WQ0002702_Regional Office Historical File Pre 2018 (7)

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
March 2007
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mrs. Julia M. Andrews, Registered Agent
ALCHEM, Inc.
2042 Bui Philadelphus Road
Red Springs, NC 28138
and
ALCHEM, Inc.
8135 Red Road
Rockwell, NC 28138
SUBJECT: Assessment of Civil Penalty for
Violations of NC General Statute 143-215.1 (6) and
Non -Discharge Permit No. WQOOO27O2
Case No. PC-2006-0586
Rowan County
Dear Mrs. Andrews:
This letter transmits notice of a civil penalty assessed against ALCHEM, Inc. in the amount of $0000, which
includes $467.54 in investigative costs. Attached is a copy of the assessment document explaining this
penalty.
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:
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
Nne
orthCarolliina
Division of Water Quality / Aquifer Protection Section / Mooresville Regional Office Phone: [phone] Fax: [phone] Jgtut,R[l�
610 East Center Avenue, Suite 301, Mooresville, NC 28115 Customer Service 1-877-623-6748 Internet: http://aw.ehnr.state.nc.us �/ V

ALCHEM Inc. Assessment
WQ0002702
OR
Page 2
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. 14313-282.1(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 his decision in the matter of the remission request. His 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
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.
OR

ALCHEM Inc. Assessment
WQ0002702
Page 3
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 business 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 state holidays. The original and one (1) copy of the petition must be
files with The Office 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
671.4 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, 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
WQ0002702
Page 4
If you have any questions, please contact me at [phone] or Mr. Ed Hardee at [phone].
Sincerely,
Andrew H. Pitner, P.G.
Environmental Regional Supervisor
Aquifer Protection Section
Mooresville Regional Office
ATTACHMENTS
cc: Ed Hardee, DWQ APS Central Office w/attachments
File PC-2006-0586 w/ attachments
APS Central Files w/ attachments
DWQ Public Information Office w/attachments

STATE OF NORTH CAROLINA
COUNTY OF ROWAN
IN THE MATTER OF:
ALCHEM, Inc.,
FOR VIOLATIONS OF PERMIT
NO. WQ0002702 AND
NCGS 143-215.1
NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
File No. PC-2006-0586
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 Regional
Supervisor of the Mooresville Regional Office Aquifer Protection Section of the Division of Water Quality
(DWQ), of the North Carolina Department of Environment and Natural Resources, make the following:
I. FINDINGS OF FACT:
A. ALCHEM, Inc. (ALCHEM) is a corporation organized and existing under the laws of the State of North
Carolina. ALCHEM operates an industrial recycle system in Rockwell, -North Carolina, Rowan County.
The registered agent for ALCHEM is Julia M. Andrews.
B. On January 21, 1999, DWQ issued Non -Discharge Permit No. WQ0002702 to ALCHEM that allows for
the recycling of industrial wash water from a bauxite process. The permit expired on December 31, 2004.
C.. Said permit contains the following relevant conditions:
Permit condition 5 states, "In the event that the facilities fail to perform satisfactorily, including the
creation of nuisance conditions, the Permittee shall take immediate corrective action, including those
actions that may be required by this Division, such as the construction of additional or replacement
treatment and disposal facilities."
2. Permit condition 8 states, "The issuance of this permit shall not relieve the Permittee of the
responsibility for damages to the surface and groundwaters resulting from operation of this facility."
3. Permit condition 11 states, "Freeboard in all of the lagoons shall not be less than two feet at any time."
D. On December 5 and 12, 2007, DWQ staff from the Mooresville Regional Office and the Central Office
inspected the facility and determined the following:
1. The low pH (ranging from 2.62 — 3.41 SUS) measured in the wastewater in the three lagoons indicates
that the recycle system is not effectively washing the residuals before they enter the lagoons.
2. Groundwater samples were collected from monitoring wells MW-1 (upgradient) and MW-2
(downgradient). The samples were analyzed for aluminum. The laboratory results revealed the
concentrations of aluminum to be 790 µg/L and 4200 µg/L, respectively. These values are consistent
with self -monitoring reports submitted to the DWQ by the permittee for MW-1 and MW-2 in November
2006. The self -monitoring reports indicate that the concentration of aluminum in MW-2 has

progressively increased over the last two years. This indicates that the operation is damaging the
groundwater.
3. The freeboard in lagoon #3 was measured as 1.5 feet during the follow-up inspection.
F. On December 20, 2006, the Division issued a Notice of Violation (NOV) / Notice of Recommendation for
Enforcement (NRE) to ALCHEM identifying violations of N.C.G.S. 143-215.1 (6) and conditions of Water
Quality Non Discharge Permit No. WQ0002702.
G. The NOV/NRE was received on December 21, 2006, by certified mail with return receipt.
H. Staff costs and expenses associated with observing the violations, defining their nature and bringing
enforcement action totaled $467.54.
Based upon the above Findings of Fact, I make the following:
II. CONCLUSIONS OF LA
A. ALCHEM is a "person" within the meaning of G.S.143-215.6A pursuant to G.S. 143-212(4).
B. Permit No. WQ0002702 is required by N.C.G.S. 143-215.1. This permit was issued on January 21, 1999,
and expired on December 31, 2004.
C. ALCHEM violated G.S. 143-215.1(a)(6) and conditions 5, 8 and 11 of DWQ Permit No. WQ0002702 by
failing to take immediate corrective action when the facility failed to perform satisfactorily, for damage to
the groundwaters as a result of the operation of the facility and, for failure to maintain two feet of freeboard
in the lagoons at all times.
D. 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.
E. 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.
F. The Regional Supervisor of the Mooresville Aquifer Protection Section, Division of Water Quality, pursuant
to delegation provided by the Secretary of the DepartmentofEnvironment and Natural Resources and the
Director 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 is hereby assessed a civil penalty of:
$ 467.54
IV. NOTICE:
for failing to perform to permit standards as required by G.S. 143-215.1 and,
permit condition 5, which states that in the event that the facilities fail to perform
satisfactorily, the permittee will take immediate corrective action
for permit condition 8, which holds the peirmittee responsible for damages to the
grouhdwaters resulting from operation of the facility
for permit condition 11 for failing to maintain two foot of freeboard in all of the
lagoons at all times
TOTAL CIVIL PENALTY, which is 0% percent of the maximum penalty
authorized by G.S. 143-215.6A.
Investigation and Enforcement costs assessed.
TOTAL AMOUNT DUE
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, Inc., in
accordance with N.C.G.S. 143-215.6(A)(d).
(Date) Andrew H. Pitner, P.G.
Environmental Regional Supervisor
Aquifer Protection Section
Mooresville Regional Office

JUSTIFICATION FOR REMISSION REQUEST
Case Number: PC-2006-0586 County: Rowan
Assessed Party: ALCHEM, Inc.
Permit No. (if applicable): W00002702 Amount assessed: $
Please use this form when requesting remission of this civil penalty. You must also complete the "Request For
Remission Waiver of 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 14313-282.1(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, Inc., )
Permit NO. WQ0002702 )
WAIVER OF RIGHT TO AN
ADMINISTRATIVE HEARING AND
STIPULATION OF FACTS
FILE NO. PC-2006-0586
Having been assessed civil penalties totaling 00.00 for violation(s) as set forth in the assessment .
document of the Division of Water Quality, Aquifer Protection Section dated March , 2007, 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 are as 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 20
Signature
ADDRESS
TELEPHONE

March ... , 2007
MEMORANDUM
TO: Ed Hardee
FROM: Andrew Pitner
PREPARED BY: Peggy Finley
SUBJECT: Enforcement
Violation of Permit No. WQ0002702
ALCHEM, Inc.
Attached is the enforcement report/recommendation concerning violations of the subject permit. The
violations resulted from ALCHEM's failure to take immediate correction action when the facility failed to
perform satisfactorily, for damages to the groundwaters as a result of the operation of the facility and,
for failure to maintain the required two -foot freeboard in the lagoons. This Office is issuing a civil
penalty.
The attached material should be self-explanatory; however, if you have any questions, please contact
Peggy Finley or me.
Attachments
MAF

Page 1
Summary
On December 5 and 12, 2006, DWQ staff from the Mooresville Regional Office visited the ALCHEM
facility for a pre -scheduled inspection and a follow-up inspection. David Goodrich from the Central
Office accompanied regional office staff on December 5. The inspection, including a review of the
records, revealed that the recycle system has not performed satisfactorily for an extended period of
time. This is evidenced by wash water and residuals that are very acidic and that contain significant
amounts of aluminum. The operation of the lagoons has been poor as evidenced by the lack of the
required freeboard. In addition, the Division has reason to believe that there has been damage to the
groundwater in. the vicinity of lagoon #2 from this recycle system. The first two conditions have been
observed and reported in previous inspections but have not been addressed by the permittee.
Chronology of Recent Events/Correspondence
December 5, 2006 — An inspection revealed the same site conditions found, in previous inspections,
including low pH in all three lagoons and freeboard less than the required two feet in Lagoon #3. In
addition, groundwater sampling performed that day confirmed permittee-reported elevated
concentrations of aluminum in downgradient monitoring well MW-2.
December 20, 2006 — a NOWNRE was issued for permit (WQ0002702) violation of permit conditions 5
(failure to perform to permit conditions satisfactorily), 8 (damages to groundwater), and 11 (failure to
maintain adequate freeboard).
January 11, 2007 — Randall Andrews of ALCHEM responded by fax to the violations in the notice
(Attachment #... ). He attributed the high readings for aluminum -in MW-2 to poor sampling methods
and questioned the measurement by MRO staff of 1.5 feet of freeboard in lagoon #3. He stated that he
would have a plan ready shortly. He asked for a meeting with the MRO staff to discuss the issues.
January 16, 2007 — MRO emailed and faxed Randall Andrews regarding a date for the meeting
originally scheduled for January 24, 2007 and now moved to January 31, 2007 at 10:30 AM, to
accommodate Mr. Andrew's schedule.
January 31, 2007 — Meeting at MRO with Randall Andrews, ALCHEM and Gary Ribblett, P.E. Senior
Projects Manager, Delta Environmental. Mr. Andrews did not provide a plan or timeline for removal and
disposal of the lagoon residuals. Mr. Andrews stated that he would submit a plan by February 2, 2007.
February 19, 2007 — Mr. Andrews faxed a response to the January 31 meeting. (Attachment #... ). In it
he promised a prompt solution for the low pH in the lagoons and a timely response to the groundwater
problem. No further communication has been received from Mr. Andrews regarding these matters.

CHECKLIST FOR PERMIT VIOLATIONS
1. A copy of the Permit (#WQ0002702, expired) is attached.
2. The violator is ALCHEM, Incorporated. Mrs. Julia M. Andrews is the registered agent for the
company.
Mrs. Julia M. Andrews
2042 Buie Philadelphus Road
Red Springs, North Carolina 28377
3. This enforcement involves violations of non -discharge Permit conditions.
4. Copies of correspondence are attached.
5. Laboratory reports for chain -of -custody groundwater samples collected on December 5 are
attached.
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 violation is considered to be chronic due to poor management practices over at least the
last 24 months.
8. Were any specific notifications submitted concerning noncompliance?
A NOWNRE was sent on December 20, 2006, which documented the subject permit violations
and indicated that an enforcement recommendation would be prepared.
9. Cost of the investigation:
4 hours by Peggy Finley for preparation
of enforcement report at $20.38/hour = 81.52
2 hours by Andrew H. Pitner, P.G. for supervisory review
at $28.62/hour = 57.24
1 hour for clerical processing at $10.93/hour = 10.93
Mileage 50.8 @ $0.26 per mile = 13.21
Certified mail, 1 @ 4.64/ea. = 4.64
Administrative Cost for processing .report = 300.00
Total $ 467.54

Page 3
CIVIL PENALTY ASSESSMENT FACTORS FOR WATER QUALITY CASES
Type:. Permit Violations
Non -Discharge Permit No. WQ0002702
Violator: ALCHEM
Regional Office: Mooresville
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:
There has been no documented harm to the public health or private property as a result of these violations.
Groundwater has been impacted by elevated levels of aluminum.
2. The duration and gravity of the violation:
Two of the violations were first identified during an inspection on 09/20/2005. The same deficiencies were found
during an inspection on 12/05/2006. The increasing levels of aluminum have been documented by permittee self -
monitoring reports since June 2006.
3. The effect on water/groundwater quality:
Groundwater in the vicinity of MW-2 contains levels of aluminum that are considerably higher than background
conditions.
4. The cost to rectify the damage:
The cost to rectify damage is difficult to determine. ALCHEM has not taken any preventive or responsive action
to date.
5. Amount of money saved by noncompliance:
The amount of money saved is difficult to determine.
6. Whether or not the violations were committed willfully or intentionally:
ALCHEM has been notified about poor operating conditions several times through inspections and the issuance
of Notices of Violation for two related permits that it holds.
7. The prior record of the violator in complying or failing to comply with programs over which the
Environmental Management Commission has regulatory authority:
The ALCHEM facility has an extensive record of non-compliance with DWQ, 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.
Please see ALCHEM file history attached.
8. Type of violator and general nature of business:
The permittee manufactures chemicals for water and wastewater treatment. The primary use of the facility is to
convert bauxite ore into alum.

9.
10.
Page 4
Violator's degree of cooperation (including efforts to prevent) or recalcitrance:
The permittee has demonstrated a pattern of denying and/or disputing staff findings along with excuses for poor
management of the recycle system, including lack of knowledge of problems at the site. This is typically followed
by promises of action with inadequate or no actual follow through.
Mitigating circumstances:
This Office is concerned with the twenty-one year history of poor management of ALCHEM's non -discharge
facilities. ALCHEM continues to demonstrate a lack of attention regarding permit conditions and management of
the recycle system. Verbal promises of action to improve the situation have not produced results.
See file history included in package.
11. Cost to the State of the enforcement procedure:
The cost to the State in bringing about this enforcement action is as follows:
4 hours by Peggy Finley for preparation
of enforcement report at $20.38/hour
= 81.52
2 hours by Andrew H. Pitner, P.G. for supervisory review
at $28.62/hour = 57.24
1 hour for clerical processing at $10.93/hour = 10.93
Mileage 50.8 @ $0.26 per mile _ = 13.21
Certified mail, 1 @ 4.64/ea. = 4.64
Administrative Cost for processing report = 300.00
Total $ 467.54

DIVISION OF WATER QUALITY -- CIVIL PENALTY ASSESSMENT
Violator: ALCHEM, Inc.
County: Rowan
Case Number: PC-2006-0586
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 (X) moderately significant ( ) significant ( ) 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 ( ) moderately significant (X ) significant ( ) very significant () extremely significant
4) The cost of rectifying the damage;
( ) not significant ( ) moderately significant (X) significant () very significant( ) extremely significant
5) The amount of money saved by noncompliance;
( ) not significant ( ) moderately significant (X) 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.
Date Alan Klimek, P.E.

i
03/11/2007 22:06 9108435789 IAC INC
. ALCHEM., INC.
Corporate Office
2042 Buie Philadelphus Road
Red Springs, NC 28377
Tel. [phone]
Fax [phone]
rfa(@--emr,net
March 1.2, 2007
Mr. Andrew Pitner.
Environmental Regi.o»al, Supervisor
NCDENR
61.0 East Center St., Suite: 301
Mooresville, NC 28115
Dear Mr. Pti.ner:
PAGE 02
Sales and Manufacturino
8135 Red Road
Rockwell, NC 28138
Tel. [phone] — 800-462-2586
Fax [phone]
pdryeCa alltel.net
We have received tbi.s .Letter of Recommendation from Gary Ribblett with DELTA
ENVIRONMENTAL, We are in desperate need to start the sand removal process. Please
advise as to What the next step we take should be.
Best regards,
A..LC.HEM, INC
Randall F- Andrews,
Plant Manager
ams
tr

03/11/2007 22:06 9108435789 IAC INC PAGE 03
SUSTAINABLE STRATEGIES FOR GLOBAL LEADERS
March 9, 2007
Mr. Randall Andrews
ALCHEM, Inc.
2042 Buie Philadelphus Rd.
Red Springs, NC 25377
Subject: Progress and Recommendations
Rockwell, North Carolina
Dear Randall:
This letter is to confirm our conversation regarding our recommendations
previously discussed_ You have explained to me that you are in the process of
cleaning out the old, damaged reactor, and that you plan to install the new
mixing tank very soon. I understand that installation of this new washer -mixer
will allow you to discharge the sand -water mixture into the lagoons at a pH of
6.0 or higher as required by permit.
In order to successfully raise the pH of the existing lagoons however, it would
be best to be able to remove the sand from the lagoons to be treated to raise
its pH. Otherwise, the beneficial effect of your new washer -mixer will be
limited by the lower pH sand already in the lagoons.
In our meeting in Mooresville with NO DENR, Ms. Huffman and Mr. Pitner
indicated that they may be amenable to placing additional sand in the storage
DELTA area if it had its pH appropriately raised. I agree with them that this higher pH
material would likely have a beneficial effect on stormwater and leachate from
the disposal area.
Per the measurements we have discussed, placing sand with a higher pH into
the disposal area should have a beneficial effect on the pH of stormwater and
leachate from the existing fill area_
If sand can be cleaned from one lagoon at a time and mixed with sufficient
lime, it may be possible to place the sand in the disposal area and help with
the pH of the runoff. Regular sampling and documentation of the pH of each
batch of the treated sand will help verify that we are moving in the right
direction.
The most recent correspondence from NC DENR forbids additional sand
placement in the disposal area, so their prior approval would be required
before placing the sand.
Once the lagoon is cleaned of lower pH sand, and a higher pH sand -water
mixture can be added from your new mixer, you should have more success in
raising the lagoon pH, hence addressing problems in both the fill area and the
lagoons. Clearly it will be much easier to raise the pH in an empty lagoon than
one that contains lower pH sand.
8008 Corporate Center Drlve Sulte ioa Charlotte, NC 2e226 USA
Phone: :n-I.e,ai. ar :+c) / A00.477.71 1 I. Fax 7n-t. ;•1 ;.�U_�,

PAGE 04
'13/11/2007 22:06 9108435789
Mr, Randal Andrews
ALCHEM, Inc.
5tormwater Pond Berm Reconstruction
Match 9, 2007
IAC INC
2of2
We would he happy to discuss these recommendations in more detail at your convenience_ Please do not
hesitate to contact me at [phone] with questions,
Sincerely,
DELTA ENVIRONMENTALCONSULTANTS, INC.
Gary C. Ribblett, RE.
Senior Project Manager

" "03/11/2007 22:06 9108435789 IAC INC PAGE 01
AL CHEM9 INC.
8135 RED ROAD
ROCKWELL, NC 28137
PHONE: [phone] FAX [phone]
EMAIL: PDRYE@ALLT)EL.NET
FAXTRANSMITTAL
DATE AND TIME:
MARCH 1 2, 2007
TO:
ANDREW PITNER
COMPANY:
N O D E ICI R
FAx NO.:
704-663-6040
FROM:
ANGELA
COMPANY:
ALCHEM INC.
PHONE NO.:
704-279-7908
FAx No:
704-279-8418
No. OF PAGES:
9 !�, INCLUDING COVER
MESSAGE:

M-
AP
February 19, 2007
Mr., Andrew Pitner
Environmental Regional Supervisor
NCDENR.
610 East Center St., Suite 301
Mooresville, NC 28115
Dear Mr. ,-LIPT:,
I would like to address some of the problems that we discussed in our 1-neeting with Ms.
Peggy Finley.
1. The pl-i of the lagoons were low. We expect to solve this problem shortly. We
should have the damaged reactor out of the way. We should start to neutralize the
tiny bit of free acid contained in the sand
2- We are looking at the problem that you indicated that we have with the down
slope monitoring well. I will have more on it by the end of the week. I will go
back and do some research on the analytical results. If there is a definite need I
will do another sample for the well.
3. The lagoon with a water level too close to the top. I spoke with Wayne Drye
about this again. I can, not say what happened as I was not there. The real
problem is that there is too much sand in the lagoons and they need to be at least
partially emptied. I have looked at the 13OYLE report again. It states that we
should have done a better job of packing down the sand. It gives several other
suggestions. It does not indicate to me that there is any problem that we cannot
solve. We did not get our track hoe to dig out the sand until late in November.
We also have our packer at Rockwell and we can pack the sand and place it in
"thin lifts" that will suit for the compaction. We plan to get a. company such as
SandME to work with us on this. I really see no problem at all with this. We
really need more sand at the area where we will build. I do not plan to put any
sand on the west side of the railroad. All of the sand is mixed with Lime. We test
each load. Again, I am asking what I can do to satisfy you. that placing some of
the sand on our build area wil I not cause any problem environmental or otherwise.
I believe from the letters I receive from you that you do not feel that we really
plan to build. Alchem is not using the sand fill area as a dumping ground. Our
objective is to use the sand beneficially.
Best regards,
'HE C:
Randall F. Andrews,
Plant Manager
anxs

boe-
01/28/2007 19:55 9108435789 IAC INC
ALCHEM, INC.
Corporate Office
2042 Bole Phlladelphlls Road
Read Springs, NC: 28377
Tel. [phone] -- 800-522-2944
F,ix 91p.843-5789
rfaCr.�semr.net
January 26, 2007
Mr, Andrew Pitner
,F_.»virownental Regional Supervisor
NCDENR
61.0 .East Center St-, Suite 301
Mooresvil-le, NC 28115
Re; .NOV No. NOV-2006-PC-0061
Dear Mr. Ptiner:
PAGE 01
Sales and Manufacturing
81.3.5 Red Koad
Rockwell, NC 28138
Tel. [phone] — 800.462-2586
Fhx 704-279-8418
pdryeQalltel.net
T1,.a1tk you for your letter of January 19, 2007. Alchem has not used tiie permitted fill
area since we .received a letter about this in mi.d .December.. I have been. talking with
Engineers about this project since then. and trying to .find a solution to tbis .problem. At
one time we sold some of our sand to a fertilizer manufacturer. I have contacted thorn
and taken new samples to try andget this as atl outlet again. The only proposal that I
have, I recently received and just the cost for the engineering was fa.r more than the value
of our company. At one time I called the Salisbury Landfill, but having to pay the
disposal fee is someth.in.g that would wreck us economically. We are .fast pulling tl.�e
water down to very minimal Ievel.s again. There were two very large rain storms back in
middle and late November. We have changed the ditch coming under the railroad and so
now the water from the large area across the railroad is diverted frorn. our contained area.
I would like to ask that you consider allowing us to put about 500 tons from the storage
area nearest. our reactorinto the area near the railroad. I plan to use that fill., and that area.
on wh.i.ch to put our Maga.esium. Hydroxide and Calcium. Hydroxide unixing tanks.
Thank you for, your consideration.
Best regards,
ALCHh1VI, INC
Randall F. Andrews,
Plant Manager.

01/11/2007 03:29 9108435789 IAC INC
PAGE 01
ALCHEM, INC.
8135 ICED ROAD
ROCKWELL, NC 28137
PHONE: 704-279M7908 FAX [phone]
ENTAIL: PDRYELPALL•,TEL-NI T
FAX TRANSMITTAL
DATE AND Tw:
JANUARY 1 1, 2007
TO:
PEGGY FINLEY
COMPANY:
NCDENR
FAX No.:
704-663-6040
FROM:
ANGELA
COMPANY.
ALCHEM INC.
PHONE NO.:
704-279.7908
FAx No, .
704-279-84.18
NO. OF PACES: 4, INCLUDING COVER
MESSAGE:
0

FROM FAX NO. : Feb. 21 2002 10:54PM P1
ALCHEM., INC.
Corporate Office Sales and Manufacturing
2042 Buie Phiindelphus Road 8135 Red Road
Red Springs, NC 28377 Rockwell, NC 28138
Tel. [phone] — 800-522-2944 Tel. [phone] w 800-462-2586
Fax 910.M-5789 Fax [phone]
rfa(u)seranner pdrye@alftel,net
C ebruary 9, 20[17=�'
Mr. Andrew Pitner
Environmental Regional Supervisor
NCDENR
610 East Center St., Suite 301
Mooresville, NC 28115
Dear Mr. Ptiner:
Thank you for meeting with me last Wednesday. I would like to outline some of the
problems that we have discussed.
Seepage of the captured liquid.- We were unaware that there could be seepage. I have
called at least 6 engineering companies to try and get some help. Several of them, such
as BOYLE ENGTNEEI-ING were too busy for the foreseeable future. I did get people
from two firms to come and look. Monday afternoon..I had another on site visit and I feel
that this firm has an idea of how to solve the problem that will work scientifically and be
economical. We expect to have a very sound step by step plan very shortly. This plan
should include work by a Geologist and PE. I have looked into taking the sand
somewhere else. At one time I had contacted the ROWAN COUNTY LANDFILL. I
have called them again. 1 can tell you that if we are forced to take out the sand to a
landfill, there is every possibility that because of the economics ALCHEM will not be
able to survive- There is a real possibility that ALCHE.M will be forced to close and
terminate the jobs of all employees. Our business has not been profitable for several
years. In the last four years we have had two very large competitors declare bankruptcy
and close plants. I realize that it is not your responsibility to keep our company
operating, but it is mine, and I do not wish to close and tell our employees to go to work
elsewhere.
dn*We are currently mixing all of the sand that we remove from Lagoons with lii-ne and then
we check the pH to make certain that it is above 6. We have the test results�e �ur�
AVU t�rea.suri g i1MI C.tirt eras can 9iffil f T 17clieve that MS. }It�££nlan has reviewed these results
in t eh past. One of the stipulations of the Lagoon permit is that a. pH level of 6 be tested
for and results logged. I lr- ,.e Geri°a�'prly is rto stile ctu"rt�a�l reason, for nC+t�rt iri _the send ic�.s
: e tk>Le g. fracg-%This is an area that I wish to
use for our Alkali Slurry manufacturing. We now have all of the equipment on site to
place the sand and compact it to a level where there will be some structural integrity.

FROM : FAX NO. : Feb. 21 2002 10:55PM P2
INCO
Corporate Office Sales and Man acturin
8135 Red Road
2D42 Buie Philodelphus Rpad Rockwell, NC: 28138
Red Springs, NC 28377 TeL [phone] ^- 800-462.2586
Tel, 910-843-2121 — 800-522-2944 Fax [phone]
Fax 9104�43.5789 [e-mail]
;fa(u�semr.net
There is no problem with using the sand but it is necessary to pack it properly. My
understanding is that it is necessary to pack approximately 6 feet of sand to achieve a
sound structural integrity. If we use clay or fill from off site, we would need to use the
same
a di packing procedures d�sar
-enbayd spotential
users of the sand. I could give you a list if that is necessary- I have several other
possibilities that we are exploring. A# ane time we sold the sand to a fertilizer
manufacturer as a filler and replacement for river Sand. I have contacted the Plant
Manager and personally taken a sample. I have furnished them with analytical data on
the sand. The project is certainly in the discussion stage. I do not see the need to furn. ish
you at this time with his name and telephone number. They are within 60 miles of
Rockwell and the economics will work. I am following this very closely and will check
on this again probably Monday or Tuesday. I have some other potential uses and I aryl
exploring them. All of these take time and cannot be done fast. We need to use 500 tons
of our sand now. We currently mix it with Lime, We have lime on site for the mixing
and pH adjustments. We expect to remove the bricks and damaged reactor and place the
newly built wash tank within 7-10 days. This should allow us to remove more of our
product from the sand and more easily raise the pH level of the sand.
I would like to point out that the level of water in the sand berm area is already very.low.
We have diverted the storm water around the berm area instead of into it. We are
currently pulling up water from this area into our process. We feel that within 7-10 days
there will be no water in this area. We feel that with the storm water diversion that we
will be able to keep the water level at a level so that there is essentially no danger of any
additional possible seepage.
Please consider my request to remove some of the sand from these lagoons and use it so
that we can continue to operate our facility in a financially sound manner.
Best regards,
ALCHEM, INC
Randall F. Andrews,
Plant Manager
arcs

+' 610 Elast Center Avenue, Suite 301
Mooresville, North Carolina 28115
Telephone: [phone]
Fax: [phone]
-IlTo:::L>j6j,-O( From: e',^ j
Fax: _ '� S'� Pages:
Phone: Date: / '7
Re: CC:
❑ Urgent ❑ For Review ❑ Please Comment ❑ Please Reply ❑ Please Recycle

W
01/11/2007 03:29 9108435789 IAC INC
ALCHEM,, INC.
Car orate; Office
-042 Buie Philadelphus Road
Red Springs, NC. 28377
Tel. 910-843,2121 — 800-522.2944
Fax [phone]
rfaq�semr.net
January 1 1, 2007
Ms. Peggy Finley
Division of Water Quality
NCDENR
610 Fast Center Ave.
Suite 301
Mooresville, NC 2811.5
Re: Permit No: WQ0002702
NOV No. 2006-PC-0586
Dear Ms. Finley:
There are three problems indicated in your NOV.
PAGE 02
Sales and Man.ufacturin
8135 Red Road
Rockwell, NC 28138
Tel, 704-279-7908 -- 800-462-2586
Fax [phone]
[e-mail]
1. The .i.ow pig. We are adding Lime to increase the pH of the water in the lagoons.
We are washing; the sand. We have built another washing tank and mixer to
additionally wash the sand.
2. The very latest sample for Aluminum was 0.555 mg/I. This sample was taken at
the same time as your visit of. 12-5-06 and kept in our sample locker until it was
sent to PAR Labs oil 12-12-06. 1 really feel that any increase in. Aluminum would
be much mare attributable to poor sampling methods that scooped up Aluminum
Silicate from the ground water than a leaking lagoon. We intend to investigate
this further. What are the results of your sampling?
3. 1 spoke with Wayne Drye and he said that he .felt that the freeboard in all of the
lagoons was more than 2.0. feet. We .intend to pay much closer. attention,, to this.
We do not expect this to continue. to happen if it did happen to be less than 2.0
feet. I have searched for an engineering f,rm that can help us with some of these
things that need correction. T have met wit], this company twice and had a site
visit by one of their employees that can help us.
I plan to prepare a. list of items that need work and present it to you. with a list of what we
Plan to do as well as a time line to finish. I will plan to ,have that .ready shortly. I would
lake to meet with you as soon as your time schedule allows.
Best regards,
AIL CHFM, INC

01/11/2007 �j03:29 9108435789 IAC.INC
Randall F. Aizdrews,
President
a..ms
PAGE 03

01/11/2007 03:29 9108435709 IAC INC PAGE 04
" "'1s t042798418 ALCHEM INC
PAGE el
PAR Lalboratarles, Inc:
2217 Graham Pork Drive
ueoparoA�ES Wa PO Box Al 1483
Charlo"o, NC 282AI-1481
Phone: [phone]; Fax: 704-�58S•8335
lUC Ctrr! N ao; BC Cart d` A90d9
wwwpariabs.com
ti
REPORT OF ANny.-ZS
A.ttn; PHYLLIS DRYS
,A.LCHEM INC
8135 RED ROAD PROLIECT PIAM9! MSC 05
ROCXWMLL, VC 28138- DATZ, 12/3-9/06
SAMPLE NUMBER- 75479 SAMPLE ID =12
DATE �.�`1"-P�FP• 32/12/05 SAMPLE MATRjx- Witt
DATE RECEIVED- 12/13/06 SIMPLER- LMN TIME SAMP•LUD' Um
TIME RECEIVED- 1131 AELIvzRED BY- UPS RECEIVED 6y. M&Y'
TYPE SAmpLE,. Oxa4 .
Page 3 of 2
ANALYSIS .ANALYSzs
METHOD DATE TIM$ RY RESULT UNITS
ALUMINUM, TOTAL EPA 200.7. 12/19/06 11D2 CT 0.55S mg/L
1ADOPATORY DIRSCTOR

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ection
Sample ID: AB11322
Descr.: ALCHAM 0 PO Number # 6G2384
Location ID: MROAPNLC p VisitlD
County: ROWAN z F \NATE
D0�O 9Q Collect Date: 12/05/2006
River Basin pt § `O G Collect Time:: 11:20
Report To MROAP —„• - I I R r
Region: MRO 7J1 o Y �l j' Date Received: 12/06/2006
Collector: P FINLEY -+ o e r Time Received: 09:30
Sample Matrix: GROUNDWATER m p
cD Labworks LoginlD AMA
Loc. Type: WATER SUPPLY E
Sample Depth � ` Date Reported: 01/04/2007
Emergency Yes/No
Sample Comment
• COC Yes/No YES
CAS# Analyte Name PQL Result Qualifier Units Approved By
LAB
Sample temperature at receipt by lab I I 0.8 °C MMATHIS
_ MET
7429-90-5 Al by ICP 150 1 790 uq/L ESTAFFORD
7439-96-5 Mn by ICPMS 110 I 15 ug/L ESTAFFORD
Laboratory Section>> 1623 Mail Service Center, Raleigh, NC 27699-1623 [phone] Page 1 of 1

, I GROUNDWATER FIELD/LAB FORM
County --Rt> V�Ck1\^1 _ 1_1 '0 eZ:) Z �2 --/
Quad No_____________ Serial No.________________
Lat--------------- — Long .------- ----------
Report To: ARO, FRO,6 , RRO, WaRO, WiRO,
Department of Environment and Natural Resources
DIVISION OF WATER QUALITY -GROUNDWATER SECTION
SAMPLE TYPE SAMPLE PRIORITY ] —
XWater Routine Lab Number /��/ .��___
❑ Soil ❑ Emeroencv �1 t Date Receivedl�_�p `��Ti . ............ D..
❑ Other-__--:Rec'd By(t From:Bu , Courier, and Del.,
Chain of Custody Other:__ _—
Data Entry By:— _— Ck:_—_-----
WSRO, Kinston FO, Fed. Trust, Central Off., Other: ----------------------- Data
----
Shipped by: Bus, ourier and Del., Other: ----- • _ _Purpose: Reported: — --------------- —----- --
��__
Collector(s):____, —C_ r� 1-— Date__�2A-: ©�Time_�! � _ Baseline, Complaint(iompliance, UST, Pesticide Study, Federal Trust, Other: ________---_
FIELD ANALYSES (circle one)
•Owner----� �--���M --=-- --- — - - - -- -
pH 400.-- --� �"�----------- Spec. Cond.o4------ -
-----at 25°C Location or Site----�=,-3 �-- � � L�--��-'`=�----�---- t. r�_�.3 ���------------------ -- -
Temp.io_-----� � °C Odor-2 .----------------- Description of sampling point____ p"1'J
Appearance illir' z�� _— ' -----------------
{-- Sampling Method__�.� — _ _ Sample interval
__---------
Field Analysis By: -------------- Remarks-- '
LABORATORY ANALYSES 1/.5.<-,,;;r..,4PP gtime, air te-----_Y---- � ---- um in ., etc.)
BOD 310 mg/L
COD High 340 mg/L
COD Low 335 mg/L
Coliform: MF Fecal 31616 /100ml
Coliform: MF Total 31504 /100ml
TOC 680 mg/L
Turbidity 76 NTU
Residue, Suspended 530 mg/L
pH 403 units
Alkalinity to pH 4.5 410 mg/L
Alkalinity to pH 8.3 415 mg/L
Carbonate 445 mg/L
Bicarbonate 440 mg/L
Carbon dioxide 405 mg/L
Chloride 940 mg/L
Chromium: Hex 1032 ug/L
Color: True 80 Cu
Cyanide 720 mg/L
Lab C
Diss. Solids 70300 mg/L
Fluoride 951 mg/L
Hardness: Total 900 mg/L
Hardness (non-carb 902 mg/L
Phonols 32730 ug/I •
Specific Cond. 95 uMhos/cm
Sulfate 945 mg/L
Sulfide 745 mg/L
Oil and Grease mg/L
NH3 as N 610 mg/L
TKN as N 625 mg/L
NO2 + NO3 as N 630 mg/L
P: Total as P 665 mg/L
GW-54 REV. 12/87 For Dissolved Analysis -submit filtered sample and write "DIS" in block.
g-Silver 46566 l`r '} ug/L
AI -Aluminum 46557 ug/L
As -Arsenic 46551 ug/L
Ba-Barlum 46558 ug/L
Cn-Cnlclum 46552 mg/L
Cd-Cadmium 46559 ug/L
Cr-Chromium 46559 ug/L
Cu-Copper46562 ug/L
Fe -Iron 46563 ug/L
Hg-Mercury 71900 ug/L
K-Potassium 46555 mg/L
Mg -Magnesium 46554 mg/L
Mn-Manganese 46565 ug/L
Na-Sodium 46556 mg/L
Ni-Nickel ug/L
Pb-Lead 46564 ug/L
Se -Selenium ug/L
Zn-Zinc 46567 ug/L
Organochlorine Pesticides
Organophosphorus Pesticides
Nitrogen Pesticides
Acid Herbicides
PCBs
Semivolatile Organics
TPH-Diesel Range
Volatile Organics (VOA bottle)
TPH-Gasoline Range
TPH-BTEX Gasoline Range
LAB USE ONLY
Temperature on arrival: /
E

Report to: MRO GROUNDWATER SECTION Page / of /
CHAIN OF CUSTODY (COC) RECORD
NC DENR/DWQ LABORATORY (check one): [ X ] CENTRAL [ i ARO [ ] WaRO
For Investigation of: Soil Groundwater Incident No.
Sample collector (print name)
and GW-54 forms completed by: MARGARET FINLEY Sample collector's signature:
Field storage conditions and location (when applicable):
Lab Use Only
LAB NO.
SAMPLE ID
QUAD. NO.
LOCATION
DATE
SAMPLED
TIME
SAMPLED
NUMBER
OF
CONTAINERS
nn IC
0w
I'nji
DC-
ZUUb
DENR
MRO
L—D—WQ Ac
uifer Protec
off—
Relinpished by (signature):
Date
Time
JZ
ei by (sign e):
C
ate
o
me
Relinq ' ed by (signature):
Date
Time
Received by (signa re):
Dale
Time
Relinquished by (signature):
Date
Time
Received by (signature):
Date
Time
Method of Shipment (circle one). State Couri Hand -delivered Federal Express UPS Oth
Security Type and Conditions:
Sealed by:
Margaret Finley,
I on h
A�ZijSg�
INTRAI,ARORATORV CTTAIN OP CTISTCII)V - T.qh Tice ()nly
LAB NUMBERS
FROM THROUGH
NUMBER
BOTTLES
ANALYSES
REQUESTED
RELINQUISHED
Y:
RECEIVED
BY:
DATE
TIME
o� C
QA\Forms\Sample Receiving\COC form GW 4/10/Oldbs

I��il Laborato Section esufts
1
�.,Loc. Descr.:
ALCHAM
Sample ID:
AB11323
p
PO Number #
6G2385
Location ID:
MROAPNLC
L
VisitlD
County:
River Basin
ROWAN
r--);
k� C7�
!�
Z
u
Or[ArFR
�� QG
Collect Date:
Collect Time::
12/05l2006
11:40
Report To
MROAP
�I
u c
Z;
Region:
MRO
41 %0ti
Uo C==:3
d
Date Received:
12/06/2006
Collector:
P FINLEYC
o
Time Received:
09:30
Sample Matrix:
Loc. Type:
GROUNDWATER iD 01
WATER SUPPLY
_
Labworks LoginlD
AMA
0
Date Reported:
01/04/2007
Sample Depth
Sample Comment
Emergency Yes/No
COC Yes/No
YES
CAS#
Analyte Name
PQL Result Qualifier
Units
Approved By
LAB
Sample temperature
at receipt by lab
I I 0.8
°C
MMATHIS
MET
7429-90-5
AI by ICP
150 I 4200
ug/L
ESTAFFORD
7439-96-5 Mn by ICPMS 110 I 440 ug/L ESTAFFORD
Laboratory Section>> 1623 Mail Service Center, Raleigh, NC 27699-1623 [phone] Page 1 of 1

GROUNDWATER FIELD/LAB FORM
SAMPLE TYPE SAMPLE PRIORITY
County_—_ C W a-1-, — �� D� �� Water Routine
Quad No_____________ Serial No ❑ Soil ❑ Emeraencv
Lat.---------------- Long.--------________ ❑ Othcr_. _ ...:-------- ------ ---
tihain of Custody
Report To: ARO, FRO, vIRO, WaRO, WiRO,
WSRO, Kinston FO, Fed. Trust, Central Off., Other: _ _
pp y Hand Del., Other:___----_ _ _ Purpose:
Shipped b : Buy, our'
North Carolina - /
Department of Environment and Natural Resources
DIVISION OF WATER QUALITY -GROUNDWATER SECTION
Lab Numbet��_aM5
Date Received _ &P ie: r
Rec'd By: Received
(ouri , Hand Del.,
Other: —_--_
------------
Data Entry By:—_ -- Ck:--_—___
Data
Reported: --_-_____
Colleclor(s):' _ 1 n , ,N-_-- Date_t 2 s � Tilne_ �1� Baseline, Complain Com liance, UST, Pesticide Study, Federal Trust, Other:________
FIELD ANALYSES OWner G� cirdeone) ----
pH noa.s Spec. Cond.s,g' at 25"C Location or Site___.a
Temp.lo__—_1__ 2:i-�C-
..Odor ______________ Description of sampling p(
Appearance----- -------- Sampling Method-----
- T --- --
Field Analysis By: _
___---_------ Remarks__�-
LABORATORY ANALYSES c�
BOD 310 mg1L
COD High 340 mg/L
COD Low 335 mg/L
Coliform: MF Fecal 31616 /100ml
Coliform: MF Total 31504 /100ml
TOC 680 mg/L
Turbidity 76 NTU
Residue, Suspended 530 mg/L
pH 403 units
Alkalinity to pH 4.5 410 mg/L
Alkalinity to pH 8.3 415 mg/L
Carbonate 445 mg/L
Bicarbonate 440 mg/L
Carbon dioxide 405 mg/L
Chloride 940 mg/L
Chromium: Hex 1032 ug/L
Color: True 80 cU
Cyanide 720 mg/L
Lat) uomments
Diss. Solids 70300 mg/L
Fluoride 951 mg/L
Hardness: Total 900 mg/L
Hardness (non-carb 902 mg/L
Phonols 32730 ug/l
Specific Cond. 95 uMhos/cm
Sulfate 945 mg/L
Sulfide 745 mg/L
Oil and Grease mg/L
NHa as N 610 mg/L
TKN as N 625 mg/L
NOZ + NO, as N 630 mg/L
P: Total as P 665 mg/L
GW-54 REV. 12/87 For Dissolved Analysis -submit filtered sample and write'DIS' in block.
az--------
_--------------
Sample Interval__—___—_______
, _ / -����y� (PytKping time. air (amp., eta)
Ag-Silver 46566 ug/L
AI -Aluminum 46557 ug/L
As -Arsenic 46551 ug/L
Ba-Barium 46558 ug/L
Cn-Cnlclum 46552 mg/L
Cd-Cadmium 46559 ug/L
Cr-Chromium 46559 ug/L
Cu-Copper46562 ug/L
Fe -Iron 46563 ug/L
Hg-Mercury 71900 ug/L
K-Potassium 46555 mg/L
Mg -Magnesium 46554 mg/L
Mn-Manganese 46565 ug/L
Na-Sodium 46556 mg/L
Ni-Nickel ug/L _
Pb-Lead 46564 ug/L
Se -Selenium ug/L
Zn-Zinc 46567 ug/L
Organochlorine Pesticides
Organophosphorus Pesticides
Nitrogen Pesticides
Acid Herbicldos
PCBs
Semivolatile Organics
TPH-Diesel Range
Volatile Organics (VOA bottle)
TPH-Gasoline Range
TPH-BTEX Gasoline Range
LAB USE ONLY
Temperature on arrival: i

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so that we can return the card to you.
■ Attach this card to the back of the mailpiece,
or on the front if space permits.
r 1. Article Addressed to:
ALCITEM`INC..;.
8 13 5 RED ROAD:.
ROCKWEi L NC 28138'
ma t%nov/nore/nov-;20.06:ipc=0586,12/20/06
A. Sig ture
I ❑ Agent
X t, — b ElAddressee
B. Receive y (Printed Nam C. Date of Delivery
D. Is delivery address different from item 1? ❑ Yes
If YES, enter delivery address below: ❑ No
3. ice Type
gCertified Mail ❑ Express Mail
❑ Registered 126 Return Receipt for Merchandise
❑ Insured Mail ❑ C.O.D.
4. Restricted Delivery? (Extra Fee) ❑ Yes
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item 4 if Restricted Delivery is desired.
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0 Print your name and address on the reverse
❑ Addressee
so that we can return the card to you.
■ Attach this card to the back of the mailpiece, B{�Reeceived y (Printed Name) C. Date of Delivery
s� or on the front if space permits. ' r f •+O
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D. Is de ry address different from item 1?
1. Article Addressed to:
❑ Yes
If YES, enter delivery address below:
❑ No
ti M" R RANDALL•ANDRF,WS .
II ALCHEM INC
r t' 2042 BUIE PHILADELPHUS ROAD
, ,.RED SPRINGS NC 28377 3. SSjee lceType
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❑ Registered ES Return Receipt
for Merchandise
❑ Insured Mail ❑ C.O.D.
4. Restricted Delivery? (Extra Fee)
❑Yes
2. Article N tuber
(transfer rom!ser'vice Iabef) i i 7 G 2 2 Er g; Q 0 011: 3 4.9 4 .2399
6 m � f i Febft�ary 20b4 ( .. i 1 00, mestic Re !.(rti Rbcjlpt
102595-02-M-1540

O� :
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Randall Andrews
Alchem, Inc.
2042 Buie Philadelphus Road
Red Springs, North Carolina 28377
and
Alchem, Inc.
8135 Red Road
Rockwell, North Carolina 28138
Dear Mr. Andrews:
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
AQUIFER PROTECTION SECTION
December 20, 2006
RE: ' Notice of Violation/Notice of
Recommendation for Enforcement
NOV No. 2006-PC-0586
Violation of permit conditions of Non -
discharge permit No. WQ0002702
(dated January 21,1999)
Industrial Recycle — Bauxite Process
Rockwell, Rowan County
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 (DWQ) 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 December 5, 2006, staff from the Aquifer Protection and Surface Water Protection Sections
conducted an inspection at the referenced facility. A follow-up inspection was conducted on December
14, 2006. Additionally, a review was conducted of the subject permit (issued January 21, 1999) and your
groundwater compliance monitoring data. This information indicates that you are in violation.of the
following permit conditions:
Division of Water Quality / Aquifer Protection Section / Mooresville Regional Office Phone: [phone] Fax: [phone] NortliCarolina
610 East Center Avenue, Suite 301, Mooresville, NC 28115 Customer Service 1-877-623-6748 Internet: www.ncwaterauality.ora Naturally

t
Alchem
December 20, 2006
Page 2
Condition 5 — In the event that the facilities fail to perform satisfactorily, including the creation of
nuisance conditions, the Permittee shall take immediate corrective action, including those
actions that may be required by this Division, such as the construction of additional or
replacement treatment and disposal facilities.
• The low pH (ranging from 2.62 — 3.41 SUS) of the wastewater in the three lagoons
indicates that the recycle system is not effectively washing the residuals before
they enter the lagoons. See Attachment and inspection report.
Condition 8 - The issuance of this permit shall not relieve the Permittee of the responsibility for
damages to surface and groundwaters resulting from operation of this facility.
• The concentration of aluminum in MW-2 has progressively increased to where the
November 2006 compliance monitoring report showed MW-2 to have a
concentration of 4.76 mg/L. This would indicate that lagoon #2 is leaking and
impacting the groundwater.
Condition 11 — Freeboard in all of the lagoons shall not be less than two feet at any time.
• The freeboard in lagoon #3 was measured as 1.5 feet during the follow-up inspection.
Based on these problems, you are required to submit a report prepared by a North Carolina
professional engineer that specifies what steps need to be taken so that the recycle system will perform
satisfactorily. In addition, you must submit a plan, with a timeline, for removal and disposal of the
residuals in the three lagoons. You must have a North Carolina professional engineer verify the liner
integrity of each lagoon and repair of the banks. Your plan should include a design for stormwater
diversion. Please submit the engineering report and the plan within 90 days of receipt of this notice.
The 2006 inspections revealed that two of these deficiencies were found during the August
2005 inspection but were not corrected. Therefore, the Mooresville Regional Office is recommending
an enforcement action for the cited violations. If you have justification that these violations are caused
by circumstances beyond your control, or if have an explanation that you wish to present, please
respond in writing within twenty days (20) days following receipt of this notice. The Mooresville
Regional Office will review your response and forward it to the Water Quality Division Director with the
enforcement package. It should be noted that, in accordance with General Statute 143-215.6A,
initiation of an enforcement action could result in assessment of civil penalties of up to $25,000 per day.
Please address your response to the attention of Peggy Finley. It is also requested that your
response letter reference the date and subject of this NOV/NRE as well as the permit number. Should
you have any questions concerning this matter, please do not hesitate to call Ms. Finley at (704) 663-
1699.
Sinc. reiy,
Andrew.H. Pitner, P.G.
Environmental Regional Supervisor MRO APS

Alchem
December 20, 2006
Page 2
Condition 5 — In the event that the facilities fail to perform satisfactorily, including the creation of
nuisance conditions,, the Permittee shall take immediate corrective action, including those
actions that may be required by this Division, such as the construction of additional or
replacement treatment and disposal facilities.
• The low pH (ranging from 2.62 — 3.41 SUS) of the wastewater in the three lagoons
indicates that the recycle system is not effectively washing the residuals before
they enter the lagoons. See Attachment and inspection report.
Condition 8 - The Issuance of this permit shall not relieve the Permittee of the responsibility for
damages to surface and groundwaters resulting from operation of this facility.
• The concentration of aluminum in MW-2 has progressively increased to where the
November 2006 compliance monitoring report showed MW-2 to have a
concentration of 4.76 mg/L. This would indicate that lagoon #2 is leaking and
impacting the groundwater.
Condition 11 — Freeboard in all of the lagoons shall not be less than two feet at any time.
• The freeboard in lagoon #3 was measured as 1.5 feet during the follow-up inspection.
Based on these problems, you are required to submit a report prepared by a North Carolina
professional engineer that specifies what steps need to be taken so that the recycle system will perform
satisfactorily. In addition, you must submit a plan, with a timeline, for removal and disposal of the
residuals in the three lagoons. You must have a North Carolina professional engineer verify the liner
integrity of each lagoon and repair of the banks. Your plan should include a design for stormwater
diversion. Please submit the engineering report and the plan within 90 days of receipt of this notice.
The 2006 inspections revealed that two of these deficiencies -were found during the August
2005 inspection but were not corrected. Therefore, the Mooresville Regional Office is recommending
an enforcement action for the cited violations. If you have justification that these violations are caused
by circumstances beyond your control, or if have an explanation that. you wish to present, please
respond in writing within twenty days (20) days following receipt of this notice. The Mooresville
Regional Office will review your response and forward it to the Water Quality Division Director with the
enforcement package. It should be noted that, in accordance with General Statute 143-215.6A,
initiation of an enforcement action could result in assessment of civil penalties of up to $25,000 per day.
Please address your response to the attention of Peggy Finley. It is also requested that your
response letter reference the date and subject of this NOV/NRE as well as the permit number. Should
you have any questions concerning this matter, please do not hesitate to call Ms. Finley at (704) 663-
1699.
Sinc. rely,
4
Andrew.H. Pitner, P.G.
Environmental Regional Supervisor MRO APS

Alchem
December 20, 2006
Page 3
Enclosures: December 2006 Inspection Report
Attachment 1
Attachment 2
Site Map
Cc: APS Land Application Unit, Permits Enforcement
APS Land Application Unit — David Goodrich
Wayne Drye, Plant Manager — Alchem, Inc., 8135 Red Rd., Rockwell 28138
MAF/recycle/alchem/perm NOV 12-19-06

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
Alan W. Klimek, P.E., Director
N I �?W'j
0
IT
NCDENR
NON -DISCHARGE COMPLIANCE INSPECTION
Recycle/Reuse System
GENERAL INFORMATION
City/Town/Owner: Randall Andrews County: Rowan
Permit # WQ 0002702 Project Name: Alchem, Inc
Issuance Date: 1/21/99 Expiration Date: 12/31/04
Permittee Contact: Wayne Drye, Plant Mgr. Telephone No. '704/279-7908
ORC Name: none required
Reason for Inspection
X ROUTINE COMPLAINT FOLLOW-UP OTHER
Type of Inspection
Surface Irrigation X Recycle System Other
Inspection Summary. (additional comments may be included on attached pages)
The permit was renewed in 2004 but is still being adjudicated.. The recycle facility is
therefore operating under the permit issued in 1999. Violations that were identified during
the August 2005 inspection have not been corrected. This was pointed out to the plant
manager Mr. Drye. Lagoons #1 and #2 are still full but reportedly are not receiving the
slurry. Lagoon-#3 is full, but is still in use. Freeboard at its southeast end measured less
than the required 2 feet.
Is a follow-up inspection necessary_X_yes no
Inspector Name/Title Peggy Finley, Hydro Tech II
Tel. No. 704/235-2183 Fax No. 704/663-6040
Date of Inspections: Dec. 5 & 14, 2006

Permit #WQ0002868 Page 2
Type
_X_Recycle /Reuse
Treatment
Y Are treatment facilities consistent with those outlined in the current permit.
N Do all treatment units appear to be operational? If no, note below.
Comment: The recycle system is operating with only one reactor tank. The second
tank was reportedly damaged beyond repair a couple of years ago. It has not yet
been replaced. A neutralizer has reportedly been acquired but has not been
installed.
Residuals Storage Lagoons
(check any/all that apply)
Y Influent structure (free of obstructions)
Y Banks/berms (are there signs of seepage, overtopping, down cutting or erosion)
_N_ Vegetation (is there excessive vegetation on the lagoon bank
_?_ Liner (if visible, is it intact)
_NA Baffles/curtains (in need of repair)
N Freeboard (>2 feet from overtopping)
_N _ Staff gauge ( clearly marked)
_N_ Evidence of overflow (vegetation discolored or laying down/broken)
_N_ Unusual color (very black, textile colors)
NA Foam (are antifoam agents used)
_NA Floating mats (sludge, plants, inorganics)
—Y—Excessive solids buildup (from bottom)
NA Aerators/mixers operational (if present)
NE Effluent structure (free of obstructions, easily accessible)
Comments: Lagoons #1 and #2 are full but reportedly are not receiving slurry.
Lagoon #2 has been dredged in its southeast corner to prevent further overflow. It
is possible that this dredging has damaged the clay liner. Lagoon #3 is full and is
still in use. Freeboard at its southeast corner measured 1.5 feet. Reportedly, the
lagoons have not been cleaned out in two years. The banks of all the lagoons are
eroded in many places. There are gullies present that indicate that stormwater runs
into the lagoons.

Permit #WQ0002868
Recordkeepina
Page 3
Y Is permit available upon request?
_Y Is GW monitoring being conducted?
_Y_ Are monitoring reports present?,
Y Are lab sheets available for review?
Y Are all samples analyzed for the required parameters?
_N_ Are there any 2L GW quality violations?
_N_ Is a GW-59A completed for facility?
NE Are operational logs present? Complete?
Y _ Are inspection reports available?
N Is the operation and maintenance manual present? Complete?
N Has DWQ received any complaints regarding the facility in the last 12 months?
_Y Are the monitoring wells properly secured?
_N_ Are the monitoring wells damaged?
Comment: The log indicates that the lagoons are inspected regularly. The log did
not indicate problems with the lagoons. The pH of the water in lagoon #3 is checked
regularly. It was noted that, according to the log, the pH has dropped in the last
month or so from ranges of 5.0 down to ranges of 3.0. The pH in each lagoon was
measured during the inspection by DWQ personnel. Lagoon pH #1 = 3.31, lagoon #2
= 3.41, lagoon #3 = 2.62. The pH of the water from the municipal system was 6.03.
The pH of the well water on the November 16, 2006 GW-59 report form was 6.02.

12/12/2006 10:51 919-715-0588
NCDE&NR/WATER QUAL
PAGE 02
Temperature and pil headings taken at the ALCHEM Facility in Rockvvell
by APS Personnel on December 5, 2006
Site
Water
#
Site Description
TemA
P19
1
Stormwater Drainage Ditch downstream of railcar off-loading spot.
6.1°C
3.68
2
Approximately50 feet downstream of Site # 1.
6.2°C
3.52
3
Shallow wetland or seep from stormwater detention pond, outside berm.
6.1°C
3.16
4
Same area as Site # 3, near the base of the berm.
6.4°C
3.08
5
The "corner" of the bermed stormwater detention pond.
9.7°C
3.80
6
Close to Site # 5.
9.7°C
3.82
7
Upstream location along the "boundary" stream.
7.0°C
5.36
8
Approximately 90 feet downstream of Site # 7.
6.0°C
5.44
9
Approximately 90 feet downstream of Site # S.
6.7°C
5.56
10
Possible surface seep in wet area between "boundary" stream and berm.
9.8°C
5.66
11
"Elbow" of the "boundary" stream where it changes direction.
9.3°C
5.28
12
Apparent seep area below berm. Seeps noted on the berm itself.
8.4°C
3.04
13
Upper stormwater detention pond on northern side of isthmus,
9.2°C
3.94
14
Lower stounwater detention pond on southern side of isthmus.
9.1°C
3.99
15
Northwest corner of Lagoon # 2. '
6.8°C
3.41
16
Northeast corner of Lagoon ## 3.
8.6°C
2.62.
17
Southern edge of Lagoon # 1.
6.1°C
3.31
Note: All three Lagoons were essentially full of "sand" at the time of the field visit
on December 5, 2006,
J

Alchem, Inc
pH
MW-1 MW-2
Date
February-02
6.4
July-02
5.7
February-03
5.85
July-03
5.8
February-04
6.5
August-04
6
March-05
5.75
July-05
5.8
December-05
5.45
June-06
5.96
November-06
5.63
WQ0002702
Al
MW-1
MW-2
0.089
0.77
0.088
0.137
0.034
0.34
0.281
0.178
0.062
0.207
0.125
0.596
0.051
0.184
0.72
0.82
0.9
3.24
0.3
2.34
0.43
4.76

FILE
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mrs. Julia M. Andrews, Registered Agent
ALCHEM, Inc.
2042 Bui Philadelphus .Road
Red Springs, NC 28138
and
ALCHEM, Inc.
8135 Red Road
Rockwell, NC 28138
SUBJECT
Dear Mrs. Andrews:
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
February 20, 2007
Assessment of Civil Penalty for
Violations of NC General Statute 143-215.1 (6) and
Non -Discharge Permit No. W00016338
Case No. NOV-2006-PC-0061
Rowan County
This letter transmits notice of a civil penalty assessed against ALCHEM, Inc. in the amount of $10,677.61,
which includes $677.61 in investigative costs. Attached is a copy of the assessment document explaining this
penalty.
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:
Please submit payment to the attention of:
Mr. Ed Hardee
DWQ/Aquifer Protection Section
1636 Mail Service Center
Raleigh, North Carolina 27699-1636
OR
ne
NoithCarolina
Division of Water Quality / Aquifer Protection Section / Mooresville Regional Office Phone: [phone] Fax: [phone] �atut,� //„
610 East Center Avenue, Suite 301, Mooresville, NC 28115 Internet: htto://gw.ehnr.state.nc.us l[J

.r
ALCHEM Inc. Assessment
WQ0016338
Page 2
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 letter. 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 and
a detailed statement, which you believe establishes whether:
(a) one or more of the civil penalty assessment factors in G.S. 14313-282.1(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
during a bimonthly enforcement conference and inform you of his decision in the matter of the
remission request. His 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 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.
OR

ALOHEM Inc. Assessment
WQ0016338
Page 3
3. Submit a written request for an administrative hearing:
If you wish to contest any statement in this assessment letter, you must request an
administrative hearing. This request must be in the form of a written petition to the Office of
Administrative Hearings and must conform to Chapter 150B of the North Carolina General
Statutes. You must file your original petition with the
Office of Administrative Hearings
6714 Mail Service Center
Raleigh, North Carolina 27699-6714
AND
Mail or hand -deliver a copy of the petition to
And to:
Mrs. Mary Penny Thompson, General Counsel
Department of Environment and Natural Resources
1601 Mail Service Center
Raleigh, North Carolina 27699-1601
Mr. Ed Hardee
DWQ/Aquifer Protection Section
1636 Mail Service Center
Raleigh, North Carolina 27699-1636
Failure to exercise one of the options above within thirty days, as evidenced by a date stamp (not a postmark)
indicating when we received your response, will result in this matter being referred to the Attorney General's
Office with a request to initiate a civil action to collect the penalty.
If you have any questions, please contact me at [phone] or Mr. Ed Hardee at [phone].
Sincerely,
�R
Andrew H. Pitner, P.G.
Environmental Regional Supervisor
Aquifer Protection Section
Mooresville Regional Office
ATTACHMENTS
cc: Ed Hardee, DWQ APS Central Office Wattachments
File NOV-2006-PC-0061 w/ attachments
APS Central Files w/ attachments

STATE OF NORTH CAROLINA
NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
COUNTY OF ROWAN
File No. PC-0061
IN THE MATTER OF:
ALCHEM Inc.,
FOR VIOLATIONS OF PERMIT
NO. WQ0016338 AND
NCGS 143-215.1
FOR FAILING TO PROPERLY
OPERATE AND MAINTAIN
RESIDUALS REUSE SYSTEM
FINDINGS AND DECISION
AND ASSESSMENT
OF CIVIL PENALTY
Acting pursuant to North Carolina General Statute (G.S.) 143-215.6(A), I, Andrew H. Pitner, P.G.,
Environmental Regional Supervisor of the Mooresville Regional Office Aquifer Protection Section 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, Inc. (ALCHEM) is a corporation organized and existing under the laws of the State of North
Carolina. ALCHEM operates a bauxite residuals reuse system in Rockwell, North Carolina, Rowan
County. The registered agent for ALCHEM, Inc., is Julia M. Andrews.
B. On March 1, 1999, DWQ issued Non -Discharge Permit No. WQ0016338 to ALCHEM, which allows the
use of spent bauxite sand from a wash recycle system (permit No. WQ0016338) to be mixed with clay and
used as structural fill. Permit WQ0016338 expired on December 31, 2004.
C. Said permit contains the following relevant conditions:
Permit condition 1.1 states, "the facilities should be effectively maintained and operated as a non -
discharge system to prevent the discharge of any wastes resulting from the operation of this program."
2. Permit condition 11.3 requires adequate provisions be taken to prevent wind erosion and surface runoff
from conveying pollutants from the residuals treatment area onto the adjacent property or into any
surface water.
D. On or about October 24, 2005, ALCHEM receives a geotechnical report from BOYLE Engineering
regarding site conditions. This report was commissioned by ALCHEM to fulfill the request of DENR
Central Office, dated June 8, 2005. This report concluded (page 3) "analysis of the existing embankment
(berm) discovered. that the existing embankment fill conditions are too variable and are unsuitable to retain
any additional lateral loads without risk of global stability failure and subsequent breach". The berm has
shown signs of failure since 2005. To date, the berm issues have not been addressed.

E. - On December 5, 2006, DWQ APS staff, from the Mooresville Regional Office, observed seepage of low
pH water from the berm area, on the opposite side where storm water had collected. The storm water pH
collected inside the berm has been historically low since the berm was built. The ph of seepage seen
during the December 5, 2006 inspection reflected a pH of 3.08 SU. The seepage drains to a marshy area
and then into an unnamed tributary of Second Creek (12-17-2, class C).
F. On December 20, 2006, the Division issued a Notice of Violation (NOV) / Notice of Recommendation
Enforcement (NRE) to Alchem, Inc., identifying violations of N.C.G.S. 143-215.1 (6) and conditions of
Water Quality Non Discharge Permit No. WQ0016338. ALCHEM was also directed to stop using the fill
area until corrections are made to the berm and to procure an alternative disposal option.
G. The NOV/NRE was received on December 21, 2006, by certified mail with return receipt.
H. Staff costs and expenses associated with observing the violations, defining their nature and bringing
enforcement action totaled $677.61.
Based upon the above Findings of Fact, I make the following:
H. 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. WQ0016338 was issued on March 1, 1999 and expired on December 31, 2004.
C. ALCHEM violated G.S. 143-215.1(a)(6), Part 1.1 and Part 11.3 of DWQ Permit No. WQ0016338 by failing to
properly operate and maintain a non -discharge land application system and allowing pollutants to reach
surface waters.
D. 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.
E. 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.
F. The Director, Division of Water Quality, pursuant to N.C.G.S. 143E-10, has been delegated authority to
assess civil penalties.
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. 143B-282.1.
Accordingly, ALCHEM is hereby assessed a civil penalty of:
$ 8,000.00 for failing to perform to permit standards as required by G.S. 143-215.1. and

Permit condition Part 1.1 which states that the facilities should be effectively
maintained and operated as a non -discharge system to prevent the discharge of
any wastes resulting from the operation of this program.
$ 2,000.00 for permit condition Part 11.3, which requires adequate provisions be taken to
prevent wind erosion and surface runoff from conveying pollutants from the
residuals treatment area onto the adjacent property or into any surface water.
$ 10,000.00 TOTAL CIVIL PENALTY, which is 40% percent of the maximum penalty
authorized by G.S. 143-215.6A.
$ 677.61 Investigation and Enforcement costs assessed.
$ 10,677.61 TOTAL AMOUNT DUE
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, Inc., in
accordance with N.C.G.S. 143-215.6(A)(d).
_ 2 C) . 0­1
(Date)
Andrew H. Pitner, P.G.
Environmental Regional Supervisor
Aquifer Protection Section
Mooresville Regional Office

GW Case Number:
Assessed Party:
Permit No. (if applicable):
JUSTIFICATION FOR REMISSION REQUEST
County:
Amount assessed:
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 andlor
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:
\Rem. req.

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT
AND NATURAL RESOURCES
COUNTY OF ROWAN
IN THE MATTER OF ASSESSMENT)
OF CIVIL PENALTIES AGAINST )
NON -DISCHARGE PERMIT )
NO. WQ0016338 )
ALCHEM, Inc., )
WAIVER OF RIGHT TO AN
ADMINISTRATIVE HEARING AND
STIPULATION OF FACTS
FILE NO. NOV-2006-PC-0061
Having been assessed civil penalties totaling $10,677.61 for violation(s) as set forth in the assessment
document of the Division of Water Quality, Aquifer Protection Section dated February 20, 2007, 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 are as 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 , 20
BY
ADDRESS
TELEPHONE

February 20, 2007
MEMORANDUM TO: Ed Hardee, APS, LAU
FROM: Andrew Pitner, MRO, APS ,
PREPARED BY: Ellen Huffman, MRO, APS'`
SUBJECT: Enforcement
Violation of Permit No. WQ0016338
ALCHEM, Inc.
Attached is the enforcement package sent to ALCHEM on February 20, 2007, with supporting
documentation concerning violations of.the subject permit. The violations resulted from
ALCHEM's mismanagement of the bauxite reuse program This Office is issuing a penalty.
The attached material should be self-explanatory; however, if you have any questions, please
contact Mrs. Ellen Huffman or me.
Attachments
ebh

Page 1
Summary
On Wednesday, December 5, 2006, the Mooresville Regional Office, accompanied by David
Goodrich, Central Office, visited the ALCHEM facility for a pre -scheduled inspection. During the
inspection, water and saturated soil was observed in two places that were approximately 20-30 feet
along the exterior of the berm. This was pointed out to the ALCHEM operator on site at the time of
inspection. These same conditions have been observed in a previous inspection (August 2005) and
have not been addressed.
Chronology of Events/Correspondence
December 5, 2006 — An inspection reflects the same site conditions found in previous inspections,
including low pH in all three lagoons, low pH in storm water collected by the berm, and poor berm
conditions as stated in earlier reports.
December 20, 2006 — a NOV/NRE was issued for permit (WQ0016338) conditions, pH issues, and
apparent berm failure (water seeping).
December 20, 2006 — a NOV/NRE was issued for permit (WQ0002702) conditions, pH issues,
groundwater, and freeboard.
January 8, 2007 — letter from Alchem regarding NOV/NRE. Alchem states that they were unaware that
the berm is seeping. Alchem also states "it is apparent that there is some very small amount of
seepage under the retaining berm". Alchem asks for a meeting between Alchem and MRO .staff to
discuss the issues.
January 11, 2007 — Alchem responds to groundwater violations (WQ0002702 NOWNRE).
January 16, 2007 - MRO emailed and faxed Randall Andrews regarding a date for the meeting
originally scheduled for January, 24, 2007 and then moved to January 31, 2007 at 10:30 AM, to
accommodate Mr. Andrews schedule.
January 19, 2007 — Certified letter from MRO responding to the January 8 letter from ALCHEM,
reiterating conditions in the NOV/NRE and the need for an alternative disposal plan for the residuals to
be presented at the meeting scheduled for January 31, 2007, and a plan to correct current plant
conditions.
January 26, 2007 — letter from Alchem, asking the MRO to consider allowing 500 tons of material to be
moved and put into an area near the railroad (?). ALCHEM re -stated the desire to use the fill as
structural fill for chemical mixing tanks.
January 31, 2007 — Meeting at MRO with Randall Andrews, ALCHEM. Mr. Andrews did not have an
alternative disposal plan. Mr. Andrews promises an alternative disposal plan by February 2, 2007. Mr.
Andrews brought Gary Riblett, P.E. , Senior Projects Manager, Delta, with him to the meeting.
February 12, 2007 — response received from ALCHEM — did not include an alternative disposal plan.

CHECKLIST FOR PERMIT VIOLATIONS
1. A copy of the Permit (#WQ0016338, expired) is attached.
2. The violator is ALCHEM, Incorporated. Mrs. Julia M. Andrews is the agent for the company.
Mrs. Julia M. Andrews
2042 Buie Philadelphus Road
Red Springs, North Carolina 28377
3. This enforcement involves violations of non -discharge Permit conditions.
4. Copies of correspondence are attached.
5. There are no chain -of -custody samples.
6. The violation is not due to a power failure or by-pass of any treatment facility.
7. Are violation(s) chronic and/or due. to a single operational upset?
The violation is considered to be chronic due to poor management practices observed during
the last 24 months.
8. Were any specific notifications submitted concerning noncompliance?
A NOWNRE was sent on December 20, 2006, which documented the subject permit violations
and indicated that an enforcement recommendation would be prepared.
9. Cost of the investigation:
6 hours by Ellen Huffman for preparation
of enforcement report at $24.92/hour = 149.52
2 hours by Andrew H. Pitner, P.G. for supervisory review
at $28.62/hour = 57.24
1 hour for clerical processing at $10.93/hour = 10.93
Mileage 50.8 @ $0.26 per mile = 132.08
Administrative Cost for processing report = 300.00
Certified Mail 6 @ $4.64 /ea. = 27.84
Total 677.61

DIVISION OF WATER QUALITY
ENFORCEMENT CASE ASSESSMENT FACTORS
Type: Permit Violations
Non -Discharge Permit No. WO0016338
Violator: ALCHEM
Regional Office: Mooresville
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:
Low pH seepage was discharging into a marshy area that drains to a nearby stream. The stream pH was normal
due to dilution.
2. The duration and gravity of the violation:
The violations were first identified during an inspection on 09/20/2005. The same issues were found during an
inspection on 12/05/2006.
3. . The effect on water/groundwater quality:
There is no documented effect on water, public health, and fish or wildlife, as a result of these violations. Impacts
to groundwater quality are being pursued through enforcement of ALCHEM permit WQ0002702.
4. The cost to rectify the damage:
The cost to rectify damage is difficult to determine. ALCHEM has not taken any preventive or responsive action
even though ALCHEM was aware of the berm issues when the BOYLE Engineering report was received on
October 24, 2005.
5. Amount of money saved by noncompliance:
The amount of money saved is difficult to determine. One possible way that savings could be calculated would be
to multiply the dry tons of product disposed of in the fill area by landfill tipping fees from March 1, 1999 to the
present. Permit WO0016338 allows for disposal of 3000 dry tons/year. The tipping fee for Rowan County Landfill
is $28.00 per ton, which calculates to a gross estimate of $84,000 per year /dry tons.
6. Whether or not the violations were committed willfully or intentionally:
ALCHEM has been notified about poor operating conditions several times through issuance of a Notices of
Violations and inspections. ALCHEM has been in receipt of an engineering assessment by BOYLE Engineering
for over a year. The BOYLE Engineering report detailed the subject problems and offered several solutions,
however, ALCHEM has not taken steps to rectify any of them.
7. The prior record of the violator in complying or failing to comply with programs over which the
Environmental Management Commission has regulatory authority:
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, NOWNRE 09/20/2005,
NOV/NRE 01/06/2006, NOV/NRE 12/20/2006, NOWNRE 12/20/2006.
Please see ALCHEM file history attached.
8. Type of violator and general nature of business:

ZI
9.
10.
11
The permittee manufactures chemicals for water and wastewater treatment. The primary use of the facility is to
convert bauxite ore into Alum.
Violator's degree of cooperation (including efforts to prevent) or recalcitrance:
The permittee continues to have a 'lack of concern' regarding facility conditions, and poor management of the
bauxite fill area, despite several Notices from the Division and several letters from the permittee declaring that
they were unaware of any problems and promising to take action.
Mitigating circumstances:
This Office is concerned with the (21 year) history of poor management of ALCHEM's non -discharge facilities.
ALCHEM continues to have a 'lack of concern' about the permit conditions, and poor management of the bauxite
fill area. ALCHEM was directed to perform an engineering study of the berm and fill area. ALCHEM has not
taken any preventive or responsive action even though ALCHEM was aware of the berm issues when the BOYLE
engineering Report was received by ALCHEM on October 24, 2005. The MRO had to call the engineering firm to
find out if the report was even finished. The MRO called ALCHEM several times to request a copy of the report.
The MRO finally received a copy 6 months later, on March 1, 2006. ALCHEM promised to submit to the MRO an
alternative disposal plan by February 2, 2007. To date, ALCHEM has not sent any requested information to this
office.
See file history included in package.
Cost to the State of the enforcement procedure:
The cost to the State in bringing about this enforcement action is as follows:
6 hours by Ellen Huffman for preparation
of enforcement report at $24.92/hour
= 149.52
2 hours by Andrew H. Pitner, P.G. for supervisory review
at $28.62/hour = 57.24
1 hour for clerical processing at $10.93/hour = 10.93
Mileage 50.8 @ $0.26 per mile = 132.08
Administrative Cost for processing report = 300.00
Certified Mail 6 @ $4.64 /ea. = 27.84
Total Costs
$ 677.61

DIVISION OF WATER QUALITY -- CIVIL PENALTY ASSESSMENT
Violator: ALCHEM, Inc.
County: Rowan
Case Number: PC-2006-0061
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 (X) moderately significant ( ) significant ( ) 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 ( ) moderately significant (X) significant () very significant( ) extremely significant
5) The amount of money saved by noncompliance;
( ) not significant () moderately significant () significant (X) 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.
Date Alan Klimek, P.E.

UNITED STATES
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1. Article Addressed to:
I Mrs: Julia M. Andrews
ALCHEM, Inc.
2042 Bui Philadelphus Rd.
i Red Springs NC 28138
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so that we can return the card to you.
® Attach this card to the back of the mailpiece,
or on the front if space permits.
1. Article Addressed to:
Mrs. Jtalia M. Andrews
ALCHEM, Inc.
2042 Bui Philadelphus Rd.
Red Springs NC 28138
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102595-02-M-1540

William G. Ross Jr.; Secretary :.'
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
AQUIFER PROTECTION SECTION
December 20, 2006
CERTIFIED MAIL.
RETURN RECEIPT REQUESTED
Mr. Randall Andrews
ALCHEM, Inc.
2042 Buie Philadelphus Road
Red Springs, NC 28377
and
ALCHEM, Inc.
8135 -Red: Road
Rockwell,'NC 28138
Dear Mr. Andrews,
CM # 7003 2260 0001 3494 5390
CM # 7003 2260 0001 3494 5406
Subject: Notice of Violation/ Notice of
Recommendation for Enforcement
NOV No. NOV-2006-PC-0061
Violation of permit conditions of Non -
discharge permit No. WQ0016338
(dated March 1, 1999)
Bauxite Residuals Reuse Program
Rockwell, Rowan County
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 (DWQ) 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.
While issues related to more recent permits are addressed, your facility is currently operating under
the March 1, 1999, version of Non -discharge permit WQ0016338 for bauxite residuals reuse. An inspection
for permit WQ0016338 was conducted by Ms. Ellen Huffman, Aquifer Protection Section (APS) Mooresville
Regional Office (MRO), Mr. David Goodrich, APS Central Office, and accompanied by Mr. Wes Bell,
Surface Water Protection Section MRO, on December 5, 2006. Several violations of the subject permit
were noted during this inspection. These violations include:
Permit conditions 1,1 requires the residual program be effectively maintained and operated as a non -
discharge system. and 11.3 requires adequate provisions be taken to prevent wind erosion and surface
runoff from conveying pollutants from the residuals treatment area onto the adjacent property or into
any surface waters.
Conditions at the time of inspection revealed that the berm is not effectively retaining the water
'that has collected in the residual bauxite disposal area. The pH of the water in the storage area
at the time of inspection averaged 3.8 SUs. The pH of the water seeping from'a 40ft long area at
the foot of the backside of the berm was 3.13 SUs.
No thCarolina
Division of Water Quality / Aquifer Protection Section / Mooresville Regional Office Phone: [phone] Fax: [phone] �� fl�l,� //�
610 East Center Street, Suite 301, Mooresville, NC 28115 Internet: http://gw.ehnr.state.nc.us ` [[

Page 2 of 2
December 20, 2006
As related to this issue, Mr. Goodrich requested an engineering evaluation of the berm on June 8,
2005. The MRO APS received the evaluation conducted by Boyle Engineering on March 1, 2006. This
report discovered that, "the existing embankment fill conditions are too variable and are unsuitable to retain
any additional lateral loads without risk of global stability failure and subsequent breach." (See BOYLE
Consulting Engineers report dated Oct. 24, 2005, Executive Summary, page 3).
In light of the conditions found during this inspection, including excessive amounts of stormwater
collected in the bauxite fill area and numerous seep areas on the outside of the berm, the DWQ APS has
concluded that this facility is not being effectively maintained and operated as a non -discharge system and
that the bauxite fill area cannot receive any more residuals until the area is stabilized and/or
repaired. Corrective measures taken to address this problem will need to be signed off on by a NC
Professional Engineer. As such, ALCHEM must find a suitable alternative disposal option for any
future lagoon cleaning and notify the Division in writing within 20 days of receipt of this notice, of
the method of disposal to be used.
The Mooresville Regional Office is recommending an enforcement action against this permit for the
above referenced violations. If you have justification that these violations are caused by circumstances
beyond your control, or you have an explanation that you wish to present, please respond in writing within
twenty (20) days following receipt of this notice. The Mooresville Regional Office will review your response
and forward it to the Water Quality Division Director with the enforcement package. It should be noted that
that, in accordance with General Statute 143-215.6A,initiation of an enforcement action could result in
assessment of penalties up to $25,000 per day.
Please address your response to the attention of Ms. Huffman. It is also requested that your response
reference the date and subject of this NOV/NRE, as well as the permit number. If you have any questions
concerning this matter, please do not hesitate to contact Ms. Huffman at [phone].
Sincerely,
Andrew H. Pitner, P.G.
Environmental Regional Supervisor MRO APS
Enclosures
12-5-06 Inspection report
map & pH readings
cc: APS Land Application Unit, Permits Enforcement
APS Land Application Unit, David Goodrich
Wayne Drye, Plant Manager, ALCHEM, Inc, Red Road

State'of Norith Carolina
D) partment of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Alan W. Klimek, P.E. Director
NCDENR
NON -DISCHARGE COMPLIANCE INSPECTION
GENERAL INFORMATION
City/Town/Owner: Alchem Inc.
Permit No.: W00016338
Last Amended Date: N/A
SOC Issuance Date(if applicable): N/A
Permittee Contact: Wa. n� e Drye
ORC Name: N/A
ORC Cert.#: N/A
Reason for Inspection
County: Rowan County
Issuance Date: March 1, 1999
Expiration Date:
Expiration Date:
Telephone No.:
Telephone No.: _
ORC:
ecember 31.2004
N/A'
704/ 279-7908
704/ -
X ROUTINE COMPLAINT X FOLLOW-UP OTHER
Type of inspection
Collection System Spray Irrigation Sludge X Other
Inspection Summary: (additional comments may be included on attached pages)
This permit is expired. The new permit has been contested and currently in the adjudication
process. The facility was inspected using the permit conditions in the expired permit
WQ0016338, dated March 1, 1999.
David Goodrich, APS, Central Office, Andrew Pitner, APS, MRO, Wes Bell, SWP, MRO, also
attended the inspection on December 5, 1006. Physical readings of temperature and pH were
taken in several locations. See map and readings attached to this inspection report. The earthen
berm, surrounding the fill area, shows constant signs of seeping along the lower end of the berm
impoundment.. pH readings of the seeping water in this area were in the 3.08 SU range. pH
readings of the water inside the bauxite fill area, were in the 3.8 — 3.9 SU range. The earthen
berm was- originally constructed due to a previous failure to keen the bauxite residuals on site.
Boyle Consulting Engineers evaluated the berm for structural integrity in the. summer of 2005.
Continued on page 2
Is a follow-up inspection necessary _X yes _ no
Inspector(s) Name(s)/Title(s) Ellen Huffinan / Env. Specialist II
Telephone No. 704/663-1699 Fax No. 704/663-6040
Date of Inspection December 5, 2006

Water Recycle System Inspection
WQ0016338 ALCHEM, Inc.
Inspection Summary Continued
pg 2
The MRO APS received the Boyle report in March 1, 2006. The Boyle report reflected
inconsistencies in the berm construction and predicted probable failure. ALCHEM has not taken
any action to repair/replace the berm. Currently there is a large amount of rainwater in the
lagoon. This has increased the unstable conditions of the bauxite area. This inspection included
sampling of existing monitoring wells for permit # WQ0002712, which is the permit for the
water recycling system used to wash the spent bauxite, stored in the three lagoons prior to final
use in the "fill" area. A "follow-up" inspection by Peggy Finley and Ellen Huffman was on
December 14, 2006 and included record keeping and another review of the seep area. The seep
area is still saturated.
Type of System
Bauxite Residuals Reuse
Record Keeping
Y/N
Y Copy of current permit available at residual generating site
Y Current metals analysis (2 x's year)
Y TCLP analysis- 1 x per permit cycle, starting in 1999.
N Hauling records (# gal and/or ton hauled during calendar year to date)
N/E Records of lime purchased
Y Fill inspection log (records).
Treatment (check treatment type(s) used)
Wash Recycle System (WQ0002712)
Transport N/A
Spill control plan in transport vehicle?
Does transport vehicle appear to be maintained?
Comments -
Operation & Maintenance records N/A
Disposal Reuse Area
Describe storm
No Site condition adequate
YES Signs of runoff / ponding
Monitoring well(s) Y/N: Y
The wells at this site are associated with the water recycle system permitted under WQ0002702

r
12/002008 09:.29; 919-715-0588 NCDE&NR/WATER QUAL PAGE 02
Temperature and pH Readings taken at the A.LCIIEM Facility in Rockwell
by APS Personnel on December 5, 2006
Site
Water
#
Site Description
Temp
PH
1
Stormwater Drainage Ditch, downstream of railcar off-loading spot.
6.16C
3.68
2
Approximately 50 feet downstream of Site # 1.
6.2°C
3.52
3
Shallow wetland or seep from stormwater detention pond, outside berm:
6.16C
3.16
4
Same area as Site # 3, near the, base of the berin.
6.46C
3.08
S
The "corner" of the bermed stormwater detention pond.
9.76C
3.80
6
Close to Site # 5.
9.7°C
3.82
7
Upstream location along the "boundary". stream.
7.0°C
5.36
8
Approximately 90 feet downstream of Site # 7.
6.O6C
5.44
9
Approximately 90 feet downstream of Site # 8.
63T
5.56
10
Possible surface seep in wet area betvween ."boundary" stream and berm.
9.86C
5.66
11
"Elbow" of the "boundary" stream where it changes direction.
9.36C
5.28
12
Apparent seep area below berm. Seeps noted on the berm itself
SAOC
3.04
13
Upper stormwater detention pond on northern side of isthmus.
9.26C
3.94
14
)cower stormwater detention pond on southern side of isthmus.
9.111C
3.98
15
Northwest corner of Lagoon # 2.
6.8°C
3.41
16
Northeast corner of Lagoon # 3.
8.66C
2.62
17
Southern edge of Lagoon # 1.
6.16C
3.31
Note: All three Lagoons were essentially full of "sand" at the time of the field visit
on December 5, 2006.

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B. Received by (Printed Name) C. Date of Delivery ,
D. Is diNkery address different from item ?- ❑ Yes
If YES, enter delivery address below: ❑ No
MR RANDALL ANDREWS
ALCHEM INC
2042 BUIE P1-7ILADELPHUS ROAD
RED STRINGS NC 28377 3. Service Type
1eh/nov/none/n6v-2006-pc-0061 12/20/06 apJ Certified Mail ❑ Express Mail
❑ Registered ZI Return Receipt for Merchandise
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4. Restricted Delivery? (Extra Fee) ❑ Yes
2. Article Number (-- ----
(Transferfrom service labeO i -7003 2260 0001 3494 5390
P fo rl jq$jj I Feb
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UNITED STATES POSTtAI `SR•b!IGE :A;, v�,•-
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DENR DWQ Aquifer Protection
610 E. Center Ave., Ste. 30-1
Mooresville NC 28115
is Complete items 1, 2, and 3. Also complete
item 4 if Restricted Delivery is desired.
® Print your name and address on the reverse
so that we can return the card to you.
® Attach this card to the back of the mailpiece,-
or on the front if space permits.
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If YES, enter delivery address below: ❑ No
8135 12edJkd.
Rockwell, -NC 28138 3. Se�ceType
lfd Certified Maii ❑ypress Mail
❑ Registered ®Return Receipt for Merchandise
❑ Insured Mail ❑ C.O.D.
4. Restricted Delivery? (Extra Fee) ❑ Yes
2. Article Number 7006 2760 0001 8493 8740
(transfer from service taoeq
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Domestic Return Receipt
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18 J �Zk_ s 0 -- - ---
Alan W. Klimek, P.E. Director
Division of Water Quality
DU Q-11
` Z'';"
AQUIFER PROTECTION SECTION
December 20, 2006
CERTIFIED MAIL
RETURN RECEIPT" REQUESTED
Mr. Randall Andrews
ALCHEM, Inc. CM # 7003 2260 0001 3494 5390
2042 Buie Philadelphus Road
Red Springs, NC 28377
and
ALCHEM, Inc'.'.*.
8135-Red:R6ad -
Rockwell,_ NC,28138
Dear Mr. Andrews,
CM # 7003 2260 0001 3494 5406
Subject: Notice of Violation/ Notice of
Recommendation for Enforcement
NOV No. NOV-2006-PC-0061
Violation of permit conditions of Non -
discharge permit No. WQ0016338
(dated March 1, 1999)
Bauxite Residuals Reuse Program
Rockwell, Rowan County
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 (DWQ) 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.
While issues related to more recent permits are addressed, your facility is currently operating under
the March 1, 1999, version of Non -discharge permit WQ0016338 for bauxite residuals reuse. An inspection
for permit WQ0016338 was conducted by Ms. Ellen Huffman, Aquifer Protection Section (APS) Mooresville
Regional Office (MRO), Mr. David Goodrich, APS Central Office, and accompanied by ,Mr. Wes Bell,
Surface Water Protection Section MRO, on December 5, 2006. Several violations of the subject permit
were noted during this inspection. These violations include:
Permit conditions 1,1 requires the residual program be effectively maintained and operated as a non -
discharge system. and 11.3 requires adequate provisions be taken to prevent wind erosion and surface
runoff from conveying pollutants from the residuals treatment area onto the adjacent property or into
any surface waters.
Conditions at the time of inspection revealed that the berm is not effectively retaining the water
that has collected in the residual bauxite disposal area. The pH of the water in the storage area
at the time of inspection averaged 3.8 SUs. The pH of the water seeping from a 40ft long area at
the foot of the backside of the berm was 3.13 SUs.
NorthCarolina
Division of Water Quality / Aquifer Protection Section / Mooresville Regional Office Phone: [phone] Fax: [phone] a J��lrj,� //�
610 East Center Street, Suite 301, Mooresville, NC 28115 Internet: http://gw.ehnr.st@te:nc.us d V l[

vecernuei w, cuvo ;
As related to this issue, Mr. Goodrich requested an engineering evaluation of the berm on June 8,
2005. The MRO APS received the evaluation conducted by Boyle Engineering on March 1, 2006. This
report discovered that, "the existing embankment fill conditions are too variable and are unsuitable to retain
any additional lateral loads without risk of global stability failure and subsequent breach." (See BOYLE
Consulting Engineers report dated Oct. 24, 2005, Executive Summary, page 3).
In light of the conditions found during this inspection, including excessive amounts of stormwater
collected in the bauxite fill area and numerous seep areas on the outside of the berm, the DWQ APS has
concluded that this facility is not being effectively maintained and operated as a non -discharge system and
that the bauxite fill area cannot receive any more residuals until the area is stabilized and/or
repaired. Corrective measures taken to address this problem will need to be signed off on by a NC
Professional Engineer. As such, ALCHEM must find a suitable alternative disposal option for any
future lagoon cleaning and notify the Division in writing within 20 days of receipt of this notice, of
the method of disposal to be used.
The Mooresville Regional Office is recommending an enforcement action against this permit for the
above referenced violations. If you have justification that these violations are caused by circumstances
beyond your control, or you have an explanation that you wish to present, please respond in writing within
twenty (20) days following receipt of this notice. The Mooresville Regional Office will review your response
and forward it to the Water Quality Division Director with the enforcement package. It should be noted that
that, in accordance with General Statute 143-215.6A,initiation of an enforcement action could result in
assessment of penalties up to $25,000 per day.
Please address your response to the attention of Ms. Huffman. It is also requested that your response
reference the date and subject of this NOWNRE, as well as the permit number. If you have any questions
concerning this matter, please do not hesitate to contact Ms. Huffman at [phone].
Sincerely,
"I_ 1 11
Andrew H. Pitner, P.G.
Environmental Regional Supervisor MRO APS
Enclosures
12-5-06 Inspection report
map & pH readings
cc: APS Land Application Unit, Permits Enforcement
APS Land Application Unit, David Goodrich
Wayne Drye, Plant Manager, ALCHEM, Inc, Red Road

Ntate of ivortn t;a°rouna
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Alan W. Klimek, P.E. Director
.A&4
NCDENR
NON -DISCHARGE COMPLIANCE. INSPECTION
GENERAL INFORMATION
City/Town/Owner: Alchem Inc.
Permit No.': WQ0016338
Last Amended Date: N/A
SOC Issuance Date(if applicable): N/A
Permittee Contact: Wayne Drye
ORC Name: N/A
ORC Cert.#: N/A
County: Rowan County
Issuance Date: March 1, 1999
Expiration Date:
December 31, 2004
Expiration Date:
N/A
Telephone No.:
704/ 279-7908
Telephone No.:
704/ -
ORC:
Reason for Inspection
X ROUTINE COMPLAINT X FOLLOW-UP OTHER
Type of inspection
Collection System Spray Irrigation Sludge _X—Other
Inspection Summary: (additional comments maybe included on attached pages)
This permit is expired. The new permit has been contested and currently in the adjudication
process. The facility. was inspected using the permit conditions in the expired permit
WQ0016338, dated March 1, 1999.
David Goodrich, APS, Central Office, Andrew Pitner, APS, MRO, Wes Bell, SWP, MRO, also
attended the inspection on December 5, 1006. Physical readings of temperature and pH were
taken in several locations. See map and readings attached to this inspection report. The earthen
berm, surrounding the fill area, shows constant signs of seeping along the lower end of the berm
impoundment. pH readings of the seeping water in this area were in the 3.08 SU range. pH
readings of the water inside the bauxite fill area, were in the 3.8 — 3.9 SU range. The earthen
berm was originally constructed due to a previous failure to keep the bauxite residuals on site.
Boyle Consulting Engineers evaluated the berm for structural integrity in the summer of 2005.
Continued on page 2
Is a follow-up inspection necessary X yes _ no
Inspector(s) Name(s)/Title(s) Ellen Huffman / Env. Specialist II
Telephone No. 704/663-1699 Fax No. 704/663-6040
Date of Inspection December 5, 2006

Water Recycle System Inspection
WQ0016338 ALCHEM, Inc.
Inspection Summary Continued
Pg 2
The MRO APS received the Boyle report in March 1, 2006. The Boyle report reflected
inconsistencies in the berm construction and predicted probable failure. ALCHEM has not taken
any action to repair/replace the berm: Currently there is a large amount of rainwater in the
lagoon. This has increased the unstable conditions of the bauxite area. This inspection included
sampling of existing monitoring wells for permit 9 WQ0002712, which is the permit for the
water recycling system used to wash the spent bauxite, stored in the three lagoons prior to final
use in the "fill" area. A "follow-up" inspection by Peggy Finley and Ellen Huffman was on
December 14, 2006 and included record keeping and another review of the seep area. The seep
area is still saturated.
Type of System
Bauxite Residuals Reuse
Record Keeping
YIN
Y Copy of current permit available at residual generating site
Y Current metals analysis (2 x's year)
Y TCLP analysis- 1 x per permit cycle, starting in 1999.
N Hauling records (9 gal and/or ton hauled during calendar year to date)
N/E Records of lime purchased
Y Fill inspection log (records).
Treatment (check treatment type(s) used)
Wash Recycle System (WQ0002712)
Transport N/A
Spill control plan in transport vehicle?
Does transport vehicle appear to be maintained?
Comments -
Operation & Maintenance records N/A
Disposal Revise Area
Describe storm
No Site condition adequate
YES Signs of runoff / ponding
Monitoring well(s) Y/N: Y
The wells at this site are associated with the water recycle system permitted under WQ0002702

1L/ CJ 0/ LCl U0 UZ) L=. 71 D- / 1J-UJOO WH I C-M UlUHL hiVL uL
Temperature and pH Readings taken at the ALCHEM Facility in Rockwell
by A.PS Personnel on December 5, 2006
Site
Water
#
Site Description
Temp
PH
1
Stormwater Drainage Ditch, downstream of railcar off-loading spot.
6.1°C
3.68
2
Approximately 50 feet downstream of Site # 1.
6.2°C
3.52
3
Shallow wetland or seep from stormwater detention pond, outside berm.;
6.1°C
3.16
4
Same area as Site # 3, neax the base o£the berm.
6.4°C
3.08
5
The "comer" of the berated stormwater detention pond.
9.7°C
3.80
6
Close to Site # 5.
9.7°C
3.82
7
Upstream location along the "boundary" stream.
7.0°C
5.36
8
Approximately 90 feet downstream of Site # 7.
6.0°C
5.44
9
Approximately 90 feet downstrearn of Site # 8.
6.7°C
5.56
10
Possible surface seep in. wet area betweer►."boundary" stream, and berm.
9.80C
5.66
11
"Elbow" of the "boundary" stream where it changes direction.
9.3°C
5.28
12
Apparent seep area below berm. Seeps noted on the berm itself.
8.4°C
3.04
13
Upper stormwater detention pond on northern side of isthmus.
9.2°C
3.94
14
Lower store-iwater detention pond on southern side of isthmus.
9.1°C
3.98
15
Northwest corner of Lagoon, # 2_
6.8°C
3Al
16
Northeast corner of Lagoon # 3.
8.60C
2.62
17
Southern edge of Lagoon # 1.
6.1°C
3.31
Note: All three Lagoons were essentially full of "sand" at the time of the field visit
on December 5, 2006.

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610 E. Center Ave:,- & DEC 2 z 2
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1. Article Addressed to: D. ()T
. Is d ery address different from item 11 ❑ Yes
If YES, enter delivery address below: ❑ No
MR RANDALL ANDRE,WS
ALCHEM INC
2042 BUIE PHILADELPHUS ROAD
RED SPRINGS NC 28377 3. service Type
Leh/nov/pore/n6-2006-pc-0061 12/20/06 ap
Certified Mail ❑Express Mail 3
❑ Registered Return Receipt for Merchandise
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4. Restricted Delivery? (Extra Fee) 2. Article Number ❑ Yes
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UNITED STATES POSTAL SERVICE'
1RD1C IEOWE
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Postage & Fees Paid
LISPS
Permit No. G-10
address, and ZIP+4 in7bo
NC DE1gR MRO
DWQ - A4c fer Protection fer Protection
610 F,'.. :enter Ave., Ste. 301
Mooresville NC 28115
lri�;litrlrrtitl<<,14ri,ltr�Irlrltl,l,trllr►Irlrit,l,irrrrlLrl .
■ Complete items , -' •- -- .
item 4 if Restricted Delivery is desired.
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so that we can return the card to you-
■ Attach this card to the bache mot piece,
or on the front if space permits.
' 1, Article Addressed to:
8135 RED ROAD
ROCKwELLN0061 C 28139
12120106 P
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❑ Yes
D. Is delivery address different from item 1? No
if YES, enter delivery address below:
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4. Restricted Delivery? (Extra
5406
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2Z6❑ p001 3494 i
2. Article Number
(transfer from service label)'
102595-02-M-1540 :'
2004
Domestic Return Receipt
PS Form 3811, February .. -
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ALCHEM INC.
rnFsent8135 RED ROADROCKWELLNC28138
l
eh/nov/nore/nov-2006-pc-0061 12/20/06 ap

r 03/11/2007 22:06 9108435789 IAC INC
ALCHEM., INC.
Cornarate Qffice
2042 Buie Philadelphus Road
Red Springs, NC 28377
Tel. [phone] — 800-522-2944
Fax 910-M5789
rFa(alsemr.net
March 1.2, 2007
Mr. Andrew Pitner.
Environmental Regi.oiW Supervisor
NCDENR
610 Fast Center St., Suite 301
Mooresville, NC 28115
Dear M..r, Ptin.er:
PAGE 02
Sales and Manufacturina
8135 Red Road
Rockwell, NC 28138
Tel, 704.279.7908 — 800-462-2586
Fax [phone]
pdrgeCa7alltel,net
We have received this Letter of Recommendation from Gary Ribblett with DELTA
ENVIRONMENTAL, We are in desperate need to start the sand removal process. Please
advise as to what the next step we take should be.
Best regards,
ALC.HEM, INC
Randall F. Andrews,
Plant Manager
ams

.✓
.4 03/11/2007 22:06 9108435789
IAC INC
PAGE 03
SUSTAINABLE STRATEGIES FOR GLOBAL LEADERS
March 9, 2007
Mr. Randall Andrews
ALCHEM, Inc.
2042 Buie Philadelphus Rd.
Red Springs, NC 28377
Subject: Progress and Recommendations
Rockwell, North Carolina
Dear Randall:
This letter is to confirm our conversation regarding our recommendations
previously discussed. You have explained to me that you are in the process of
cleaning out the old, damaged reactor, and that you plan to install the new
mixing tank very soon. I understand that installation of this new washer -mixer
will allow you to discharge the sand -water mixture into the lagoons at a pH of
6.6 or higher as required by permit.
In order to successfully raise the pH of the existing lagoons however, it would
be best to be able to remove the sand from the lagoons to be treated to raise
its pH. Otherwise, the beneficial effect of your new washer -mixer will be
limited by the lower pH sand already in the lagoons.
In our meeting in Mooresville with NC DENR, Ms. Huffman and Mr. Pitner
indicated that they may be amenable to placing additional sand in the storage
DELTA area if it had its pH appropriately raised. I agree with them that this higher pH
material would likely have a beneficial effect on stormwater and leachate from
the disposal area.
Per the measurements we have discussed, placing sand with a higher pH into
the disposal area should have a beneficial effect on the pH of stormwater and
leachate from the existing fill area.
If sand can be cleaned from one lagoon at a time and mixed with sufficient
lime, it may be possible to place the sand in the disposal area and help with
the pH of the runoff. Regular sampling and documentation of the pH of each
batch of the treated sand will help verify that we are moving in the right
direction.
The most recent correspondence from NC DENR forbids additional sand
placement in the disposal area, so their prior approval would be required
before placing the sand.
Once the lagoon is cleaned of lower pH sand, and a higher pH sand -water
mixture can be added from your new mixer, you should have more success in
raising the lagoon pH, hence addressing problems in both the fill area and the
lagoons. Clearly it will be much easier to raise the pH in an empty lagoon than
one that contains lower pH sand.
W.I.
XInogen
8008 Corporate Center Drlve Sulte 101) Charlotte, NC 20226 USA
—
Phone: /04.54].')h'a11 / HOr1.477.7.11 1. Fax: 'ind.5'13.A035
N�KAL--- lr,ltaew%L--ef)m.

03/11/2007 22:06 9108435789 IAC INC PAGE 04
Mr, Randal Andrews
ALGHEM, Inc.
5tormwater pond Berm Reconstruction
Maroh 9, 2007
2of2
We would be happy to discuss these recommendations in more detail at your convenience. Please do not
hesitate to contact me at [phone] with questions.
Sincerely,
DELTA ENVIRONMENTALCONSULTANTS, INC.
,A, C.
Gary C. Ribblett, P.E.
Senior Project Manager

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Alan W. Klimek, P.E. Director
IT
NCDENR
NON -DISCHARGE COMPLIANCE INSPECTION
GENERAL INFORMATION
City/Town/Owner: Alchem Inc.
Permit No.: WQ0016338
Last Amended Date: N/A
SOC Issuance Date(if applicable): N/A
Permittee Contact: Wayne Drve
ORC Name: N/A
ORC Cert.4: N/A
Reason for Inspection
County: Rowan County
Issuance Date: March 1, 1999
Expiration Date:
December 31, 2004
Expiration Date:
N/A
Telephone No.:
704/ 279-7908
Telephone No.:
704/ -
ORC:
X ROUTINE COMPLAINT X FOLLOW-UP OTHER
Type of inspection
Collection System Spray Irrigation Sludge _X Other
Inspection Summary. (additional comments may be included on attached paces)
This permit is expired. The new permit has been contested and currently in the adjudication
process. The facility was inspected using the permit conditions in the expired permit
WQ0016338, dated March 1, 1999.
David Goodrich, APS, Central Office, Andrew Pitner, APS, MRO, Wes Bell, SWP, MRO, also
attended the inspection on December 5, 1006. Physical readings of temperature and pH were
taken in several locations. See map and readings attached to this inspection report. The earthen
berm, surrounding the fill area, shows constant signs of seeping along the lower end of the berm
impoundment. pH readings of the seeping water in this area were in the 3.08 SU range. pH
readings of the water inside the bauxite fill area, were in the 3.8 - 3.9 SU range. The earthen
berm was originally constructed due to a previous failure to keep the bauxite residuals on site.
Boyle Consulting Engineers evaluated the berm for structural integrity in the summer of 2005.
Continued on page 2
Is a follow-up inspection necessary X yes _ no
Inspector(s) Name(s)/Title(s) Ellen Huffman / Env. Specialist II
Telephone No. 704/663-1699 Fax No. 704/663-6040
Date of Inspection December 5, 2006

t
Water Recycle System Inspection pg 2
WQ0016338 ALCHEM, Inc.
Inspection Summary Continued
The MRO APS received the Boyle report in March 1, 2006. The Boyle report reflected
inconsistencies in the berm construction and predicted probable failure. ALCHEM has not taken
any action to repair/replace the berm. Currently there is a large amount of rainwater in the
lagoon. This has increased the unstable conditions of the bauxite area.. This inspection included
sampling of existing monitoring wells for permit # WQ0002712, which is the permit for the
water recycling system used to wash the spent bauxite, stored in the three lagoons prior to final
use in the "fill" area. A "follow-up" inspection by Peggy Finley and Ellen Huffman was on
December 14, 2006 and included record keeping and another review of the seep area. The seep
area is still saturated.
Type of System
Bauxite Residuals Reuse
Record Keepin
Y/N
Y Copy of current permit available at residual generating site
Y Current metals analysis (2 x's year)
Y TCLP analysis- 1 x per permit cycle, starting in 1999.
N Hauling records (# gal and/or ton hauled during calendar year to date)
N/E Records of lime purchased
Y Fill inspection log (records).
Treatment (check treatment type(s) used)
Wash Recycle System (WQ0002712)
Transport N/A
Spill control plan in transport vehicle?
Does transport vehicle appear to be maintained?
Comments -
Operation & Maintenance records N/A
Disposal Reuse Area
Describe storage.
No Site condition adequate
YES Signs of runoff / ponding
Monitoring well(s) Y/N: Y
The wells at this site are associated with the water recycle system permitted under WQ0002702

ROWAN C;UUN 1 Y JUL11J WA�1� iH1�LriLl
__D-----
ROWAN COUNTY SOLID WASTE LANDFILL
Location: 789 Campbell Road
- Hours: Monday through Friday
Saturday
Phone: [phone]
Fax: [phone]
WASTES ACCEPTED:
Woodleaf, NC 27054
7:30 to 4:00
8:00 to 2:00
Solid Waste- $28 per ton (29.50 Out of County)- Any waste generated by Rowan County residents and
businesses. Any large quantities of out -of -county waste accepted must be approved by the Director of
Environmental services prior to disposal. No hazardous waste, medical waste, liquids, batteries
(automotive) or tires are accepted at Rowan County's landfill.
Demolition Waste- $17 per ton (18.50 Out of County)- This includes trees, dirt, concrete, asphalt,
shingles, wood scraps and other inert debris. No paper, plastic, metal, or other solid wastes are accepted
at this rate.
Scrap Metal- No charge- This includes appliances such as washers, refrigerators, air conditioners, etc.
Tires- No charge- Please call to get approval to drop off tires at the landfill.
ALL ITEMS BEING BROUGHT TO THE LANDFILL MUST BE COVERED AND/OR SECURED ON THE
VEHICLE BEFORE COMING OR ACCESS WILL BE DENIED.
HISTORY
The Rowan County Solid Waste Landfill has been in operation since December 1989. It is a 415 ton per
day landfill. The landfill has a life expectancy of years at our current disposal rates.
The landfill has a clay liner and an HDPE liner. This liner is to protect the groundwater from being
contaminated by the solid waste. Any water that collects on the liner is collected and held in a lagoon.
It is then pumped to a waste water facility for treatment.
The landfill is self-supporting and does not operate from taxes.
http://www.co.rowan.nc.us/enviroservs/swm.htm 2/15/2007

01/11/2007 03:28 9108435789 IAC INC ALCHEM.9 INCO
Cornarate 0jace
2042 8uia Phlladelphus Road
Red Springs, NC 28377
Te1. 910-843-2121 — 800-522-2944
Fax [phone]
rrar�semr.net
Tat ii ry n;.2G107 zy
Ms. Ellen Huffman
Division of Water Quality
NCDENR
Mooresville Regional Office
610 East Center Ave.
Suite 301
Mooresville, NC 2811.5
Re: NOV No. 2006-PC-0061
Date 12-20-06
Dear Ms. Huffman:
PAGE 02
Sales and Manufacturin
8135 Red Road
Rockwell, NC 28138
Tel. [phone] — 800.462-2586
Fax [phone]
pdrye(ftiltel.net
I have r ceived your NOV. However, I did not see this until December 27, as I was
traveling before and until Christmas. I was able to travel to Rockwell and view the area
that you discuss in your Letter of 1.2-20-06.
Neither I nor any other Alchem personnel were aware of any seepage under the retaining
berm- It is apparent that there is some very smallamount of seepage under the retaining
berm. We are presently trying to .hire someone to come in and make a small retaining
wall around these seepage areas. We think that there may be two areas where this is
occurring. We are also pumping and using all of the water in. the enclosed area. V'Je are
trying to get an engineering company to come and tell us what we need to do to put a
berm. around the area that will be sealed. I cannot tell you today what we will do with the
sand. I would like to get the berm repaired and continue to put sand in our. fill area. We
need this sand to bring the property up to grade. Could I please schedule a. meeting at
Your earliest convenience to discuss all of the above.
Best regards,
ALCHEM, [NC
! Fri --
Randall F. Andrews,
President

T
WDENR MRO Fax:[phone]
�A: T r a n s m 1 -t Conf- RaK,iD r -t �#�
P.1
Jan 19 2007 16:06
Fax/Phone Number
Mode
Start
Time
Page
Result
Note
19108C35789
NORMAL
19'.16:06
11'31"
1
:« O K
[Fwd: RF: Meeting]
Subject: [Fwd: Re: Meeting]
From: Ellen Huffman <[e-mail]>
Date: Fri, 19 Jan 2007 10:40:22 -0500
To: Randall Andrews ALCHEM Via@semr,net>
CC: Ellen Huffman <[e-mail]>
I regret that you may not have received the email dated 1/16/07, forwarded below,
which states that the meeting has been moved to January 31, 2007, at 10:00 AM, here
in the Mooresville Office_
Ellen Huffman
Environmental Specialist II
North Carolina.Dept. of Environment & Natural'Resources
Aquifer Protection
610 East Center Avenue
Mooresville, NC 28115
Ph; 704.663.1699 Fait: 704.663.6040
Subject: Re: Meeting
k'iro Ellen u [e-mail]>
te]Pue;> 1'bJa2.4�11:55:40 -0500
To: Randall <rfa@ mr.net>
CC: aoidrew pitner <[e-mail]>, Peggy Hanley <[e-mail]>, Ellen
Huffman <[e-mail]?, Wes Bell <Wes.Bell@:acmail.net>, DAVID GOODRICH
<DAV [e-mail]>
Due to several conflicting schedules, the meeting has been moved to January 31, 2007, 10:30 AM at the
Mooresville Office, DENR WQ_
See you then,
Ellen Huffman
Randall wrote:
GOOD MORNING MS. HUFFMAN
I WANTED TO INFORM YOU THAT I HAVE A DR'S APPT ON JAN 23 AND GARY RIBLETT WHO IS
OUR ENVIRONMENTAL ADVISOR. 1S NOT AVAILABLE UNTIL JAN 25. I WANTED TO KNOW IF
WE COULD ME WITH YOU THE MORNING OF JANUARY 25? PLEASE LET ME KNOW.
Randall F. Andrews

69
N1CDENR MRO Fax:[phone]
AC:* T r a n s m i -t Conf_ Re?r-io r-t Ac4,
P. 1
Jan 19 2007 16:07
Fax/Phone Number
Mode
Start
Time
Page
Result
Note
17042798418
NORMAL
19,16:07
0'40"
1
* O K
Fwd: itel Meeting]
Subject:. [Fwd: Re: Meeting]
From: Ellen Huffoaan <ellen.huffta1'[e-mail]>
Date: Fri, 19 Jan 2007 10:40:22 -0500
To: Randall Andrews ALCHEM <rfa@sexnr_net>
CC: Ellen Huffman <Ellen.Hufrnan@ncmail-net>
I regret that you may not have received the email dated 1/16/07, forwarded below,
which states that the meeting has been moved to January 31, 2007, at 10:00 AM, here
in the Mooresville Office_
Ellen Huffman
Environmental. Specialist II
North -Carolina -Dept. of Environment & Natural Resources
Aquifer Protection r
610 East Center Avenue
Mooresville, NC 28115
Ph: 704.663.1699 Fax: [phone]
Subject: Re: Meeting
From: Ellen Huffman <ellem,[e-mail]>
Date: Tue, 16 Jan 2007 11:55:40 -0500
To: Randall -,[e-mail]>.
CC: andrew pitaer <[e-mail]>, Peggy Finley <Peggy.FiD1ey a�7ncmail.net>, Ellen
Huffman <Ellen.Huf [e-mail]>, Wes Bell <[e-mail], DAVID GOODRICH
<[e-mail]>
Due to several conflicting schedules, the meeting has been moved to January 31, 2007, 10:30 AM at the
Mooresville Office,.DENR WQ.
See you then,
Ellen Huffman
Randall wrote:
GOOD MORNING MS. HUFFMAN
I WANTED TO INFORM YOU THAT I HAVE A DR'S APPT ON JAN 23 AND GARY RIBLETT WHO IS
OUR ENVIRONMENTAL ADVISOR. IS NOT AVAILA81LL UNTIL JAN 25. 1 WANTED TO KNOW IF
WE COULD ME WITH YOU THE MORNING OF JANUARY 25? PLEASE LET ME KNOW
Randall F. Andrews

[Fwd: Re: Meeting]
Subject: [Fwd: Re: Meeting]
From: Ellen Huffman <[e-mail]>
Date: Fri, 19 Jan 2007 10:40:22 -0500
To: Randall Andrews ALCHEM <[e-mail]>
CC: Ellen Huffinan <[e-mail]>
I regret that you may not have received the email dated 1/16/07, forwarded below,
which states that the meeting has been moved to January 31, 2007, at 10:00 AM, here
in the Mooresville Office.
Ellen Huffman
Environmental Specialist II
North Carolina Dept. of Environment & Natural Resources
Aquifer Protection
610 East Center Avenue
Mooresville, NC 28115
Ph: 704.663.1699 Fax: [phone]
Subject: Re: Meeting
From: Ellen Huffman <[e-mail]>
Date: Tue, 16 Jan 2007 11:55:40 -0500
To: Randall <[e-mail]>
CC: andrew pitner <[e-mail]>, Peggy Finley <[e-mail]>, Ellen
Huffman <[e-mail]>, Wes Bell <[e-mail]>, DAVID GOODRICH
<DAVID. [e-mail]>
Due to several conflicting schedules, the meeting has been moved to January 31, 2007, 10:30 AM at the
Mooresville Office, DENR WQ.
See you then,
Ellen Huffman
Randall wrote:
GOOD MORNING MS. HUFFMAN
I WANTED TO INFORM YOU THAT I HAVE A DR'S APPT ON JAN 23 AND GARY RIBLETT WHO IS
OUR ENVIRONMENTAL ADVISOR. IS NOT AVAILABLE UNTIL JAN 25. 1 WANTED TO KNOW IF
WE COULD ME WITH YOU THE MORNING OF JANUARY 25? PLEASE LET ME KNOW.
Randall F. Andrews
INDUSTRIAL AND AGRICULTURAL CHEMICALS, INC.
2042 Buie Phil Rd
Red Springs, NC 28377
Tel. [phone] ext 23 Fax [phone]
Ellen Huffman
1 of 2. 1/19/2007 3:39 PM

[Fwd: Re: Meeting]
Environmental Specialist II
North Carolina Dept. of Environment & Natural Resources
Aquifer Protection
610 East Center Avenue
Mooresville, NC 28115
Ph: 704.663.1699 Fax: [phone]
Re: Meeting Content -Type: message/rfc822
Content -Encoding: 7bit
2 of 2 1/19/2007 3:39 PM

VqA
'
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
L
r
Alan W. Klimek, P.E. Director
> A
Division of Water Quality
AQUIFER PROTECTION SECTION
January 19, 2d07
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Randall Andrews
ALCHEM, Inc.
2042 Buie Philadelphus Road
Red Springs, NC 28377
and
ALCHEM, Inc.
8135 Red Road
Rockwell, NC 28138
Subject:
Response received regarding
Notice of Violation/ Notice of
Recommendation for
NOV No. NOV-2006-PC-0061
Bauxite Residuals Reuse Program
WQ0016338
Rowan County
Dear Mr. Andrews,
. The Mooresville Regional Office received your faxed letter of response to the subject Notice of
Violation/Notice of Recommendation for Enforcement (NOV/NRE), on January 11, 2007.
We would like to remind you that the NOV/NRE has directed you not to use the permitted fill area and .
to find another method of disposal until current conditions are rectified. We strongly advise you not to
build any more earthen berms on the property, as any changes made to this facility requires you to apply
for a permit modification. Corrective measures taken to address the conditions noted in the subject
NOV/NRE will need to be signed off on by a NC Professional Engineer. As your response did not
identify suitable disposal options by the deadline given in the subject NOWNRE, we strongly advise
you to come forth with an alternative disposal option while repairs are made to the subject facility.
Please be ready to present a suitable disposal option on or before the meeting scheduled for 10:30 AM,
January 31, 2007, in The Mooresville Regional Office.
Please be advised that an enforcement action for the subject permit is forthcoming and that your
response and any corrective actions made, will be forwarded with the enforcement package to the director
of DWQ.
Division of Water Quality / Aquifer Protection Section / Mooresville Regional Office Phone: [phone] Fax: [phone]
610 East Center Street, Suite 301, Mooresville, NC 28115 Internet: http://gw.ehnr.state.nc.us

ALCHEM, Inc..
Page 2 of 2
January 19, 2007
If you have any questions concerning this matter, please do not hesitate to contact Ms. Huffman at
[phone].
a
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cc: Ed Hardee, Residuals Coordinator a) z
David Goodrich, Non Discharge Per L °a E
�Il�frYn,are,11119or��sviTfe,e"'�gi'o"�"�"na LLaCO�
Central Files
Sincerely, .7
AnriraUi H. Pitner_ P.G.
RO APS
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ALCHEM,
INC.
1 HUJ V 1
Corporate Office
2042 i3ule. Philadelphus Rued
Red Springs, NC 28377
TA 910-8413- .121 — 800-522-2944
Fax 910.84s-5789
rfaG.�aemr,rtet ,
t�Xt171,1:1I 2, ,`4@0
Mr, Andrew Pitney
F..nviron.m.cntal Regional Supervisor
NCDENR
610 .Gast Center St., Suite 301
Mooresvi.IJe, NC 28115
'Re: NOV No. NOV-2006-PC-0061
Dear Mr. Ptiner:
Sales and Manufacturing
8135 Red Koad
Rockwell, NC 28138
Tel.[phone]
Fax [phone]
[e-mail]
Th.a.nk you for your letter of January 19, 2007. Alchem has not used the perin.ittcd fill
area since we .received a letter about this in mid. December. I have been. talking with
Engineers about this project Since then, and trying to find a solution to this problem. At
o.ne time we sold some of our sand to a fertilizer manufacturer. I have contacted them
and taken new samples to try andget this as an outlet again. The only proposal that I
have, I recently received and just the cost for the engineering was .far more than the value
of our company. At one time i called the Salisbury Landfill, but having to pay the
disposal fee is sometl,in.g that would wreck us eeonorn, ca.11y. We are .fast pulling tl.,e
water down to very minimal levels again. There were two very large .rain storms back in
middle and late November. We have changed the ditch coming under the railroad and so
now the water from the large area across the railroad is diverted From. our contained area.
I would Ji.].ce to ask. tlla.t you consider allowing us to put-ahofut-=50.O�toa-sAfr..or.�l-tire-,tor.-age=`
area nearest: our reactor .into the area near the rails.oa.d. I plan to use that F.l.l., and that area
on which to put ou.r Magnesium. Hydroxide and Calciu,n. Hydroxide in.ixi.ng tanks.
Thank you for your consideration.
Best regards,
ALCHF,M, INC
Randall F. Andrews,
Pla.1at Manager. .

b
w...........................................................................................................................................................................................
FROM FAX NO. Feb. 26 2002 03:53AM P1
ALCHEM, INC,,
Cnr orate Office Sates and Manu acturin
8135 Red Road
2042 Buie Philadelphus Road Rockwell, NC 28188
Red Springs, NC 28377 Tel. [phone] — 800-462-2586
I -el. 910-848.2121 -- 800.522-2944 Fax [phone]
Fax [phone] pdrye(0edltel.net
r#a ay5eMtjaPI.
February 9, 2007
Mr. Andrew Eitner
Environmental Regional Supeivi$or
NCDENR
610 East Center St., Suite 301
Mooresville, NC 28115
Dear Mr. Ptiner-
Alchem has retained Delta Consultants to evaluate the existing berm. structure containing
the storniwater runoff from the bauxite fill area, and recommend the corrective
measures.
Current thoughts are to install a synthetic barrier within the berm, and increase the
thickness of the berm with suitable compacted 'soil to provide redundancy in protection
against leakage. Specific geotechnieal and engineering details are required to be able to
accomplish this design and construction safely and correctly, and to determine if this is
the best course of action. Delta is preparing a workplan and proposed schedule for
accomplishing these tasks. The first steps are expected to include collection
of geotechnical information from the existing berm to determine specifics as to the
location and depth of the possible leakage. This information will be necessary to select
appropriate depth of the barrier system and berm design details.
Best regards,
EM,1NC
t
Randall F. Andrews,
Plant Manager
arms

a
v
03/11/2007 22:06 9108435789 IAC INC
PAGE 01
AL,CHEM, INC.
8138 RED ROAD
ROCKWELL, NC 28137
PHONE: [phone] FAX 704,279.8418
EMAIL: [e-mail]
FAX. TRANSMITTAL
DAr5 AND TIME: MARCH 12, 2007
TO:
ANDREW PITNER
COMPANY:
NCDENR
FAx No.:
704-663-6040
FROM:
ANGELA
COMPANY:
ALCHEM INC.
PHONE NO.:
704-279-7908
FAx No:
704-279-84 9 8
No. OF PAGES:
Li V, INCLUDING COVER
MESSAGE:

...............................................................................................................................................................................................
FROM FAX NO. Feb. 26 2002 03:53AM P1
ALCHEM, INC*
Cor orate O ee Sates and 1dManu aeturin
8135 Red Road
2042 Buse Philadelphus Road Rockwell, NC 28188
Red Springs, NC 28377
Tel, 704279-79U8 — - -
'yel. 910-W-2121 -800.522-2944 Fax [phone]
Fax %0-843.5789 Pdrve<rvalltel.net
rfa uysem�,�
February 9, 2007
Mr. Andrew Pitner
Environmental Regional Supervisor
NCDENR.
610 East Center St., Suite 301
Mooresville, NC 28115
D C�CC�DdC�
F E B 14 2007
NC DEW MRO
DWQ - A uifer Protection
Dear Mr Ptin,er:
Alchem has retained Delta Consultants to evaluate the existing berm. stiucture containing
the stormwater runoff from the bauxite fill area, and recommend the corrective
measures.
Current thoughts are to install a synthetic barrier within the berm, and increase the
thickness of the berm with suitable compacted soil to provide redundancy in protection
against leakage. Specific geotechnical and engineering details are required to be able to
accomplish this design and construction safely and correctly, and to determine if this is
the best course of action. Delta is preparing a workplan and proposed schedule for
accomplishing these tasks. The first steps are expected to include collection
of geotechnical information from the existing berm to determine specifics as to the
location and depth of the possible leakage. This information will be necessary to select
appropriate depth of the barrier system and berm design details.
Best regards,
A EM, eINC
1
Randall F. Andrews,
Plant Manager
erns

03/11/2007 22:06 9108435789 IAC INC
ALCHEM., INC.
Corporate Qflice
2042 BWe Philadelphus Road
Red Springs, NC 28377
Tel. [phone] — 800-522-2944
Fax [phone]
rfa(i:lsemr.net
March 1.2, 2007
Mr. Andrew Pitner.
Environmental Regional Supervisor
NCDENR
61.0 East Center St., Suite 301
Mooresville, NC 28115
Dear MY. Ptiner:
PAGE 02
Sales and Manufacturing
8135 Red Road
Rockwell, NC 28138
Tel. [phone] — 800-462-2586
Fax [phone]
pdrWe[a)alltel.net
We have received this Letter of Recommendation from Gary R. ibblett with DELTA
ENVIRONMENTAL. We are in desperate need to start the sand removal process. Please
advise as to what the next step we take should be.
Best regards,
AL.CHEM, INC
Randall F. Andrews,
Plant Manager
arcs

t,
03/11/2007 22:06 9108435789 IAC INC PAGE 03
SUSTAINABLE STRATEGIES FOR GLOBAL LEADERS
March 9, 2007
Mr. Randall Andrews
ALCHEM, Inc.
2042 Buie Philadelphus Rd.
Red Springs, NC 25377
Subject: Progress and Recommendations
Rockwell, North Carolina
Dear Randall:
This letter is to confirm our conversation regarding our recommendations
previously discussed. You have explained to me that you are in the process of
cleaning out the old, damaged reactor, and that you plan to install the new
mixing tank very soon. I understand that installation of this new washer -mixer
will allow you to discharge the sand -water mixture into the lagoons at a pH of
6.0 or higher as required by permit.
In order to successfully raise the pH of the existing lagoons however, it would
be best to be able to remove the sand from the lagoons to be treated to raise
its pH. Otherwise, the beneficial effect of your new washer -mixer will be
limited by the lower pH sand already in the lagoons.
In our meeting in Mooresville with NC DENR, Ms. Huffman and Mr. Pitner
LTA'
r indicated that they may be amenable to placing additional sand in the storage
area if it had its pH appropriately raised. I agree with them that this higher pH
material would likely have a beneficial effect on stormwater and leachate from
the disposal area.
Per the measurements we have discussed, placing sand with a higher pH into
the disposal area should have a beneficial effect on the pH of stormwater and
leachate from the existing fill area.
Inogen-
If sand can be cleaned from one lagoon at a time and mixed with sufficient
lime, it may be possible to place the sand in the disposal area and help with
the pH of the runoff. Regular sampling and documentation of the pH of each
batch of the treated sand will help verify that we are moving in the right
direction_
The most recent correspondence from NC DENR forbids additional sand
placement in the disposal area, so their prior approval would be required
before placing the sand.
Once the lagoon is cleaned of lower pH sand, and a higher pH sand -water
mixture can be added from your new mixer, you should have more success in
raising the lagoon pH, hence addressing problems in both the fill area and the
lagoons. Clearly it will be much easier to raise the pH in an empty lagoon than
one that contains lower pH sand,
8008 Corporate Center drive Suite 100 Charlotte, NC 28226 USA
Phone: r(i'1.-',4].')tiYO / R00.11 ,7111. Fax: ifl•1.'i•i?.gU35
t a_e n V_c,¢ pl,

y
03/11/2007 22:06 9108435789 IAC INC PAGE 04
Mr, Randal Andrews
ALGHEM, Inc.
Stormwater Fond Sarm Reconstruction
MelYoh 9, 2007
2of2
We would be happy to discuss these recommendations in more detail at your convenience_ Please do not
hesitate to contact me at [phone] with questions.
Sincerely,
DELTA ENVIRONMENTALCONSULTANTS, INC.
Gary C. Ribblett, P,R.
Senior Project Manager

03/11/2007 22:06 9108435789
IAC INC
PAGE 01
AL,CHEM, INC.
8135 RED ROAD
ROCKWELL, NC 213137
PHONE: [phone] FAX [phone]M8418
EMAIL: [e-mail]
FAX TRANSMITTAL
DATE~ AND TIME: MARCH 1 2, 2007
TO: ANDREW PITNER
COMPANY: NCDENR
FAx No.: 704-663-6040
FROM: ANGELA
COMPANY: ALCHEM INC.
PHONE No.: 704-279-7908
FAx NO: 704-279-8418
NO, OF PAGES: V, INCLUDING COVER
MESSAGE:

O rvncuaci F. Emaaicy, vUvcn wi
William G. Ross Jr., Secretary
11YO$ pG North Carolina Department of Environment and Natural Resources
r Alan W. Klimek, P.E. Director
-H Division of Water Quality
j AQUIFER PROTECTION SECTION
March 12, 2007
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Randall Andrews
ALCHEM, Inc.
2042 Buie Philadelphus Road
Red Springs, NC 28377
and
ALCHEM, Inc.
8135 Red Road
Rockwell, NC 28138
Subject: Response to ALCHEM Letters
Dated March 5 and 12, 2007
Regarding WQ0016338
Bauxite Residuals Reuse Program and
Regarding WQ0002702
Industrial Recycle — Bauxite Process
Rowan County .
Dear Mr. Andrews,
The Mooresville Regional Office is in receipt of your faxed letters of March 5th and March 12th, 2007.
The NOWNRE dated December 12, 2006, directed you not to use the permitted fill area and to find a
suitable alternative disposal option until current site conditions are properly rectified. The NOWNRE dated
December 20, 2007, directed you to prepare an engineering report within 90 days of your receipt of the
letter that details the steps you will take to make the recycle system perform satisfactorily. This report must
detail the plan, with a timeline, for removal and disposal of the residuals in the three lagoons. In addition, a
NC professional engineer will need to verify the integrity of the liners of each of the lagoons and repair of
the banks. This plan should also include a design for stormwater diversion. Based on your receipt of the
NOWNRE on December 21, 2006, the Division of Water Quality expects your completed plan will be
submitted no later than March 21, 2007.
Though we are pleased to know that you have begun to engage the services of a consulting engineer
and have started the process of identifying options to make necessary repairs to the facility, to date, you
have not submitted a complete plan that addresses the environmental concerns outlined in the NOWNREs.
As such, I strongly suggest that your next steps are to assemble and submit a plan that addresses the
problems at your facility.
Division of Water Quality / Aquifer Protection Section / Mooresville Regional Office Phone:
610 East Center Street, Suite 301, Mooresville, NC 28115
One
[phone] Fax: [phone] NofthCarohna
Internet: http.//gw.ennr_state.nc.us naturally

ALCHEM, Inc.
WQ0016338 & WQ0002702
March 12, 2007
Page 2 of 2
If you have any questions concerning this matter, please do not hesitate to contact Ms. Huffman, Ms.
Finley, or myself at at [phone].
Sincerely,
Andrew H. Pitner, P.G.
Environmental Regional Supervisor MRO APS
cc: Gary Ribblet, P.E. DELTA, 8008 Corporate Center Dr., Charlotte, NC 28226
Ed Hardee, Residuals Coordinator
David Goodrich, Non -Discharge Permitting Unit
Ellen Huffman & Peggy Finley, Mooresville Regional Office

NCDENR MRO Fax:[phone]
3RAc T r a n s m i t Con-F_ R.ePo r-t =+__+-
P. 1
Mar 12 2007 15:03
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Mode
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Note
7045434035
NORMAL
12,15:03
0'23"
3
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51G East Cer+terAverue Suite 301
Moolesviue Norlh Carolina 28115
ielePhone. 704-6E3-1699
Fax. 704-c63-6040
To: IGc From: s
Fax: 70y(— Pages:
Phone: Dane: 1 ,21 0 %
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19108435789
NORMAL
12,14:58
0'51"
.3
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310 Easi Center Avenue Swle 3C1
Moc,es✓I!e. North Caralira 2EI15
T eleFhr,ne 704-663-1699
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610 East Center Avenue, Suite 301
r Mooresville, North Carolina 23115
Telephone: [phone]
Fax: 7,34-663-6040
To:
From:
Fax: 7ov/— 5 3— S/ Pages: !� • _ V�
Phone:
Date: n --.? — / _ 0
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610 East Center Avenue, Suite 301
"Mooresville, North Carolina 22115
Telephone: [phone]
Fax: [phone]
To: v ��� From:
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7a'M- ��/ Pages:
Phone: Date:
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ylt� 4c C-L-0- ka— r A, jl-� -

WAIF micnaei v. tasiey, uovernor
Q 9FILE
William G. Ross Jr., Secretary
i ; Q North Carolina Department of Environment and Natural Resources
Cq �� Alan W. Klimek, P.E. Director
Division of Water Quality
AQUIFER PROTECTION SECTION
February 14, 2007
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Randall Andrews
ALCHEM, Inc.
2042 Buie Philadelphus Road
Red Springs, NC 28377
and
ALCHEM,, Inc.
8135 Red Road
Rockwell, NC 28138
Subject: Response to ALCHEM Letter
Dated February 9, 2007
Regarding WQ0016338
Bauxite Residuals Reuse Program
Rowan County
Dear Mr. Andrews,
The Mooresville Regional Office received your faxed letter of response (dated 02/09/2007) on
February 12, 2007, regarding our request for an alternative disposal plan for the subject permit. Your letter
asked for permission to use the bauxite fill area to dispose of 500 dry tons of spent sand.
We would like to remind you that the NOV/NRE dated December 20, 2006, directed you not to use
the permitted fill area and to find another method of disposal until current'site conditions are properly
rectified. This was reiterated in our letter of January 19, 2007, and during our meeting on January 31,
2007. This means that any suitable disposal plan will likely be temporary in nature while you correct
conditions at the site.
Currently, materials already placed in the fill area from previous lagoon cleanings still have a
residual affect on the stormwater, lowering the pH to unsuitable levels. There is nothing in place to date to
treat the pH of the stormwater to neutral. File photos from previous inspections indicate that the area,
which you intend to build on; is already filled with bauxite material, however, testing by BOYLE Engineering
(report dated'.October 24, 2605, page 14), reflect that the material has not been compacted properly. This
report also states that the fills have been blended with some of the native residual soils, .however, the
materials are dissimilar and do not readily mix, indicating instability. This report also offered two possible
solutions (same report, page 16) that may be considered by this office. You may also choose to submit to
us another engineer -directed solution for review and possible approval.
Division of Water Quality / Aquifer Protection Section / Mooresville Regional Office Phone: [phone] Fax: [phone]
610 East Center Street, Suite 301, Mooresville, NC 28115 Internet: http://gw.ehnr.state.nc.us

ALCHEM, Inc. Page 2 of 2
WQ0016338
February 14, 2007
As stated in previous correspondence, any changes made to the operations of this facility require you
to apply for a permit modification. Corrective measures taken to address the conditions noted in the
NOWNRE will need to be signed off on by a NC Professional Engineer.
If you have any questions concerning this matter, please do not hesitate to contact Ms. Huffman
at [phone].
Sincerely,
UNITED STATES POSTAL SERVICE
...� .,,.�, ter... , ..... .. . ........... .._.,..._..., ..... ....
gq -
cc: Ed Hardee, Re • Sender: Please print your name, address,
David GoodriO
Ellen Huffman,;
Central Files
DENR DWQ Aquifer Pt t ion
610 E. Center Ave., Ste`-- 301,
Mooresville NC 28115
n
G
c
m
UNITED STATES�P?STAf
• Sender: Please print your name, address, and I
_ t7
Aquifer Protection D
DENRDWQ q c
610 E. Center Ave., Ste. 301
Mooresville NC 28115
;,:,;' { � llt!lII1t41i7t911tU1'!�I►It t�l�l�il t�1911�!l�il.l'11�1�141111, tt

OFF TF9
u�jtV. i7
>t it
Michael F. Easley, Governor
William G. Ross Jr., Secretary
FIL
E
h Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
CERTtFIIED MAIL
RETURN RECEIPT REQUESTED
Mr. Randall Andrews
ALCHEM, Inc.
2042 Buie Philadelphus Road
Red Springs, NC 28377
and
ALCHEM, Inc.
8135 Red Road
Rockwell, NC 28138
Dear Mr. Andrews,
AQUIFER PROTECTION SECTION
March 12, 2007
Subject: Response to ALCHEM Letters
Dated March 5 and 12, 2007
Regarding WQ0016338
Bauxite Residuals Reuse Program and
Regarding WQ0002702
Industrial Recycle — Bauxite Process
Rowan County
The Mooresville Regional Office is in receipt of your faxed letters of March 5th and March 12th, 2007.
The NOWNRE dated December 12, 2006, directed you not to use the permitted fill area and to find a
suitable alternative disposal option until current site conditions are properly rectified. The NOV/NRE dated
December 20, 2007, directed you to prepare an engineering report within 90 days of your receipt of the
letter that details the steps you will take to make the recycle system perform satisfactorily. This report must
detail the plan, with a timeline, for removal and disposal of the residuals in the three lagoons. In addition, a
NC professional engineer will need to verify the integrity of the liners of each of the lagoons and repair of
the banks. This plan should also include a design for stormwater diversion. Based on your receipt of the
NOV/NRE on December 21, 2006, the Division of Water Quality expects your completed plan will be
submitted no later than March 21, 2007.
Though we are pleased to know that you have begun to engage the services of a consulting engineer
and have started the process of identifying options to make necessary repairs to the facility, to date, you
have not submitted a complete plan that addresses the environmental concerns outlined in the NOV/NREs.
As such, I strongly suggest that your next steps are to assemble and submit a plan that addresses the
problems at your facility.
Division of Water Quality / Aquifer Protection Section / Mooresville Regional Office Phone: [phone] Fax: [phone]
610 East Center Street, Suite 301, Mooresville, NC 28115 Internet: http://gw.ehnr.state.nc.us
rthCarolina
aturally

.-, - -3 ry ;-3 L; . .1
ALCHEM, Inc.
WQ0016338 & WQ0002702
March 12, 2007
Page 2of2
If you have any questions concerning this matter, please do not hesitate to contact Ms. Huffman, Ms.
Finley, or myself at at [phone].
Sincerely,---
Andrew H. Pitner, P.G.
Environmental Regional Supervisor MRO APS
cc: Gary Ribblet, P.E. DELTA, 8008 Corporate Center Dr., Charlotte, NC 26226
Ed Hardee, Residuals Coordinator
David Goodrich, Non -Discharge Permitting Unit
Ellen Huffman & Peggy Finley, Mooresville Regional Office
■ Complete items 1, 2; and 3. Also complete
item 4 if Restricted Delivery is desired.
■ Print your name and address on the reverse
so that we can return the card to you.
■ Attach this card to the back of the mailpiece
or on the front if space permits.
1. Article Addressed to:
ALCHEM, Inc..
8135 Red Rd.
Rockwell NO:--'813'8� vvv
2. Article Number
(transfer from service label)
P21Fo�rri 381-1i.IFetiruarvi,
A. Siggdture :::�7'
I
LJ Addressee � Agent
B. Received by (Printed Name) C. Date of Delivery Addressee
C. Date of Delivery
D. Is delivery address different from item 1? Ye I
If YES, enter delivery address below: ❑ No im item 1? 11 Yes
i below: ❑ No
I
❑ess Mail ,
7Receipt for Merchandise is Mail
❑ C.O.D. I Receipt for Merchandise
4. Restricted Delivery? (Extra Fee) ❑ Yes
1 ❑ Yes
7006 2760 0001 8493 8672
Domestic Refurri Receipt 102595-02-M-1540
102595-02-M-1540
3. SServii Type
Wertified Mail
❑ Registered
❑ Insured Mail

4
NCDENR MRO Fax:[phone]
AC:HK T ransm il-t Conf_ Repo r-t *:A-
P.1 Mar 12 2007 15:08
Fax/Phone Number
Mode
Start
Time
Page
Result
Note
7045431035
NORMAL
12,15:08
0'00"
0
D.0.7
T- Check condition of remote fax.
610 Easi CantarA,.erue, Sui(z 301
Mooresvide, North Carolira 26115
i eiephone 70a-e63-1694
Fax 7^,a-e63-6Ca0
To:
DENR
Mooresville
Regional
Office
From:
Fax: ?o3Pages: (�'� Ul • V C�'�-�t/
Phone: Date: 2 ^ ��2- - D /%
Re:�, CC:
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