amount of
6. Investment in Finance Company:
53,006,121 in 1991 and $3,079,787 in 1990.
Statesman Financial Corporation (SFC„) is a 50%-owned
Under the Agreements, cash is advanced by Southern States
affiliate of Southern States.
(primarily as revolving advances for sales of products) and
excess cash of the managed member cooperatives is advanced
Southern States owns 9,718 shares of Class A preferred stock
to Southern States. The interest rate charged or credited on
which are recorded at their total par value of $9, 718,000.
monthly balances of these advances approximates the Na-
SFC's authorized common stock consists of 690 shares ($100
tional Bank for Cooperatives seasonal loan rate. Net interest
par value) of which one-half is owned by Southern States and
income realized by Southern States on net advances totaled
one-half by 69 managed member cooperatives. Southern
S288,416 and $309,164 in 1991 and 1990, respectively.
States accounts for its 50% ownership in SFC by the equity
method.
Net purchases by patrons include purchases by managed
member cooperatives of approximately $166,000,000 in 1991
SFC and Southern States are parties to an agreement under
and $152,000,000 in 1990.
which SFC purchases, with recourse, a portion of Southern
States' receivables. Under the terms of the agreement, South-
4. Receivables:
ern States pays a fee of 1/8% of receivables sold (subject to a
The Company grants credit to farmers and other retail and
minimum of $5,000 per month) to SFC. In addition, the
wholesale purchasers of agricultural production supplies pri-
receivables are discounted at an amount sufficient to provide
manly in Delaware, Kentucky, Maryland, North Carolina,
SFC with revenues equal to at least 100% of interest charges
Virginia and West Virginia. Receivables at year end are as
incurred on related indebtedness. Receivables sold to SFC
totaled $564,014,000 and $503,779,000 for 1991 and 1990,
follows: 1991 1990
p y' res ectivel The related fees and discounts for 1991 and 1990
Current:
were $3,237,000 and $3,044,000, respectively.
Trade:
SFC has entered into operating lease agreements with South -
Accounts $ 97,605,908 $80,295,765
ern States whereby Southern States leases computer equip -
Notes 1,944,920 1,814,884
Advances to managed member
ment, an airplane and liquid propane tanks from SFC. The net
cooperatives (Note 3) 19,722,931 17,010,228
book value of the assets leased to Southern States by SFC
Less receivables sold to
totaled $2,784,079 and $126,232 as of June 30, 1991 and
Statesman Financial
1990, respectively. Total operating lease expenses incurred by
Corporation (Note 6) (75,032,589) (46,032,589)
Southern Statesunderthe leasing agreements totaled $462,000
and $27,000 in 1991 and 1990, respectively.
44,241,170 53,088,288
Southern States' 50% share of SFC's net income has been
Less allowance for doubtful
included in the Company's consolidated statement of opera -
accounts (1,808,831) (1,642,537)
tions as a reduction of interest expense.
Total current receivables $42,432,339 $51,445,751
A summary balance sheet and statement of operations for SFC
Noncurrent:
as of June 30, 1991 and 1990 and for the vears then ended are
Notes:
shown below:
Trade $ 860,928 S 200,500
TCR (Note 14) 1,000,000 1,000,000
Balance Sheet
1991 1990
Total noncurrent
Assets
receivables $ 1,860,928 $ 1,200,500
Cash $ 147,254 $ 209,522
5. Inventories:
Receivables:
Receivables purchased from Southern
Inventories at year end consist of the following:
States Cooperative, Inc. 75,032,589 46,032,589
Installment contracts 7,014,668 7,119,646
1991 1990
Asset -based loans 5,619,997 4,992,699
Finished goods:
Southern States Cooperative, Inc. 590,773 618,660
Purchased for resale $80,154,230 $74,177,669
Investment in National Bank for
Manufactured 8,344,450 9,294,552
Cooperatives capital stock 3,182,645 2,983,021
Property, plant and equip-
88,498,680 83,472,221
ment, net 2,823,926 151,386
Materials and supplies 9,392,108 8,832,690
Other assets 209,023 148,773
Totals $97,890,788 $92,304,911
Total assets $94,620,875 $62,256,296
24

Liabilities and
Stockholders' Equity
1991
1990
Notes payable -National Bank for
Cooperatives:'
Short-term line of credit
$69,696,300
$46,950,000
Term loan
14,300,000
5,000,000
Accounts payable and accrued
expenses
537,878
323,940
Dividends payable
49,077
49,577
Stockholders' equity
10,037p620
9,932,779
Total liabilities and
stockholders' equity
S 94,620,875
$62,256,296
Statement of
Operations
Revenues
$ 5,864,606
$ 5,196,792
Expenses:
Interest
4,199,956
3,812,525
Other
1,422,949
1,207,508
5,622,905 5,020,033
Income before income taxes 241,701 176,759
Income taxes 86,783 64,906
Net income $ 154,918 5 111,853
Southern States' equity
interest $ 77.459 S 55.926
*SFC has a Master Loan Agreement with the National Bank for
Cooperatives ("CoBank") that provided for a $70,000,000
seasonal line of credit (subject to certain net worth restric-
tions) and a $15,000,000 term loan at June 30, 1991, The
seasonal line of credit, which expires on December 16, 1991
was reduced to $60,000,000 on August 12, 1991. The line of
credit borrowings of $69,696,300 at June 30, 1991 are due
December 16, 1991 and bear interest at varying rates estab-
lished by CoBank (approximately 7% at June 30, 1991).
Average daily seasonal and term loan borrowings were ap-
proximately $55,730,000 during 1991 and $45,983,000 dur-
ing 1990 and the weighed average interest rates were 7.54%
and 8.28%, respectively, during 1991 and 1990. The
514,300,000 term loan is due on December 16,1999 and bears
interest at varying rates established by CoBank (7.25% to
9.65% at June 30, 1991). SFC is required to maintain invest-
ments in CoBank's stock and allocated equities based on
percentages of the average loans outstanding. These invest-
ments are pledged as collateral for the notes payable.
7. Investments in Other Companies:
Investments in other companies consist of the following at
yearend:
1991
1990
CF Industries, Inc.
$25,159,577
$25,159,577
National Bank for Cooperatives
6,558,218
6,283,867
Southern States Insurance
Exchange
6,978,634
5,689,064
Universal Cooperatives, Inc.
3,633,753
3,545,132
Farmers Chemical Association, Inc.
643,600
643,600
Other Cooperatives
840,369
764,832
Miscellaneous
928,649
430,669
Totals
$44,742,800
$42,516,741
At June 30, 1991 and 1990, the Company's aggregate equity
in the net assets of these investees exceeded the carrying value
of such investments by approximately $8,700,000 and
$7,000,000, respectively. Patronage refunds received for 1991
and 1990 were as follows:
1991 1990
CF Industries, Inc.
$ 2,966,779
$ 1,323,530
National Bank for Cooperatives
321,950
531,740
Southern States insurance
Exchange
1,283,899
2,026,976
Universal Cooperatives, Inc.
177,241
380,786
Other
196
253
Totals
S 4,750,065
$ 4,263,285
Purchases by Southern States from CF Industries, Inc. and
Universal Cooperatives, Inc. were approximately $70,050,000
and $67,821,000 in 1991 and 1990, respectively.
8. Property, Plant and Equipment.
Property, plant and equipment at year end is summarized as
follows:
1991 1990
Land
$ 13,712,777
S 14,946,622
Buildings and improvements
59,558,663
57,292,454
Machinery and equipment
67,794,568
59,202,860
Furniture and fixtures
21,792,862
20,422,161
.automotive equipment
23,324,108
26,770,960
Construction in progress
4,329,556
1,113,177
Totals $ 190,512,534 S179,748,234
At June 30, 1991, property, plant and equipment having an
aggregate book value of $8,885,208 was pledged as collateral
under industrial revenue financings (see Note 10).
Included in cost of property, plant, and equipment for 1991
is interest capitalized in the amount of $30,109.
9. Short -Term Notes Payable:
At June 30, 1991, the Company had a $ 70,000,000 short-term
line of credit with CoBank and short-term lines of credit with
other institutions totaling $62,000,000 which generally do
not require the maintenance of compensating balances be-
cause credit extension is subject to availability of funds. At
June 30, 1990, short-term notes of $2,500,000 with interest at
8.85% were payable to CoBank.
During 1991, average daily short-term borrowings were ap-
proximately $16,300,000 (maximum outstanding -
$47,500,000) at a weighted average interest rate approximat-
ing 7.28%. During 1990, such borrowings averaged approxi-
mately $14,850,000 (maximum outstanding - $40,000,000)
at a weighted average interest rate approximating 8.67%.
These rates were computed net of patronage refunds received
from CoBank.
SOUTHERN

lO.Long-Term Debt
Long-term debt at year end consisted of:
Term note—CoBank due
1999, 9.66% and 9.55% at
June 30, 1991 and 1990,
respectively (A)
Term note —Aetna Life Insurance
Company due 2000, 9.25% pe;
annum (B)
Industrial revenue financings (C)
Capital lease obligations
Debenture bonds and notes due
through 2001(max. rate 10%)
1991 1990
$48,258,000 $51,100,000
25,000,000 25,000,000
14,914,999 9,845,833
15,493 44,775
158,731 157,683
Total long-term debt 88,347,223 86,148,291
Less current maturities (2,064,795) (970,332)
Long-term debt due after
one year $86,282,428 S85,177,959
(A)The term notes with CoBank are payable S7,950,000 in
1993, $21,058,000 in 1994, $7,950,000 in 1995, $6,700,000
in 1996, $2,200,000 in 1997 and S1,200,000 annually in
1998-1999. Under the terms of the short-term and long-term
loan agreements with CoBank, which provide for interest at
variable rates, the Company is required to maintain invest-
ments in CoBank's capital stock and allocated equities based
on percentages of the average loans outstanding. At June 30,
1991, investments in the amount of $6,558,218 were pledged
as collateral for indebtedness to CoBank.
(B)The Senior Notes, Series A (the "Notes") issued to Aetna Life
Insurance Company and due August 4, 1999 are payable
S1,000,000 annually 1992-1996, $2,000,000 in 1997 and
$6,000,000 annually 1998-2000. The Company may prepay
the Notes during the periods ending August 4, 1998 and
August 4, 1999 at 102% and 101%, respectively, of the
outstanding principal.
(C) Six industrial revenue financings require payments suffi-
cient to enable the industrial development authorities to pay,
as required, the principal, premium, if anv, and interest on
the revenue bonds. The obligations mature serially in the
following annual amounts - $1,038,333 in 1992, $1,073,333
in 1993, $1,098,333 in 1994, $1,633,333 in 1995, $1,213,333
in 1996 and in varying amounts ranging from $500,000 to
S1,620,000 annually in 1997-2006. The obligations bear
interest at rates ranging from 5.00% to 8.25%.
Long-term debt maturing within each of the four fiscal years
after June 30, 1992 is as follows: 1993 - $10,042,515; 1994 -
$23,167,727; 1995 - $10,595,921; and 1996 - $8,927,239.
Under the most restrictive outstanding debt agreement, the
Company is required to maintain, at fiscal year end, on a
consolidated basis: (a) working capital of at least $65,000,000;
(b) a ratio of current assets to current liabilities of at least 1.6
to 1; (c) net worth of at least 39% of total assets and not less
than $115,000,000; and (d) a ratio of adjusted long-term debt
to net worth not to exceed .75 to 1.
11.Capital Stock:
Southern States' authorized capital stock consists of 20,000,000
shares of common stock ($1 par value); 200,000 shares of
cumulative preferred stock ($100 par value), issuable in series,
the redemption of which is limited to 20,000 shares annually;
and 130,000 shares of NC Redeemable Preferred Stock ($100
par value). The Subsidiary has authorized 22,487 shares of 9%
Redeemable Preferred ($100 par value) (see Note 2). The NC
Preferred Stock is nonvoting (except as provided by statute),
is junior to other existing preferred stock but prior to the
common stock, and has fixed preferences as to dividends and
liquidation. Such shares are subject to mandatory redemp-
tion by Southern States-18,600 shares ($1,860,000) annually
July 15, 1992 through July 15, 1995 and 18,400 shares
($1,840,000) on July 15, 1996 at par value plus any accrued
and unpaid dividends. The 9% Redeemable Preferred is re-
deemable at par value plus any accrued and unpaid dividends,
at the option of either the Subsidiary or the holder, five years
after its issuance.
Southern States' authorized common stock is membership
common stock and, pursuant to the requirements of the
Agricultural Cooperative Association Act of Virginia and the
Company's Articles of Incorporation and bylaws, its issuance
or transfer is limited to bona fide producers of agricultural
products and cooperative associations that are owned and
controlled by such producers who use the services or supplies
of Southern States. Dividends on Southern States' common
stock are limited annually to 6% of its aggregate par value.
Each member, regardless of the number of shares of common
stock registered in the member's name, is entitled to one vote
in the affairs of the Company. Under various circumstances
the Company repurchases common stock from its members
at par value plus declared and unpaid dividends, if any. In the
event of liquidation or other disposition of the Company's
assets, the holders of common stock, after satisfaction of
obligations to holders of all preferred stock, would be entitled
to receive a maximum of $1 per share (par value) plus declared
and unpaid dividends, if any.
�5

Changes in preferred stock ($100 par) and common stock ($1 par) during 1990 and 1991 were as follows:
7 1/2%
9%
5%-6% Preferred
Redeemable NC Preferred
Redeemable Preferred
Aggregate
Aggregate
Aggregate
Shares
Par Value
Shares
Par Value
Shares
Par Value
Balances,
June 30, 1989
20,204
$2,020,400
130,000
$13,000,000
Issued
272
27,200
22,487
S2.248,700
Redeemed
(1,166)
(116,600)
(18,600)
(1,860,000)
Balances,
June 30, 1990
19,310
1,931,000
111,400
11,140,000
22,487
S2,248,700
Issued
281
28,100
Redeemed
(1,049)
(104,900)
(18.600)
(1,860,000)
Balances,
June 30, 1991
18,542
$1,854,200
92,800
$9,280,000
22,487
S2,248,700
12. Employee Benefit and Compensation Plans:
Southern States sponsors a multiemployer defined benefit
retirement plan (the "Plan") which is noncontributory and
includes substantially all employees of Southern States and 75
managed member cooperatives. For 1991 and 1990, Southern
States' expenses, including administrative expenses, were
S2,705,756 and $2,497,380, respectively. A comparison of
accumulated benefits and net assets of the Plan, as estimated
by the Plan's actuary, is presented below. The information
relating specifically to Southern States' employees is not
available.
July 1
1990 1989
,-Actuarial present value of plan
benefits:
Vested $ 63,722,232 $60,903,825
Nonvested 2,462,446 1,971,306
Total benefits $ 66,184,678 $62,875,131
Net assets available
for benefits $80,193,688 $75,636,510
Under Southern States' 401(k) plan, Southern States matches
employee contributions and may make discretionary contri-
butions. Employee contributions are matched to the extent of
40% of the participant's first 3% contributed and 15% of the
next 2% contributed. Southern States' matching contribu-
tions for 1991 and 1990 were $474,883 and $334,125, respec-
tively. Effective January 1, 1991, the Subsidiary profit sharing
plan was merged into the Southern States' 401(k) plan (See
Note 2).
Common
Aggregate
Shares Par Value
11,202,627 $11,202,627
5,007 5,007
(674,893) (674,893)
10,532,741 10,532,741
9,834 9,834
(143,835) (143,835)
10,398,740 S10,398,740
Southern States provides certain medical and life insurance
benefits for retired employees. Substantially all of Southern
States' employees may become eligible for those benefits,
generally upon attaining normal retirement age while em-
ployed by Southern States. Those and similar benefits for
active employees are provided through an insurance com-
pany whose premiums are based on benefits paid. Southern
States recognizes the cost of providing these benefits by
expensing the annual insurance premiums. For 1991, the
premiums for retired employees were S22,266 for life insur-
ance and $827,303 for medical insurance. For 1990, such
premiums were $19,815 and $335,020, respectively.
In December 1990, the Financial Accounting Standards Board
issued Statement of Financial Accounting Standards No. 106,
"Employers' Accounting for Postretirement Benefits Other
Than Pensions" ("SFAS 106"). The new standard requires
companies to accrue the cost of such benefits, primarily
health care and life insurance, during the employee's period
of service rather than the current practice of recognizing costs
as claims are paid. The standard must be adopted during the
Company's 1994 fiscal year. The Company has not com-
pleted the complex analyses required to determine the full
impact of SFAS 106; however, the Company believes that
even though adoption will most likely result in higher em-
ployee benefit expense, adoption will not impact cash flow
and will not have a material adverse effect on the Company's
financial position.
Southern States has in effect other compensation plans for
key management and retail branch personnel under which
current and deferred awards, based principally on operating
results, are made. The aggregate charge to operations with
respect to these plans approximated $1,095,000 in 1991 and
$1,121,000 in 1990.
SOUTHERN

13. Income Taxes:
Income taxes are composed of the following:
1991 1990
Current:
Federal S 2,813,767 5 2,607,754
State 390,028 448,035
Total current 3,203,795 3,055,789
Deferred federal and state (1,077,878) (1,598,252)
Total $ 2,125,917 3 1,457,537
The significant differences between the U.S. federal statutory
income tax rate and the effective income tax rate are as
follows:
1991 1990
Statutory federal income tax rate 34.0% 34.0%,
Patronage refunds deduction (14.2)
State income taxes, net of federal benefit 1.7 2.1
Other, net 1.3 0.3
Effective tax rate 22.8% 20.6%,
The Company has deferred adoption of Statement of Finan-
cial Accounting Standards No. 96, "Accounting for Income
Taxes" ("SFAS 96"). When adopted, SFAS 96 will change the
method of calculating the provision for income taxes, but will
have no impact on actual tax payments. Based on statutory
income tax rates currently in effect, management does not
expect that the adoption of SFAS 96 will have a significant
impact on the Company's financial position or future net
income.
14. Texas City Refining Investment:
On June 30, 1988, Texas City Refining, Inc. ("TCR") (33-1/3%
owned by Southern States) sold its refinery segment, which
represented a substantial portion of TCR's operations, to
Phibro Refining - Texas City, Inc. ("Phibro"), an affiliate of
Hill Petroleum Company, for $33,000,000. The sale agree-
ment provided for contingent compensation to TCR of up to
$5,000,000 based upon future prices of crude oil and up to
$15,000,000 based upon future profits of the refinery sold to
Phibro. As of June 30, 1991 crude oil prices did not meet the
prescribed levels for contingent compensation, therefore
relieving. Phibro of the obligation to make the $5,000,000
contingent payment to TCR. The remaining S15,000,000 of
contingent compensation will be payable to TCR after June
30, 1993 if the conditions of the sale agreement are met. The
Company has a $1 million receivable from TCR which it
expects to recover from TCR's disposition of its remaining
assets (See Note 4).
15.Commitments and Other Matters:
a. Leases - Southern States is a party to an agreement whereby
an investment company (the "Owner") constructed, on land
owned by Southern States and leased to the Owner for a 70-
year term expiring in 2048, a headquarters building for lease
to Southern States. Under the terms of the building lease,
Southern States is obligated to pay rent (net of income from
the land rental) based upon the cost of the building and
executory costs such as insurance, maintenance and property
taxes. This operating lease has an initial term of 30 years,
expiring in October 2008, and contains options allowing
Southern States to renew the lease for two additional five-year
periods and to purchase the building, at certain times through-
out the lease, at the greater of the building's original cost or
its then fair market value as defined in the lease. Should
Southern States not exercise its purchase option by the
expiration of the building lease, the Owner has options,
exercisable throughout the remaining term of the land lease,
to purchase the land at its then fair market value.
In addition, the Company leases transportation, data process-
ing and other equipment under operating leases expiring
generally during the next five years. Rental expense approxi-
mated $6,594,000 in 1991 and $6,565,000 in 1990.
The Company's approximate minimum lease commitments
under noncancellable operating leases, less noncancellable
subleases, are as follows:
Office Building
Year Equipment Lease Subleases Totals
1992 S3,439,000 S 736,000 5(600,000) S 3,575,000
1993
2,315,000
1-36,000 (157,000)
2,894,000
1994
2,100,000
740,000
2,840,000
1995
1,175,000
742,000
1,917,000
1996
678,000
742,000
1,420,000
Thereafter
253,000
9,096,000
9,349,000
b. Other Matters -The Company's 1991 and 1990 consoli-
dated statement of operations includes a provision in cost of
products purchased and marketed and other operating costs
of $2,008,700 and $3,122,707, respectively, to cover esti-
mated environmental remediation costs. The unpaid por-
tion of such costs totaled $2,298,903 and $2,140,680 at June
30, 1991 and 1990, respectively, and is included as a liability
in the Company's consolidated balance sheet for the respec-
tive years. The remaining actual environmental remediation
liability may be different from management's estimates due
to: the uncertainty of the extent of pollution, the complexity
of laws and government regulations and their interpretation,
the varying costs and effectiveness of alternative cleanup
technologies -and methods, the uncertain level of insurance
or other types of recovery, and the questionable level of the
Company's involvement.
The Company is a defendant in several lawsuits arising in the
ordinary course of business. While the outcome of any
litigation cannot be predicted with certainty, the Company
believes that the ultimate disposition of these matters will
not have a materially adverse effect on its consolidated
financial position or business.
At June 30, 1991, commitments for the construction and
acquisition of plant and equipment totaled approximately
S 7,280,000.
ft

16. Supplemental Disclosures of Cash Flow Information:
The components of cash provided by (used in) current assets
and liabilities, net of effects of acquisitions of Wetsel, follow:
1991
1990
Receivables $ 8,352,984
$ (1,897,031)
Inventories (5,585,877)
6,120,694
Refundable income taxes 457,199
391,773
Prepaid expenses (656,004)
(413,062)
Accounts payable 1,697,095
(7,101,779)
Accrued expenses (1,060,133)
4,514,604
Other (net) (1,120,021)
(666,173)
$ 2,085,243
$ 949,026
To the Board o f Directors
Southern States Cooperative, Inc.
Cash payments for interest (net of amounts capitalized) were
$12,238,025 and $12,010,410 for 1991 and 1990, respec-
tively. Cash payments for income taxes were $2,791,294 and
$3,078,067 for 1991 and 1990, respectively.
Southern States' acquisition of Wetsel included the following
cash and noncash transactions:
Fair value of net assets acquired, including
acquisition costs of $277,059
Cash acquired
9% Redeemable Preferred issued to sellers
Cash paid
We have audited the consolidated balance sheet of Southern States Cooperative, Inc.
and subsidiaries (the "Company") as of June 30, 1991 and 1990, and the related
consolidated statements of operations, patrons' equity, and cash flows for the years
then ended. These financial statements are the responsibility of the Company's
management. Our responsibility is to express an opinion on these financial statements
based on our audits.
We conducted our audits in accordance with generally accepted auditing standards.
Those standards require that we plan and perform the audit to obtain reasonable
assurance about whether the financial statements are free of material misstatement.
An audit includes examining, on a test basis, evidence supporting the amounts and
disclosures in the financial statements. An audit also includes assessing the accounting
principles used and significant estimates made by management, as well as evaluating
the overall financial statement presentation. We believe that our audits provide a
reasonable basis for our opinion.
In our opinion, the financial statements referred to above present fairly, in all material
respects, the consolidated financial position of Southern States Cooperative, Inc. and
subsidiaries as of June 30, 1991 and 1990, and the consolidated results of their
operations and their cash flows for the years then ended in conformity with generally
accepted accounting principles.
Richmond, Virginia
September 16, 1991
$ 4,877,259
(98,204)
(2,248, 700)
$ 2,530,355
SOUTHERN

ATTACHMENT V

ENGINEERING ALTERNATIVES ANALYSIS
in support of
APPLICATION FOR PERMIT TO DISCHARGE - SHORT FORM C-GW
Southern States Fertilizer Plant
Statesville, North Carolina
LEI Job No. 56-1570.94
I. GENERAL INFORMATION
A. Facility Information
Southern States Fertilizer Plant
Iredell County
Route 1, Box 639
Highway 70 East
Statesville, North Carolina 28677
Report prepared by Thomas F. Beggs, P.E.
Registered North Carolina No. 13807
Law Environmental, Inc.
4333 Wilmont Road, Suite 300
Charlotte, North Carolina 28208
Phone: [phone]
B. Description of Proposed Discharge Facility
The proposed discharge facilities will consist of pumps to extract ground water from three
recovery wells at the site. Four -inch diameter pipes will convey the water from the site to the
proposed discharge point at Fourth Creek. The water will not be treated prior to discharge.
C: Wastewater Treatment Plant Service
The project will not be served by a wastewater treatment plant.
D. Phased Development
The project will not include phased development.

NPDES Permit Application
Attachment V: Engineering Alternatives Analysis
Page 2
11. EVALUATION OF ENVIRONMENTAL
FEASIBILITY OF DISCHARGE ALTERNATIVES
-- A. Evaluation of Environmental Feasibifity
Disposal options were considered in accordance with the NCDEHNR Guidance for Evaluation
of Wastewater Disposal Alternatives. Four discharge disposal alternatives were considered, as,
summarized below.
1. Discharge to a Publicly Owned Treatment Works.
2. Discharge to a Subsurface Disposal System.
3. Discharge through a Spray Irrigation System.
4. Discharge to a Flowing Stream.
Information concerning each of these alternatives is presented on the following pages.
1. Discharge to a Publicly Owned Treatment Works.
a. Existing Sewerage System
A publicly owned wastewater treatment plant is located approximately one mile northeast of the
site. This facility (The Fourth Creek Water/Wastewater Treatment Plant, see Figure 1) accepts
municipal sewage from the city of Statesville.
On February 5, 1992, Law Environmental submitted a letter to the Director of the Fourth Creek
Plant, Mr. Joe Hudson. The letter formally requested that the plant accept ground water
discharged from the nearby Southern States site. Laboratory analyses of representative ground
water samples were included in support of the request. A copy of the letter is attached.
As outlined on the attached response from Mr. Hudson dated February 11, 1992, the Fourth
Creek Water/Wastewater Treatment Plant agreed to consider acceptance of the proposed
discharge. However, the treatment plant set forth several requirements which must be met prior
to final acceptance.

NPDES Permit Application
Attachment V: Engineering Alternatives Analysis
Page 3
On February 26, Law responded to the plant with the following questions:
1. Does the Fourth Creek Treatment Plant have denitrification equipment?
-- 2. Would the Fourth Creek plant treat the Southern States effluent to reduce the nitrate
concentrations prior to discharge to Fourth Creek?
3. Would it be necessary for Southern States to pre -treat the ground water prior to
discharge? If so, what method(s) of pre-treatment would be required?
A meeting between Law Environmental and Mr. Hudson was held on April 1, 1992. During
- the meeting, Mr. Hudson indicated that:
1. The plant does not possess denitrification equipment.
2. The plant would not attempt to reduce. nitrate or nitrite concentrations prior to
discharge into Fourth Creek.
3. Pretreatment might be necessary to reduce suspended solids.
A summary of the meeting discussion (dated April 8) is attached.
In summary, the Fourth Creek Water/Wastewater Treatment Plant does not possess
denitrification equipment. Therefore passage of water through the plant would not enhance
environmental quality. Accordingly, this option of discharge was dropped from further
consideration.
b. Planned Sewerage System
The City of Statesville municipal government operates two wastewater treatment plants; one is
on Third Creek approximately three miles west and upgradient of the Southern States site, and
one is on Fourth Creek approximately one mile northeast of the site. The nearer facility (on
Fourth Creek) was constructed in 1981 and was recently expanded.
The Assistant Director for both plants is Mr. Steven Lambert. On February 6, 1992, we
discussed with Mr. Lambert future City plans for wastewater treatment. Mr. Lambert indicated
that the recent expansions of Fourth Creek plant were designed to provide sufficient capacity for
many years. Therefore, no new wastewater treatment plants are planned for construction within
the next five years. Furthermore, no expansion of treatment plant technology is planned to
provide denitrification capabilities. -
2. Discharge to a Subsurface Disposal System.
As outlined in the Background Information section of this document (Attachment U), former
holding ponds at the site appear to have been the source of nitrate/nitrite impact on ground
water. The holding ponds have now been closed,. The goal of remediation at this site will be
to extract ground water and thereby remove impacted water from the site, reducing
nitrates/nitrites (as nitrogen) to concentrations acceptable to the NCDEHNR.

NPDES Permit Application
Attachment V: Engineering Alternatives Analysis
Page 4
To accomplish this goal, it will be necessary to remove ground water from the site. Reinjection
of the water on -site would be counterproductive to this goal. Moreover, the water could not be
reinjected.on-site because on -site soils are fine grained and therefore low in permeability. There
is insufficient open land available (either on -site or on surrounding properties) to accommodate
the anticipated 100 gallon per minute flow rates.
Discharge to a subsurface disposal system, or infiltration gallery, was determined to be
environmentally infeasible. This option was therefore dropped from further consideration.
3. Discharge through a Spray Irrigation System.
On June 13, 1991, the NCDEHNR issued non -discharge Permit No. WQ0004556 to Southern
States Cooperative, Inc. The permit authorized spray irrigation of approximately 2.5 million
gallons of water from two former holding ponds at the site. The permit was effective from the
date of issuance through May 31, 1992.
Spray irrigation was conducted at the site on a once -a -week basis during the period of July 11
through August 27, 1991. An area covering approximately 10 acres received the discharge, and
grasses in the area were periodically harvested during the spray cycles to remove nitrogen from
the site. The water in both holding ponds was successfully removed, and the ponds were closed
by removing the former dams and using soil from the dams to backfill low areas.
The spray operation was limited to four hours per week to avoid runoff. The maximum
allowable spray volume was 255,000 gallons per week, and the maximum allowable nitrogen
loading rate was 250 pounds of nitrogen per acre per year.
As previously noted, concentrations of approximately 140 mg/l nitrate/nitrite (as nitrogen) are
anticipated in the ground -water discharge. Given the permit restrictions (runoff, nitrogen
loading) outlined above, we have determined that the previously permitted 10-acre spray
irrigation system could accommodate flow of only approximately five gallons per minute.
Approximately 200 to 300 acres of usable open. land would therefore be required to allow
continuous spray irrigation. This land area is not available either on -site or on surrounding
properties.
Discharge through a spray irrigation system was found to be environmentally infeasible, and this
option was therefore dropped from further consideration.

NPDES Permit Application
Attachment V: Engineering Alternatives Analysis
Page 5
B. Review of Environments/Feasibility
Each of the three discharge alternatives outlined above have been found to be environmentally
infeasible. Therefore, we have considered the option of discharging recovered ground water to
Fourth Creek under an NPDES permit. The environmental feasibility of this option is outlined
below.
C. Discharge to a Flowing Stream
The nearest flowing stream is Fourth Creek. Fourth Creek flows west -to -east about 1.5 miles
north of the Southern States site. The stream is classified Class C - aquatic life propagation and
survival, fishing, wildlife, and secondary recreation. Based on 7Q10 flows calculated by the
United States Geological Survey, Fourth Creek meets the requirements for classification as a
flowing stream. The 7Q10 flow for Fourth Creek is sufficient to dilute the nitrate/nitrite (as
i
nitrogen) concentrations to levels commensurate with Class C standards.
The proposed point of discharge is shown on the attached Figure 1. This discharge point was
chosen because it is at the most easily accessible point on Fourth Creek relative to the Southern
States plant.
A four -inch diameter discharge line could be constructed from the plant eastward along Highway
70 to State Road 2313 (John Long Road). The pipe could then be routed northward, under
Highway 70 and the Norfolk Southern Railroad tracks to State Road 2312 (Buckbee Road), and
northeastward on Buckbee Road to private property adjoining Fourth Creek.
Right -of -Way Encroachment Agreements for this route have been issued by the Department of
Transportation and the Norfolk Southern Railroad (copies attached). In addition, the private
property owner (Mr. James W. Davidson) has given written consent for the project. Please refer
to Drawing 1 for a detailed route map. Copies of property owner consent forms for the
proposed route are attached.
III. COST ESTIMATION AND COMPARISON
Only one of the four discharge alternatives was found to be environmentally feasible. Therefore
cost estimations and comparisons were not performed.

Engineering Alternatives Analysis Support Documents
1. Figures
2. Correspondence with Fourth Creek Publicly Owned Treatment Works
3. Department of Transportation Right -of -Way Encroachment Permit
4. Norfolk Southern Railroad Encroachment Permit
5. Letters of Authorization from Properly Owners

1. Figures

. jU( It
FOURTH CREEKEv� It
WATER/ WASTEWATER
TREATMENT PLANT
-`eon/.. _Q — m8 4
,SOUTHERN STATES
FERTILIZER PLANT
SITE%
Lu
50
- Z`/ SDI =�� Gr==:... `b �`�.,. /."" -- — _ - 1 e • i
S"
S'
0 2000
EXPLANATION LAW ENVIRONMENTAL, INC.
APPROX. SCALE, FT.
® PROPERTY BOUNDARY CHARLOTTE, NORTH CAROLINA
® PROPOSED NPDES DISCHARGE POINT PROPOSED NPDES DISCHARGE LOCATION
FOURTH CREEK
SOUTHERN STATES FERTILIZER PLANT
STATESVILLE NORTH CAROLI A
REF.: 1969 U.S.G.S. 7.5 MIN. TOPOGRAPHIC MAPS:
STATESVILLE EAST, AND SHEPHERDS, NORTH,CAROLINA NOTE: ALL LOCATIONS ARE APPROXIMATE. JOB NO. 56-1570.94 1 FIGURE 1

Ti!T x-
Y71.70
x Y70.Y/
x
•
• _`
x In
X871.40
Y�M PLANT
871.30
•
x�nr�
xwl.rY
XN�
x u
am
x87W EM
�0
XY7
•
r
�X1171A11
X"l le
LAW ENVIRONMENTAL, INC.
CHARLOTTE, NORTH CAROLINA
PROPOSED RECOVERY WELL LOCATIONS
SOUTHERN STATES FERTILIZER PLANT
STATESVILLE, NORTH CAROLINA
JOB NO. 56-1570.94 1 FIGURE 2

2. Correspondence with Fourth Creek Publicly Owned Treatment Works

v -
LAW ENVIRONMENTAL, INC.
4333 WILMONT ROAD, SUITE 300
CHARLOTTE, NORTH CAROLINA 28217
P.O. BOX 240674
April 8, 1992 CHARLOTTE, NORTH CAROLINA 28224-0674
704-357-1747 704-357-1622 (FAX)
Fourth Creek Wastewater Treatment Plant
P. O. Box 1111
Statesville, North Carolina 28677
Attention: Mr. Lenwood F. "Joe" Hudson, Jr.
Director
Subject: Summary of Discussion
April 1, 1992 Meeting
Proposed Discharge from Southern States
Fertilizer Plant to the Fourth Creek
Wastewater Treatment Plant
Statesville, North Carolina
LEI Job No. 56-1570.94
Gentlemen:
On April 1, 1992, Mr. Thomas Beggs of Law Environmental and Mr. Scott Smith of Canonie
Environmental Services Corporation met with Mr. Hudson and Ms. Carol Rogers, Fourth Creek
Wastewater Pretreatment Coordinator. The purpose of our meeting was to discuss several issues
related to discharge of ground water from the Southern States Fertilizer Plant. This letter serves
to summarize the discussion.
PROJECT BACKGROUND
Law and Canonie are continuing to evaluate the feasibility of discharging ground water from the
Southern States property to the Fourth Creek plant. We anticipate that the site will yield a
maximum of 100 gallons per minute, or approximately 5G= million gallons per year. Initial
nitrate/nitrite (as nitrogen) concentrations are expected to be 150 mg/l. Concentrations should
decrease with time, and the project is expected to continue for up to ten years.
On February 5, 1992, Law submitted a formal request for authorization to discharge nitrogen -
impacted water to the Fourth Creek plant. Detailed inorganic laboratory analyses of the
proposed discharge were included with the request.

Fourth Creek Wastewater Treatment Plant
April 8, 1992
page 2
The Fourth Creek plant responded to our request in a letter dated February 11. The letter set
forth the following minimum requirements for discharge:
1. Extra -Territorial Agreement to discharge must be executed.
2. Permit to discharge would include the City's option to discontinue acceptance upon
due notice to discharger.
3. Discharger would be billed at current outside sewer rates; $14.32 for the first 300
cubic feet and $4.70 per 100 cubic feet thereafter.
4. Discharger must bear all costs associated with tie-ins.
On February 26, 1992, Law submitted a request for additional information regarding treatment
plant operations. The request was discussed in detail during our April 1 meeting.
DISCUSSION OF PROPOSED DISCHARGE
Mr. Hudson indicated that the Fourth Creek Wastewater Treatment Plant does not possess
denitrification capability. However, minimal denitrification of nitrogen -impacted water may
occur as a secondary benefit of aeration/clarification processes. The plant does not specifically
attempt to remove nitrates or nitrites. If the Southern States effluent is accepted by the plant,
denitrification would not be attempted by the plant prior to discharge of the water into Fourth
Creek.
The Fourth Creek plant is currently experiencing difficulty with solids in the waste stream. The
policy of the plant is therefore to require pretreatment of effluent accepted from outside sources.
The purpose of pretreatment is to minimize the suspended solids content. Carbon filtration or
similar technology would be acceptable for this purpose.
Mr. Beggs noted that the previously submitted inorganic laboratory analyses may not accurately
represent production well effluent. The previous water samples were drawn from small -diameter
monitoring wells. Production wells pumping continuously for extended periods should produce
less turbid ground water.
Production wells have not yet been installed at the site. Therefore, in an effort to simulate
production conditions, the monitoring wells were resampled using a 45 micron nylon filter to
screen suspended solids. The samples were again analyzed for the inorganic parameters, and
the results have been summarized on the attached table. - A copy of this table was provided to
Ms. Rogers for review during the meeting.

Fourth Creek Wastewater Treatment Plant
April 8, 1992
page 3
Mr. Hudson indicated that the Fourth Creek plant would adhere to the policy of pretreatment
by carbon filtration and would reserve the right to inspect pretreatment facilities at any time.
The plant would also require that an access valve be provided at the main treatment plant. The
purpose of the valve would be to give plant personnel immediate flow control if unauthorized
constituents are detected in the effluent.
Trenching procedures for tie-in to the plant were briefly discussed during the meeting. Mr.
Hudson indicated that the tie-in sewer line from Southern States should be routed around the
-, Fourth Creek facility to the east. The plant has an extensive network of underground utilities,
and installation of a sewer line through the plant could be disruptive. Mr. Hudson suggested
that Mr. Wayne Lambert, Director of Public Works for the City of Statesville, be contacted
prior to sewer line installation.
The meeting was adjourned with the understanding that Law would issue a letter to document
the discussions. We note that a final determination regarding discharge to the Fourth Creek
plant may be delayed several months, pending review of our plans by the North Carolina
Division of Environmental Management.
If there are any questions regarding this letter, or if our understanding of the topics discussed
is inaccurate, please contact us.
Sincerely,
LAW ENVIRONMENTAL, INC.
Thomas F. Beggs, P.E.
Principal
attachment
cc: Mr. Scott Smith
Canonie Environmental Services Corporation

GROUNDWATER INORGANIC RESULTS
SOUTHERN STATES FERTILIZER PLANT
STATESVILLE, NORTH CAROLINA
LEI JOB NO. 56-1570.94
INORGANICS
Calcium, Total
Filtered
1100
Unfiltered
1470
Filtered
37
Unfiltered
ND
Filtered
14
Unfiltered
370
Filtered
110
Unfiltered
142
Filtered
--
Unfiltered
18.2
Filtered
360
Unfiltered
--
Filtered
850
Unfiltered
11
Filtered
412
Unfiltered
335
Copper, Total
ND
ND
ND
ND
ND
ND
ND
ND
--
0.03
ND
--
ND
0.03
ND
0.01
Iron, Total
ND
4.18
ND
0.14
ND
6.88
ND
ND
--
0.10
ND
--
ND
0.32
ND
1.94
Potassium, Total
10
ND
120
155
2.4
9
17
19.7
--
6.6
5.1
--
30
31.6
30.8
37
Magnesium, Total
120
153
7.9
9.55
2.2
30.5
34
38.8
--
5
37
--
81
11
47
41
Manganese, Total
0.7
1.04
4.8
1 3.07
0.05
1.77
1 ND
ND
--
0.02
0.3
--
1.5
0.23
1.225
1.02
Sodium, Total
81
8.86
10
ND
5.5
ND
25
ND
--
6.4
21
--
50
50
32.1
11
Alkalinity
46
32
ND
3.5
1.3
14.5
78
56
--
58
13
--
25
28
27.2
32
Chloride
1200
1270
110
129
26
203
110
110
--
ND
220
--
560
597
371
385
Ammonia, As N
1.1
1.5
57
79.2
ND
ND
0.15
ND
--
ND
0.04
--
19
14.4
12.9
15.9
Nitrite, As N
ND
0.23
0.09
0.17
ND
ND
0.38
13.8
--
ND
ND
--
0.08
ND
0.09
2.37
Nitrate, As N
370
455
160
29.9
8.5
163
37
34.7
--
2.4
26
--
37
230
106
153
Phosphate, As P
0.05
0.14
0.09
ND
0.05
1.2
0.13
ND
--
0.34
0.1
--
0.39
0.3
0.14
0.33
Sulfate
340
653
260
327
ND
345
160
189
--
ND
440
--
1400
1620
433
522
Total Dissolved
Solids
5300
6890
580
637
120
2530
740
757
--
136
1800
--
4100
4760
2106
2618
Total Suspended
Solids
19
1650
ND
33
ND
3490
ND
24
--
6
ND
--
ND
32
3.2
873
pH'
5.8
5.5
4.8
5
5.1
5.4
7.8
7.5
--
8.8
5.8
--
5.7
5.4
5.83
6.27
Specific
Conductivity"
5400
6880
850
1350
150
1810
840
915
--
135
2200
--
4300
4860
2290
2656
Turbidity*
8.60
1000
ND
14
ND
1840
ND
2
--
0.57
ND
--
ND
4
1.43
477
Notes:
pH units
units In umhos/cm
"' units In NTU
Unfiltered samples gathered on October 2, 1991.
Field filtered samples gathered on February 13, 1992. Nylon 45-micron filters used.
1570-TFB/syh

February 26, 1992
Mr. Joe Hudson, Director
Fourth Creek Water/Wastewater Treatment Plant
P.O. Box 1111
Statesville, North Carolina 28677
Subject: Request for Additional Information
Proposed Discharge from Southern States
Fertilizer Plant to the Fourth Creek
Wastewater Treatment Plant
Statesville, North Carolina
LEI Job No. 56-1570.94
Dear Mr. Hudson:
o
v -
LAW ENVIRONMENTAL, INC.
4333 WILMONT ROAD, SUITE 300
CHARLOTTE, NORTH CAROLINA 28217
P.O. BOX 240674
CHARLOTTE, NORTH CAROLINA 28224-0674
704-357-1747 704-357-1622 (FAX)
We have received your February 11, 1992 correspondence; thank -you for responding so quickly
to our Request for Authorization to Discharge Nitrogen -Impacted Ground Water (letter dated
February 5, 1992).
Law Environmental is continuing to evaluate the feasibility of discharging ground water from
the Southern States property to the Fourth Creek treatment plant. As you recall, we anticipate
that the site will yield a maximum of 100 gallons per minute, or approximately 50 million
gallons per year. Initial nitrate/nitrite (as nitrogen) concentrations are expected to be 150 mg/l.
Concentrations should decrease with time, and the project is expected to continue for up to ten
years.
To assist in our efforts to evaluate the option of discharge to the Fourth Creek Treatment Plant,
we would greatly appreciate your response to the following questions:
1. Does the Fourth Creek Treatment Plant have denitrification equipment?
2. Would the Fourth Creek plant treat the Southern States effluent to reduce the nitrate
concentrations prior to discharge to Fourth Creek?
3. Would it be necessary. for Southern States to pre -treat the ground water prior to
discharge? If so, what method(s) of pre-treatment would be required?

Mr. Joe Hudson
February 26, 1992
Page 2
We appreciate your continuing assistance and look forward to hearing from you on these
matters.
Sincerely,
LAW ENVIRONMENTAL, INC.
P. Greg Garrett, E.I.T
Staff Engineer
Thomas F. Beggs, P.E.
Principal

Wnter/Maztewater 01reatment t1lants
704-878-3438
77
ttje
. (.+dux 1111 • tUtrimille. Wartll CITarulina 28577
February 11, 1992
ALL Greg Garrett
Law Environmental, Inc.
P. O. Box 240674
Charlotte, NC 28224-0674
Re: Request to Discharge
Southern States Fertilizer Plant
Dear Mr. Garrett:
Consideration has been given to your request to discharge the referenced water to the
Fourth Creek Wastetreatment Plant.
We are open to considering this favorably after further discussions with you.
In order to assist you in further discussions the following are the minimum requirements
at this time:
1. Extra-TerritOrial Agreement to discharge rnusr be executed.
2. Permit to discharge will be issued and include the Citys option
to discontinue acceptance upon due notice to discharger.
3. Discharger will be billed at current outside sewer rates which are
at this time $14.32 for the first 300 cu.ft. and $4.70 per
100 cu. ft. after that.
4. Discharger will have to bear all costs associated with tie-ins
(taps, meters, etc.)

If you would like to continue these discussions please call me at 704-878-3438.
Sincerely,
L. F. "Joe" Hudson, Jr., Director
Water/Wastewater Treatment
LFH/sg
cc: Jack King

� s
LAW ENVIRONMENTAL, INC.
4333 WILMONT ROAD, SUITE 300
CHARLOTTE, NORTH CAROLINA 28217
P.O. BOX 240674
CHARLOTTE, NORTH CAROLINA 28224-0674 _
704-357-1747 704-357-1622 (FAX)
February 5, 1992
Mr. Joe Hudson, Jr.
Director
Fourth Creek Water/Wastewater Treatment Plant
P.O. Box 1111
Statesville, North Carolina 28677
Subject: Request for Authorization to Discharge
Nitrogen -Impacted Ground Water
Southern States Fertilizer Plant
Hwy. 70 East, Statesville, North Carolina
LEI Job No. 56-1570.94
Dear Mr. Hudson:
As discussed during our January 21, 1992 meeting, Law Environmental is evaluating
alternatives for disposal of nitrogen -impacted ground water from the Southern States
Fertilizer Plant. The plant is located near your facility on Hwy. 70 East, Statesville, North
Carolina.
This letter serves as a request for authorization to discharge ground water recovered from
the Southern States site to the Fourth Creek Water/Wastewater Treatment Plant.
The ground water removal project is being conducted in cooperation with the North
Carolina Department of Environment, Health, and Natural Resources (NCDEHNR). The
NCDEHNR will establish guidelines for the removal of ground water which has been
impacted by nitrates and nitrites.
Southern States plans to begin ground -water extraction from three recovery wells during.
1992. Based on the results of an aquifer pump test, we estimate that the site will yield a
maximum of 100 gallons per minute (approximately 50 million gallons per year). Initial
nitrate/nitrite (as nitrogen) concentrations are expected to be approximately 150 mg/1.
Concentrations are expected to decrease with time, and the project is anticipated to continue
for up to ten years.
1570-Pic/byh
1- Printed on Rewcled Paper

Fourth Creek Treatment Plant
February 5, 1992
Page 2
In addition to nitrates and nitrites, we have analyzed representative ground -water samples
for a broad range of inorganic parameters. Laboratory test results are attached for your
review. We note that the samples were collected from monitoring wells at the site. In our
opinion, the Total Suspended Solids results are not representative of water which will be
drawn from properly designed and fully developed recovery wells.
In an effort to obtain representative ground -water samples to assist you in evaluating our
request, our technicians will resample each monitoring well. The samples will be filtered
in the field using Nalgene pressurized filters (45 micron nylon filter media) to remove
suspended solids. Inorganic parameters will again be analyzed, and laboratory results will
be forwarded to you as they become available.
We hope that the information presented herein will allow you to determine whether ground
water from Southern States can be discharged to the Fourth Creek Treatment Plant. If you
have any questions or require additional information, please do not hesitate to contact us.
Thank -you for your assistance on this project.
Sincerely,
LAW ENVIRONMENTAL, INC.
P. Greg Garrett, E.I.T.
Staff Engineer
Thomas F. Beggs, P.E.
Principal _
PGG:TFB:syh
1570-PGG/syh

GROUNDWATER INORGANIC RESULTS
STATESVILLE, NORTH CAROLINA
INORGANICS
Sample Identifications
Concentrations
and
in mg/L
60A"
7"A"
79 Fit
7" I"
6" En
7° H"
Average
Calcium, Total
1470
ND
370
142
18.2
11.2
335
Copper, Total
ND
ND
ND
ND
0.025
0.025
0.0083
Iron, Total
4.18
0.14
6.88
ND
0.1
0.32
1.94
Potassium, Total
ND
155
9
19.7
6.58
31.6
37.0
Magnesium, Total
153
9.55
30.5
38.8
5
11
41.3
Manganese, Total
1.04
3.07
1.77
ND
0.015
0.226
1.02
Sodium, Total
8.86
ND
ND
ND
6.39
50.3
10.9
Alaklinity
32
3.5
14.5
56
58
28
32.0
Chloride
1270
129
203
110
ND
597
385
Ammonia, as N
1.5
79.2
ND
ND
ND
14.4
15.9
Nitrite, as N
0.23
0.17
ND
13.8
ND
ND
2.37
Nitrate, as N
455
29.9
163
34.7
2.4
230
153
Phosphate, as P
0.14
ND
1.2
ND
0.34
0.3
0.330
Sulfate
653
327
345
189
ND
1620
522
Total Dissolved Solids
6890
637
2530
757
136
4760
2618
Total Suspended Solids
1650
33
3490
24
6
32
873
pH*
5.5
5
5.4
7.5
8.8
5.4
6.27
Specific Conductivity* *
6880
1350
1810
915
135
4860
2656
Turbidity * * `
1000
14
1840
2
0.57 1
4 11
477
Note:
* pH units
* * units in umhos/cm
* * * units in NTU
Sampling Date = October 2, 1991
ND = Not Detected
1570/syh

3. Department of Transportation Right -of -Way Encroachment Permit

TEL:
Sep 01 92 14:33 No.044 P.02
,'AMFS G. MARTIN
GOVERNOR
THOMAS J. HAR iLLSON
SfC,RI-1 ARY
COUNTY:
SUBJECT:
lredell
STATE OF NORTH CAROLINA
DEPARTMENT OF TRANSPORTATION
P. O. BOX 47
SHELBY, NC 28150
August 26, 1992
Right of way Encroachment Agreement
US 70, SR 2313, SR 2312
Southern States Cooperative, Inc.
P. o. Box 26234
Richmond, Virginia 23260
Gentlerrlen :
DIVISION OF HIGHWAYS'
WILLIAM G. MARLEY, in.. P.C,
STATE HIGHWAY ADMINISTRAI (); l
Attached is approved Right of Way Encroachment Agreement cover-
ing installation of 2000' of 4" PVC SDR21 pipe on US 70, 1200' of 4" PVC
SDR21 pipe on SR 2313, 2900' of 4" PVC SDR21 pipe on SR 2312, as shown on the.
attached map and plan sketch in Iredell County.
Approval is given subject to provision;: in the Agreement and
attachments thereto which are made a pars; of the Agreement.
It would be appreciated if you would advise our District Ufficc
at Statesville prior to the date of beginning work on this installa-
tion.
The Department of Transportation does not: guarantee the right
of way on this road, nor will it be responsible for any claim for
damages brought by any property owner by reason of the installation.
Please advise, in writing, when this -work has been completed.
Yours very truly,
&..-
R. W. SPAN LER
DIVISION ENGINEER
TWELFTH DIVISION
:lj
cc* Mr. Doug Allison (AtteJchme:nts )
Mr. J. W. Rand (Attach rents)
An Equal Opportunity/Affirmative Action Employer

}
I
i
�4
STATE DF RD1:TH GARDLI1lA
RMIE ffj1j �"WEGT t,s+g t'T,t7rc MINTY DF tna�rlr
DEPAASMEHT of 7PARSMIArsoN RIGHT CIF itey ENEP.DAElMENT ICAUMENT
_mD, PRrWAY nNC SECMEWAY HIGNLMys
MFl:rr'GiA-f•;y1'^r'P �'iltMf.
r.9.nnx 262YC, Richfaoada Virginia 23M
TMI1r AGREEMENT, wde and entered lato this the 2l da`y or ,�
by arfd bet, the Dr-,parPa, nt of T,a•ssvortation, party of th,e rlrSt tart: an SINfTH7K
S —_ party of the second part,
Pf T11ESSETHt
THAT WILAEAS, the party of tl,e second part Cesires to erx mart, cc the right of ww
or the p,,61 is road desl9nated as pause _Tn , locateA ,rL�_{'a_ls lrf6 T'a1T A Mn.rc
xl_tvhn SSGN L7079rY�_'ni1QN SflCtYTgNSyH„•f>:r- eeti oryMD r�f"Nlwaftm r-- -
ED. 23t2 M LUEF. R1W]'L
SMEREA.S, It Is to tM_ eotertal advantage of tF,e party of the secc_ d mart to effect
Ma ene,l?atfY.ent, and the partly of the first »art in the exercise of eot%ority conferred
taaon It by ;fatale, is x11lin9 to "mit the encroachrent rpthle the lflflts of the right
of way as indicated, subject to the cc<dltior,s of this egreaaent;
NOW THEREFORE, 1T IS AGIMED that the party of the First part hsreby grants to the
party of the second cart the right and vr[r11t9e to rla` this encrlvthrrent as shunn of
attached elan s:xt Esla speciflcatfer+s aA special,yronelcions rMcli are made a part
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4. Norfolk Southern Railroad Encroachment Permit

i -
NORFOLK _._----- ..--_._ _
SOUTHERN
Norfolk Southern Corporation D. N. Zureich
Transportation Department Superintendent
p p �- -- - - - 1120 W. Washington Street Piedmont Division
Greenville, South Carolina 29601----------'-__ _
803 255-4335
August 12, 1992 HN/sa
4-6-3-Elmwood, NC
Mr. Thomas F. Beggs
Law Environmental, Inc.
4333 Wilmont Road, Suite 300
Charlotte, NC 28208
Dear Mr. Beggs:
Please refer to yours of May 8, 1992 making application
for a pipeline crossing located at Milepost S-20 plus 1107 feet
to point of switch plus 445.6 feet on spur track, Elmwood, NC.
This is to advise that the subject crossing has now
been approved by our Engineering Department and an agreement to
cover will be furnished in the near future.
We ask that you notify the following at least one week
prior to making the installation:
Ms. Sheila M. Howie
[phone]
Mr. A. D. Felty
[phone]
Track Supervisor, J. L. Manning
[phone] or [phone]
b;ith insurance requirements wet, an emergency need to
install prior to executing the agreement will be considered by
this office; however, a letter of intent to execute the
agreement must be received. A letter of intent cannot be
accepted if you desire to participate in Norfolk Southern's
Master Railroad Protective Liability Insurance Program.
V truly yours,
N. Z re
Superinteni
Operating Subsidiaries: Norfolk Southern Railway Company / North American Van Lines, Inc.

5. Letters of Authorization from Property Owners

R.D. Monroe Inc. (and Building Tenant, Jefferson Smurfit/CCA)

04/30i q2 1 3: 15 001
Southern States
Cooperative, Inc.
66M West Broad Street
Post Office Box 26234
9ichmond, Virginia 23260
Telephone [phone]
them
April 21, 1992 States
?. J. /1/t-A TAc.
3 0-v /4t O-r r v P S -rL•
P.o . E
Dears 7ir
Southern States Cooperative is planning to install a four -inch
diameter underground water line from its property on Highway 70
to Fourth Creek. The line will run along Highway 70 from the
Southern States Fertilizer Plant eastward to John Long Road.
The line will then be drilled under Highway 70 and the Norfolk
Southern Railroad, following John Long Road northward to Fourth
Creek. The proposed route is shown on the attached drawing.
The line will be installed on North Carolina Department of
Transportation right-of-way. However, the NCDOT has suggested
that we get approval for the work from property owners along the
Proposed route.
The pipeline will be carefully placed in an excavated trench
that is six -inches wide and thirty -inches deep. After the pipe
is located in the trench,- the excavation will be carefully
backfilled with compacted soil. Any damage to your yard or
pavement caused by this work will be repaired by Southern States
at its expense. We will do our best to leave your yard in the
same condition as it was before the excavation. Our field crew
will not obstr­ct traffic to your property, and the water a cr 11.is
will not interfere with your existing utilities.
Southern States appreciates you working with us and asks that
you sign this letter in the space below indicating your
permission for Southern States to construct the water line as
described in the letter.
Sincerely,
amen A. Greene
Manager
Statesville ]Fertilizer plant
DATE:
SIGNED BY:.
TITLE:
COMPANY : i.vt i,% iv c.

Southern States
Cooperative, Inc.
6606 West Broad Street
Post Office Box 26234
Richmond, Virginia 23260
Telephone [phone]
April 21, 1992
286'77
Dear Mr X r e #" 4(:
Southern
States
Southern States Cooperative is planning to install a four -inch
diameter underground water line from its property on Highway 70
to Fourth Creek. The line will run along Highway 70 from the
Southern States Fertilizer Plant eastward to John Long Road.
The line will then be drilled under Highway 70 and the.Norfolk
Southern Railroad, following John Long Road northward to Fourth
Creek. The proposed route is shown on the attached drawing.
The line will be installed on North Carolina Department of
Transportation right-of-way. However, the NCDOT has suggested
that we get approval for the work from property owners along the
proposed route.
The pipeline will be carefully placed in an excavated trench
that is six -inches wide and thirty -inches deep. After the pipe
is located in the trench, the excavation will be carefully
backfilled with compacted soil. Any damage to your yard or
pavement caused by this work will be repaired by Southern States
at its expense. We will do our best to leave your yard in the
same condition as it was before the excavation. Our field crew
will not obstruct traffic to your property, and the water line
will not interfere with your existing utilities.
Southern States appreciates you working with us and asks that
you sign this letter in the space below indicating your
permission for Southern States to construct the water line as
described in the letter.
Sincerely,
ames A. Greene
Manager
Statesville Fertilizer Plant
DATE:
SIGNED BY:
TITLE : j�
COMPANY:

Furst-McNess Company

Southern States
Cooperative, Inc.
6606 West Broad Street
Post Office Box 26234
Richmond, Virginia 23260
Telephone [phone]
EA)
Southem
April 21, 1992 States
F1,5 f /" 'N" (.
2,
Dear Mr RIDDLE
Southern States Cooperative is planning to install a four -inch
diameter underground water line from its property on Highway 70
to Fourth Creek. The line will run along Highway 70 from the
Southern States Fertilizer Plant eastward to John Long Road.
The line will then be drilled under -Highway 70 and the Norfolk
Southern Railroad, following John Long Road northward to Fourth
Creek. The proposed route is shown on the attached drawing.
The line will be installed on North Carolina Department of
Transportation right-of-way. However, the NCDOT has suggested
that we get approval for the work from property owners along the
proposed route.
The pipeline will be carefully placed in an excavated trench
that is six -inches wide and thirty -inches deep. After the pipe
is located in the trench, the excavation will be carefully
backfilled with compacted soil. Any damage to your yard or
pavement caused by this work will be repaired by Southern States
at its expense. We will do our best to leave your yard in the
same condition as it was before the excavation. Our field crew
will not obstruct traffic to your property, and the water line
will not interfere with your existing utilities.
Southern States appreciates you working with us and asks that
you sign this letter in the space below indicating your
permission for Southern States to construct the water line as
described in the letter.
gcerely,
es A. Greene
Manager
Statesville Fertilizer Plant
DATE: 4/29/92
SIGNED BY: . J .%.Q1
TITLE: Plant Manager
COMPANY: Furst-McNess Company

American Homes, Inc.

Southern States
Cooperative, Inc.
6606 West Broad Street
Post Office Box 26234
Richmond, Virginia 23260
Telephone [phone]
Southern
April 21, 1992 States
A n\ eA
Dear Mr ,r
Fr L e
Southern Stat s Coopperative is planning to install a four -inch
diameter underground water line from its property on Highway 70
to Fourth Creek. The line will run along Highway 70 from the
Southern States Fertilizer Plant eastward to John Long Road.
The line will then be drilled under Highway 70 and the Norfolk
Southern Railroad, following John Long Road northward to Fourth
Creek. The proposed route is shown on the attached drawing.
The line will be installed on North Carolina Department of
Transportation right-of-way. However, the NCDOT has suggested
that we get approval for the work from property owners along the
proposed route.
The pipeline will be carefully placed in an excavated trench
that is six -inches wide and thirty -inches deep. After the pipe
is located in the trench, the excavation will be carefully
backfilled with compacted soil. Any damage to your yard or
pavement caused by this work will be repaired by Southern States
at its expense. We will do our best to leave your yard in the
same condition as it was before the excavation. Our field crew
will not obstruct traffic to your property, and the water line
will not interfere with your existing utilities.
Southern States appreciates you working with us and asks that
you sign this letter in the space below indicating your
permission for Southern States to construct the water line as
described in the letter.
Sincerely, DATE:
SIGNEO
James A. Greene TITLE
Manager
Statesville Fertilizer Plant COMPA

Wayside Volunteer Fire Department

Southern States
Cooperative, Inc.
6606 West Broad Street
Post Office Box 26234
Richmond, Virginia 23260
Telephone [phone]
Southern
April 21, 1992 States
V�/�S�r�CQ V��✓H�-eel I irP ��.
L SG 77
Dear Mr A R j
j ✓ a
Southern States Cooperative is planning to install a four -inch
diameter underground water line from its property on Highway 70
to Fourth Creek. The line will run along Highway 70 from the
Southern States Fertilizer Plant eastward to John Long Road.
The line will then be drilled under Highway 70 and the Norfolk
Southern Railroad, following John Long Road northward to Fourth
Creek. The proposed route is shown on the attached drawing.
The line will be installed on North Carolina Department of
Transportation right-of-way. However, the NCDOT has suggested
that we get approval for the work from property owners along the
proposed route.
The pipeline will be carefully placed in an excavated trench
that is six -inches wide and thirty -inches deep. After the pipe
is located in the trench, the excavation will be carefully
backfilled with compacted soil. Any damage to your yard or
pavement caused by this work will be repaired by Southern States
at its expense. We will do our best to leave your yard in the
same condition as it was before the excavation. Our field crew
will not obstruct traffic to your property, and the water line
will not interfere with your existing utilities.
Southern States appreciates you working with us and asks that
you sign this letter in the space below indicating your
permission for Southern States to construct the water line as
described in the letter.
Si rely,
mes A. Greene
Manager
'Statesville Fertilizer Plant
DATE •
SIGNED BY:
TITLE: zoic
COMPANY: `(%5, � e_ O FD, G u,.--

Montgomery Industries

Southern States
Cooperative, Inc.
6606 West Broad Street
Post Office Box 26234
Richmond, Virginia 23260
Telephone [phone]
April 21, 1992
Pry
-73
Dear Mr
Southern
States
Southern States Cooperative is planning to install a four -inch
diameter underground water line from its property on Highway 70
to Fourth Creek. The line will run along Highway 70 from the
Southern States Fertilizer Plant eastward.to John Long Road.
The line will then be drilled under Highway 70 and the Norfolk
Southern Railroad, following John Long Road northward to Fourth
Creek. The proposed route is shown on the attached drawing.
The line will be installed on North Carolina Department of
Transportation right-of-way. However, the NCDOT has suggested
that we get approval for the work from property owners along the
proposed route.
The pipeline will be carefully placed in an excavated trench
that is six -inches wide and thirty -inches deep. After the pipe
is located in the trench, the excavation will be carefully
backfilled with compacted soil. Any damage to your yard or
pavement caused by this work will be repaired by Southern States
at its expense. We will do our best to leave your yard in the
same condition as it was before the excavation. Our field crew
will not obstruct traffic to your property, and the water line
will not interfere with your existing utilities.
Southern States appreciates you working with us and asks that
you sign this letter in the space below indicating your
permission for Southern States to construct the water line as
described in the letter.
nc rely,
James A. Greene
`Manager
Statesville Fertilizer Plant
DATE: b ' /5_ �Z
SIGNED BY •
TITLE: Vi�'Pc{�� I/o�.3
COMPANY:

Leonard S. and Mary T. Gilliam, Jr.

Southern States
Cooperative, Inc.
6606 West Broad Street
Post Office Box 26234
Richmond, Virginia 23260
Telephone [phone]
April 21, 1992
Leonard S. and Mary T. Gilliam, Jr.
437 Summit Avenue
Statesville, North Carolina 28677
Dear Mr, Gilliam:
00"
Southern
States
Southern States Cooperative is planning to install a four -inch
diameter underground water line from its property on Highway 70
to Fourth Creek. The line will run along Highway 70 from the
Southern States Fertilizer Plant eastward to John Long Road.
The line will then be drilled under Highway 70 and the Norfolk
Southern Railroad, following John Long Road northward to Fourth
Creek. The proposed route is shown on the attached drawing.
The line will be installed on North Carolina Department of
Transportation right-of-way. However, the NCDOT has suggested
that we get approval for the work from property owners along the
proposed route.
The pipeline will be carefully placed in an excavated trench
that is six -inches wide and thirty -inches deep. After the pipe
is located in the trench, the excavation will be carefully
backfilled with compacted soil. Any damage to your yard or
pavement caused by this work will be repaired by Southern States
at its expense. We will do our best to leave your yard in the
same condition as it was before the excavation. Our field crew
will not obstruct traffic to your property, and the water line
will not interfere with your existing utilities.
Southern States appreciates you working with us and asks that
you sign this letter in the space below indicating your
permission for Southern States to construct the water line as
described in the letter.
Sincerely,
James A. Greene
Manager
Statesville Fertilizer Plant
DATE:
SIGNED BY:
�,�� �� • /
TITLE.
COMPANY:

Mr. Justin Davidson

Southern States
Cooperative. inc.
6606 West Broaa Street
Pest Office Box 26234
Richmona. Virginia 23260
Telephone [phone]
August 17, 1992
Mr. Justin Davidson
Route 1, Box 623
Statesville, NC 28677
Dear Mr. Davidson:
0-
Southern
States --
Southern States Cooperative is planning to install a four -inch diameter underground water line
from its property on Highway 70 to Fourth Creek. The line will run along Highway 70 from
the Southern States Fertilizer Plant eastward to John Long Road. The line will then be drilled
under Highway 70 and the Norfolk Southern Railroad, following John Long Road northward to
Buckbee Road. The line will run along the south side of Buckbee Road and will cross the road
at Mr. James W. Davidson's gate. The line will then run across Mr. James W. Davidson's
property to Fourth Creek.
The line will be installed predominantly on North Carolina Department of Transportation right-
of-way. However, the NCDOT has suggested that we get approval for the work from property
owners along the proposed route.
The pipeline will be carefully placed in an excavated trench that is six -inches wide and thirty -
inches deep. After the pipe is located in the trench, the excavation will be carefully backfilled
with compacted soil. Any damage to your yard or pavement caused by this work will be
repaired by Southern States at its expense. We will do our best to leave your yard in the same
condition as it was before the excavation. Our field crew will not obstruct traffic to your
property, and the water line will not interfere with your existing utilities.
Southern States appreciates you working with us and asks that you sign this letter in the space
below indicating your permission for Southern States to construct the water line as described in
the letter.
Sincerely, DATE: g Z
• C P �1 SIGNED BY:
f
Pames A. Greene
(-ra)
Manager
Statesville Fertilizer Plant

Mr. James W. Davidson

Southern States
Cooperative. Inc.
6606 West Broad Street
Post Office Box 26234
Richmond, Virginia 23260
Telephone [phone]
July 27, 1992
Southem-
Mr. James W. Davidson States
Buckbee Road (SR 2312)
Statesville, North Carolina 28677
Dear Mr. Davidson:
As you know, Southern States Cooperative is planning to install a four -inch diameter
underground water line from its property on Highway 70 to Fourth Creek. The line will be
permitted by the North Carolina Division of Environmental Management. The line will run
along Highway 70 from the Southern States Fertilizer Plant eastward to John Long Road. The
line will then be drilled under Highway 70 and the Norfolk Southern Railroad, following John
Long Road northward to Buckbee Road. The line will follow Buckbee Road to your property,
and is proposed to follow your private road from Buckbee Road to Fourth Creek.
The pipeline will be carefully placed in an excavated trench that is six -inches wide and thirty -
inches deep. After the pipe is located in the trench, the excavation will be carefully backfilled
with compacted soil. We will not discharge any water through the pipe without the state permit.
The water is not hazardous and will not hurt your or your neighbors' property or livestock.
Southern States will be responsible for any legal liability or claims which could be brought
against you by third parties that result from the company's use of the pipeline or from the water
that comes from its plant through the pipeline. Southern States will also defend you from such
claims. Any damage to your property caused by this work will be repaired by Southern States
at its expense. Our field crew will not obstruct traffic to your property, and the water line will
not interfere with your existing utilities.
Southern States appreciates ,you working with us and asks that you sign this letter in the space
below indicating your permission for Southern States to construct the water line as described in
the letter.
Sincerely,
ames A. Greene
Manager
Southern States Fertilizer Plant
SIGNATURE:
Mr. James W. Davidson
DATE: % -- ;� 9 -- � •�

GARAGE
,D
OFFI E
Legend
Purina Feed Mill Property
1 '
845
65W6"E" 840 L
Z48 I
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Southern States Cooperative Inc.
Statesville Fertilizer Facility L' ' ! 795
r t r
805 ' i ® 790
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D[TNCKL.EE ENV'RONMENTALCONSULTANTS
511 KEISLER DRIVE - SUITE 102 50200 1, 2, 9
CARY,& D T T OFFICE:
NORTH CAROLINA)85 27511
_ uN OFFICE: [phone] Drawing figure
WEB: DUNCKIEEDUNHAM COM 50200 6
Title Shallow Ground Water Contour Map
8/3/2005 October 2006
Project
1 "=165' Southern States Fertilizer Facility, Statesville, North Carolina
DR) R W
K65W7"C" /
Residential
Properties
785
1(784.59)
K65W7"F"
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I �/
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785
Source of base map: Law Engineering and Environmental Services

GARAGE
\" /
OFFI E
Legend
K65W6 B
® (849.04)
STORAGE
0
845
MAIN
PLANT
®K65W7"A" Monitoring Well Locations
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\ Ground Water Contour in Feet
—10 Direction of Ground Water Flow
Purina Feed Mill Property
845
840 ' L
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io
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OFFICE: (919) 858 - 9898
WEB' DUNCKIEEDUNHAM.COM
q0011N
i
fob No. Layers Vate Title Shallow Ground Water Contour Map
50200 1, 2, 8 8/3/2005 April 2006
)cawing igure Scale roject
50200 5 1 "=165' ) Southern States Fertilizer Facility, Statesville, North Carolina
795
Residential
Properties
790
785
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65W7"C" (784.66)
K65W7"D" (791.14 785
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Source of base map: Law Engineering and Environmental Services

GARAGE
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K65W6"B"
® (23)
STORAGE \E3
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®R W— 5
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Property Line
Nitrate Isoconcentration Line in mg/L
(150)
Nitrate Isoconcentration in mg/L (ppm)
(NS)
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ND
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Quantitation Limit
DLTNCKLEE ENVIRONMENTAL CONSULTANTS
511 KEISLER DRIVE - SUITE I07
DT T T CARYHAM, NORiH CARDLINA
U � 27511
OFFICE: (919) 858 - 9898
WEB: DUNCKIEEDUNHAM COM
Purina Feed Mill Property
K65W6"E" � P
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APPROXIMATE WELL FOR PLANT
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i
Southern States Cooperative Inc.
Statesville Fertilizer Facility
50200 1 1, 2, 11 1 8/3/2005
50200 1 4 1 1"=165'
100
K65W7"K„ K65W6"D"
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Title Nitrate Results with Shallow Plume Isoconcentration
October 2006
M'
Residential
Properties
Southern States Fertilizer Facility, Statesville, North Carolina I Source of base map: Law Engineering and Environmental Services

Purina Feed Mill Property
• I ,
1 K65W6°E" r
" �� (140) O~ A PROXIMATE '
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Statesville Fertilizer Facility
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DUNCKLEEI
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511 KEISLER DRIVE - SUITE 102 50200 1, 2, 10 8/3/2005
CARY, NORTH CAROLINA 27511
r_.Iwo> & DUNHAM OFFICE: [phone] Drawing Ngure Cale Project
WEB: DUNCI4EEDUNHAM.COM 50200 3 1 "=165' Southern States Fertilizer Facility, Statesville, North Carolina Source of base map: Law Engineering and Environmental Services

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Southern States Cooperative Inc.
Statesville Fertilizer Facility
50200 1 0, 1, 2 1 8/3/2005
50200 1 2 1 1"=165'
Title
I I
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Site Plan
m
J
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Properties
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Purina Feed Mill Property
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K65 6 5 6D
.- - K65W7„K" (NS)
65W7„i„ ® }
(140) ®65W7» L„ I oo
�► W— 6 '
ji
100
Op q
Southern States Coop tive Inc.
Statesville Fertilizer Facih \ \ boo
,J o
o o
�i cri o o
-- - 10 1
Legend - 1 (NS) ' -
\
65W7„B„
0 Saprolite Monitoring Well
RW 2 -
®�
K65W7"F"
® Bedrock Monitoring Well _ I K65W7"Cs� o H 8 a
Recovery Well
(30.3) Nitrate Concentrations in mg/L
Nitrate Isoconcentration Line
I � Dashed where inferred - -
- Property Line- - - - - - I (39) / U z
Graphical Scale
Note: Pond A and B are approximate I 180 360 Dry Stream
'
locations based on CAP data (1994 Canonie) �, I

Purina Feed Mill Property I i
---- - 335 ,
01
3�operty Line
7765WCE"
Former 83 8.95 PROXIMATE lrj
Pond A K65W6"B" Former : 325 j o N
( ) �' PUMPINGVSATION
AGE 0 (DRY) 34v :.'"_Pond B ; (838.61) K65W c
320 I �b wo
STORAGE _ -- - -�--- -- - - - _ b
- - S APPROXIMATE �� y Z
�� O - _ R W— 5 WATION OF
ATER IICSUPPLY
❑ APPROXIMATE WELL FOR PLANT ' U
0 335 LOCATION.OF ® OPERATIONS (IN USE) 31S O 0 rn '^'
- SUPPLY WWELLL FOR PLANT
OPERATIONS (NOT IN USE)
330
310
j - - I - - Residential
MAIN i Properties
PLANT 325 !/ - �
K65 "D"
320 K65W7" K"
"J" �I o
i �®(808.93)
--- 65W7
315 (8 6) ®(808.13)
- -� , ------ K65W7"t_"0 W-6 - j' ,' oo N
I
310
Qj
Southern States Cooperative Inc. \ ! r �r
Statesville Fertilizer Facility I� !
LV
',I `� jay � -__ '� --_ ,� o •� N
Legend
�65 7"
Q5 Saprolite Monitoring Well
� H W s
® V
(DRY) RW 2
K65W7'�F" &
IS Bedrock Monitoring Well K65W7"C" ( 0
® Recovery Well
(350) Ground Water Elevation in Feet
Ground Water Contour
Ground Water Flow Direction K65W7"D"
_
PropertyLme_----- - --- - _-
Graphical Scale
Note: Pond A and B are approximate - Dry Stream
locations based on CAP data (1994 Canonie) 4 180 360

Purina Feed Mill Property
Property Line
840
vRr1%Air,1'n'1 ' Former LOCATION OF
Pond B
AGE
STORAGE
845 LOCATION OF
APPRO)'MATE WELL FOR PLANT
C==:] LOCATION OF OPERATIONS (IN USE)
WA EH
FORMER
840 SUPPLY WELL FOR PLANT 825
OPERATIONS (NOT IN USE)
820
83p-
815
MAIN
810
Southern States Cooperative Inc.
Statesville Fertilizer Facility
Legend
Q5 Saprolite Monitoring Well
0 Bedrock Monitoring Well
A Recovery Well
(350) Ground Water Elevation in Feet
Ground Water Contour
Ground Water Flow Direction
(NM) Not Measured Property Line -
Note: Pond A and B are approximate Graphical Scale
Properties
CIO
C14
CD
(DRY
Z
My
Dry Stream