WQ0002702_Regional Office Historical File Pre 2018 (6)

s e
NCDENR
North Carolina Department of En ironment and Natural Resources
Division of ater Quality
Beverly Eaves Perdue Coleen H. ullins
Governor Direct r
August 5, 2010
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Randall Andrews, Registered Agent
ALCHEM, Inc.
2042 Buie Philadelphus Road
Red Springs, NC 28138
and
ALCHEM, Inc.
8135 Red Road
Rockwell, NC 28138
Dee Freeman
Secretary
SUBJECT: Assessment of Civil Penalty for
Violations of NC General Statute 143-215.1 (6) and
Non -Discharge Permit No. WQ0016338
Non -Discharge permit No. WQ0002702
Case No. PC-2010-0064
NOV-2010-PC-0438
Rowan County
Dear Mr. Andrews:
This letter transmits notice of a civil penalty assessed against ALCHEM, Inc. in the amount of $43,018.16,
which includes $1,018.16 in investigative costs. A copy of the assessment document explaining this penalty is
attached.
This action was taken under the authority vested in me by delegation provided by the Secretary of the
Department of Environment and Natural Resources and the Director of the Division of Water Quality. Any
continuing violation(s) may be the subject of a new enforcement action, including an additional penalty.
Within thirty days of receipt of this notice, you must do one of the following three items:
1. Please submit payment of the penalty:
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone] Customer Service:1-877-623-6748
Intemetwww.ncwaterquality.org
Nne
orthCarolina
NahlrallY
An Equal Opportunity 1 Affirmative Action Employer

A ®"
ALCHEM, Inc. Assessment- „
WQ0016338 and WQ0002702
August 5, 2010
Payment should be made directly to the order of the Department of Environment and
Natural Resources (do not include waiver form). Payment of the penalty will not
foreclose further enforcement action for any continuing or new violation(s). Please
submit payment to the attention of:
Mr. Ed Hardee
DWQ/Aquifer Protection Section
1636 Mail Service Center
Raleigh, North Carolina 27699-1636
2. Submit a written request for remission or mitigation including a detailed justification for
such request:
A request for remission or mitigation is limited to consideration of the reasonableness of the
amount of the penalty and is not the proper procedure for contesting the accuracy of any of the
statements contained in the assessment document. Because a remission request forecloses
the option of an administrative hearing, such a request must be accompanied by a waiver of
your right to an administrative hearing and a stipulation that there are no factual or legal issues
in dispute. You must execute and return to this office the attached waiver and stipulation form,
the Justification for Remission Request and a detailed statement, which you believe establishes
whether:
(a) one or more of the civil penalty assessment factors in G.S. 143B-282.1(b) were
wrongfully applied to the detriment of the petitioner;
(b) the violator promptly abated continuing environmental damage resulting from the
violation;
(c) the violation was inadvertent or a result of an accident;
(d) . the violator had been assessed civil penalties for any previous violations;
(e) payment of the civil penalty will prevent payment for the remaining necessary remedial
actions.
Please submit this information to the attention of: , ,
Mr. Ed Hardee
DWQ/Aquifer Protection Section
1636 Mail Service Center
Raleigh, North Carolina 27699-1636
Please note that all information presented in support of a request for remission must be
submitted in writing. The Director of the Division of Water Quality will review the information and
inform you of her decision in the matter of the remission request. Her response will provide
details regarding case status, directions for payment and provision for further appeal of the
penalty to the Environmental Management Commission's Committee on Civil Penalty

ALCHEM, Inc. Assessment
W00016338 and WQ0002702
August 5, 2010
Remissions. Please be advised that the Committee cannot consider information that was not
part of the original remission request considered by the Director, and therefore, it is very
important that you prepare a complete and thorough statement in support of your request for
remission.
3. File a petition for an administrative hearing with the Office of Administrative Hearings:
If you wish to contest any statement in the attached assessment document you must file a
petition for an administrative hearing. You may obtain the petition form from the Office of
Administrative Hearings. You must file the petition with the Office of Administrative Hearings
within thirty (30) days of receipt of this notice. A petition is considered filed when it is received
in the Office of Administrative Hearings during normal office hours. The Office of Administrative
Hearings accepts filings Monday through Friday between the hours of 8:00 a.m. and 5:00 p.m.,
except for official state holidays. The original and one (1) copy of the petition must be filed with
the Office of Administrative Hearings. The petition may be faxed - provided the original and one
copy of the document is received in the Office of Administrative Hearings within five (5)
business days following the faxed transmission.
The mailing address for the Office of Administrative Hearings is:
Office of Administrative Hearings
6714 Mail Service Center
Raleigh, North Carolina 27699-6714
Telephone [phone] Facsimile [phone]
A copy of the petition must also be served on DENR as follows:
Ms. Mary Penny Thompson, General Counsel
Department of Environment and Natural Resources
1601 Mail Service Center
Raleigh, North Carolina 27699-1601
Please mail or hand deliver a copy to:
Mr. Ed Hardee
DWQ/Aquifer Protection Section
1636 Mail Service Center
Raleigh, North Carolina 27699-1636
Please indicate the case number (as found on page one of this letter) on the petition.
Failure to exercise one of the options above within thirty (30) days of receipt of this letter, as evidenced by an
internal date/time received stamp (not a postmark), will result in this matter being referred to the Attorney
General's Office for collection of the penalty through a civil action. Please be advised that additional penalties
may be assessed for violations that occur after the review period of this assessment.

ALCHEM, Inc. Assessment
WQ0016338 and W00002702
August 5, 2010
If you have any questions, please contact me at [phone] or Mr. Ed Hardee at [phone].
Sincerely,
1��-/ r
Andrew H. Pitner, P.G.
Environmental Program Supervisor III
Aquifer Protection Section
Mooresville Regional Office
ATTACHMENTS
cc: Ed Hardee, DWQ APS Central Office w/attachments
Case # PC-2010- 0064 w/ attachments
APS Central Files w/ attachments
Anita LeVeaux, Attorney General's Office, Environmental Division

STATE OF NORTH CAROLINA
COUNTY OF ROWAN
IN THE MATTER OF:
ALCHEM INCORPORATED
FOR VIOLATIONS OF
PERMIT NO. WQ0016338,
PERMIT NO. WO0002702
AND N.C.G.S. 143-215.1
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL
RESOURCES
File No. PC-2010-0064
FINDINGS AND DECISION
AND ASSESSMENT OF CIVIL PENALTIES
Acting pursuant to delegation provided by the Secretary of the Department of Environment
and Natural Resources and the Director of the Division of Water Quality, I, Andrew H. Pitner,
P.G., Environmental Program Supervisor III of the Mooresville Regional Office (MRO) Aquifer
Protection Section (APS) of the Division of Water Quality (DWQ), of the North Carolina
Department of Environment and Natural Resources, make the following:
FINDINGS OF FACT:
A. ALCHEM INCORPORATED (herein referred to as ALCHEM) is a corporation organized
and existing under the laws of the State of North Carolina. ALCHEM operates a washwater
recycle system and a bauxite residuals disposal (monofill) system in Rockwell, North
Carolina, Rowan County. The registered agent for ALCHEM is Randall Andrews.
B. The Non -Discharge Permit WQ0002702 was issued December 28, 2004. It allows
ALCHEM to recycle washwater from the production of alum and to store the resulting
bauxite residuals in on -site lagoons. Permit WQ0002702 expires on November 30, 2012.
C. The Non -Discharge Permit No. WQ0016338 was issued Dec. 28, 2006. It allows ALCHEM
to dispose of the spent bauxite residuals on site, after they meet certain conditions, or be
disposed of in a subtitle D landfill. The permit was adjudicated by Alchem. A settlement
agreement between Alchem and DWQ was filed on November 27, 2007, making the permit
effective. Permit WQ0016338 expires on November 30, 2014.
D. On April 14, 2010, the facility was inspected by DWQ staff from the Mooresville Regional
Office using the permit conditions contained in the most recent permits as well as the terms
settlement agreement. On April 26, 2010, a follow-up inspection of the facility was
conducted by DWQ staff from the Mooresville Regional Office.
Said permits contain the following relevant conditions with inspection findings:
1. WQ0002702, Condition 13 requires the recycled water to be maintained at a pH of 6.0
Standard Units as it goes to the storage lagoons. The production records do not
document pH readings for all the batches. In addition, the pH readings from the three
lagoons which were taken by APS staff during the April 14, 2010, inspection indicated all
the values to be well below 6.0 S.I.

ti-
2. WQ0002702, Condition 10 requires two feet of freeboard in all lagoons. ALCHEM staff
was advised of freeboard concerns during the April 14, 2010, inspection. During the
follow-up inspection on April 26, 2010, APS staff measured freeboard at four points on
the northern half of lagoon #1. Freeboard measurements ranged from 11 to 22 inchs
and spent bauxite solids were piled higher than the grade of the lagoon.
3. WO0002702, Condition 12 requires vegetative cover to be maintained. There was no
protective vegetative cover on any of the lagoon berms during the April 14, 2010
inspection.
4. WQ0002702, Condition 22 requires maintenance of an inspection log of the recycle
facility. No such log was available for review during April 14, 2010, inspection.
5. WQ0002702, Condition 28 and WQ0016338, Condition 111.6 (mis-numbered on page 5 of
the permit) both require the permittee to report noncompliance. Lagoon activity records
for 2009 are incomplete and noncompliant pH readings were not reported to the division.
No notice was filed with the division regarding failure to maintain the required freeboard.
6. WQ00163381 Condition 111.2 requires maintenance of records tracking all application
activities such as location of residuals utilization and volume disposed. A report from
Delta Environmental indicated that lagoon #3 was inspected in September 2009 after
cleanout but there was no docmentation in the 2009 Annual Report of where the spent
bauxite went for disposal.
7. WQ0016338, Condition 111.3 requires residual analyses to be conducted twice per year
for metals, pH, and phosphorus. Only one analysis for metals was included in the 2009
Annual Report.
8. WQ0016338, Condition 111.6 requires maintenance of records for five years tracking all
application activities associated with the surface disposal unit, including:
a) Date and freeboard level measurements.
b) Source and date of residuals disposed of in the surface disposal unit.
c) Cumulative volume of residuals disposed in the surface disposal unit.
d) Remaining volume in the surface disposal unit.
e) An estimate of remaining useful life for the surface disposal unit
No records were available during the April 14, 2010, inspection to document any of
these activities/evaluations.
9. WQ0016338, Condition V.1 requires maintenance of an inspection log for residuals
storage, transport and the disposal facilities. No such log was available for review
during the inspection on April 14, 2010.
E. On June 10, 2010, DWQ issued a Notice of Violation (NOV)/Notice of Intent (NOI) to
Enforce to ALCHEM, identfying violations of Non -Discharge Permits WQ0002702 and
WQ00016338.
F. Staff costs and expenses associated with observing the violations, defining their nature and
bringing enforcement action totaled $ 1318.16.

Based upon the above Findings of Fact, I make the following:
II. CONCLUSIONS OF LAW:
A. ALCHEM is a "person" within the meaning of G.S.143-215.6A pursuant to G.S. 143-212(4).
B. Permit No. WO0016338 is required by N.C.G.S. 143-215.6A. It was issued on December
28, 2006, and became effective and enforceable on November 27, 2007. The permit expires
on November 30, 2014.
C. Permit No. WQ0002702 is required by N.C.G.S. 143-215.6A. It was issued on December
28, 2004. The permit expires on November 30, 2012.
D. ALCHEM violated N.C.G.S. 143-215.1 and Permit WQ0002702 to the manner and extent as
described in Condition 13 by failing to maintain the recycled water at a pH of 6.0 Standard
Units as it goes to the storage lagoons.
E. ALCHEM violated N.C.G.s. 143-215.1 and Permit WQ0002702 to the manner and extent as
described in Condition 10 by failing to maintain two feet of freeboard in all lagoons.
F. ALCHEM violated N.C.G.s. 143-215.1 and Permit WQ0002702 to the manner and extent as
described in Condition 12 by failing to maintain protective vegetative cover on lagoon berms.
G. ALCHEM violated N.C.G.S. 143-215.1 and Permit WQ0002702 to the manner and extent as
described in Condition 22 by failing to maintain an inspection log for the recycle facility.
H. ALCHEM violated N.C.G.S 143-215.1, Permit WQ0002702 Condition 28, and Permit
WQ0016338 Condition 111.6 (mis-numbered on page 5 of the permit) to the manner and
extent as described by failing to report noncompliance.
I. ALCHEM violated N.C.G.S. 143-215.1 and Permit WQ0016338 to the manner and extent as
described in Condition 111.2 by failing to maintain records to track all application activities
such as location of residuals utilization and volume disposed.
J. ALCHEM violated N.C.G.S. 143-215.1 and Permit WO0016338 to the manner and extent as
described in Condition 111.3 by failing to submit residuals analysis for metals twice a year in
2009.
K. ALCHEM violated N.C.G.S. 143-215.1 and WQ0016338 to the manner and extent as
described in Condition 111.6 by failing to maintain tracking records for all application activities
associated with the surface disposal unit.
L. ALCHEM violated N.C.G.S. 143-215.1 and Permit WQ0016338 to the manner and extent
described in Condition VA by failing to maintain a log of inspections of the residuals stroage,
transport, and disposal facilities.
M. General Statute 143-215.6A(a)(2) provides that a civil penalty of not more than $25,000.00
per violation may be assessed against a person who violates or fails to act in accordance
with the terms, conditions, or requirements of a permit required by N.C.G.S. 143-215.1.

N. General Statute 143-215.3(a)(9) provides that the reasonable costs of any investigation,
inspection or monitoring survey may be assessed against a person who violates any
regulations, standards, or limitations adopted by the Environmental Management
Commission or violates any terms or conditions of any permit issued pursuant to N.C.G.S.
143-215.1, or special order or other document issued pursuant to N.C.G.S. 143-215.2.
O. The Regional Supervisor of the Mooresville Aquifer Protection Section, Division of Water
Quality, pursuant to delegation provided by the Secretary of the Department of Environment
and Natural Resources and the Director of the Division of Water Quality has the authority
to assess civil penalties in this matter.
Based upon the above Findings of Fact and Conclusions of Law, I make the following:
III. DECISIONS:
Pursuant to N.C.G.S. 143-215.6A in determining the amount of the penalty, I have taken into
account the Findings of Fact and Conclusions of Law and considered all the factors listed in
N.C.G.S. 14313-282.1.
Accordingly, ALCHEM shall be, and hereby is, assessed a civil penalty of:
$ 16,000.00 for one violation of N.C.G.S. 143-215.1 and Permit WQ0002702
by failing to maintain the recycled water at a pH of 6.0 Standard
Units as it goes to the storage lagoons.
$ 5,000.00
$ 1,000.00
$ 2,000.00
$ 2,000.00
$ 5,000.00
$ 4,000.00
for one violation of N.C.G.S. 143-215.1 and Permit WQ0002702
by failing to maintain two feet of freeboard in all lagoons
for one violation of N.C.G.S. 143-215.1 and Permit WQ0002702
by failing to maintain protective vegetative cover on lagoon berms.
for one violation of N.C.G.S. 143-215.1 and Permit WQ0002702
by failing to maintain an inspection log for the recycle facility.
for one violation of N.C.G.S. 143-215.1, Permit WO0002702, and
Permit WQ0016338 by failing to report noncompliance.
for one violation of N.C.G.S. 143-215.1 and Permit WQ0016338
by failing to maintain records to track all application activities such
as location of residuals utilization and volume disposed.
for one violation of N.C.G.S. 143-215.1 and Permit WQ0016338
by failing to submit residuals analysis for metals twice a year in
2009.
$ 5,000.00 for one violation of N.C.G.S. 143-215.1 and Permit WQ0016338
by failing to maintain tracking records for all application activities
associated with the surface disposal unit such as freeboard
measurements, source and date of disposal, cumulative disposal,
remaining volume and useful disposal life.

$ 2,000.00 for one violation of N.C.G.S. 143-215.1 and Permit WO0016338
by failing to maintain a log of inspections of the residuals stroage,
transport, and disposal facilities.
$ 42,000.00 TOTAL CIVIL PENALTY, which is 18 percent of the maximum
penalty authorized by G.S. 143-215.6A.
$ 1,018.16 Investigation and Enforcement costs assessed.
$ 43,018.16 TOTAL AMOUNT DUE
Pursuant to N.C.G.S. 143-215.6A in determining the amount of the penalty, I have taken into
account the Findings of Fact and Conclusions of Law and considered all the factors listed in
N.C.G.S. 14313-282.1, which are:
1) The degree and extent of harm to the natural resources of the State, to the public
health, or to private property resulting from the violation;
2) The duration and gravity of the violation;
3) The effect on ground or surface water quantity or quality or on air quality;
4) The cost of rectifying the damage;
5) The amount of money saved by non-compliance;
6) Whether the violation was committed willfully or intentionally;
7) The prior record of the violator in complying or failing to comply with programs over
which the Environmental management Commission has regulatory authority; and
8) The cost to the State of the enforcement procedures.
IV. NOTICE:
I reserve the right to assess civil penalties and investigative costs for any continuing violations
occurring after the assessment period indicated above. Each day of a continuing violation may
be considered a separate violation subject to a maximum $25,000.00 per day penalty. Civil
penalties and investigative cost may be assessed for any other rules and statutes for which
penalties have not yet been assessed.
V. TRANSMITTAL:
These Findings of Fact, Conclusions of Law and Decision shall be transmitted to
ALCHEM Incorporated in accordance with N.C.G.S. 143-215.6(A)(d).
(Date) Andrew H. Pitner, P.G.
Environmental Program Supervisor III
Aquifer Protection Section
Mooresville Regional Office

JUSTIFICATION FOR REMISSION REQUEST
Case Number: PC-2010-0064 County: Rowan
Assessed Party: ALCHEM Incorporated
Permit No. (if applicable): WO0016338 &WQ0002702 Amount assessed: $43,018.16
Please use this form when requesting remission of this civil penalty. You must also complete
the "Request For Remission Waiver of Right to an Administrative Hearing and Stipulation of
Facts" form to request remission of this civil penalty. You should attach any documents that you
believe support your request and are necessary for the Director to consider in determining your
request for remission. Please be aware that a request for remission is limited to consideration
of the five factors listed below as they may relate to the reasonableness of the amount of the
civil penalty assessed. Requesting remission is not the proper procedure for contesting whether
the violation(s) occurred or the accuracy of any of the factual statements contained in the civil
penalty assessment document. By law [NCGS 133-215.6A(f)] remission of a civil penalty may
be granted when one or more of the following five factors applies. Please check each factor
that you believe applies to your case and provide a detailed explanation, including copies of
supporting documents, as to why the factor applies (attach additional pages as needed).
(a) one or more of the civil penalty assessment factors in NCGS 143B-282.1(b) were
wrongfully applied to the detriment of the petitioner (the assessment factors are
included in the attached penalty matrix and/or listed in the civil penalty
assessment document);
(b) the violator promptly abated continuing environmental damage resulting from the
violation (i.e., explain the steps that you took to correct the violation and prevent
future occurrences);
(c) the violation was inadvertent or a result of an accident (i.e., explain why the
violation was unavoidable or something you could not prevent or prepare for);
(d) the violator had not been assessed civil penalties for any previous violations;
_ (e) payment of the civil penalty will prevent payment for the remaining necessary
remedial actions (i.e., explain how payment of the civil penalty will prevent you
from performing the activities necessary to achieve compliance).
EXPLANATION:

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT
AND NATURAL RESOURCES
COUNTY OF ROWAN
IN THE MATTER OF ASSESSMENT)
OF CIVIL PENALTIES AGAINST )
ALCHEM INCORPORATED )
Permit No. WO0016338 and )
Permit No. WQ00002702 )
WAIVER OF RIGHT TO AN
ADMINISTRATIVE HEARING AND
STIPULATION OF FACTS
FILE NO. PC-2010-0064
Having been assessed civil penalties totaling $43,018.16 for violations as set forth in the
assessment document of the Division of Water Quality, Aquifer Protection Section dated
August 5, 2010 the undersigned, desiring to seek remission of the civil penalties, does hereby
waive the right to an administrative hearing in the above -stated matter and does stipulate that
the facts areas alleged in the assessment document. The undersigned further understands that
all evidence presented in support of remission of this civil penalty must be submitted to the
Director of the Division of Water Quality within 30 days of receipt of the notice of assessment.
No new evidence in support of a remission request will be allowed after 30 days from the receipt
of the notice of assessment.
This the day of 120
Signature
ADDRESS
TELEPHONE

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1. Article Addressed to:
Randall Andrews. Registered - Agent
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2042 Buie Philadelphus Rd.
Red Springs NC 28377
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1-1 CAROLINA
VAN
ALCHEM, INC.,
Petitioner,
V.
NORTH CAROLINA DEPAI;CFMENT OF
ENVIRONMENT AND NATURAL
RESOURCES, DIVISION OF WATER
QUALITY,
Respondent.
IN THE OFFICE OF
ADMINISTRATIVE HEARINGS
10 EHR 00296
10 EHR 05463
RESPONDENT'S MOTION
TO RETURN CASE TO
THE GENERAL COURT OF JUSTICE
OR DISMISS WITH PREJUDICE
NOW COMES Respondent, North Carolina Department of Environment and Natural
Resources, Division of Water Quality ("DWQ"), by and through its undersigned attorney, Anita
LeVeaux, Assistant Attorney General, pursuant to NC Gen. Stat. § 150B-33(8) and moves this
Court to return the hearing in this contested case to the General Court of Justice in Rowan
County or in the alternative, pursuant to NC Gen. Stat. § 41(b) to issue a dismissal with
prejudice. In support of this Motion, the Respondent shows the following:
1. The individual cases were consolidated to be heard before the Honorable Beecher
R. Gray on March 14, 2011.
2. On June 13, 2011, the parties to this contested case proceeding entered into a
Consent Order which settled the contested case, signed by the Honorable Beecher Gray.
Consistent with the terms therein, Alchem agreed to pay a total of seventy thousand forty-two
hundred dollars and eighty-two cents ($70,042.82). A copy of the Consent Order is attached
hereto and incorporated herein as Exhibit A.

3. Petitioner made four (4) payments through its counsel totaling
dollars ($6,000.00), leaving a balance of sixty-four thousand forty-two hundred dollars and
eighty-one cents ($64,042.81) owed to DWQ. Payments were acknowledged upon receipt and
copies are attached hereto and incorporated herein as Exhibit B.
4. . Petitioner asserts without supporting documentation, that the corporation has
dissolved and has no money. Upon this assertion, Respondent asked the Honorable Judge Gray
to have the Petitioner appear and show cause. On April 9, 2012, Respondent filed a motion for
an order directing Petitioner to appear and show cause why it should not be held in civil
contempt.
5. On May 8, 2012, Respondent's motion for an order was denied in an Order from
Judge Gray noting that there were no grounds for the Order.
6. Respondent has secured a copy of Petitioner's Certificate of Administrative
Dissolution dated November 30, 2012. This dissolution is not a legal dissolution of the
corporation. Once a corporation has been administratively dissolved, the only requirement for
reinstatement is that an Application for Reinstatement be filed.
7. There is nothing in the record which shows that the Articles of Dissolution for the
legal dissolution of the corporation have been tiled consistent with applicable NC Statutes
including NC Gen. Stat. §§ 55-14-01 through 55-14-03. Accordingly, Respondent submits that
Alchem continues to be a viable entity under the jurisdiction of OAH consistent with the above
Consent Order.
8. NC Gen. Stat. § 150B-33 (b)(8) provides that. an Administrative Law
Judge may issue an order returnable in the General Court of Justice, Superior Court Division to

show cause why the person should not be held in contempt. Respondent asks this court to enter
an order to return this case to the General Court of Justice, Rowan County, Superior Court
Division.
9. In the alternative, because of Petitioner's failure to comply with the terms of this
Consent Order, Respondent, pursuant to Rule 41(b), requests that the Administrative Law Judge
dismiss this matter with prejudice so that legal action may be pursued in Rowan County Superior
Court.
WHEREFORE, Respondent prays for an Order granting its MOTION TO RETURN
THIS CASE TO T -GENERAL COURT OF JUSTICE or DISMISS WITH PREJUDICE.
This the l day of ` , 2013.
ROY COOPER
Attorney Gene
Anita LeVeaux
Assistant Attorney General
N.C. Bar No. 13667
N. C. Department of Justice
Environmental Division
Post Office Box 629
Raleigh, NC 27602-0629
[phone]/ Tel
[phone]/Fax
aleveaux a,ncdo�ov

STATE OF NORTH CAROLINA IN THE OFFICE OF
ADIv INISTRATIVE HEARINGS
COUNTY OF ROWAN 10 EHR 0296 AM
10 EHR 5463
Alchem, Inc.-,
Petitioner, )
CONSENT ORDER
V. )
}
N.C. Dept. of Environment and Natural )
Resources, Division of Water Quality, )
Respondent. )
EXHIBIT
it A
The Honorable Beecher R. Gray, Administrative Law Judge of the Office of
Administrative Hearings and counsel for the parties were heard in open court upon the
calendaring of the above contested case hearing on March 4, 2011. This matter was brought
before the Honorable Beecher R. Gray after the parties successfully mediated the contested case
issues on March 4, 2011. The parties, Alchem, Inc. ("Petitioner"), and the North Carolina
Division of Water Quality ("DWQ") of the North Carolina Department of Environment and
Natural Resources, ("Respondent"), hereby enter into this "Consent Order" in order to resolve
this matter in controversy, as set out below, pursuant to N.C. Gen. Stat. § 150B-31(b).
This matter comes within Respondent's purview as it relates to matters which concern
Petitioner's Non -discharge Permits WQ0016338 and WQ0002702 and two Assessments of
Civil Penalties in the amounts of twenty-seven thousand twenty-four dollars and sixty-five cents
($27,024.65) including $1,024.65 in investigative costs and forty-three thousand eighteen dollars
and sixteen cents ($43,018.16) including $1,018.16 in investigative costs resulting in a total
Assessment of Civil Penalties in the amount of seventy thousand forty-two dollars and eighty-
one cents ($70,042.81).
The undersigned further agreed that the Office of Administrative Hearings shall retain its
jurisdiction over this Consent Order until this civil penalty assessment is paid in full consistent
with the terms set out below, or on or before March 31, 2014.
NOW, THEREFORE, without any trial of fact or law in this matter, in mutual
consideration of the covenants set forth below, and with the consent of the parties, it is hereby
OREDERED, ADJUDGED AND DECREED that:

Administrative Hearings has jurisdiction to hear this case pursuant to N.C.
150B-23 and 130A-22(e).
ie been correctly designated and are properly before the Office of
Administrative Hearings. The Office of Administrative Hearings has jurisdiction over
the parties and the subject matter.
3. The Petitioner will pay a total of seventy thousand forty-two dollars and eighty-one cents,
$70,042.81 ("Settlement Amount % which includes investigative costs.
4. The Settlement Amount shall be paid in thirty-six monthly payments, beginning April 1,
2011, of $1,500.00 per month for the first twelve months; and $2,168.45 for the
remaining twenty-four months to DENR, the Division of Water Quality.
5. The payments shall be paid by check made payable to the "North Carolina Department
Environment and Natural Resources" or to "DENR, Division of Water Quality" at the
following address:
Anita LeVeaux
Attorney General's Office
Environmental Protection Division
9001 Mail Service Center
Raleigh, NC 27699-9001
6. The breach of any condition of Paragraphs one, two, three or four by Petitioner will
render immediately due and payable the Total Civil Penalty Assessment, seventy
thousand, forty-two dollars and eighty-one cents, $70,042.81, the. Petitioner will be given
credit for all prior payments.
7. Petitioner and DENR expressly stipulate and acknowledge that, by entering into this
Agreement, the sole issue in any action by DENR is to collect the Total Civil Penalty
Assessment amount of the civil penalty assessment, as set out above; in accordance with
the terms of paragraph four above and will be limited to the Petitioners' compliance with
the terms of this Agreement. Only as it relates to the matters before this tribunal, i.e.,
Case PC-2009-0121, NOV-2009-PC-0470; and Case PC-2010-0064, NOV-2010-PC-
043 8.
8. DENR agrees to accept the Settlement Amount in complete satisfaction of the civil
penalty assessments subject to the terms of this Agreement, i.e., "the permit conditions
violations of 2009 and 2010" only DENR Case No. PC-2009-0121, NOV-2009-PC-0470;
and Case PC-2010-0064, NOV-2010-PC-0438.

Z5
Nothing in this Agreement shall restrict any right of Respondent to take
action against Petitioner for any pending or future violations as it relate
No.8 above.
10. This Agreement shall be binding upon the parties and is entered into knowingly,
intelligently, and voluntarily.
11. Defendant Alchem, Inc. shall, on or before April 1, 2011, pay $1,500.00, monthly for the
first twelve months and $2168.45 for the remaining twenty-four months consistent with
the terms of this Consent Order.
12. The parties shall comply with all terms of this Consent Order.
13. Nothing in this Consent Order shall restrict the right of Petitioner to contest a new or
subsequent enforcement action arising outside of the aforesaid rules and regulations.
14. The Court shall retain continuing jurisdiction in this case until all parties have complied
with all provisions of this Consent Order. Full compliance with the terms and conditions
of this Consent Order as set forth, above, shall complete this matter.
15. The contempt provisions of Article 2, Chapter SA of North Carolina General Statutes
shall be available to enforce this Consent Order.
16. This Consent Order may be signed out -of -court, out -of -term, out -of -county and out -of
district.
17. Judge Beecher R. Gray and the parties further agreed that the deadline for completion of
payments shall be on or before the March 31, 2014.
THEREFORE, with the consent of the parties as evidenced by the signatures below, it is
hereby ordered that the Respondent will make a payment of $1,500.00, monthly for the first
twelve months and $2168.45 for the remaining twenty-four months until the total Settlement
Amount has been paid starting April 1, 2011. Failure to make timely payments will result in the
full and complete payment of the civil penalty assessed becoming due and payable to the
Respondent, i.e., seventy thousand forty-two dollars and eighty-one cents ($70,042.81) minus
any and all prior payments.
This the day of March 2011.
Av"nqko /'?
Beecher R. Gray
Administrative Law Judge Presiding
Office of Administrative Hearings

Roy Cooper
Attorney General
Anita LeVeaux
Assistant Attorney
for Respondent
L7s*L I\,
rlhk�
, as
�kvl
Woodson, Sayers, Lawther
Short, Parrott, Walker and Abramson, LLP
Attorney for Petitioner
Andrew H. Pitner Randall Andrews
Environmental Program Supervisor III President,
DWQ, Aquifer Protection, MRO Alchem, Inc.
Petitioner

A copy of the foregoing was mailed to:
Sean C Walker
Woodson Sayers Lawther Short
Parrott & Walker LLP
PO Box 829
`Salisbury, Arc 28145
ATTORNEY FOR PETITIONTR
Anita LeVeaux
Assistant Attorney General
NC Department of Justice
9001 Mail Service Center
Raleigh, ArC 27699-9001
ATTORNEY FOR RESPONDENT
-Thus the 14th day of June, 2011.
Office o£Admimstrative Hearings
6714 Mail Service Center
Raleigh, NC 27699-,6714
(919) .4,313000

KVY GVVtrirt[
nrrORNEY GENMIAl-
..airs= �Oyo�J
s EXHIBIT
��. B
State of North Carolina
Department of Justice 111"PL Y TO: Amanda Foster
linvironmenlal DiAMoo
11'0 BOX 629 Telephone: 919i716-6600
Ralelg4l, North Carolina Fax: [phone]
27602
Nlay 19, 2011
Mr. Sean C. Walker
Attorney at Law
PO" Box 829
Salisbury, north Carolina 28145-0829
SUBJECT: Civil Penalty Assessment Payment for- Alchenr, Inc., 10 ERR 0296, 10
- EFIR 5463, Rowan County
Dear Mr. Walker:
This letter acknowledges receipt of check number 27012, dated April 15, 2011, in the
amount,of $1,500.00 and check number 27036, dated May 2, 2011, in the amount of S1,500.00,
which leaves a balance due of $67,042.81. In accordance with the Consent Order the settlement
amount shall be paid in thirty-six monthly payments, beginning April 1, 2011, of$1,500.00 por
month for the first twelve months, and S2,168:45 for the reinaining twenty-four months.
Thank you for your payment and it will be credited to the account. For your convenience
you will find enclosed a self-addressed envelope for your next: payinent. Please Mote that all
checks should be nlarle hnhabie to. NCDLNR.
Sincerely,'
Amanda Foster
Program Assistant
Enclosure
cc: Anita LeVeaua

y�`fMSTN nHo'
f
State of North Carolina
ROY COOPER Department of Justice
/Vi"170ANilY GENERAL PO Box 629
Raleigh, North Carolina
27602
June 21, 2011
Mr_ Sean C. Walker
Attorney at Law
PO Box 829
Salisbury, North Carolina 28145-0829
RE
++ 4i........ 10, 1J1\'1]11111
r�iepnono: 919/716-66 m
nix:,)igni6-o767
SUBJECT: Civil.Penalty Assessment Payment for-,41chen:, Ine., 10 EHR 0296, 10
EHR 5463, Rowan County
Dear Mr. Walker;
This letter acknowledges receipt of check number 27094, dated June 6, 2011, in the
amount of $1,500.00. Thank you for your payment and it will be credited to your account. As a
reminder, there is still a balance of$65,542.81 due on tits account. For your convenience you
will bind enclosed a self-addressed envelope for your next payment.
Sincerely,
Amanda Foster
Program Assistant
Enclosure
cc: Anita LeVeaux
0

NITORMY GENERAL
a
State of North Carolina
Del)artment of justice
PO Box 629
Raleigh, North Carolina
27602
June 30, 2011
-Mr, Sean C. Walker
Attorney at Law
PO'Box 829
Salisbury, North Carolina 28145-0829
RIPPLY TO: Amanda Poster
1'sitvirotlnlanlal Division
rdephone: 919/716.6600
Fax: 919n16-6767
SUBJECT: Civil Penalty Assessment Payment for- Alchem, Inc., 10 EHR 0296, 10
EHR 5463, Rogan County
Dear Mr. Walker:
This letter acknowledges receipt of check number 27137, dated June 27, 2011, in the
amotint of $1,500.00. Thank you for your payment and it will be credited to your account. As a
reminder, there is still a balance of $64,042.81 due on the account. For your convenience you
will find eficlosed a self-addressed envelope for your next payment.
Enclosure
Sincerely,
Amanda Foster
Program Assistant
cc: Anita LeVeaux
0

CERTIFICATE OF SERVICE
I, Anita LeVeaux, do hei eby certify that a copy of the foregoing MO1 wiN I U icr_, t UIUN
'I'I-IIS CASE TO "TI-IE GENERAL COURT OF JUSTICE or DISMISS WITH PREJUDICE has been
served upon Petitioner by depositing a copy of the same in the care and custody of the United States
Postal Service, first-class mail, postage prepaid and addressed as follows:
Sean C. Walker, Esq.
Woodson Sayers Lawther Short
Parrott & Walkrk, LLP
Post Office Box 829
Salisbury, NC 28145
ATTORNEYS FOR THE PETITIONER
This the fkday of �fa, 2013.
ROY COOPER
Attorney GeiA. ral' __.
Anita LeVeaux
Assistant Attorney General

rH CAROL INA
)WAN
ALCHEM, INC.,
Petitioner,
M
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL
RESOURCES, DIVISION OF WATER
QUALITY,
Respondent.
IN THE OFFICE OF
ADMINISTRATIVE HEARINGS
10 EHR 00296
10 EHR 05463
ORDER
THIS CAUSE came before the undersigned Administrative Law Judge on a Motion to Return
Case to the General Court of Justice or Dismiss with Prejudice. For good cause shown, it appears
to the Court that the motion should be allowed.
IT IS THEREFORE ORDERED, ADJUDGED AND DECREED that this case be returned
to the General Court of Justice pursuant to NC Gen. Stat. 150B 33-(b).
This the day of , 2013.
Beecher R. Gray
Administrative Law Judge

103
Sean C. Walker, Esq.
Woodson Sayers Lawther Short
Parrott R. Walerk, LLP
Post Office Box 829
Salisbury, NC 28145
ATTORNEYS FOR THE PETITIONER
Anita LeVeaux
Assistant Attorney General
N. C. Department of Justice
Environmental Division
Post Office Box 629
Raleigh, NC 27602-0629
ATTORNEYS FOR THE RESPONDENT

Subject:
Attachments:
LeVeaux, Anita [[e-mail]]
Friday, January 11, 2013 8:27 PM
Pitner, Andrew; Finley, Peggy
Alchem Motion
Alchem Motion.pdf
Andrew and Peggy:
Please note the attached consistent with our discussion earlier this week. Also, as discussed, if a matter at this site
needs immediate attention be mindful you would simply make a request for injunctive relief. Call if you have any
questions. Best, Anita

ATE OF NORTH CAROLINA IN THE OFFICE OF
"i i 's?' ADMINISTRATIVE HEARINGS
COUNTY OF ROWAN
Alchem, Inc.,
Petitioner,
V.
N.C. Dept. of Environment and Natural
Resources, Division of Water Quality,
Respondent.
l
10 EHR 0296
10 EHR 5463
CONSENT ORDER
The Honorable Beecher R. Gray, Administrative Law Judge of the Office of
Administrative Hearings and counsel for the parties were heard in open court upon the
calendaring of the above contested case hearing on March 4, 2011. This matter was brought
before the Honorable Beecher R. Gray after the parties successfully mediated the contested case
issues on March 4, 2011. The parties, Alchem, Inc. ("Petitioner"), and the North Carolina
Division of Water Quality ("DWQ") of the North Carolina Department of Environment and
Natural Resources, ("Respondent"), hereby enter into this "Consent Order" in order to resolve
this matter in controversy, as set out below, pursuant to N.C. Gen. Stat. § 150B-31(b).
This matter comes within Respondent's purview as it relates to matters which concern
Petitioner's Non -discharge Permits WQOO16338 and WQ0002702 and two Assessments of
Civil Penalties in the amounts of twenty-seven thousand twenty-four dollars and sixty-five cents
($27,024.65) including $1,024.65 in investigative costs and forty-three thousand eighteen dollars
and sixteen cents ($43,018.16) including $1,018.16 in investigative costs resulting in a total
Assessment of Civil Penalties in the amount of seventy thousand forty-two dollars and eighty-
one cents ($70,042.81).
The undersigned further agreed that the Office of Administrative Hearings shall retain its
jurisdiction over this Consent Order until this civil penalty assessment is paid in full consistent
with the terms set out below, or on or before March 31, 2014.
NOW, THEREFORE, without any trial of fact or law in this. matter, in mutual
consideration of the covenants set forth below, and with the consent of the parties, it is hereby
OREDERED, ADJUDGED AND DECREED that:

1. The Office of Administrative Hearings has jurisdiction to hear this case pursuant to N.C.
Gen. Stat. §§ 150B-23 and 130A-22(e).
2. All parties have been correctly designated and are properly before the Office of
Administrative Hearings. The Office of Administrative Hearings has jurisdiction over
the parties and the subject matter.
3. The Petitioner will pay a total of seventy thousand forty-two dollars and eighty-one cents,
$70,042.81 ("Settlement Amount"), which includes investigative costs.
4. The Settlement Amount shall be paid in thirty-six monthly payments, beginning April 1,
2011, of $1,500.00 per month for the first twelve months, and $2,168.45 for the
remaining twenty-four months to DENR, the Division of Water Quality.
5. The payments shall be paid by check made payable to the "North Carolina Department
Environment and Natural Resources" or to "DENR, Division of Water Quality" at the
following address:
Anita LeVeaux
Attorney General's Office
Environmental Protection Division
9001 Mail Service Center
Raleigh, NC 27699-9001
6. The breach of any condition of Paragraphs one, two, three or four by Petitioner will
render immediately due and payable the Total Civil Penalty Assessment, seventy
thousand, forty-two dollars and eighty-one cents, $70,042.81, the Petitioner will be given
credit for all prior payments.
7. Petitioner and DENR expressly stipulate and acknowledge that, by entering into this
Agreement, the sole issue in any action by DENR is to collect the Total Civil Penalty
Assessment amount of the civil penalty assessment, as set out above; in accordance with
the terms of paragraph four above and will be limited to the Petitioners' compliance with
the terms of this Agreement. Only as it relates to the matters before this tribunal, i.e.,
Case PC-2009-0121, NOV-2009-PC-0470; and Case PC-2010-0064, NOV-2010-PC-
043 8.
8. DENR agrees to accept the Settlement Amount in complete satisfaction of the civil
penalty assessments subject to the terms of this Agreement, i.e., "the permit conditions
violations of 2009 and 2010" only DENR Case No. PC-2009-0121, NOV-2009-PC-0470;
and Case PC-2010-0064, NOV-2010-PC-0438.

s Agreement shall restrict any right of Respondent to take any enforcement
Petitioner for any pending or future violations as it relates to Alchem. See
10. This Agreement shall be binding -upon the parties and is entered into knowingly,
intelligently, and voluntarily.
11. Defendant Alchem, Inc. shall, on or before April 1, 2011, pay $1,500.00, monthly for the
first twelve months and $2168.45 for the remaining twenty-four months consistent with
the terms of this Consent Order.
12. The parties shall comply with all terms of this Consent Order.
13. Nothing in this Consent Order shall restrict the right of Petitioner to contest a new or
subsequent enforcement action arising outside of the aforesaid rules and regulations.
14. The Court shall retain continuing jurisdiction in this case until all parties have complied
with all provisions of this Consent Order. Full compliance with the terms and conditions
of this Consent Order as set forth, above, shall complete this matter.
15. The contempt provisions of Article 2, Chapter SA of North Carolina General Statutes
shall be available to enforce this Consent Order.
16. This Consent Order may be signed out -of -court, out -of -term, out -of -county and out -of
district.
17. Judge Beecher R. Gray and the parties further agreed that the deadline for completion of
payments shall be on or before the March 31, 2014.
THEREFORE, with the consent of the parties as evidenced by the signatures below, it is
hereby ordered that the Respondent will make a payment of $1,500.00, monthly for the first
twelve months and $2168.45 for the remaining twenty-four months until the total Settlement
Amount has been paid starting April 1, 2011. Failure to make timely payments will result in the
full and complete payment of the civil penalty assessed becoming due and payable to the
Respondent, i.e., seventy thousand forty-two dollars and eighty-one cents ($70,042.81) minus
any and all prior payments.
This the ®T day of March 2011.
Beecher R. Gray
Administrative Law Judge Presiding
Office of Administrative Hearings

Roy Cooper
Attorney General,.--
C
Anita LeVeaux
Assistant Attorney General
for Respondent
Andrew H. Pitner
Environmental Program Supervisor III
DWQ, Aquifer Protection, MRO
SeVriV lker, Esq.
WOWO , Sayers, Lawther
Short, P tt, Walker and Abramson, LLP
Attorney for Petitioner
Randall Andrews
President,
Alchem, Inc.
Petitioner

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A copy of the foregoing was mailed to:
Sean C Walker
Woodson Sayers Lawther Short
Parrott & Walker LLP
PO Box 829
'Salisbury, NC 28145
ATTORNEY FOR PETITIONER
Anita LeVeaux
Assistant Attorney General
NC Department of Justice
9001 Mail Service Center
Raleigh, NC 27-699-9001
ATTORNEY FOR RESPONDENT
This the 14th day of June, 2011.
.�W 02
Office of Administrative Hearings
6714 Mail Service Center
Raleigh, NC 27699-6714
(919) 4313000
Fax: [phone]

RECEIVE®
JUN 15 2011
N.C. ATTORNEY GENERAL
Environmental Division

PLEASE PRIs 1 CLEARLY OR TYPE
0
TH CAROLINA
Y OF (1) ROWAN
(2) ALCHEM INC
(your name)
PETITIONER.
V.
(3) NCDENR
h1rD-T I G S
-SEP '. 20M
var!S(1r�t.rr�t�
PETIT tiNALJF: �:�!_' . '
`
t FOR A
' CONTESTED CASE HEARING
,
(The State agency or board about RESPONDEN
which V u are complaining) t
I hereby ask for a contested case hearing as provided for by North C';tn,ltna Cieneral Statute § 150B-23 because the Respondent has:
(Briefly state facts showing how you belie, e I uu have been harmed by the State agency or board.)
_ Re _NOV-2010—PC-0438 , Cased PC_2010-0064. The^person who wart chore �t the —III ��5
—Jason Desiato. Jason Desiato is a crintirtal; U- showed me records that showed ewer tt
to be within limits. He stole all of he records and was fired for stealin on A r_il 12g
aware
The entity that should bear this fide is Jason Desiato. P — --
aware of this, 4S $ er16ALCHEM ersonnel. were involved. I have made NCDENR personne
(4) Amount in controversy '+ 18 �f applicable)
(If more space is needed. attach additional pages.)
(5) Because of these facts. the State agency or board has: (check at let,,, ,ute from each column)
—X deprived me of property;
_ordered me to pay a fine or civil penalty; or —X —exceeded its authorit-, or jurisdiction;
_- otherwise substantially prejudiced my rights: —acted erroneously;
AND P _failed to use proper procedure;
,}acted arbitrarily or capricioush: or
(6) Date: 8-31-10
_Xlaw or al to act as required by l'
(71 1,wi phone number: (910) 84 r 121
(8) Print your full address: 8135 Red Rd. Rockwell, NC 28138
(9) Print your name: Randall street adrews box) —------_ _-_
(city) (state) ('-ip)
(10) Your signature: i }<iIIn a 11y-A X U lfli- .rl _ - ------ - -
You must mail deliver a COPY' of this Petition
board to determinene the name of thto the State a€e1 ,, aboard named on line (3) of this form
e person to be served.
You should contact the agenc. ,,,
ERT
I certify that this Petition has been served on the State agency o bIr,l 11am, OFed oS by pICtEg a copy of it with the United States PO ,
with sufficient postage affixed OR by delivering it to the named agcn: „r board: .>tal Service
{name of person served) — (I2) _NCT)FNR —
(13) 1601 Mail Service Center (state agency or board listed on line3)--------
(streetaddress/p.o. box) ---- . Ralezgh NC 2769 _
(city) (state) — tzi� code -- ------
04)Thisthe 31 _day of_ A ust _ --
'" IV -
When you have completed this form, you MUST mail or deliver the ORIGINAL AND ONE C'OPV to the Office of Adn
Mail Service Center, Raleigh, NC 27699-6714.
unistrative Hearings.
H-06 (0s/l o)

heet
NCDENR
Correspondence Tracking System
00309201003963
Summary
Petition for a Contested Case Hearing: Alchem, Inc. v. DENR,��
Received 09/07/2010 via Letter
Legal issue for Mary Penny Thompson
Issued 08/31/2010 by Randall Andrews of Alchem, Inc.
** For Recipient Use Only **
To:
Date: /
Respond By:
Please: Prepare a reply for my signature and return to me.
Reply, noting the letter was referred to you by me. *
Prepare a reply for the Govemor's signature and return to me.
Reply, noting the letter was referred to you by the Govemor.
For your information.
Take appropriate action -
Note and file.
Note and return to me.
Note and see me about this.
Your comments and/or recommendations.
"Copy to Secretays Office
Remarks
Page 1 of 1
http://ibeam.enr.state.ne-us/os/dts/print.do?dispatch=crsdProfile&id=3963
9/8/2010

Y it
August 5, 2010
MEMORANDUM
TO: Ed Hardee, APS, LAU
FROM: Andrew Pitner, MRO, APS 01
PREPARED BY: Peggy Finley & Ellen Huffman, MRO, APS -
SUBJECT: Enforcement Case - PC-2010-0064
Violation of Permit No. WQ0016338 and
WQ0002702
ALCHEM, Inc.
Attached is the enforcement package sent to ALCHEM, Inc. on August 5, 2010,
with supporting documentation concerning violations of the subject permits. The
violations resulted from ALCHEM's failure to comply with permit conditions. This
Office is issuing a penalty.
The attached material should be self-explanatory; however, if you have any
questions, please contact Peggy Finley or me.
Attachments
m of

Page 1
Summafy
See attached Compliance Inspection Report
CHECKLIST FOR PERMIT VIOLATIONS
1. Copies of the Permits (#WQ0016338, WO0002702) are attached.
2. The violator is ALCHEM, Incorporated. Mr. Randall Andrews is the agent for the
company.
Mr. Randall Andrews
2042 Buie Philadelphus Road
Red Springs, North Carolina 28377
3. This enforcement involves violations of non -discharge Permit conditions and
general statute G.S. 143-215.1.
4. Copies of correspondence are attached.
5. Copies of chain -of -custody. Not applicable
6. The violation is not due to a power failure or by-pass of any treatment facility.
7. Are violations chronic and/or due to a single operational upset?
The permittee has received Notices of Violation and has been subject to
enforcement in the past for most of these same issues. The violations are not
associated with a single operational upset.
8. Were any specific notifications submitted concerning noncompliance?
A NOV/NOI was sent on June 10, 2010, which documented the subject permit
violations and indicated that an enforcement recommendation would be
prepared. A response to the NOV/NOI was received by the MRO on
9. Cost of the investigation:
20 hours by Ellen Huffman for preparation
of enforcement report at $28.00/hour = 560.05
5 hours by Peggy Finley for preparation
of enforcement report at $26.21/hour = 131.03
10 hours by Andrew H. Pitner, for supervisory review
at $34.81/hour = 348.07
1 hour for clerical processing at $10.93/hour = 10.93
Certified Mail 2 @ $5.54 /ea. = 11.08
Total $ 1061.16

DIVISION OF WATER QUALITY
CIVIL PENALTY ASSESSMENT FACTORS
Violator: Alchem Incorporated
County: Rowan
Case Number: PC-2010-0064
Permit Numbers: W00002702 and W00016338
1)
2)
3)
4)
5)
6)
ASSESSMENT FACTORS
The degree and extent of harm to the natural resources of the State, to the public health, or
to private property resulting from the violation;
Impacts to groundwater and surface water at the facility have been documented,
including contamination of neighboring water supply wells. Violations associated with
this enforcement case include failure to keep process water at a pH of 6 or above, which
has been a chronic problem at the facility. While the pH problem in the lagoons may be
related to groundwater contamination issues at the site, it is not clear that this directly
contributed to groundwater contamination. That there are existing issues with
contamination at the site and that Alchem has demonstrated unwillingness to correct the
problems is a very significant factor in this assessment.
The duration and gravity of the violation;
The facility has had a lengthy history of non-compliance. The permittee has been cited
repeatedly over the last few years for recordkeeping deficiencies, pH violations and,
failure to maintain the required lagoon freeboard. This is considered a significant factor.
The effect on ground or surface water quantity or quality or on air quality;
Groundwater and surface water at and near the facility have been impacted by Alchem's
operations. The degree to which the current violations are related to those impacts is not
clear. This is considered a moderately significant factor.
The cost of rectifying the damage;
The cost to rectify damage from these violations is not clear. This is considered a
moderately significant factor.
The amount of money saved by noncompliance;
It is difficult to quantify the amount saved from failure to document the required
information and have it available to DWQ inspectors. Missed analytical samples would
be in the low hundreds of dollars. Establishing and maintaining vegetative cover would
likely be in the hundreds of dollars. The cost to properly maintain the pH of the recycle
water as required is estimated to be in the thousands of dollars. This is considered a
moderately significant factor.
Whether the violation was committed willfully or intentionally;

d
7)
8)
The violations were willful and intentional. Alchem has a lengthy history of
noncompliance and been aware of the regulatory requirements of their permits from
previous inspections, Notices of Violation, enforcements, and settlement agreements.
This is considered extremely significant.
The prior record of the violator in complying or failing to comply with programs over
which the Environmental Management Commission has regulatory authority; and
The ALCHEM facility has an extensive record of non-compliance, including NOV
10/25/1990, NOV 01/07/2002, NOV 03/15/2002, NOV/NRE 05/12/2003, NOV
08/19/2003, NOV/NRE 01/12/2005, NOV/NRE 09/20/2005, NOV/NRE 01/06/2006,
NOV/NRE 12/20/2006, NOV/NRE 12/20/2006, NOV/NRE 3/25/08, NOV/NRE 6/2/09.
This is considered extremely significant.
The cost to the State of the enforcement procedures.
The cost to the State in bringing about this enforcement action is as follows:
20 hours by Ellen Huffman for preparation
of enforcement report at $28.00/hour = 560.05
5 hours by Peggy Finley for preparation
of enforcement report at $/hour
10 hours by Andrew H. Pitner, for supervisory review
at $/hour
1 hour for clerical processing at $10.93/hour
Certified Mail 2 @ $5.54 /ea.
This is considered a moderately significant factor.
Date
Total
\ .a
Supervisor blame
= 131.03
= 348.07
= 10.93
11.08
$ 1061.16

DIVISION OF WATER QUALITY -- CIVIL PENALTY ASSESSMENT
Violator: ALCHEM, Inc.
County: Rowan
Case Number: PC-2010-0064
ASSESSMENT FACTORS
1) The degree and extent of harm to the natural resources of the State, to the public health,
or to private
( ) not significant ( ) moderately significant( ) significant (x) very significant ( ) extremely
significant
2) The duration and gravity of violation;
( ) not significant ( ) moderately significant(x) significant( ) very significant ( ) extremely
significant
3) The effect on ground or surface water quantity or quality or on air quality;
( ) not significant (x) moderately significant ( ) significant ( ) very significant ( )
extremely significant
4) The cost of rectifying the damage;
( ) not significant (x) moderately significant ( ) significant () very significant( ) extremely
significant
5) The amount of money saved by noncompliance;
( ) not significant (x) moderately significant( ) significant ( ) very significant ( ) extremely
significant
6) Whether the violation was committed willfully or intentionally;
( ) not significant ( ) moderately significant( ) significant ( ) very significant (x) extremely
significant
7) The prior record of the violator in complying or failing to comply with programs
over which the Environmental management Commission has regulatory
authority; and
( ) not significant ( ) moderately significant( ) significant ( ) very significant (x) extremely
significant
8) The cost to the State of the enforcement procedures.
( ) not significant (x) moderately significant ( ) significant ( ) very significant () extremely
significant
Date Andrew H. Pitner, P.G.

REMISSION FACTORS
( ) Whether one or more of the civil penalty assessment factors were wrongly applied to the
detriment of the petitioner;
( ) Whether the violator promptly abated continuing environmental damage resulting from
the violation;
( ) Whether the violation was inadvertent or a result of an accident;
( ) Whether the violator had been assessed civil penalties for any previous violations; and
( ) Whether payment of the civil penalty will prevent payment for the remaining necessary
remedial actions.
.r«m
Andrew . i ner, P.G.

Alchem,
Corporate Office
2042 Buie Philadelphus Road
Red Springs, NC 28377
Tel. [phone]
Fax [phone]
rfcVP.semr.net
June 28, 2010
Inc. . %
Sales and n05upring
8135 Red Road
Rockwell, NC 28138
Tel. [phone]
Fax [phone]
alchcmin ti?windstream.net
Mr. Andrew 1-1. Pitner, P.G. Environmental. Program Supervisor
NC Department of Environmental & Natural Recourses
Division of Water Quality
610 East Center Ave Suite 301
Mooresville, NC 28115
RE: Notice of Violation (NOV) and
Notice of Intend (NOI) to Enforce
NOV-2010-PC-0438
WQ0002702, WQ0016338
Rockwell. Rowan County
Letter dated June 10, 2010
Dear Mr. Pitner,
ru
JUL - 2 2010
I am in receipt of the above referenced letter. As of May 17, 2010, 1 have assumed the
responsibilities of plant engineer at this facility. Please also be advised, there is an ongoing
criminal investigation for embezzlement and thief by employee at Alchem, on some of the past
management, Mr. Robert Wolcott and Mr. Jason Desiato. I have been placed onsite to get
environmental and manufacturing issues resolved. Therefore, I wish to respond to your letter in
paragraph form.
WQ0002702: Condition #13 requires the recycled water to be maintained at a pH of 6.0
Standard Units as it goes to the storage lagoons:
Regarding the pH readings, Trent Tidwell is currently certified to take these readings.
Your letter states that Trent made the comment, "he has not been onsite to inoniior the pJJ
.for less than 18 months". However Trent states this statement is false. I have discussed
this with Trent and he stated that his statement was taken entirely out of context. Trent
may be the only person certified to take pl-I readings, and. Trent has been onsite each and
every day, Monday — Friday. He may not havc�bc(5-n—here-,the entire time, each day,
however, it would be irrelevant for someone to simple sit atthe lagoon and constantly
monitor the pH. The pI-1 was checked continu6usly_—arid¢re6orded. These records were
believed to be allegedly stolen by Mr. Jason Desiato upon his departure. As of today, there
has been a. mixer tank to provide additional treatment to raise our pH discharge.
Furthermore, we have contacted NCDENR in an attempt to schedule an onsite visit to

assist us with getting more people certified. In your letter you state, ".41chemhas never
achieved compliance for pH on the reactors prior to this time, ivhich is the reason the 1
lagoons continues to have loin pH". It is our opinion that this statement is false. Alchem �'aL
was washing the sand in the reactor and then discharging it to recycle this water. We feel
h that if anyting differently was believed, it was a misunderstanding by NCDENR.
WQ0002702 Condition #14 .requires a site -life estimate for the fill area.
You stated in your letter, "It iiws noted again that the monofrll area has been crud
continues to be extensively modified and gradedIt ti>>c7s apparent to stc{ff dw-ing this
inspection and from revieiv of'pasi inspection photos that significant grading activity has
taken place. " We totally disagree with this statement. To our knowledge, the site -life .has
not been reduced, and the fact that Alchem has not been given permission to fill areas sincelQ
signing the settlement agreement filed November 27, 2007, is false. We believe that
7'
Alchem has not offered any site -life; therefore, this is a non -issue. �f
WQ0002702 Condition #10 requires two feet of freeboard in all lagoons.
When NCDENR arrived, it had only been a few days since we had an enormous rainfall.
R L, This water is recycled and used. As far as maintaining two feel of freeboard, Alchem has 1
in fact maintained a two feet of freeboard. The area that NCDENR is measuring, has some ��i'�')
sand stocked. piled in the area, which was done in an attempt to dry it out. However. the
current :fl eeboard is still in the area of two feet.
WQ0002702 Condition #12 required vegetative cover to be maintained.
/ Alchem has spent thousand of dollars in seed and mulch in and around the top of these
^n� vegetative embankments. At this time, we are forwarding samples to NC State University
'for their recommendation in obtaining vegetative cover in this area./�
J �Wr Q0002702 Condition #22 requires maintenance of an inspection log of the recycle
All of our environmental logs have allegedly been stolen b Mr. Jason Desiato, in. an
g g Y a
attempt to cause Alchem further financial harm. This is also part of the ongoing criminal
investigation, between Rowan County Sheriff's Department, Mr. Desiato, and Mr. r� ��`�,
Wolcott. r
WQ0002702 Condition 428 requires the pennittee to report noncompliance `1
Alchem continues to believe that we were in constant compliance; however we can not
offer any validity due to the fact that our environmental records have been allegedly stolen
by Mr. Desiato and Mr. Wolcott. We feel these were stolen to further Alchem's potential'
environmental problems. Yet, Alchem is maintaining a current book with copies in a
locked filing cabinet on a daily basis.
WQ0016 38 Condition 111.2 required maintenance of records tracking all application `—
activities such as location of residuals utilization and volume disposed.91
0
NCDENR is suggesting that the spent bauxite "sand" was disposed. To this date, none of
this material has ever left Alchein's property, to my knowledge or to the knowledge of Mr.
Randall Andrews, as I have discussed this matter with him. Furthermore, Mr. Trent
Tidwell, plant manager, has no knowledge of any of this material being disposed of or /Z,�
leaving otu• property. It is Alchem's believe that any sand that is on the property is at the
p1l of 6.0. In additional, you stated, "If available, please provide documentation of
disposal of the lagoon #3 Again, we are not aware of any disposal. Furthermore, this
1

would probably be obtained in any stolen and/-.ort red envi'ronill6ntal records that Mr.
Desiato and Mr. Wolcott may have taken in aft allegedly thief.
WQ0016338 Condition 1.11.3 requires residual analyses to_bc conducted twice per year for
metals, pH and phosphorus.
We believe this did occur, however we are in the process of locating records, as we believe
this is again part of the records that were allegedly stolen by Mr. Desiato and Mr. Wolcott.
WQ0016338 Condition 111.6 requires maintenance of records for five years tracking all
application activities associated with the surface disposal unit including (a, b, c, d, and e)
WQ0016338, Condition V.1 requires logging of inspection of the residual storage, transport
ai disposal facilities.
l� tems listed in, a, b, c, d, and e, were onsite approximately 60 — 90 days ago. Once again,
we feel that these records are part of the allegedly thief my Mr. Desiato & Mr. Wolcott.
Alchem has started a new e of environmental record keeping so this will not happen
� YP p g PP
CJ again in the future. C� �
��s � fi ' -
Once we started the criminal investigation on Mr. Desiato and Mr. Wolcott, it is Alchem's final
believe that even though these two gentlemen have different last names, they are in fact brothers
whom had a criminal plot to cause Alchem, environment and financial harm by allegedly
stealing these records upon their departure. We are working diligently with the Rowan County
Sheriff and our attorneys to make every legal effort to recover these stolen documents.
Upon my arrival, I have constructed and installed an 8-inch thick concrete wall, to contain the
Alum manufacturing area. We intend on moving our pumps and piping of this area in
approximately 30 days and installing an epoxy coating to further stop potential leakage. At this
time, the existing containment walls appear to be water tight and in good working order.
Furthermore, Alchem is working to improve its manufacturing process so that a reflection. of
improved enviromnental stewardship will apply.
We have come to the conclusion that over the past several years, the past plant managers at
Alchem have not performed and fulfilled their duties as I feel should have been. In addition,
with the ongoing criminal investigation for the alleged. embezzlement and thief by employee,
Alchem is working diligently through. the court system to obtain these records in which we feel
have been stolen. We are also working diligently. to get Alchem back in compliance with the
requirement ofNCDENR.
Alchem has purchased thousands of dollars of equipment to get the process of total compliance
moving forward. There are several other factors that are in the design stage at this time, to
improve environmental stewardship at this facility.
The statements made by Mr. Robert "Bob" Wolcott, that the materials were, ordered, was
probably false, yet the ownership of Alchem had no idea this brataken place,.�The ownership
has taken aggressive means and methods at thus time to get the- c-onstruction process moving
forward, which is visually apparent.
We request that these facts be taken in consideration aiid that any civil fines may be
reconsidered, as Alchem is an employer to appmximatelye - q, d high paying jobs in Rowan
County, in a time when jobs are extremely scarce and`fhe employiiient rate is high.
;j
+' r
'a
a

Upon your next visit-, Alchern wishes to demonstrate some of the changes that have been made to
correct these problems.
Sincerely,
Alchem, Inc.
Charles D. Andrews
Plant Engineer
J. x

ALCHEM, INC.
Corporate Office
2042 Buie Philadelphus Road
Red Springs, NC 28377
Tel. 9io-843-2121 — 800-522-2944
Fax 9io-843-5789
[e-mail]
July 1, 2010
Mr. Andrew Pitner
Regional Environmental Supervisor
NCDENR Division of Water Quality
Mooresville Regional Office
610 East Center Ave.
Suite 301
Mooresville, NC 28115
Permit #: WQ001633)8
Dear Mr. Pitner:
I K1
Sales and Manufacturing
8135 Red Road
Rockwell, NC 28138
Tel. [phone]o8 — 800-462-2586
Fax [phone]
[e-mail]
U
g., SI C
JUL ® 2 2010
V'
Just for the record. While I was at ALCHEM on numerous occasions Jason Desiato
showed me a log book that was a recording of pH reading form the sampling port in the
reactor and from the various lagoons. All of the readings were on various days and
various months. All of the readings were above 6.0 on the pH scale. If the book was not
at ALCHEM when the inspection was done then it was stolen by Jason Desiato. While at
ALCHEM Jason stole at least the following: Money, truck tires, fuel, records, and
equipment. He even stole a book that had engine filter numbers and he stole the copies of
ALCHEM's permits. ALCHEM personnel are currently working on a list of stolen items
to give to the Rowan County Sherriff's department. His brother, Robert Wolcott
embezzled over $400,000, and left the company a financial wreck. ALCHEM personnel
are working on a list of stolen items that were removed by Robert and Denise Wolcott.
Robert and Denise were fired on February 8, 2010. Jason was fired on April 12, 2010. I
plan to send you a copy of the Rowan County Sherriff s report. I should have this next
week.
e ----
Best regards,
ALCHEM, INC.
Randall F. Andrews,
President
ams

ealv> -

ALCHEM, INC.
Corporate Office
2042 Buie Philadelphus Road
Red Springs, NC 28377
Tel. 9io-843-2121 - 800-522-2944
Fax [phone]
[e-mail]
July 1, 2010
Mr. Andrew Pitner
Regional Environmental Supervisor
NCDENR Division of Water Quality
Mooresville Regional Office
610 East Center Ave.
Suite 301
Mooresville, NC 28115
Permit #: WQ0016338
Dear Mr. Pitner:
Sales and Manufacturing
8135 Red Road
Rockwell, NC 28138
Tel. [phone]
Fax [phone]
[e-mail]
J0L ® 2 2010
MWM - Ac!t. ffer Protection
Quite some time ago I wrote to you asking that we be allowed to perform the residuals
analysis only once per year. You were going to send this request to someone in Raleigh.
I have not heard back from anyone on this. Would you advise me if you have heard
anything or if you can tell me who to send this request to.
Best regards,
ALCHEM, INC.
Eo���
Randall F. Andrews,
President
ams

ALCHEM, INC.
Corporate Office
2042 Buie Philadelphus Road
Red Springs, NC 28377
Tel. [phone] — 8o0-522-2944
Fax 9io-843-5789
[e-mail]
July 1, 2010
Mr. Andrew Pitner
Regional Environmental Supervisor
NCDENR Division of Water Quality
Mooresville Regional Office
610 East Center Ave.
Suite 301
Mooresville, NC 28115
Permit #: WQ0016338
Dear Mr. Pitner:
Sales and Manufacturing
8135 Red Road
Rockwell, NC 28138
Tel. [phone]o8 — 800-462-2586
Fax [phone]
[e-mail]
DU
JUL - 2 2010
C1FNR MRO
DWQ - Aq,±Par 1'rotoction
Just for the record. While I was at ALCHEM on numerous occasions Jason Desiato
showed me a log book that was a recording of pH reading form the sampling port in the
reactor and from the various lagoons. All of the readings were on various days and
various months. All of the readings were above 6.0 on the pH scale. If the book was not
at ALCHEM when the inspection was done then it was stolen by Jason Desiato. While at
ALCHEM Jason stole at least the following: Money, truck tires, fuel, records, and
equipment. He even stole a book that had engine filter numbers and he stole the copies of
ALCHEM's permits. ALCHEM personnel are currently working on a list of stolen items
to give to the Rowan County Sherriff's department. His brother, Robert Wolcott
embezzled over $400,000, and left the company a financial wreck. ALCHEM personnel
are working on a list of stolen items that were removed by Robert and Denise Wolcott.
Robert and Denise were fired on February 8, 2010. Jason was fired on April 12, 2010. I
plan to send you a copy of the Rowan County Sherriff's report. I should have this next
week.
Best regards,
ALCHEM, INC.
J
Randall F. Andrews,
President
ams

ALCHEM, INC.
Corporate Office
2042 Buie Philadelphus Road
Red Springs, NC 28377
Tel. [phone] -- 8o0-522-2944
Fax [phone]
[e-mail]
July 1, 2010
Mr. Andrew Pitner
Regional Environmental Supervisor
NCDENR Division of Water Quality
Mooresville Regional Office
610 East Center Ave.
Suite 301
Mooresville, NC 28115
Permit #: WQ0016338
Dear Mr. Pitner:
Sales and Manufacturing
8135 Red Road
Rockwell, NC 28138
Tel. [phone] — 800-462-2586
Fax [phone]
[e-mail]
D u re. Q V
JUL - 2 2010
DWQ -Aquifer Protection
Quite some time ago I wrote to you asking that we be allowed to perform the residuals
analysis only once per year. You were going to send this request to someone in Raleigh.
I have not heard back from anyone on this. Would you advise me if you have heard
anything or if you can tell me who to send this request to.
Best regards,
ALCHEM, INC.
Randall F. Andrews,
President
ams

Pitner, Andrew
From: Angela Scott [[e-mail]]
Sent: Thursday, July 01, 2010 4:23 PM
To: Pitner, Andrew
Subject: Scan_Doc0012.pdf - Adobe Reader
Attachments: Scan_Doc0012.pdf; LTR-NCDENR-AP10.doc; LTR-NCDENR-AP9.doc
Please see attached documents from Randall Andrews
1

PfflWi-U*1
i.
Corporate Office
2042 Buie Philadelphus Road
Red Springs, NC 28377
Tel. [phone]
Fax [phone]
rfag?sernnnet
June 28, 2010
Mr. Andrew I I. Pitner, P.G. Environmental Program Supervisor
NC Department of Environmental & Natural Recourses
Division of Water Quality
610 East Center Ave Suite 301
Mooresville. NC 28115
RE: Notice of Violation (NOV) and
Notice of Intend (NOI) to Enforce
NOV-2010-PC-0438
WQ0002702, WQOO16338
Rockwell, Rowan County
Letter dated June 10, 2010
Dear Mr. Pitner,
Sales and (Manufacturing
8135 Red Road
Rockwell, NC 28138
Tel. [phone]
Fax [phone]
alcheminc@,wind stream. net
I am in receipt of the above referenced letter. As of May 17, 2010, I have assumed the
responsibilities of plant engineer at this facility. Please also be advised, there is an ongoing
criminal investigation for embezzlement and thief by employee at Alchem, on some of the past
management, Mr. Robert Wolcott and Mr. Jason Desiato. I. have been placed onsite to get
environmental and manufacturing issues resolved. Therefore, I wish to respond .to your letter in
paragraph form.
WQ0002702: Condition #13 requires the recycled water to be maintained at a pI I of 6.0
Standard Units as it goes to the storage lagoons:
Regarding the pH readings, Trent Tidwell is currently certified to take these readings.
Your letter states that Trent made the comment, "he has not been onsite to monitor the pH
for lens than 18 months". However Trent states this statement is false. I have discussed
this with Trent and he stated that his statement was taken entirely out of context. Trent
may be the only person certified to take pH readings. and Trent has been onsite each and
every day, Monday — Friday. He may not have been here the entire time, each day,
however, it would be irrelevant for someone to simple sit at the lagoon and constantly
monitor the pH. The pH was checked continuously, and recorded. These records were
believed to be allegedly stolen by Mr. Jason Desiato upon his departure. As of today, there
has been a mixer tank to provide additional treatment to raise our pl-I discharge.
Furthermore. we have contacted NCDENR in an attempt to schedule an onsite visit to

assist us with getting more people certified. In your letter you state, "Alchetrt has never
achieved compliance for• pff on the reactors prior to this time, which is the reason the
lagoons conlin-nes• to have lost, pH". It is our opinion that this statement is false. Alchem
was washing the sand in the reactor and then discharging it to recycle this water. We feel
that if anvthing differently was believed, it was a misunderstanding by NCDENR.
WQ0002702 Condition 914 requires a site -life estimate for the fill area.
You stated in your letter. "It isas noted again that the monofill area has been and
continues to be extensively modified and graded. It was apparent to staff dt.trirrg this
inspection. and from reviein of pasl inspection photos that significant grading activity has
taken place. " We totally disagree with this statement. To our knowledge, the site -life has
not been reduced, and the fact that Alchem has not been given permission to fill areas since
signing the settlement agreement filed .November 27. 2007, is false. We believe that
Alchem has not offered any site -life; therefore, this is a non -issue.
WQ0002702 Condition 410 requires two feet of freeboard in all lagoons.
When NCDENR arrived, it had only been a few days since we had an enormous rainfall.
This water is recycled and used. As far as maintaining two feel of freeboard. Alchetn has
in fact maintained a. two feet of freeboard. The area that NCDENR is measuring, has some
sand stocked piled in the area, which was done in an attempt to dry it out. however, the
current freeboard is still in the area of two feet.
WQ0002702 Condition #12 required vegetative cover to be maintained.
Alchem has spent thousand of dollars in seed and mulch in and around the top of these
vegetative embankments. At this time, we are forwarding samples to NC State University
for their recommendation in obtaining vegetative cover in this area.
WQ0002702 Condition #22 requires maintenance of an inspection log of the recycle facility.
All of our environmental logs have allegedly been stolen by Mr. Jason Desiato, in an
attempt to cause Alchem further financial hann. This is also part of the ongoing criminal
investigation. between Rowan County Sheriff's Department, Mr. Desiato, and Mr.
Wolcott.
WQ0002702 Condition 9.28 requires the pennittee to report noncompliance
Alchem continues to believe that we were in constant compliance; however we can not
offer any validity due to the fact that our environmental records have been allegedly stolen
by Mr. Desiato and Mr. Wolcott. We feel these were stolen to further Alehem's potential
.environmental problems. Yet, Alchem is maintaining a current book with copies in a
locked filing cabinet on a daily basis.
WQ0016333 Condition 111.2 required maintenance of records tracking all application
activities such as location of residuals utilization and volume disposed.
NCDENR is suggesting that the spent bauxite "sand" was disposed. To this date, none of
this material has ever left Alchem's property, to my knowledge or to the knowledge of Mr.
Randall Andrews. as I have discussed this matter with him. Furthermore. Mr. Trent
Tidwell. plant manager, has no knowledge of any of this material being disposed of or
leaving our property. It is Alchem's believe that any sand that is on the property is at the
pH of 6.0. In additional, you stated, "If available, please provide doCltmentalion of
disposal of the lagoon #3 ". Again, we are not aware of any disposal. Furthermore, this

would probably be obtained in an}' stolen Lind/or altered environmental records that Mr.
Desiato and Mr. Wolcott may have taken in an allegedly thief
WQ0016338 Condition I I L 3 requires residual analyses to be conducted twice per year for
metals, pi and phosphorus.
We believe this did occur. however we tare in the process of locating records, as we believe
this is again part of the records that were alleoedly stolen by Mr. Desiato and Mr. Wolcott.
WQ00161 )8 Condition 111.6 requires maintenance of records for live years tracking all
application activities associated with the surface disposal unit including(a. b, C. d, and e)
WQOOI 6338, Condition V.1 requires loggino of inspection oi' the residual storage, transport
and disposal facilities.
Items listed in, a, b. c. d, and e, were onsitc approximately 60 — 90 days ago. Once again,
we feel that these records are part of the allegedly thief my Mr. Desiato & Mr. Wolcott.
Alchem has started a .new type of environmental record keeping so this will not happen
main in the future.
Once we started the criminal investigation on 'vir. Desiato and Mr. Wolcott, it is Alchem's final
believe that even though these two gentlemen have different last names, they are in fact brothers
whom had a criminal plot to cause Alchem. environment and financial harm by allegedly
stealing these records upon their departure. %Vc are working diligently with the Rowan County
Sheriff and our attorneys to make every legal el'fort to recover these stolen documents.
Upon my arrival, I have constructed and installed an 8-inch thick concrete wall, to contain the
Alum manufacturing area. We intend on moving our pumps and piping of this area in
approximately 30 days and installing an epoxy coating to further stop potential leakage. At this
time, the existing containment walls appear to be water tiaht and in good working order.
Furthermore. Alchem is working to improve its manufacturing process so that a reflection of'
improved enviromnental stewardship will apply.
We have come to the conclusion that over the past several years, the past plant managers at
Alchem have not performed and fulfilled their duties as I feel should have been. In addition,
with the ongoing criminal investigation for the alleged embezzlement and thief by employee,
Alchem is working diligently through the court system to obtain these records in which we feel
have been stolen. We are also working diligently to get Alchem back in compliance with the
requirement of NCDENR.
Alchem has purchased thousands of dollars of eduipment to get the process of total compliance
moving forward. There are several other factors that are in the design stage at this time. to
improve environmental stewardship at this faciliiy.
The statements made by Mr. Robert "Bob" Wolcott, that the materials were ordered, was
probably Use, yet the ownership of Alchem had no idea this was taken place. The ownership
has taken aggressive means and methods at this time to get the construction process moving
forward, which is visually apparent.
We request that these facts be. taken in consideration and thatany civil fines may be
reconsidered, as Alchem is an employer to approximately 20 good high paying lobs In Rowan
County, in a time when jobs are extremely scarce kind the unemployment rate is high.

Upon your next visit, Alchem wishes to demonstrate some of the changes that have been made to
correct these problems.
Sincerely,
Alchem, Inc.
Charles D. Andrews
Plant Engineer

ALCHEM, INC.
Corporate Office
2042 Buie Philadelphus Road
Red Springs, NC 28377
Tel. [phone] — 800-522-2944
Fax [phone]
[e-mail]
July 1, 2010
Mr. Andrew Pitner
Regional Environmental Supervisor
NCDENR Division of Water Quality
Mooresville Regional Office
610 East Center Ave.
Suite 301
Mooresville, NC 28115
Permit #: WQ0016338
Dear Mr. Pitner:
Sales and Manufacturing
8135 Red Road
Rockwell, NC 28138
Tel. [phone] — 8o0-462-2586
Fax [phone]
[e-mail]
Quite some time ago I wrote to you asking, that we be allowed to perform the residuals
analysis only once per year. You were going to send this request to someone in Raleigh.
I have not heard back from anyone on this. Would you advise me if you have heard
anything or if you can tell me who to send this request to.
Best regards,
ALCHEM, INC.
Randall F. Andrews,
President
ams

�zati. `%Yi 7�'n

t.
ALCHEM, INC.
Corporate Office
2042 Buie Philadelphus Road
Red Springs, NC 28377
Tel. [phone] — 8o0-522-2944
Fax 9io-843-5789
[e-mail]
July 1, 2010
Mr. Andrew Pitner
Regional Environmental Supervisor
NCDENR Division of Water Quality
Mooresville Regional Office
610 East Center Ave.
Suite 301
Mooresville, NC 28115
Permit #: WQ0016338
Dear Mr. Pitner:
Sales and Manufacturing
8135 Red Road
Rockwell, NC 28138
Tel. [phone] — 800-462-2586
Fax [phone]
[e-mail]
Just for the record. While I was at ALCHEM on numerous occasions Jason Desiato
showed me a log book that was a recording of pH reading form the sampling port in the
reactor and from the various lagoons. All of the readings were on various days and
various months. All of the readings were above 6.0 on the pH scale. If the book was not
at ALCHEM when the inspection was done then it was stolen by Jason Desiato. While at
ALCHEM Jason stole at least the following: Money, truck tires, fuel, records, and
equipment. He even stole a book that had engine filter numbers and he stole the copies of
ALCHEM's permits. ALCHEM personnel are currently working on a list of stolen items
to give to the Rowan County Sherriff s department. His brother, Robert Wolcott
embezzled over $400,000, and left the company a financial wreck. ALCHEM personnel
are working on a list of stolen items that were removed by Robert and Denise Wolcott.
Robert and Denise were fired on February 8, 2010. Jason was fired on April 12, 2010. I
plan to send you a copy of the Rowan County Sherriff s report. I should have this next
week.
Best regards,
ALCHEM, INC.
Randall F. Andrews,
President
ams

� -r-Tv" I -->
rrry -02. A

ALCHEM, INC.
Corporate Office Sales and Manufacturing
2042 Buie Philadelphus Road 8135 Red Road
Red Springs, NC 28377 Rockwell, NC 28138
Tel. 9io-843-2121-- 800-522-2944 Tel. [phone] — 800-462-2586
Fax [phone] Fax [phone]
[e-mail] [e-mail]

Tvv
m
wq
A kP-4

Pitner, Andrew
From:
Sent:
To:
Cc:
Subject:
Ms. Scott & Mr. Andrews,
Pitner, Andrew
Thursday, June 17, 2010 3:59 PM
'Angela Scott'; '[e-mail]'
Huffman, Ellen; Finley, Peggy; Hardee, Ed
RE: NOV 2010-PC-0438 ALCHEM
An extension for your response to the subject NOV is acceptable. Your response is now due to the Mooresville Regional
Office no later than July 1, 2010.
Andrew Pitner
From: Angela Scott [mailto:[e-mail]]
Sent: Thursday, June 17, 2010 11:23 AM
To: Pitner, Andrew
Subject: NOV 2010-PC-0438 ALCHEM
Good Morning Mr. Pitner,
Mr. Andrews is in receipt of the Notice of Violation dated June 10, 2010. We are asked to respond to this NOV within 10
days of receipt. Due to overwhelming amount of information required for this response, Mr. Andrews would like to ask if
ALCHEM could have an additional 10 days to prepare this response. Please let me know if this will be acceptable. Thank
you.
Angela Scott
ALCHEM, INC.
2042 Buie Philadelphus Rd.
Red Springs, NC 28377
Phone: [phone] ext. 24
Fax: [phone]
email: angela(apsemr.net

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FILE
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director, Division of Water Quality Secretary
7 June 10, 2010
Certified Mail
Return Receipt Requested
Alchem Incorporated
2042 Buie Philadelphus Rd.
Red Springs, NC 28377
Attention: Randall Andrews
Subject: Notice of Violation (NOV) and
Notice of Intent (NOI) to Enforce r;
NOV-2010-PC-0438
WQ0002702, W00016338 �' r
Recycle System, Monofill
Rockwell, Rowan County
Dear Mr. Andrews:
Chapter 143, North Carolina General Statutes, authorizes and directs the Environmental Management
Commission of the Department of Environment and Natural Resources to protect and preserve the water and
air resources of the State. The Division of Water Quality (division) has the delegated authority to enforce
adopted pollution control rules. This letter is a standard notification and is intended to advise you of the legal
requirements under North Carolina law.
On April 14, 2010, staff from the Mooresville Regional Office, Aquifer Protection Section (Ellen
Huffman, Peggy Finley, and Maria Schutte) conducted an inspection of the Alchem facility in Rockwell. Follow-
up visits were conducted on the afternoon of April 14 and again on April 26. As a result of these events, the
facility was found to be in violation of conditions of the subject permits and the November 27, 2007, Settlement
Agreement. This NOV also includes violations found in the review of annual report for 2009. Specific violations
are discussed below:
WQ0002702, Condition #13 requires the recycled water to be maintained at a pH of 6.0 Standard Units as it
goes to the storage lagoons.
The pH readings for the last 18 months have not been performed under supervision of a person
certified to take pH. Trent Tidwell is the only person at Alchem currently certified and he stated that he
has not been on site to monitor pH for the last 18 months. Production records indicate that not all
batches have been analyzed for pH. Billy, one of the alum production operators, stated when he takes
pH readings, they have been taken from the top of the reactor instead of the sampling port and are
therefore not representative of a "washed" batch of bauxite. While this may be acceptable for your
internal process control, this does not represent material going to the lagoons and this is a violation of
permit WQ0002702, Condition 13, and the settlement agreement filed November 27, 2007. According
to Trent Tidwell, the new mixer tank was recently installed to provide additional treatment
Division of Water Quality/ Aquifer Protection Section/ Mooresville Regional Office
610 East Center Avenue, Suite 301, Mooresville, North Carolina 28115 1a�Otle
Phone: [phone] Fax: [phone] Customer Service: 1-877-623-6748 lei oTthCarolina
Internet: vwN.ncwaterquality.org 11%'h` ally
An Equal Opportunity 1 Affirmative Action Employer

Aldieil N_OV 1NOI
June 10, 2009
(washing/neutralization) of the spent bauxite from the reactor in order to achieve a pH of 6.0 or greater
as required by both permits and the settlement agreement. This information indicates that ALCHEM
has never achieved compliance for pH from the reactors prior to this time and is the reason that the
lagoons continue to have a low pH. It must also be concluded that none of the reactions documented
in the 2009 annual report were properly neutralized as required by the permits and the 2007 settlement
agreement. pH readings of the lagoons were taken by MRO APS staff at the time of this inspection - all
three lagoons have pH readings well below 6.0 S. U. (see inspection report).
WQ0002702, Condition #14 requires a site life estimate for the fill area.
It was noted again that the monofill area has been and continues to be extensively modified and
graded. It was apparent to staff during this inspection and from review of past inspection photos that
significant grading activity has taken place. This activity has made the previously submitted site -life
report invalid. The latest site -life evaluation was performed by DELTA Environmental in August of
2009. This report was never submitted as requested in the July 2009 NOV/NOI, but a copy was
recently obtained by the MRO. The report reflects that, at that time, the site -life had been reduced from
9.5 years to 6 years. Please explain why the site life has been reduced as ALCHEM has not been
given permission to use the fill area since the signing of the settlement agreement filed
November 27, 2007, Another site -life evaluation of the fill area will need to be performed as soon
as possible to determine if there is any site life left.
W00002702, Condition #10 requires two feet of freeboard in all lagoons.
Alchem staff was advised of freeboard concerns during the April 14th inspection. During the follow-up
visit on April 26, 2010, APS staff measured the freeboard at four points in the northern half of lagoon
#1. Freeboard measurements to the liquid surface ranged from 11 to 22 inches and spent bauxite
solids were piled higher than the lagoon walls. Grading around the lagoons has negated the relevance
of the markers on the staff gauges required in Condition #11 of this permit. Maintaining proper
freeboard has been a non-compliance issue at this site in the past as documented in previous
inspections. Inadequate freeboard was not reported to the MRO prior to the inspection.
WQ0002702, Condition #12 requires vegetative cover to be maintained.
There is no protective vegetative cover on any of the earthen basin embankments (lagoon berms) as
required and this has been an ongoing issue as documented in the previous inspections in 2009, 2008,
2007, 2006, and 2005.
WQ0002702, Condition #22 requires maintenance of an inspection log of the recycle facility.
There is no inspection log being maintained and it is not clear that inspections required by Condition
#21 have occurred.
WQ0002702, Condition #28 requires the permittee to report noncompliance.
A review of the 2009 Annual Report reflects inconsistencies with pH readings when compared to the
additional information request received in November 2009 for the previous NOV, and the lagoon pH
report submitted in August 2009. Basically, Alchem has submitted data covering the same time period
on three occasions with differing pH readings recorded in each submittal. In all cases, these data do not
reflect pH values found by DWQ during the inspections of the lagoons. Lagoon activity records
submitted for 2009 are incomplete. No report was filed regarding failure to maintain required freeboard.
WQ0016338, Condition 111.2 requires maintenance of records tracking all application activities such as location
of residuals utilization and volume disposed.
Production records (volume produced) for 2009 and lagoon volumes, are not consistent. Records
submitted by DELTA, indicate that lagoon # 3 was inspected on September 15, 2009, but there is no
documentation in the Annual Report of where the spent bauxite from lagoon #3 was disposed. Please
note that Lagoons #1 and #2 were cleaned out and inspected in 2008, Given the changes in the
volume of the fill area and no evidence that Alchem has properly neutralized the residuals going to the

E-A
Alchem NOWNOI
June 10, 2009
lagoons, the Division believes that acidic residuals from lagoon #3 were disposed of in the fill area. If
available, please provide documentation of disposal of the contents of lagoon #3.
WQ0016338, Condition 111.3 requires residual analyses to be conducted twice per year for metals, pH, and
phosphorus.
Only one analysis for metals was submitted for the 2009 annual report.
WQ0016338, Condition 111.6 requires maintenance of records for five years tracking all application activities
ssociated with the surface disposal unit, including:
a) Date and freeboard level measurements - no records were available during the inspection.
b) Source and date of residuals disposed in the surface disposal unit — no disposal to the fill area was
reported.
c) Cumulative volume of residuals disposed in the surface disposal unit — no disposal to the fill area
was reported.
d) Remaining volume in the surface disposal unit — no records were available during the inspection.
e) An estimate of remaining useful disposal life for the surface disposal unit — invalidated by continuing
activity noted in inspection (also see WQ0002702, Condition 414 above).
If
W00016338, Condition 111.6 (mis-numbered on page 5 of the permit) requires notification of noncompliance.
pH, record keeping, etc., have been non -compliant for all of 2009 and not reported as such. If
available, please provide documentation of any notification to the Mooresville Regional Office of
noncompliance and of written reports filed.
WQ0016338, Condition V.I. requires logging of inspections of the residuals storage, transport and disposal
facilities.
There is no inspection log maintained at the facility.
Failure to comply with conditions in a permit may result in a recommendation of enforcement action, to
the Director of the Division of Water Quality who may issue a civil penalty assessment of not more that twenty-
five thousand ($25,000) dollars against any "person" who violates or fails to act in accordance with the terms,
conditions, or requirements of a permit under authority of G.S. 143-215.6A. Please note that each day a
violation continues may be considered a separate violation, subject to additional civil penalties.
As a_result of the violations described in this Notice, this office is considering a recommendation for a
civil penalty assessment to the Director of the Division. If you wish to present an explanation for the violations
cited, or if you believe there are other factors that should be considered, please send such information to me in
writing within ten (10) days following receipt of this letter. Your response will be reviewed, and, if an
enforcement action is still deemed appropriate, it will be forwarded to the Director and included for
consideration.
Should you have any questions, feel free to contact me at 704/235-2180 or via email at:
Andrew. [e-mail].
Sincerely,
Andrew H. Pitner, P.G.
Environmental Program Supervisor
Enclosure: Inspection Report
Cc: Trent Tidwell, Alchem Incorporated, 8135 Red Road, Rockwell, North Carolina 28138
MRO-APS Files
DWQ-APS Land Application Unit, Raleigh
Anita LeVeaux, AG Office

K3
Mate of North Carolina
Department of Environment
and Natural Resource;
Division of Water Quality
Beverly Eaves Perdue, Governor
Dee Freeman, Secretary
Coleen H. Sullins, Director
OWDISCHARGE COMPLIANCE INSPEECTIO
Recycle System & Bauxite Residuals Monofill
GENERAL INFORMATION
Owner: Randall Andrews County: Rowan . Project Name: Alchem, Inc.
Permit No. WQ0002702 Issuance Date: Dec. 28, 2004 Expiration Date: Nov. 30, 2009
Note: Session Law 2009-406 extended this permit to 11-30-2012
Permit No. W00016338 Issuance Date: Dec. 28, 2006 Expiration Date: Nov. 30, 2011
Note: Session Lanni 2009-406 extended this permit to 11-30-2014.
Permittee Contact: Trent Tidwell, Operations Mgr. Telephone No. 704/279-7908
Reason for Inspection
X ROUTINE COMPLAINT X FOLLOW-UP OTHER
Inspection Summary:
The last inspection for this facility was April 30, 2009 and resulted in an enforcement Action. This enforcement
action is currently being adjudicated.
This inspection finds the facility in violation.
Staff from the Mooresville Regional Office, Aquifer Protection Section (Ellen Huffman, Peggy Finley, and Maria
Shutte) conducted an inspection on April 14, 2010. Follow-up visits took place on the afternoon of April 14 and
again on April 26. These events revealed that ALCHEM is non -compliant with conditions in both subject
permits and the 2007 settlement agreement.
It was noted that as of March 2010, Trent Tidwell is currently in charge as operations manager. Bob Wolcott is
no longer working for ALCHEM. Jason De Siato was present for part of the inspection.
Production records for 2010 that cover production from Jan. 1, 2010 to March 29, 2010 were reviewed. These
records reflect that pH is not taken after every completed reaction.
The validity of pH readings from the sampling port as recorded in the production batch book are questionable
since plant personnel stated that pH readings were taken on samples of spent bauxite from the top of the
reactor instead of from the sampling port as required by the settlement agreement. Trent Tidwell stated that he
has been "on the road" for the last year and a half and has riot been involved in plant operations. DWQ
Laboratory Section records from May 2007 indicate that Trent Tidwell is the lab supervisor. Based on this,
DWQ concludes that no one with certification has been present to oversee collection of pH or observe that pH
has been collected properly or to see that the pH meter was properly calibrated before testing.
continued

ALCHEM Inspection April 14, 2010
Inspection Summary continued:
Page 2
The pH of the lagoons and the storm -water pond was monitored by MRO APS staff during this inspection. pH
readings were recorded as: lagoon #1- 2.21 S.U. Lagoon #2- 3.39 S.U. lagoon #3 appeared to have just liquid
in it and had a pH of 2.96 S.U. The storm -water basin had a pH of 3.69 S.U. The water from the storm -water
pond is pumped into the plant for production water. At this time it is unclear as to why the storm -water pond
continues to have a low pH. The validity of pH readings for lagoon #1 as recorded in the production batch
book appear questionable because pH readings taken by MRO during this inspection reflect much lower
results.
A pile of dirt approximately 20 ft tall is being stored on the fill area (this dirt has been placed there since the last
site -life of the fill area was performed). It was stated that the intended use for this dirt is for road maintenance.
The source of the dirt is currently unknown.
All three lagoons do not have any protective vegetation for erosion control as required by permit WQ0002702.
Past inspections (2005-09) conclude that this continues to be an ongoing problem meeting this permit
requirement.
Record Keeping review
A review of the 2009 Annual report reflects serious inconsistencies with pH readings when compared to the
additional information request received in November 2009 for the previous NOV, and the lagoon pH report
submitted in August 2009. Basically, data reflects numbers that are internally inconsistent. Lagoon activity
records submitted for 2009 are incomplete.
There was no pH log -or record of calibration to verify that the pH meter being used for compliance monitoring
has been calibrated before each use. See inspection summary.
Treatment
The reactor near lagoon #1 was supposed to have been repaired (reference inspection and photos from Oct.
14, 2008). Mr. Wolcott had stated at that time that the material to repair the reactor had been ordered. An
observation made by Peggy Finley on April 14, 2010, during a reaction, noted that the reactor still leaks and
that the leaking water has a pH of 3.86 S.U. and was being diverted by a ditch dug into the ground to the front
of the chemical tank area. There is no proper containment for the reactor or any of the tanks on site.
Per Trent Tidwell, the new tank recently installed (see photo next page) is to try to provide additional treatment
to the spent bauxite from the reactor to achieve a pH of 6 as required by both permits and the settlement
agreement. Based on this information, DWQ concludes that ALCHEM has never achieved compliance for pH
from the reactors and inadequate process control is the reason that the lagoons have a low pH and that all
reactions from 2009 were never neutralized as required by the permits and settlement agreement. This does
not support the pH readings that were submitted in the annual report for 2009.
Residuals Storage Lagoons
Lagoon #1 has a pH of 2.20 S.U. and is currently receiving spent bauxite. Lagoon #2 has a pH of 3.39 S.0 and
appears to be about 1/3 full of spent bauxite. Lagoon # 3 has been cleaned out and is about 1/3 full of (what
appears to be) water. The liquid in #3 has a pH of 2.96 S.U.
Despite efforts to establish a vegetative cover on the outer walls of the lagoons as noted in the last inspection,
they remain effectively devoid of such vegetation for erosion control. See comments in inspection summary.
During the April 14 visit, Trent Tidwell was advised of freeboard concerns. During the follow-up visit on April
26, APS staff measured the freeboard at four points in the northern half of lagoon #1. Freeboard
measurements to liquid surface ranged from 11 to 22 inches and spent bauxite was piled higher than the
lagoon walls. Freeboard issues have been problematic during past inspections as well and grading has
rendered the markers invalid.

ALCHEM Inspection April 14, 2010
Page 3
Transport of Residuals
It was stated that no residuals have been removed from the lagoons this year (January 1, 2010, to the
present).
Residuals Fill Area and Storm -water Basin
As noted in the photos below, most of the fill area has been graded to meet berm level. The latest site -life
evaluation was performed by DELTA in August of 2009. This report was not received by this office as
requested in the July 2009 NOVNOI. A copy has just been retained by the MRO and reports that the site -life
has been reduced from 9.5 years to 6 years indicating that additional material has gone to the fill area. Since
that report, it appears that even more.grading activity has taken place and a very large amount of what
appears to be fill dirt is currently being stored on top of the fill area. A third site life evaluation of the fill area
will need to be re -calculated to determine if there is remaining space.
These photos were taken during this inspection.
Photo 1-Reactor pump April 14, 2010.
Photo 2-Fill area April 2010
Photo 1- Note the white substance on the ground. Trent stated the material was lime to help neutralize the
leaking water from the reactor. .

ALCHEM Inspection April 14, 2010 Page 4
Recordkeepinc
A review of the batch production log for January through March 2010 documents pH readings as being taken
at the sampling pert. Plant personnel stated that the pH was taken from the top of the reactor. The log also
reflects pH of >6.0 in the lagoon. pH taken by APS staff at the time of this inspection show pH as being much
iower. It was stated by both Trent and Jason that there is no calibration log book for the pH meter. Jason
stated that he takes the meter to a lab once a year for calibration. Chet Whiting (lab certification inspector,
MRO) had supplied ALCHEM with calibration instructions, pH method instructions which include calibration as
a requirement to perform pH, and the forms for this certification requirement in 2008 but, no one has kept this
log as instructed.
Cornkliance Monitoring
Groundwater monitoring required by permit WQ0002702 is currently being conducted on a quarterly schedule
as part of continuing groundwater investigation for 2L violations. Reports have been submitted by John
Reuscher with DELTA Environmental.
Follow-up Inspection
Upon being notified that the mixer was in operation, Peggy Finley revisited the site on April 26 and observed
the collection of a sample from the mixer port. A pH measurement was taken by ALCHEM personnel. The
result was noted to be 7.18 S.U.

07/06/2010 -10:22 7042168701
ROWAN CO SHF OFFICE
PAGE 02
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07/06/2010 10:22
7042168701
ROWAN CO SHF OFFICE
PAGE 01
To:
ROWAN COUNTY Y SHERIFF'S OFFICE
232 NORTH MAIN STREET, SALISBURY, NORTH CAROLINA 28144
TELEPHONE: [phone] FAX: [phone]
Fax # : t6 - lD()
From -.
Date
Pages ,
Remarks:
(Including Cover Page(s)
Notice: The information contained in this facsimile message is legally privileged and confidential
information intended only for the use of the individual or entity above. If the reader of this message Is
not the intended recipient, you are hereby notified that any dissemination, distribution or Copy of this
telecopy is strictly prohibited. If you have received this teleoopy in error, please immediately notify us
by telephone and return the original message to us at the address above via the United States Postal
Service.
Thank You,
704-216-8700
Facslmlle Farm R05012b10g,pdf

Batch #
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
Annual report
Date of 2008
Reaction reaction sent to samp.port pH
Prod. Records. Lagoon # recld 08/04/2009
Add. info report
NOV-PC-0470
Sampling Port lagoon pH
recd 11/20/2009
3/3/2008
3
3/4/2008
3
3/5/2008
3
sp-7:12
3/6/2008
3
3/7/2008
3
3/10/2008
3
3/11/2008
3
sp-6.87
sp-6.87 .: _
3/12/2008
3
3/13/2008
3
3/14/2008
3
3/17/2008
3
3/18/2008
3
sp-6,.89
sp-6.89
3/19/2008
3
3/20/2008
3
3/21/2008
3
3/24/2008
3
sp-7.2
sp-7.2 -
3/25/2008
3
3/26/2008
3
3/27/2008
3
3/28/2008
3
3/31/2008
3
4/1/2008
3
sp-7.1
sp77.1 -
4/2/2008
3
4/3/2008
3
4/4/2008
3
4/7/2008
3
— --
4/8/2008
3
sp-7.11
sp-7.11
4/9/2008
3
Apr-08
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4/11/2008
3
4/14/2008
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4/15/2008
3
4/16/2008
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4/17/2008
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4/18/2008
3
4/21/2008
3
4/22/2008
3
sp-6.98
sp-6.98
4/23/2008
3
-
4/24/2008
3
425/2008
3
4/28/2008
3
4/29/2008
3
sp-6.39
4/30/2008
3
--
5/1/2008
3
_
5/2/2008
3
-
5/5/2008
3
sp-6.89
sp�6.58

47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
81
82
83
84
85
86
87
88
89
90
91
92
93
94
95
96
5/6/2008
3
- -
5/7/2008
3
5/8/2008
3
5/9/2008
3
sp76.6'
5/11/2008
3
5/12/2008
3
5/13/2008
3
sp-6.92
5/14/2008
3
5/15/2008
3
sp-6.22 -
5/16/2008
3
5/19/2008
5/20/2008
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3
5/21/2008
3
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5/22/2008
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5/23/2008
3
5/26/2008
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5/27/2008
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5/28/2008
3
5/29/2008
3
5/30/2008
3
sp-6.44
6/2/2008
3
-
6/3/2008
3
6/12/2008
3
,a
6/4/2008-6/13/2008
reactor down
_
6/16/2008
3
6/17/2008
3
6/18/2008
3
6/19/2008
- 3
6/20/2008
1
6/23/2008
1
6/24/2008
1
6/25/2008
1
6/26/2008
1
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6/27/2008
1
6/30/2008
1
7/1/2008
1
7/2/2008
1
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7/3/2008
1
7/8/2008
1
7/9/2008
1
7/10/2008
1
sp-6.44
7/11/2008
1
" - - - - -
7/14/2008
1
7/15/2008
1
7/16/2008
1
7/17/2008
1
sp-6.71
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300
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end of report
6/8/2009
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20
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