NC0082821_Regional Office Historical File Pre 2018 (10)

Southern States
Cooperative, Inc.
'�' C' OPPu• OP 1VATi1ddAl
6606 West Broad Street
Post Office Box 26234
RESOV?�CZS AND
OOIi21FdT1�'I it -;y , , n ,
Richmond, Virginia 23260
Telephone [phone]
SEP 2 1�3�
s
y
DIVISIET OF
COO
�.E tft�F fiF f f i OFFICE
Southern
States
September 25, 1990
Mrs. Chris DeRoller
2ydrogeologist
State of North Carolina
Department of Environment,
Health & Natural Resources
919 North Main Street
Mooresville, NC 28115
RE: Groundwater Incident # 5083
Iredell County, NC
Dear Mrs. DeRoller:
I,
Enclosed are two copies of the Phase II Groundwater
Assessment report for the above referenced incident.
I received a copy of Mr. William Pope's reply to your
letter of September 12, to Mr. Tsumas, but have had no further
contact with Mr. Tsumas or Mr. Pope. It appears that Mr. Pope
has consented for you to obtain the required samples but still
has not given us authorization to do so. Please advise your
course of action in this matter.
If you have questions, please advise.
Sincerely,
i Hilton M. Withers
Manager, Environmental Affairs
HMW/pgf
cc: Kim Bram
Louis Ingram

LAW ENVIRONMENTAL, INC.
431 MINUET LANE
CHARLOTTE, NORTH CAROLINA 28217
P.O. BOX 240674
CHARLOTTE, NORTH CAROLINA 28224-0674
704-527-6717
September 21, 1990
Iv. C. Pr1'-r
,-
Southern States Cooperative, Inc.
P.O. Box 26234
Richmond, VA 23260
Attention: Mr. Hilton M. Withers
Manager, Environmental Affairs
Subject: Report of Phase H Ground -Water Assessment
Southern States Fertilizer Plant
Statesville, North Carolina
LEI Job No. 56-9606.50
Gentlemen:
As authorized by your acceptance of our Proposal contained in our June 15, 1990 submittal
entitled "Response to May 4, 1990 State letter and proposed Phase II Ground -Water
Assessment", Law Environmental, Inc. has completed the proposed ground -water assessment
activities at the Southern States Fertilizer Plant in Statesville; North Carolina. The purpose
of our work was to provide additional response to a Notice of Violation for the site issued
on December 12, 1989 and a May 4, 1990 letter, both by the North Carolina Department
of Environment, Health, and Natural Resources (NCDEHNR). This report summarizes our
understanding of the background information, our field investigation procedures and
laboratory testing results, and our data interpretation and recommendations.
In summary, concentrations of nitrate/nitrite ground -water contamination were encountered
in each of the newly constructed monitoring wells on site. Based on these findings, Law
Environmental proposes additional investigative activities to more clearly define the vertical
and horizontal extent of contamination. Detailed information regarding our findings and
recommendations is presented herein.

Southern States Cooperative, Inc.
September 21, 1990
Page 2
We note that one of the ground -water monitoring wells planned for this phase of our work
(Well K65W6"F") was not installed. The well was to be drilled east of the Southern States
site on property owned by Ralston Purina Company. A formal request was made to
Ralston Purina for permission to drill on their property (please refer to the access request
letter included in the Appendix). However, authorization to proceed was granted too late
for the information to be included herein. The well was installed on September 18, 1990
and results of ground -water sampling and testing will be forwarded under separate cover as
they become available.
Law Environmental appreciates the opportunity to provide our professional consulting
services on this phase of the project. If you have any questions regarding this report please
feel free to contact us.
Sincerely,
LAW ENVIRONMENTAL, INC.
Bernard B. Schumak
Project Hydrogeologist
r
Thomas F. Beggs, P.E.
Principal
Jimmy N. Smith, P.E.
Assistant Vice President
Charlotte Services Manager
BBS:TFB:JNS:lwv
Attachments

K�J

TABLE OF CONTENTS
PAGE
1.0 PROJECT INFORMATION .................................. 1-1
1.1 Background Summary .................................. 1-1
1.2 Notice of Violation .................................... 1-2
2.0 ASSESSMENT ACTIVITIES .................................. 2-1
2.1 Soil Test Borings ...................................... 2-1
2.2 Monitoring Well Installation ............................. 2-2
2.3 Ground -Water Sampling .......................:........ 2-4
3.0 SUBSURFACE CONDITIONS ................................ 3-1
4.0 RESULTS OF CHEMICAL ANALYSES 4-1
5.0 DATA ANALYSIS AND INTERPRETATION .................... 5-1
5.1 Ground -Water Analysis ................................... 5-1
5.2 Soil Analysis ........................................... 5-2
6.0 CONCLUSIONS AND RECOMMENDATIONS ................... 6-1
TABLES
FIGURES
APPENDIX - TEST BORING RECORDS
GROUND -WATER MONITORING WELL
INSTALLATION RECORDS
WELL CONSTRUCTION RECORDS
LABORATORY TEST DATA REPORTS
ACCESS REQUEST LETTER

1.0 PROJECT INFORMATION
1.1 Background Summary
The Southern States Fertilizer Plant is located on U.S. Highway 70 approximately six miles
east of Statesville, North Carolina (see Figure 1). We understand that the facility was
constructed in the 1950's. Southern States Cooperative, Inc. purchased the plant from W.
R. Grace & Co. in February, 1988.
Various farm and garden fertilizers are manufactured at the plant using raw materials
brought in by truck and rail. The materials are usually off-loaded directly onto conveyor
belts for transfer to storage areas within the plant.
Finished products are warehoused on site pending shipment. Small warehouse areas at the
north end of the main plant and in a small building just east of the main plant are also used
to store pre -mixed, bagged products on pallets. These products are sold direct to consumers
without modification by Southern States.
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 smokestack emissions. The scrubbers use a "wet" system which takes up all excess
process water in the plant.
1-1

Prior to scrubber installation approximately ten years ago, excess process water was
reportedly discharged into holding ponds on site. Two of the former holding ponds are
extant approximately 1,000 ft southwest of the plant. Two other ponds have reportedly been
closed. One of these was located due east of the plant (near Well K65W6"B") and was
reportedly closed approximately twenty years ago. The other was located 300 ft southeast
of the plant (near Well K65W6) and was reportedly closed approximately five years ago.
Modifications to plant processes have been implemented over the past several years, and
waste products are now believed to be appropriately contained within the manufacturing
facility.
A general site location plan is presented in the attached Figure 1. Site topography and
specific features are presented in Figures 2 and 3.
1.2 Notice of Violation
Southern States Cooperative retained Law Environmental in September, 1989 to assist with
evaluation and remediation efforts at the Statesville Fertilizer Plant. On December 12,
1989, the North Carolina Department of Environment, Health and Natural Resources
(NCDEHNR) issued a Notice of Violation for the site.
The notice (received by Southern States on December 20, 1989), stated that excessive
concentrations of nitrate and/or nitrite had been discovered in two NCDEHNR wells at the
site. Combined nitrate/nitrite concentrations were greater than the threshold value of 11
1-2

mg/l 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 within 60 days.
On January 19, 1990, representatives of Southern States Cooperative and Law
Environmental met with Messrs. Jesse Wells and Jeff Lautier at the NCDEHNR
Mooresville office. It was agreed that Law Environmental would construct six ground -water
monitoring wells at the site. Two of the wells would be extended to bedrock (defined as
auger refusal) and four would be shallow monitoring wells intended to address the lateral
extent of contamination. (Please refer to Law Environmental's February 5, 1990 letter
outlining the proposed field work.) Well installation 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's Phase I
Ground -Water Assessment Report dated March 29, 1990 (LEI Job No. 56-9606.40).
Additional ground -water assessment was recommended.
On May 4, 1990, the State of North Carolina Department of Environment, Health and
Natural Resources (NCDEHNR) issued a letter to Southern States Cooperative, Inc. The
letter indicated that the NCDEHNR Mooresville Regional Office had reviewed Law
Environmental's Phase I Ground -Water Assessment report for the Statesville Southern
States Fertilizer Plant. The letter stated that NCDEHNR was in agreement with Law
1-3

concerning the need for further assessment activities. NCDEHNR indicated that these
activities should be designed to more fully define the vertical and horizontal extent of
nitrate/nitrite ground -water contamination. Specifically, NCDEHNR suggested six points
for consideration during Phase II assessment.
A June 15, 1990 submittal (LEI Job No. 56-9606.60) was prepared by Law to respond to the
May 4, 1990 State letter. It also contained a proposed Phase II Ground -Water Assessment
work plan.
This Phase II Assessment report is intended to address the specific items set forth in the
NCDEHNR Notice of Violation and their May 4, 1990 letter. A report submittal date
extension was granted by NCDEHNR based on an extension request issued by Southern
States on June 26, 1990. The extension established a new report submittal deadline of
October 1, 1990.
Our understanding of the plant procedures and processes is based on our discussions with
Southern States personnel. We have also been furnished with general site topography plans.
We have not conducted a detailed review of plant records or process equipment
specifications.
1-4

2.0 ASSESSMENT ACTIVITIES
2.1 Soil Test Borings
Our Phase II assessment activities included four soil test borings. These borings were
designated K65W6"D", K65W71)", K65W70, and K65W77. A fifth soil test boring
(K65W6"F") was planned for Phase II; however, authorization from the property owner to
drill this off -site boring was provided too late for the results to be included herein. The
borings were positioned such that they would supplement information gathered during Phase
I regarding ground -water contour elevations and contaminant plume concentrations. The
boring locations are shown in the attached Figure 2.
The borings were drilled by mechanically advanced, hollow -stem steel augers. Soil sampling
and penetration testing were performed in general accordance with ASTM D 1586. At
regular intervals, soil samples were obtained with a standard 1.4-inch I.D., 2-inch O.D., split -
tube sampler. The sampler was first seated 6 inches to penetrate any loose cuttings, and
then driven an additional 12 inches with blows of a 140-pound hammer falling 30 inches.
The number of blows required to drive the sampler the final 12 inches was recorded and
is designated the "penetration resistance".
Representative portions of the soil samples, thus obtained, were examined by an engineer
and a geologist in the laboratory to verify the driller's field classifications. Test Boring
Records are included in the Appendix, showing the soil descriptions and penetration
resistances.
2-1

2.2 Monitoring Well Installation
Seven ground -water monitoring wells were completed at the subject site. Four of these wells
were installed at the locations of the four soil test borings mentioned previously. These
wells, screened near the water table, were designated K65W6"D", K65W7"D", K65W7"E",
and K65W7"G". The four shallow screened wells consisted of 2-inch diameter schedule 40
PVC pipe with flush -threaded joints. The lower 10-ft section of each well consisted of
manufactured 0.010-inch wide slot well screen. Washed sand backfill was placed around the
outside of the pipe to at least 2-ft above the top of the well screen. A 2-ft minimum
bentonite seal was placed above the sand backfill. The remainder of the annular space was
grouted to the surface with a cement/bentonite grout. Ground -Water Monitoring Well
Installation Records presented in the Appendix illustrate well construction details.
Ground -water monitoring wells K65W6"D", K65W7"D", K65W7"E" and K65W7G" were
constructed as water -table wells with the top of the well screen placed near the water table
at the time of construction.
Wells K65W6"E", K65W7F" and K65W7"H" were completed within 10 ft horizontally of
existing wells. Well K65W7F" was screened at a depth of approximately 17.5 to 27.5 ft
below ground surface. This depth corresponded to the point of auger refusal in partially
weathered rock.
2-2

Wells K65W6"E" and K65W7"H" were constricted utilizing air rotary drilling techniques.
These wells consisted of approximately 6-inch PVC riser grouted in the shallow zone to
better seal off the shallow zone. An approximately 4-inch PVC riser was then grouted to
the top of competent rock. The borehole was then advanced approximately 10 ft with a 3-
7/8 inch air -hammer to the desired open -face interval.
At each location, the down -hole drilling equipment was decontaminated by steam cleaning
prior to drilling. Steam cleaning was performed to minimize the possibility of cross -
contamination between wells.
Upon completion of drilling, lockable steel covers were placed over each well. The covers
are intended to protect the well casing and deter vandalism. Each cover was grouted at the
surface.
Horizontal locations of the monitoring wells and borings were identified in the field by a
registered surveyor licensed in the State of North Carolina. Relative elevations of the tops
of well casings and the ground surfaces at the borings were measured with a survey level and
rod, referencing a benchmark identified by the furnished topographic plan drawing. The
benchmark, (a railroad spike in the base of a telephone pole near the west entrance drive),
was assumed to be at an elevation of 868.30 MSL.
2-3

Test Boring Records, Ground -Water Monitoring Well Installation Records and Well
Construction Records are presented in the Appendix.
2.3 Ground -Water Sampling
Ground -water samples were obtained from each monitoring well on August 1, 1990.
Sampling was performed by a team of hydrogeologic technicians from our office.
The monitoring wells were developed to allow the formation around the screened interval
to recover from the effects of drilling and to bring fresh formation water into the wells. The
water table wells were developed by removing at least six well volumes using separate,
decontaminated, Teflon bailers. Rock wells were developed using air lifting techniques,
removing at least six well volumes.
The wells were sampled using Teflon bailers and new polypropylene rope. The Teflon
bailers were cleaned in the laboratory with phosphate -free detergent, dilute nitric acid, and
isopropanol, with distilled water rinse after each step. The bailers were wrapped with
aluminum foil to minimize the possibility of contamination during transportation to the site.
Field measurements included water levels, pH, and specific conductivity. Table 1 illustrates
measured field parameters from both the February (Phase I) and August (Phase II)
sampling events.
2-4

The samples were packaged in ice and shipped for chemical analysis via next -day delivery
to Law Environmental National Laboratories in Kennesaw, Georgia. The samples were
tested for nitrate and nitrite content in general accordance with EPA Method 353.2. Chain -
of -custody documentation was used to provide a written record tracing the possession and
handling of the samples from the time of collection through laboratory analysis and final
recording of the results. Laboratory analysis and a copy of the chain -of -custody are included
in the Appendix.
2-5

3.0 SUBSURFACE CONDITIONS
The project site is located in the Piedmont Physiographic Province, an area underlain by
ancient igneous and metamorphic rocks. The virgin soils encountered in this area are the
residual product of in -place chemical weathering of rock which was similar to the rock
presently underlying the site. In areas not altered by erosion or disturbed by the activities
of man, the typical residual soil profile consists of silty and/or clayey soils near the surface,
where soil weathering is more advanced, underlain by sandy silts and silty sands. The
boundary between soil and rock is not sharply defined. This transitional zone termed
"partially weathered rock", is normally found overlying the parent bedrock. Partially
weathered rock is defined, for engineering purposes, as residual material with standard
penetration resistances in excess of 100 blows per foot. Weathering is facilitated by
fractures, joints and by the presence of less resistant rock types. Consequently, the profile
of the partially weathered rock and hard rock is quite irregular and erratic, even over short
horizontal distances.
Generally, the soil borings drilled during this phase of assessment encountered residual soils
ranging from sandy silts to silty sands. The silty soils extended from the ground surface to
depths of approximately 10 feet. Below 10 ft, primarily silty fine sands were encountered.
The sands ranged in relative density from very loose to dense. Boring K65W7F"
encountered mainly sandy soils.
3-1

Borings K65W7"D" and K65W717" were extended into partially weathered rock (sampled
as silty fine to medium sand). Partially weathered rock is defined as residual material
having a standard penetration resistance greater than 100 blows per foot. Boring K65W7"7"
encountered auger refusal at a depth of 28.0 feet below grade. Refusal to soil drilling
equipment may indicate a boulder, lenses of rock, or bedrock. Core drilling would be
required to characterize the refusal material.
After a stabilization period ranging from 5 to 21 days, the ground -water level in each well
was measured using a battery -operated electronic measuring device. At borings K65W6 "A"
through "E", the ground -water depths ranged from approximately 16.3 to 31.3 ft below grade.
At borings K65W7 "A" through "H", ground -water depths ranged from 4.5 to 27.3 ft below
grade.
As shown in Figure 2, our measurements revealed that the ground -water flow direction is
generally northeast to southwest. Previous data confirms this trend, and further suggests
that a ground -water high point or "ridge" straddles the northeast corner of the site. Ground-
water northeast of the "ridge" apparently flows northeastward toward Fourth Creek, while
ground -water southwest of the ridge flows southwestward toward Third Creek. Figure 2
illustrates estimated ground -water elevations.
3-2

Ground -water levels may fluctuate several feet with seasonal and rainfall variations.
Normally, the highest ground -water levels occur in late winter and spring and the lowest
levels occur in late summer and fall. We note that due to the limited number of monitoring
well locations, the considerable topographic relief, and the fact that LEI and NCDEHNR
measurements were taken on different dates, the contour lines illustrated in Figure 2 depict
general flow only; localized flow may be somewhat different.
The above descriptions provide a general summary of the subsurface conditions
encountered. The Test Boring Records in the Appendix contain detailed information
recorded at each boring and include our interpretation of the subsurface conditions based
on examination of the field samples. The lines designating interfaces between various strata
represent approximate boundaries and the transition between strata may be gradual.
Generalized lithologic cross -sections are presented in Figures 4 and 5.
3-3

4.0 RESULTS OF CHEMICAL ANALYSES
Table 1 summarizes the laboratory chemical test results. The ground -water samples were
tested for nitrate and nitrite concentrations in general accordance with EPA Method 353.2.
As previously noted, 15A NCAC 2L guidelines for drinking water quality set forth a
standard threshold for nitrate of 10 mg/1 and for nitrite of 1 mg/l. Our testing indicated
that the combined nitrate/nitrite concentrations ranged from a low of 0.63 mg/1 at. boring
K65W6"D" to a high of 280 mg/l at boring K65W7"H". Law monitoring wells sampled on
February 13, 1990 are also listed on Table 1. The potable water well of unknown depth
located south of the site (sampled by others during the summer of 1989) also reportedly
showed a nitrate/nitrite concentration (22 mg/1) above drinking water standards. Measured
nitrate/nitrite concentrations and estimated horizontal isopleths are presented in Figure 3.
The isopleths illustrated should only be used in a general manner and actual concentrations
are likely to be somewhat different. Vertical nitrate/nitrite concentrations are illustrated
in Figures 4 and 5.
4-1

5.0 DATA ANALYSIS AND INTERPRETATION
5.1 Ground -Water Analysis
The purpose of the new monitoring wells was to help identify the extent of ground -water
contamination and to provide information to respond to the State's December 12, 1989
Notice of Violation and their May 4, 1990 letter. Laboratory analysis of ground -water
samples obtained from the new monitoring wells indicated the presence of nitrate/nitrite
(as N). Monitoring wells K65W7D", K65W7E", K65W7F" and K65W714" revealed
ground -water N concentrations in excess of 15A NCAC 2L drinking water standards.
Laboratory analysis from well K65W711" (within 10 ft horizontally of existing wells K65W7
and K65W7A") indicated that N contamination exists in shallow, intermediate, and deep
aquifer zones at this location. Well K65W7A" previously encountered auger refusal at
approximately 44 ft below grade and is screened from approximately 32 to 42 feet.
Monitoring well K65W714" is a rock well with its open face interval from approximately 100
to 110 feet. Monitoring well K65W7 is an NCDEHNR well and is screened close to the
water table. The total depth of N contamination at the K65W7 well cluster is currently
unknown.
Monitoring wells K65W7D" and K65W7E" had N values slightly above drinking water
standards. Monitoring wells K65W7"F" and K65W7G" were installed close to the southwest
corner of the property and had measured N concentrations of 99 mg/l and 1.7 mg/l,
5-1

respectively. Well K65W7"F" is screened from approximately 17.5 to 27.5 ft in partially
weathered rock near auger refusal. K65W 7 "G" is a water table well screened from
approximately 5.0 to 15.0 feet. It is likely that ground -water contamination has migrated off -
site at the southwest corner of the site.
Based on the water -table wells, subsurface N contamination is thought to have mainly
migrated along a path following the surface drainage feature between wells K65W6 and
K65W7"G". The limits of N contamination to the east of well K65W6 and to the south of
K65W7"G" have not been determined. Access to drill the proposed well K65W6"F" had not
been granted by the property owner when this submittal was being prepared. A formal
request was made and a drawing illustrating the proposed location was provided to the
relevant property owner on July 18, 1990 (a copy of the letter is included in the Appendix).
The proposed location was also surveyed by a North Carolina. Registered Surveyor.
However, authorization from the property owner to drill K65W6"F" was granted too late for
the results to be included herein.
5.2 Soil Analysis
In conjunction with our ground -water sampling activities, we obtained representative soil
samples from each monitoring well location. The samples were obtained from depths of
approximately three ft below grade using a manually advanced steel auger. The auger was
cleaned between sampling locations.
5-2

Soil samples were returned to our laboratory for nitrate/nitrite testing. The results of these
tests are presented in Table 2.
In summary, our sampling and testing indicated that N contamination does not appear to
be present in near -surface soils at significant concentrations. Neither nitrate nor nitrite was
detected in samples representing four of the seven boring locations. Nitrate was not
detected in any of the seven samples. At the three locations where nitrate was detected,
concentrations varied from 1.1 to 3.4 mg/l. Laboratory analysis for the soil sample taken
near recently completed monitoring well K65W6"F" will be submitted at a later date.
5-3

6.0 CONCLUSIONS AND RECOMMENDATIONS
This Phase H Assessment has contributed substantially to the documentation of
nitrate/nitrite contamination at the Southern States Fertilizer Plant. The extent of N in
ground water has been well defined. However, it is our opinion that further assessment
activities will be necessary to meet the requirements outlined in the NCDEHNR May 4,
1990 letter.
Based on the laboratory analysis completed to date and information provided to us by
Southern States and W. R. Grace, we believe that the source of ground -water contamination
is associated with past plant activities. Specifically, the presence of holding ponds appears
to have been responsible for the impact on ground water at the site. This conclusion is
supported by the elevated N concentrations down -gradient of both the former holding ponds
east and southeast of the plant and the two existing ponds southwest of the plant.
Modifications to plant processes have been implemented over the past several years, and
waste products are now believed to be appropriately contained within the manufacturing
facility.
Near -surface soil samples obtained at the site contained very low N concentrations.
Nitrate/nitrite concentrations in ground -water, however, have been found to increase with
depth at several locations. It therefore appears likely that the source of contamination has
been adequately addressed by recent plant modifications and significant releases are no
6-1

longer occurring. Nitrate/nitrite in the near surface soil has probably been dissipated by
biological reduction, and shallow ground -water zones have probably been flushed by rainfall
percolation.
The extent of N contamination in ground water has not yet been completely defined. The
creek which borders the site to the west and south may be acting as a barrier to off -site
migration of contaminants. Possible off -site migration eastward has not yet been addressed
because authorization for installation of monitoring well K65W6"F" has only recently been
granted by the adjacent property owner. High N concentrations in the deep wells at
K65W7"H" and K65W7"F" indicate that the vertical extent of contamination has not yet been
defined.
Law Environmental therefore recommends that the following steps be initiated as part of
a Phase III Assessment at the site:
1. Sample the recently installed well at K65W6"F" and incorporate
the findings into this Phase II assessment.
2. Obtain samples from the inoperable former potable water wells
located south and east of the site. These deep wells could yield
valuable information regarding the vertical extent of N
concentrations.
6-2

3. Obtain surface water samples from the creek which borders the
site. Samples should be gathered upstream, midstream, and
downstream of suspected areas of contamination.
4. Install a water table monitoring well and a monitoring well
extending to the top of partially weathered rock near the
existing deep potable well south of the site. This would provide
three vertical sampling points in the vicinity. Authorization
from the relevant property owner would need to be obtained.
5. Install an additional deep Type III monitoring well (with open
face sampling zone from 175 to 200 ft below grade) near
K65W7. The purpose of this well would be to determine the
vertical extent of N contamination in the vicinity of the existing
former holding ponds.
6-3

TABLE 1
GROUND -WATER FIELD PARAMETERS/LABORATORY ANALYSES
SOUTHERN STATES FERTILIZER PLANT
STATESVILLE, NORTH CAROLINA
LEI JOB NO. 56-9606.50
Specific
Boring
Conductance
NO2 + NO3
Number
Temperature Co
my/cm
pH
(as N) mg/l
*K65W6"A"
18.6
6.430
5.27
370
*K65W6"B"
15.7
0.330
4.31
22
*K65W6"C"
15.2
0.841
5.41
76
*K65W7"A"
16.0
1.320
5.81
53
*K65W7"B"
14.5
0.983
4.30
21
*K65W7"C"
14.9
1.878
4.49
93
K65W611D"
18.0
0.041
5.01
0.63
K65W6"E"
18.9
0.500
11.17
7.3
K65W711D"
22.4
1.100
5.14
11
K65W7"E"
16.3
0.234
4.75
15
K65W7"F"
19.6
1.777
5.73
99
K65W7"G"
18.6
0.090
5.01
1.7
K65W7"H"
25.2
N.M.
6.11
280
* - Wells sampled on 2/13/90, others sampled on 8/1/90.
N.M. - No Measurement, instrument not working properly.

TABLE 2
SOIL SAMPLING/LABORATORY ANALYSES
SOUTHERN STATES FERTILIZER PLANT
STATESVILLE, NORTH CAROLINA
LEI JOB NO. 56-9606.50
Boring
Sample Depth
Nitrate - NO3
Nitrite - NO2
Number
(feet)
(in mg/1)
(in mg/1)
K65W6"D"
3
ND
ND
K65W6"E"
3
3.4
ND
K65W711D"
3
1.6
ND
K65W7"E"
3
ND
ND
K65W711F"
3
1.1
ND
K65W711G"
3
ND
ND
K65W711H"
3
ND
ND
ND - Not Detected
Samples analyzed by Law Environmental National Laboratories,
Kennesaw, Georgia.

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�`� 5.� 1 1 \�. �eso. I ( N• ' -- ': ^-- N{yY -___ ra ,. 9
1_870
( r •, '-�. '. !� l Tom" l /'.'� /
N-N
0 2000 I �i
APPROX. SCALE, FT. g LAW ENVIRONMENTAL, INC.
CHARLOTTE, NORTH CAROLINA
SITE LOCATION MAP
SOUTHERN STATES FERTILIZER PLANT
STATESVILLE NORTH CAROLINA
REF.: U.S.G.S. 7.5 MIN. TOPOGRAPHIC MAP, STATESVILLE EAST QUADRANGLE, DATED 1969. JOB NO. 56-9606 FIGURE 1

APPENDIX
`rES`I' BORING RECORDS
GROUND -WATER MONITORING WELL INSTALLATION RECORDS
WELL CONSTRUCTION RECORDS
LABORATORY TEST DATA REPORTS
ACCESS RF',QU S LETTER

o''_�

CORRELATION OF PENETRATION RESISTANCE
I WITH CONSISTENCY
NO. OF BLOWS, N
RELATIVE DENSITY
PARTICLE SIZE IDENTIFICATION
I 0-4
Very Loose
BOULDERS: Greater than 300 mm
5-10
Loose
SANDS: 11-20
Firm
m COBBLES: 75 mto 300 mm
V ery m
GRAVEL: Coarse - 19.0 mm to 75 mm
I 31-30
OVER 50
Dense
Very Dense
Fine - 4.75 mm to 19.0 mm
SANDS: Coarse - 2.00 mm to 4.75 mm
NO. OF BLOWS, N
CONSISTENCY
Medium - 0.425 mm to 2.00 mm
Fine - 0.075 mm to 0.425 mm
I 0-2
Very Soft
3-4
Soft
SILTS & CLAYS: Less than 0.075 mm
SILTS 5-8
Firm
& 9-15
Stiff
NOTE: Numbers next to boring on
I CLAYS: 16-30
Very stiff
.profile
represent standard penetration
31-50
Hard
resistance (blows per foot).
OVER 50
Very Hard
KEY TO DRILLING SYMBOLS
I Undisturbed Sample
i Water Table 24 HR. BT Boring Terminated
® Split Spoon Sample
SZ Water Table at Time of Drilling AR Auger Refusal
KEY TO SOIL CLASSIFICATIONS
TOPSOIL
SANDY CLAYEY SILT
SANDY SILT
SILTY SAND
SAND
PARTIALLY WEATHERED ROCK

DEPTH
(FT.)
0.0
0.5
5.0
9.0
30.0
38.0
DESCRIPTION ELEVATION • PENETRATION - BLOWS/FOOT
(FT.)
RA-7 , 0 10 20 30 40 60 80 100
Topsoil
-
842.1
837 1
832.1
827.1
822.1
817.1
812.1
Residuum: Very stiff red brown micaceous sandy
SILT
-- - - - - - - - - - - - - - - - - - - - - - - --
Firm red brown micaceous sandy SILT
-- — — — — — — — — — — — — — — — — — — — — — — — —
Loose gray tan micaceous silty fine SAND
Firm to very firm gray tan micaceous silty fine
SAND
-
Boring terminated at 38.0 feet
REMARKS:
SEE KEY SHEET FOR EXPLANATION OF
SYMBOLS AND ABBREVATIONS USED ABOVE
20
16
8
5
6
8
10
1
7
16
28
BORING NUMBER K65W6 D
DATE DRILLED July 12, 1990
PROJECT NUMBER 56-9606.50
PROJECT SOUTHERN STATES FERTILIZER
PAGE 1 OF 1

DEPTH
(FT.)
0.0
0.5
6.(
8.(
12.(
18.0
22.0
23.0
DESCRIPTION ELEVATION • PENETRATION - BLOWS/FOOT
(FT.)
,02 R 0 10 20 30 40 60 80 100
Topsoil
793.E
788.6
783.E
778.6
?73.6
768.E
763.6
Residuum: Very stiff brown sandy SILT
Firm orange brown silty SAND
Firm brown gray sandy clayey SILT
Z.
Very stiff tan orange clayey SILT with coarse sand
Dense brown fine to coarse SAND
Partially weathered rock sampled as gray brown
silty medium SAND
Boring terminated at 23.0 feet
SEE KEY SHEET FOR EXPLANATION OF
SYMBOLS AND ABBREVATIONS USED ABOVE
15
22
11
8
25
36
50/2"
BORING NUMBER K65W7 D
DATE DRILLED July 13, 1990
PROJECT NUMBER 56-9606.50
PROJECT SOUTHERN STATES FERTILIZER
PAGE 1 OF 1

DEPTH
(FT.)
0.0
0.5
8.0
13.0
35.0
DESCRIPTION ELEVATION • PENETRATION - BLOWS/FOOT
(FT.)
Q,,, , 0 10 20 30 40 60 80 100
Topsoil
816.4
811.4
806.4
801.4
796.4
791.4
786.4
Residuum: Stiff to very stiff red brown sandy
clayey SILT
-------------------- - - - - - -
Stiff red brown sandy clayey SILT
Firm to very firm brown and tan micaceous silty
SAND
Boring terminated at 35.0 feet
REMARKS;
Soil descriptions based on driller's field log.
SEE KEY SHEET FOR EXPLANATION OF
SYMBOLS AND ABBREVATIONS USED ABOVE
15
20
17
12
12
16
11
13
25
BORING NUMBER K65W7 E
DATE DRILLED July 11, 1990
PROJECT NUMBER 56-9606.50
PROJECT SOUTHERN STATES FERTILIZER
PAGE 1 OF 1

DEPTH
(FT.)
0.0
0.5
5.0
11.0
22.0
28.0
DESCRIPTION ELEVATION • PENETRATION - BLOWS/FOOT
(FT.)
70Q Q 0 10 20 30 40 60 80 100
Topsoil
788.8
783.8
778.8
773.8
768.8
763.8
758.8
Residuum: Firm gray tan silty medium SAND
with some coarse sand and gravel
--------------------------
Very loose to loose gray tan silty medium SAND
with coarse sand
Very firm to very dense gray tan, red orange silty
fine SAND
Partially weathered rock sampled as gray tan, red
orange silty fine SAND
Auger refusal at 28.0 feet
REMARKS:
SEE KEY SHEET FOR EXPLANATION OF
SYMBOLS AND ABBREVATIONS USED ABOVE
10
13 1
4
7
37
27
50/1"
50/0"
BORING NUMBER K65W7 F
DATE DRILLED July 16, 1990
PROJECT NUMBER 56-9606.50
PROJECT SOUTHERN STATES FERTILIZER
,PAGE 1 OF 1

GROUND -WATER MONITORING WELL INSTALLATION RECORDS

1
GROUND -WATER MONITORING WELL INSTALLATION RECORD
JOB NAME SOUTHERN STATES PLANT JOB NUMBER 56-9606.50
WELL NUMBER K65W6"D" GROUND SURFACE ELEVATION 847.14 FT.
LOCATION SOUTHERN STATES FERTILIZER PLANT,' STATESVILLE, NORTH CAROLINA
INSTALLATION DATE 7/12/90
LOCKABLE CAP
VENTED PVC CAP
STEEL PIPE
STICKUP 2.23 FT.
BORING
CEMENT/BENTONITE GROUT
BENTONITE SEAL
2' PVC PIPE
SAND
'
PVC SCREEN
CAP
1 NOTE: ALL PVC PIPE JOINTS HAVE SCREW CONNECTORS
DEPTH TO
BASE OF
GROUT SEAL
20.0 FT. DEPTH TO
TOP OF
SAND BACKFILL
22.5 FT.
TOTAL DEPTH
OF WELL
-38.0 FT.
DEPTH OF
PVC SCREEN
GROUND WATER 29.37 FT. BELOW TOP OF CASING ON 8/1/90 1
MONITORING WELL
LAW ENVIRONMENTAL, INC.
:�: INSTALLATION RECORD
CHARLOTTE, NORTH CAROLINA

MONITORING WELL INSTALLATION RECORD
JOB NAME SOUTHERN STATES PLANT JOB NUMBER 56-9606.50
WELL NUMBER K65W6"E" GROUND SURFACE ELEVATION 862.85 FT.
LOCATION SOUTHERN STATES FERTILIZER PLANT, STATESVILLE, NORTH CAROLINA
INSTALLATION DATE 7/24/90
LOCKABLE CAP
GROUT SEAL
BOREHOLE
PVC PIPE
CEMENT/BENTONITE GROUT
4" DIA. PVC PIPE
CEMENT/BENTONITE GROUT
ROCK
OPEN FACE
ROCK WELL
ig
PVC CAP
STICKUP 2.04 FT.
DEPTH OF 6"
PVC PIPE
62.0 FT.
DEPTH OF 4"
PVC PIPE
123.3 FT.
GROUND
SURFACE
TOTAL
DEPTH OF
WELL
133.0 FT.
GROUND WATER 18.82 FT. BELOW TOP OF CASING ON 8/1/90.
LAW ENVIRONMENTAL, INC. MONITORING WELL
INSTALLATION RECORD
CHARLOTTE, NORTH CAROLINA

GROUND -WATER MONITORING WELL INSTALLATION RECORD
JOB NAME SOUTHERN STATES PLANT JOB NUMBER 56-9606.50
WELL NUMBER K65W7"D" GROUND SURFACE ELEVATION 798.59 FT.
LOCATION SOUTHERN STATES FERTILIZER PLANT, STATESVILLE, NORTH CAROLINA
INSTALLATION DATE 7/13/90
LOCKABLE CAP
STEEL PIPE-, VENTED PVC CAP
2.05 FT.
BORING
DEPTH TO
BASE OF
GROUT SEAL
CEMENT/BENTONITE GROUT 9.0 FT.
DEPTH TO
TOP OF
SAND BACKFILL
11.0 FT.
BENTONITE SEAL
2' PVC PIPE
�13.0 FT.
SAND llA-E
' DEPTH OF
PVC SCREEN PVC SCREEN
CAP 23.0 FT.
I NOTE: ALL PVC PIPE JOINTS HAVE SCREW CONNECTORS
TOTAL DEPTH
OF WELL
23.5 FT.
GROUND WATER 10.80 FT. BELOW TOP OF CASING ON 8/1/90
A= MONITORING WELL
LAW ENVIRONMENTAL, INC.
c • INSTALLATION RECORD
lql!L-
CHARLOTTE, NORTH CAROLINA

GROUND -WATER MONITORING WELL INSTALLATION RECORD
JOB NAME SOUTHERN STATES PLANT JOB NUMBER 56-9606.50
WELL NUMBER K65W7"E" GROUND SURFACE ELEVATION 821.46 FT.
LOCATION SOUTHERN STATES FERTILIZER PLANT, STATESVILLE, NORTH CAROLINA
INSTALLATION DATE 7/11/90
LOCKABLE CAP
STEEL PIPE VENTED PVC CAP
STICKUP 2.24 FT
BORING
DEPTH TO
BASE OF
SEAL
T S
CEMENT/BENTONITE GROUT 21 GROU
DEPTH TO
TOP OF
SAND BACKFILL
23.0 FT.
BENTONITE SEAL
2' PVC PIPE
25.0 FT.
SAND
DEPTH OF
PVC SCREEN PVC SCREEN
CAP L35.0 FT.
I NOTE: ALL PVC PIPE JOINTS HAVE SCREW CONNECTORS
TOTAL DEPTH
OF WELL
35.6 FT.
GROUNDWATER 25.55 FT. BELOW TOP OF CASING ON 8/1/90 1
iL
G LAW ENVIRONMENTAL, INC. MONITORING WELL
INSTALLATION RECORD
CHARLOTTE, NORTH CAROLINA

GROUND -WATER MONITORING WELL INSTALLATION RECORD
JOB NAME SOUTHERN STATES PLANT JOB NUMBER 56-9606.50
WELL NUMBER
K65W7"F" GROUND SURFACE ELEVATION 793.74 FT.
LOCATION SOUTHERN STATES FERTILIZER PLANT, STATESVILLE, NORTH CAROLINA
INSTALLATION DATE 7/16/90
STEEL PIPE
BORING
CEMENT/BENTONITE GROUT
BENTONITE SEAL
2' PVC PIPE
SAND
PVC SCREEN
CAP
I NOTE: ALL PVC PIPE JOINTS HAVE SCREW CONNECTORS
LOCKABLE CAP
-.,- VENTED PVC CAP
STICKUP 2.41 FT.
DEPTH TO
BASE OF
GROUT SEAL
13.0 FT.
DEPTH TO
TOP OF
SAND BACKFILL
'15.0 FT.
TOTAL DEPTH
OF WELL
28.5 FT.
GROUND WATER 7.45 FT. BELOW TOP .OF CASING ON 8/1 /90
MONITORING WELL
LAW ENVIRONMENTAL, INC.
t�
INSTALLATION RECORD
-CHARLOTTE, NORTH CAROLINA

GROUND -WATER MONITORING WELL INSTALLATION RECORD
JOB NAME SOUTHERN STATES PLANT JOB NUMBER 56-9606.50
WELL NUMBER K65W7"G" GROUND SURFACE ELEVATION 793.49 FT.
LOCATION SOUTHERN STATES FERTILIZER PLANT, STATESVILLE, NORTH CAROLINA
INSTALLATION DATE 7116/90
STEEL PIPE
LOCKABLE CAP
VENTED PVC CAP
STICKUP 2.49 FT.
BORING
DEPTH TO
BASE OF
GROUT SEAL
CEMENT/BENTONITE GROUT 3.0 FT.
DEPTH TO
TOP OF
SAND BACKFILL
4.0 FT.
BENTONITE SEAL
2' PVC PIPE
5.0 FT.
SAND
t•• DEPTH OF
PVC SCREEN PVC SCREEN
CAP 15.0 FT.
1 NOTE: ALL PVC PIPE JOINTS HAVE SCREW CONNECTORS
TOTAL DEPTH
OF WELL
15.6 FT.
GROUND WATER 7.02 FT. BELOW TOP OF CASING ON 8/1/90 1
MONITORING WELL
C = LAW ENVIRONMENTAL, INC.
INSTALLATION RECORD
CHARLOTTE, NORTH CAROLINA

MONITORING WELL INSTALLATION RECORD
JOB NAME SOUTHERN STATES PLANT JOB NUMBER 56-9606.50
WELL NUMBER K65W7°H" GROUND SURFACE ELEVATION 831.78 FT.
LOCATION SOUTHERN STATES FERTILIZER PLANT, STATESVILLE, NORTH CAROLINA
INSTALLATION DATE 7/27/90
LOCKABLE CAP -n r--PVC CAP
GROUT SEAL
BOREHOLE
- PVC PIPE
CEMENT/BENTOMTE GROUT
4".DIA. PVC PIPE
CEMENT/BENTONITE GROUT
ROCK
OPEN FACE
ROCK WELL
STICKUP 2.14 FT.
DEPTH OF 6"
PVC PIPE
50.0 FT.
DEPTH OF 4"
PVC PIPE
100.0 FT.
GROUND
SURFACE
-I
TOTAL
DEPTH OF
WELL
110.0 FT.
GROUND WATER 29.46 FT. BELOW TOP OF CASING ON 8/1/90
LAW ENVIRONMENTAL, INC. MONITORING WELL
INSTALLATION RECORD
CHARLOTTE, NORTH CAROLINA

WELL CONSTRUCTION RECORDS

NORTH CAROLINA DEPARTMENT OF NATURAL RESOURCES AND COMMUNITY DEVELOPMENT
DIVISION OF EIdVIRONI.ENTAL MANAGEMEN'T - QR&JNpwATER SECTION
P.O. BOX 27687 - RALE1064 N.C. 27611, PONE [phone]
WELL CONSTRUCTION RECORD
FOR OFFICE USE ONLY
Ouad. No. Serial No.
Lat. Long, pc
Minor Basin
Basin Code
Header Ent. GW-1 Ent.
DRILLING CONTRACTOR LAW ENGINEERING K65W611D"
STATE WELL CONSTRUCTION
DRILLER REGISTRATION NUMBER 332 PERMIT NUMBER: 48-0238-WM-0078
1. WELL LOCATION: (Show sketch o1 the location below)
Nearest Town: Statesville, North Carolina County: Iredell.
(Road, Community, or Subdivision and Lot No.)
2. OWNER Southern States Cooperative, .,Inc.
ADDRESS U.S. Highway 70 East
Street or Houle No.)
Statesville, North Carolina
City or Town State zip Code
3. DATE DRILLED 7/12/90 USE OF WELL. Monitoring
A. TOTAL DEPTH 38.0 CUTTINGS COLLECTED ® Yes ❑ No
5. DOES WELL REPLACE EXISTING WELL? ❑ Yes aD No
6. STATIC WATER LEVEL: 29.37 FT. 0 above TOP OF CASING,
® below
TOP OF CASING IS 2.23 FT. ABOVE LAND SURFACE.
7. YIELD (gpm): METHOD OF TEST
S. WATER ZONES (depth):
9. CHLORINATION: Type Amount
10. CASING:
Wall Thickness
Depth
Diameter or Weignt/Ft.
Material
From
0 To 25.5
Ft. 2-IN Schedule
40 PVC
From
To
Ft.
From
11. GROUT:
Depth
Material
Method
From
0 To 25.5
Ft. Cement/Bentonite
Pour
From
20.0 To 22.5
Fl,Bentonite
Pour
12. SCREEN:
Depth Diameter Slot Size Material
From 25.5 To 35.5 Ft, 2 in. 0.010 in. PVC
From To Ft. in. in.
From To Ft. in. in.
13. GRAVEL PACK:
Depth Size Material
From 22.5 To 38.0 Ft Fine -Medium SAND
From To Ft.
14. REMARKS:
Depth
From To
0 - 0.5
0.5 - 9.0
9.0 - 38.0
DRILLING LOG
Formation Description
Topsoil
Sandy SILT
Silty SAND
See Test Boring Records
II additional space is needed use back of form.
LOCATION SKETCH
(Show direction and distance from at least two State Roads,
or other map reference points)
rt
1.\
I DO HEREBY CERTIFY THAT THIS WELL WAS CONSTRUCTED IN ACCORDANCE WITH 15 NCAC 2C, WELL CONSTRUCTION'
STANDARDS, AND THAT A COPY OF THIS RECORD HAS BEE PROVIDED TO T .E �L OWNER
SIGNATU E OF CONTRACTOR OR AGENT DATE
Submit orioinal to Division of Environmental Management and copy to well owner.

NORTH CAROUNA DEPARTMENT OF NATURAL RESOURCES AND CC`i`, LAITY DEVELOPII�
DIVISION OF ENVIRONMENTAL "ANAGEMENT - GROUNDWATER SECTION
P.O. BOX 27687 - RALEIGH,N.C. 27611, PHONE [phone]
WELL CONSTRUCTION RECORD
FOR OFFICE USE ONLY
Ouad. No. Serial No.
Lat. Long. Pc
Minor Basin
Basin Code
Header Ent. GW-1 Ent.
DRILLING CONTRACTOR LAW ENGINEERING K65W6"E"
STATE WELL CONSTRUCTION
DRILLER REGISTRATION NUMBER 332 PERMIT NUMBER: 48-0238-WM-0078
1. WELL LOCATION: (Show sketch of the location below)
Nearest Town: Statesville, North Carolina County: Iredell
(Road, Community, or Subdivision and Lot No.)
2. OWNER Southern States Cooperative, Inc.
ADDRESS U.S. Highway 70 East
(Street or Route No.
Statesville, North Carolina
City or Town State Zip Code
3. DATE DRILLED 7/24/90 USE OF WELL. Monitoring
4. TOTAL DEPTH 133.0 CUTTINGS COLLECTED ❑ Yes' ® 140
5. DOES WELL REPLACE EXISTING WELL? ❑ Yes El No
6. STATIC WATER LEVEL: 18.80 FT. O above TOP OF CASING,
IN below
TOP OF CASING IS 2'04 FT. ABOVE LAND SURFACE.
7. YIELD (gom? METHOD OF TEST
S. WATER ZONES (depth):
9. CHLORINATION: Type Amount
10. CASING:
Wall Thickness
Depth
Diameter or Weight/Ft. Material
From
0
To 62.0
Ft. 6-IN Schedule 40 PVC
From
0
To 123.3 Ft 4-IN Schedule 40 PVC
From
To
Ft.
11. GROUT:
Depth
Material Method
From
0
To 62.0
Ft.Cement/Bentonite Pressure
From
0
To 123.3
Ft Cement/Bentonite Pressure
12. OPEN FACE INTERVAL
Depth
From 123.3 To 133.0 Ft.
From To Ft.
From To Ft.
13. GRAVEL PACK:
Diameter Slot Size Material
4 in NA in. NA
in. in.
in. in
Depth Size Material
From To Ft.
From To Ft.
14. REMARKS:
Depth DRILLING LOG
From To Formation Description
N/A
If additional space is needed use back o1 form.
LOCATION SKETCH
(Show direction and distance from at least two State Roads,
or other map reference points)
1�, t i'1111i� l
l�
I DO HEREBY CERTIFY THAT THIS WELL WAS CONSTRUCTED IN ACCORDANCE WITH 15 NCAC 2C, WELL CONSTRUCTION'
STANDARDS, AND THAT A COPY OF THIS RECORD HAS BEEN PROVIDED TO THEW L OWN R.
SIGNATURE OF CONTRACTOR OR AGENT DATE
Submit orioinal to Division of Environmental Management and Copy to well owner.

NORTH CAROLINA DEPARTI.ENT OF NATURAL RESOURCES AND CO-Lk"TY DEVELO-4ENT FOR OFFICE USE ONLY
DIVISION OF EN'VIRONNENTAL MANAGEMENT - GROUNDWA71M SECTION
P.O. BOX 27EE7-RALEIGH.N.C. 27611. PHONE [phone] Ouad. No. Serial No.
Lat. Long. Pc
Minor Basin
WELL CONSTRUCTION RECORD Basin Code
Header Ent. GW-1 Ent.
DRILLING CONTRACTOR LAW ENGINEERING K65W711D"
STATE WELL CONSTRUCTION
DRILLER REGISTRATION NUMBER 332 PERMIT NUMBER: 48-0238-WM-0078
1. WELL LOCATION: (Show sketch of the location below)
Nearest Town: Statesville, North Carolina County: Iredell
(Road, Community, or Subdivision and Lot No.)
2. OWNER Southern States Cooperative, Inc.
ADDRESS U.S. Highway 70 East
(Street or Route No.)
Statesville North Carolina
City or Town State Zip Code
3. DATE DRILLED 7/13/90 USE OF WELL. Monitoring
4. TOTAL DEPTH 23.5 CUTTINGS COLLECTED ❑ Yes' ® No
5. DOES WELL REPLACE EXISTING WELL? ❑ Yes M No
6. STATIC WATER LEVEL 10.83 FT. D above TOP OF CASING,
TOP OF CASING IS 2.05 below
FT. ABLAND SURFACE
7. YIELD (gpm): METHOD OF TEST
S. WATER ZONES (depth):
9. CHLORINATION: Type Amount
10. CASING:
Wall Thickness
Depth
Diameter or Weight/Ft. Material
From
0 To 13.0
Ft.
2-IN Schedule 40 PVC
From
To
Ft.
From
To
Ft.
11. GROUT:
Depth
Material Method
From
0 To 9.0
Ft.
Cernent/Bentonite Pour
From
To
Ft.
12. SCREEN:
Depth Diameter Slot Size Material
From 13.0 To 23.0 Ft. 2 in. 0.010 in. PVC
From To Ft. in. in.
From To Ft. in. in.
13. GRAVEL PACK:
Depth Size Material
From 11.0 To 23.5 Fl. Fine - Medium SAND
From To Ft.
IA. REMARKS: _
From
Depth
To
DRILLING LOG
Formation Description
0 -
0.5
Topsoil
0.5
- 6.0
Sandy SILT
6.0
- 8.0
Silty SAND
8.0
- 12.0
Clayey SILT
12.0
- 18.0
Clayey SILT
18.0
- 22.0
Fine to Coarse SAND
22 -
23.0
PWR Silty Medium SAND
See Test Boring Records
It additional space is needed use back of form.
LOCATION SKETCH
(Show direction and distance from at least two State Roads,
or other mar) reference points)
IV
ruJ ��i-eso �HV✓Y. 70
kj-
�� is •� I , � },� �'� , ��� 1
7l�
I DO HEREBY CERTIFY THAT THIS WELL WAS CONSTRUCTED IN ACCORDANCE WITH 15 NCAC 2C. WELL CONSTRUCTION'
STANDARDS, AND THAT A COPY OF THIS RECORD HAS ByEN PROVIDED T9 TH= W,5jL.L OW%ER.
by 7
TUR
SIGNAE OF CONTRACTOR OR AGENT DATE
r" ''""`" "ram• Submit orioinal to Division of Environmental Management and copy to well owner.

NORTH CAROLINA DEPARTMENT OF NATURAL RESOURCES AND COMMUNITY DEVELO"AEtlT
DIVISION OF ENVIRoNMENTAL MANAGE1.EMT -—&)►.IOWATER SECTtoH
P.O. BOX 27E87 - RALEIGH,N.C. 27611. PHONE (Pig) 733-5083
WELL CONSTRUCTION RECORD
Ouad. No. _
La t.
Minor Basin
Basin Code
Header Ent
FOR OFFICE USE ONLY
Serial No.
Long. Po _
DRILLING CONTRACTOR LAW ENGINEERING K65W7" E"
STATE WELL CONSTRUCTION
DRILLER REGISTRATION NUMBER 332 PERMIT NUMBER: 48-0238-WM-0078
1. WELL LOCATION: (Show sketch of the location below)
Nearest Town: Statesville, North Carolina County: Iredell
(Road, Community. or Subdivision and Lot No.)
2. OWNER Southern States Cooperative, Inc.
ADDRESS U.S. Highway 70 East
Street or Route No.)
Statesville North Carolina
City or Town State Zip Code
3. DATE DRILLED 7/11/90 USE OF WELL. Monitoring
4. TOTAL DEPTH 35.0 CUTTINGS COLLECTED Dies' ❑ No
S. DOES WELL REPLACE EXISTING WELL? ❑ Yes ® No
6. STATIC WATER LEVEL: 25.56 FT. D above TOP OF CASING,
224 O below
.
TOP OF CASING IS FT. ABOVE LAND SURFACE.
7. YIELD (gpm} METHOD OF TEST
S. WATER ZONES (depth):
S. CHLORINATION: Type Amount
10. CASING:
Wall Thickness
Depth Diameter or Weight/Ft. Material
From 0 To 25,0 Ft 2-IN Schedule 40 PVC
From To Ft.
From To Ft.
11. GROUT:
Depth Material Method
From 0 To 21.0 Ft. Cement/Bentonite Pour
From 21.0 To 23.0 Fl. Bentonite Pour
12. SCREEN:
Depth Diameter Slot Size Material
From 25.0 To 35.0 Ft. 2 irL 0.010 in. PVC
From To Ft. in. in.
From To Ft. in. in.
13. GRAVEL PACK:
Depth Size Material
From 23.0 To 35:0 Ft Fine -Medium SAND
From To Ft.
14. REMARKS:
GW-1 Ent.
Depth DRILLING LOG
From To Formation Description
0 - 0.5 TOPSOIL
0.5 - 13.0 Clayey SILT
13.0 - 35.0 Silty SAND
See:Test Boring Records
It additional space is needed use back of form.
LOCATION SKETCH
(Show direction and distance from at least two State Roads,
or other map reference points)
All
I DO HEREBY CERTIFY THAT THIS WELL WAS CONSTRUCTED IN ACCORDANCE WITH 15 NCAC 2C, WELL CONSTRUCTION'
. STANDARDS, AND THAT A COPY OF THIS RECORD HAS BEEN E 1NELL WNER.
SIGNATURE OF CONTRACTOR OR AGENT DATE
Submit oricinal to Division o1 Environmental Manapemenl and copy to well owner.

NORTH CAROLINA DEPARTMENT OF NATURAL RESOURCES AND COMMUNITY DEVELO-MENT
DIVISION OF ENVIRONMENTAL MANAGEMENT - GROUNDWATER SECnoN
P.O. BOX 27697 - RALEIGH,N.C. 27811. PHONE [phone]
WELL CONSTRUCTION RECORD
Ouad. No. _
Lat.
Minor Basin
Basin Code
Header Ent,
FOR OFFICE USE ONLY
Serial No.
Long, pc
DRILLING CONTRACTOR LAW ENGINEERING K65W7"F"
STATE WELL CONSTRUCTION
DRILLER REGISTRATION NUMBER 332 PERMIT NUMBER: 48-0238-WM-0078
1. WELL LOCATION: (Show sketch of the location below)
Nearest Town: Statesville, North Carolina County: Iredell
(Road, Community, or Subdivision and Lot No.)
2. OWNER Southern States Cooperative, Inc.
ADDRESS_ U.S. Highway 70 EAst
(Street or Route No.)
Statesville North Carolina
City or Town State Zip Code
3. DATE DRILLED 7/16/90 USE OF WELL. Monitoring
4. TOTAL DEPTH 28.5 CUTTINGS COLLECTED ®Yes' ❑ No
5. DOES WELL REPLACE EXISTING WELL? ❑ Yes Z No
6. STATIC WATER LEVEL: 7.45 FT. D above TOP OF CASING,
241 IR below
.
TOP OF CASING IS FT. ABOVE LAND SURFACE.
7. YIELD (gpm? METHOD OF TEST
S. WATER ZONES (depth):
9, CHLORINATION: Type Amount
10. CASING:
Wall Thickness
Death Diameter or Weight/Ft. Material
From 0 To 17.5 Ft 2-IN Schedule 40 PVC
From -To-Ft.-
From To Ft.
11. GROUT:
Depth Material Method
From 0 To 13.0 Ft. Cement/Bentonite Pour
From 13.0 To 15.0 Ft.Bentonite Pour
12. SCREEN:
Depth Diameter Slot Size Material
From 17.5 To 27.5 Ft. 2 in 0.010 in. PVC
From To Ft. in. in.
From To Ft. in. in.
13. GRAVEL PACK:
Depth Size Material
From 15.0 To 27.5 FI.Fine-Medium SAND
From To Ft..
14. REMARKS:
Depth
From To
0 - 0.5
0.5 - 11.0
11.0 - 22.0
In n no n
GW-1 Ent.
DRILLING LOG
Formation Description
Topsoil
Silty Medium SAND
Silty Fine SAND
Partially Weathered Rock
Silty Fine SAND
See Test Boring Records
If additional space is needed use back of form.
LOCATION SKETCH
(Show direction and distance from at least two State Roads,
or other map reference points)
vim• �� -� I��I, �// y„r_` . �,
SITE e5o'70
���—
;' TO
711�1'
fZYGO
I DO HEREBY CERTIFY THAT THIS WELL WAS CONSTRUCTED IN ACCORDANCE WITH 15 NCAC 2C, WELL CONSTRUCTION
STANDARDS, AND THAT A COPY OF THIS RECORD HASa;---EN PROVIDED TPLL OW ER.
SIGNATURE OF CONTRACTOR OR AGENT DATE
'w"Submit orioinal to Division of Environmental Management and copy to well owner.

NORTH CAROIJNA DEPARTMENT OF NATURAL RESOURCES AND C04Akk MTY DEVELOPMENT
DIVISION OF ENVIRONMENTAL MANAGEW-W - pROUNDWATER SECTION
P.O. BOX 27687 - RALEIOH.N.C. 27611. PHONE (D 19) 733-5083
WELL CONSTRUCTION RECORD
FOR OFFICE USE ONLY
Quad. No. Serial No.
Lat. Long. Pc
Minor Basin
Basin Code
Header Ent. GW-1 Ent.
DRILLING CONTRACTOR LAW ENGINEERING K65W7"G"
STATE WELL CONSTRUCTION
DRILLER REGISTRATION NUMBER 332 PERMIT NUMBER: 48-0238-WM-0078
1. WELL LOCATION: (Show sketch of the location below)
Nearest Town: Statesville, North Carolina County: Iredell
(Road, Community, or Subdivision and Lot No.)
2. OWNER Southern States Cooperative, Inc.
ADDRESS U.S. Highway 70 East
Street or Houle No.
Statesville North Carolina
City or Town State Zip Code
3. DATE DRILLED 7/16/90 USE OF WELL. Monitoring
A. TOTAL DEPTH 15.0 CUTTINGS COLLECTED 2Yes ❑ No
5. DOES WELL REPLACE EXISTING WELL? ❑ Yes ® No
6. STATIC WATER LEVEL: 7.02 FT. D above TOP OF CASING,
® below
TOP OF CASING IS 2.49 FT. ABOVE LAND SURFACE.
7. YIELD (gpm): METHOD OF TEST
S. WATER ZONES (depth):
9. CHLORINATION:
Type
Amount
10. CASING:
Wall Thickness
Depth
Diameter or Weight/Ft. Material
From 0
To 5.0
Ft
2-IN Schedule 40 PVC
From
To
Ft.
From
To
Ft.
11. GROUT:
Depth
Material Method
From 0
To 3.0
Ft.Cement/Bentonite
Pour
From 3.0
To 4.0
Ft,
Bentonite Pour
12. SCREEN:
Depth Diameter Slot Size Material
From 5.0 To 15.0 Ft. 2 in 0.010 in. PVC
From To Ft. in. in.
From To Ft. in, in.
13. GRAVEL PACK:
Depth Size Material
From 4.0 To 15:0. Ft. Fine -Medium SAND
From To Ft.
14. REMARKS:
Depth DRILLING LOG
From To Formation Description
N/A
It additional space is needed use back of form.
LOCATION SKETCH
(Show direction and distance from at least two State Roads,
or other map reference points)
�U
I - N,
I DO HEREBY CERTIFY THAT THIS WELL WAS CONSTRUCTED IN ACCORDANCE WITH 15 NCAC 2C, WELL CONSTRUCTION'
. STANDARDS, AND THAT A COPY OF THIS RECORD HAS PROVIDED TOOT '" LL NER. 9/a �/��
SIGNATURE OF CONTRACTOR OF; AGENT DATE
Submit orioinal to Division of Environmental Management and copy to well owner.

NORTH CAROLINA DEPARTMENT OF NATURAL RESOURCES AND COMMUNITY DEVELOPMENT
DIVISION OF ENVIRONMENTAL MANAGEMFJlT - GROUNDWATIER SECTION
P.O. BOX 27687 - RALEIGH,N.C. 27011. PHONE (DID) 733-5083
WELL CONSTRUCTION RECORD
FOR OFFICE USE ONLY
Ouad. No. Serial No.
Lat. Long. Pc
Minor Basin
Basin Code
Header Ent. GW-1 Ent.
DRILLING CONTRACTOR LAW ENGINEERING K65W7"H"
STATE WELL CONSTRUCTION
DRILLER REGISTRATION NUMBER 332 PERMIT NUMBER: 48-0238-WM-0078
1. WELL LOCATION: (Show sketch of the location below)
Nearest Town: Statesville, North Carolina County: Iredell
(Road, Community, or Subdivision and Lot No.)
2. OWNER Southern States Cooperative, Inc.
ADDRESS U.S. Highway 70 East
Street or Route No.
Statesville North Carolina
City or Town State Zip Code
3. DATE DRILLED 7/27/90 USE OF WELL. Monitoring
4. TOTAL DEPTH 110:0 CUTTINGS COLLECTED ❑Yes' E) No
5. DOES WELL REPLACE EXISTING WELL? ❑ Yes © No
6. STATIC WATER LEVEL: 29.48 FT. D above TOP OF CASING,
TOP OF CASING IS 2.14 below
FT. ABLAND SURFACE.
7. YIELD (gpm): METHOD OF TEST
8. WATER ZONES (depth):
9. CHLORINATION: Type Amount
10. CASING:
Wall Thickness
Depth Diameter or Weioht/Ft. Material
From 0 To 50.0 Ft 6-IN Schedule 40 PVC
From 0 To 100.0 FI. 4-IN Schedule 40 PVC
From To Ft.
11. GROUT:
Depth Material Method
From 0 To 50.0 FI.Cement/Bentonite Pressure
From 0 To 100.0 Ft. Cement /Bentonite Pressure
12. Open Face
Depth Diameter Slot Size Material
From 100.0 To 110.0 Ft. 4 in. NA in. NA
FrDm To Ft. in. in.
From To Ft, in, in.
13. GRAVEL PACK:
Depth
From To
From To
14. REMARKS:
F1.
Ft.
Size Material
Depth DRILLING LOG
From To Formation Description
N/A
If additional space is needed use back of form.
LOCATION SKETCH
(Show direction and distance from at least two State Roads,
or other map reference points)
I,\
I DO HEREBY CERTIFY THAT THIS WELL WAS CONSTRUCTED IN ACCORDANCE WITH 15 NCAC 2C, WELL CONSTRUCTION
STANDARDS, AND THAT A COPY OF THIS RECORD HASPEEN PROVI EaD �TO TV
W L OW`�ER.
LCJ .c,ic I /z
SIGNATURE OF CONTRACTOR OR AGENT DATE
''" ' ^^' ' rO• Submit orioinal to Division of Environmental Manaoement and copy to well owner.

LAW ENVIRONMENTAL, INC.
112 TOWNPARK DRIVE
KENNESAW, GEORGIA 30144-5599
404-421-3400
August 13, 1990
—
Law Environmental, Inc.
431 Minuet Lane
Charlotte, NC 28217
Attention: Tom Beggs
LE Job Number: 56-9606.50
..
Subject: Chemical analyses
of samples received on 08/02/90.
—
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 now be reproduced except in full
without the approval of Law
Environmental National Laboratories.
If there are any questions,
please do not hesitate to contact us.
�-=
Sincerely,
i`
LAW ENVIRONMENTAL NAT ABS
Clifford H. McBride
`
QC Coordinator
it
Attachment: Data Report
Invoice

LAW ENVIRONMENTAL NATIONAL LABORATORIES
TEST DATA REPORT
Date 08/13/90
age 1
--- Project Information ---
Lab Number : 90-6564-07
Project No. . 56-9606.50 Cust. No. .
Project Name : SOUTHERN STATES
Manager: TOM BEGGS
Sample Information
Station ID :
K65 W6 "E"
Sampled Date/Time :
08/01/90 16:00
Matrix :
W
Received Date/Time :
08/02/90 10:15
Type :
GRAB
Received From/By :
JM/KOP
Collector :
JM
Chain of Custody :
0
Number of Containers :
1
Remarks :
--- Test Data ---
Parameter .............................. Method.... Units PQL....... Results... Test Date Analy
•- INORGANIC CHEMISTRY RESULTS --
Nitrogen, Nitrate EPA 353.2 mg/1 0.05 7.3 08/03/90 JAL
'iitrogen, Nitrite EPA 353.2 mg/l 0.05 0.050 08/03/90 JAL
Signed �l ��

LAW ENVIRONMENTAL NATIONAL LABORATORIES
TEST DATA REPORT
Date 08/13/90
Page 1
--- Project Information ---
Lab Number : 90-6564-02
Project No. . 56-9606.50 Cust. No. .
Project Name : SOUTHERN STATES
Manager: TOM BEGGS
Sample Information
Station ID
: K65 W7 "D"
Sampled Date/Time :
08/01/90 14:45
Matrix
: W
Received Date/Time :
08/02/90 10:15
Type
: GRAB
Received From/By :
JM/KOP
Collector :
JM
Chain of Custody :
0
Number of Containers :
1
Remarks :
--- Test Data ---
Parameter .............................. Method.... Units PQL....... Results... Test Date Analy
-- INORGANIC CHEMISTRY RESULTS --
Nitrogen, Nitrate EPA 353.2 mg/1 0.05 11 08/09/90 OR
Nitrogen, Nitrite EPA 353.2 mg/l 0.05 0.081 08/02/90 JAL
Signed / C�

LAW ENVIRONMENTAL NATIONAL LABORATORIES
TEST DATA REPORT
Date 08/13/90
Page 1
--- Project Information ---
Lab Number : 90-6564-05
Project No. 56-9606.50 Cust. No. .
Project Name SOUTHERN STATES
Manager: TOM BEGGS
Sample Information
Station ID
: K65 W7 "E"
Sampled Date/Time
: 08/01/90 15:30
Matrix
: W
Received Date/Time :
08/02/90 10:15
Type
: GRAB
Received From/By :
JM/KOP
Collector
: JM
Chain of Custody :
0
Number of Containers :
1
Remarks :
--- Test Data ---
Parameter .............................. Method.... Units PQL....... Results... Test Date Analy
-- INORGANIC CHEMISTRY RESULTS --
Nitrogen, Nitrate EPA 353.2 mg/l 0.05 15 08/03/90 JAL
Nitrogen, Nitrite EPA 353.2 mg/l 0.05 ND 08/03/90 JAL
Signed � 4 izi )

LAW ENVIRONMENTAL NATIONAL LABORATORIES
TEST DATA REPORT
Date 08/13/90
Page 1
--- Project Information ---
Lab Number 90-6564-03
Project No. 56-9606.50 Cust. No.
Project Name SOUTHERN STATES
Manager: TOM BEGGS
Sample Information
Station ID
: K65 W7 "F"
Sampled Date/Time :
08/01/90 15:15
Matrix
: W
Received Date/Time :
08/02/90 10:15
Type
: GRAB
Received From/By :
JM/KOP
Collector
: JM
Chain of Custody :
0
Number of Containers :
1
Remarks :
--- Test Data ---
Parameter .............................. Method.... Units PQL....... Results... Test Date Analy
-- INORGANIC CHEMISTRY RESULTS --
Nitrogen, Nitrate EPA 353.2 mg/l 0.05 99 08/03/90 JAL
Nitrogen, Nitrite EPA 353.2 mg/1 0.05 0.081 08/03/90 JAL
Signed

LAW ENVIRONMENTAL NATIONAL LABORATORIES
TEST DATA REPORT
Date 08/13/90
Page 1
--- Project Information ---
Lab Number 90-6564-04
Project No. 56-9606.50 Cust. No.
Project Name SOUTHERN STATES
Manager: TOM BEGGS
--- Sample Information ---
Station ID
K65 W7 "G"
Sampled Date/Time
: 08/01/90 15:20
Matrix
W
Received Date/Time
: 08/02/90 10:15
Type
GRAB
Received From/By
: JM/KOP
Collector
JM
Chain of Custody
: 0
Number of Containers
: 1
Remarks :
--- Test Data ---
Parameter .............................. Method.... Units PQL....... Results... Test Date Analy
-- INORGANIC CHEMISTRY RESULTS --
Nitrogen, Nitrate EPA 353.2 mg/l 0.05 1.7 08/09/90 OR
Nitrogen, Nitrite EPA 353.2 mg/1 0.05 ND 08/02/90 JAL
Signed

LAW ENVIRONMENTAL NATIONAL LABORATORIES
TEST DATA REPORT
Date 08/13/90
Page 1
--- Project Information ---
Lab Number : 90-6564-01
Project No. . 56-9606.50 Cust. No.
Project Name : SOUTHERN STATES
Manager: TOM BEGGS
Sample Information
Station ID
K65 W7 "H"
Sampled Date/Time
08/01/90 14:30
Matrix
W
Received Date/Time
08/02/90 10:15
Type
GRAB
Received From/By
JM/KOP
Collector
JM
Chain of Custody
0
Number of Containers
1
Remarks :
--- Test Data ---
Parameter .............................. Method.... Units PQL....... Results... Test Date Analy
-- INORGANIC CHEMISTRY RESULTS --
Nitrogen, Nitrate EPA 353.2 mg/l 0.05 280 08/03/90 JAL
Nitrogen, Nitrite EPA 353.2 mg/l 0.05 ND 08/03/90 JAL
Signed/UiL

LAW ENVIRONMENTAL NATIONAL LABORATORIES
TEST DATA REPORT
Date 08/13/90
Page 1
--- Project Information ---
Lab Number : 90-6564-08
Project No. : 56-9606.50 Cust. No. :
Project Name : SOUTHERN STATES
Manager: TOM BEGGS
--- Sample Information ---
Station ID BAILER RINSE Sampled Date/Time : 08/01/90 16:05
Matrix W Received Date/Time : 08/02/90 10:15
Type GRAB Received From/By : JM/KOP
Collector JM Chain of Custody : 0
Number of Containers : 1
Remarks :
--- Test Data ---
Parameter .............................. Method.... Units PQL....... Results... Test Date Analy
-- INORGANIC CHEMISTRY RESULTS --
Nitrogen, Nitrate EPA 353.2 mg/l 0.05 ND 08/02/90 JAL
Nitrogen, Nitrite EPA 353.2 mg/l 0.05 ND 08/02/90 JAL
Signed ��

LAW ENVIRONMENTAL NATIONAL LABORATORIES
TEST DATA REPORT
Date 08/13/90
Page 1
--- Project Information ---
Lab Number : 90-6564-09
Project No. : 56-9606.50 Cust. No.
Project Name : SOUTHERN STATES
Manager: TOM BEGGS
--- Sample Information ---
Station ID
: K65 W6 "D"
Sampled Date/Time
07/31/90 14:00
Matrix
: SO
Received Date/Time
08/02/90 10:15
Type
: GRAB
Received From/By
JM/KOP
Collector
: JM
Chain of Custody
0
Number of Containers
1
Remarks :
--- Test Data ---
Parameter .............................. Method.... Units PQL....... Results... Test Date Analy
-- INORGANIC CHEMISTRY RESULTS --
Moisture (Oven Dried @ 105C) EPA 160.3M % 1 16 08/02/90 OR
Nitrogen, Nitrate MSA 84-3M mg/kg 0.5 ND 08/02/90 JAL
Nitrogen, Nitrite MSA 84-3M mg/kg 0.5 ND 08/02/90 JAL
Signed

LAW ENVIRONMENTAL NATIONAL LABORATORIES
TEST DATA REPORT
Date 08/13/90
Page 1
--- Project Information ---
Lab Number : 90-6564-11
Project No. . 56-9606.50 Cust. No.
Project Name : SOUTHERN STATES
Manager: TOM BEGGS
--- Sample Information ---
Station ID
K65 W6 "E"
Sampled Date/Time
07/31/90 18:00
Matrix
SO
Received Date/Time
08/02/90 10:15
Type
GRAB
Received From/By
JM/KOP
Collector
JM
Chain of Custody
0
Number of Containers
1
Remarks :
--- Test Data ---
Parameter .............................. Method.... Units PQL....... Results... Test Date Analy
-- INORGANIC CHEMISTRY RESULTS --
Moisture (Oven Dried @ 105C)
Nitrogen, Nitrate
Nitrogen, Nitrite
EPA 160.3M % 1
MSA 84-3M mg/kg 0.5
MSA 84-3M mg/kg 0.5
27 08/02/90 OR
3.4 08/02/90 JAL
ND 08/02/90 JAL
Signed All <

LAW ENVIRONMENTAL NATIONAL LABORATORIES
TEST DATA REPORT
Date 08/13/90
Page 1
--- Project Information ---
Lab Number 90-6564-12
Project No. 56-9606.50 Cust. No.
Project Name SOUTHERN STATES
Manager: TOM BEGGS
Sample Information
Station ID
: K65 W7 "D"
Sampled Date/Time :
07/30/90 14:00
Matrix
: SO
Received Date/Time :
08/02/90 10:15
Type
: GRAB
Received From/By :
JM/KOP
Collector
: JM
Chain of Custody :
0
Number of Containers :
1
Remarks :
--- Test Data ---
Parameter .............................. Method.... Units PQL....... Results... Test Date Analy
-- INORGANIC CHEMISTRY RESULTS --
Moisture (Oven Dried @ 105C) EPA 160.3M % 1 16 08/02/90 OR
Nitrogen, Nitrate MSA 84-3M mg/kg 0.5 1.6 08/02/90 JAL
Nitrogen, Nitrite MSA 84-3M mg/kg 0.5 ND 08/02/90 JAL
Signed

LAW ENVIRONMENTAL NATIONAL LABORATORIES
TEST DATA REPORT
Date 08/13/90
Page 1
--- Project Information ---
Lab Number 90-6564-15
Project No. 56-9606.50 Cust. No.
Project Name SOUTHERN STATES
Manager: TOM BEGGS
--- Sample Information ---
Station ID
K65 W7 "E"
Sampled Date/Time
: 07/30/90 15:30
Matrix
SO
Received Date/Time
: 08/02/90 10:15
Type
GRAB
Received From/By
: JM/KOP
Collector
JM
Chain of Custody
: 0
Number of Containers
: 1
Remarks :
--- Test Data ---
Parameter .............................. Method.... Units PQL....... Results... Test Date Analy
-- INORGANIC CHEMISTRY RESULTS --
Moisture (Oven Dried @ 105C) EPA 160.3M % 1 21 08/02/90 OR
Nitrogen, Nitrate MSA 84-3M mg/kg 0.5 ND 08/02/90 JAL
Nitrogen, Nitrite MSA 84-3M mg/kg 0.5 ND 08/02/90 JAL
1 -
Signed

LAW ENVIRONMENTAL NATIONAL LABORATORIES
TEST DATA REPORT
Date 08/13/90
Page 1
--- Project Information ---
Lab Number : 90-6564-14
Project No. . 56-9606.50 Cust. No. .
Project Name : SOUTHERN STATES
Manager: TOM BEGGS
--- Sample Information ---
Station ID
K65 W% "F"
Sampled Date/Time
:.07/30/90 15:20
Matrix
SO
Received Date/Time
08/02/90 10:15
Type
GRAB
Received From/By
JM/KOP
Collector
JM
Chain of Custody
0
Number of Containers
1
Remarks :
--- Test Data ---
Parameter .............................. Method.... Units PQL....... Results... Test Date Analy
-- INORGANIC CHEMISTRY RESULTS --
Moisture (Oven Dried @ 105C) EPA 160.3M °. 1 11 08/02/90 OR
Nitrogen, Nitrate MSA 84-3M mg/kg 0.5 1.1 08/02/90 JAL
Nitrogen, Nitrite MSA 84-3M mg/kg 0.5 ND 08/02/90 JAL
Signed 6

LAW ENVIRONMENTAL NATIONAL LABORATORIES
TEST DATA REPORT
Date 08/13/90
Page 1
--- Project Information ---
Lab Number : 90-6564-13
Project No. . 56-9606.50 Cust. No.
Project Name : SOUTHERN STATES
Manager: TOM BEGGS
--- Sample Information ---
Station ID
K65 W7 "G"
Sampled Date/Time
07/30/90 15:00
Matrix
SO
Received Date/Time
08/02/90 10:15
Type
GRAB
Received From/By
JM/KOP
Collector
JM
Chain of Custody
0
Number of Containers
1
Remarks :
--- Test Data ---
Parameter .............................. Method.... Units PQL....... Results... Test Date Analy
-- INORGANIC CHEMISTRY RESULTS --
Moisture (Oven Dried @ 105C) EPA 160.3M % 1 15 08/02/90 OR
Nitrogen, Nitrate MSA 84-3M mg/kg 0.5 ND 08/02/90 JAL
Nitrogen, Nitrite MSA 84-3M mg/kg 0.5 ND 08/02/90 JAL
Signed �� ��

LAW ENVIRONMENTAL NATIONAL LABORATORIES
TEST DATA REPORT
Date 08/13/90
Page 1
--- Project Information ---
Lab Number 90-6564-10
Project No. 56-9606.50 Cust. No.
Project Name SOUTHERN. STATES
Manager: TOM BEGGS
--- Sample Information ---
Station ID
K65 W7 "H"
Sampled Date/Time
07/31/90 15:30
Matrix
SO
Received Date/Time
08/02/90 10:15
Type
GRAB
Received From/By
JM/KOP
Collector
JM
Chain of Custody
0
Number of Containers
1
Remarks :
--- Test Data ---
Parameter .............................. Method.... Units PQL....... Results... Test Date Analy
-- INORGANIC CHEMISTRY RESULTS --
Moisture (Oven Dried @ 105C) EPA 160.3M °° 1 19 08/02/90 OR
Nitrogen, Nitrate MSA 84-3M mg/kg 0.5 ND 08/02/90 JAL
Nitrogen, Nitrite MSA 84-3M mg/kg 0.5 ND 08/02/90 JAL
Signed �' " ~ ( VJ-

U IVIRI ITAI _ — —
SAMPLING S Oy 4-b G r wl 5 T#q 4 e s
NAME OF FACILITY:
INFORMATION
STREET ADDRESS: N BC 740 wes 4-
CITY/STATE: 5%A ic5�) I Its �G• VI':
PROJECT NAME JOB NO. to
�oo N �-T'r� 56- 5o z a ,�4`&
SAMPLERS (SIGNATURE) Q 4�
G - Q z
O U
A M P L 1 N G DATE d O 1— - O 44 ,p ��• ��° `.jp °OZ` L°P°
_ O JCS Q Q Q %loo Q P� OQ G•
TIME 0 �'� SAMPLE STATION DESCRIPTION p ��� Gv �O�G �Q .� 01
D D Qy Z LENL LAB NO.
W 3 0 vl
N5
k 65 w 7 I'D
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15Wo A K 0 w 6" �
166o 5 w „�.„ CY-,
ler o. os'
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RE INQl.ISHED BY: DATE/TIME RECEIVED BY: RELINQUISHED BY: RECEIVED BYt DATE/TIME
G
(SIGNATURE) 9"1-73 (SIGNATURE) .(SIGNATURE) (SIGNATURE)
RELINQUISHED BY: DATE/TIME RECEIVED BY: RELINQUISHED BY: REOtIVED AT LAB %RATORY: DATE/TIME
(SIGNATURE) (SIGNATURE) (SIGNATURE
DISTRIBUTION: ORIGINAL AND YELLOW COPIES ACC PA Y SAM LE SHIPMENT TO LABORATORY.
PINK COPY RETAINED BY SAMPLERS. YELLOW COPY RETAINED BY LABORATORY.
REMARKS:
(SIGNATURE pm
RECOVERY WELL - RW
• SOURCE RCRA MONITORING WELL • MW
CODES: SOIL/SEDIMENT-SO
SLUDGE - SL
NPDES DISCHARGE - ND
DRINKING WATER - DW

Aw ONI L, Ir
�H,"'"' OF ^' iST"^Y f"'^OF'^
SAMPLING NAME OF FACILITY: se)114-) pY, S7g�-,e
INFORMATION.
STREET ADDRESS:
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PROJECT NAME
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JOB NO.
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\ \ \ \ \ \ ♦ \ `L LENL LAB NO.
SAMPLERS (SIGNATURE)
r►vl
SAMPLING DATE 7 _ O a
TIME
<
m
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w ppo
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SAMPLE STATION DESCRIPTION
1 Noo
5 w
1500
65 w ��U-r�
15a0
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IS 30
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65 .7
RE INQUISHED BY.
DATE/TIME
�-{� 6
RECEIVED BY:
RELINQUISHED BY:
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DATE/TIME
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REMARKS:
RECOVERY WELL - RW
• SOURCE RCRA MONITORING WELL - MN
CODES: SOIL/SEDIMENT-SO
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Mr. Howard T. Nelson
July 18, 1990
Page Two
As presented in our phone conversations, we request
authorization in accordance with the attached license agreement,
for purpose of constructing the monitoring wells.
If you have further questions, please contact me at 804-
281-1158.
Sincerely,
Hilton M. Withers
Manager, Environmental Affairs
HMW/pf
Enclosures

LAW ENVIRONMENTAL, INC.
431 MINUET LANE
CHARLOTTE, NORTH CAROLINA 28217
P.O. BOX 240674
CHARLOTTE, NORTH CAROLINA 28224-0674
704-527-6717
June 15, 1990
Southern States Cooperative, Inc.
P.O. Box 26234
Richmond, VA 23260
Attention: Mr. Hilton M. Withers
Manager, Environmental Affairs
Subject: Response to May 4, 1990 State Letter, and
Proposed Phase Ii Ground -Water Assessment
Southern States Fertilizer Plant
Statesville, North Carolina
LEI Job No. 56-9606.60
Gentlemen:
As discussed during our June 4 meeting, this document has been prepared to respond to
a May 4, 1990 letter from Ms. Chris DeRoller of the State of North Carolina, Department
of Environment. Health and Natural Resources, Division of Environmental Management
to Mr. Hilton Withers of Southern States. Also contained in this submittal is a proposed
Phase II Ground -Water Assessment work plan for your review.
i

Southern States Cooperative, Inc.
June 15, 1990
Page 2
Section 1.0 of this document is organized such that the numbering of the sub -sections
corresponds to the numbering of major points of the State's May 4, 1990 letter. Section 1.0
also includes a request to the State for an extension of compliance time. Section 2.0
includes the proposed Phase II Ground -Water Assessment Work Plan along with our
proposed schedule and cost estimate.
Law Environmental, Inc. appreciates the continuing opportunity to provide our professional
services on this project. If you have any questions concerning this proposal, please contact
US.
Sincerely,
LAW ENVIRONMENTAL, INC.
6.
Bernard B. Schumak
Project Hydrogeologist
Thomas F. Beggs,
Principal
BBS:TFB:sdy
Attachments
P.E.

1.0 RESPONSE TO MAY 4, 1990 LETTER
On May 4, 1990, the state of North Carolina Department of Environment, Health, and
Natural Resources (NCDEHNR) issued a letter to Southern States Cooperative, Inc. The
letter indicated that the NCDEHNR Mooresville Regional office had reviewed Law
Enviornmental's Phase I Ground -water Assessment report for the Statesville Southern States
Fertilizer Plant (please refer to Law's report dated March 29, 1990, Job No. 56-9606.40).
The letter stated that NCDEHNR was in agreement with Law concerning the need for
further assessment activities. NCDEHNR indicated that these activities should be designed
to more fully define the vertical and horizontal extent of nitrate/nitrite ground -water
contamination. Specifically, NCDEHNR suggested six points for consideration during Phase
II assessment. Each of the points is presented below, followed by our response.
1.1 "What is the source of groundwater contamination and what is the extent of soil
contamination?"
Based on the laboratory analyses to date and information provided to us by Southern
States, the source of ground -water contamination is thought to be associated with past plant
activities. Modifications to plant activities have been implemented over the past several
years, and waste products are now believed to be wholly contained within the manufacturing
facility.
Past activities likely included releases near the southeast corner of the plant. Holding
ponds were located between the plant and existing monitoring wells K65W6 and K65W6A

(please refer to the attached Figures 1 and 2). The extent of soil contamination is currently
unknown. It is thought that soil contamination follows surface drainage patterns. One
major route may be from the southeast corner of the plant toward existing well K65W6
(near previous holding ponds). Another possible route may be from the plant toward the
former holding ponds numbered 1 and 2. Soil sampling to better define the extent of
contamination is proposed in the Phase II Ground -Water Assessment which is part of this
submittal.
1.2 "How far east of monitor well No. K65W6 does groundwater contamination extend?"
The extent of ground -water contamination east of existing well number K65W6 is not
known. The property east of this area is not owned by Southern States. Approval from the
property owner to construct monitoring wells has not yet been granted. A letter for
permission has been sent to the land owner. The new wells proposed in the Phase I1
Ground -Water Assessment should better define the limits of possible ground -water
contamination.
1.3 "How far south of monitor well No. K65WTU does groundwater contamination
extend?"
An additional water -table well is proposed approximately 300 ft south of existing well
K65W7"C" at the southern edge of Southern States' property. This new well will be
designated K65WTF" and should help to define the extent of ground -water contamination
south of existing well K65W70.

1.4 'What is the vertical extent. of groundwater contamination in the area of monitor
well No. K65W709"
An additional deeper well will be installed near proposed well K65W7F". This well will
be designated K65W7"G". This deeper well, along with the laboratory data from the
proposed deeper well near existing wells K65W7 and K65W7"A", may provide sufficient
data to estimate the vertical extent of contamination at existing well K65W70. If
sufficient data is not obtained, an additional deep well may be proposed near K65W70.
1.5 "How deep will the proposed water table monitoring wells be?"
Table 1 contains estimated well depths and water levels for the proposed new wells. The
actual well depths and screened intervals selected will be based on site specific
hydrogeologic conditions encountered at the time of drilling. Ten -foot well screens are
proposed. The intent of the Phase II Ground -Water Assessment program is to better define
both the lateral and vertical extent of ground -water contamination.
1.6 'What is the pH of the ground water in the different wells?"
Table 1 of Law Environmental's Phase I Ground -Water Assessment (LEI Job Number 56-
9606 dated March 29, 1990) contained field pH, temperature and specific conductivity data
for wells installed during the Phase I Assessment. Field parameters, including pH
information, will be obtained at each proposed sampling event during Phase II assessment
activities.
In conclusion, the NCDEHNR letter requested that Southern States submit a Phase It
Assessment Report or request additional time within sixty days of receipt of the letter.

On behalf of our client, we are hereby requesting an extension of the compliance deadline
for this project. Southern States is making a conscientious effort to achieve compliance with
State environmental guidelines. As can be seen by review of the following section, a
substantial scope of additional work remains. An extension of at least sixty additional days
should make possible a thorough technical evaluation and report. For more information
regarding our proposed schedule, please refer to the attachments.
If this proposed extension is acceptable, please issue a brief letter acknowledging your
approval for our file. Also, please state the length of extension granted (at least 60 days,
preferably 120 days).

2.0 PROPOSER PHASE II WORK PLAN
Phase I Ground -Water Assessment did not fully define the vertical or horizontal extent of
nitrate/nitrite (N) ground -water contamination. To help define the extent of ground -water
contamination, and to obtain additional site -specific hydrogeology, Law recommends an
additional phase of ground -water assessment.
Eight new ground -water monitoring wells are proposed. To better define the horizontal
extent of ground -water contamination, five new water table wells will be installed. Figure
2 illustrates the proposed locations. The exact location of monitoring wells may be
modified as dictated by drilling equipment access.
To better define the vertical extent of ITT contamination, three deep wells are recommended.
One well will be installed near existing well K65W6, one near K65W7, and one
approximately 300 ft south of K65W7"C".
2.1 Soil Test Borings and Soil Sampling
Five soil test borings will be drilled at the approximate locations shown in the attached
Figure 2. Law borings K65W6"A", K65W6'B", and K65W6"C" were situated near existing
NCDEHNR boring K65W6. Similarly, Law Borings K65W7"A" through "C" were located
near existing NCDEHNR boring K65W7. The new soil test borings will be designated
K65W6"D", K65W6"F", K65W7"D", K65W7'E", and K65W7"G". The borings have been
positioned in conjunction with three additional monitoring wells such that they will provide

additional information regarding ground -water contour elevations and contaminant plume
concentrations.
The borings will be drilled by mechanically advancing hollow -stem steel augers. Soil
sampling and penetration testing will be performed in general accordance with ASTM D
1586. At regular intervals, soil samples will be obtained with a standard 1.4-inch I.D., 2-
inch O.D., split -tube sampler. The sampler will be first seated 6 inches to penetrate any
loose cuttings, and then driven an additional 12 inches with blows of a 140-pound hammer
falling 30 inches. The number of blows required to drive the sampler the final 12 inches
will be recorded and is designated the "penetration resistance".
Representative portions of the soil samples, thus obtained, will be examined by an engineer
or geologist to verify the driller's field classifications. At least one soil sample from the
shallow zone of each boring will be returned to our laboratory for nitrate/nitrite testing.
Test Boring Records will be prepared showing the soil descriptions and penetration
resistances.
2.2 Monitoring Well Installation
Eight ground -water monitoring wells will be completed at the subject site. Five of these
wells will be installed at the locations of the soil test borings mentioned previously. The
other three wells will be installed at the following locations (see Figure 2): K65W6"E",
K65W7"7", and K65W7"H". Each well will consist of a 2-inch diameter schedule 40 PVC
pipe with flush -threaded joints. The lower 10-ft section of each well will consist of
manufactured 0.010-inch wide slot well screen. Washed sand backfill will be placed around
the outside of the pipe to at least 2-ft above the top of the well screen. A 2-ft minimum

bentonite seal will be placed above the sand backfill. The remainder of the annular space
will be grouted to the surface with a cement/bentonite grout. Ground -Water Monitoring
Well Installation Records will be prepared to illustrate well construction details.
Ground -water monitoring wells K65W6"D", K65W6"F", K65W7"D" K65W7"E", and
K65W7"F" will be constructed as water -table wells with the tops of the well screens placed
near the water table at the time of construction.
Wells K65W6"E" and K65W7H" will be completed within 10 ft horizontally of existing well
K65W6 and K65W7, respectively. They will be rock wells drilled utilizing air -rotary drilling
techniques and will have their open faces or screened intervals placed at depths of
approximately 100 ft below ground surface. Well K65W7"G" will be drilled to auger refusal
(or a maximum of 70 ft). If shallow refusal is encountered, the boring will not be
completed as a monitoring well.
At each boring location, the down -hole drilling equipment will be decontaminated by steam
cleaning prior to drilling. Steam cleaning will be performed to minimize the possibility of
cross -contamination between wells.
Upon completion of drilling, lockable steel covers will be placed over each well. The
covers are intended to deter unauthorized entry and limit vandalism. Each cover will be
grouted at the surface.
Horizontal locations of the monitoring wells and borings will be identified in the field by
measuring with a tape and estimated right angles, referencing existing landmarks. Relative

elevations of the tops of well casings and the ground surfaces at the borings will be
measured with a survey level and rod, referencing a benchmark identified by the furnished
topographic plan drawing.
Test Boring Records, Ground -Water Monitoring Well Installation Records and Well
Construction Records will be prepared.
2.3 Ground -Water Sampling
Ground -water samples will be obtained from the newly installed monitoring wells. Sampling
will be performed by a team of hydrogeologic technicians from our office.
The monitoring wells will be developed to allow the formation around each screened
interval to recover from the effects of drilling and to bring fresh formation water into the
wells. The wells will be developed by removing at least six well volumes (or twice to
dryness if recovery is slow) using separate, decontaminated, Teflon bailers.
The wells will be purged and sampled using Teflon bailers and new polypropylene rope.
The Teflon bailers will be cleaned in the laboratory with phosphate -free detergent, dilute
nitric and isopropanol rinse, with distilled water rinse after each step. The bailers will be
wrapped with aluminum foil to minimize the possibility of contamination during
transportation to the site. Field measurements will include water levels, pH, temperature
and specific conductivity.
The samples will be packaged in ice and shipped for chemical analysis via next -day delivery
to Law Environmental National Laboratories in Kennesaw, Georgia. The samples will be

tested for nitrate and nitrite content in general accordance with EPA Method 353.2. Chain -
of -custody documentation will be used to provide a written record tracing the possession
and handling of the samples form the time of collection through laboratory analysis and
final recording of the results. Laboratory analysis and a copy of the chain -of -custody
records will be presented in the written report.
2.4 Report
Water level measurements will be taken in the newly installed wells and again at the
existing LEI monitoring wells. These data will be used to refine the ground -water contours
shown in Figure 2 of the Phase I Ground -Water Assessment. Horizontal and vertical
isopleths will be illustrated on a site plan figure and a cross -sectional figure if sufficient
data is obtained during this phase of ground -water assessment.
A written report will be submitted which describes the work done and presents the
laboratory test results as well as our evaluation of the general ground -water conditions.
2.5 Schedule
Field work has been scheduled and should begin within about two weeks following State
approval of this plan. Drilling and well installation likely will require one to two weeks and
development and sampling another week. Laboratory analyses is likely to take about three
weeks. Our written report will follow about two to three weeks after laboratory results have
been received.
The activities scheduled above are presented graphically in the attachments.

2.6 Compensation
Law Environmental proposes to provide the Phase II services outlined herein in accordance
with the unit rate Fee Schedule presented in our earlier proposals. A Cost Estimate
Exhibit (revising the estimate presented in our April 23, 1990 proposal) is attached. As
with previous activities, invoices for our work will be submitted every four weeks and are
payable upon receipt.
2.7 Authorization
As noted, we have received your signed authorization (with hand-written amendments to
the General Conditions and Fee Schedule) for our Phase I services. If desired, we can
maintain the Proposal Acceptance Sheet on file as authorization for Phase II.
If this proposal is satisfactory, please advise us to proceed by issuing a brief letter
acknowledging this document and the associated cost estimate, or by signing and returning
the attached Proposal Acceptance Sheet. The previously agreed Contract Terms and
Conditions will then apply to our Phase II services.

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ess n wr
SCALE 1:24000
1 MILE =09% LAW ENVIRONMENTAL, INC.
1000 0 1000 2000 3000. 4000 5000. 6000 7000FEET
1 5 0 1 KILOMETER CHARLOTTE, NORTH CAROLINA
CONTOUR INTERVAL 10 FEET
DATUM IS MEAN SEA LEVEL SITE LOCATION PLAN
MAPPED, EDITED, AND PUBLISHED BY THE GEOLOGICAL SURVEY SOUTHERN STATES FERTILIZER PLANT
CONTROL BY USGS AND USC&GS STATESVILLE, NORTH CAROLINA
TOPOGRAPHY BY PHOTOGRAMMETRIC METHODS FROM AERIAL
PHOTOGRAPHS TAKEN 1965. FIELD CHECKED 1969 JOB NO. 56-9606 FIGURE 1

TABLE 1
ESTIMATED WELL DEPTHS AND WATER LEVELS
PHASE'II GROUND -WATER ASSESSMENT
SOUTHERN STATES FERTILIZER PLANT
STATESVILLE, NORTH CAROLINA
LEI JOB NO. 56-9606
Well
Estimated
Estimated Depth
Designation
Well Depth (ft)
to Ground Water (ft)
K65W611D"
40
30
K65W611E"
100
15
K65W6"F"
45
35
K65W711D"
15
5
K65W7"E"
30
20
K65W711F"
15
5
K65W711G"
50
5
K65W711H"
100
20

SCHEDULE OF PROPOSED ACTIVITIES
PHASE II GROUND -WATER ASSESSMENT
SOUTHERN STATES: FERTILIZER PLANT
STATESVILLE,' NORTH CAROLINA
LEI JOB NO.56-9606
JUNE 11 JUNE 21 JULY 1 JULY 11 JULY 21 JULY 31' AUG. 10 AUG.'20 AUG.30
SEPT.9 SEPT.19 SEPT.29
TASK
SUBMITTAL. OF PHASE
•
II WORK PLAN
NCDEHNR REVIEW
--'
WELL INSTALLATION
- - - - --
FIELD WORK
AND SAMPLING
LABORATORY ANALYSES
- - - -
PREPARATION OF
PHASE 11 REPORT
SUBMITTAL OF
♦ -
PHASE 11 REPORT
AUTHORIZATION OF
OFF -SITE WELL
-- - - - - - - - - -�
INSTALLATION
ESTIMATED TIME BASED ON FAVORABLE FACTORS (CLEAR WEATHER, TIMELY
PERMISSION TO DRILL OFF -SITE, ETC.)
�- -� ESTIMATED TIME BASED ON UNFAVORABLE FACTORS (DELAYS IN OBTAINING
PERMISSION TO DRILL OFF -SITE, POOR WEATHER, ETC.)

Southern States
Cooperative, Inc.
6606 West Broad Street
Post Office Box 26234
Richmond, Virginia 23260
Telephone.[phone]
November 19, 1990
Mrs. Chris DeRoller
Hydrogeologist
State of North Carolina
Department of Environment,
Health and Natural Resources
919 North Main Street
Mooresville, NC 28115
Dear Mrs. DeRoller:
N. C. DEPT. OFF NATURAL
RESOURCES AND
COMMUNITY DEVELOPMENT
NOV 2 1 199Q
DIVISI3D OF MVIRV11,1, GTAL MATIAGEMERT
WWRESVILLE REGIONAL OFfICE
RE: Groundwater Incident # 5083
Iredell County, NC
co($j 5 ,
Southern
States
Enclosed is a copy of our consultant's response to your letter
of October 3, 1990. As you will note, they believe a 60 day
extension is necessary to accomplish this proposal; therefore, I
request such an extension.
I am sending this now so you may review prior to our meeting on
November 27 at 10:15 a.m. in your office.
I am also enclosing a copy of addendum #1 to the phase II
groundwater assessment report sent to you on September 25, 1990.
You will note from this addendum that the well on the property,.
to our east has only trace amounts of nitrate/nitrite.
If you have questions, please advise.
Sincerely,
f-//#m l,�i� rs l�0
Hilton M. Withers
Manager, Environmental Affairs
HMW/pgf
cc: Tom Beggs - Law Environmental

LAIN ENVIRONMENTAL, INC.
431 MINUET LANE
CHARLOTTE, NORTH CAROLINA 28217
P.O. BOX 240674
CHARLOTTE, NORTH CAROLINA 28224-0674
704-527-6717
November 13, 1990 N. c, D>up-y_ of lv�TURAL
REaouatC.Es ,LuD
COAUKuNi M DE1TE L0pMrN r
Southern States Cooperative, Inc.
P.O. Box 26234
Richmond, VA 23260
Attention: Mr. Hilton M. Withers
Manager, Environmental Affairs
Subject: Response to October 3, 1990 State Letter, and
Proposed Phase III Ground -Water Assessment
Southern States Fertilizer Plant
Statesville, North Carolina
LEI Job No. 56-9606.80
Gentlemen:
N OV 2 1 1
016'I'Vill OF HIVIRVINKUTRL f ANACHIEff
5101ESVILEE P0101-ML OFFICE
As requested by your letter dated October 31, 1990, this document has been prepared to
respond to an October 3, 1990 letter from Ms. Chris DeRoller of the State of North
Carolina, Department of Environment, Health and Natural Resources, Division of
Environmental Management, to Mr. Hilton Withers of Southern States. Also contained in
this submittal is a proposed Phase III Ground -Water Assessment work plan for your review.
Section 1.0 of this document is organized such that the numbering of the sub -sections
corresponds to the numbering of major points in the State's October 3, 1990 letter. Section
1.0 also includes a request to the State for an extension of compliance time. Section 2.0
includes the proposed Phase III Ground -Water Assessment work plan along with our
proposed schedule and cost estimate.

Southern States Cooperative, Inc.
November 13, 1990
Page 2
Law Environmental, Inc. appreciates the continuing opportunity to provide our professional
services on this project. If you have any questions concerning this proposal, please contact
us.
Sincerely,
LAW ENVIRONMENTAL, INC.
Bernard B. Schumak
Project Hydrogeologist
Thomas F. Beggs, P.E.
Principal
BBS:TFB:clp
Attachments
cc: Mr. Louis Ingram
W. R. Grace & Co.

RESPONSE TO OCTOBER2' 1990 S'I'A.,rE LET-VF"�rt)
AND P"ROPOL3E D IvAkSE TH GROUND -WATER ASSESSME-NT
SOUTHE'R.NT STATES FfIMMIZER PL-1kNT
STATESVILLE, NOIRTI-I C.AROLINA
Prepared for:
squ'then�l States Cooperative, Inc.
Ricklmond, Virginia
by:
Law Einviremmeutal, Inc.
Charlotte, North Carolina
November 1-3, 19,90
LEI Job No.

1.0 RESPONSE TO OCTOBER 3, 1990 LETTER
On October 3, 1990, the state of North Carolina Department of Environment, Health, and
Natural Resources (NCDEHNR) issued a letter to Southern States Cooperative, Inc. The
letter indicated' that the NCDEHNR Mooresville Regional office had reviewed Law
Environmental's Phase II Ground -Water Assessment report for the Statesville Southern
States Fertilizer Plant (please refer to Law's report dated September 21, 1990, Job No. 56-
9606.50).
The letter stated that NCDEHNR was in agreement with Law concerning the need for
further assessment activities. NCDEHNR indicated that these activities should be designed
to more fully define the vertical and horizontal extent of nitrate/nitrite ground -water
contamination. Specifically, NCDEHNR suggested four points for consideration during
Phase III assessment. Each of the points is presented below, followed by our response.
1.1 "The pH level in well K65W611E" is unusually high and may have affected the
nitrite/nitrate concentrations in the well. This well must be resampled."
Monitoring well K65W6"E" will be resampled during our Phase III assessment. The ground
water from this well will be tested in the field to determine pH, and a sample will be sent
to the laboratory for nitrate/nitrite testing. Results will be included in our written report.
1

1.2 "The drainage feature mentioned on page 5-2 flows in a westerly direction
before turning south along the western property boundary. The downgradient
direction from ponds 1 and 2 is almost due west. Contamination in the
saprolite aquifer may be discharging into the creek paralleling the western
property boundary. However, contamination in the bedrock aquifer may not
be affected by the Creek. An additional deep (bedrock) monitoring well is
necessary west of the ponds and the creek."
An additional deep (bedrock) monitoring well is proposed for installation on adjacent
property west of the site. The approximate location of this off -site well is shown in the
attached Figure 1. The well will be approximately 100 ft deep with a 15-ft open -face
interval from 85 to 100 feet. Ground water from the well will be analyzed for
nitrate/nitrite.
We note that this well, designated K65W7"L', will be drilled on property owned by others.
The project will be delayed pending drilling authorization from the property owner.
1.3 "You may wish to wait for the results from the deep potable water supply well
before locating the monitor wells that will be south of the property line."
On July 27, 1990, Southern States Cooperative issued a letter to the owner of three nearby
potable water wells. The letter requested permission to sample the wells. The owner has
not yet responded to the request.
2

Law Environmental agrees that the information from these potable wells would aid in
positioning the off -site monitoring wells proposed south of the site. However, the project
will be delayed pending receipt of authorization from the owner of the wells.
1.4 "In the July 6, 1990 letter, we requested that soil sampling be done in the
areas of the suspected sources. Five of the samples collected in the Phase II
assessment were quite distant from the suspected sources. Samples taken
from K65W6"E" and K65W7H" were close to the holding ponds but several
feet above the bottom of the holding ponds. Sediment samples from the
bottom of ponds 1 and 2 should be analyzed for nitrates and nitrites."
During the past several months, Law Environmental has been gathering field data in support
of a planned pond dewatering program. As part of this effort, two sediment samples from
the bottom of Pond No. 1 and one sample from the bottom of Pond No. 2 were obtained.
The samples were tested in July, 1990 for the following parameters:
Nitrogen, Ammonia
Nitrogen, Nitrate
Nitrogen, Nitrite
Phosphorus, Total
Total Kjeldahl Nitrogen
Copper, Total
Nickel, Total
Zinc, Total
Cadmium, Total
Lead, Total
The results of these tests are presented in the Attachments. A more detailed discussion of
the results will be included in our Phase III report.
3

In conclusion, the NCDEHNR letter requested that Southern States submit a Phase III
Assessment Report or request additional time within sixty days of receipt of the letter.
On behalf of our client, we are hereby requesting an extension of the compliance deadline
for this project. Southern States is making a conscientious effort to achieve compliance with
State environmental guidelines. As can be seen by review of the following section, a
substantial scope of additional work remains. An extension of at least sixty additional days
should make possible a thorough technical evaluation and report. For more information
regarding our proposed schedule, please refer to the attachments.
If this proposed extension is acceptable, please issue a brief letter acknowledging your
approval for our file. Also, please state the length of extension granted (at least 60 days,
preferably 120 days to allow time for authorization of off -site well installation).
2

2.0 PROPOSED PHASE III WORK PLAN
Phase II Ground -Water Assessment did not fully define the vertical or horizontal extent of
nitrate/nitrite (N) ground -water contamination. To help define the extent of ground -water
contamination, and to obtain additional site -specific hydrogeology, Law recommends an
additional phase of ground -water assessment.
The first step in our Phase III assessment will be to obtain samples from the three
inoperable former potable water wells located south and east of the site. These deep wells.
could yield valuable information regarding the vertical extent of nitrate/nitrite
contamination.
We also propose to obtain surface water samples from the creek which borders the site to
the west and south. Samples will be gathered upstream, midstream, and downstream of
Ponds 1 and 2.
Four new monitoring wells are proposed. Near the potable well south of the site, we
propose to install a water table monitoring well (K65W7"J") and a monitoring well extending
to the top of partially weathered rock (K65W7"K"). This would provide three vertical
sampling points in the vicinity. (We note that authorization from the relevant property
owner would need to be obtained.)
9

Near the existing well cluster at K65W7, we propose to install an additional Type III
monitoring well (K65W7I") This well would have an open face sampling zone from 175
to 200 ft below grade. The purpose of this well would be to determine the vertical extent
of nitrate/nitrite contamination in the vicinity of Ponds 1 and 2.
A Type III monitoring well (K65W7"L") is also proposed on adjacent property west of the
site. This well will be installed in response to the concern expressed in DEM's October 3,
1990 letter. Authorization to drill the well must be obtained from the property owner.
The planned location of .each proposed Phase III monitoring well is presented in the
attached. Figure 1.
2.1 Soil Test Borings
In conjunction with the installation of wells K65W7K" and K65W7"J", soil test borings will
be drilled. Data generated by these borings will indicate the type and consistency of
subsurface soil in the area.
The borings will be drilled by mechanically advancing hollow -stem steel augers. Soil
sampling and penetration testing will be performed in general accordance with ASTM D
1586. At regular intervals, soil samples will be obtained with a standard 1.4-inch I.D., 2-inch
O.D., split -tube sampler. The sampler will be first seated 6 inches to penetrate any loose
0

cuttings, and then driven an additional 12 inches with blows of a 140-pound hammer falling
30 inches. The number of blows required to drive the sampler the final 12 inches will be
recorded and is designated the "penetration resistance".
Representative portions of the soil samples, thus obtained, will be examined by an engineer
or geologist to verify the driller's field classifications. Test Boring Records will be prepared
showing the soil descriptions and penetration resistances.
2.2 Monitoring Well Installation
Monitoring wells will be installed at locations K65W7K" and K65W7" J" as described above.
Each well will consist of a 2-inch diameter schedule 40 PVC pipe with flush -threaded joints.
The lower 10-ft section of each well will consist of manufactured 0.010-inch wide slot well
screen. Washed sand backfill will be placed around the outside of the pipe to at least 2-ft
above the top of the well screen. A 2-ft minimum bentonite seal will be placed above the
sand backfill. The remainder of the annular space will be grouted to the surface with a
cement/bentonite grout. Ground -Water Monitoring Well Installation Records will be
prepared to illustrate well construction details.
7

Ground -water monitoring well K65W7'T' will be constructed as a water table well with the
top of the well screen near the water table. Well K65W7"K" will be drilled to auger refusal
(or a maximum of 70 feet). The well screen will be placed near the bottom of the boring.
Wells K65W7"I" and K65W7"L" will be rock wells drilled utilizing air -rotary techniques.
Well K65W7I" will have an open -face sampling interval from a depth of 175 to 200 ft below
grade. Well K65W7"L" will be drilled to approximately 100 ft below grade and will have
a 15 ft open face interval at the bottom.
At each boring location, the down -hole drilling equipment will be decontaminated by steam
cleaning prior to drilling. Steam cleaning will be performed to minimize the possibility of
cross -contamination between wells.
Upon completion of drilling, lockable steel covers will be placed over each well. The covers
are intended to deter unauthorized entry and limit vandalism. Each cover will be grouted
at the surface.
Horizontal locations of the monitoring wells and borings will be identified in the field by
measuring with a tape and estimated right angles, referencing existing landmarks. Relative
elevations of the tops of well casings and the ground surfaces at the borings will be
measured with a survey level and rod, referencing a benchmark identified by the furnished
topographic plan drawing. This work will be performed by a subcontracted surveying firm.

Test Boring Records, Ground -Water Monitoring Well Installation Records and Well
Construction Records will be prepared.
2.3 Ground -Water Sampling
Ground -water samples will be obtained from the newly installed monitoring wells. Sampling
will be performed by a team of hydrogeologic technicians from our office.
The monitoring wells will be developed to allow the formation around each screened
interval to bring fresh formation water into the wells. The wells will be developed by
removing at least six well volumes (or twice to dryness if recovery is slow) using separate,
decontaminated, Teflon bailers.
The wells will be purged and sampled using Teflon bailers and new polypropylene rope.
The Teflon bailers will be cleaned in the laboratory with phosphate -free detergent, dilute
nitric and isopropanol rinse, with distilled water rinse after each step. The bailers will be
wrapped with aluminum foil to minimize the possibility of contamination during
transportation to the site. Field measurements will include water levels, pH, temperature
and specific conductivity.
01

Ground -water samples will be obtained from the former potable wells by reconnecting the
electric pumps and pumping water to the surface. The wells will be purged by pumping at
least six well volumes prior to sampling.
The samples will be packaged in ice and shipped for chemical analysis via next -day delivery
to Law Environmental National Laboratories in Kennesaw, Georgia. The samples will be
tested for nitrate and nitrite content in general accordance with EPA Method 353.2. Chain -
of -custody documentation will be used to provide a written record tracing the possession and
handling of the samples. form the time of collection through laboratory analysis and final
recording of the results. Laboratory analysis and a copy of the chain -of -custody records will
be presented in the written report.
2.4 Report
Water level measurements will be taken in the newly installed wells and again at the existing
LEI monitoring wells. These data will be used to refine the ground -water contours shown
in Figure 2 of the Phase II Ground -Water Assessment. Horizontal and vertical isopleths will
be illustrated on a site plan figure and a cross -sectional figure.
A written report will be submitted which describes the work done and presents the
laboratory test results as well as our evaluation of the general ground -water conditions.
IN

2.5 Schedule
Field work can begin within about two weeks following State approval of this plan and
authorization from the relevant property owners. Drilling and well installation likely will
require one to two weeks and development and sampling another two weeks. Laboratory
analyses is likely to take about three weeks. Our written report will follow about two to
three weeks after laboratory results have been received..
2.6 Compensation
Law Environmental proposes to provide the Phase III services outlined herein in accordance
with the unit rate Fee Schedule presented in our earlier proposals. A Cost Estimate Exhibit
(revising the estimate presented in our September 17, 1990 submittal) is attached. As with
previous activities, invoices for our work will be submitted every four weeks and are payable
upon receipt.
2.7 Authorization
As noted, we have received your signed authorization (with hand-written amendments to the
General Conditions and Fee Schedule) for our Phase II services. If desired, we can
maintain the Proposal Acceptance Sheet on file as authorization for Phase III.
11

If this proposal is satisfactory, please advise us to proceed by issuing a brief letter
acknowledging this document and the associated cost estimate, or by signing and returning
the attached Proposal Acceptance Sheet. The previously agreed Contract Terms and
Conditions will then apply to our Phase III services.
12

AYfACIRMENTS
Laboratory Test Results for Pond Bottom Sediments
Figure 1: Proposed Phase III Well Locations and Estimated Isopleths
for Water -Table Wells
Table 1: Estimated Well Depths and Water Levels
Cost Estimate Exhibit
Proposal Acceptance Sheet

o
LAW ENVIRONMENTAL, INC.
112 TOWNPARK DRIVE
KENNESAW,GEORGIA 30144-5599
404-421-3400
August 14, 1990
Law Environmental, Inc.
431 Minuet Lane
Charlotte, NC 28217
Attention: Tom Beggs
LE .lob Number: 56-9606.70
Subject: Chemical analyses of samples received on 07/27/90.
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.
If there are any questions, please do not hesitate to 'coritact us.
Sincerely,
LAW ENVIRONMENTAL N L LABS
j
Clifford H. McBride
QC Coordinator
Attachment: Data Report
Invoice

LAW ENVIRONMENTAL NATIONAL LABORATORIES
TEST DATA REPORT
to 08/14/90
ge 1
--- Project Information ---
Lab Number 90-6516-01
Project No. 56-9606.70 Cust. No.
Project Name SOUTHERN STATES PLANT
Manager: TOM BEGGS
Sample Information
Station ID :
HOLDING POND NO. 1
Sampled Date/Time :
07/26/90 10:00
Matrix :
SO
Received Date/Time :
07/27/90 10:14
Type :
GRAB
Received From/By :
TFB/GP
Collector
: TFB
Chain of Custody.:
412
Number of Containers :
3
Remarks :
--- Test Data ---
Lrameter .............................. Method..'.. Units PQL....... Results... Test Date Analy
-- INORGANIC CHEMISTRY RESULTS --
>isture (Oven Dried @ 105C)
EPA
160.3M
1
37
07/31/90
GW
.trogen, Ammonia
SA 84-3M
mg/kg
0.15.
64
08/08/90
JL
?nitrogen, Nitrate
MSA
84-3M
mg/kg
0.5
0.73
07/31/90
JL
'J4•trogen, Nitrite
MSA
84-3M
mg/kg
0.5
ND
07/31/90
JL
iosphorus, Total
EPA
365.2M
mg/kg
0.2
15.0,
07/30/90
JL
_-)tal Kjeldahl Nitrogen
EPA
351.1M
mg/kg
0.15
1900
08/08/90
JL
METALS ANALYSIS - METALS PREP RESULTS
--
)pper, Total
EPA
7210
mg/kg
3
4.1
08/08/90
DE
Nickel, Total
EPA
7520
mg/kg
4
100
08/08/90
DE
74•nc, Total
EPA
7950
mg/kg
2
.25
08/08/90
DE
idmium, Total
EPA
7131
mg/kg
0.2
0.3
08/08/90
DF
_,ad, Total
EPA
7421
mg/kg
0.5
0.17
08/07/90
DE
•- SERIES 35000
)tal Metals Prep: .Solid AA Flame
EPA
3050
N/A
08/03/90
HH
Total Metals Prep: Solid Furnace
EPA
3050
N/A
08/03/90
HH
Signed C_ f �� ��LIT

LAW
ENVIRONMENTAL
NATIONAL LABORATORIES
TEST DATA REPORT
to 08/14/90
'gage 1
--- Project
Information ---
Lab Number
90-6516-02
Cust. No.
Project No.
56-9606.70
Project Name
SOUTHERN STATES PLANT
Manager:
TOM BEGGS
--- Sample
Information ---
Station ID
HOLDING POND
NO.1
Sampled Date/Time
Date/Time
07/26/90 11:00
07/27/90 10:14
Matrix
W
Received
Received From/By
TFB/GP
Type
Collector
GRAB
TFB
Chain of Custody
: 412
Number of Containers
3
Remarks :
--- Test Data ---
irameter :............................. Method.... Units PQL....... Results... Test Date Analy
-- INORGANIC CHEMISTRY RESULTS --
EPA
350.1
mg/1
0.03
61
08/08/90
JL
�trogen, Ammonia �
-itrogen, Nitrate
EPA
353.2
mg/l
0.05'
07/31/90
JL
Nitrogen, Nitrite
EPA
353.2
mg/l
0.05
0.
07/31/90
JL
nosphorus, Total
EPA
365.2
mg/1
0.01
22
22
63
0/0/90
08/8/90
JL
JL
otal Kjeldahl Nitrogen
EPA
351.2
mg/l
0.08
-- METALS ANALYSIS - METALS PREP RESULTS --
EPA
7210
mg/l
0.02
ND
08/03/90
DE
opper, Total
,.ickel, Total
EPA
7520
mg/1
0.04
ND
08/06/90
KE
Zinc, Total
EPA
7950
mg/l
0.02
0.03
08/08/90
DE
admium, Total
EPA
7131
mg/1
0.002
ND
08/08/90
DE
ead, Total
EPA
7421
mg/l
0.005
ND
08/03/90
DE
- SERIES 35000
otal Metals Prep: Aqueous AA Flame
EPA
3010
N/A
08/
HH
total Metals Prep: Aqueous Furnace
EPA
3020
N/A
08/01/90 1/90
HH
i
Signed

LAW
ENVIRONMENTAL
NATIONAL LABORATORIES
TEST DATA REPORT
I to 08/14/90
1 ge 1
--- Project
Information ---
Lab Number
90-6516-03
Project No.
56-9606.70
Cust. No.
Project Name
SOUTHERN STATES PLANT
Manager:
TOM BEGGS
--- Sample
Information ---
Station ID :
HOLDING POND
NO.2
Sampled Date/Time
07/26/90 11:15
Matrix :
W
Received Date/Time
07/27/90 10:14
Type :
GRAB
Received From/By
TFB/GP
Collector :
TFB
Chain of Custody
412
Number of Containers.
3
Remarks :
--- Test Data ---
Lrameter ............... "............... Method.... Units PQL....... Results... Test Date Analy
-- INORGANIC CHEMISTRY RESULTS --
.trogen, Ammonia
EPA
350.1
mg/l
0.03
23
08/13/90
JL
.trogen, Nitrate
EPA
353.2
mg/l
0.05.
ND
07/31/90
JL
Nitrogen, Nitrite
EPA
353.2
mg/l
0.05
ND
07/31/90
JL
".1hosphorus, Total
EPA
365.2
mg/1
0.01
24
07/30/90
JL
)tal Kjeldahl Nitrogen
EPA
351.2
mg/l
0.08
33.
08/1-3/90
JL
-- METALS ANALYSIS - METALS PREP RESULTS
--
)pper, Total
EPA
7210
mg/1
0.02
ND
08/03/90
DE
.ckel, Total
EPA
7520
mg/l
0.04
ND
08/06/90
KE
Zinc, Total
EPA
7950
mg/l
0.02
0.07
08/08/90
DE
"zdmium, Total
EPA
7131
mg/l
0.002
ND
08/08/90
DE
gad, Total
EPA
7421
mg/l
0.005
ND
08/03/90
DE
--- SERIES 35000
)tal Metals Prep: Aqueous AA Flame
EPA
3010
N/A
08/01/90
HH
�ta1 Metals Prep: Aqueous Furnace
EPA
3020
N/A
08/01/90
HH
Signed

=, LAW ENVIRONMENTAL, INC. CHAIN OF CUSTODY RECORD
NATIONAL LABORATORY 1 / /
112 TOWNPARK DRIVE SAMPLING NAME OF FACILITY: 500-ae/thr�G�IT r (( C
KENNESAW GEORGIA 30144 INFORMATION
[phone]
PROJECT NAME
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SAMPLING DATE
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DISTRIBUTION: ORIGINAL AND YELLOW COPIES ACCOMPANY SAMPLE SHIPMENT TO LABORATORY.
PINK COPY RETAINED
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RECEIVED BY LABORATORY: DATE /TIME
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RCRA MONITORING WELL- MW ' DRINKING WATER - DW
SOIL/SEDIMENT - SO HAZARDOUS WASTE -HW
SLUDGE -SL SURFACE WATER - SW
NON -AQUEOUS - NA

TABLE 1
ESTIMATED WELL DEPTHS AND WATER LEVELS
PHASE III GROUND -WATER ASSESSMENT
SOUTHERN STATES FERTILIZER PLANT
STATESVILLE, NORTH CAROLINA
LEI JOB NO. 56-9606.80
Well Estimated Estimated Depth
Designation Well Depth (ft) to Ground Water (ft)
-------------------------------------------------------------------
K65W7"I"
200
30
K65W7"J"
35
25
K65W7"K"
60
25
K65W7"L"
100
20

COST ESTIMATE EXHIBIT'
PHASE III GROUND -WATER ASSESSMENT
SOUTHERN STATES FERTILIZER PLANT
STATESVILLE, NORTH CAROLINA
LEI JOB NO. 56-9606.80
I. INSTALLATION OF A 2-INCH DIAMETER PVC WATER TABLE AND
A PARTIALLY WEATHERED ROCK MONITORING WELL
A) 'Site Layout/Potable Well Inspection ............ $ 600
B) Drilling Vehicle Mobilization .................. $ 350
C) Auger Drilling
Drilling Set Up ....................... $ 100
Assume one boring to 40 ft,
40 ft x $7.50/ft ....................... $ 300
Assume one boring to 80 ft in partially
weathered rock, 80 ft x $10.50/ft .......... $ 840
D) Type II/III Monitoring Wells
2 wells, 120 ft total @ $22/ft ............. $2640
Additional casing, 50 ft total @ $34/ft ...... $1700
E) Hourly Drill Crew Services
Standby, difficult moving, or
decontamination assume 8 hrs. @ $110/hr ... $ 880
F) Per Diem Charges
3 days @ $110/day .................... $ 330
G) Steam Cleaner Charges
4 days @ $65/day .................... $ 260
H) Well Covers
2 covers @ $160 each 320
1
Estimated Cost ................. '8320
Add 15% Contingency ............ 1230
Total ......................... $9550
'Reference Law Environmental's September 21, 1990 Phase II Ground -Water
Assessment Report (LEI Job No. 56-9606.50) and the DEM response dated October 3, 1990.

1
REVISED COST EXHIBIT CONTINUED
II. INSTALLATION OF ONE DEEP ROCK WELL
A) Rock Well/Air Drilling
Cost is $14,400 including the cost of a 6-inch diameter PVC
pipe to 175 ft with a 25-ft open face interval. Includes cost to
set 62 ft of 10-inch temporary casing.
............................. $14,400
Add 15% Contingency ....................... 2,200
Total ............................. $16,600
B) Additional Rock (bedrock) Well as Requested by the North
Carolina Division of Environmental Management's October 3,
1990 Letter.
Cost is $8,900 including the cost of a 4-inch diameter PVC pipe
to approximately 100 ft (based on depth to bedrock) with a 15
ft open face interval. Includes cost to set 65 ft of 10-inch
temporary casing.
............................. $ 8,900
Add 15% Contingency .................. $ 1.300
Total ............................. $10,200
III. FIELD CONSULTING SERVICES
Engineer/Geologist to monitor drilling operations (full-time observations),
and submit well -drilling permit application forms to state regulatory agencies.
Assume............................. $ 6,400
Estimated Phase III Well -Drilling Cost ..................... $42,750

2
REVISED COST ESTIMATE EXHIBIT CONTINUED
IV. FIELD SAMPLING AND LABORATORY TESTING
Assume two technicians for eight days to measure water levels in new LEI
wells, develop wells, take field measurements, collect samples from well
K65W6"E", the four new wells, and the three potable wells, and take three
creek samples .................................. $6,500
Laboratory Testing:
Nitrates/Nitrites
Eight wells and three creek samples ........... $ 400
Allowance for testing other parameters
as may be requested by the State ............... $4,400
Surveyor to determine elevations of existing
potable wells and new monitoring wells ............... $6,200
Note: This cost estimate assumes the existing well pumps can be utilized for
sampling and electrical power is provided to the pumps by others.
Estimate Phase III Field Sampling_Cost .................... $17,500
V. HYDROGEOLOGICAL ANALYSIS AND REPORT PREPARATION
Project professional to refine ground -water contour map, prepare
nitrate/nitrite isopleth maps, coordinate project activities, and prepare a
Phase III draft report.
Assume 180 hrs @ $75/hr ......................... $13,500
Principal Engineer/Geologist review
Assume 20 hrs @ $120/hr .................... $ 2,400
Clerical/drafting costs, assume ...................... $ 1,200
Travel expenses, mileage, etc . ...................... $ 850
VI. MEETINGS
Client/regulatory personnel meetings to discuss job progress and field results,
telephone conferences, etc. assume ................... $ 3,800
Estimated Phase III Report Cost 21 750
ESTIMATED TOTAL ]PHASE III ASSESSMENT COST $82,000

LAW ENVIRONMENTAL, INC.
a
a professional engineering and
earth science consulting firm
Identification of Services
Project Name
Project Location
Proposal No. and Date _
Consultant's Designation
PROPOSAL ACCEPTANCE SHEET
for Projects involving Hazardous Substances
PHASE III GROUND —WATER ASSESSMENT SERVICES
SOUTHERN STATES FERTILIZER PLANT
STATESVILLE, NORTH CAROLINA
LEI JOB NO. 56-9606.80; DATED NOVEMBER 13, 1990
CHARLOTTE, NORTH CAROLINA
CLIENT
Name SOUTHERN STATES COOPERATIVE, INC.
Address P.O. BOX 26234
RICHMOND, VA Zip Code 23260
Attention: MR. HILTON M. WITHERS
FOR NOTICES:
Client: Name _
Address
Consultant: Name _
Address
SPECIAL INSTRUCTIONS:
_ Phone number
Title MANAGER, ENVIRONMENTAL AFFAIRS
Phone number
Phone number
PROPOSAL ACCEPTANCE
The Terms and Conditions of this Proposal, including the terms on this page and the reverse hereof are:
Accepted this _ day of 19
Print or type individual, firm or corporate body name
Signature of authorized representative
Print or type name of authorized representative and title

TERMS AND CONDITIONS
SERVICES TO BE PROVIDED. Law Environmental. Inc. and/or its subsidiaries, affiliates, and at no time assume title to said waste.
branches, or divisions, as an Independent consultant, agrees to provide Client for its sole
benefit and exclusive use consulting services set forth in our Proposal.
DEFINITIONS. When used herein, the terms "we". "us", or "our" refer to Consultant and the
terms "you", "your", "he", "his". "it" and "Its" refer to Client.
RIGHT OF ENTRY AND RIGHT TO PROCEED. Client grants a right of entryfrom time !o time
to Consultant, its agents, staff, consultants, and contractors or subcontractors, for the purpose
of performing and with the riaht to perform all acts. studies, and research including without
limitation the making of tests and evaluations, pursuant to the agreed services. Client
represents that he possesses all necessary permits and licenses required for the continuation
of its activities at the site.
BILLING AND PAYMENT. Unless otherwise indicated in our Proposal, our billings will be
based on actual accrued time, test costs, and expenses. Client agrees to pay invoice upon
receipt. Should payment not be received within 30 days, the amount due shall bear a service
charge of 1 % percent per month or 18 percent per year and the cost of collection, including
reasonable attorneys' fees, i1 collected by law or through an attorney. If 11/2 percent per month
exceeds the maximum allowed by law, the charge will automatically be reduced to the
maximum legally allowed. If Client has any objections to any invoice or part thereof submitted
by Consultant, he shall so advise us in writing giving his reasons within 14 days of receipt of
such invoice. Client agrees it will not exercise any right of set-off it has under this Agreement,
any continuing agreement with Consultant, or any right of set-off provided by law. No
deduction shall be made from Consultant's invoice on account of penalty, liquidated damages,
or other sums withheld from payments to contractors or others. Payment of the invoice shall
constitute final approval as to all aspects of the work performed to date as well as the necessity
thereof. If the project is terminated in whole or in part then we shall be paid for services
performed prior to our receiving or issuing written notice of such termination, in addition to our
reimbursable expenses and any shut down costs incurred. Shut down costs may, at our sole
discretion, include completion of analysis and records necessary to document our files and
protect o jr professional reputation.
DAMAGE AT SITE. We will not be liable for any property damage or bodily injury arising from
damage to or interference with surface or subterranean structures (including, without
limitation, pipes, tanks, telephone cables, etc.) which are not called to our attention in writing
and correctly shown on the plans furnished by Client in connection with work performed under
this Agreement. Client recognizes that the use of exploration and test equipment may
unavoidably affect, alter, or damage the terrain and affect subsurface, vegetation, buildings,
structures arid equipment in, at, or upon the site. Client accepts the fact that this is inherent to
our work and will not hold us liable or responsible for any such effect, alteration or damage.
STANDARD OF CARE AND WARRANTY. Professional services provided by us will be
performed, findings obtained, and recommendations prepared in accordance with generally
accepted engineering principles and practices. THIS WARRANTY IS IN LIEU OF ALL OTHER
WARRANTIES, EITHER EXPRESS OR IMPLIED.
PUBLIC LIABILITY. Consultant maintains workers' compensation and employer's liability
insurance for our employees as required by state laws. In addition, we maintain compre-
hensive general liability and auto liability insurance with limits of S1,000,000. A Certificate of
Insurance can be supplied evidencing such coverage. We will not be liable or responsible for
any loss, damage, or liability beyond the amounts, limits, coverage, or conditions of such
insurance specified above. In the event any third party brings suit or claim for damages against
us alleging exposure to or damage from material, elements or constituents at or from Client's
facility before, during, or after the services of this Agreement, which is alleged to have resulted
in or caused disease or any adverse health condition to any third party or resulting in cost for
remedial action, unin habitability of the property, or other property damage, then: Client agrees
to defend us in any such suit or claim and pay on our behalf any judgment resulting against us,
including any interest thereon. Further. Client with our concurrence will select, hire and pay an
a-omey to defend any such suit or claim, will pay Court costs for which we may be liable in any
such suit and will bear and pay litigation expenses Client incurs in providing a reasonable and
professional defense which will be provided by Client according to prevailing local standards.
Client will nave the right to investigate, negotiate and settle, with our concurrence, anysuch suit
or claim, and we will cooperate in the defense of any such suit or claim.
PROFESSIONAL LIABILITY. Client agrees to iimil our liability to client or any third party
ansing from negligent professional acts, errors or omissions, such that our total aggregate
liability shall not exceed S50,000 or our total tee. whichever is greater. If Client prefers to have
haher limits of professional liability coverage, we agree, upon receipt of Client's written
r-ouest at the time of accepting our Proposal, to increase the limits of liability up to a maximum
of S1,000,000, at an additional cost o1 10 percent of our total tee.
SAMPLING AND TESTING LOCATION. The fees included in our Proposal do not include
costs associated with surveying of the site and/or facility to determine accurate horizontal and
vertical locations of tests. If surveying is required, cost of surveying will be paid by Client. Field
tests or boring locations described in our report or shown on sketches are based on specific
information furnished by others or estimates made in the field by our personnel. Such
dimensions, depths or elevations are approximations.
SAMPLE HANDLING AND RETENTION. Generally, test samples or specimens are
consumed or substantially altered during the conduct of tests and Consultant, at our sole
dscretion, will dispose (subject to the following) of any remaining residue immediately upon
completion of tests.
A. NON -HAZARDOUS SAMPLES. At Client's written request, we will maintain preserv-
able test samples and specimens or the residue therefrom for 30 days affer submission of our
report free of storage charges. After the initial 30 days and upon written request• we will retain
test specimens or samples fora mutually acceptable storage charge and period of time. Client
agrees that it will not hold us responsible or liable for any loss of lest specimens or samples
retained in storage.
B. HAZARDOUS OR POTENTIALLY HAZARDOUS SAMPLES. In the event that samples
contain substances or constituents hazardous or detrimental to health, safety, or the
environment as defined by federal, stale or local statutes, regulations, or ordinances, we will,
ahercomplelion of testing and at Client's expense, (i) return such samples to Client, or Iii) using
a manifest signed by Client as generator, we will have such samples transported to a location
vWMr 1 by Client lnr final disnnsal_ Client anrees to nav all cnsts assnciated with the storage.
HAZARDOUS SUBSTANCES AND CONSTITUENTS. Client agrees to advise us up —
execution of this Agreement of any hazardous substances or any condition existing in, on. or
near the site presenting a potential danger to human health. the environment, or equipme-
Client agrees to provide continuing information as it comes available to the attention of Clien
the future. By virtue of entering into this Agreement or of providing services hereunder, we
not assume control o1 or responsibility for the site or the person in charge of the site,
undertake responsibility for reporting to any federal, stale or local public agencies any
conditions at the site that may present a potential danger to public health, safety or the
environment. Client agrees to notify the appropriate federal, stale or local public agencies
required by law, or otherwise to disclose, in a timely manner, any information that may
necessary to prevent any danger to health, safety, or the environment. In connection w....
hazardous waste, Client agrees to the maximum extent permitted by law to defend, hold
harmless and indemnify Consultant from and against any and all claims and liabilities resulli—
Irom:
(a) Client's violation of any federal, state or local statute, regulation or ordinance relating
the disposal of hazardous substances or constituents;
(b) Client's undertaking of or arrangement for the handling, removal, treatment, storage.
transportation or disposal of hazardous substances or constituents found or identified at the
site;
(c) Changed conditions or hazardous substances or constituents introduced at the site
Client or third persons before or after the completion of services herein.
(d) Allegations that Consultant is a handler, generator, operator, treater or storer, transposer,
or disposer under the Resource Conservation and Recovery Act of 1976 as amended or anv
other similar Federal, state or local regulation or law.
CONTAMINATED EQUIPMENT. All laboratory and field equipment contaminated in p
forming our services and which cannot be reasonable decontaminated shall become inr
property and responsibility of client. All such equipment shall be delivered to Client or
disposed of in a manner similar to that indicated for hazardous samples. Client agrees to r-
the fair market value of any such equipment which cannot reasonable be decontaminate
UNFORESEEN OCCURRENCES. If, during the performance of services, any unforest
hazardous substances or constituents or other unforeseen conditions or ocurrences are
encountered which, in our sole judgment signif icantlyaffect or may affect the services, the risk
involved in providing the services, or the recommended scope of services, we will proml
notify Client thereof. Subsequent to that notification, Consultant may.
(a) If practicable, in our sole judgment, complete the original Scope of Services
accordance with the procedures originally intended in the Proposal;
(b) Agree with Client to modify the Scope of Services and the estimate of charges to include
study of the previously unforeseen conditions or occurrences, such revision to be in writ
and signed by the parties and incorporated herein; or
(c) Terminate the services effective on the date specified by us in writing.
CLAIMS. In the event that Client makes claim against us at law or otherwise, for any alleged
error, omission, or act arising out of the performance of our services, that cannot be mutup'l-
resolved without resort to litigation, and Client fails to prove such claim, then Client shall pay
costs incurred by us in defending ourselves against the claim, including• without limitation, i
personnel -related costs, attorneys' fees. court costs, and other claim -related expens_
including, without limitation, costs, fees, and expenses of experts. Client agrees that for the
purposes of this Agreement it has failed to prove its claim when the judgment in litigation is for a
sum of money less than that sum offered by us to resolve the matter without litigation.
DOCUMENTS. Client will furnish or cause to be furnished such reports, data, studies, pla
specifications, documents and other information deemed necessary by us for proper per-
formance of our services. We may rely upon client -provided documents in performing the
services required under this Agreement; however, we assume no responsibility or liability
their accuracy. Client -provided documents will remain property of Client. All documei
including but not ::mited to, drawings, specifications, reports, boring logs, field notes, I
oratory test data, calculations and estimates, prepared by us as instruments of service
pursuant to this Agreement. shall be our sole property. Client agrees that all documents of any
nature furnished to Client or Clients agents or designees, it not paid for, will be returned ur
demand and will not be used by Client for any purpose whatsoever. Client further agrees t
under no circumstances shall any documents produced by us pursuant to this Agreement
used at any location or for any project not expressly provided for in this Agreement without o.,•
prior written permission. If Client uses all or any portion of our work on another project without
our permission, Client shall to the maximum extent permitted by law save us harmless from:
and all claims arising from such unauthorized reuse. Further, no part of any document
deliver to Client shall be reproduced or distributed, whether for advertising or any of
purpose, without our prior written consent. Any such reproduction or distribution shall be at
Client's sole risk and without liability or legal exposure to Consultant.
FIELD REPRESENTATIVE. The presence of our field personnel either full -or part-time wil
for the purpose of providing observation and field testing of specific aspects of the prop
Should a contractor be involved in the project, our work does not include supervisior
direction of the actual work of the contractor, his employees or agents. The contractor should
be so advised. The contractor should also be informed that neither the presence of our field
representative nor the observation and testing by us shall excuse contractor in any way
defects discovered in contractor's work. It is agreed that we will not be responsible for jol
site safety on the project and that we do not have the right to stop the work of the contract(
SEVERABILITY. In the event that any provision herein shall be deemed invalid or unen-
forceable, the other provisions hereof shall remain in full force and effect, and binding upon rho
parties hereto.
SURVIVAL. All obligations arising prior to the termination of this Agreement and all provisi
of this Agreement allocating responsibility or liability between Client and Consultant shall
survive the completion of the services and the termination of this Agreement.
INTEGRATION. This Agreemenl and the documents attached hereto and which are in,
porated herein constitute the entire Agreement between the parties and cannot be Chan
except by a written instrument signed by both the parties.
GOVERNING LAW. This Agreement shall be governed in all respects by the laws of the State

RESOURCES AND
)3E'4 tLS7vjje$ m
LAW ENVIRONMENTAL, INC.
P..,:li�li Y111L11i n
431 MINUET LANE
CHARLOTTE, NORTH CAROLINA 28217
P.O. BOX 240674
CHARLOTTE, NORTH CAROLINA 28224-0674
704-527-6717
October .24, 1990
Southern States Cooperative, Inc.
P.O. Box 26234
Richmond, VA 23260
Attention: Mr. Hilton M. Withers
Manager, Environmental Affairs
Subject: Addendum No. 1
Report of Phase H Ground -Water Assessment
Southern States Fertilizer Plant
Statesville, North Carolina
LEI Job No. 56-9606.50
Gentlemen:
On September 21, 1990, Law Environmental submitted a Phase II Ground -Water
Assessment Report for the subject project. The report presented our evaluation of data
gathered from seven Phase II monitoring wells.
An eighth well was originally planned for Phase H. This well (designated K65W6"F") was
situated east of the site on property owned by Ralston Purina Company. Authorization to
install the well was not granted by Ralston Purina until mid -September; therefore, data from
the well was not available during the preparation of our report.
Well K65W6"F" was installed on September 18, 1990 using field techniques similar to those
described for other shallow wells at the site. The total well depth was 20.0 ft, and ground
water was encountered at a depth of 13.7 ft below the ground surface during sampling on
September 25. Laboratory tests on water and soil samples from the well were conducted
using procedures. similar to those previously described.
In summary, only trace amounts of nitrate/nitrite were detected in the ground water sample
from K65W6"F". Nitrate/nitrite contamination was not detected in the soil sample. The
results of our laboratory tests, along with a summary of field data for K65W6"F" are
attached.

Southern States Cooperative, Inc.
October 24, 1990
Page 2
This Addendum No. 1 is intended to be a part of our September 21, 1990 report.
Information presented herein should be evaluated in conjunction with the September 21
report.
Law Environmental appreciates the opportunity to provide our professional consulting
services on this project. If you have any questions regarding this addendum, please feel free
to contact us.
Sincerely,
LAW ENVIRONMENTAL, INC.
Bernard B. Schumak
Project Hydrogeologist
Thoma F Beggs, P.E.
Principal
BBS:TFB:lwv
cc: W. R. Grace & Co.
Mr. Louis Ingram

TABLE 1
GROUND -WATER FIELD PARAMETERS/LABORATORY ANALYSES
SOUTHERN STATES FERTILIZER PLANT
STATESVILLE, NORTH CAROLINA
LEI JOB NO. 56-9606.50
ADDENDUM NO. 1
Specific
Boring Conductance NO2 + NO3
Number Temperature Co my/cm pH (as N) mg/1
*K65W6"A"
18.6
6.430
5.27.
370
*K65W6"B"
15.7
0.330
4.31
22
*K65W611C"
15.2
0.841
5.41
76
*K65W7"A"
16.0
1.320
5.81
53
*K65W7"B"
14.5
0.983
4.30
21
*K65W7"C"
14.9
1.878
4.49
93
K65W6"D"
18.0
0.041
5.01
0.63
K65W6"E"
18.9
0.500
11.17
7.3
**K65W6"F"
19.0
0.700
6.28
0.14
K65W711D"
22.4
1.100
5.14
11
K65W7"E"
16.3
0.234
4.75
15
K65W7"F"
19.6
1.777
5.73
99
K65W7"G"
18.6
0.090
5.01
1.7
K65W711H"
25.2
N.M.
6.11
280
* - Wells sampled on 2/13/90; others sampled on 8/1/90.
N.M. - No Measurement, instrument not working properly.
** - Well K65W611F" sampled on 9/25/90.

TABLE 2
SOIL SAMPLING/LABORATORY ANALYSES
SOUTHERN STATES FERTILIZER PLANT
STATESVILLE, NORTH CAROLINA
LEI JOB NO. 56-9606.50
ADDENDUM NO. 1
Boring
Sample Depth
Nitrate - NO3
Nitrite - NO2
Number
(feet)
(in mg/1)
(in mg/1)
K65W611D"
3
ND
ND
K65W611E"
3
3.4
ND
**K65W6"F"
3
ND
ND
K65W711D"
3
1.6
ND
K65W711E"
3
ND
ND
K65W711F"
3
1.1
ND
K65W7"G"
3
ND
ND
K65W711H"
3
ND
ND
ND - Not Detected
Samples analyzed by Law Environmental National Laboratories,
Kennesaw, Georgia.
** Well K65W611F" sampled on 9/25/90; others sampled on 8/1/90.

GROUND -WATER MONITORING WELL INSTALLATION RECORD
JOB NAME SOUTHERN STATES FERTILIZER PLANT JOB NUMBER 56-9606.50
WELL NUMBER K65W6"F" GROUND SURFACE ELEVATION --
LOCATION STATESVILLE, NORTH CAROLINA _ MEASURING POINT ELEVATION
INSTALLATION DATE 9/18/90
LOCKABLE CAP
VENTED PVC CAP
STEEL PIPE
STICKUP 2. 10 FT
BORING
GROUT
BENTONITE SEAL
2' PVC PIPE
SAND
PVC SCREEN
CAP
NOTE: ALL PVC PIPE JOINTS HAVE SCREW CONNECTORS
DEPTH TO
BASE OF
GROUT SEAL
4.0 FT
DEPTH TO
TOP OF
SAND BACKFILL
6.5 FT
TOTAL DEPTH
OF WELL
20.0 FT
GROUND WATER 15.8 FT BELOW TOP OF CASING
ON 9/25/90.
CLAW ENVIRONMENTAL, INC. MONITORING WELL
INSTALLATION RECORD
CHARLOTTE, NORTH CAROLINA

NORTH CAROUNA DEPARTMENT OF NATURAL RESOURCES AND COMMUNITY DEVELOPMENT
DIVISION OF ENVIRONMENTAL MANAGEMENT - GROUNOWATIER SECTION
P.O. BOX 27687 - RALEIGH.II.C. 27611. PHONE (01 D) 733-5083
WELL CONSTRUCTION RECORD
FOR OFFICE USE ONLY
Ouad. No. Serial No.
Lat. Long. Pc
Minor Basin
Basin Code
Header Ent. GW-1 Ent.
DRILLING CONTRACTOR LAW ENGINEERING K65W6"F"
STATE WELL CONSTRUCTION
DRILLER REGISTRATION NUMBER 332 PERMIT NUMBER: 48-0238-WM-0078
1. WELL LOCATION: (Show sketch of the location below)
Nearest Town: Statesville, North Carolina County: Iredell
(Road, Community, or Subdivision and Lot No.)
2. OWNER Southern States Cooperative, Inc.
ADDRESS U.S. Highway 70 East
Statesville (Street or Route No.
North Carolina
City or Town State Zip Code
3. DATE DRILLED 9/18/90 USE OF WELL. Monitoring
4. TOTAL DEPTH 2O.0 CUTTINGS COLLECTED El Yes' ❑ No
5. DOES WELL REPLACE EXISTING WELL? ❑ Yes © No
6. STATIC WATER LEVEL: 15.00 FT. ❑ above TOP OF CASING,
® below
TOP OF CASING IS 2.10 FT. ABOVE LAND SURFACE.
7. YIELD (gpm): METHOD OF TEST
S. WATER ZONES (depth):
9. CHLORINATION:
Type
Amount
10. CASING:
Wall Thickness
Depth
Diameter or Weight/Ft. Material
From 0
To 8.5
Ft.
2-IN Schedule 40 PVC
From
To
Ft.
From
To
Ft.
11. GROUT:
Depth
Material Method
From 0
To 4.0
F1.
Cement/Bentonite Pour
From 4.0
To 6.5
Ft.
Bentonite Pour
12. SCREEN:
Depth
Diameter Slot Size Material
From 8.5
To 18.5
Ft.
2 in. 0.010 in. PVC
From
7o
Ft.
in, in.
From
To
Ft,
in. in.
13. GRAVEL PACK:
Depth
Size Material
From 6.5
To 18.5
Fl.
Fine -Medium SAND
From
To
Ft.
14. REMARKS:
Depth DRILLING LOG
From To Formation Description
0 - 0.5 Topsoil
0.5 - 5.0 Clayey Silt
5.0 - 18.0 Silty Fine SAND
18.0 - 20.0 Partially Weathered Rock as
Silty Fine SAND
See Test Boring Records
If additional space is needed use back of form.
LOCATION SKETCH
(Show direction and distance from at least two State Roads,
or other map reference points)
it
l�
t�
I DO HEREBY CERTIFY THAT THIS WELL WAS CONSTRUCTED IN ACCORDANCE WITH 15 NCAC 2C, WELL CONSTRUCTION'
STANDARDS, AND THAT A COPY OF THIS RECORD HAS BEEN PROVIDED TO THE WELL OWNER.
SIGNATURE OF CONTRACTOR OR AGENT DATE
��^ ' ^ ,pro• Submit onoinal to Division of Environmental Management and copy to well owner.

KEY TO CLASSIFICATIONS AND SYMBOLS
ORRELATION OF PENETRATION RESISTANCE WITH
RELATIVE DENSITY AND CONSISTENCY -
NO. OF BLOWS, N
RELATIVE DENSITY
0 _ y
Very Loose
5 _ 10
LOOSE
SAN DS :1 - 20
= irc.
21 - 30
Very Firm
J1 _ 50
Dense
51.
Very Dense
Consistency*
0 - 1
Very Soft
2 _ y
Soft
SILTS AND CLAYS 5 _ g
Firm
9 _ 25
Stiff
16 - 30
Very Stiff
3--
Herd
SYMBOLS
I -UNDISTURBED SAMPLE (LID) RECOVERED
m -UNDISTURBED SAMPLE (UD) NOT RECOVERED
1DO 2'' -NUMBER OF BLOWS 000) ro DRIVE THE SPOON A NUMBER OF INCHES (2)
AX EX. NX -CORE BARREL SIZES WHICH OBTAIN CORES 1-1/E, 1-5/E AND 2-1/E INCHES IN
DIAMETER RESPECTIVELY
65% -PERCENTAGE (65) OF ROCK CORE RECOVERED
ROD -ROCK QUALITY DES IGNAT ION -%OF CORE SEGMENTS 4 OR MORE INCHES LONG
-WATER TABLE AT LEAST 2-9HOURS AFTER DRILLING
-WATER TABLE ONE HOUR OR LESS AFTER DRILLING
t -LOSS OF DRILLING WATER
Grout
L - Bentonite Seal
Screen Section
j_
OVM - Organic Vapor Measurement
PPM - Part Per Million
ND - Not Detected
DRILLING PROCEDURES
SOIL SAMPLING ANC PENCTR ATION TESTING PERFORMEC IN ACCORDANCE WITH ASTM. D i5b6-67.
HE STANDARD PENCT RATION RESISTANCE IS THE NUMBCR OF BLOWS OF A 1AD POUND HAMMER
ALLING 30 INCHES TO DRIVE A 2 INCH C.D.. 1.A INCH I.D. SPLIT SPOON SAMPLER ONE FOOT.
CORE DRILLING IN ACCORDANCE WITH ASTM. DESIGNATION C 2113-6ZT.
HE UNDISTURBED) SAMPLING PROCEDURE iS DESCRIBED EY ASTM SPECIFICATION D 15E7-67.

LEVATION DEPTH
Topsoil
1.0 Soft to stiff red -brown clayey SILT
TEST BORING RECORD
PENETRATION -BLOWS PER FOOT
nroii niero eu,r
5.0 Loose to very firm green -grey silty fine SAND
18.0 —
Loose to very firm grey -brown micaceous clayey
silty fine SAND
20.0
Partially weathered rock sampled as grey silty
SAND
Boring Terminated
0
r
11
REMARKS: DRILLED BY MA BORING NUMBER K65W6"F"
LOGGED BY MV DATE STARTED 9/18/90
CHECKED BY TB DATE COMPLETED 9/18/90
JOB NUMBER 56-9606.50
PAGE 1 OF 1 Law Environmental
5015"

i v
LAW ENVIRONMENTAL, INC.
112 TOWNPARK DRIVE
KENNESAW, GEORGIA 30144-5599
404-421-3400
October 2, 1990
Law Environmental, Inc.
431 Minuet Lane
Charlotte, NC 28217
Attention: Tom Beggs
LE Job Number: 56-9606.50
Subject: Chemical analyses of samples received on 09/26/90.
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.
If there are any questions, please do not hesitate to contact us.
Sincerely,
LAW ENVIRONMENTAL NA LABS
Clifford H. McBride
QC Coordinator
Attachment: Data Report
Invoice

LAW ENVIRONMENTAL NATIONAL LABORATORIES
TEST DATA REPORT
Date 10/01/90
Page 1
--- Project Information ---
.Lab Number : 90-6929-01
Project No. : 56-9606 Cust. No.
Project Name : SOUTHERN STATE FERTILIZER
Manager: TOM BEGGS
--- Sample Information ---
Station ID : K 65W 6 F Sampled Date/Time : 09/18/90 12:10
Matrix : SO Received Date/Time : 09/26/90 09:50
Type : GRAB Received From/By : MV/KP
Collector : MV Chain of Custody : 738
Number of Containers 1
Remarks
--- Test Data ---
Parameter .............................. Method.... Units PQL....... Results... Test Date Analy
-- INORGANIC CHEMISTRY RESULTS --
Moisture (Oven Dried @ 105C) EPA 160.3M °° 1 20 10/01/90 MS
Nitrogen, Nitrate MSA 84-3M mg/kg 0.1 ND 09/28/90 OR
Nitrogen, Nitrite MSA 84-3M mg/kg 0.1 ND 09/28/90 OR
Signed �7

LAW ENVIRONMENTAL NATIONAL LABORATORIES
TEST DATA REPORT
Date 10/01/90
Page 1
--- Project Information ---
Lab Number 90-6929-02
Project No. 56-9606 Cust. No.
Project Name SOUTHERN STATE FERTILIZER
Manager: TOM BEGGS
--- Sample Information ---
Station ID K 65W 6 F Sampled Date/Time 09/25/90 11:00
Matrix W Received Date/Time 09/26/90 09:50
Type GRAB Received From/By DT/KP
Collector DT Chain of Custody 738
Number of Containers 2
Remarks
--- Test Data ---
Parameter .............................. Method.... Units PQL....... Results... Test Date Analy
-- INORGANIC CHEMISTRY RESULTS --
Nitrogen, Nitrate EPA 353.2 mg/l 0.05 0.14 09/28/90 OR
Nitrogen, Nitrite EPA 353.2 mg/l 0.05 ND 09/28/90 OR
Signed/(J��

LAW ENVIRONMENTAL, INC. CHAIN OF CUSTODY RECORD
�. NATIONAL LABORATORY
0738
® _ = 112 TOWN PARK DRIVE
T KENNESAW, GEORGIA 30144
v [phone] J
90.6G�� _ V /
SAMPLING NAME OF FACILITY:
INFORMATION
STREET ADDRESS:
CITY / STATE: ZIP:
PROJECT NAME
>ov'tl, cci b S 14�E �'E2 EY 1' z62
JOB NO.
5 cv '- 4 <, o (o
o �
z ¢
1z:
oc-)
Qcv P��,
��, ��° ao��
�`QN,� PZXQ43o`a�e?
ero �� Doti' aoti' Apo �� • ? ? .� ' Doti' �yo �� .
SAMPLERS (SIGNATURE)
CA
SAMPLING TE
cl - 15 -- ot Oco
TIME
:
o
'SOURCE
CODE
SAMPLE STATION DESCRIPTION
LENL LAB NO.
I2:10
5�
K Gg w G ��F122
RELINQUISHED BY:
(SIGNATU E)
DATE / TIME
y
RECEIVED BY:
DATE /TIME
RELINQUISHED BY:
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LAW ENVIRONMENTAL, INC.
�0 431 MINUET LANE
CHARLOTTE, NORTH CAROLINA 28217
I
TO: NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT, HEALTH AND NATURAL
RESOURCES
919 NORTH MAIN STREET
LMOORESVILLE, NC 28115
DATE
SEPTEMBER 3 1991
JOB NO.
56-1570.90
PROJECT NAME:
SOUTHERN STATES
FERTILIZER PLANT
ATTENTION:
MS. CHRISTINE M.
DEROLLER
RE:
REMEDIAL ACTION
WORK PLAN
SOUTHERN STATES
FERTILIZER PLANT
STATESVILLE, NORTH CAROLINA
LETTER OF TRANSMITTAL
GENTLEMEN: WE ARE SENDING YOU N Attached ❑ Under separate cover via the following items:
❑ Shop drawings ❑ Prints ❑ Plans ❑ Samples ❑ Specifications
❑ Copy of letter ❑ Change order $1
IF ENCLOSURES ARE NOT AS NOTED. KINDLY NOTIFY US AT ONCE.
COPIES
DATE
NO.
DESCRIPTION
1
8/29/91
----
REMEDIAL ACTION WORK PLAN
SOUTHERN STATES FERTILIZER PLANT
STATESVILLE, NORTH CAROLINA
(REFERENCE DEM INCIDENT #5083)
I
e.- Tr, J�.. .11..Tr,T•
THESE ARE TRANSMITTED as checked below:>P�13jg.j , >- `'
❑ For approval ❑ Approved as submitted 0-Resubmit copies for approval
X For your use ❑ Approved as noted %J ` ❑ Submit copies for distribution
L<A
❑ As requested El Returned for corrections type g�;?F;i�;Return .tJy corrected prints
❑ For review and comment ❑ pal
❑ FOR BIDS DUE 19 ❑ PRINTS RETURNED AFTER LOAN TO. US
REMARKS MS. DEROLLER
PAGE 15 OF OUR AUGUST 29, 1991 REMEDIAL ACTION PLAN WAS INADVERTENTLY
OMITTED FROM THE COPY SUBMITTED TO YOUR OFFICE. PLEASE ACCEPT THE ATTACHED
COMPLETE DOCUMENT WITH OUR APOLOGIES.
COPY TO MR. HILTON WITHERS
-14�'-_
SOUTHERN STATES COOPERATIVE Signed:
ORIGINAL THOMAS F. BEGGS, P.E.

Prepared for:
Southern States Cooperative, Inc.
Richmond, Virginia
Law Environmental, Inc.
Charlotte, North Carolina
August 29, 1991
LEI Job No. 56-1570.90

TABLE OF CONTENTS
PAGE
1.0 INTRODUCTION ........................................ 1
2.0 SITE BACKGROUND INFORMATION .......................... 2
2.1 Facility Information .................................. 2
2.2 Ground Water Issues .................................. 3
3.0 WORK PLAN - RAP PREPARATION. ...........................
6
3.1
RAP Objectives .....................................
6
3.2
Additional Data Collection ..............................
6
3.2.1
Aquifer Hydrogeological Characterization ...............
6
3.2.1.1 Test Well Installation ....................
8
3.2.1.2 Aquifer Performance Test .................
10
3.2.1.3 Analysis of Aquifer Test Data ...............
13
3.2.1.4 Aquifer Performance Test Report .... ........
13
3.2.2
,
Off -site Downgradient Well Installation ................
14
3.3
Conceptual Design Development . . . . . . . . . . . . . . . . . . . . . . . . . . .
14
3.3.1
Hydraulic Control System . . . . . . . . . . . . . . . . . . . . . . . . .
15
3.3.2
Ground Water Treatment/Discharge System .............
15
3.4
Detailed Design .....................................
16
3.4.1
Construction Details .............................
17
3.4.2
Operating Characteristics and Performance Standards ......
17
3.4.3
Permits and Approvals ...........................
18
3.5
Monitoring ........................................
18
3.5.1
Ground Water Monitoring . . . . . . . . . . . . . . . . . . . . . . . .
18
3.5.2
Remedial Action System Re-evaluation .................
18
4.0 SCHEDULE............................................19

REMEDIAL ACTION WORK PLAN
SOUTHERN STATES FERTILIZER PLANT
STATESVILLE, NORTH CAROLINA
1.0 INTRODUCTION
This document presents a work plan for the development of the conceptual and
detailed design of the ground water remedial action system at the Southern States
Cooperative, Inc. (Southern States) Fertilizer Plant in Statesville, North Carolina.
The remedial action system developed as a result of the execution of this plan will
be presented to North Carolina Department of Environment, Health, and Natural
Resources (NCDEHNR) for review and approval as a remedial action plan (RAP).
Background information regarding the site is presented in Section 2.0 of this
document. The work plan for the preparation of the RAP is presented in
Section 3.0. The objectives are presented in Section 3.1. The tasks associated
with design of the remedial action system are presented in Sections 3.2 through
3.4. These tasks include 1) the collection of additional data necessary to
complete the conceptual and final design; 2) the development of the conceptual
design, which includes the evaluation of the hydrogeological data and the selection
of the system to provide appropriate hydraulic control over the site, and the
selection of the most appropriate method for disposing of ground water generated
by the hydraulic control system; and 3) the detailed design, which includes the
engineering and planning necessary for the construction and operation of the
remedial action system. The preliminary long-term monitoring plan is discussed in
Section 3.5. A schedule for the preparation of the RAP is presented in Section
4.0.

2
2.0 SITE BACKGROUND INFORMATION
2.1 Facility Information
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
195Os. Southern States purchased the plant from W. R. Grace & Co. in February
1988.
Various farm and garden fertilizers are manufactured at the plant using raw
materials brought in by truck and rail. The materials are usually off-loaded directly
onto conveyor belts for transfer to storage areas within the plant.
Finished products are warehoused on -site pending shipment. Small warehouse
areas at the north end of the main plant and in a small building just east of the
main plant are also used to store pre -mixed, bagged products on pallets. These
products are sold directly to consumers without modification by Southern States.
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 smokestack 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.
U,AV19M.7"

3
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.
2.2 Ground Water Issues
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/I 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 (LEI Job No. 56-9606.40). Additional ground water
assessment was recommended.
On May 4, 1990, the NCDEHNR issued a letter to Southern States. The letter
indicated that the NCDEHNR Mooresville Regional Office had reviewed the "Phase
Ground -Water Assessment Report" for the Statesville Southern States Fertilizer
Plant. The letter stated that NCDEHNR was in agreement with Law Environmental
9W: s.Tao

4
concerning the need for further assessment activities. NCDEHNR indicated that
these activities should be designed to define more fully the vertical and horizontal
extent of nitrate/nitrite as nitrogen concentration.
A June 15, 1990 submittal was prepared by Law Environmental to respond to the
May 4, 1990 letter from NCDEHNR. The submittal contained a proposed Phase II
ground water assessment work plan designed to address the issues raised by
NCDEHNR.
i
The Phase II ground water assessment activities were completed and a "Phase II
Ground -Water Assessment Report" was submitted to NCDEHNR on September 25,
1990.
Analytical results from Phase II analyses indicated that subsurface nitrate/nitrite as
nitrogen 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 II report
submittal, neither the horizontal nor vertical extent of nitrate/nitrite as nitrogen had
been adequately 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/nitrite as nitrogen concentrations. The results of the laboratory analysis of
the ground water indicated a nitrate/nitrite level as nitrogen significantly below the
NCDEHNR threshold value. These results were submitted to NCDEHNR on
November 19, 1990.

5
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 Remedial Action
Plan 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 (revised deadline: August
30, 1991). This extension was confirmed by a letter from Law Environmental
dated July 12, 1991. The NCDEHNR also agreed that the submittal should present
a work plan outlining the steps necessary for the preparation and submittal of a
RAP.
The above -referenced work plan for the preparation of a RAP addressing the
ground water issues at the site is presented in Section 3.
U4:LS7UrMT*

0
3.0 WORK PLAN - RAP PREPARATION
3.1 RAP Objectives
The overall objectives directing the investigation and remedial activities at the
Statesville Site are to develop and implement a technically and economically
practical approach to insure that the public health and environment are protected
from adverse affects from ground water which may have been impacted by
nitrate/nitrite as nitrogen.
More specifically, the objectives of the RAP are to minimize or prevent the off -site
migration of ground water impacted with nitrate or nitrite as nitrogen at levels
exceeding 10 parts per million (ppm) and 1 ppm, respectively.
The conceptual design work, outlined in Section 3.3, is intended to evaluate the
full range of remedial alternatives, and identify the approach that best meets the
objective stated above.
3.2 Additional Data Collection
Additional site characterizartion data are required to develop the conceptual design
properly. The required data and the plans for its collection are discussed below.
3.2.1 Aquifer Hydrogeological Characterization
The purpose of the work described in this section will be to provide the aquifer
characteristics necessary for the design of a ground water recovery system to
intercept potential off -site migration of constituents previously identified at the
site.
1 tMARU 96
i
l
r

The scope of work included within the aquifer performance test program will
include the installation of three test wells in the vicinity of the property boundary,
downgradient from the on -site ponds. Upon completion of the installation and
development of these test wells, composite water samples will be collected from
each test well for laboratory analysis for nitrate and nitrite as nitrogen. The well
exhibiting the highest concentrations of nitrate/nitrite as nitrogen will be selected
as the aquifer performance test well. The other two test wells will be used as
observation wells to monitor the aquifer performance during the pumping test on
the selected test well. The combination of both the aquifer performance test data
and previously collected field data will provide the information necessary to design
the ground water recovery system.
The aquifer performance testing program will be performed in six stages:
1. Install three test wells and collect composite water samples;
2. Conduct packer tests on the selected test well;
3. Grout test wells to final completion depth;
4. Perform aquifer test and collect water quality samples;
5. Analyze aquifer performance test results;
6. Prepare aquifer performance test report.

R]
3.2. 1.1 Test Well Installation
The location of the three test wells will be in the vicinity of the southern property
boundary of the Southern States Facility. The locations of these three test wells
are shown on Figure 1. Each test well will be drilled in stages as outlined below.
Both the unsaturated zone and the partially weathered rock will be cased off, and
an open hole will be drilled into the bedrock. Each test well will be constructed as
follows:
Drill 10-inch-diameter open hole to top of rock (protective casing will be
used as needed to prevent borehole collapse);
2. Install six -inch -diameter steel casing to top of bedrock;
3. Drill six -inch -diameter open hole into bedrock to an approximate
elevation of 630 feet above mean sea level, using air hammer drilling;
4. Collect one composite sample of ground water from the test well for
laboratory analysis;
5. Run packer tests in the open rock hole of the selected test
Well which exhibits the highest ground water concentrations
of nitrate/nitrite as nitrogen;
6. Grout the open rock hole of the selected test well to the final
completion depth based on the results of the packer tests.
Wj:1"VrMTft

P1
A 10-inch-diameter open hole will be drilled by rotary air hammer to the top of
bedrock (approximate depth of 50 feet below ground surface). Approximately 50
feet of six -inch -diameter steel casing will be assembled and lowered into the open
hole. Centralizers will be attached to the bottom of the casing prior to lowering
the assembled casing into the open hole. The annular space above the top of
bedrock will be filled with cement grout from bottom to top.
After the casing has been set and the grout cured, the six -inch -diameter open hole
will be drilled using air -hammer methods down to an elevation of approximately
630 feet above mean sea level. The test well will be developed prior to collecting
a composite water sample fromthe well. The composite sample of ground water
from each test well will be submitted to a laboratory for a 24-hour-turnaround
analysis of nitrate and nitrite as nitrogen. The results of these laboratory analyses
Will'be used to identify the test well containing the highest total concentration of
nitrate and nitrite as nitrogen. This test well will be selected as the discharge well
for the proposed aquifer performance test. In addition, dual purpose packer tests
will also be performed on the selected test well. The first set of packer tests will
be to pump out ground water from each packer test zone for laboratory analysis of
nitrate and nitrite as nitrogen. This will provide information on the vertical extent
of nitrate and nitrite as nitrogen concentrations within the bedrock fractures. The
second set of tests on the selected test well will be hydraulic conductivity packer
tests. This series of tests will provide information on the yield capacity of the
bedrock fractures within the test well. All ground water generated dur ing the well
development and packer testing will be collected and/or disposed of in the same
manner as the aquifer performance test water, discussed in Section 3.2.1.2.
WJ:U70TMT"

10
The results of the packer testing will be used to provide the basis for selecting the
final depth of the open hole in each of the three test wells. The open holes in each
of the test wells may be plugged with a mix of cement grout and bentonite up to
the depth established from the results of the packer testing. The selected test well
is now,ready for the aquifer performance test as described in Section 3.2.1.2.
The test program described in Section 3.2.1.2 has been developed to obtain the
aquifer characteristics of the bedrock formation along the southern property
boundary of the site. To obtain additional information about the geophysical
characteristics of the partially weathered rock and near surface soils overlying the
bedrock formation, soil samples from the saturated subsurface strata will be
obtained during installation of the test wells. However, the test wells will be
installed using -air rotary drilling techniques, which makes sample retrieval difficult.
Consequently, a geotechnical test boring rig will be mobilized to the site for the
purpose of obtaining the soil samples. Hydraulic conductivity of the soil and
weathered rock will be estimated based on grain size analysis of the soil samples.
This information will be important in developing the final ground water recovery
system for the site.
3.2.1.2 Aouifer Performance Test
The effects of pumping from the selected test well on water levels in both the
partially weathered rock and bedrock in the vicinity of the test well will be
monitored within the other two new wells (now observation wells) and other
selected existing monitoring wells. The existing monitoring wells anticipated for
use during the aquifer performance test include K65W7"An, K65W7"B",
K65W7"C", K65W7"D-, K65W7-E-, K65W7-F-, K65W7-G-, K65W7-H-,
K65W7"1", and K65W6"D". The approximate locations of the
observation/monitoring wells are shown on Figure 1.
dj:07UrMTM

11
The response of the water levels in the bedrock will be monitored in both of the
new deep observation wells during the proposed aquifer performance test. The
partially weathered rock unit overlying the bedrockwill be monitored by existing
monitoring wells. However, the locations of these existing monitoring wells will be
reviewed with respect to the location of the test well selected for pumping during
the aquifer performance test. This review will be based on the need for field data
that can be collected during the proposed aquifer performance test.
An eight -hour step drawdown test will be conducted on the test well prior to the
aquifer performance test for the purpose of assessing the withdrawal rate for the
test. The anticipated constant withdrawal rate for the aquifer performance test is
expected to be approximately five gallons per minute.
A submersible pump will be used to withdraw water from the test well. In each of
the observation wells, the test well, and selected shallow monitoring wells,
pressure transducers will be installed for measuring the changes in the piezometric
heads during the aquifer performance test. Periodic water level calibration checks
will be performed using the wetted tape method.
The aquifer test is expected to continue until sufficient drawdown data are
obtained at selected observation and monitoring wells, and the test well. Test
data sufficiency will be determined by matching draWdown versus time plots for
the wells with selected type curves. The expected duration of the aquifer
performance test is approximately one day. However, this duration may be
changed depending on the observed drawdowns.
A suitable flow -measuring device, capable of low -flow measurements, will be
installed on the pump discharge line for the duration of the aquifer performance
test.
WJ:U7M7Z.TW

HK
During the aquifer test, water quality samples will be collected at 12-hour intervals
from the discharge stream. These water quality samples will be collected in
laboratory- prepared sample bottles. The samples will be stored in suitable
refrigerated receptacles prior to shipping to an approved laboratory for analysis.
The samples will be used to assess the treatability of the discharge water and will
be analyzed for the following parameters:
• pH;
• conductivity;
• nitrite as nitrogen;
• nitrate as nitrogen.
All ground water generated during the aquifer performance test will be collected for
disposal following completion of the test. The water will either be discharged
through the permitted spray irrigation system (currently being used to dewater the
ponds) or collected and contained for use as process water in the manufacturing
process.
A temporary tank will be staged in the area of the three test well locations for
containment of well development and sample purge water. If needed, an additional
tank will be staged at the location of the test well chosen for the pump test to
contain the step drawdown and pump test water. The water will either be pumped
directly from the holding tanks for discharge through the spray irrigation system, or
pumped into a tanker truck for transfer to additional holding tanks staged near the
manufacturing facility.
Uj,.LFMrMT"

13
3.2-1.3 Analysis of-Aguifer Test Data
The drawdown versus time data from the aquifer performance test will be plotted
and analyzed for type curve matching. The aquifer characteristics determined for
the observation wells will be compared to assess the degree of homogeneity and
anisotropy within the partially weathered rock and bedrock underlying the test site.
The effect of the withdrawal from the test well on the water levels in both the
partially weathered rock (PWR) and bedrock will be evaluated from the drawdown
versus time data collected from each of the observation and monitoring wells.
The data will be reviewed in the context of the results of the packer testing
described in Section 3.2.1.1. The results of the analysis of the aquifer
performance test data will assist in evaluating the potential for assuming that the
bedrock is equivalent to a porous medium. This assumption is important in terms
of the methodologies selected for the analysis of the aquifer performance test data.
The results of the water quality analyses will be reviewed for nitrate and nitrite as
nitrogen concentrations and time -dependent changes in concentrations. The data
will also be reviewed for changes in the ratios of constituent levels during the
aquifer performance test and any other changes that can be identified.
3.2.1.4 Aguifer Performance Test Regort
A report will be written which will describe the results of the work elements
outlined above. Details of the test wells will be provided, and the results of both
the aquifer performance test and the water quality analyses will be included in the
report. The procedures used to analyze the results of the field work will also be
described. The results of the aquifer performance test will ultimately be used to
design the ground water recovery/interception system for the Southern. States Site.
*J.97ffM'r"

14
3.2.2 Off -site Downgradient Well Instaligtign
An off -site monitoring well will be installed south of the creek (downgradient of the
site). Sampling and analytical results from this well will confirm the presence or
absence of off -site downgradient nitrate/nitrite as nitrogen migration. In addition,
the well will serve as a monitoring well to be used in the remedial action system
monitoring and evaluation program, discussed in Section 3.5. The well will be
installed into bedrock with a screen interval depth of approximately 150 to 160
feet below grade. The approximate location of the off -site monitoring well is
shown on Figure I -
The off -site well cannot be installed at the proposed location without permission
from the property owner. Should permission be obtained and the well installed
prior to the aquifer performance test, this well would also be used as an
observation well to monitor downgradient drawdown effect during the pumping
test.
3.3 Concel2tual Design Develol2ment
The objectives of the conceptual design phase of the work plan are to evaluate the
technical and economic feasiblity of the various remedial approaches, to identify
the most appropriate remedial approach, and to identify technical issues requiring
further consideration during the detailed design phase. The conceptual design
development can be broken down into two separate but related areas: the
hydraulic control system and the ground water treatment/discharge system. These
two areas are discussed below.
*J:157UMT"

15
3.3.1 Hydraulic Control System,
As indicated in Section 3.1, the objective of the remedial action system is to
prevent the off -site migration of nitrate/nitrite as nitrogen -impacted ground water in
concentrations exceeding state -accepted levels. It is assumed that hydraulic
control will be achieved by installing and operating ground water pumping wells.
The approximate location and flow rate of the pumping wells will be specified in
the conceptual design phase.
The specification of the appropriate well locations and flow rates will be based on
the hydraulic characterization of the aquifer. The hydraulic characterization of the
aquifer will be quantified based on data collected during the pump test, and will
include the development of the relationship between the pumping rate for a given
well, the resulting drawdown of the ground water, and the associated radius of
influence.
It is anticipated that several hydraulic control pumping scenarios will be evaluated
during the conceptual design phase. These scenarios include a series of
interceptor wells located along the downgradient edge of the property, source
wells located near the center of the plume, and a combination of the interceptor
well and source well approaches.
3.3.2 Ground Water Treatment/Dischar-ge System
The selection of the appropriate ground water treatment/discharge system
(treatment system) will be driven by the hydraulic control system conceptual
design, i.e., the flow rate and anticipated nitrate/nitrite as nitrogen concentration
of produced water. A number of treatment system approaches will be considered,
including the following:
tkj.-1570M.TM

ff �-
0 Spray irrigation;
0 Internal consumption of produced water in the plant;
Discharge to publicly owned treatment works (POTW);
Discharge to creek without treatment under a National Pollutant
Discharge Elimination System (NPDES) permit;
Discharge to creek under a NPDES permit following biological
denitrification.
Combinations of the above systems will also be considered.
Specific performance criteria (discharge limits) will be developed for the selected
treatment system.
3.4 Detai ed Design
The detailed engineering work necessary to construct and operate the remedial
action system will be completed during the detailed design phase. This engineering
work will address all of the applicable technical issues, and will include the
following:
0 - Hydrogeological engineering (detailed well design);
0 Process/chemical engineering (treatment system design);
Civil and mechanical engineering (structural engineering, foundation
design, water gathering and discharge system design, etc.);
tW:WXrMTM

17
0 Electrical engineering (process control and instrumentation system
design).
3.4.1 CQnstruction Details
The construction detalls.will be comprised of a set of construction drawings and a
set of equipment specifications.
The construction drawings are expected to include the following:
• Pumping well details;
• Pumping well locations;
• Ground water gathering and discharge system piping details;
• Treatment system piping and instrumentation diagram;
0- Control schematic diagram (electrical "ladder" diagram);
0 - Equipment layout plan;
0- Trenching and foundation plans.
It is expected that major pieces of equipment will be completely specified during
the detailed design phase. Therefore, the equipment specifications will consist of
product literature and specifications from the chosen equipment suppliers.
3.4.2 012eraling Characteristics and Perfamance Standards
The operating characteristics and performance standards will be presented in the
form of a flow sheet and material balance showing the wells, treatment equipment,
lines, flow rates, anticipated nitrate/nitrite as nitrogen concentrations, and key
operating temperatures and pressures.
WJ:U7UM.TM

18
.4.3 Permits and ADDrov
Upon completion of the conceptual design, the required permits and approvals will
be identified. The types of permits that may be required include water discharge
permit (i.e., NPDES permit), drilling permits, and state, county, and local
construction permits. It is not anticipated that an air permit will be required.
Monitori
The purpose of the monitoring program is to evaluate the performance of the
remedial action system with respect to the objectives stated in Section 3.1. The
monitoring program will be comprised of two elements, an on -going ground water
monitoring program and a remedial action system re -appraisal.
3.5.1 Ground Water Monitorina
An on -going ground water monitoring plan will be developed to confirm the
performance of the remedial action system. The plan will specify the sample
locations, sampling frequency, and analytical protocols.
3.5.2 Remedial Action System Re-evaluation
The RAP will also specify that a formal re-evaluation of the remedial action be
performed. It is anticipated that the re-evaluation will be performed approximately
one year after startup of the system.
UJ:LWWM.Tn

19
4.0 SCHEDULE
A schedule showing the above identified tasks is presented as Figure 2.
do:MUM.T"

GROUND WATER REMEDIATION PROJECT
SOUTHERN STATES FERTILIZER PLANT
STATESVILLE, NORTH CAROLINA
Project Task
start
Aug
III
Sep I Oct Nov
HIIIIII
Doc Jan
Feb
Mar Apr May
Jun Jul
Aug
I WORK PLAN PREPARATION
8/12/91
W!"I
1.1 REVIEW DRAFT
8/12/91
2w
m
1.2 REVISE AND FINALIZE
8/26/91
1w 11111
1.3 SUBMITTAL TO STATE
8/30/91
4
8/30
2 INSTALL OFF -SITE MONITORING WELL
8/12/91
2.1 NEGOTIATIONS WITH LAND OWNER (SEE NOTE 1)
8/12/91
1:jw
22 FIELD ACTIVITIES
11/4/91
2w
M
2.3 WELL SAMPLING AND ANALYSIS
11/18/91
2w =1
2.4 DOCUMENT RESULTS
12/2/91
1w
N
2.5 REVIEW AND FINALIZE
12/9/91
2w
2.6 SUBMIT TO STATE
12/20/91
'2/20
3 AQUIFER PUMP TEST
8/12/91
3.1 REVIEW / FINALIZE PLAN
8/12/91
3.2 PREPARATION / MOBILIZATION
9/9/91
3w
3.3 FIELD ACTIVITIES
9/30/91
SW
3.4 PREPARE DRAFT REPORT
11/4/91
SW
3.5 REVIEW
12/9/91
1/16
3.6 INTERNAL MEETING TO DISCUSS PUMP TEST RESULTS
12/16/91
3.7 REVISE AND FINALIZE
12/23/91
1w
3.8 SUBMITTAL TO STATE
12/30/91
12/30
PrePaired For. Soluffilem Stdes Cooperafte Inc.
Date: 8/27/91
Project Number: 91-1,61-02
Individual Task Summary Task Milestone
Bold numbers left of bars repesent durations of tasks (w - weeks).

GROUND WATER REMEDIATION PROJECT
SOUTHERN STATES FERTILIZER PLANT
STATESVILLE, NORTH CAROLINA
Project Task
Start
Aug
Sep Oct Nov
Doc Jan
Fab
Mar Apr May
Jun Jul
Aug
4 HYDRAULIC CONTROL
12/9/91
4.1 EVALUATION OF PUMPING OPTIONS
12/9/91.
3w
4.2 INTERNAL MEETING TO DISCUSS HYDRAULIC CONTROL OPTIONS
12/16/91
1
/16
4.3 DOCUMENT EVALUATION / RECOMMEND, PUMPING CONFIGURATION.
12/23/91
2w
' GROUND WATER TREATMENT / DISPOSAL
8/12/91
5.1 OBTAIN TREATMENT TECHNOLOGY BACKGROUND INFORMATION
8/12/91
5.2 EVALUATION OF TREATMENT / DISPOSAL OPTIONS
12/23/91
3w mm
5.3 DOCUMENT EVALUATION AND RECOMMEND TREATMENT SYSTEM
1/7/92
2w
6 FINALIZE CONCEPTUAL DESIGN
1/21/92
6.1 PREPARE PROCESS FLOW SHEET AND MATERIAL BALANCE
1/21/92
2w
6.2 SPECIFY KEY OPERATING AND PERFORMING PARAMETERS
1/21/92
2w
8.3 DEVELOP BUDGETARY CONSTRUCTION COST ESTIMATE
1/21/92
3W
6.4, REVIEW CONCEPTUAL DESIGN
2/11/92
2�w
6.5 INTERNAL MEETING TO DISCUSS AND FINALIZE CONCEPTUAL DESIGN
2/24/92
2/24
6.6 SUBMITTAL OF CONCEPTUAL DESIGN TO STATE
3/6/92
3/6
6.7 MEETING WITH STATE TO DISCUSS CONCEPTUAL DESIG N
3/30/92
3/30
ftepamd f%r: Soutlwn StwW Cooperative Inc.
Date: 8/27/91
Project Number: 91-161-02
Individual Task Summary Task Milestone
Bold numbers left of bars repesent durations of tasks (w - weeks).

GROUND WATER REMEDIATION PROJECT
SOUTHERN STATES FERTILIZER PLANT
STATESVILLE,. NORTH CAROLINA
Project Task
Start
Aug
So Oct Nov
000 Jan
Feb
Mar Apr May
Jun Jul
Aug
7 DETAILED DESIGN
2/11/92
7.1 PROCESS, MECHANICAL, ELECTRICAL ENGINEERING
3/31/92
3W
7.2 PREPARE CONSTRUCTION DRAWINGS
4/14/92
7.3 PREPARE EQUIPMENT SPECIFICATIONS
4/14/92
iw
7.4 PROCURE VENDOR / SUBCONTRACTOR PROPOSALS
4/21/92
3W
7.5 IDENTIFY REQUIRED PERMITS / APPROVALS
2/11/92
2W
7.6 UPDATE CONSTRUCTION COST ESTIMATE
5/5/92
2W
7.7 REVIEW AND FINALIZE DETAILED DESIGN
5/19/92
2W
8 DEVELOP MONITORING PROGRAM
2/11/92
a. I DOCUMENT PROPOSED PROGRAM
2/11/92
2W
8.2 REVIEW AND FINALIZE PROGRAM
3/31/92
2W
9 REMEDIAL ACTION PLAN
5/19/92
9.1 PREPARE DRAFT
5/19/92
sw mo6mm
9.2 REVIEW DRAFT
6/23/92
2W
9.3 INTERNAL MEETING TO DISCUSS REMEDIAL ACTION PLAN
6/30/92
6/30
9.4 MAKE REVISIONS
7/7/92
1 W,
N
9.5 SUBMrrTAL TO STATE
7/13/92
Notes:
1. Off -site monitoring well installation is contingent upon permission from the land owner to access the property.
Negotiations with the land owner may impact this schedule, including successive activities.
Prepared For: Souftwn Stat . as CooperaUve Im
Date: 8/27/91
Project Number: 91-161-02
Individual Task Summary Task Milestone
Sold numbers left of bars repasent durations of tasks (w - weeks).

LAW ENVIRONMENTAL, INC.
431 MINUET LANE
CHARLOTTE, NORTH CAROLINA 28217
P.O. BOX 240674
CHARLOTTE, NORTH CAROLINA 28224-0674
704-527-6717
March 29, 1990
Southern States Cooperative, Inc.
P.O. Box 26234
Richmond, VA 23260
Attention: Mr. Hilton M. Withers
Manager, Environmental Affairs
Subject: Report of Phase I Ground -Water Assessnent
Southern States Fertilizer Plant
Statesville, North Carolina
LEI Job No. 56-9606.40
Gentlemen:
As authorized by your acceptance of our Proposal No. 56-9116B dated
January 23, 1990, Law Environmental, Inc. has completed initial
ground -water assessment activities at the Southern States
Fertilizer Plant in Statesville, NC. The purpose of our work was
to provide a response to a Notice of Violation for the site issued
December 12, 1989 by the North Carolina Department of Environment,
Health, and Natural Resources (NCDEHNR). This report summarizes
our understanding of the background information, our field
investigation procedures and laboratory testing, and our data
interpretation and recommendations.
In summary! concentrations of nitrate/nitri-L--e ground -water
contamination were encountered in each of the six newly constructed
4
monitoring wells on site. The results appeared to verify
preliminary laboratory results obtained by NCDEHNR. Based on these
initial findings, Law Environmental proposes additional
investigative activities to more clearl�7 define the horizontal and
vertical extent of contamination. Detailed information regarding
our findings and recommendations is presented herein.

Southern States Cooperative, Inc.
March 29, 1990
Page 2
Law Environmental appreciates the opportunity to provide our
professional consulting services on this phase of the project. If
you have any questions regarding this report please feel free to
contact us.
Sincerely,
LAW ENVIRONMENTAL, INC.
Bernard B. Schumak
Project Hydrogeologist
Thomas F. Beggs,.P.E.
Principal Engineer
P. E.
Jimmy N. S ith,
Assistant Vice President
Charlotte Services Manager
BBS:TFB:JNS:sdy
Attachments

TABLE OF CONTENTS
Pt'%GE
1.0 PROJECT INFORMATION ............................... 1-1
1.1 Background Summary ........................... 1-1
1.2 Notice of Violation .......................... 1-2
2.0 ASSESSMENT ACTIVITIES ............................. 2-1
2.1 Soil Test Borings ............................ 2-1
2.2 Monitoring Well Installations ................ 2-2
2.3 Ground -Water sampling ........................ 2-4
3.0 SUBSURFACE CONDITIONS ............................. 3-1
4.0 RESULTS OF CHEMICAL ANALYSES ...................... 4-1
5.0 DATA ANALYSIS AND INTERPRETATION .................. 5-1
6.0 RECOMMENDATIONS ................................... 6-1
TABLES
FIGURES
APPENDIX A - TEST BORING RECORDS
GROUND -WATER MONITORING WELL INSTALLATION RECORDS
LABORATORY TEST DATA REPORTS

1.0 PROJECT INFORMATIOY
1.1 Background Summary
The Southern States Fertilizer Plant is located on U.S. Highway 70
approximately six miles east of Statesville, North Carolina (see
Figure 1) . We understand that the facility was constructed in the
1950's. Southern States Cooperative, Inc. purchased the plant from
W. R. Grace & Co. in February, 1988.
Various farm and garden fertilizers are manufactured at the plant
using raw materials brought in by truck and rail. The materials
are usually off-loaded directly onto conveyor belts for transfer
to storage areas within the plant.
Finished products are normally warehoused on site. Small warehouse
areas at the north end of the main plant and in a small building
just east of the main plant are used to store pre -mixed, bagged
products on pallets. These products are sold direct to consumers
without modification by Southern States.
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
1-1
I

smokestack emissions. The scrubbers use a "wet-11 system which takes
up all excess process water in the plant.
Prior to scrubber installation approximately ten years ago, excess
process water was reportedly discharged into holding ponds on site.
Two of the former holding ponds are extant approximately 1,000 ft
southwest of the plant. A third former holding pond. was reportedly
closed approximately five years ago. This pond was smaller than
the other two and was located 300 ft southeast of the plant.
A general site location plan is presented in the attached Figure
1. Site topography and specific features are presented in Figures
2 and 3.
1.2 Notice of Violation
Southern States cooperative retained Law Environmental in
4
September, 1989 to assist with evaluation and remed.J-ation efforts
at the Statesville Fertilizer Plant. On December 12, 1989, the
North Carolina Department of Environment, Health and Natural
Resources (NCDEHNR' issued a Notice of Violation for the site.
The notice (received by Southern States on December 20, 1989),
stated that excessive concentrations of nitrate and/or nitrite had
been discovered in two NCDEHNR wells at the site. Combined
nitrate/nitrite concentrations were greater than the threshold
value of 11 mg/1 set forth in Title 15, Subchapter 2L, Section
1-2

.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 within 60 days.
On January 19, 1990, representatives of Southern States Cooperative
and Law Environmental met with Messrs. Jesse Wells- and jef f Lautier
at the NCDEHNR Mooresville office. -It was agreed that Law
Environmental would construct six ground -water monitoring wells at
the site. Two of the wells would be extended to bedrock (defined
as auger refusal) and four would be shallow monitoring wells
intended to address the lateral extent of contamination. (Please
refer to Law Environmental's February 5, 1990 letter outlining the
proposed field work.) Well installation was conducted during the
period of January 30 through February 7, 1990.
This'report is intended to address the Sp,-Cj-fiC items set forth in
the NCDEHNR Notice of Violation. We understand that a report
submittal date extension was granted by NCDEHNR based on an
extension request issued by Southern States on February 15, 1990.
The extension established a new report submittal deadline of April
20, 1990.
Our understanding of the plant procedures and processes is based
on our discussions with Southern States personnel. We have also.
been furnished with general site topography plans. We have not
1-3

conducted a detailed review of plant records or process equipnent
specifications.
1-4

2.0 ASSESSMENI'ACTIVITIES
2.1 Soil Test Borings
Six soil test borings were drilled at the approximate locations
shown in the attached Figure 2. Law borings K65W611AII, K65W6-IB-1,
and K65W611CII were situated near existing NCDEHNR boring K65W6.
Similarly, Law Borings K65W7 "All through IICII were located near
existing NCDEHNR boring K65W7. The borings were positioned such
that they would provide additional information regarding ground-
water contour elevations and contaminant plume concentrations.
The borings were drilled by mechanically advanced, hollow -stem
steel augers. Soil sampling and penetration testing were performed
in general accordance with ASTM D 11586. At regular intervals, soil
samples were obtained with a standard 1.4-inch I.D., 2-inch O.D.,
split -tube sampler. The sampler was first seated.6 inches to
penetrate any loose cuttings, and then driven an additional 12
inches with blows of a 140-pound hammer falling 30 inches. The
number of blows required to drive the sampler the final 12 inches
was recorded and is designated the "penetration resistance".
Representative portions of the soil samples, thus obtained, were
examined by an engineer in the laboratory to verify the driller's
field classifications.* Test Boring Records are included in
2-1

Appendix A, showing the soil descriptions and penetration
resistances.
2.2 Mon1toring Well Installation
Six ground -water monitoring wells were completed at the subject
site. These wells were installed at the locations of the six soil
zest borings mentioned previously. The new wells were designated
K65W611AII, K65W611B11, K65WOCII, K65W711A--, K65W7-1B11 and K65W711C11.
Each well consisted of 2-inch diameter schedule 40 PVC pipe with
flush hreaded joints. The lower 10-ft section of each well
consisted of manufactured 0.010-inch wide slot well screen. Washed
sand back-Iffill was placed around the outside of the pipe to at least
2-ft above the top of the well screen. A 2-ft minimum bentonite
seal was placed above the sand backfill. The remainder of the
annular space was grouted JC_o the surface with a cement/bentonite
grout. Ground -Water Monitoring Well Installation Records found in
Appendix A illustrate well construction details.
Ground -water monitoring wells K65W611B11, K65W611C11, K65W711B11 and
K65W711CII were constructed as water -table wells with the ton of the
well screen placed near the water table at the time of
construction.
Well K65W611A11 was completed within 10 ft horizontally of existing
well K65W6. Its screened interval was placed at a depth of
approximately 48 to 58 ft below ground surface. This denth
2-2

corresponded to the point of auger refusal in partially weathered
rock. Well K65W7"A" (located within io ft horizontally of existing
well K65W7) was screened from approximately 32 to 42 feet.
At each location, the down -hole drilling equipment was
decontaminated by steam cleaning prior to drilling. Steam cleaning
was Performed to minimize the possibility of cross -contamination
between wells.
Upon conpletion of drilling, lockable steel covers were placed over
each well. The covers were intended to protect the well casing and
deter vandalism. Each cover was grouted at the surface.
Horizontal locations of the -monitoring wells and borings were
identified in the field by measuring with a tape and estimated
right angles, referencing existing landmarks. Relative elevations
of the tops of well casings and the ground surfaces at the borings
were measured with a survey level and rod, referencing a benchmark
identified by the furnished topographic plan drawing. The
benchmark, (a railroad spike in the base of a telephone pole near
the west entrance drive), was assumed to be at an elevation of
868.30 MSL.
A cursory search of Iredell County well permit records revealed the
presence of a potable water well off -site approximately 1000 f-'C_-
east of the Main Plant. The records indicated that the well was
2-3
9

installed in November, 1972. The current status of this well is
unknown. The approximate locations of this well and a potable
water well located south of the property are presented in Figures
2 and 3.
Test Boring Records, Ground -Water Monitoring Well Installation
Records and Well Construction Records are presented in Appendix A.
2.3 Ground-Wa'Cer Sampling
Ground -water samples were obtained from each monitoring well on
February 13, 1990. Sampling was performed by a team of
hydrogeologic technicians from our office.
The monitoring wells were developed to allow the formation around
the screened interval to recover from the effects of drilling and
to bring fresh formation water into the wells. The wells were
developed by removing at least six well volumes using separate,
decontaminated, Teflon bailers.
The wells were purged and sampled using Teflon bailers and new
polypropylene rope. The Teflon bailers were cleaned in the
laboratory with phosphate -free detergent, dilute nitric acid, and
isopropanol, with distilled water rinse after each step. The
bailers were wrapped with aluminum foil to minimize the possibility
of contamination during transportation to the site. Field
2-4

measurements included water levels, pH, and specific conductivity.
Table 1 illustrates measured field parameters.
The samples were packaged in ice and shipped for chemical analysis
via next -day delivery to Law Environmental National Laboratories
in Kennesaw, Georgia. The samples were tested for nitrate and
nitrite content in general accordance with EPA Method 353.2.
Chain -of -custody documentation was used to provide a written record
tracing the possession and handling of the samples from the time
of collection through laboratory analysis and final recording of
the results. Laboratory analysis and a copy of the chain -of -
custody are included in Appendix A.
2-5

3. 0 SUBSURFACE CONDI.TIGNS
The project site is located In the Piedmont Physiographic Province,
an area underlain by ancient igneous and metamorphic rocks. The
virgin soils encountered in this area are the residual product of
in -place chemical weathering of rock which was similar to the rock
presently underlying the site. I-n areas not altered by erosion or
disturbed by the activities of man, the typical residual soil
profile consists of silty and/or clayey soils near the surface,
where soil weathering is more advanced, underlain by sandy silts
and silty sands. The boundary between soil and rock is not sharply
defined. This transitional zone termed "partially weathered rock",
is normally found overlying the parent bedrock. Partially
weathered rock is defined, for engineering purposes, as residual
material with standard penetration resistances in excess of 100
blows per foot. Weathering is facilitated by fractures, joints and
by the presence of less resistant rock types. Consequently, the
profile of the partially weathered rock and hard rock is quite
irregular and erratic, even over short horizontal distances.
Generallv the Law soil borings encountered residual SO4
�r Lls ranging
from sandy silts to silty sands. At borings K65W6 "All through "C",
the near -surface soils consisted of firm to very stiff nicaceous
slightly clayey sandy silts. The silt soils extended from the
'�_i

ground surface to depths of approximately 10 feet. Below 10 ft,
primarily silty fine sands were encountered. The sands ranged in
relative density from loose to dense. A thiLn layer of very loose
silty fine sand was encountered from 23 to 28 ft below grade in
boring K65W6"B".
Similar residual soils were encountered in borings K65W7 "All
through "C". In this group of borings, the surficial micaceous
slightly clayey sandy silt stratum extended only to depths ranging
from 4 to 6 ft below grade. Loose to dense silty sands were
encountered below the silts to termination depths.
Borings K65W6"A", K65W611C" and K65W7"A" were extended into
partially weathered rock (sampled as silty fine sand). Partially
weathered rock is defined as residual material having a standard
penetration resistance greater than 100 blows per foot. Borings
K65W6"A" and K65W7"A" encountered auger refusal at depths of 58 and
44 ft, respectively. Refusal to soil drilling equipment -may
indicate a boulder, lenses of rock, or bedrock. Core drilling
would be required to characterize the refusal material-.
After a stabilization period ranging from 7 to 14 days, the ground-
water level in each boring was measured using a battery -operated
electronic measuring device. At borings K65W6 "All through "C", the
ground -water depths ranged from approximately 16.5 to 36.3 ft below
3-2

grade. At borings K65W7 "All through "C", ground -water depths
ranged from 14.0 to 20.9 ft below grade.
As shown in Figure 2, our measurements revealed that the ground-
water flow direction is generally northeast to southwest. Pa:evious
data gathered by NCDEHNR confirms this trend, and further suggests
that a ground -water high point or "ridge" straddles the northeast
corner of" the site. Ground -water northeast of the "ridge" flows
northeastward toward Fourth Creek, while ground -water southwest of
4
the ridge flows southwestward toward Third Creek. Figure 2
illustrates estimated ground -water elevations.
Ground -water levels may fluctuate several feet with. seasonal and
rainfall variations. Normally, the highest ground -water levels
occur in late winter and spring and the lowest levels occur in late
summer and fall. We note that due to the limited number of
monitoring well locations, the considerable topographic relief, and
the fact that LEI and NCDEHNR measurements were taken on different
datesl the contour lines illustrated in Figure 2 depict general
flow only; localized flow may'be somewhat d1fferent.
The above descriptions provide a general summary of -the subsurface
conditions encountered. The Test Boring Records in Appendix A
contain detailed information recorded at each boring and include
our interpretation of the subsurface conditions based on
examination of the fiald samples. The lines designating interfaces
3 - 3

between various strata represent approximate boundaries and the
transition between strata may be gradual. Generalized lithologic
cross -sections are presented in Figure 'I.
3-4

4.0 RESULTS OF CHI�MICAL ANALYSIS
Table 1 summarizes the laboratory chemical test results. The
ground -water samples were tested for nitrate and nitrite
concentrations in general accordance with EPA Method 353.2. As
previously noted, 15A NCAC 2L guidelines for drinking water quality
set forth a standard threshold for nitrate of 10 mg/1 and for
nitrite of 1 mg/l. our testing indicated that the combined
nitrate/nitrite concentrations ranged from a low of 21 mg/l at
boring K65W7"B" to a high of 370 mg/l at boring K65W6"A". The
potable water well located south of the site (sampled by others
during the summer of 1989) also reportedly showed a nitrate/nitrite
concentration (22 mg/1) above drinking water standards. Measured
nitrate/ni-IC-rite concentrations are presented in Figure 3.
4-1

5.0 DATA ANALYSIS AND INTERPRETATION
The purpose of the new monitoring wells was to help identify the
extent of ground -water contamination and to provide information to
respond to the State's December 12, 1989 Notice of Violation.
Laboratory analysis of ground -water samples obtained from the new
monitoring wells indicated the presence of nitrate/nitrite (as 14)
in excess of 15A NCAC 2L drinking water standards at each of the
wells sampled.
Laboratory analysis from well K65W711A11 (within 10 ft of existing
well K65W7) indicated that N contamination existed both in shallow
and deep aquifer zones. Well K65W711A11 encountered auger refusal
at approximately 44 ft below grade. It is therefore likely that
the upper rock zone has been impacted.
Monitoring wells K65W711B11 and K65W711C11 had N values above drinking
water standards. The 93 mg/l concentration detected at K65W711C11
indicated that the contaminant plume had migrated close to the
southwest corner of the property. The unnamed creek may act as a
barrier to further migration under static ground -water conditions.
5-1

Concentrations of N at K65W611AII, K65W6"B" and K65W611CII also
exceeded drinking water standards; measured values were 370 mg/l,
22 mg/1 and 76 mg/l, respectively. These high concentrations may
indicate that the N contamination may have originated at the former
holding pond located near the K6-,-IW6 well group. The increase in
concentration with depth at the K65W6 well group may indicate that
the upper aquifer zone has been flushed and/or biologically
reduced.
5-2

6.0 RECOMMENDATIONS
This phase of the investigat4 on has not defined the vertical or
-L
horizontal extent of N contamination. To help define the extent
-er contamination, and to obtain add it4 Lonal site -
of ground-wat
specific hydrogeology, Law recommends an additional phase of
ground -water assessment.
Six new ground -water monitoring wells are proposed. Two water -
table wells will be installed approximately 800 ft south and 800
ft southwest of exi St4 ng monitoring well K65W6. Two additional
water -table wells will be installed approximately 300 ft southwest
and 400 ft southeast- of existing well K65W7"B". These four new
water--t-able wells will be utilized to hel-D define the horizontal
extent of ground -water contamination. The exact location of
monitoring wells may be nodified as dictated by drilling equipment
access.
To better define the vertical extent of N contamination, two
additional deer-) rock wells are recommended. one additional rock
well will be installed near existing K65W6 and one near K65W7.
The newly installed wells will. be appropriately sampled using
laboratory provided sampling jars and following state guidelines.
6-1

The newly installed wells will be analyzed for nitrate and nitrite
in general accordance with EPA 41-.est method 353.2.
Water level measurements will be taken in the newly installed wells
and again at the existing LEI monitoring wells. These data will
be used to refine the ground -water contours shown in Figure 2. We
note that horizontal and vertical isopleths have not been presented
in this submittal but will be included in the report of the next
phase of activities.
A written report will be submitted which describes the work done
and presents the laboratory test results as well as our evaluation
of the general ground -water conditions.
Field work could begin within about two weeks following State
approval of this plan. Drilling and well installation likely will
require one week and development and sampling another week.
Laboratory analyses is likely to take about three weeks. Our
written report will follow about two to three weeks after
laboratory results have been received.
6-2

TABLE I
FIELD PARAMETERS
SOUTHERN STLTES FERTILIZER PLANT
STATESVILLE, NORTH CAROLINA
LEI JOB NO. 56-9606.40
Specif ic
Boring Conductance N 0 2 + NO3
Number Temperature Co mv/cm pH (as N) mg/l
K65W6"All
18.6
6.430
5.27
370
K65W6"B"
15.7
0.330
4.31
22
K65W6"C"
15.2
0.841
5.41
76
K65W7"A"
16.0
1.320
5.81
53
K65W7"B"
14.5
0.983
4.30
21
K65W7"C"
14.9
1.878
4.49
93

FIGURES 1-4

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35045',
80� 3d" U... 21 11450000 FEET '15 50' SIR 47'30"
SCALE 1:24000
1 0 1 MILE LAW ENVIRONMENTAL, INC.
1000 0 100 00 3000 4000 5000 6000 7000 FEET
CHARLOTTE, NORTH CAROLINA
1- 5 0 1 KILOMETER
CONTOUR INTERVAL io FEET
DATUM IS MEAN SEA LEVEL SITE LOCATION PLAN
MAPPED, EDITED, AND PUBLISHED BY THE GEOLOGICAL SURVEY SOUTHERN STATES FERTILIZER PLANT
CONTROL BY USGS AND USC&GS STATESVILLE, NORTH CAROLINA
TOPOGRAPHY BY PHOTOGRAMMETRIC METHODS FROM AERIAL
PHOTOGRAPHS TAKEN 1965. FIELD CHECKED 1969 6-9606 FIGURE I

V.-Vol"10
TEST BORIlqG RECORDS
GROUND —WATER MONITORING WELL INSTALLATION RECORDS
WELL CONSTRUCTION RECORDS
LABORATORY TEST DATA REPORTS

�I '. ' .

CORRELATION OF PENETRATION RESISTANCE
WITH CONSISTENCY
NO. OF BLOWS, N
CONSISTENCY
PARTICLE SIZE IDENTIFICATION
0-4
Very Loose
BOULDERS: Greater than 300 mm
5-10
Loose
SANDS: 11-30
Firm
COBBLES: 75 mm to 300 mm
31-50
Dense
GRAVEL: Coarse - 19.0 mm to 75 mm
OVER 50
Very Dense
Fine - 4.75 mm to 19.0 mm
SANDS: Coarse - 2.00 mm to 4.75 mm
NO. OF BLOWS, N
CONSISTENCY
Medium - 0.425 mm to 2.00 mm
Fine - 0.075 mm to 0.425 mm
0-2
Very Soft
3-4
Sof t
SILTS & CLAYS: Less than 0.075 mrn
SILTS 5-8
Firm
& 9-15
Stif f
NOTE: Numbers next to boring on profile
CLAYS: ' 16-30
Very stiff
represent standard penetration
31-50
Hard
resistance (blows per foot).
OVER 50
Very Hard
KEY TO DRILLING SYMBOLS
Undisturbed Sample Water Table 24 HR. BT Boring Terminated
Split Spoon Sample -�Z Water Table at Time of Drilling AR Auger Refusal
KEY TO SOIL CLASSIFICATIONS
... TOPSOIL
-H, CLAYEY SANDY SILT
MSANDY SILT AND SILTY SAND
SAND

DEPTH
(FT.)
0.0
0.5
12.E
27.5
40.0
DESCRIPTION ELEVATION *PENETRATION- BLONVS/FOOT
(FT.)
Qrl) 1) 0 10 20 30 40 60 80 100
Topsoil
857.2--
x
x 852.2--
847.2-
842.2--
837.2-
-
832.2--
827.2--
x
/ x
z
Firm to Stiff Orange Brown Micaceous Slightly
Clayey Sandy SILT
:z
Firm Gray Brown Silty Fine SAND
- - - - - - - - - - - - - - - - - - - - - - - - - - -
Very Firm Yellow Brown Silty Fine SAND
-- --
REMARKS:
Static Water Elevation = 847.8
SEE KEY SHEET FOR EXPLANATION OF
SYMBOLS AND ABBREVATIONS USED ABOVE
8
12
14
14
11
17
15
21
29
26
BORING NUMBER K65W6-A
DATE DRILLED February 5, 1990
PROJECT NUMBER 56-9606.40
PROJECT SOUTHERN STATES FERTILIZER
PAGE I OF 2

DEPTH DESCRIPTION
(FT.)
58.0
I
ELEVATION 0 PENETRATION - BLOWS/FOOT
(FT.)
0 10 20 30 40 60 80 100
Very Firm to Very Dense Gray Brown Silty Fine
SAND
817.2-
812.2-
807.2—
802.2-
797.2-
- 792.2-
- 787.2—
Auger Refusal at 58.0 Feet.
REMARKS:
Static Water Elevation = 847.8
SEE KEY SHEET FOR EXPLANATION OF
SYMBOLS AND ABBREVATIONS USED ABOVE
28
30
50/4"
BORING NUMBER K65W6-A
DATE DRILLED February 5, 1990
PROJECT NUMBER 56-9606.40
PROJECT SOUTHERN STATES FERTILIZER
PAGE 2 OF 2

I
DEPTH DESCRIPTION
(FT.)
0.0
6.(
17.E
22.5
31.0
ELEVATION
(FT.)
.1110
0 PENETRATION - BLOWS/FOOT
10 20 30 40 60 80 100
Loose to Firm Tan Brown Silty Fine to Medium
SAND
- — — — — — — — — — — — — — — — — — — — — — — — — — —
Firm to Loose Brown Pink Silty Fine to Medium
SAND
864.1-
859.1
844.1-
839.1—
834.1—
----
Stiff Tan Brown Sandy SILT
Very Loose to Loose Gray Brown Silty Fine to
Medium SAND
Auger Bo ring Terminated at 31.0 Feet.
REMARKS:
Static Water Elevation = 855.0
SEE KEY SHEET FOR EXPLANATION OF
SYMBOLS AND ABBREVATIONS USED ABOVE
10
12
12
10
10
10
3
9
BORING NUMBER K65W6-B
DATE DRILLED January 31, 1990
PROJECT NUMBER 56-9606.40
PROJECT SOUTHERN STATES FERTILIZER
PAGE I OF I

DEPTH
(FT.)
0.0
0.5
6.0
12.5
18.0
32.5
40.0
DESCRIPTION ELEVATION $PENETRATION- BLO'WS/FOOT
(FT.)
WRO Sz 0 10 20 30 40 60 80 100
Topsoil
A.
854.8—
849.8-
844.8
839.8-
834.8-
829.8-
824.8—
Stiff to Very Stiff Red Brown Micaceous Slightly
Clayey Sandy SILT
Firm Orange Brown Micaceous Silty Fine SAND
- - - - - - - - - - - - - - - - - - - - - - - - - - -
Firm Gray Tan Fine SAND
- — — — — — — — — — — — — — — — — — — — — — — — — — —
Firm Red Brown Yellow Silty Fine SAND
- - - - - - - - - - - - - - - - - - - - - - - - - - -
Dense to Very Dense Tan Brown Silty Fine to
Medium SAND
- t
- --
REMARKS:
Static Water Elevation = 825.4
SEE KEY SHEET FOR EXPLANATION OF
SYMBOLS AND A13BREVATIONS USED ABOVE
11
16
16
13
20
18
14
20
30
76
BORING NUMBER K65W6-C
DATE DRILLED January 31, 1990
PROJECT NUMBER 56-9606.40
PROJECT SOUTHERN STATES FERTILIZER
PAGE I OF 2

DEPTH DESCRIPTION
(FT.)
45.0
ELEV'ATION *PENETRATION- BLONVS/FOOT
(FT.)
10 20 30 40 60 80 100
Very Dense Gray Brown Fine to Medium SAND
Auger Boring Terminated at 45.0 Feet.
809.8-
- 804.8-
- 799.8-
- 794.8-
- 789.8-
- 784.8—
REMARKS:
Static Water Elevation = 825.4
BORING NUMBER
DATE DRILLED
PROJECT NUMBER
PROJECT
PAGE 2 OF 2
SEE KEY SHEET FOR EXPLANATION OF
SYMBOLS AND ABBREVATIONS USED ABOVE
50/6"
K65W6-C
January 31, 1990
56-9606.40
SOUTHERN STATES FERTILIZER

DEPTH
(FT.)
0.0
0.5
6.
1 2J
27.5
40.0
DESCRIPTION ELEVATION *PENETRATION- BLOM'S/FOOT
(FT.)
- 1 0 10 20 30 40 60 80 100
Topsoil
826.2—
821.2-
816.2-
811.2
806.2-
801.2-
796.2—
Very Stiff Red Brown Micaceous Slightly Clayey
Fine Sandy SILT
Firm to Loose Orange Brown Micaceous Silty
SAND
- - - - - - - - - - - - - - - - - - - - - - - - - - -
Loose to Firm Tan Micaceous Fine to Medium
SAND
- - - - - - - - - - - - - - - - - - - - - - - - - - -
Very Firm to Dense Gray Brown Micaceous Silty
SAND (Mottled)
-- - - -
VI
REM -ARKS:
Static Water Elevation = 812.5
SEE KEY SHEET FOR EXPLANATION OF
SYMBOLS AND ABBREVATIONS USED ABOVE
18
16
11
9
8
10
12
24
47
50/4"
BORING NUMBER K65W7-A
DATE DRILLED February 2, 1990
PROJECT NUMBER 56-9606.40
PROJECT SOUTHERN STATES FERTILIZER
,PAGE 1 OF 2

DEPTH DESCRIPTION
(FT.)
44.1
ELEVATION 0 PENETRATION - BLOWS/FOOT
(FT.)
0 10 20 30 40 60 80 100
Very Dense Gray Brown Micaceous Fine SAND
— 786.2-
- 781.2-
- 776.2-
- 771.2-
- 766.2-
- 761.2-
- 756.2—
Auger Refusal at 44.0 Feet.
REMARKS:
Static Water Elevation = 812.5
SEE KEY SHEET FOR EXPLANATION OF
SYMBOLS AND ABBREVATIONS USED ABOVE
BORING NUMBER
DATE DRILLED
PROJECT NUMBER
PROJECT
PAGE 2 OF 2
50/2"
K65W7-A
February 2, 1990
56-9606.40
SOUTHERN STATES FERTILIZER

DEPTH
(FT.)
0.0
0.5
6.(
17.,'
32.0
DESCRIPTION ELEVATION 0 PENETRATION - BLOWS/FOOT
(FT.)
01— 0 10 20 30 40 60 80 100
Topsoil
'�0
814.5—
809.5-
804.5-
794.5--
789.5
784.5—
Stiff to Very Stiff Orange Brown Micaceous
Slightly Clayey Fine Sandy -SILT
Firm to Loose Orange Gray Brown Micaceous
Silty Fine to Medium SAND
- — — — — — — — — — — — — — — — — — — — — — — — —
Loose to Firm Yellow Tan Micaceous Silty Fine to
Medium SAND
7
Auger Boring Terminated at 32.0 Feet.
REMARKS:
Static Water Elevation = 806.9
SEE KEY SHEET FOR EXPLANATION OF
SYMBOLS AND ABBREVATIONS USED ABOVE
11
19
14
11
9
6
13
19
BORING NUMBER K65W7-13
DATE DRILLED February 1, 1990
PROJECT NUMBER 56-9606.40
PROJECT SOUTHERN STATES FERTILIZER
PAGE 1 OF I

DEPTH
(FT.)
0.0
0.5
3.(
8.11
23.0
DESCRIPTION ELEVATION *PENETRATION- BLONNIS/FOOT
(FT.)
szn,7 r 0 10 20 30 40 60 80 100
Topsoil
802.6-
7c-�7.6--
792.6-
787.6-
- 782.6--
- 777.6-
- 772.6-
:z
Stiff Orange Brown Micaceous Slightly Clayey
Sandy SILT
Firm Brown Micaceous Slightly Clayey Silty Fine
to Medium SAND
- - - - - - - - - - - - - - - - - - - - - - - - - -
Loose Gray Brown Micaceous Silty Fine SAND
----
Auger Boring Terminated at 23.0 Feet.
REMARKS:
Static Water Elevation = 795.7
SEE KEY SHEET FOR EXPLANATION OF
SYMBOLS AND ABBREVATIONS USED ABOVE
12
11
17
9
9
10
BORING NUMBER K65W7-C
DATE DRILLED February 1, 1990
PROJECT NUMBER 56-9606.40
PROJECT SOUTHERN STATES FERTILIZER
PAGE I OF 1

GROUND -WATER MONITORING WELL INSTALLATION RECORDS

GROUND -WATER MONITORING WELL INSTALLATION RECORD
JOB NAME SOUTHERN STATES PLANT JOB NUMBER 56-9606.40
WELL NUMBER. K 65 W 6 "A" - GROUND SURFACE ELEVATION Bt.-2.23 FT.
LOCATION SOUTHERN STATES FERTILIZER PLANT, STATESVILLE, NORTH CAROLINA
INSTALLATION DATE _ 2/6/90
GROUND SURFACE
LOCKABLE CAP
VENTED PVC CAP
STEEL PIPE --iOTSTICKUP = 2.29'
BORING
DEPTH TO TOP
G 45.0'
ROUT OFSAND BACKFILL
DEPTH TO
BASE OF
GROUT SEAL
43.0'
BENTONITE SEAL
2" PVC PIPE
SAND
PVC SCREEN DEPTH OF
PVC SCREEN
48.0' TO 58.0'
CAP
NOTE: ALL PVC PIPE JOINTS
HAVE SCREW CONNECTORS
TOTAL DEPTH
OF WELL
58.0'
GROUND WATER AT 16.70 FT. BELOW TOP OF CASING ON 2/13/90.
AOr MONITORING WELL
LAW ENVIR011MENTAL, MC. INSTALLATION RECORD
CHARLOTTE. NORTH CAROLINA

GROUND -WATER MONITORING WELL INSTALLATION RECORD
JOB NAME SOUTHERN STATES PLANT JOB NUMBER 56-9606,40
WELL NUMBER K 65 W 6 "B" - GROUND SURFACE ELEVATION 869.13 FT.
LOCATION SOUTHERN STATES FERTILIZER PLANT, STATESVILLE, NORTH-CAROLINA
INSTALLATION DATE 1/31/90
GROUND SURFACE
STEEL PIPE
BORING
GROUT
BENTONITE SEAL
2" PVC PIPE
LOCKABLE CAP
VENTED PVC CAP
STICKUP= 2.42'
DEPTH TO TOP
I OFSAND BACKFILL
DEPTH TO 10.5'
BASE OF
GROUT SEAL
8.5'
1
SAND
DEPTH OF
PVC SCREEN
PVC SCREEN
12.5' TO 22.5'
CAP
NOTE: ALL PVC PIPE JOINTS
HAVESCREW CONNECTORS
TOTAL DEPTH
OF WELL
31.01
GROUND WATER AT 16.55 FT. BELOW TOP OF CASING ON 2/13/90. 1
MONITORING WELL
LAW ENVIRONMENTAL. INC. INSTALLATION RECORD
CHARLOTTE, NORTH CAROLINA

GROUND -WATER MONITORING WELL INSTALLATION RECORD
JOB NAME SOUTHERN STATES PLANT JOB NUMBER 56-9606.40
WELL NUMBER K 65 W 6 "C" - GROUND SURFACE ELEVATION 859.79 FT.
LOCATION SOUTHERN STATES FERTILIZER PLANT, STATESVILLE, NORTH CAROLINA
INSTALLATION DATE 1/31/90
GROUND SURFACE
LOCKABLE CAP
STEEL - PIPE VENTED PVC CAP
__�C�CTSTICKUP= 1.90'
BORING
TOTAL
�O
DEPTH
DEPTH TOP OF
I
WELL
GROUT
OFSAND BACKFILL 45.0'
DEPTH TO 31.5'
BASE OF
GROUT SEAL
29.5'
BENTONITE SEAL
2 PVC PIPE
SAND
PVC SCREEN
-7
)EPTH OF
--
PVC SCREEN
33.5' TO 43.5'
CAP
NOTE: ALL PVC PIPE JOINTS
HAVESCREW CONNECTORS
GROUND WATER AT 36.25 FT. BELOW TOP OF CASING ON 2/13/90.
MONITORING WELL
LAW ENVIRONMENTAL. INC.
7 INSTALLATION RECORD
CHARLOTTE. NORTH CAROLINA

GROUND -WATER MONITORING WELL INSTALLATION RECORD
JOB NAME SOUTHERN STATES PLANT JOB NUMBER 56-9606.40
WELL NUMBER K 65 W 7 "A" - GROUND SURFACE ELEVATION 831.17 FT.
LOCATION SOUTHERN STATES FERTILIZER Pt -ANT, STATESVILLE, NORTH CAROLINA
INSTALLATION DATE _2/5/90
GROUND SURFACE
LOCKABLE CAP
STEEL - P I P E VENTED PVC CAP
STICKUP= 2.30'
BORING
I TOTAL DEPTH
DEPTH TO TOP
OF WELL
GROUT OFSAND BACKFILL 44.0'
DEPTH TO 30.0'
BASE OF
GROUT SEAL
28.01
BENTONITE SEAL
2" PVC PIPE
SAND
PVC SCREEN
DEPTH OF
PVC SCREEN
32.0' TO 42.0'
CAP
NOTE: ALL PVC PIPE JOINTS
HAVE SCREW CONNECTORS
GROUND WATER AT 20.93 FT. BELOW TOP OF CASING ON 2/13/90.
MONITORING WELL
LAW ENVIRONMENTAL, INC. INSTALLATION RECORD
CHARLOTTE, NORTH CAROLINA

GROUND -WATER MONITORING WELL INSTALLATION RECORD
JOB NAME SOUTHERN STATES PLANT JOB NUMBER 56-9606.40
WELL NUMBER K 65 W 7 "B" GROUND SURFACE ELEVATION 819.53 f T.
LOCATION SOUTHERN STATES FERTILIZER PLANT, STATESVILLE, NORTH CAROLINA
INSTALLATION DATE 2/l/90
GROUND SURFACE
STEEL PIPE
LOCKABLE CAP
VENTED PVC CAP
STICKUP= 2.22'
BORING
TOTAL DEPTH
DEPTH F- TOP OF WELL
GROUT OFSAND BACKFILL 32.0'
DEPTH TO 13.0'
BASE OF
GROUT SEAL
11.01
BENTONITE SEAL
2" PVC PIPE
SAND
PVC SCREEN
CAP
NOTE: ALL PVC PIPE JOINTS
HAVE SCREW CONNECTORS
DEPTH OF
PVC SCREEN
15.0' TO 25.0'
GROUND WATER AT 14.90 FT. BELOW TOP OF CASING ON 2/13/90.
MONITORING WELL
LAW ENVIRONMENTAL, INC. INSTALLATION RECORD
CHARLOTTE. NORTH CAROLINA

GROUND -WATER MONITORING WELL INSTALLATION RECORD
JOB NAME SOUTHERN ST.,',,TES PLANT JOB NUMBER 56-9606.40
WELL NUMBER K 65 W 7 "C" GROUND SURFACE ELEVATION 807.62 FT.
LOCATION SOUTHERN STATES FERTILIZER PLANT, STATESVILLE, NORTH CAROLINA
INSTALLATION DATC 2/11/90
GROUND SURFACE
STEEL PIPE
BORING
GROUT
BENTONITE SEAL
2" PVC PIPE
SAND
PVC SCREEN
CAP
NOTE: ALL PVC PIPE JOINTS
HAVESCREW CONNECTORS
LOCKABLE CAP
VENTED PVC CAP
STICKUP= 2.10'
DEPTH TO TOP
I OFSAND BACKFILL
DEPTH TO 9.51
BASE OF
GROUT SEAL
7.5'
L
DEPTH OF
PVC SCREEN
12.0' TO 22.0'
ILI
TOTAL DEPTH
OF WELL
23.0'
GROUND WATER AT 13.99 FT. BELOW TOP OF CASING ON 2/13/90.
MONITORING WELL
LAW ENVIRONMENTAL, INC. INSTALLATION RECORD

WELL CONSTRUCTION RECORDS

NORTH CAROUNA DEPARTWENT OF MATLARAL RESCkPRCES AND CC*A1A-P4T'rY DEyELO&%4E),(T
DIVISION Or EWVIRONkC�nAL "A.NAG6ELW� - GR&AJOWATOR SF-CT)Cq
P.O. BOX 27687 - RALEIGKN.C. 27e 1 1. P"ONE (9 19) 73�- 5093
WELL CONSTRUCTION RECORD
FOR C)rFl:;E USE C i,-Y
C)uaC:. No. Serial No.
L2 i, Long. _ PC
Minor Basin
Basin Coce
Heacw Ent. Gw-1 Ent.
DRILLING CONTRACTOR LAW ENGINEERING K65W'A"
DRILLER REGISTRATION NUMBER �32 STATE WELL CONt"TRI-17TION
PERMIT NUMBER: 48-02384N-0070
1. WELL LOCATION: [Show sketch of the location below)
Nearest Town: STATESVILLE, NC County: IREDELL
(Road. Community. or Subolvision and Lot Nic.)
2. OWNER SOUTHERN STATES COOPERATIVE, INC.
ADDRESS U.S. EIGHWAY 70 EAST
(Street or Houle tqo.j
STATESVILLE NC
City or Town State ZiD Cooe
DATE DRILLED 2/5/90 — USE OF WELL. MONITORING
A. TOTAL DEPTH 58.0 CUTTINGS COLLECTED MYes FJ No
5. DOES "'ELL IREPLACE EXISTING WELL? 0 Yes E) No
6. STATIC WATER LEVEL: 16.70 FT. CD above TOP OF CASING,
X): oelow
TOP OF CASING IS 2. 29 FT. ABOVE LAND SURFACE.
7. YIELD (gnm): -NA fAETHOD OF TEST
E. WATER ZONES (depth): - - —
9. CHLORINATION: T yp e NA Amount
10. CASING:
Wall Thic:kness
Deolh Diameter or Weicni/Fi. Material
From 0 70 48 FI. 2-IN SCHEDULE 40 PVC
From - To -F
From - To
11. GROUT:
DeWh Material method
From 43 To- 45 Ft. BENTONITE PELLETS
From 0 To Z43 FI..CE-MENT/BENT01\'ITE
12. S C P. E E N:
DeDir; . Diameter Slot Size Ulaterial
From 48 T c---� 8 Ft. 2 in. 0.010in. Pvc
F rom — T c— Fi. in. in.
From— To— Ft. in. in.
GRAVEL PACK:
DeDlh Size Mlaterial
From 45 To 58 Ft. FINE —MEDIUM SAIM
From --To— Fi.
14. R---IVARKS:—
Depth DRILLING LOG
From To Formanon DescriDnon
0-0.5 TOPSOIL
O.c-12.5 CLAYEY SANDY SILT
12.5-58 SILTY FINE SAND
SEE TEST BORING RECORDS
If additional sDace is needed use back of Jorm.
LOCATION SKETCH
(Show direction anc distance from at least two S*,ale Roads.
or other maD reference ocinis)
I JEV
Z
P.,
-------------
Q�
47*30' 'it
I DO HEREBY CERTIFY THAT THIS WELL WAS CONSTRUCTED IN ACCORDANCE WITH. 15 NCAC 2C. WELL CONSTRUCTION'
STANDARDS. AND THAT A COPY Or: THIS RECORD H S
,� BEEN PROVIDED TO THE WELL OWNER.
D21T441-� e. zx"I�k : 31-- 2 7Z9 0
SIGNATURE OF CONTRACTOR OR AGENT DATE
Submit oricinal to Division o! Environmental Manaoemenj and CODN' 10 well owner.

NORT� CARCA-jNk D1PkRT�,*-K1 Or NATLN�&L RESOJRCES AND CC*A"-j,41TY DEVE�.O-,ACWT
DIVL510*q Or EWVIR0N6EW7A.L W-A,-"W64E�pr - GA;L8`lOwA1TEP SECTIO"
P.O. BOX 27667 - 27e 1 1. P��E ts 12) 73,4-5093
WELL CONSTRUCTION RECORD
F OR 09 F ICE USE ON- Y
Cju&C. No. Serial No.
La 1. Long;._ PC
Minor be sin
Basin Code
header Ent. GVY-1 Ent.-
DRILLING CONTRACTOR LAW ENGINEERING K65W6"B"
STATE WELL CONSTRUCTION
DRILLER REGISTRATION NUMBER 332 PERMIT 14UMBER: 48-0238—WIA-0070
1. WELL LOCATION: (Show Sketch of the location below)
Neares! Town: STATESVILLE, NC County: IREDELL
(Roar-, Communily, or Suoc�iyision and Lot No.)
2. OWNER SOUTHERN STATES COOPERATIVE, INC
A D D RE S S U. . HIGHWAY 70 EAST
(-Street cr Houle NoJ
STATESVILLE NC
City or Town State 210 Cooe
3. DATE DRILLED 1/31/90 USE OF WELL. MONITORING
4. TOTAL DEPTH 3 1. 0 CUTT114GS COLLECTED E-Yes- E) NO
5. DOES WELL REPLACE EXISTING WELL? Yes 2 No
6. STATIC WATER LEVEL: 16.55 FT. above TOP OF CASING,
bVow
TOP OF CASING IS 2. 4 2 FT. ABOVE LAND SURFACE.
7. YIELD (gom): NA - METHOD OF TEST
E. WATER ZONES (depth): -
9. CHLORINATION: Type NA Amount
10. CASING:
Wall Thickness
Depth Diameter or Weignt/Fi. Material
From 0 To 12.5 FI. 2—IN SCHEDULE 40 PVC
From —To —Ft.—
From — To —FI.-
11. GROUT:
Depth 1.4alerial Method
From 8.5 To 10.5 Ft. BENTONITE PELLETS
From 0 T 0 --E5 Ft. CEMENT/BENTONITE_
12. SCREEN:
Deptri Diameter Slot Size Material
From 12.5 To 22.5 Ft. 2 in. 0.010 in.PVC
From — To— Ft. — in. in.
From— To— Ft. — in. in.
13. GRAVE:L PACK:
De�lh Size Material
From 10 - 5 To 31.0 FI.FINE—MEDIUM SAND
From—lo F
14. PEMARKS: —
Depth
From
r)Pii I mr- i nr.
To Formation Descriolion
0-0.5 TOPSOIL
0.5-17.5 SILTY FINE TO MEDIUM SAND
17.5-22.5 SANDY SILT
22.5-31 SILTY FINE TO MEDIUM SAND
SEE TEST BORING RECORDS
It additional space is needed use back. of form.
=ATION SKETCH
(Show direction and distance from at least two State Roads
or other map reference points)
Q.
47'30*
70
I DO HEEREBY CERTIFY THAT THIS WELL WAS CONSTRUCTED IN ACCORDANCE WITH 15 NCAC 2C, WELL CONSTRUCTION'
STANDARDS. AND THAT A COPY OF THIS RE:CORD HAS B�E:N PROVIDE�) TO THE WELL OWNER
& -27
SIGNATURE OF CONTRACTOR OR AGENT DATE
Submit orioinal lo Division of Environmental Manaoemenl and CODY 10 w0l Owner.

FOR OFFICE USE ON-Y
t4ORTH CARS)�-JNA DEPARTWF-PT Or NATIJRAL PESOURCES AND CO*A&A-P41T'Y XVaOP��
DIVISIC>-4 OF FJWIRON�.CWTAL "A-KAG6E--- - C36R&.-IDWATEP Wcno-i
P.O. BOX 27667 - RA.LEIGH.K.C. 27e 1 1. P�+�E (6 19) 733-6063
WELL CONSTRUCTION REECORD
OuaC. No.
L at.
Minor Bbsin
Basin Code
Header Ent,
- Serial No.
Lont;-­
_ PC
GW-1 Ent.
DRILLING CONTRACTC)R LAW ENGINEERING K65W6"C"
STATE WELL CONSTRUCTION
DRILLER REGIS7RATION NUMBER 332 PERMIT NUMBER: 48-0238-WM-00710
1. WELL LOCATION: (Show skc;h of the location below)
Nearest Town: STATESVILLE. NQ County: IREDELL
(Road, Community, or Subdivision and Lot No.)
2. OWNER SOUTHERN STA ES COOPERATIVE, INC.
ADDRESS U.S. HIGHWAY 70 EAST
(Street cf Houle No.J
STATESVILLE NC
City or Town Stale 210 Code
3. DATE DRILLED 1/31/90 — USE OF WELL -MONITORING
4. TOTAL DEPTH 45.0 CUTTINGS COLLECTED fR-Yes 0 No
S. DOES WELL REPLACE EXISTING WELL? EJ Yes 5 No
6. STATIC WATER LEVEL: 36, 25 FT. 0 abDVe TOP -OF CASING,
Vow
TOP OF CASING IS 1 - 90 FT. AF0tv)E LAND SURFACE.
7. YIELD (gpm): NA - METHOD OF TEST
S. WATER ZONES (depth):
S. CHLORINATION: Type NA Amount
10. CASING:
Wall Thirkness
Depth Diameter or Weignt/Fi. Material
From 0 -To 33 . 5 FI.- 2-IN SCHEDULE (LPVC
From -7o -FI.-
From - To-Fl.-
1 1. GROUT:
Depth lAalerial Method
From 29.5 To 31.5 Ft. BENTONTTE PELLETS
From 0 -to 29.5 Ft. CEMENT /BENTON ITE
12. SCREEN:
Dep:n
From 33.5 To 43.5 Ft.
From — To— Ft.
From_ -I c— Fl.
*,3. GRAVEL PACK:
Diameter Slot Size Malerial
2 in. 0. 0 10 in. Pvc
in. in.
iri.— in.
Depth Size Maierial
From 31.5 To 45.0 Ft. 'FINE -MEDIUM SAND
From I c— F:.
14. REMARKS: —
Depth DRILLING LOG
From To Formation DescriDlion
0-0.5 TOPSOIL
0.5-6 SLIGHTLY CLAYEY SANDY SILT
6-12.5 SILTY FINE SAND
12.5-18 FINE SAND
18-32.5 SILTY FINE SAND
32.5-45 SILTY FINE TO MEDIUM SAND
SEE TEST BORING RECORDS
11 additional sciace is needed use back of form.
LOCATION SKETCH
(Show direction and distance from at least two Stale Roads
or other map retlerence points)
WWI
1p
47'30. il
I DO H=REBY CERTIFY THAT THIS WELL WAS CONSTRUCTED IN ACCORDANCE WITH 15 NCAC 2C. WELL CONSTRUCTION'
STANDARDS. AND THAT A COPY OF THIS RECORD H S BEEN PR VI : TH= WELL WNER.
A�v
SIGNATURE OFF CONTRACTOR OR AGENT DATE
Sunmit orioinal to Division of Environmenlal w.anaoemeni and copy to well owner.

NORT)� CAROLJNA DE114IRT14CWT 01� NATLNkAL RESOURCES AND CO"--Xqt- MVELOPIAEN7
olv;SjC,-j OF EN'VIRONMENTAL 614"iAC6E64E-WT - o6qOUP1JVWATE�R SECT)OW
P.O. BOX 27687 - RALEIG�ILK-C- 27 a IA. P"ONE (PIG) 733-6093
%YELL CONSTRUCTION RECORD
FOR OFFl--E USE ON-Y
Duac. No. . Serial No.
Lat. Long._ Pc
Minor Basin
Basin Code
Header Ent. GW-1 En..
DRILLING CONTRACTOR LAW ENGINEERING K65W7"A"
STATE WELL CONSTRUCTION
DRILLER REGISTRATION NUMBER 332 PERMIT NUMBER: 4�,-0238—WM-0070
1. WELL LOCATION: (Show Sketch of the location below)
Nearest 7own: STATESVILLE, NC --- County: IREDELL
Depth DPILLING LOG
(Road. Community, or Suboivision and Lot No.)
2. OWNER SOUTHERN.STATES COOPEPATIVE, INC.
ADDRESS U.S. HIGHWAY 70 EAST
[Street cr Route No.j
STATESVILLE_ NC
City or Town Stale Zip Code
3. DATE DRILLED 2/5/90 USE OF WELL. MONITORING
4. TOTAL DEPTH 44.0 CUTTINGS COLLECTED fR-Yes' 0 No
5. DOES WELL REPLACE EXISTING WELL? E3 Yes J�D No
6. STATIC WATER LEVEL: 20. 93 FT. above TOP OF CASING,
E below
TOP OF CASING is 2. 30 FT. ABOVE LAND SURFACE.
7. YIELD (gvm): NA - METHOD OF TEST
a. WATER ZONES (depth):
9. CHLORINATION: Type NA Amount
10. CASING: Wall Thickness
Depth Diameter or Weignt/Fl. Material
From - 0 To 42-OFI. 2—IN SCHEDULE'40 PV
From Tc -Fl.-
From To -FI.-
1. GROUT:
Depth Malerial Method
From 28.0 To 30-OFt.BENTONITE PELLETS
From 0 To 28.0 Ft. CEMEN.T/BENTONTTE
12. SCREEN:
Depth Diameter Slot Size 1,/,aterial
From - 32.0 To 42.0 Fl. 2 in.0.010 in. PVC
From — To__ Fl. in. in.
From— 7c— Ft. in. — irL
13. GRAVEL PACK:
DeQlh Size Material
From 30.0 To 44.0 Ft. FTNE-MEDTUM SAND
From_ To_ F:.
14. REMARKS:
From To Formation DeSCrlDIiOn
0-0-5 Tnpq()TT
0.5-6 SLIGHTLY CLAYEY FINE SANDY
SILT
6-12.5 SILTY SAND
12.5-27.5 FINE TO MEDIUM SAND
27.5-40 SILTY SAND "KOITLED)
40-44 FINE SAND
SEE TEST BORING RECORDS
It additional sDace is needed use back. of form.
LOCATION SKETCH
(Show direction and distance from at least two Stale Roads,
or other mao reference points)
G J
" ik)
47'30*
I DO HEREBY CERTIFY THAT THIS WELL WAS CONSTRUCTED IN ACCORDANCE WITH 15 NCAC 2C. WELL CONSTRUCTION.
STANDARDS. AND THAT A COPY OF THIS RECORD HASBEEN PROVIDED TO THE WELL OWNER.
�? �0_ k-
: kl�41
SIGNATURE OF CONTRACTOR OR AGENT DATE
Submit orioinal to Division of Ervironmental Manaclemeni and coDy to well owner.

FOR OFFIC;E L)SE ON'-Y
NORTW CAROJNA DEPART�,VEWT Or NATURAL RESO04CES AND CO*Ak*-*4r'ry DEvF_L0-.AE�r-
DIVL;JON OF EWIROOdMEP47A�L WA)'CAGEJ-� - (:iq;o"owATE)R s.Ec'noN
P.O. BOX 27687 - PLAIXIC�H.K.r­ 27C1 1. PHONE (PIP) 733-b083
WELL CONSTRUCTION RECORD
CivaC. No.
L at.
Minor Basin
Basin Code
Header Ent
Serial No.
Long._ Pc
GW-1 Ent.
DRILLING CONTRACTCIR LAW ENGINEERING K65W7"B"
STATE WELL .�ONSTRUCTION
DRILLER REGISTRAT10N NUMBER 332 PERMIT NUMBER: 48-0238—WM-0070
i. WELL LOCA71ON: (Show sketch of tne location below)
Nearest . Town: �TATESVILLE, NC County: 17REDtLL
(Road, Community, or Subdivision and Lot No.)
2. OWNER SOUTHERN STATES C002ERATIVE, INC.
ADDRESS U.S. HIGHWAY 70 EAST
(Street cr Howe No.)
STATESVILLE NC
City or Town State Zip Code
3. DATE DRILLED 2/1/90 USE OF WELL. MONITORING
.4. T07AL DEPTH — 32. 0 cu'rTINGS COLLECTED nYes' E3140
5. DOES WELL REPLACE EXISTING WELL? 0 Yes, [@ No
6. STATIC WATER LEVEL: 14 -.90 FT. [D above TOP OF CASING,
M below
TOP OF CASING is 2. 22 FT. ABOVE LAND SURFACE.
7. YIELID Cgom): NA METHOD OF TEST
S. WATER ZONES (depth):
S. CHLORINATION: ' Type ' NA Amount
10. CASING:
Wall Thickness
Depth Diameter or Weignl/Ft. Material
From 0 70 25-0 Fl. 2—IN SCHEDULE 40 PVC
From —7o�Fl.—
From —To —F',.-
11. GROUT:
Depth Material Method
Ffom 11.0 To 13.0 FI.BENTONITE PELLETS
From 0 T, 11.0 Ft. CEMENT /BENTONITE
,2. SCREEN:
Depin Diameter Slot Size Malerial
From 15.0 To 25.0 FI.2 in. 0..010 in. PVC
FrDm—Tc_FI._in.—in.
From— To— Ft. — in.— irL
:3. GRAVEL PACK:
Depth Size Material
From 13.0 To 32,0 Fl. FINE -MEDIUM SAND
Fror.-,—To— Fi.
14. R= M.ARKS: —
Depth DRILLING LOG
From To Formalion DescriDlion
0-0.5 TOPSOIL
0.5-6.0 SLIGHTLY CLAYEY FINE SANDY
SILT
6.0-32 SILTY FINE TO MEDIUM SAND
SEE TEST BORING RECORDS
It additional space is needed use back of form.
-LOCATION SKETCH.
(Show direction and distance from at least two Stale Roads,
or oiner map reference points)
L
70
I DO HEREBY CERTIFY THAT THIS WELL WAS CONSTRUCTED IN ACCORDANCE WITH 15 NCAC 2C. WELL CONSTRUCTION
STANDARDS, AND THAT A COPY OF THIS RECORD HAS BEEN PROVIDE::D TO THE WELL OWNEP.
:a� 4 - - 2-- -�� -3
SIGNATURE OF LONTRACTOR OR AGENT DATE
Submit oricinal to Division of Environmenial Maneoemeni and coi)y to well owner.

NORrH CAROUNA DEPART).CW7 OF NATURAL RE&OuP.CES AND CO�A"­WrTY DEVELOII`��'T
DIV�&O,N Or EN`V1RO#j6CW7AL k&A,-"GE�-CWT - C64CUNOWATOR SECno"
P.O. BOX 2 7657 - RALEIG�i.N.C. 27C 1 1. Pt�E (9 19) 733-6093
WELL CONSTRUCTION RECORD
VOR OFFICE USE ON'-Y
Civad. No. Serial No..
Lat. Long. PC
Minor Basin
Basin Code
Header Ent. GW-1 En..
DRILLING CONTRACTOR LAW ENGINEERING K65W7"C"
DRILLER REGISTRATION NUMBER 332 STATE WELL CONSTRUCTION
PERMIT NUMBER:. 4?-0238-WM-0070
1. WELL LOCATION: (Show Sketch of the location below)
Nearest Town: STATESVILLE, NC County: IREDELL
(Road, Community, or Subdivision and Lot No.)
2. OWNER SOUTHERN STATES COOPERATIVE, INC.
ADDRESS U.S. HIGHWAY 70 EAST
(Street or Route No.)
STATESVILLE NC
City or Town State Zio Code
3. DATE DRILLED - 2/1/90 — USE OF WELL. MONITORING
4. TOTAL DEPTH. 23 . 0 CUTTINGS COLLECTED :0-Yes' ED No
5. DOES WELL REPLACE EXISTING WELL? E3 Yes @ No
6. STATIC WATER LEVEL: 13. 99 FT. j above TOP OF CASING.
below
TOP OF CASING is 2. 10 FT. ABOVE LAND SURFACE,
7. YIELD (gom): NA METHOD OF TEST
S. WATER ZONES (depth):
9. CHLORINATION: Type NA Amount
10. CASING:
Wall Thickness
Depth Diameter or Weignt/Ft. Material
From 0 To 12. 0 F1 2—IN SCHEDULE 40 PVC
From —To —Fl.
From —To --Ft.
1 1. GROUT:
Depth Material method
From 7.5 To 9. 5 FI.BENTONITE PELLETS
From 0 To 7.5 Ft. CEMENT/BENTONITE -
12. SCREEN:
Depth Diameter Slot Size 1.0mierial
From- 12,0 To 22.0-Fl.2 in. 0. 0 10 in. PVC
From — To— Ft. in. in.
From_ To— Ft. in.— in.
GRAVEL PACK:
Deolh Size Material
From 9.5 To 23.0 Fi.FINE-MEDIUM SAND
From 7 o— Fi.
14. RE MA RK S: —
Depth DRILLING LOG
From To Formation Description
0-0.5 TOPSOIL
0.5-3 SLIGHTLY CLAYEY SANDY SILT
3-8.5 SLIGHTLY CLAYEY SILTY FINE
TO MEDIUM SAND
8.5-23 SILTY FINE SAND
SEE TEST BORING RECORDS
It additional sD2ce is needed use back of form.
LOCATION SKETCH
(Show direction and distance from at least two State Roads,
or oiner m2D reference Points)
A
J.
. r k�, \
47'30'
I DO HEREBY CERTIFY THAT THIS "'ELL WAS CONSTRUCTED IN ACCORDANCE WITt-. 15 NCAC 2C. WELL CONSTRUCTION'
-STANDARDS, AND THAT A COPY OF THIS RECORD HAS BEEN PROVIDED TO, THE %YE 0 W N E R.
E4
16. -Ar_A4-1d� 0
SIGNATURE OF CONTRACTOR OR AGENT DATE
Submit orioinal to Division of Ervironmental Manaoemeni and coDy to well owner.

LABORATORY TEST DATA RECORDS

LAW ENVIRONMENTAL INC.
112 TOWNPARK DRIVE
KENNESAW, GEORGIA 30144-5599
404-421-3400
February 19, 1990
Law Environmental, Inc.
431 Minuet Lane
Charlotte, NC 28217
Attention: Tom Beggs
LE Job Number: 56-9606
Subject: Chemical Analysis of Samples Received
on 02/14/90.
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 Lo the contents of the samples
as submitted. This report shall not be reproduced except in full
without the approval of Law Environmental National Laboratories.
-if there are any questions, please do not hesitate to contact us.
Sincerely,
LAW ENVIRONMENTAL NAT LABS
Clifford H. McBride
QA/QC Coordinator
Attachment: Data Report
Invoice

LAW ENVIRONMENTAL NATIONAL LABORATORIES
TEST DATA REPORT
Date 02/16/90
ge 1
--- Project Information ---
Lab Number : 90-5289-02
Project No. : 56-9606 Cust. No.
Project Name : SOUTHERN STATES
Manager: TOM BEGGS
Sample Information
Station ID
K-65 W-6A
Sampled Date/Time
: 02/13/90 13:20
Matrix
W
Received Date/Time
: 02/14/00 10:35
Type
GRAB
Received From/By
: DH/ST
Collector
DH
Chain of Custody
: 8559
Number of Containers
: 1
Remarks :
--- Test D�ta ---
Parameter .............................. Method.... Units PQL ....... Results ... Test Date Analy
INORGANIC RESULTS
Nitrogen, Nitrate EPA 353.2 mg/l 0.05 370 02/15/90 OR
Y4'L.rogen,Nitrite EPA 353.2 mg/l 0.05 ND 02/15/90 OR
Signed

LAW ENVIRONMENTAL NATIONAL LABORATORIES
TEST DATA REPORT
Date 02/16/90
ge 1
--- Project Information ---
Lab Number 90-5289-01
Project No. 56-9606 Cust. No.
Project Name SOUTHERN STATES
Manager: TOM BEGGS
--- Sample Information ---
Station ID
: K-65 W-6B
Sampled Date/Time
: 02/13/90 13:15
Matrix
: W
Received Date/Time
: 02/14/90 10:35
Type
: GRAB
Received From/By
: DH/ST
Collector
: DH
Chain of Custody
: 8559
Number of Containers
: 1
Remarks :
--- Test Data ---
Parameter .............................. method .... Units PQL ....... Results ... Test Date Analy
- INORGANIC RESULTS
Nitrogen, Nitrate EPA 353.2 mg/l 0-05 22 02/15/90 OR
",�41-1-rogen,Nitrite EPA 353.2 mg/1 0.05 ND 02/15/90 OR
Signed

LAW ENVIRONMENTAL NATIONAL LABORATORIES
TM-T DATA REPORT
Date 02/16/90
Ige 1
Project Information ---
Lab Number 90-5289-03
Project No. 56-9606 Cust. No.
Project Name SOUTHERN STATES
Manager: TOM BEGGS
--- Sample Information ---
Station ID :
K-65 W-6C
Sampled Date./Time
: 02/13/90 13:25
Matrix :
W
Received Date/Time
: 02/14/90 10:35
Type :
GRAB
Received From/By
: DH/ST
Collector :
DH
Chain of Custody
: 8559
Number of Containers
: 1
Remarks :
--- Test Data ---
Parameter ............................... Method.... Units PQL ....... Results ... Test Date Analy
INORGANIC RESULTS --
Nitrogen, Nitrate
"7":trogen,Nitrite
EPA 353.2 mg/l 0.05
EPA 353.2 mg/1 0.05
76 02/15/90 OR
ND 02/15/90 OR
Signed

LAW ENVIRONMENTAL NATIONAL LABORATORIES
TEST DATA REPORT
Date 02/16/90
ge 1
--- Project Information ---
Lab Number : 9D-5289-04
Project No. : 56-9606 Cust. No.
Project Name : SOUTHERN STATES
Manager: TOM BEGGS
--- Sample Information ---
Station ID
K-65 W-7A
Sampled Date/Time
02/13/90 13:30
Matrix
W
Received Date/Time
02/14/90 10:35
Type
GRAB
Received From/By
DH/ST
Collector
DH
Chain of Custody
8559
Number of Containers
1
Remarks :
--- Test Data ---
Parameter .............................. Method.... Units PQL ....... Results ... Test Date Analy
- INORGANIC RESULTS --
Nitrogen, Nitrate
N�trogen,Nitrite
EPA 353.2 mg/1 0.05 52 02/15/90 OR
F-PA 353.2 mg/l 0.05 0.78 02/15/90 OR
�7
Signed

LAW ENTVIRONTMEN"TAL NATIONAL LABORATORIES
TEST DATA REPORT
D��e 02/16/90
Te 1
--- Project Information ---
Lab Number 90-5289-05
Project No. 56-9606 Cust. )10.
Project Name SOUTHERN STATES
Manager: TOM BEGGS
--- Sample Information ---
Station ID
K-65 W-7B
Sampled Date/Time
: 02/1' ' ? ' /90 13:45
Matrix
W
Received Date/Time :
02/14/go 10:35
Type
GRAD
Received From/By :
DH/ST
Collector
DH
Chain of Custody :
8559
Number of Containers :
1
Remarks :
--- Test Data ---
2-arameter .............................. Method.... Units PQL ....... Results ... Test Date Analy
- INORGANIC RESULTS --
Nitrogen, Nitrate
N �rogen,Nitrite
EPA 353.2 mg/l 0.05
EPA 353.2 mg/l 0.05
Signed
21 02/15/90 OR
ND 02/15/90 OR

LAW ENVIRONTMENTAL NATIONAL LABORATORIES
TEST DATA REPORT
"I-te 02/16/90
ge 1
--- Project Information ---
Lab Number 90-5289-06
Project No. 56-9606 Cust. No.
Project Name SOUTHERN STATES
Mana,-,er: TOM BEGGS
--- Sample Information ---
Station ID
: K-65 W-7C
Sampled Date/Time
02/13/90 13:40
Matrix
: W
Received Date/Time
02/14/90 10:35
Type :
GRAB
Received From/By
DH/ST
Collector :
DH
Chain of Custody
8559
Number of Containers
1
Remarks :
--- Test Data ---
Porameter .............................. Method.... Units PQL ....... Results ... Test Date Analy
. INORGANIC RESULTS --
Nitrogen, Nitrate
1 trogen,Nitrite
EPA 353.2 mg/l 0.05
EPA 353.2 mg/l 0.05
Signed
93 02/15/90 OR
0.15 02/15/90 OR

- ----- ENI Alt ro- - RE -31D
m� A-� IM I IUI)11%L. LMDUI11A I UnIVO
112 TOWNPARK DRIVE
--7
SAMPLING NAME OF FACILITY: -5curlll�Al :5 7,472��-S
V KENNESAW, GEORGIA 30144
INFORMATION
STREET ADDRESS:
[phone]
CITY/STATE: zll-:
PROJECT N.AME
JOB NO.
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SAMPLERS (SIG
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RELINQUISHED BY: DATE/TIME RECEIVED BY: RELINQUISHED PY: RECEIVED BYi DATE/TIME
(SIGNATURE) (SIGNATURE) (SIGNATURE) (SIGNATURE) I
RELINQUISHED BY:
DATE/TIME
RECEIVED BY:
RELINQUISHED BY:
(SIG NATUR E)
- - - .-- .
VIVE
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(SIGNATUR
(S I G N A T U R E)
DISTRIBUTION: ORIGINAL AND YELLOW COPIES ACCOMPANY SAMPLE SHIPMENT TO LABO 202k4 7550
PINK COPY RETAINED BY SAMPLERS. YELLOW COPY RETAINED 13Y LABORATORY.
REMARKS: —ASIAL5-1.5. : 1117-84,725 A1,17X,72�7-
C-- .' �/ iiECOVERY WELL - RW
'--s-6uncir RCRA MONITORING WELL - MW
CODES: SOIL/S ED IMENT - SO
SLUDGE - SL
NPI);7' DISCHARGE - ND
Df7I.'?KyP-IG WPTER - DW
HAZARDOUS WASTE - HW