WQ0002702_Regional Office Historical File Pre 2018 (8)

REPORT OF PRELIMINARY GEOTECHNICAL EXPLORATION
& EARTHEN EMBANKMENT ANALYSIS
8135 RED ROAD
ROCKWELL, NORTH CAROLINA
Prepared for:
Mr. Randall Andrews
Alchem Inc.
Rockwell, NC
consulting
Onglineers
4340-H Taggart Creek Road
Charlotte, NC 28208
Project 05-133
Aber 24, 2005 f
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BOYLE CONSULTING ENGINEERS, PLLC
Development and Construction Project Services --
October 24, 2005
Mr. Randall Andrews
Alchem Inc.
8135 Red Road
Rockwell; NC 28138
13�'i! a^dart Cre lc RCL Ste. H
Charlotte; NC 28208
Phone: [phone]
Fax: [phone]
Subject: Report of Geoteehnical Exploration & Earthen Embankment Analysis
Proposed New Tank Farm Pad
8135 Red Road
BCE Project No. 05-133
Dear Mr. Andrews:
As authorized by acceptance of our proposal 05-133, dated July 15, 2005, Boyle Consulting Engineers,
PLLC (BCE) has recently performed a Preliminary Geotechnical Exploration & Earth Embankment
Analysis of the referenced property in Rockwell, North Carolina. This report describes the work
performed, presents the data obtained,. and provides our recommendations relative to site preparation and
building foundations. This report is intended for the use of Mr. Randall Andrews/ Alchem Inc. The
contents of this report should not be relied upon by any other entity without the express written consent of
BCE.
We appreciate the opportunity to provide our professional services on this project. Please contact us
should you have any questions pertaining to this report.
Sincerely,
BOYLE CONSULTING ENGINEERS, PLLC
Nathan B. Cooke, P.G.
Senior Geologist
Registered, NC 1051
Attachments
Charl Boyle, P.E.
Managing Principal
Registered, NC 19681
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Report of Preliminary Geotechnical Exploration & Earthen Embankment Analysis October 24, 2005
Proposed New Tank Farm Pad, Rockwell, North Carolina Final
BCE Project 05-133
TABLE OF CONTENTS
iEXECUTIVE SUMMARY ........................................................i................................................................................. I
PROJECTOVERVIEW ............................................................................................................................................. 4
PROJECTINFORMATION ........................................................... ....... ...................
4
SCOPEOF WORK ........................................................................................................................................................
5
PURPOSEOF EXPLORATION .................................................................................................................... ...................
6
FIELD EXPLORATION, LABORATORY TESTING AND MAP RECORDS SEARCH .................................7
SOILTEST BORINGS...................................................................................................................................................
7
BULKSAMPLING ........................................................................................................................................................
7
LABORATORYTESTING ..............................................................................................................................................
8
Visual/Manual Soil Classification ............................ : ..................................... : .....................................................
8
NaturalMoisture Content .....................................................................................................................................
8
GrainSize Distribution .........................................................................................................................................
8
SoilPlasticity ........................................................................................................................................................
9
LaboratoryCompaction Testing ...........................................................................................................................
9
MAPRECORDS SEARCH ...........................................................................................................................................
10
SITERECONNAISSANCE ...........................................................................................................................................
10
RESULTS OF FIELD EXPLORATION, LABORATORY TESTING AND MAP RECORDS SEARCH
...... 11
REGIONALGEOLOGY ................................................................................................................................................
11
SOILSURVEY ...........................................................................................................................................................
11
SOILCONDITIONS .................................................... **'**'**"* ...... .........
GROUNDWATERCONDITIONS ..................................................................................................................................
13
ANALYSISAND RECOMMENDATIONS ............................................................................................................
ii
SITEDEVELOPMENT PRECAUTIONS .........................................................................................................................
14
ExistingUndocumented Fills ..............................................................................................................................
14
HighPlasticity Clay ............................................................................................................................................
15
Ground -Water Control .......................................................................................................................................
15
FOUNDATIONRECOMMENDATIONS ..........................................................................................................................
16
Recommended Allowable Bearing Pressure .......................................................................................................
17
PAVEMENT AND FLOOR SLAB RECOMMENDATIONS .................................................................................................
18
GLOBAL STABILITY ANALYSIS OF EXISTING BERM ................................. ................................................................
19
SITE PREPARATION AND GRADING (BERM) ..............................................................................................................
20
GeneralSite Preparation Notes. ................... o ......................................................................................... I ...........
21
LIMITATIONSOF ANALYSIS .....................................................................................................................................
22
CONSTRUCTION SCHEDULE CONSIDERATIONS .................. s ...................................................................................
23
REVIEWOF GRADING PLANS ...................................................................................................................................
23
STANDARDOF CARE . .................................................................................................................................................
23
APPENDICES

Report of Preliminary Geotechnical Exploration & Earthen Embankment Analysis October 24, 2005
Proposed New Tank Farm Pad, Rockwell, North Carolina Final
BCE Project 05-133
EXECUTIVE SUMMARY
The Subject Site is located at the intersection of Red Road and Crescent Road in Rockwell, Rowan
County, North Carolina. The elongate parcel is comprised of approximately 33.7 acres of land. The
Subject Site is gently rolling terrain bisected by a drainage feature which trends towards the southeast.
An earthen embankment has been constructed inside the northern and eastern site boundaries and some
ponded surface water was observed at the lower site elevations along the berm interior. Approximately
20 ft of fill (reportedly comprised of residual silica mixed with on -site soils) is present north of the
residual silica lagoons and west of the containment berm.
We understand that long-term development plans include raising the site grade within the area defined by
the existing berm with the mixed residual silica and on -site soils to prepare a level building pad for a tank
farm and dry bulk materials storage. Gravel parking/drive areas will surround the proposed structures.
The anticipated construction will likely consist of various single -story steel -frame buildings with metal
veneer. The floor systems will likely be slab -on -grade floors for the office and materials
storage/containment areas.
In a letter from Mr. David Goodrich, Hydrogeologist with the North Carolina Division of Water Quality
(NCDWQ) dated June 8, 2005, Alchem, Inc. (ALCHEM) was requested to provide NCDWQ with
engineering documentation of the following items for review of a non -discharge permit:
1. A structural evaluation of the residual silica from bauxite digestion (residual silica) or fills
comprised of on -site soils mixed with the residual silica,
2. Density (Standard Proctor), optimum moisture content and selected other physical properties
pertinent to the geotechnical stability of the foundation soils.
This report addresses items 1 (structural evaluation of the residual silica soils) and 2 (various pertinent
physical properties identified by our laboratory).
During an on -site meeting with our Mr. Nathan Cooke, P.G. and Mr. Andrews, the analysis of the existing
containment berm and the future configuration of the raised berm were discussed.
A total of 10 soil test borings were performed during the field exploration. The borings were generally
located either in the earthen berm or in the fill pad areas and typically encountered varying thicknesses of
fill soils overlying stiff to dense non -plastic residual soils. Soft, wet alluvial soils were encountered at the
1

Report of Preliminary Geotechnical Exploration & Earthen Embankment Analysis October 24, 2005
Proposed New Tank Farm Pad, Rockwell, North Carolina Final
BCE Project 05-133
lower elevations of the drainage feature. Groundwater was encountered at depths of between 2 and 17.7
ft below existing grade
The existing fills in the area of the proposed building appear to have been placed in a random uncontrolled
manner resulting in zones of uncompacted (soft) fill. The most conservative site repair would be the undercut
and replacement of the existing fill with engineered fill. In our opinion, this would be an overly conservative
approach on this site given the type of planned structures. An alternative to complete fill undercutting would
be to partially undercut the existing fill and any deleterious soils to provide at least 5 ft of new, well -
compacted engineered fill to separate the building foundations and slab bottom from any fill left in -place.
The fill thickness would be measured from the footing bearing elevation and compacted in thin lifts to 95
percent of Standard Proctor. Placement of one or more feet of bridging fill or use of geotextile fabric or
geogrid might be required on the undercut fill soils to provide a working platform. If organic debris or
organic fill is encountered, deeper undercutting would be required. Bridging fill would not be included in
the required 5 ft of engineered fill below foundations.
This partial undercutting of the existing soils would mean some risk of long term settlement due to settlement
of any left -in -place uncompacted fill material. The Owner should recognize the risk of potential future
settlement of this approach which could require future repair or maintenance. The potential for differential
settlement for the buildings would be.the most concern. Differential settlement concern could be minimized
by use of a post -tensioned slab system or by a heavily reinforced monolithic slab of appropriate thickness to
allow the building to settle more uniformly. Flexible connections for piping coming into the building would
be desirable to help accommodate future settlement potential. We recommend use of a maximum soil
bearing pressure of 2000 psf be used for foundations bearing on the engineered fill replaced in the above
partial undercut option. The use of wood frame construction would be desirable to minimize the effects of
settlements. If masonry walls are used, liberal construction joints in the walls should be used.
In areas along the western edge of the site where the existing fill is likely to be thin or absent, the firm
(N=12 blows per foot) or better residual soils are likely suitable to support a system of conventional
shallow foundations for the proposed building and pavement subg_rade if they are similar to the residual
soils encountered at depth by the borings.
Analysis of reinforced earth slopes was performed in order to determine feasibility of the construction of
an earthen embankment which structurally retains the residual silica. This analysis is not intended to
replace design documents necessary to satisfy various environmental regulatory requirements. Our
PA

Report of Preliminary Geotechnical Exploration & Earthen Embankment Analysis October 24, 2005
Proposed New Tank Farm Pad, Rockwell, North Carolina Final '
BCE Project 05-133
analysis of the existing embankment 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. Further analysis reveals that a re -built reinforced earth embankment using geo-grids
can replace the existing embankment and retain the residual silica waste with a reasonable and acceptable
factor of safety.
In general, the site geotechnical conditions and soils/materials will require significant repair of the
planned building pad before construction as described in this report can proceed. Site repair will also be
required to replace the existing earth embankment and properly install the reinforced earth embankment.
01

Report of Preliminary Geotechnical Exploration & Earthen Embankment Analysis October 24, 2005
Proposed New Tank Farm Pad, Rockwell, North Carolina Final
BCE Project 05-133
PROJECT OVERVIEW
PROJECT INFORMATION
The following project information was obtained from a verbal Request for Proposal from Mr. Randall
Andrews/ Alchem Inc., as well as our online review of Rowan County GIS information.
The Subject Site (8135 Red Road) is located at the intersection of Red Road and Crescent Road in
Rockwell, Rowan County, North Carolina. The elongate parcel is comprised of approximately 33.7 acres
of land. Figure 1 in the attached Appendix presents a Site Location Plan indicating the approximate site
and vicinity. Figure 2 in the attached Appendix presents a Boring Location Plan indicating the general
site conditions. .
The U.S.G.S. 7.5-minute topographic map depicts the Subject Property to the east of a local topographic
high. The Subject Site is gently rolling terrain and bisected by a drainage feature which trends towards
the southeast. The total vertical relief across the area of the proposed construction is estimated to be
approximately 20 to 25 feet (approximately elevation 780 to 800) feet National Geodetic Vertical Datum
(NGVD). An earthen embankment has been constructed inside the northern and eastern site boundaries
and some ponded surface water was observed at the lower site elevations along the berm interior.
Approximately 20 ft of fill (reportedly comprised of residual silica mixed with on -site soils) is present
north of the residual silica lagoons and west of the existing containment berm.
We understand that development plans include extending the fill area with the mixed.residual silica and
on -site soils to prepare a level building pad for a tank farm and dry bulk materials storage. Gravel
parking/drive areas will surround the proposed structures. The anticipated construction will likely consist
of single -story steel -frame building with metal veneer. The floor systems will likely be slab -on -grade
floors for the office and materials storage/containment areas.
11

Report of Preliminary Geotechnical Exploration &.Earthen Embankment Analysis October 24, 2005
Proposed New Tank Farm Pad, Rockwell, North Carolina Final
BCE Project 05-133
In a letter from Mr. David Goodrich, Hydrogeologist with the North Carolina Division of Water Quality
(NCDWQ) dated June 8, 2005, Alchem, Inc. (ALCHEM) was requested to provide NCDWQ with
engineering documentation of the following items for review of a non -discharge permit:
1. A structural evaluation of the residual silica from bauxite digestion (residual silica) or fills
comprised of on -site soils mixed with the residual silica,
2. Density (standard Proctor), optimum moisture content and selected other physical properties
pertinent to'the geotechnical stability of the foundation soils.
During an on -site meeting with our Mr. Nathan Cooke, P.G. and Mr. Andrews, the analysis of the existing
containment berm and the future configuration of the raised berm were discussed. We understand that
there was an overtopping of a smaller pre-existing berm in the past and that plans are to raise the current
berm as new residual silica is mixed with on -site soils to prepare a building pad for a plant expansion
project. We also understand that the environmental requirements do not allow water which contacts the
residual silica to leave the containment area.
BCE has been requested to address the two items listed above as well as analyzing the existing and future
berm configuration. Other items requested by NCDWQ are being addressed by ALCHEM separately.
The above project information is based on the furnished site sketch plan, USGS topographic information,
the referenced letter addressed to ALCHEM from NCDWQ, dated June 8, 2005 and our on -site meeting
with Mr. Andrews on June 30, 2005.
SCOPE OF WORK
The conclusions and recommendations contained in this report are based on the results of 10 soil test
borings, laboratory testing and manual/visual examination of representative soil samples, and an
engineering analysis of the results with respect to the outlined project information. Analysis of a
conceptual retained earth slope was included in the scope of work.
5

Report of Preliminary Geotechnical Exploration & Earthen Embankment Analysis October 24, 2005
Proposed New Tank Farm Pad, Rockwell, North Carolina Final
BCE Project 05-133
PURPOSE OF EXPLORATION
The purpose of this exploration was to explore the soil and groundwater conditions at the site and to
develop engineering recommendations to guide BCE in the analysis of the reinforced earth slopes and
develop building foundation recommendations. We accomplished these objectives by the following:
1. drilling soil test borings to explore the subsurface soil conditions and collect samples for
laboratory testing, examination and classification,
2. measuring stabilized groundwater depths after the borings are completed to document the site
groundwater conditions,
3. performing an engineering/geological site reconnaissance to observe the site conditions and
detect issues that may not have been detected by the borings, observed by the engineering
technicians or indicated by published information,
4. performing a map records search of readily available geologic, topographic and soils
information
5. performing laboratory testing and visual/manual examination of soil samples from the
borings to evaluate pertinent engineering properties, and
6. analyzing the field data to develop appropriate engineering recommendations and estimate
soil parameters for use by your civil and/ or structural engineering team.
on

Report of Preliminary Geotechnical Exploration & Earthen Embankment Analysis October 24, 2005
Proposed New Tank Farm Pad, Rockwell, North Carolina Final
BCE Project 05-133
FIELD EXPLORATION, LABORATORY TESTING AND MAP RECORDS SEARCH
I
Details of the procedures used for the field exploration, laboratory testing and map records search are
presented in Appendix E of this report. Additional background regarding the. results of the field
exploration, laboratory/examination testing and map records search are presented in Appendix C of this
report. Site specific details regarding these procedures follow.
SOIL TEST BORINGS
BCE advanced 10 soil test borings at the site locations shown on the.attached Boring Location Plan
(Appendix A, Figure 2).' The soil test borings were advanced to a maximum depth of 20 feet below
existing grade. The boring locations were selected by BCE and established in the field by BCE personnel
from map -scaled distances, by measuring from site landmarks and estimating right angles. Surveying
equipment was not used to locate the borings in the field; therefore, the locations depicted on the Boring
Location Plan should be considered approximate. Elevations shown on the profiles and Test Boring
Records are estimated based on interpolation between ground surface contours shown on the partial
topographic site plan furnished by Mid -Atlantic Associates. Representative portions of the soil samples
obtained were classified and tested in our laboratory. Soil Test Boring Records are attached (Appendix
B), showing the soil descriptions, penetration resistances, and other subgrade characteristics.
BULL{ SAMPLING
Bulk samples were obtained at selected locations of soil materials designated as native or borrow soils,
residual silica (non -blended) and a mixture of residual silica and native soils (blended). These bulk samples,
along with sealed samples of each material, were transported to the laboratory for testing. The locations of
these samples are indicated on the boring location plan. The native soils were excavated with construction
equipment provided by Alchem from the lower elevations of the proposed fill area. The non -blended soils
(unmixed residual silica) were obtained by direct shovel excavation of a recently placed (dump truck) load of
lagoon waste silica. The blended soils were excavated with a shovel by visually identifying mixed zones in
the eroded sidewalls of the existing fill. The blended soils are readily visually identified as a white -colored
residual silica matrix with clots of orange clayey silt.
7

Report of Preliminary Geotechnical Exploration & Earthen Embankment Analysis October 24, 2005
Proposed New Tank Farm Pad, Rockwell, North Carolina Final
BCE Project 05-133
LABORATORY TESTING
Representative soil samples were selected and tested in our laboratory to check field classifications and to
determine pertinent engineering properties. The laboratory testing program included visual
classifications, moisture content, grain size, soil plasticity, and compaction tests.
Visual/Manual Soil Classification
An experienced soil engineer or professional geologist classified each soil sample on the basis of texture
and plasticity in accordance with the Unified Soil Classification System. The group symbols for each soil
type are indicated in parentheses following the soil descriptions on the boring logs. A brief explanation of
the Unified System is included with this report. The soil engineer grouped the various soil types into the
major zones noted on the boring logs. The stratification lines designating the interfaces between
earth materials on the boring logs and profiles are approximate; in situ, the transitions may be gradual.
Natural Moisture Content .
The natural moisture content of selected samples was determined in accordance with ASTM D 2216. The
moisture content of the soil is the ratio, expressed as a percentage, of the weight of water in a given mass
of soil to the weight of the soil particles. The results are presented in Table 1, Laboratory Test Results
found in the Appendix. The moisture contents of the non -blended materials are within 3 percent of the
optimum moisture content. Moisture conditioning of existing soils should be minimal. The moisture
content of the blended soils was 8 percent dry of optimum moisture content. These blended soils would
require significant moisture conditioning.
Grain Size Distribution
Grain size tests were performed on representative soil samples to determine the particle size distribution
of these materials. After initial drying, the samples were washed over a U.S. standard No. 200 sieve to
remove the fines (particles finer than a No. 200 mesh sieve). This test was performed in a manner similar
to that described by ASTM D 422. The results are presented as percent fines on the attached Laboratory
Test Results, Table 1.
8

Report of Preliminary Geotechnical Exploration & Earthen Em bankment Analysis October 24, 2005
Proposed New Tank Farm Pad, Rockwell, North Carolina Final
BCE Project 05-133
Soil Plasticity
Representative samples of the site soils were selected for Atterberg Limits testing to determine their soil
plasticity characteristics. The soil's Plasticity Index (PI) is representative of this characteristic and is
bracketed by the Liquid Limit (LL) and the Plastic Limit (PL). These characteristics are determined in
accordance with ASTM D 4318. The LL is the moisture content at which the soil will flow as a heavy
viscous fluid. The PL is the moisture content at which the soil begins to lose its plasticity. The data
obtained are presented on the attached Laboratory Test Results, Table 1 in the Appendix.
Certain soils swell and shrink (change volume) with changes in soil moisture content. The PI is related to
this potential volume change ability. When excessive volume changes occur in soils confined beneath
foundations, floor slabs and pavements, structural deformations or pavement subgrade weakening can
occur. Experience has shown that soils having a PI of less than 15 are only slightly susceptible to volume
changes. Soils having a PI greater than 30 are generally susceptible to these volume changes. Soils with
a PI between these limits have moderate volume change potential. Table 2 on the following page
summarizes the general relationship between PI and soil volume. change potential. The site soils tested at
this site are non -plastic and therefore not susceptible to volume change with moisture content change.
TABLE 2, POTENTIAL SOIL VOLUME CHANGE POTENTIAL
A7VT) PT.A.STW[TY RFLATION,SHIP
VOLUME CHANGE
POTENTIAL
SHRINKAGE LIMIT
PLASTICITYINDEX
Low
15+
0-18
Moderate
10-15
15-28
High
7-12
25-41
Very High
0-11
35+
Adapted From Bowles (1996)
Laboratory Compaction Testing
Representative samples of the existing site soils from the project site were collected and returned to the
laboratory for compaction testing. A Standard Proctor compaction test (ASTM D 698) was performed on
the selected sample to determine the compaction characteristics, including the maximum dry density and
optimum moisture content. The results are presented in the Moisture Density_ Relationship curves and on
Table 1 found in the Appendix and discussed on the following page.

Report of Preliminary Geotechnical Exploration & Earthen Embankment Analysis October 24, 2005
Proposed New Tank Farm Pad, Rockwell, North Carolina Final
BCE Project 05-133
TABLE 3
HOT.STURE DENSITY RELATIONSHIPS
Optimum
Sample
Maximum Dry
Moisture
Designation
Density, (pcfi
Content, Percent
Silica
58.5
51.3
Silica Blend
63.0
56.3
Residuum
102.8
19.5
MAP RECORDS SEARCH
The following map records were utilized to evaluate site groundwater and soil conditions.
Rockwell, North Carolina 7.5-Minute Topographic Quadrangle, dated 1993,
published by the US Geological Survey (see Appendix A, Figure 1).
Geologic Map of the Charlotte 1°x 2° Quadrangle, North Carolina and South
Carolina, dated 1988, published by the USGS.
On-line Soil Survey of Rowan County, provided by the Rowan County GIS Service.
SITE RECONNAISSANCE
A site reconnaissance was performed by our Mr. Nathan Cooke, P.G., concurrently with performing the
boring layout. The surface soils were obvious fills excavated from the residual silica lagoons and
occasionally contained scattered construction debris and clayey zones. Evidence of mixing of the residual
soils with the residual silica was observed. The berm appears to have been constructed by excavating a
trench and placing the excavated materials into the berm. Ground water was present several feet below
the natural ground surface. No springs, rock outcrops, or other geologic features were observed during
the reconnaissance. No other unusual items were observed during our reconnaissance.
10

Report of Preliminary Geotechnical Exploration & Earthen Embankment Analysis October 24, 2005
Proposed New Tank Farm Pad, Rockwell, North Carolina Final
BCE Project 05-133
RESULTS OF FIELD EXPLORATION, LABORATORY TESTING AND MAP
RECORDS SEARCH
REGIONAL GEOLOGY
The site is located within the Piedmont Physiographic Province of North Carolina. The bedrock
underlying the site is reported to be Salisbury granite, a relatively large intrusion of light-colored igneous
rock which has become weakly metamorphosed into a type of granite gneiss. Additional details of
regional geology relative to the site area are presented in Appendix C.
SOIL SURVEY
The Soil Survey of Rowan County (from Rowan County GIS) indicates that the Helena and Cecil soil
series are present at the site. Cecil soils are typically preferred by local contractors due to their relatively
ease of workability except during wet weather. Helena soils are associated with highly plastic clay
deposits and are generally contain excessive amounts of clayey materials unsuitable for direct support of
foundations and pavements. Additional details of soil series relative to the site area are presented in
Appendix C.
SOIL CONDITIONS
All borings (except for boring B-10) encountered fill materials to depths ranging between 9 and 20+ ft
below existing grade. The berm fills typically consisted of sandy silty clay or sandy clayey silt with
standard penetration resistances ranging between 2 and 37 bpi (blows per 1.75-inch increment). The fill
in the berm near boring B-4 contained boulders which caused auger refusal on several offsets. Much of
the berm fill at borings B-1, B-2 and B-3 was judged to be moderately to highly plastic, based on our
manual and visual examination. These plastic clays are known locally as "bull's tallow". Much of the fill
was wet or moist and sometimes contained organic matter. The deeper fill at boring B-5 appears as if
alluvial soils were excavated and used as fill resulting in a sampled material that has many of the
properties of both alluvium and fill. This material was designated as "Fill or Alluvium" on the Test
Boring Record and was classified as wet, sandy clayey silt with abundant organics.
11

Report of Preliminary Geotechnical Exploration & Earthen Embankment Analysis October 24, 2005
Proposed New Tank Farm Pad, Rockwell, North Carolina Final
BCE Project 05-133
Borings B-6 thru B-9 were drilled in the higher site elevations and encountered fill materials to depths
ranging between 9 and 20+ ft below existing grade. Depth of fill increased eastward across the proposed
building pad area. The building pad fills typically consisted of white -tan silty sand (the residual silica)
with sandy silty clay or sandy clayey silt inclusions (the native soils) and having standard penetration
resistances ranging between 2 and 37 bpi (blows per 1.75-inch increment). The fill at boring B-6
contained rock fragments and organics. Occasional zones encountered clay soils that were judged to be
moderately to highly plastic, based on our manual and visual examination. The borings did not encounter
deleterious materials however some debris was observed embedded in the fill matrix in larger ravines
eroded into the existing fill mass. Based on the ground surface contours the fill should not exceed about 2
or 3 ft at boring B-6, yet greater than 20 ft of fill materials were encountered.
Alluvial (water -deposited) soils were encountered beneath the fill at boring B-5 to a depth of 20+ ft below
the surface and from beneath topsoil at boring B-10. The alluvium consisted of a wet, hard sandy clayey
silt with gravel at boring B-5 and sandy clayey silt and silty clay at B-10. Standard penetration
resistances ranged between 10 and 37 bpi. The alluvial soils typically contained minor amounts of
organic matter however abundant organics were encountered at boring B-5 at a depth of about 12 ft below
existing grade.
The residual profile generally consists of stiff to hard sandy clayey silts underlain by stiff sandy silt,
although highly plastic sandy silty clays were encountered at borings B-7. Based on the predominance of
highly plastic clay fills in portions of the berm fills we suspect that much of the site is underlain by
similar highly plastic clays in undisturbed areas.
Residual material hard enough to be designated partially weathered rock was not encountered at the
boring locations. The borings which. encountered auger refusal (B-4 and B-10) were either on boulders
within fill (B-4) or hand auger refusal at B-10 in very cohesive clays which swelled when excavated
seizing the auger sidewalls.
Refusal may result from boulders, lenses, ledges or layers of relatively hard rock underlain by partially
weathered rock or residual soil; refusal may also represent the surface of relatively continuous bedrock.
Core drilling procedures are required to penetrate refusal materials and determine their character and
continuity. Core drilling was beyond the scope of this exploration.
12

Report of Preliminary Geotechnical Exploration & Earthen Embankment Analysis October 24, 2005
Proposed New Tank Farm Pad, Rockwell, North Carolina Final
BCE Project 05-133
Subsurface data is presented graphically in profile in Appendix A (Figure 3). Detailed information for
each boring location is shown on the soil test boring records included in Appendix B. i
GROUNDWATER CONDITIONS
During drilling activities groundwater was encountered at borings B-3, B-6 and B-10 at depths ranging
between 4 and 12 feet. Ground -water levels were measured again on August 19, 2005. At that time, the
ground -water levels were encountered at depths ranging between 2 and 17.7 ft below the surface. The
groundwater levels noted within the berm fills (borings B-1, B-4 and B-5) likely represent a perched
water condition. Perched water refers to surface water that has infiltrated the upper soil layers only to
become trapped by relatively impermeable clayey soil or rock. Numerous highly plastic clay zones were
encountered by the borings within the embankment fill. Perched water is also likely at boring B-6 where
relatively deep fills were encountered. Refer to Appendix D for Recommended Construction Practices
related to control of site groundwater and surface water, if encountered.
13

Report of Preliminary Geotechnical Exploration & Earthen Embankment Analysis October 24, 2005
Proposed New Tank Farm Pad, Rockwell, North Carolina Final
BCE Project 05-133
ANALYSIS AND RECOMMENDATIONS
SITE DEVELOPMENT PRECAUTIONS
In general, the site conditions and soils are generally suitable for construction of the planned fill pad. The
following items are emphasized to help identify potential problems that may arise during the construction
activities.
Existine Undocumented Fills
The borings indicate that the relative consistency of the existing fill soils near the anticipated bearing
levels is relatively loose or soft which likely indicates a lack of proper compaction. The fills have been
blended with some of the native residual soils (mostly sandy clayey silts and some silty clays) however
the materials are dissimilar and do not readily mix. Some organics and small roots were observed
weathering out of the fill matrix.
The quantities of undocumented fill are unknown. These fill soils (if relatively free of organics) can
likely be re -used as engineered fill beneath buildings and parking areas (after moisture adjustment, as
necessary and approval by BCE). Although the borings did not detect organics, significant amounts of
foreign materials, possible voids or soft material zones, such materials may be encountered elsewhere
within the site. The relatively variable (although relatively low) N-values recorded within the fill material
suggest that the fill did not receive a uniform level of compactive effort.
Undocumented fill is typically uncontrolled and carries the risk of improper compaction, inclusion of
deleterious material, and concealment of unacceptable bearing conditions such as voids, basements,
excavations, wells, etc. Therefore, in our minion, the existing fill at the site is not suitable to provide
direct foundation support for the proposed construction. Likewise, slabs supported by undocumented fill
could settle excessively if voids or inclusions within the old fill begin subsidence or settlement under the
weight of new fill and/or building loads. Given these subsurface conditions, we recommend two general
development options to provide adequate foundation support as detailed in the foundation
recommendations on the following page (16). These two options involve various levels of risk related to
slab and foundation support.
14

Report of Preliminary Geotechnical Exploration & Earthen Embankment Analysis October 24, 200E
Proposed New Tank Farm Pad, Rockwell, North Carolina Final
BCE Project 05-133
Hi!h Plasticity Cla
As indicated previously, a layer of moderate to high plasticity clay was encountered at 7 of 10 of the soil
test borings. This high plasticity clay, known locally as "bull tallow" is commonly found within the
Helena soil unit and occasionally in the Mecklenburg and Enon units as mapped by the US Soil
Conservation Service. This material has the tendency to exhibit a high shrink/swell potential and is not
suitable for direct building or pavement support (without chemical additives.) In building areas where the
proposed footings are within 5 feet of the highly plastic clay, the clay material generally must be undercut
and removed. In pavement areas and potentially beneath slabs, the material may either be undercut or
stabilized using lime or cement treatment. In addition, this material will generally not be suitable for use
as engineered fill beneath buildings but could potentially be placed in green areas or other non-structural
fill applications. We have also found that this material is sensitive to moisture conditions and is difficult
to adequately compact if the moisture content is not close to the optimum moisture content. Therefore,
the type of remediation required for development of any specific portion of the site will depend on the
actual grades, structure location and soil conditions. The recommendations presented in this report
assume the common practice of removal of the highly -plastic bull tallow soils beneath building,
foundations and pavement/ slab areas where near subgrade.
Ground -Water Control
Groundwater was not encountered within anticipated construction and excavation limits explored by the
borings within the planned fill pad area. We do not anticipate a need for ground -water control during
grading in the cut portions of the building pad or parking area. Ground water is present near the
elevations of the base of the existing embankment/berm. Groundwater control will likely be required
during construction in the embankment reconstruction areas of the site. We recommend that the
groundwater table be lowered and maintained at a depth of at least 2 ft below bearing levels and
excavation bottoms during construction. Adequate control of this groundwater could likely be
accomplished by means of numerous gravity ditches and pumping from gravel -lined, cased sumps. The
contractor should be prepared to promptly remove surface water from the general construction area by
similar methods.
15

Report of Preliminary Geotechnical Exploration & Earthen Embankment Analysis October 24, 2005
Proposed New Tank Farm Pad, Rockwell, North Carolina Final
BCE Project 05-133
.' FOUNDATION RECOMMENDATIONS
BCE realizes that completely undercutting the existing fill is likely not feasible and is overly conservative.
An alternative to complete fill undercutting or use of driven pile support would be to partially undercut the
existing fill and highly plastic soils to provide at least 4 ft of new, well -compacted engineered fill (preferably
comprised of native soils) to separate the building foundations and slab bottom from any fill left in -place.
The non -blended residual silica may be used as engineered fill however long term building performance may
not as satisfactory as the native soils. The fill thickness would be measured from the footing bearing
elevation and compacted in thin lifts to 95 percent of standard Proctor. Placement of one or more feet of
bridging fill or use of geotextile fabric such as Mirifi 50OX or 60OX (or equivalent), might be required on the
undercut fill soils to provide a working platform. If very trashy, organic fill is encountered, deeper
undercutting would be required. Bridging fill would not be included in the required 4 ft of fill below
foundations.
This partial undercutting of the existing soils would mean some risk of long term settlement due to settlement
of the left -in -place fill material. The owner should recognize the risk of potential future settlement of this
approach which could require future repair or maintenance. The potential for differential settlement for the
buildings would be of most concern. Differential settlement concern could be minimized by use of a post -
tensioned slab system or by a heavily reinforced monolithic slab of appropriate thickness to allow the
building to settle more uniformly. Flexible connections for piping coming into the building would be
desirable to help accommodate future settlement potential. The use of wood frame construction would be
desirable to minimize the effects of settlements. If masonry walls are used, liberal construction joints in the
walls should be used.
The use of driven timber piles or reinforced mat foundations should be considered instead of the
previously recommended undercutting and replacement. Both options should be further evaluated when
construction plans are finalized. In our opinion, based on the results at borings B-1 through B-5,
individual pile capacities of 20 tons could be obtained for timber piles driven to depths ranging between
25 to about 30 ft below existing site grade.
V

Report of Preliminary Geotechnical Exploration & Earthen Embankment Analysis October 24, 2005
Proposed New Tank Farm Pad, Rockwell, North Carolina Final
BCE Project 05-133
Timber piles should be pressure -treated with a minimum tip diameter of 8 inches. Pre-augering a hole 75
to 90 percent of the pile diameter through the fill and alluvium may be required for timber piles to
promote driving efficiency and to limit driving stresses.
We recommend that a pile hammer with a rated energy of 9,000 to 15,000 ft-lbs be used. Care should be
taken to avoid overdriving the piles if sudden take-up occurs on very dense soils or partially weathered
rock.
The vertical support provided by the soil in contact with the pile cap should be omitted from the capacity
calculations. We recommend a minimum center -to -center pile spacing of 3 pile diameters. This
restriction is advisable to limit surface heave, to enhance the bearing efficiency of the individual piles,
and to reduce the possibility of damaging previously installed piles. During installation of piles, it is
recommended that the piling be driven from the center of each pile group to the perimeter to help
minimize any heaving effects.
We recommend that a soil technician working under the direct supervision of the soils engineer be present
during the pile driving to assist in establishing the required total driving resistance and to log the
penetration resistances and installed pile depths.
Recommended Allowable Bearing Pressure
Foundations bearing in new engineered fill (comprised of either native soils or residual silica) compacted
to 95 percent of the Standard Proctor maximum dry density and not containing excessive fibrous organic
materials, debris or other foreign materials may be designed utilizing an allowable net soil bearing
pressure of 2000 psf based on total foundation design load. To document the existing fill is compacted to
the required degree, density testing should be performed by an experienced engineering technician in the
existing fill at the foundation bearing level. If fill is found to be compacted to a lesser degree, it should
be undercut and replaced with properly compacted fill.
For a typical footing with an average bearing pressure of 2000 psf, we anticipate foundation settlement on
the order of one inch or less. Differential settlements between adjacent, similarly loaded columns
typically are assumed to be on the order of one half the total settlement, or about 1/2 inch.
17

Report of Preliminary Geotechnical Exploration & Earthen Embankment Analysis October 24, 2005
Proposed New Tank Farm Pad, Rockwell, North Carolina Final
BCE Project 05-133
If undercutting of existing fill is required, the foundation excavation should extend horizontally beyond
ZD
all sides of the footings for a.;distance equal to one-half of the vertical undercut below the footing bottom,
before sloping up.
In addition, an appropriate number of hand auger borings should be extended into the existing fill at
several locations to confirm quality of the fill and to check presence of possible unsuitable materials to a
depth of at least 4 ft below the foundation bearing level. If unsuitable materials or questionable quality
fill materials are encountered below the foundation bearing level, such materials should be undercut and
replaced with new engineered fill as stated in this report.
PAVEMENT AND FLOOR SLAB RECOMMENDATIONS
Pavements can likely be supported by the proo&olled on -site non -plastic residual soils as encountered by
borings and on properly -compacted engineered fill.. Pavement design was beyond the scope of this report.
We have not been provided with specific traffic loading and frequency information for a formal pavement
design, and have not performed laboratory or field CBR tests. However, pavement subgrade conditions
should be relatively good for properly compacted new fill. Typical pavement sections used in the vicinity
for similar sites are as follows.
A pavement section consisting of 3 inches of asphalt underlain by 6 inches of aggregate base course is typical
for the area and is recommended for pavement areas subject to automobile traffic loads. In driveways, truck
unloading and dumpster areas, We suggest an increased pavement section of 4 inches of asphalt and 8 inches
of aggregate base course to prolong pavement life where heavy truck loads may be concentrated. A concrete
pad about 6 inches thick is recommended for truck loads at a dumpster site and in areas of sharp radius
turning. The pavement surface should be sloped to promote rapid drainage of surface water. Asphalt and
aggregate base course should meet the requirements of the North Carolina Department of Transportation
Standard Specifications.
Based on the results of our exploration and our experience with the soils in the project vicinity, we
recommend rigid pavements and slabs be designed based on a modulus of subgrade reaction of between
110 and 125 pounds per cubic inch (pci), following proper subgrade preparation as discussed in the
section entitled SUBGRADE PREPARATION found in Appendix D of this report.
18

Report of Preliminary Geotechnical Exploration & Earthen Embankment Analysis October 24, 2005
Proposed New Tank Farm Pad, Rockwell, North Carolina Final
BCE Project 05-133
The grade slabs may not be soil supported, without proper steel reinforcement. We recommend that the
floor slab be .isolated from the foundation footings so differential settlement of the structure will not
induce shear stresses on the floor slab.
GLOBAL STABILITY ANALYSIS OF EXISTS tG BERM
The existing berm was judged to be unsuitable to remain as constructed due to the following:
1. Highly variable blowcounts and material types indicating that the berm was placed in an
uncontrolled manner,
2. Boulders and roots are present which can settle or decompose and provide pathways for water
migration,
3. The fill and native soil surface preparation is undocumented and may be not be successfully
installed
We recommend that the existing berm be re -built using approved engineered fill placed in a controlled
manner and monitored by BCE personnel. We examined a variety of berm geometries and would suggest
a geogrid-reinforced earthen berm with a l..:l slope on the interior and exterior slope faces.
We have utilized estimated shear strengths of the existing and proposed berm fill and foundation soils.
Based on our past experience with similar soils, we have estimated shear strength parameters for slope
stability analysis as shown on Figure 4.
The analysis was performed at the visually -determined maximum height section of the existing berm and
the ground surface elevations were obtained from a partial topographic site plan provided to BCE by Mid -
Atlantic Associates, P.A.
A computer program using the Modified Bishop method was used in the stability analysis. The safety
factors in the rotational analysis are defried as the ratio of resisting moments to the driving moments
tending to produce slope failure. The minimum recommended safety factor under long-term steady-state
loading conditions for earthen berms/embankments is 1.3. Results of our final slope stability analyses are
shown on Figure 4.
Our analysis included failure surfaces that penetrated the reinforced soil zone and deeper unreinforced
areas. Use of a reinforced earth embankment maximizes the useable surface area available for materials
storage or building construction.
19

Report of Preliminary Geotechnical Fxploration & Earthen Embankment Analysis October 24, 2005
Proposed New Tank Farm Pad, Rockwell, North Carolina Final
BCE Project 05-133
' SITE PREPARATION AND GR-DI G (BERNI)
The area of the proposed new berm should be dewatered as far in advance as is feasible using gravity
drains and pumping from periodically -spaced sumps. This should minimize the amount of undercutting
required and provide a stable base to begin construction of the berm fills.
Existing topsoil, vegetation, existing fill, alluvium and water softened residual soils and surface soils
containing organic matter or other deleterious materials should be stripped from within the proposed
reinforced berm areas. After stripping and rough excavation grading, we recommend that areas to-.
provide support for the reinforced fill and engineered fill be carefully inspected for soft surficial soils and
proofrolled with a 25 to 35-ton, four -wheeled, rubber -tired roller, a loaded dump truck or similar
approved equipment. The proofroller should make at least four passes over each location, with the last
two passes perpendicular to the first two (where feasible). Areas which wave, rut or deflect excessively
and continue to do so after several passes of the proofroller should be undercut to firmer soils or bridged
using geotextile fabrics and stone. The undercut areas should be backfilled in thin lifts with suitable
engineered fill materials. The proofrolling and undercutting operations should be carefully monitored by
an experienced engineering technician working under the direct supervision of the geotechnical engineer.
The surface of compacted subgrade soils can deteriorate and lose its support capabilities when exposed to
environmental changes and construction activity. Deterioration can occur in the form of freezing,
formation of erosion gullies, extreme drying, and exposure for a long period of time or rutting by
construction traffic. We recommend that the surfaces of slope subgrades that have deteriorated or
softened be proofrolled, scarified and recompacted (and additional fill placed, if necessary) immediately
prior to construction of the floor slab or pavement. Additionally, excavations through the subgrade soils
(such as utility trenches) should be properly backfilled in compacted lifts. Recompaction of subgrade
surfaces and compaction of backfill should be checked with a sufficient number of density tests to
determine if adequate compaction is being achieved.
The fill slope, as presently envisioned, will be constructed over a relatively shallow existing slope. The
new reinforced slope should be horizontally benched at least every 2 ft in elevation to "key" the
compacted materials into the slope.
20

Report of Preliminary Geotechnical Exploration & Earthen Embankment Analysis October 24, 2005
Proposed New Tank Farm Pad, Rockwell, North Carolina Final
BCE Project 05-133
Based on our visual examination, limited laboratory classification and compaction testing and experience
with similar type soils, the on -site residual soil and existing fill is generally suitable for use as engineered i
fill. We do not recommend using the waste silica product as backfill in the berm if the berm is reinforced
with geogrids (due to potential unpredictable chemical reactions as well as erodability). In general, soils
containing more than 5 percent (by weight) fibrous organic materials or having a Plasticity Index (PI)
greater than 30 (less than 15 is preferable) should not be used for fill.
General Site Preparation Notes
Natural ground is comprised of relatively permeable silt and sand overlain by relatively impermeable
clays and clayey silts. During most construction this layering becomes inverted by peeling off the upper
clays and placing them in deeper fills. This process leaves only permeable silt and sand available to
complete the fine grading. Unfortunately, water readily infiltrates this fill mass resulting in degradation
of the support capability of the fill which can lead to differential settlement and foundation distress. We
recommend that finish grading permit the placement of about 12 inches of cohesive soil (clayey silt and/
or clays) to form a relatively impermeable "cap". The capping layer minimizes infiltration of surface
water and minimizes the potential for pad degradation from water or other liquid chemicals.
The edge of the engineered fill should extend horizontally beyond the outside edge of the building
foundations at least 10 ft or a distance equivalent to the height of fill to be placed,, whichever is greater,
before sloping. The outer edge of fill should be at least 5 ft beyond paved areas. We have not performed
any laboratory triaxial shear tests for slope stability calculations, but our experience suggests that
permanent cut and fill non -reinforced slopes placed on a suitable foundation should be constructed at 2:1
(horizontal to vertical) and 2.5:1, respectively, or flatter. Fill slopes should be adequately compacted.
Cut and fill slope surfaces should be protected from erosion by grassing or other means.
The use of an erosion control blanket is recommended for the establishment of vegetation on slopes. We
recommend the seeding of the slope with drought -resistant grasses such as weeping lovegrass. Weeping
lovegrass is a perennial bunchgrass with a shallow and extensive root system that is used extensively for
erosion control on low -fertility soils. Other vegetation types may be better suited to the pH of the site
soils.
21

Report of Preliminary Geotechnical Exploration & Earthen Embankment Analysis October 24, 2005
Proposed New Tank Farm Pad, Rockwell, North Carolina Final
BCE Project 05-133
Modification of drainage entering the existing fill pad/containment area to divert surface water and
drainage water away would benefit the performance of the reinforced earth slope. This would likely
include a temporary diversion ditch located between the rail line, the waste lagoons and the fill
pad/containment area. Diversion of any underground utilities around the perimeter of the containment
area is also recommended.
BCE further recommends that a technician or staff engineer be retained during construction of the
reinforced earthen berm to monitor the construction and assist in field decisions regarding the various
aspects of reinforced earth slope installation.
LEUITATIONS OF ANALYSIS
Our engineering analysis of the proposed berm does not constitute an engineering design drawing or
specification for construction purposes. Our analysis and recommendations can readily be converted into
construction -ready drawings by a civil engineering/design firm. Our scope was to evaluate the feasibility
of the proposed berm and evaluate. the condition/future use of the existing berm.
Our evaluation of foundation and slab support conditions assumes that no significant chemical
interactions occur during the expected lifetime of the tank farm structures. Chemical interactions may
produce unpredictable results which may change or alter the engineering properties of the foundation
materials. BCE did not encounter any data suggesting any detrimental changes that might occur with the
types of materials encountered by the borings on the site nor have we experienced any detrimental
changes on other chemical plant facilities. Rare instances are documented where chemical introduction
caused settlement of foundations due to altering of some of the natural soil components. Chemical
interaction research was.beyond the scope of this geotechnical exploration.
Also, BCE has not performed soil corrosivity testing to determine the reactions of concrete and iron/steel
structures with the residual silica or silica blends. The native soils are not anticipated to be more
corrosive to steel/iron or concrete than typical residual soils in the vicinity of the site. If the concrete and
iron/steel structures are set upon native soils or fills consisting of native soils then the risk of corrosion
should be mitigated.
22

Report of Preliminary Geotechnical Exploration & Earthen Embankment Analysis October 24, 2005
Proposed New Tank Farm Pad, Rockwell, North Carolina Final
BCE Project 05-133
CONSTRUCTION SCHEDULE. C ONSIDERATIONS
The native fine-grained site soils and the residual silica fills are moisture sensitive and will likely present
difficulties during proofrolling or may not be easily useable for engineered fill in the wetter seasons. If
possible, construction activities should be scheduled for the drier periods during the year.
REVIEW OF GRADING PLANS
When grading plans for the proposed project are prepared, the plans should be reviewed by BCE to assure
compliance with recommendations presented in this report. The need for additional subsurface
exploration or advice can be determined by the review.
STANDARD OF CARE
Our evaluation of the subject site has been based on our current understanding of site conditions, project
information provided to us, our observations, and data obtained from our exploration. If the project
information is incorrect or if project objectives are changed, please contact us so that our
recommendations can be reviewed. In addition, BCE should be provided with copies of grading/erosion
control plans for review. The discovery of any site or subsurface condition during construction which
deviate from data outlined in this report should be reported to us for our re-evaluation. The assessment of
site environmental conditions or the presence of pollutants in the soil, rock and groundwater of the site
was beyond the scope of this exploration. If this report is unclear or presents conflicting
recommendations, BCE should be notified promptly.
The analysis, conclusions, and recommendations submitted in this report are based on the exploration
previously outlined and the data collected at the points shown on the attached boring location plan. This
report does not reflect specific variations that may occur between test locations. The borings were located
where site conditions permitted and where it is believed representative conditions occur, but the full
nature and extent of variations between borings and of subsurface conditions not encountered by any
boring may not become evident until the course of construction. If significant variations become evident
at any time before or during the course of construction, it will be necessary to make a re-evaluation of the
conclusions and recommendations of this report and further exploration, observation, and/or testing may
be required.
23

Report of Preliminary Geotechnical Exploration & Earthen Embankment Analysis October 24, 2005
Proposed New Tank Farm Pad, Rockwell, North Carolina Final
BCE Project 05-133
;This report has been prepared in accordance with generally accepted standard soil and foundation '
engineering practices and makes no other warranties, either expressed or implied, as to the professional
advice under the terms of our agreement and included in this report. The recommendations contained
herein are made with the understanding that the contract documents between the owner and foundation or
earthwork contractor or between the owner and the general contractor and the caisson, foundation,
excavating and earthwork subcontractors, if any, shall require that the contractor certify that all work in
connection with foundations, piles, caissons, compacted fills and other elements of the foundation or
other support components are in place at the locations, with proper dimensions and plumb, as shown on
the plans and specifications for the project.
Further, it is understood the contract documents will specify that the contractor will, upon becoming
aware of apparent or latent subsurface conditions differing from those disclosed by the original
Geotechnical Exploration & Retained Earth Analysis work, promptly notify the owner, both verbally to
permit immediate verification of the change, and in writing, as to the nature and extent of the differing
conditions and that no claim by the contractor for any conditions differing from those anticipated in the
plans and specifications and disclosed by the soil studies will be allowed under the contract unless the
contractor has so notified the owner both verbally and in writing, as required above, of such changed
conditions. The owner will, in turn, promptly notify this firm of the existence of such unanticipated
conditions and will authorize such further investigation as may be required to properly evaluate these
conditions.
Further, it is understood that any specific recommendations made in this report as to on -site construction
review by this firm will be authorized and funds and facilities for such review will be provided at the
times recommended if we are to be held responsible for the design recommendations.
01H

Report of Preliminary Geotechnical Exploration & Earthen Embankment Analysis
Proposed New Tank Farm Pad, Rockwell, North Carolina
BCE Project 05-133
October 24, 2005
Final
i
APPENDIX
z
Appendices for Subsurface Exploration
Tables Table 1, Summary of Laboratory Test Data
Appendix A Site Location Plan
Boring Location Plan
Generalized Subsurface Profile
Analysis of Reinforced Slope — Elevation View
Appendix B Soil Test Boring Records
Unified Soil Classification
Reference Notes for Boring Logs and Profiles
Appendix C Regional Geology, Soils and Groundwater
Appendix D Recommended Construction Practices
Appendix E Laboratory Data Reports
Procedures Regarding Field Logs, Laboratory
Data Sheets and Samples
Appendix F Definitions & Terminology
Appendix G Project Personnel Resumes
4
25

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Alchem, Inc.
Rockwell, North Carolina
Approximate Scale, Ft. BCE Project # 05-133
Date: 10/24/05 1 Drawn By: NC I Scale: Shown I Figure 2

10/2005 12:16 9108435789
PAGE 01
Road
ngs, NC 28
4843-2i21--
"Ct
October 10, 2005
ALCHEM9 1_N__co
and M AW-W n
8i3s Red Road
RcckvvQ, NC 28IL38
TeL [phone]�
Ms. Ellen Huffman
l tnvironme w Specwitsi II
DMSION OF WATER QUALM
Aquifer Pwtwdon SeWon
Mooresville Regional Office
610 East Center Sheet, Suite 301
Mooresville, NC 29115
Dear Ms. Huffman;
We have your letter about the violations at Rockwell, NC. We are sorry that this has occurred. We are doit
everything that we can to try and get this facility so that there are not any more problems.
I can assure you that we are committing the time and money to contact any problems here. I do not think yi
will see any of these problems at all in the future. I have numbered each of these items and I am responding:
1. At the time we had to put the Sand in a pile in the middle of the Lagoon. We had apparent
received some recent rain at that time that had caused the sand to spread and be less than 2 feet fm
the top. We have corrected this and expect no further problems.
2. We wem not aware that we could not put some concrete picces in this area. We were simF
unaware that this could be a problem. As best as we know all of the foreign objects are removed.
3. Wayne Axye is working to make certain that the ph of all of these aollectiou areas have a ph abo
6.0. To the best of my knowledge this has now been cortwted.
4. & S. We are having Boyle Engineering and James T. Hill Surveyors working with us on a ply I
both of these items. We have worked with both companies for several months to get the informa$-
that we need to give you a report.
Our new pamAt wmains under appeal. Please let me tell you that we are taring to completely comply with
of the conditions and obligations in both the old and new permit, Please call me if you have any questions.
Best regards,
ALCHEK INC.
Randall Alt ,
Sales Contact
v11

Subject: Re: your fax
From: "Randall" <[e-mail]>
Date: Mon, 10 Oct 2005 15:10:57 -0400
To: "Ellen Huffman" <[e-mail]>
i will do. thank you.
----- Original Message -----
From: "Ellen Huffman" <[e-mail]>
To: "Randall Andrews ALCHEM" <[e-mail]>
Cc: "andrew pitner" <[e-mail]>; "Peggy Finley"
<[e-mail]>; "DAVID GOODRICH" <[e-mail]>
Sent: Monday; October 10, 2005 2:00 PM
Subject: your fax
Hello Randall,
I received a fax of your letter (in response to the latest NOV), today
10/10/05. The fax did not come through very well. Please mail your
response to our office at the address below. Also, please include the
names & phone numbers of the folks at Boyle and at Hill Surveyors who
are working with you to comply with your permit and a time line for when
they plan to furnish information to you regarding your permit.
Thank you,
Ellen
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]
1 of 1 10/10/2005 3:13 PM

ALCHEM
Subject: ALCHEM cmail.net>
Frown: Ellen Huffman <Ellen.Huffman@n
Date: Fri, 05 Aug 2005 11:16:29 -0400
To: Shannon Thornburg <[e-mail]>
CC: Kim Colson <[e-mail]>, DAVID GOODRICH
<[e-mail]>, Wes Bell <[e-mail]>, andrew pitner
<[e-mail]>, Peggy Finley <[e-mail]>
Hello all, who was there to
I inspected ALCHEM yesterday with Wes Bell, MRO, Surface Water,
check on the stream restoration efforts.
Below is what I observed. ears
Lagoon #1 was so full of bauxite residuals (with a little H20) that it
that the last rain pushed the residuals to the low end of the berm and p
topped the berm and drained (thankfully) to lagoon #2. There is no freeboard
space. I have told Wayne that this bauxite needs to be removed immediately to
create some sort of freeboard. The level indicators
ith the for transit that lagoons were
erea gauge
installed incorrectly. Wayne told the guy w
in this corner
this lagoon
eachand tlagoonhat rnhener oce,tthe problem stated above.hat lagoon. Re did not Wayne
gauges at thePo
int insaid that he would fix this asap.
The pH in all three lagoons and the stormwater lagoon is as follows:
lagoon #1- 1.13. lagoon #2- 1.09 and 1.2. Lagoon #3- 2.5. the stormwater
basin- 2.12 and 2.01.
This indicates that the wastewater recycle system is not being (has not been)
operated properly (for a very long time) to remove the sulfuric acid and raise the
PH to 6.0 as stated in the application from January 1986.
The ever growing berm, is now approximately + 20' in places (hmmm... land
quality mey need to get involved) and the credibility is questionable. I walked
the berm and saw all sorts of cracks, sinks, erosion, etc.
ALCHEM has placed what appears to be construction debris (huge cement slabs
with rebar sticking out) in the bauxite fill area. I informed Wayne and Randall
that only bauxite was permitted to be disposed in this area and the debris is to
be removed asap.
All of this and more! I would appreciate any guidance from Raleigh as to how
to proceed with this. Should I NOV/ROE now or wait another 30 days for the new
permit to become permanent?
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]
1of1
8/5/2005 11:30 AM

■ Complete items 1, 2, and 3. Also complete A. Signa ure
item 4 if Restricted Delivery is desired. ! ❑ Ngent
■ Print your name and address on the reverse X / /.y ❑ Addressee i
so that we can return the card to you.
I B. Receiv by (Printed Nam ■ Attach this card to the back of the mailpiece, C. Date of D 'very ;see t
qi
or on the front if space permits. ,.r "�"�
rery !
1. Article Addressed to: D. Is delivery dress d ieren �t)n 1? ❑ Yes
If YES, ter delivery address, • e c ❑ No —+-f
00
-AUGHEM, Inc �®
_&135�Red Rd.
I 'Rack yell NC 28138 3. Service,
rtifle ❑ Expre y �i
❑ Registered Otm Receipt for Merchandise
❑ Insured Mail ❑ C.O.D. Ise
4. Restricted Delivery? (Extra Fee) ❑ Yes
2. Article Number;
(Transfer from service label) ;; 710 Q 4 p 7 5 0 p 0 Q' 2 5 516 6.8 6 8 --
Ps Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540 _'

Innspection
Permit #-WQ0002702
Rowan County
August 4, 2005
Is a follow-up inspection necessary X yes no
Inspector Name/Title Ellen Huffman /Environmental Specialist I1
Telephone No. 704/663-1699 Fax No. 704/663-6040
Date of Inspection August 4, 2005
T
Activated Sludge Spray, low rate
Activated Sludge Spray, high rate
Activated Sludge Drip, low rate
Lagoon Spray, low rate
Reuse (Golf Courses)
Recycle /Reuse
Single Family Spray, low rate
Single Family Drip
X Other- This facility is a process water recycle system. The permittee also has a non -
discharge bauxite re -use permit (WQ0016338) which is currently in review.
Treatment
Yes Are treatment facilities consistent with those outlined in the current permit?
No Do all treatment units appear to be operational? If no, note below.
Pg 2
The pH in the lagoons are as follows:
lagoon 41- 1.13. lagoon #2- 1.09 and 1.2. Lagoon #3- 2.5.
This indicates that the wastewater recycle system is not keeping the washwater at a pH of 6 as
required in the new permit, condition # 13.
Debris in fill area
stormwater and berm area

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. Kimek, P.E. Director
4&17�qhw'A
NCDENR
NON -DISCHARGE COMPLIANCE INSPECTION
GENERAL INFORMATION
City/Owner ALCHEM, Inc.
Permit # WQ 0002702
Issuance Date 12-28-2004
If applicable SOC Issuance Date N/A
Permittee Contact Wayne Drye
Alt. Permittee Contact Randall Andrews
ORC N/A
24hr Contact Name
Reason for Inspection
X ROUTINE COMPLAINT
County rowan
Expiration Date 11-30-2009
Expiration Date
Telephone No. 704/279-7908
Telephone No. 910/843-2121
B/U ORC N/A
Telephone No.
FOLLOW-UP OTHER
Type of inspection
Collection System TSpray Irrigation _Drip Irrigation Sludge X Other
Inspection Summary: (additional comments may be included on attached pages)
Inspection on August 4, 2005, Accompanied by Wes Bell, MRO, Surface Water, who was there to
check on the stream restoration efforts form the enforcement action May 2003.
At the time of this inspection, Lagoon #1 was so full of bauxite residuals (with very little H20) that it
appears that the last rain pushed the residuals to the low end of the lagoon, topped the berm and drained
(thankfully) to lagoon #2. There is no freeboard. space. Wayne Drye, onsite manager, was told that this
bauxite needs to be removed immediately to create some sort of freeboard.
The level indicators for the lagoons were not installed correctly at the lowest point of the berm of each
lagoon. The pH in all three lagoons and the stormwater lagoon is as follows:
lagoon #1- 1.13. lagoon #2- 1.09 and 1.2. Lagoon #3- 2.5. the stormwater basin- 2.12 and 2.01.
This indicates that the wastewater recycle system is not keeping the washwater at a pH of 6 as required
in permit condition # 13. The berm appears to be > 20 feet in places and the credibility is questionable.
There were indications of cracks, sinks, erosion, etc.
ALCHEM has placed what appears to be construction debris (huge cement slabs with rebar sticking out)
in the bauxite fill area. Mr. Drye and Mr. Andrews wer informed that only bauxite was permitted to be
disposed in the bauxite fill area and the debris needs to be removed asap. It was noted at the time of
inspection that the City water line had been moved as required in the permit (item 19).

ALUNtM '9
Page 2 of 2
September 20, 2005 y -
® Permit condition 14 requires you to submit a site -life estimate for the fill area within 90 days of issuance of the
permit. The permit was issued December 28, 2004. To date, this information has not been received.
O Permit condition 15 requires you to submit a long-range plan for future residuals disposal, including a timetable for
implementation within 90 days of issuance. The permit was issued December 28, 2004. To date; this information
has not been received.
A follow up visit conducted on August 23, 2005, reflected the work that was done after the last inspection,
including removal of unsuitable debris from the fill area and bauxite removal from lagoon #1 to create freeboard. It
was also noted that freeboard indicators were installed; however, they were not correctly sited at the lowest point on
the berm of each lagoon. It appeares that ALCHEM is in the process of cleaning out lagoon number 3. The same
requirements for the cleaning of lagoons 1 & 2 (permit conditions 16 & 17) should also apply for lagoon number 3.
The Mooresville Regional Office is considering 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. In the absence of any justification, the Regional Office will
recommend that an enforcement action be taken against your facility. Be advised that North Carolina General
Statutes now provide for penalties of up to $25,000 per dray per violation as well as criminal penalties for
violations of state environmental laves and regulations.
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.
Mooresville Region
Aquifer Protection Supervisor
Attachment — 08/04/2005 inspection, report.
cc: Non -Discharge Compliance / Enforcement Unit
Non -Discharge Permitting Unit, Shannon Mohr Thornburg
Mooresville Regional Office, Ellen Huffman
Central Files

vvr,i`c Michael F. Easley, Governor
�� yQ William G. Ross Jr., Secretary
, G North Carolina Department of Environment and Natural Resources
s
�✓iu
3 r Alan W. Klimek, P.E. Director
_ Division of Water Quality
AQUIFER PROTECTION SECTION
September 20, 2005
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Randall Andrews, Sales Manager
ALCHEM, Inc.
2042 Buie Philadelphus Road
Red Springs, NC 28377
and
ALCHEM, Inc.
8135 Red Road
Rockwell, NC 28138
Subject: Notice of Violation/ Notice of
Recommendation for Enforcement
NOV No. NOV-2005-PC-0226
Violation of permit conditions of Non -discharge
permit No. WQ0002702
Industrial Recycle Bauxite Process
Rowan County
Dear Mr. Andrews,
Chapter 143, North Carolina General Statutes, authorizes and directs the Environmental Management
Commission of the Department of Environment and Natural Resources to protect and preserve the water and air
resources of the State. The Division of Water Quality (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.
A permit inspection was conducted by Ms. Ellen Huffman, Aquifer Protection Section, and accompanied by Mr.
Wes Bell, Surface Water Protection, on August 4, 2005. Ms. Huffman noted several violations of the subject permit
during this inspection. These violations include:
® Permit condition 10 requires a freeboard in each lagoon of no less than two (2) feet at any time. Free board of < 2
feet was noted for lagoon number 1. At the time of the inspection, lagoon number 1 was full of bauxite leaving no
freeboard available in case of a rain event.
Various types of construction debris, including old piping, concrete, and rebar, were visible in the bauxite fill area.
This permit is for bauxite fill only.
® Permit condition 13 requires the recycle system water to be kept at a pH of not less than 6 Standard Units as it
leaves the wash area and goes into the storage lagoon. The pH of all three lagoons (recycle water), were less than
6 Standard Units. The pH in all three lagoons were < 3 SUs. The permit writing section of the Aquifer Protection
Section is aware that staff is currently reviewing this condition per your faxed request dated August 15, 2005.
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.ne.us

9 ..V4�.
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Water Quality Section
919 North Main Street
Mooresville, North Carolina 28115
REPORT OF: Site inspection of lagoons & creek.
DATE OF INVESTIGATION: August 4, 2005
INVESTIGATED BY: Ellen Huffinan, Wes Bell TIME SPENT: 3 hours
PHYSICAL LOCATION:
MAILING ADDRESS:
8135 Red Road
Rockwell, NC 28138
Mr. Wayne Drye
8135 Red Rd.
Rockwell, NC 28138
TELEPHONE #: [phone]
PERSONS CONTACTED: Wayne Drye
REASON FOR VISIT: Confirm pH readings in each lagoon and stormwater and look at stream
restoration efforts.
COPIES TO: ALCHEM, Inc., as an attachment to an enforcement action.
REPORT: On August 4, 2005, Wes Bell and Ellen Huffman, MRO, visited the ALCHEM facility and
found that all the lagoons had low pH readings (1.05 to 2.15). Also noted that lagoon #1 was completely
full (no freeboard) and had evidence of overtopping (bauxite sand washed over lagoon edge) during a
recent rain event. Construction debris was found in the -residuals fill area.

Re: ALCHEM
Subject: Re: ALCHEM
From: Kim Colson <[e-mail]>
Date: Mon, 08 Aug 2005 08:13:10 -0400
To: Ellen Hoffman <[e-mail]>
CC: Shannon Thornburg <[e-mail]>, DAVID GOODRICH
<DAVID.GG®[e-mail]>, Wes Bell <Wes.Eella@n? cmaiLnet>, andrew pitner
<andrew.pitner@ncmaiLnet>, Peggy Finley <[e-mail]>
FYI - The permit apeal was dismissed will send a copy soon. Do those pH levels
push this waste into the hazardous category? It seems like I remember that
anything less than 2 is haz. waste. KC
Ellen Huffman wrote;
Hello all,
I inspected ALCHEM yesterday with Wes Bell, MRO, Surface Water, who was there
to check on the stream restoration efforts.
Below is what I observed.
Lagoon #1 was so full of bauxite residuals (with a little H20) that it
appears that the last rain pushed the residuals to the low end of the berm and
probably topped the berm and drained (thankfully) to lagoon #2. There is no
freeboard space. I have told Wayne that this bauxite needs to be removed
immediately to create some sort of freeboard. The level indicators for the
lagoons were installed incorrectly. Wayne told the guy with the transit that
he wanted a gauge in this corner of this lagoon and that corner of that lagoon.
He did not place the gauges at the lowest point in each lagoon, hence, the
problem stated above. Wayne said that he would fix this asap.
The pH in all three lagoons and the stormwater lagoon is as follows:
lagoon #1- 1.13. lagoon #2- 1.09 and 1.2. Lagoon #3- 2.5. the stormwater
basin- 2.12 and 2.01.
This indicates that the wastewater recycle system is not being (has not been)
operated properly (for a very long time) to remove the sulfuric acid and raise
the pH to 6.0 as stated in the application from January 1986.
The ever growing berm, is now approximately + 20' in places (hmmm... land
quality mey need to get involved) and the credibility is questionable. I walked
the berm and saw all sorts of cracks, sinks, erosion, etc.
ALCHEM has placed what appears to be construction debris (huge cement slabs
with rebar sticking out) in the bauxite fill area. I informed Wayne and Randall
that only bauxite was permitted to be disposed in this area and the debris is
to be removed asap.
All of this and more! I would appreciate any guidance from Raleigh as to
how to proceed with this. Should I NOV/ROE now or wait another 30 days for the
new permit to become permanent?
Kim Colson <kim.colson(Mncmail.net>
1 of 1 9/22/2005 4:12 PM

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Deparonent of Environment and Natural Resources
Alan W. Klimek, P. E., Director
Division of Water Quality
June 21, 2005
Mr. Wayne Drye, Plant Manager
ALCHEM, Inc.
8135 Red Road
Rockwell, North Carolina 28138
Subject: Follow-up Investigations
. ALCHEM, Inc./Red Road Facility
Rowan County, N.C.
Dear Mr. Drye:
Enclosed please find a copy, of a follow up Investigation Report.for the investigations
conducted on April 7, 2005 and May 27, 2005 by Mr. Wes Bell of this office. The follow-up
investigations were.performed to assess ALCHEM, Inc.'s progress with the on -site remedial
activities and the condition of the Unnamed Tributary to Second Creek (tributary).
ALCHEM, Inc.'s personnel have continued the required remedial activities within the
forested areas on the business site. The condition of the tributary continues to improve due to the
progress of the on -site remedial activities. This office is concerned with the consistently low pHs
measured within the stormwater diversion ditch adjacent to the railroad tracks and upgradient of
the residual storage area. In addition, there are concerns with stormwater contamination at the
bauxite ore unloading station (adjacent to the railroad tracks).
It is requested that a written response be submitted to this office by July 12.2005
addressing the facility's actions in determining the origin of the acidic pHs within the stormwater
diversion ditch and the measures taken to remediate the area. In addition, the response should
include the actions taken to prevent exposure of the residual bauxite ore (at the unloading
station) to the stormwater runoff entering this diversion ditch.
1 �" Carolina
Aatm=4
KC Division of Water Quality, Mooresville Regional Office, 610 East Center Avenue, Suite 301, Mooresville NC 28115 [phone] Customer Service

Mr. Wayne Drye
Page Two
June 21, 2005
Should you have questions, please do not hesitate to contact Mr. Bell or me at (704) 663-
1699.
Sincerely,
D. Rex Gleason, P.E.
Surface Water Protection Regional Supervisor
Attachments
cc: Rowan County Health Department
M

Mr. Wayne Drye
Page Two
June 21, 2005
Should you have questions, please do not hesitate to contact Mr. Bell or me at (704) 663-
1699.
Sincerely,
/D - P 1-4 )-& Z � -
D. Rex Gleason, P.E.
Surface Water Protection Regional Supervisor
Attachments
cc: Rowan County Health Department
M

' NORTH CAROLINA DEPARTMENT OF ENVIRONMENT
AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
SURFACE WATER PROTECTION UNIT
610 EAST CENTER AVENUE/SUITE 301
MOORESVILLE, NORTH CAROLINA 28115
REPORT OF: Follow-up Investigations
DATE OF INVESTIGATION: April 30, 2005 and May 27, 2005
INVESTIGATED BY: Wes Bell ',TIME SPENT: 9.0 hours
PLACE VISITED: ALCHEM, Inc.'s Business Site and Unnamed Tributary to Second Creek -
PHYSICAL LOCATION: Rockwell, Rowan County
RIVER BASIN: Yadkin -Pee. Dee
REASON FOR VISIT: Follow-up investigations to determine ALCHEM, Inc.'s remedial actions
and the condition of the Unnamed Tributary to Second Creek
COPIES TO: Rowan County Health Department
REPORT:
,On April 7, 2005 and May 27, 2005, Mr. Wes Bell of this office performed follow-up
investigations to verify ALCHEM, Inc.'s (ALCHEM) continued remedial activities within the
forested area and the condition of the unnamed tributary to Second Creek (tributary). In addition,
Mr. Bell measured the pH of the water in the stormwater drainage ditch (ditch) that was
constructed to divert all stormwater runoff around the residual storage area from the Red Road
drainage area. This stormwater diversion ditch disperses (sheet flows) the stormwater into the
forested area. No remedial activities have been performed on either of the private properties due
to the pending (or threatened) third party lawsuit. Mr. Bell met with Mr. Wayne Drye, Plant
Manager, during the April 7, 2005 site visit and with an ALCHEM employee during the May 27,
2005 site visit.
During the April 7, 2005 site visit, repairs had been made to the silt fence and a rock
mound that had been installed adjacent to the silt fence (entire length). ALCHEM personnel had
initiated the liming of the unremediated areas within the forested areas. Soil samples (including
the underlying soil, residual material, etc.) had also been collected and shipped to a lab for
analysis. The analyses revealed acidic pHs (ranged from 3.9 s.u. to 4.6 s.u.) that required lime
additions (neutralization) ranging from 2.0 tons - 6.6 tons per acre. Note: Only one ton of lime
per acre per year was recommended by the NCDA&CS Agronomic Division.
The pHs in the stormwater diversion ditch ranged from 3.53 s.u. to 4.01 s.u. The
stormwater draining into this ditch (Red Road drainage area) was measured at 6.07 s.u. The
unloading station for the sulfuric acid railcart was located directly above this ditch. No direct
evidence of an acid spill could be determined; however, ALCHEM personnel were advised to
investigate the origin of the acidic measurements and remediate the area. A large accumulation of
bauxite ore (at the unloading station) was observed within the drainage area of the stormwater

Complaint Investigation
Page Two
diversion ditch. Concerns regarding the potential runoff from the bauxite accumulation were
discussed. Note: No runoff was observed entering the ditch from this area during the
investigation.
The tributary's upstream pH was measured at 6.00 s.u. The pH measurements of the
tributary's section that flowed through the impacted areas ranged from 5.60 s.u. to 5.96 s.u.
Note: The investigation was performed during a rainfall event. Mr. Drye had indicated that the
facility had hired someone experienced in stream sampling to monitor the tributary's pH levels.
. During the May 27, 2005 site visit, it was noted that ALCHEM .personnel have continued
to make progress of liming the .unremediated areas within the forested areas. The pHs of the
stormwater drainage ditch, unnamed .tributary, lagoon, and ponded areas within the remediated
areas were measured. No flow was observed entering the stormwater diversion ditch; however,
the pHs of the two observed puddles ranged from 2.94 s.u. to 3.23 s.u. The ALCHEM personnel
had not determined the cause of the acidic pHs and no remedial actions had been initiated. In
addition, no actions had been taken to address the accumulations of the residual bauxite ore (at
the unloading station) within the drainage area of the stormwater diversion ditch. The pH of the
bauxite ore in a slurry form (combined with deionized water) was measured at 4.50 s.u.
The upstream sampling point was dry; however, stream flow was observed approximately
20 to 30 feet below the upstream sampling location. The pH was measured at 6.82 s.u. The pH
of the ponded areas adjacent to the silt fence/rock mound ranged from 6.17 sm. to 7.37 s.u. The
pH approximately 5 to 10 feet below the silt fence and remediated areas was measured at 6.40
s.u. The tributary's pH at the Medium Road culvert was measured at 4.30 s.u. The low pH
appeared to be attributed by the unremediated areas within the private properties. The pH of the
lagoon/stormwater basin for the residual storage area ranged from 2.94 s.u. to 3.23 s.u. The silt
fence'had become separated from the ground in several areas; however, no residual material was
observed in the tributary. The facility continues to monitor the tributary's pH (documentation
available) by the contracted personnel. Mr. Bell advised the ALCHEM personnel to continue
repairing the silt fence and initiateremedial activities surrounding the stormwater diversion ditch
adjacent to the sulfuric acid unloading station.
The ALCHEM staff were helpful and courteous during both investigations. Followup
investigations by this office should continue to verify the facility's remedial actions.

` Complaint Investigation
Page Two
diversion ditch. Concerns regarding the potential runoff from the bauxite accumulation were
discussed. Note: No runoff was observed entering the ditch from this area during the
investigation.
The tributary's upstream pH was measured at 6.00 s.u. The pH measurements of the
tributary's section that flowed through the impacted areas ranged from -5.60 s.u. to 5.96 s.u.
Note: The investigation was performed during a rainfall event. Mr. Drye had indicated that the
facility had hired someone experienced in stream sampling to monitor the tributary's pH levels.
.. During the May 27, 2005 site visit, it was noted that ALCHEM.personnel have continued
to make progress of liming the unremediated areas within the forested areas. The pHs of the
stormwater drainage ditch, unnamed tributary, lagoon, and ponded areas within the remediated
areas were measured. No flow was observed entering the stormwater diversion ditch; however,
the pHs of the two observed puddles ranged from 2.94 s.u. to 3.23 s.u. The ALCHEM personnel
had not determined the cause of the acidic pHs and no remedial actions had been initiated. in
addition, no actions had been taken to address the accumulations of the residual bauxite ore (at
the unloading station) within the drainage area of the stormwater diversion ditch. The pH of the
bauxite ore in a slurry form (combined with deionized water) was measured at 4.50 sm.
The upstream sampling point was dry; however, stream flow was observed approximately
20 to 30 feet below the upstream sampling location. The pH was measured at 6.82 s.u. The pH
of the ponded areas adjacent to the silt fence/rock mound ranged from 6.17 s.u. to 7.37 s.u. The
pH approximately 5 to 10 feet below the silt fence and remediated areas was measured at 6.40
s.u. The tributary's pH at the Medium Road culvert was measured at 4.30 s.u. The low pH _
appeared to be attributed by the unremediated areas within the private properties. The pH of the
lagoon/stormwater basin for the residual storage area ranged from 2.94 s.u. to 3.23 s.u. The silt
fence�had become separated from the ground in several areas; however, no residual material was
observed in the tributary. The facility continues to monitor the tributary's pH (documentation
available) by the contracted personnel. Mr. Bell advised the ALCHEM personnel to continue
.repairing the silt fence and initiate remedial activities surrounding the stormwater diversion ditch
adjacent -to the sulfuric acid unloading station.
The ALCHEM staff were helpful and courteous during both investigations. Follow-up
investigations by this office should continue to verify the facility's remedial actions.

02/11/2005 10:19 7042798418 ALCHEM INC PAGE 01
ALCHEM, INCP
Corporate Office Sales and Manufacturing
2042 Bvie Philadelphus Road 8135 Red Road
Red Springs, NC 28377 Rockwell, NC 28138
Tel. [phone] — Pax 910-W-5789 Tel. [phone] — Pax 704-279-8418
rfa(csemr.nel # [e-mail]
l
February 9, 2005
Mr, Rex Gleason
Water Quality Regional Supervisor
NCDENR
919 North Main Street
Mooresville, NC 28115
Dear Mr. Gleason:
l would like to inform you that we have taken the following steps at our facility.
1. We obtained soil sampling boxes from the local extension agent. We
sent in soil samples and asked that we be informed of the recommend
levels of Lime to add. We have already added agricultural Lime to the
soil in the affected area. We are constantly monitoring the ph of the
stream. The latest reading was in the area of ph 6.4 — 6.6. We will
continue to monitor the dry run ditch from our property.
2. We have contacted a tree expert at the county agents office. He will
be making a site visit next week and will then give us some
recommendations.
3. We have completely repaired the silt fence and put much larger stones
on it to hold it in place.
I will continue giving you reports of our progress,
Best regards,
ALCHEM, INC.
Wayne Dtye,
Plant Manager
A

ALCHEM, INC
8135 RED ROAD
ROCKWELL, NC 28138
704-279-7908 fax [phone]
[e-mail]
January 27, 2005
Mr. Wes Bell
Environmental Tech TV
NCDENR
Division of Water Quality
Mooresville Regional Office
610 East Center Ave. Suite 301
Mooresville, NC 28115
Dear Mr. Bell:
JUL 1 1 200'i .
s O TI N
Alchem staff has continued to perform repairs on the silt fence by pulling out the bottom skirt
and applying rip rap rock to it.
Alchem staff and an outside contractor removed a considerable amount of sand from the
upper area of Alchem property then applied approximately 40 tons of top soil and 3 tons of
lime. We then applied grass seed and fertilizer.
Alchem personnel have included the diversion ditch and the bauxite ore unloading station in
the clean up activities. The pH in the diversion ditch was 5.96 on 6-29-05. We have included
this area on our once per week sampling to monitor the pH levels.
Best regards,
ALCHEM, INC
Wayne Drye,
Plant Manager
pcd

w ot
01/27/2005 16:38 7042798418 ALCHEM INC PAGE 02
ALCHEM, INC
8135 RED ROAD
ROCKWELL, NC 28138
704-279-7908 fax [phone]
I)[e-mail]
January 27, 2005
Mr. D. Rex Gleason, P.E.
Surface Water Protection Regional Supervisor
NCDENR
Division of Water Quality
Surface Water Protection Unit
610 East Center Ave. Suite 301
Mooresville, NC 28115
Dear Mr. Gleason;
Alchem, Inc is very concerned about the impact of the runoff from Alchem property.
Alchem, Inc has removed sand from the stream and wooded areas using temporary personnel. Some of
the areas were not possible to enter with manual labor.
Alchem has hired Tara Group Construction to bring in heavy equipment to complete this clean up in a
quick and professional manner.
Alchem erraployees have applied Borne agricultural lime in some areas to neutralize the soil. We will
increase this effort.
The silt fence is very hard to maintain with fallen limbs and trees. Alchern is in the process now of
patting rip rap rock at the base of the silt fence and the silt fence will be observed more often.
'Mara Group has applied 3 feet to the berm around the entire residual storage perimeter in the last week and
very close to moving into the heavily wooded areas for clean up.
Alchem has contacted Rowan Community College to hire a student to do environmental checks, pH
testing, collect water samples, etc for Alchem.
Alchem, Inc personnel did pH testing every week since the last N.O.V. The pH reading was not as low as
Mr. Wes Bell reported.
1 expect to have this clean up completed by mid February weather penzritting.
if possible we would like to meet with you before you take any action on this.
Best regards,
ALCHEM, INC
> pX�e,okf
Wayne Drye,
Plaut Manager
pod

02/11/2005 10:19 7042798418 ALCHEM INC PAGE 01
ALCHEM, INC.
Corporate Office Sales and Manufacturing
2042 Buie Philadelphus Road 8135 Red Road
Red Springs, NC 28377 Rockwell, NC 28138
Tel. [phone] — Pax 910-843-5789 Tel. [phone] --- Fax [phone]
da(c)semr.nel [e-mail]
v
February 9, 2005
Mr, Rex Gleason
Water Quality Regional Supervisor
NCDENR
919 North Main Street
Mooresville, NC 28115
Dear Mr. Gleason:
I would like to inform you that we have taken the following steps at our facility.
1. We obtained soil sampling boxes from the local extension agent. We
sent in soil samples and asked that we be informed of the recommend
levels of Lime to add. We have already added agricultural Lime to the
soil in the affected area, We are constantly monitoring the ph of the
stream. The latest reading was in the area of ph 6-4 — 6.6. We will
continue to monitor the dry run ditch from our property.
2. We have contacted a tree expert at the county agents office, He will
be making a site visit next week and will then give us some
recommendations,
3. We have completely repaired the silt fence and put much larger stones
on it to hold it in place.
1 will continue giving you reports of our progress.
Best regards,
ALCHEM, INC.
Wayne Drye,
Plant Manager
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North C:nrohna r>cpartmcnl of Environmcni and Natural Fcsourccs
�' 1 .�_ , t- ;:-_•. ._' Alan W. i:hmck. V. E_ Dtrx—can
l Divtston o',N1atc: Qualm.
January 12, 2005
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Randall F. Andrews, President
ALCHEM, Inc.
2042 Buie Philadelphus Road
Red Springs, North Carolina 28377
Subject: Notice of Violation/Notice of
Recommendation for Enforcement
ALCHEM. Inc.
Violation of General Statute 143-215.1
Follow-up Investigation
Rowan County, N.C.
Tracking #: NOV-2005-SS-0001
Dear i&. Andrews:
Chapter 143, Article 21 of the North Carolina General Statutes (NCGS) authorizes and directs the
Environmental Management Commission of this Department to protect and preserve the water resources of
the State. The Division of Water Quality (DWQ) has the delegated authority to enforce adopted pollution
control rules and regulations.
Enclosed please find a copy of a follow-up Investigation Report for the investigations conducted
on December 30, 2004 and January 5, 2005 by Mr. Wes Bell. The follow-up investigations were
performed to assess ALCHEM, Inc.'s on -site remedial activities and the condition of the tributary to
Second Creek (tributary). As a result of these investigations, the following conditions were found in
violation of North Carolina General Statute (NCGS) 143-215.1 and 15A North Carolina Administrative
Code (NCAC) 2B .0211 (3)(g):
The acidic discharges into the unnamed tributary (UT) resulting from the
drainage through the unremediated wooded/riparian areas (on the
ALCHEM, Inc.'s property), had lowered the tributary's pH from 6.22 s.u.
(upstream) to 4.76 sx. (10 - 20 yards downstream of where the drainage
enters the UT). No evidence was observed to suggest that ALCHEM,
Inc. had continued remedial efforts (required in the settlement agreement)
within the wooded/riparian areas on the business site.
CIM
_Nor>nCarobna
'A'�'I*
N. C Division of Water Qualip•, Mooresville Regional Office, 610 East Cent.-r Avenue, Suite 301, Mooresville NC 28115 (704) 66=-1699 Cts-to n=7 Service
-8 —s-6748

Mr. Randall F. Andrews
January 12, 2005
Page Two
Please be advised that this report is being issued as a Notice of Violation (NOV) and Notice for
Recommendation for Enforcement (NRE) for the violations of NCGS 143-215.1, 15A NCAC 2B .0211
(3)(g), and the facility's failure to continue to remediate the wooded/riparian area located on the facility_ 's
property. Be advised that NCGS 143-215.6A provides for a civil penalty assessment of not more that
twenty-five thousand dollars ($25,000.00), or twenty-five thousand dollars ($25,000.00) per day when the
violation is of a continuing nature, against any person who fails to abide by the conditions of the permit
and who fails to apply for or to secure a permit required by NCGS 143-215.1. Penalties may also be
assessed for any damage to the surface waters of the State that may result from the unpermitted discharges.
This letter is also to advise you that this Office is considering sending a recommendation for
enforcement action to the Director of the Division of Water Quality for the acidic discharges into the
unnamed tributary to Second Creek, water quality stream standard violations (pH), and the facility's failure
to continue the cleanup on the unremediated areas on the facility's property. If you have an explanation for
the violations that you wish to present, please include same in the requested response. Your explanation
will be reviewed and if an enforcement action is still deemed appropriate, your explanation will be
forwarded to the Director along with the enforcement package for his consideration.
It is requested that you respond, in writing, within fifteen (15) days following receipt of this
Notice. The response should address the measures taken to immediately cease the acidic discharges
resulting from the drainage through the unremediated wooded/riparian areas, and the efforts to ensure
future discharges do not recur. In addition, a detailed plan should be included that specifies the
remediation activities utilized and the date of completion for the cleanup of the unremediated
wooded/riparianareas on the facility's property.
Should you have questions, please do not hesitate to contact Mr. Bell or me at [phone].
Sincerely,
D. Rex Gleason, P.E.
Surface Water Protection Regional Supervisor
I11141.1ll11G11 W
cc: Rowan County Health Department
Stormie Forte, Associate Attorney General
Wayne Drye, Plant Manager, ALCHEM, Inc.

01/27/2005 16:38 7042798418 ALCHEM INC PAGE 01
ALCHEM, INC.
8135 RED ROAD
ROCKWELL, NC 28138
704-279-7908 FAX: [phone]
polye balltel.net
FAX
TO: FROM:
Mr. D. Rex Gleason, P,E. Wayne Drye
FAX NUMBF,R: _ DATE:
1/27/2005
COMPANY: TOTAL NO. OF PAGES INCLUDING COVER:
NCDEN R 2
PHONE: NUMDUR:
RE:
Tracking #: NOV-2005-SS-001

NORTH CAROLINA DEPARTMENT OF ENVIRONMENT
AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
SURFACE WATER PROTECTION UNIT
610 EAST CENTER AVENUE/SUITE 301
MOORESVILLE, NORTH CAROLINA 28115
REPORT OF: Follow-up Investigations
DATE OF eiZc 30, 20+f4 ann005
INVESTIGATED BY: Wes Bell TIME SPENT: 6.0 hours
PLACE VISITED: Unnamed Tributary to Second Creek
PHYSICAL LOCATION: Rockwell, Rowan County
RIVER BASIN: Yadkin -Pee Dee
REASON FOR VISIT: Follow-up investigation to determine the condition of the unnamed
tributary to Second Creek
COPIES TO: Rowan County Health Department
On December 30, 2004 and January 5, 2005, Mr. Wes Bell of this office performed
follow-up investigations on the unnamed tributary to Second Creek (tributary) impacted by the
runoff from the ALCHEM, Inc.'s (ALCHEM) residual storage area. ALCHEM personnel have
made noticeable progress with the remediation of the tributary and surrounding areas; however,
the wooded/riparian areas on both private and ALCHEM properties remain covered (in several
locations) with the residual material. Due to a pending (or threatened) third party lawsuit,
ALCHEM was instructed (by their attorney) to cease their remedial efforts on the private
properties.
During both site visits, Mr. Bell observed a "rainbow sheen" on the water's surface and
an orange and white colored substrate throughout the tributary. The orange substrate and
"rainbow sheen" appeared to be caused by the natural microbial actions of iron bacteria.
However, no aquatic life was observed throughout the tributary.
ALCHEM personnel had previously installed a silt fence along the section of tributary
that runs through/adjacent to the facility's property. The silt fence was installed to prevent
additional residual runoff into the tributary. The bottom section of the silt fence was not properly
secured and the front and end sections were collapsed. Mr. Bell had previously discussed (via
telephone) with Mr. Wayne Drye, Plant Manager, similiar problems with the silt fence.
Mr. Bell observed pools of water adjacent to the silt fence that appeared to have
originated from the drainage of the woodediriparian areas on the ALCHEM property. The
drainage had channeled through the accumulated residuals of the unremediated areas in the
wooded/riparian areas and discharged into the tributary at three different locations. The pH of
the three discharges ranged from 3.12 s.u. to 3.31 s.u. prior to entering the tributary. Note: All

Complaint Investigation
Page Two
pH measurements were taken by Mr. Bell on January 5, 2005. The upstream pH ranged from
6.22 s.u. to 6.25 s.u. and the downstream pH (10 - 20 yards below the lowest drainage area) was
measured at 4.76 s.u. Additional downstream pH measurements were taken between the above -
noted sampling location and 15 - 25 yards upstream of the Medium Road culvert. These pH
levels ranged from 5.24 s.u. to 5.36 s.u. The increase in pH appeared to be influenced by the
buffering/dilution by spring water. The tributary's pH at the Medium Road culvert was 4.71 s.u.
The tributary's pH downstream of the culvert ranged from 4.53 s.u. to 5.30 s.u. The final
tributary pH value (5.30 s.u.) was taken approximately 35 - 45 yards downstream of the Medium
Road culvert Residual accumulations were also observed throughout this downstream section of
the tributary. No aquatic life was observed.
No additional residual runoff was observed from the residual storage area since the
construction of a berm around the entire residual storage perimeter. The pH of the stormwater
runoff collection basin (inside the berm) was measured at 3.57 s.u. Mr. Bell did not observe any
additional sediment accumulations in the tributary; however, a significant rain event could wash
the residual material (in the unremediated wooded/riparian areas) into the tributary due to the
poorly constructed/maintained silt fence. ALCHEM personnel should immediately initiate
cleanup activities on the unremediated areas on the facility's property (wooded/riparian areas).
In addition, the problems with the silt fence should be corrected to ensure additional residual
runoff does not occur.

r e(')Y CY )r' PRI 2
.\I-l'UYtNlcY C9tiNtai.\t,
State Of North Carolina
Dcpat'tment of Justice
R. O. Box 629
RALEIGH
27602-0(529
DATE: `o5
FACSIMILF, TRANSMITTAL SHEET
FAX NO:0
..r
FROM: —7:��22a - L
PHONE NO: [phone]
FAX NO: [phone]
SUBJECT:_40(akpy-)
NO. OF PAGES INWMING TRANSMITTAL SHEET
COMMENTS:
CONFIDENTIALITY NOTE: The information comaincd in this facsimile is legally privileged and confidential and is
intended only for the osc of the individual or entity named above. If the reader of this message is not the intended rccipient, you
arc hercby.notMed that any dissemination, distribution or copy of this information is strictly prohibited. If you have reeeivcd this
facsimile in error, please immediately notify us by telephone an return the original message to us at the address above by U.$.
postal service. Thank you.
ZO'd ZV:Il S0, T .add 99Z9-9IZ-6Z6:XE3 NOI103S QNIJI ' dMUM

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•
STATE OF NORTH CAROLINA
COUNTY OF ROWAN,
IN T1
ADMINIST]
p iG04 UAA -2 P 3: Sp o3
FILED
OFFICE OF
ALCHEM, INC., WAYNE D. DRYE, ADMI0ISTRAT1VE
HE)gRIMS
Petitioner, )
}
v, )
} SETTLEMENT AGREEMENT AND
NORTH CAROLINA DEPARTMENT OF WITHDRAWAL OF PETITION
ENVIRONMENT AND NATURAL )
RESOURCES, DIVISION OF WATER )
QUALITY, )
Respondent. )
The North Carolina Department of Environment and Natural Resources ("DENR"),
Respondent, and Petitioner, Alchem, Inc., Wayne D. Drye ("Petitioner"), hereby enter into this
Settlement Agreement ("Agreement") in order to amicably resolve matters in controversy as they
relate to the civil penalty assessment. This matter arose out of the assessment of civil penalties
and costs totaling five thousand nine hundred ninety-eight dollars and twenty-eight cents
($5,998.28, which includes three hundred ninety-eight dollars and twenty-eight cents ($398.28)
in enforcement costs), imposed upon Petitioner on August 18, 2003 for alleged violations of
North Carolina General Statutes § 143-215.1 er seq and Non -Discharge Permit WQ0016338.
DENR and the Petitioner have reached the following settlement agreement in this matter:
I . Petitioner will adhere to the following conditions:
a. Petitioner will submit a plan or schedule to remove sand and
other materials fiom a tributary to Second Creek and the
ZO'd Zt7:TT So, T .add . 99Z9-9TZ-6T6:XP_3 NOI103S GNU-1 '8 231UM

riparian areas of the two affected private properties adjacent
to A.lchem, Inc.;
b. Petitioner will submit a plan or schedule for removal of sand
and other materials deposited by Petitioner's facility to the
Mooresville Regional Office ofthe Division of Water Quality
within thirty (30) days of- ecution of tlus agreement.;
C. Petitioner shall remove sand and other materials from the
creek, creek - bank, and the areas where the deposits exist in
the forested area adjacent to the creek located on property
ownedbyAlchem, Inc, andthetwo affected private properties
adjacent to Alchem, Inc, in accordance with the plan or
schedule submitted.;
d. Petitioner shall submit written notice of completion of
removal of sand and other materials to the Mooresville
Regional Office of the Division of Water Quality within five
(5) days of said completion.
2. The Petitioner will pay a total of four thousand eight hundred seventy-eight
dollars and twenty-eight cents ($4,878.28 ("Settlement Amount"), calculated as follows: Total
Penalty S5,600.00 - 20% of penalty = 4 480.00 (80% of penalty) + investigative costs of
3$ 98.28 = $4,878.28) to DENR for settlement in the manner hereinafter described. The
Settlement Amount shall be made in the following manner: The Settlement Amount shall be
made in twenty-four (24) monthly payments. The first payment shall be due and payable on
�2-
20 'd 2b: ZZ S0, Z .add 99Z9-9ZL-6T6: x2J NOI103S QNUi l ' 2131dm

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0
March 1, 2004 in the amount of two hundred three dollars and thirty cents
payment thereafter shall be due and payable on the 18 day of each month c
the amount of two hundred three dollars and twenty-six cents ($203.26) totaling: $203.30 +
($203.26 x 23) $4,674.98 = $4,878.28_ The last payment shall be due and payable on or before
February 1, 2006.
3. The payments shall be by check made payable to the North Carolina Department
of Environment and Natural Resources (or to "DENR") at the following address_
Stonnie D. Forte, Esq.
Attorney General's Office
Environmental Protection Division
Post Office Box 629
Raleigh, NC 27602-0629
4. The breach of any condition of Paragraphs one (1), or two (2) by Petitioner Will
render due and payable the entire amount of the civil penalty assessment, including investigative
costs i.e., five thousand nine hundred ninety-eight dollars and twenty-eight cents ($5,998.28).
5. Petitioner and DENR expressly stipulate and acknowledge that, by entering into
this Agreement, Petitioner neither admits nor denies the allegations contained in the Findings and
Decisions and Assessment of Civil penalties. However, upon a breach of paragraph one (1) or
two (2) of this Agreement, by Petitioner, the sole issue in any action by DENR is to collect the
Entire amount of the civil penalty assessment including investigative costs i.e., five thousand
nine hundred ninety-eight dollars and twenty-eight cents ($5,998.28)'in accordance with the
terms of paragraph four (4) above and will be limited to the Petitioner's compliance with the
terms of this Agreement.
-3-
b0'd S�tr:TT SO, T .add 99Z9-9TZ-6T6:Xp3 NOI103S GNU-1 '8 2131dM

Z agrees to accept payments totaling four thousand eight hundred seventy -
my -eight cents ($4,878.28), in complete satisfaction of the civil penalty
assessment subject to the terms of this Agreement.
6. Nothing in this Agreement shall restrict any right of DENR to take any
enforcement action against Petitioner for any future violations; i.e., violations occurring after
May 8, 2003.
7. The DENR and Petitioner agree that, for purposes of any future bankruptcy
proceeding, this Agreement is not intended as, nor shall it be deemed to constitute, a novation of
any claims asserted by DENR against Petitioner. Petitioner further agrees that all sums payable
to DENR pursuant to this Agreement are nondischargeable in bankruptcy under 11 U.S.G. § 523.
Nothing in this Agreement releases any nondischargeability claims that may be asserted by
10 DENR in any bankruptcy proceeding, and nothing in this Agreement shall be deemed a waiver of
the DENR 's right to rely on the nature of any claim or debt released in this Agreement to show
that the claim or debt is nondischargeable.
S. This Agreement shall be binding upon the parties and is entered into knowingly,
intelligently, and voluntarily.
SO 'd ib: TT SO, T idd 99Z9-9TL-6%: xE3 NOI 33S QNU� 2 �HHM

•
WITHDRAWAL OF PETITION
9. Entry of this Agreement serve as Petitioner's Withdrawal
ConLes[ed Case Hearing Without Prejudice in these matters. The parties agree this matter is
concluded and that no further proceedings are needed or required to resolve the contested case.
This the jj!_ day of February 2004.
ROY COOPER
Attorney General
By: �—
?77i:ie D. Forte
Associate Attorney General
N. C. Department of Justice
Environmental Division
9001 Mail Service Center
Raleigh, NC 27699-9001
[phone]
[phone]/Fax
FOR THE DIVISION OF WATER PETITIONER.
QUALITY
' , "`�k Jug
Alan Klimek, Director of Alehem, Inc., Wayne D. Drye
Water Quality
3
zLc-)Date:
Date:
D. Rex Gleason, Mooresville Randall F. Andrews, Consultant
Regional Supervisor Alchem, Inc.
Date: � ,e - Date: ` �1 �00
i L
-S-
S8 ?131dm
90 -d 2t7: TT SO. T .add 99Z9-9TZ-6T6: xe3 NOI103S GNU

DIVISION OF WATER QUALITY
'ORCEMENT CASE ASSESSMENT FACTORS
Type: (PC/SS) Permit Condition/Stream Standard Violations
Violator: ALCHEM, Inc.
Address: 8135 Red Road
Rockwell; North Carolina 28135
Registered Agent: Mr. Randall F. Andrews, President
Address: 2042 Buie Philadelphus Road
Red Springs, North Carolina 28377
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 violations:
Impacts to the tributary to Second Creek and adjacent private properties occurred from the
runoff of the residuals and the sediment basin discharges from the ALCHEM, Inc. residual
storage site. The two private properties (riparian areas) contained large accumulations of
residuals (sandbar appearance) in several locations with measurements up to twelve (12)
inches. The residuals had impacted up to 500 linear feet of stream. Specifically, twelve (12)
to twenty-four (24) inches of deposition was measured throughout the impacted portion of
the tributary. The tributary's pH was nearly 100 times. more acidic than the upstream
(unaffected) section due to the deposited residuals and the sediment basin discharges.
2. The duration and gravity of the violations:
The discharges appeared to have occurred over several months.
3. The effect on ground or surface water quantity or quality or on air quality:
The riparian areas/private properties had residual deposition up to twelve (12) inches and the
stream had residual deposition up to twenty-four (24) inches. As such, no aquatic life was
found due to the stream being covered by.the runoff of the residuals. The impacted portion of
the tributary was nearly 100 times more acidic (than the upstream/unaffected portion) due to
the residual deposition and sediment basin discharges.
4. The cost of rectifying the damage:
According to ALCHEM, Inc.'s response letter, the cleanup activities were estimated at
$68,250.00. The cleanup activities incorporated by ALCHEM, Inc. have not been
completed; therefore, the official amount could not be determined.

RI
7.
9
The amount of money saved by noncompliance:
None could be determined; however, money could have been saved by facility's failure to
incorporate the appropriate erosion control measures.
Whether the violations were committed willfully or intentionally:
The violations did not appear to be willful or intentional; however, the Non -Discharge Permit
clearly indicates the conditions for compliance.
The prior record of the violator in complying or failing to comply with programs over which
the Environmental Management Commission has regulatory authority:
A NOV was. issued on January 15, 2002 by DWQ/MRO for the failure to submit the
required monitoring reports stipulated in Section HI, Parts 3 and 4 of Permit No.
WQ0016338. A NOV was issued by DWQ/MRO on October 25, 1990 regarding an illegal
discharge (overflow) from one of the settling lagoons. The stream's pH was analyzed by
MRO staff and was below the minimum water quality stream standard (less than 6.0 s.u.).
On May 30, 1986, DWQ/MRO staff observed a black pipe in the stream for the removal of
alum sludge that had accumulated in the stream. No NOV was issued. A complaint report
dated December 30, 1985 detailed several site visits conducted by MRO staff regarding the
conditions of the unnamed tributary adjacent to ALCHEM, Inc. that included: elevated
aluminum/zinc/iron levels and a white floc that had covered the stream bottom. In addition,
the investigations revealed very low pH measurements in a catch basin (< 2.0 with litmus
paper) that had collected stormwater and residual runoff from the ALCHEM, Inc. facility
(See attached reports).
The cost to the State of the enforcement procedures:
Central Office Review and Processing = $100.00
14 hours by investigators for investigating and
drafting report @ $17.38/hour = $243.32
1.0 hour by Water Quality Regional Supervisor
for review @ $39.96/hour = $ 39.96
1.0 hour for clerical support @ $15.00/hour = $ 15.00
TOTAL = $398.28
Type of violator and general nature of business (i.e. individual vs. large corporation):
ALCHEM, Inc. is a business involved with the production of alum (aluminum sulfate) that is
utilized as a settling aid for water treatment facilities.
10. Violator's degree of cooperation (including efforts to prevent or restore) or recalcitrance:
The facility has been cooperative regarding corrective actions.

nstances:
Permit No. W60016338 requires the residuals (utilized as a fill material) to be analyzed
twice per year. A review of the analyses revealed pH values in the ranges of 3.2 s.u. to 3.8
s.u. The pH of the sediment basin discharge (containing residuals and stormwater runoff).
was measured at 3.86 s.u. (on May 8, 2003). The residuals appear to contain sulfuric acid
resulting from the bauxite digestion process.
12. Assessment Factors:
a. IWC: N/A ,
b. Receiving Stream: unnamed tributary to Second Creek (Class C Water)
c: SOC/JOC status/negotiations: N/A
e. Copy of Permit: Attached
f. Damage: Stream standard violations, sedimentation impacts to the tributary and
private property (riparian areas)

Date
May 8, 2003
May 8, 2003
May 8, 2003
May 8, 2003
ATTACHMENT A
Location
40-50 ft. downstream
100-200 ft. downstream
400-500 ft. downstream
sediment basin discharge*
* located on ALCHEM, Inc.'s property
Results
4.22s.u.
4.22 s.u.
4.15 s.u.
3.86 s.u.

DIVISION OF WATER QUALITY
June 24, 2003
MEMORANDUM TO: Jeffrey O. Poupart
FROM: D. Rex Gleason
PREPARED BY: Wes Bell
SUBJECT: Enforcement Recommendation
ALCHEM, Inc.
Violation ofN.C.G.S. 143-215.1,
15ANCAC 2B .0211(3)(g), and
Non -Discharge Permit No. WQ0016338
Rowan County, N.C.
Attached is an enforcement report which details violations of N.C.G.S. 143-215.1, 15A
NCAC 2B .0211(3)(g), and Permit No. WQ0016338. Also enclosed is ALCHEM, Inc.'s response
letter to the Notice of Recommendation for Enforcement, MRO's NOV/NRE and clarification
letters, and several complaint investigations previously performed by this Office. Based upon our
review of the response, an enforcement action is still recommended.
If you have questions or require additional information, please contact Wes or me.
Attachments
M;,

CERTIFICATION PAGE
e information in this report is true to the best of my knowledge.
monitoring data have been verified by hard copy review of the
monthly reports (if applicable) and the appropriate permit (if applicable).
Signature of Principle Investigator(s):
Wesley N. Bell, Environmental Tech. IV
Date:

789 IAC,INC. PAGE 01
Fax Transmission Page From:
1 II 1 r1l\.r_ G1 "Up Of Lumberton, Inc.
*Heavy Highway * Utilities* Sewer Plants * Mining * Water Treatment Chemicals
2042 Buie Philadelphus Rd. Red Springs, North Carolina 28377
Phone [phone] Fax [phone]
N.C. Contractors License # 41562
S.C, Contractors License # 98350
Please deliver to the following:
Name' fYl+f Dateti
r
Organization: E, �J Time -
Fax Number: - Le. Voice #:
NUMBER OF PAGES INCLUDING THIS ONE: 3
Original coming by mail?
This fax is being sent by'
Name: Grlclfe
Subject: =,\C.
bpeczal instructions.
If you have received this fax In Error.. picase notify us by phone
HUB ZONE CERTIFIED
WOMEN'S BUSINESS ENTERPRISE #NC745

1789
May 23, 2003
IAC,INC.
PAGE 02
The TARA GROUP OF LUMBERTON, INC.
2042 Buie Philadelphus Rd Red Springs, NC 28377
NC# 41562 -- SC# 98350
Equipment yards -- Hwy 72 West, Lumberton, NC
Red Road, Rockwell, NC
Telephone [phone] — Facsimile 910-843-5789
Mr. D. Rex Gleason, P.E., Water Quality Regional Supervisor
North Carolina Department of National Resources
919 North Main Street
Mooresville, NC 28115
RE: Notice of Violation for Alchem, Inc.
8135 Red Road
Rockwell, NC 28138
Permit No. WQA 0 QC�pIID 3
Rowan County, NC
Dear Mr. Gleason'.
Please be advised that Alchem, Inc has hired The TARA Group of Lumberton, Inc, The
proposal for this project was signed Monday May 12, 2003. TARA Group will be providing
design build grading and erosion control repairs for our client at the above reference
address. TARA Group has subcontracted with Johnny Nobles & -Associates to provide all
surveying and engineering work that will take place on this project site. We will be
forwarding the erosion control plan to you for approval by you and DENR within the next 15
days.
We have advised our client that we will be working very closely with them within the next
week to install temporary and necessary erosion control measures so this will reduce the
possibility of any further violation in regards to this matter. We look forward to working
with you and DENR in getting this matter resolved and getting our client in compliance. Our
company maintains an excellent working relationship with the Fayetteville regional office of
DENR.
We will be contacting you shortly in regards to this matter. If you have any questions prior
to us contacting you please feel free to contact us to discuss this matter. Again, we look
forward to solving the problems at hand and putting our client back in total compliance with
your agency along with DENR.
WOMAN BUSINESS ENTERPRISE!
Heavy Highway Utilities -- Sewer Plants Mining

5789
IAC,INC.
PAGE 03
your corporation in this matter.
!'rely
lie Andrews
CC: Johnny Nobles, RLS; Johnny Nobles & Associates
Mr. Wayne Drye, Plant Manager, Alchem, Inc.
WOMAN BUSINESS ENTERPRISE!
Heavy Highway Utilities Sewer Plants
Mining

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
Coleen H. Sullins, Deputy Director
Division of Water Quality
August 20, 2003
Mr. Larry Samples
8470 Medium Road
Rockwell, North Carolina 28138
Subject: Follow-up Complaint Investigations
ALCHEM, Inc.'s Corrective Actions
Rowan County, N.C.
Dear Mr. Samples:
Attached is a copy of the Report of Investigation prepared by Mr. Wes Bell of this Office
regarding the follow-up investigations of.the corrective actions initiated by ALCHEM, Inc. to the
on -site residual storage area and the affected stream and wooded/riparian areas. The follow-up
investigations were performed by this Office on August 7 and August 8, 2003.
The report should be self-explanatory; however, if you have any questions concerning this
report, please do not hesitate to contact Mr. Bell or me at [phone].
Sincerely,
D. Rex Gleason, P.E.
Water Quality Regional Supervisor
ME
N. C. Division of Water Quality Mooresville Regional Office 919 North Main Street Mooresville NC 28115 [phone]
�v`A
14C-DENR
Customer Service
1-877-623-6748

Michael F. Easley. Governor LOB
William G. Ross Jr.. Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimck. P. E. Director
Division of Water Quality
Cole- H. Sullins, Depury Director
Division of Water Quality
August 19, 2003
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Randall F. Andrews, President
ALCHEM, Inc.
2042 Buie Philadelphus Road
Red Springs, North Carolina 28377
Subject: Notice of Violation
ALCHEM, Inc.
Failure to Incorporate Remedial
Actions/Illegal Discharge/Surface Water
Quality Standard Violations
Permit No. WQ0016338
Rowan County, N.C.
Dear Mr. Andrews:
Chapter 143, Article 21 of the North Carolina General Statutes (NCGS) authorizes and
directs the Environmental Management Commission of this Department to protect and preserve
the water resources of the State. The Division of Water Quality (DWQ) has the delegated
authority to enforce adopted pollution control rules and regulations.
Enclosed please find a copy of a follow-up Investigation Report for the investigations
conducted on August 7 and 8, 2003 by Mr. Wes Bell and Mrs. Ellen Huffman of this Office. The
follow-up investigation was performed to determine ALCHEM, Inc.'s remedial actions to the
violations noted from the initial investigations dated April 29 and May 8, 2003, as stated in the
NOV/NRE letter/report dated May 12, 2003. As a result of these investigations (8/7 and 8/8/03),
the following conditions were found in violation of North Carolina General Statute (NCGS)
143-215.1 and 15A North Carolina Administrative Code (NCAC) 2B .0211 (3)(g):
Discharges (stormwater/leachate) were observed from the facility's
residual storage area entering an unnamed tributary to Second
Creek. The upstream pH values ranged from 6.72 s.u. to 6.78 s.u.
and the downstream pH values (following the discharges) ranged
from 3.80 s.u. to 4.70 s.u. No corrective actions have been initiated
at the residuals storage area and the affected tributary and
wooded/riparian areas- as were noted in the prior investigations
conducted on April 29 and May 8, 2003.
N. C. Division of Water Quality Mooresville Regional office 919 North Main Street Mooresville NC 28115 [phone]
-MCDEENR
Customer Service
1-877-623-6748

Mr. Randall F. Andrews
NOV
Page Two
Please be advised that this report is being issued as a Notice of Violation (NOV) for the
violations of NCGS 143-215.1, 15A NCAC 2B .0211 (3)(g), and the facility's failure to initiate
remedial actions to the residual storage area and the affected tributary and wooded/riparian areas.
Be advised that NCGS 143-215.6A provides for a civil penalty assessment of not more that
twenty-five thousand dollars ($25,000.00), or twenty-five thousand dollars ($25,000.00) per day
when the violation is of a continuing nature, against any person who fails to abide by the
conditions of the permit and who fails to apply for or to secure a permit required by NCGS 143-
215.1. Penalties may also be assessed for any damage to the surface waters of the State that may
result from the unpermitted discharges.
It is requested that you respond, in writing, within twenty days following receipt of this
Notice. The response should address the measures taken to collect and remove the fill material,
and efforts to restore all -affected areas. Measures taken to prevent future discharges should also
be discussed.
1699.
Should you have questions, please do not hesitate to contact Mr. Bell or me at (704) 663-
Sincerely,
D. Rex Gleason, P.E.
Water Quality Regional Supervisor
Attachments
cc: Rowan County Health Department
Wayne Drye, Plant Manager, ALCHEM, Inc.

CAROLINA DEPARTMENT OF ENVIRONMENT
AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
WATER QUALITY SECTION
919 NORTH MAIN STREET
OORESVILLE, NORTH CAROLINA 28115
REPORT OF: Complaint Investigation
DATE OF INVESTIGATION: August 7 and 8, 2003
INVESTIGATED BY: Wes Bell and Ellen Huffmaii�tYTIME SPENT: 6.0 hours
PLACE VISITED: ALCHEM, Inc. business site and adjacent private properties
PHYSICAL LOCATION: Rockwell, Rowan County
MAILING ADDRESS: 8135 Red Road
Rockwell, N.C. 28138
TELEPHONE #: [phone]
RIVER BASIN: Yadkin -Pee Dee
PERSONS CONTACTED: Mr. Wayne Drye, Plant Manager, On -site Employees
REASON FOR VISIT: Follow-up investigation to confirm ALCHEM, Inc.'s remedial actions to
the tributary and wooded/riparian -areas
COPIES TO: Rowan County Health Department
REPORT:
On August 7 and 8, 2003, Mr. Wes Bell (8/7/03 only) and Mrs. Ellen Huffman of this
office performed follow-up investigations at the ALCHEM, Inc. business site and adjacent
private properties.
This office received a response letter (dated 5/28/03) from ALCHEM, Inc. that outlined
the corrective actions that would be incorporated at the residuals storage area. These corrective
actions included: construction of a berm around the entire storage area, construction of a holding
pond to collect all runoff, cleanup of the affected stream, and the removal of a stormwater pipe
embedded in the residual storage .area. In addition, Mr. Randall Andrews, President, met with
Mr. Bell and submitted the design of the berm and holding pond for the residuals storage area.
On 8/7/03, Mr. Bell did not observe any evidence that ALCHEM, Inc. had initiated any
stipulated corrective actions to the residual storage area, unnamed tributary, and wooded/riparian
areas. The erosion had significantly increased within the residuals storage area based on
observations made during the initial investigations (4/29/03 and 5/8/03). Both sediment basins
(for the residual storage area) were full of the residual material and one of the basins was
observed discharging into the unnamed tributary. ALCHEM, Inc. was removing the stormwater
via pump from the other sediment basin.

Complaint Investigation
Page Two
Several smaller discharges of stormwater/leachate were observed entering
from the residual storage area. On 8/8/03, Mr. Bell and Mrs. Huffm
conditions that were noted in Mr. Bell's 8/7/03 investigation.
On both days of the investigation, the upstream pH ranged from 6.72 s.u. to 6.78 s.u. and
the downstream pH values ranged from 3.80 s.u. to 4.70 s.u. The water quality stream standard
for Class C Waters is between the 6-9 s.u. (Reference: 15A NCAC 2B .0211(3)(g)). Note: The
downstream pH values (approximately 900 to 1100 feet below the confluence of an additional
tributary) ranged from 3.80 s.u. to 4.00 s.u. The pH value of the sediment basin effluent was
3.66 s.u. (on 8/8/03). In addition, the pH value for one of the side -stream discharges was 3.05
s.u. (on 8/8/03). Samples were collected in the tributary (upstream and downstream) and the
discharging sediment basin on 8/8/03.
On 8/8/03, Mr. Bell and Mrs. Huffman met with an ALCHEM, Inc. employee following
the inspection and sample collection/analysis of the tributary and sediment basin discharge. The
employee indicated that the residual storage area was too wet to perform the appropriate
measures to contain the runoff. Grass had been planted (as recommended by Rowan County
Environmental Services/Land Quality Section) and was observed on a small section of the
residual storage area. No equipment utilized for the anticipated corrective actions was observed
on -site. The reuse system was in operation during both investigations.
Mr. Bell contacted (via telephone) Mr. Wayne Drye, Plant Manager, on 8/11/03 regarding
the findings of this investigation. Mr. Drye indicated that the facility had not incorporated
remedial measures due to the inclement weather and the resulting poor soil conditions. Mr. Bell
informed Mr. Drye of the violations observed on -site and the need for immediate corrective
actions. Mr. Drye indicated that he would initiate the appropriate corrective actions. A follow-
up investigation may be necessary to verify ALCHEM, Inc.'s remedial actions.

DIVISION OF WATER QUALITY
F ORCEMENT CASE ASSESSMENT FACTORS
;ondition/Stream Standard Violations
Violator: ALCHEM, Inc.
Address: 8135 Red Road
Rockwell, North Carolina 28135
Registered Agent: Mr. Randall F. Andrews, President
Address: 2042 Buie Philadelphus Road
Red Springs, North Carolina 28377
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 violations:
Impacts to the tributary to Second Creek and adjacent private properties occurred from the
runoff of the residuals and the sediment basin discharges from the ALCHEM, Inc. residual
storage site. The two private properties (riparian areas) contained large accumulations of
residuals (sandbar appearance) in several locations with measurements up to twelve (12)
inches. The residuals had impacted up to 500 linear feet of stream. Specifically, twelve (12)
to twenty-four (24) inches of deposition was measured throughout the impacted portion of
the tributary. The tributary's pH was nearly 100 times more acidic than the upstream
(unaffected). section due to the deposited residuals and the sediment basin discharges.
2. The duration and gravity of the violations:
The discharges appeared to have occurred over several months.
3. The effect on ground or surface water quantity or quality or on air quality:
The riparian areas/private properties had residual deposition up to twelve (12) inches and the
stream had residual deposition up to twenty-four (24) inches. As such, no aquatic life was
found due to the stream being covered by the runoff of the residuals. The impacted portion
of the tributary was nearly 100 times more acidic (than the upstream/unaffected portion) due
to the residual deposition and sediment basin discharges.
4. The cost of rectifying the damage:
According to ALCHEM, Inc.'s response letter, the cleanup activities were estimated at
$68,250.00. The cleanup activities incorporated by ALCHEM, Inc. have not been completed;
therefore, the official amount could not be determined.

;.1
7
a
10.
The amount of money saved by noncompliance:
None could be determined; however, money could have been saved by facility's failure to
incorporate the appropriate erosion control measures.
Whether the violations were committed willfully or intentionally:
The violations did not appear to be willful or intentional; however, the Non -Discharge Permit
clearly indicates the conditions for compliance.
The prior record of the violator in complying or failing to comply with programs over which
the Environmental Management Commission has regulatory authority:
A NOV was issued on January 15, 2002 by DWQ/MRO for the failure to submit the required
monitoring reports stipulated in Section III, Parts 3 and 4 of Permit No. WQ0016338.. A
NOV was issued by DWQ/MRO on October 25, 1990 regarding an illegal discharge
(overflow) from one of the settling lagoons. The stream's pH was analyzed by MRO staff
and was below the minimum water quality stream standard (less than 6.0 s.u.). On May 30,
1986, DWQ/MRO staff observed a black pipe in the stream for the removal of alum sludge
that had accumulated in the stream. No NOV was issued. A complaint report dated
December 30, 1985 detailed several site visits conducted by MRO staff regarding the
conditions of the unnamed tributary adjacent to ALCHEM, Inc. that included: elevated
aluminum/zinc/iron levels and a white floc that had covered the stream bottom. In addition,
the investigations revealed very low pH measurements in a catch basin (< 2.0 with litmus
paper) that had collected stormwater and residual runoff from the ALCHEM, Inc. facility.
(See attached reports).
The cost to the State of the enforcement procedures:
Central Office Review and Processing = $100.00
14 hours by investigators for investigating and
drafting report @ $17.38/hour = $243.32
1.0 hour by Water Quality Regional Supervisor
for review @ $39.96/hour = $. 39.96
1.0 hour for clerical support @ $15.00/hour = $ 15.00
TOTAL = $398.28
Type of violator and general nature of business (i.e. individual vs. large corporation):
ALCHEM, Inc. is a business involved with the production of alum (aluminum sulfate) that
is utilized as a settling aid for water treatment facilities.
Violator's degree of cooperation (including efforts to prevent or restore) or recalcitrance:
The facility has been cooperative regarding corrective actions.

CERTIFICATION PAGE
at the information in this report is true to the best of my knowledge.
All vioiations of self -monitoring data have been verified by hard copy review of the
monthly reports (if applicable) and the appropriate permit (if applicable).
Signature of Principle Investigator(s): 4/ I • &X
. Wesley K Bell, Environmental Tech. IV
Date: � /I q /0 J

ALCUEM, INC.
39 /
May 28, 2003
Mr. D. Rex Gleason
Water Quality Regional Supervisor
NCDENR
gig North Main Street
Mooresville, NC 28115
Dear Mr. Gleason:
Sales and Manufacturing
8135 Red Road
Rockwell, NC 28138
Tel. [phone]o8 — Fax [phone]
[e-mail]
MAY 3 C 2003
K DEK Ui- ziNVAOWF-W Q
1,W MATURAL RESOURCES
MOMSMILE RECaIONALAFFICE
Thank you for your letter of May 12, 2003. I am very sorry about this problem.
Please rest assured that we do not take our responsibilities in this matter lightly.
We certainly want to do everything that we can humanly do to arrange for a long-
term solution. I would like to outline for you as best as I can in words what our
plan will be. I am certain that you are aware that we had such a large amount of
rain this spring that we were frankly overwhelmed by all of the water coming
onto our property. We never expected that such large volumes of water intrusion
would occur. Please allow me to outline the following that we can do to solve this
problem.
1. We will remove the pipe embedded in the sand area.
2. We will divert all water from Red Road and West of the train tracks
around the sand.
3. We will establish a berm around the reuse sand. We will use
recommended erosion control measures on the berm to avoid to the
greatest extent practical erosion from the berm.
4. We will establish a storm water holding pond. All storm water that has
come in contact with the reuse sand pile will be channeled to the
holding pond and pumped back up to our process water tanks.
5. We will keep an inspection log with monthly inspections to make
certain that the holding pond has not lost any storm water. We will
inspect the stream to make certain that no run off from our facility has
occurred.
6. We will clean the small stream and do our very best to restore it to its
original condition.
7. We have contracted with a local surveying and engineering company to
help us to determine how large the holding basin needs to be.

ALCHEM, INC.
Sales and Manufacturing
8135 Red Road
Rockwell, NC 28138
r89 Tel. [phone]o8 — Fax [phone]
[e-mail]
8. We plan to inspect the holding pond to make certain that it has not
filled with sand. If there is any sand we will remove it. We will inspect
monthly.
9. We intend to contract with a construction company to construct this
project. Please see enclosed contract.
I hope that this information is satisfactory to you. Please let me know if you have
any questions comments or concerns.
Best regards,
ALCHEM, INC.
OJ '�& T,/Vf
Wayne Drye,
Vice President
vll

May 28, 2003
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OA A M EA��P
The TARA GROUP OF LUMBERTON, INC.
2042 Buie Philadelphus Rd Red Springs, NC 28377
NC# 41562 — SC# 98350
Equipment yards — Hwy 72 West, Lumberton, NC
Red Road, Rockwell, NC
Telephone [phone] N Facsimile 910-843-5789
CONTRACT BETWEEN
THE TARA GROUP OF LUMBERTON AND ALCHEM, INC.
Job description: Provide all planning, design, labor and equipment to perform various work as listed.
1. Provide a diversion around the railroad tracks for offsite water to be diverted around sand storage.
2. Provide a berm around the sand storage to divert all offsite water from the sand and divert all on site
rainwater to the storm water storage area.
3. Prepare a storm water retention basis with enough capacity for a 25-year storm event.
4. Provide a plan from Johnny Nobles And Associates of Lumberton, NC to prepare this site to ensure
that all storm water is captured and used as process water.
5. Stop water flow from the pipe that is embedded in the sand.
Price: $ 68,250.00
Time: To start upon approval
Length: 120 days from approval.
Payment: Progress payments to be made every 30 days.
ALCHEM, INC.
Wayne Drye,
Vice President
TARA GROUP O-�F LUMBERTON, INC.
/D
Denise B. Andrews,
President
WOMAN BUSINESS ENTERPRISE!
Heavy Highway Utilities Sewer Plants Mining

0��vl
6fiNX*4 The TARA GROUP OF LUMBERTON, INC.
2042 Buie Philadelphus Rd Red Springs, NC 28377
NC# 41562 — SC# 98350
Equipment yards — Hwy 72 West, Lumberton, NC
Red Road, Rockwell, NC
Telephone [phone] N Facsimile 910-843-5789
am%VL
May 23, 2003
Mr. D. Rex Gleason, P.E., Water Quality Regional Supervisor
North Carolina Department of National Resources
919 North Main Street
Mooresville, NC 28115
RE: Notice of Violation for Alchem, Inc.
8135 Red Road
Rockwell, NC 28138
Permit No. >�QO©L°33S
Rowan County, NC
Dear Mr. Gleason:
Cep MPT. 0F
ARID (�SATUPTII
�OW 3 0 200.E
Please be advised that Alchem, Inc has hired The TARA Group of Lumberton, Inc. The
proposal for this project was signed Monday May 12, 2003. TARA Group will be providing
design build grading and erosion control repairs for our client at the above reference
address. TARA Group has subcontracted with Johnny Nobles & Associates to provide all
surveying and engineering work that will take place on this project site. We will be
forwarding the erosion control plan to you for approval by you and DENR within the next 15
days.
We have advised our client that we will be working very closely with them within the next
week to install temporary and necessary erosion control measures so this will reduce the
possibility of any further violation in regards to this matter., We look forward to working
with you and DENR in getting this matter resolved and getting our client in compliance. Our
company maintains an excellent working relationship with the Fayetteville regional office of
DENR.
We will be contacting you shortly in regards to this matter. If you have any questions prior
to us contacting you please feel free to contact us to discuss this matter. Again, we look
forward to solving the problems at hand and putting our client back in total compliance with
your agency along with DENR.
WOMAN BUSINESS ENTERPRISE!
Heavy Highway Utilities Sewer Plants Mining

uu
)oration in this matter.
Johnny Nobles, RLS; Johnny Nobles & Associates
Mr. Wayne Drye, Plant Manager, Alchem, Inc.
WOMAN BUSINESS ENTERPRISE!
Heavy Highway Utilities Sewer Plants Mining

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s �
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
May 12, 2003
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
7001 2510 0004 8287 709 5'
Mr. Wayne Drye, Plant Manager
ALCHEM, Inc.
8135 Red Road
Rockwell, North Carolina 28138
Subject: Notice of Violation/Notice of
Recommendation for Enforcement
ALCHEM, Inc..
Illegal Discharge/Permit Violations/
Surface Water Quality Standard Violations
-Permit No. WQ0002702
Rowan County, N.C.
Dear Mr. Drye:
Chapter 143, Article 21 of the North Carolina General Statutes (NCGS) authorizes and directs the
Environmental Management Commission of this Department to protect and preserve the water resources of
the State. The Division of Water Quality (DWQ) has the delegated authority to enforce adopted'pollution
control rules and regulations.
Enclosed please find a copy of a Complaint Investigation Report for the investigation conducted
on April 30, 2003 by Mr. Wes Bell of this Office. As a result of this investigation, the following
conditions were found in violation of North Carolina General Statute (NCGS) 143-215.1, 15A North
Carolina Administrative Code (NCAC) 213 .0211 (2), (3)(c) and (g), and Non -Discharge Permit No.
WQ0002702:
The facility's storage area for its fill material had discharged into a
drainage/wooded area and an intermittent stream. The intermittent stream
was observed_ covered (up to 24 inches) with the fill material for a total
distance of approximately 400-500 feet (upstream and downstream of
Medium Road). The upstream pH value was 6.04 s.u. and the '
downstream pH values (following the discharges) ranged from 4.15 s.u. to
4.22 s.u. The facility impaired/removed the suitability of the stream for
aquatic life and propagation and maintenance of biological integrity,
wildlife, and secondary recreation. The permittee failed to 1) properly
operate and maintain the facility as a non -discharge facility, 2) cease reuse
operation once nuisance conditions existed, 3) provide adequate
provisions to prevent surface runoff from conveying pollutants into
surface waters, and 4) notify this office of the residuals release into the
receiving stream.
Mooresville Regional Office, 919 North Main Street, Mooresville, NC 28115 N 6 R
'HONE [phone] - Customer Service
:AX [phone] 1 800 623-7748

f-
r�s
Mr. Wayne Drye
NOV/NRE
Page Two
Please be advised that this report is being issued as a Notice of Violation (NOV) and Notice of
Recommendation for Enforcement for the violations of NCGS 143-215.1, 15A NCAC 213 .0211 (2), (3)(c)
and (g), and Non -Discharge Permit No. WQ0002702. Be advised that NCGS 143-215.6A provides for a
civil penalty assessment of not more that twenty-five thousand dollars ($25,000.00), or twenty-five
thousand dollars ($25,000.00) per day when the violation is of a continuing nature, against any person who
fails to abide by the conditions of the permit and who fails to apply for or to secure a permit required by
NCGS 143-215.1. Penalties may also be assessed for any damage to the surface waters of the State that
may result from the unpermitted discharge.
It is requested that you respond, in writing, within twenty days following receipt of this Notice.
The response should address the measures taken to collect and remove the fill material, and efforts to
restore all affected areas. Measures taken to prevent future discharges should also be discussed.
This letter is also to advise you that this Office is considering sending a recommendation for
enforcement action to the Director of the Division 'of Water Quality for the discharge of the fill material
into a stream, water quality stream standard violations (pH and best usage), and the facility's failure to
abide by the conditions of Permit No. WQ0002702. If you have an explanation for the violations that you
wish to present, please include same in the requested response. Your explanation will be reviewed and if
an enforcement action is still deemed appropriate, your explanation will be forwarded to the Director along
with the enforcement package for his consideration.
To comply with the regulations, it will be necessary to collect and remove all of the fill material (in
the stream and drainage/wooded areas) and restore all affected areas as nearly as may be to the conditions
existing prior to the.discharge.
Should you have questions, please do not hesitate to contact Mr. Bell or me at [phone].
Sincerely,
D. Rex Gleason, P.E.
Water Quality Regional Supervisor
Attachments
cc: Rowan County Health Department
off

s
NORTH CAROLINA DEPARTMENT OF ENVIRONMENT
AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
WATER QUALITY SECTION
919 NORTH MAIN STREET
MOORESVILLE, NORTH CAROLINA 28115
REPORT OF: Complaint Investigation
DATE OF INVESTIGATION: April 30, 2003
INVESTIGATED BY: Wes Bell~ TIME SPENT: 2.0 hours
PLACE VISITED: ALCHEM, Inc. Business Site
PHYSICAL LOCATION: Rockwell, Rowan County
MAILING ADDRESS: 8135 Red Road
Rockwell, N.C. 28138
TELEPHONE #: [phone]
RIVER BASIN: Yadkin -Pee Dee
PERSONS CONTACTED: Mr. Wayne Drye, Plant Manager, On -site Employees
REASON FOR VISIT: Investigation of complaint regarding discharge of a white substance into
a drainage/wooded area and creek
COPIES TO: Rowan County Health Department
6403416
On April 29, 2003, this office received a complaint that a white substance from
ALCHEM, Inc. had been discharged into a drainage/wooded area and intermittent stream in
Rockwell, Rowan County. The complaint was investigated by Wes Bell of this office on April
30, 2003.
Mr. Bell arrived at a residence below ALCHEM, Inc. adjacent to Medium Road. Mr. Bell
observed large accumulations of a white, granular material (sand appearance) throughout the
drainage/wooded area. In addition, this white substance had completely covered the bottom of an
intermittent stream (unnamed tributary to Second Creek - Class C Stream) for approximately
200-300 feet (upstream of Medium Road). The intermittent stream was observed free -flowing on
top of the white substance at the time of the investigation.
Mr. Bell traced the white material (upstream) throughout the drainage/wooded area and
intermittent stream to a large storage area containing this white material. The material appeared
to be used as a fill material. This fill material appeared to have covered an area between three to
five acres. The fill area had been severely eroded allowing the material to flow across a sediment
basin and silt fence into the drainage/wooded area. The white substance (combined with a clay)
had eroded/discharged into the intermittent stream in several locations. The permittee did not
appear to have incorporated appropriate erosion control measures to contain the material.

Complaint Investigation
Page Two
Mr. Bell met with the ALCHEM, Inc. on -site employees. Mr. Bell escorted one of the
employees to the affected drainage/wooded area and intermittent stream. While at the facility,
Mr. Bell observed two lagoons adjacent to the fill material. The employee indicated that the two
lagoons were part of a wastewater reuse system. A third lagoon on -site was utilized as a backup.
Bauxite (aluminum ore) is transported to ALCHEM via railcart. The bauxite is mixed
with silica sand (80% bauxite and 20% silica sand), and made into a slurry via water additions.
Sulfuric acid is added to the bauxite slurry (to create the finished product - aluminum sulfate) and
a polymer is then added to aide in settling/removal of the sand. The sand is removed and rinsed
three times with water (to remove the aluminum) prior to discharging the sand/water mixture into
the lagoon system. The sand is removed from the lagoons and used as a fill material. The water
is also reused in the process. Mr. Bell was informed by the on -site employee that the facility
monitors two on -site groundwater monitoring wells as well as the fill material. Mr. Bell
reviewed the facility's permit requirements on -site and at this office.
Mr. Bell determined that ALCHEM, Inc. was issued Permit No. WQ0002702 by the
Division for the on -site reuse of silica residuals from bauxite digestion as a fill material. The
Permit became effective on January 21, 1999 and expires on December 21, 2004. The Permit
authorizes the usage of 3,000 tons per year of residual to be used as a fill material on the
company's property from the bauxite residuals reuse program. The facility failed to comply with
the conditions of their permit. Specifically, the facility failed to 1) properly operate and maintain
the facility as a non -discharge facility, 2) cease reuse operation once nuisance conditions existed,
3) provide adequate provisions to prevent surface runoff from conveying pollutants into surface
waters, and 4) notify this office of the residuals release into receiving waters. The accumulation
of the fill material in the stream impacted/removed the suitability of the waters for aquatic life
and maintenance of biological integrity, wildlife, secondary recreation, and agriculture, which is
a violation of 15A North Carolina Administrative Code (NCAC) 2B .0211 (2) and (3)(c).
Messrs. Bell and Alan Johnson (of this office) revisited the drainage/wooded areas and
intermittent stream upstream and downstream of Medium Road on 5/8/03. Mr. Bell sampled the
intermittent stream for pH above and below the impacted areas throughout the intermittent
stream. The upstream pH value was 6.04 s.u. and the downstream pH values ranged from 4.15 to
4.22 s.u. A pH value of 4.22 s.u. was recorded at the most distant downstream sampling location
(100-150 feet downstream of Medium Road). The facility's discharge of the fill material into the
stream caused a surface water quality pH standard violation. The standard for Class C Waters is
between the 6-9 s.u. (Reference: 15A NCAC 2B .0211(3)(g). Large accumulations of the fill
material were also observed throughout the drainage/wooded area at this downstream location.
Mr. Bell analyzed the pH of the accumulated water in the sediment basin adjacent to the fill
material. The pH value was 3.86 s.u. The sediment basin was discharging into the intermittent
stream at the time of this investigation. Mr. Johnson's measurements of the accumulations in the
stream channel showed a depth of up to twenty-four inches. Mr. Johnson also measured
accumulations up to twelve inches throughout the drainage/wooded areas (upstream and
downstream of Medium Road).

'Complaint Investigation
Page Three
Mr. Wayne Drye, Plant Manager, contacted Mr. Bell via telephone regarding the
investigation. Mr. Bell informed Mr. Drye of the findings and environmental regulations
relevant to the investigation. In addition, Mr. Bell informed Mr. Drye that the Division of Land
Resources' Land Quality Section would be notified regarding the inadequate erosion and control
measures. Mr. Drye and his staff were very cooperative and helpful throughout this
investigation. A follow-up investigation by this office may be necessary to verify adequate
remedial actions.

�F W A T�9P
Michael F. Easley, Governor
r— William G. Ross, Jr.,Secretary
—{ North Carolina Department of Environment and Natural Resources
t�
Alan W. Klimek, P.E., Director
Division of Water Quality
May 12, 2003
Mr. Larry Samples
8470 Medium Road
Rockwell, North Carolina 28138
Subject: Complaint Investigation
ALCHEM, Inc./Illegal Discharge
Rowan County, N.C.
Dear Mr. Samples:
Attached is a copy of the Report of Investigation prepared by Mr. Wes Bell of this Office
regarding your complaint of a discharge of a white substance into a drainage/wooded area and creek.
The complaint was received by this office on April 29, 2003.
The report should be self-explanatory; however, if you have any questions concerning this
report, please do not hesitate to contact Mr. Bell or me at [phone].
Sincerely,
D. Rex Gleason, P.E.
Water Quality Regional Supervisor
Attachment
cc: Rowan County Health Department
ME
Mooresville Regional Office, 919 North Main Street, Mooresville, NC 28115
SWW
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Customer Service
1 800 623-7748

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WATER QUALITY SECTION
DENR
919 NORTH MAIN STREET
MOORESVILLE NC 28111

DIVISION OF WATER QUALITY
ENFORCEMENT CASE ASSESSMENT FACTORS
Type: (PC/SS) Permit Condition/Stream Standard Violations
Violator: ALCHEM, Inc.
Address: 8135 Red Road
Rockwell, North Carolina 28135
Registered Agent: Mr. Randall F. Andrews, President
Address: 2042 Buie Philadelphus Road
Red Springs, North Carolina 28377
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 violations:
Impacts to the tributary to Second Creek and adjacent private properties occurred from the
runoff of the residuals and the sediment basin discharges from the ALCHEM, Inc. residual
storage site. The two private properties (riparian areas) contained large accumulations of
residuals (sandbar appearance) in several locations with measurements up to twelve (12)
inches. The residuals had impacted up to 500 linear feet of stream. Specifically, twelve (12)
to twenty-four (24) inches of deposition was measured throughout the impacted portion of
the tributary. The tributary's pH was nearly 100 times more acidic than the upstream
(unaffected) section due to the deposited residuals and the sediment basin discharges.
2. The duration and gravity of the violations:
The discharges appeared to have occurred over several months.
3. The effect on ground or surface water quantity or quality or on air quality:
The riparian areas/private properties had residual deposition up to twelve (12) inches and the
stream had residual deposition up to twenty-four (24) inches. As such, no aquatic life was
found due to the stream being covered by the runoff of the residuals. The impacted portion
of the tributary was nearly 100 times more acidic (than the upstream/unaffected portion) due
to the residual deposition and sediment basin discharges.
4. The cost of rectifying the damage:
According to ALCHEM, Inc.'s response letter, the cleanup activities were estimated at
$68,250.00. The cleanup activities incorporated by ALCHEM, Inc. have not been completed;
therefore, the official amount could not be determined.

5. The amount of money saved by noncompliance:
None could be determined; however, money could have been saved by facility's failure to
incorporate the appropriate erosion control measures.
6. Whether the violations were committed willfully or intentionally:
The violations did not appear to be willful or intentional; however, the Non -Discharge Permit
clearly indicates the conditions for compliance.
7. The prior record of the violator in complying or failing to comply with programs over which
the Environmental Management Commission has regulatory authority:
A NOV was issued on January 15, 2002 by DWQ/MRO for the failure to submit the required
monitoring reports stipulated in Section III, Parts 3 and 4 of Permit No. WQ0016338. A
NOV was issued by DWQ/MRO on October 25, 1990 regarding an illegal discharge
(overflow) from one of the settling lagoons. The stream's pH was analyzed by MRO staff
and was below the minimum water quality stream standard (less than 6.0 s.u.). On May 30,
1986, DWQ/MRO staff observed a black pipe in the stream for the removal of alum sludge
that had accumulated in the stream. No NOV was issued. A complaint report dated
December 30, 1985 detailed several site visits conducted by MRO staff regarding the
conditions of the unnamed tributary adjacent to ALCHEM, Inc. that included: elevated
aluminum/zinc/iron levels and a white floc that had covered the stream bottom. In addition,
the investigations revealed very low pH measurements in a catch basin (< 2.0 with litmus
paper) that had collected stormwater and residual runoff from the ALCHEM, Inc. facility
(See attached reports).
8. The cost to the State of the enforcement procedures:
Central Office Review and Processing . _ $100.00
14 hours by investigators for investigating and
drafting report @ $17.38/hour = $243.32
1.0 hour by Water Quality Regional Supervisor
for review @ $39.96/hour = $ 39.96
1.0 hour for clerical support @ $15.00/hour = $ 15.00
TOTAL = $398.28
9. Type of violator and general nature of business (i.e. individual vs. large corporation):
ALCHEM, Inc. is a business involved with the production of alum (aluminum sulfate) that
is utilized as a settling aid for water treatment facilities.
10. Violator's degree of cooperation (including efforts to prevent or restore) or recalcitrance:
The facility has been cooperative regarding corrective actions.

CERTIFICATION PAGE
I certify that the information in this report is true to the best of my knowledge.
All violations of self -monitoring data have been verified by hard copy review of the
monthly reports (if applicable) and the appropriate permit (if applicable).
Signature of Principle Investigator(s): V
. Wesley K Bell, Environmental Tech. IV
Date:

Alchem history from MRO file's
-*�Wfe—WWREMPEW290,72by Ellen Huffinan
Please note that the author has found files in several sections/divisions due to the different types of permits issued for the
same process i.e., residuals, recycle, and groundwater.
Dec. 6, 1984 — Complaint from City of Rockwell of white color in creek.
May 9, 1985 — A memorandum concerning a complaint investigation of a spill/runoff into creek
(investigated on Nov. 15, 1984) from the ALCHEM plant and drinking water well contamination. All
stream samples showed high concentrations of Al, Fe, Na, and Zn.
Dec. 30, 1985 — WQ MRO complaint investigation report summing up issues from multiple spills
throughout the last 12 months since the Nov. 15, 1984 investigation.
Jan. 2 & 7, 1985 — WQ samples the stream. Samples come back with extremely high concentrations of
Al, Fe, Na, and Zn. (data in file)
Feb. 28, 1985 — Stream samples still show high levels of Al, Fe, & Na.
March 26, 1985 — WQ received another complaint from a resident in the ALCHEM area.
April 1, 1985 - Soil samples showed high levels of Al, Fe, & Na. Well samples taken at the same time
were high in Al & Na. Down stream samples showed high concentrations of Al, Fe, Na, and Zn.
Upstream samples did not show high concentrations of Al, Fe, Na, and Zn. Also discovered the path of
runoff from ALCHEM property to the stream.
May 9, 1985 — A memorandum from Monty Payne & Jesse Wells, to Bill Jeter, concerning multiple
complaints from neighbors of ALCHEM.
June 11, 1985 —Stream samples, once again, show high levels of Al, Fe, & Na.
Sept. 9, 1985 — During a meeting with WQ and ALCHEM, it was determined that the ponds need to be
emptied and contaminated soil be removed or neutralized. if the lagoon was to be used it must be lined.
They also must submit an application for a non -discharge permit.
Jan. 3, 1986 — WQ staff report (Thurmon Horne) for ALCHEM (APN 005232) The facility has 2
existing (un-permitted) recycle lagoons. DEM & DHR have both conducted investigations regarding
well and groundwater contamination. ALCHEM has had to replace one off site drinking water well,
cleaned areas affected be run-off, and removing all liquid from the lagoons with the intention of
removing the lagoons (excavating and removing contaminated soils). ALCHEM proposes to construct a
new recycle system. The new process will involve mixing bauxite, sulfuric acid, and water in a reactor.
The waste residuals (pH between 2.0 and 2.5) will be pumped to the proposed non -discharge recycle
wastewater treatment facility. The residuals from the facility will be pumped to the retention pond
where LIME will be added to raise the pH to 6 s.u. The applicant proposes to dispose of the

ALCHEM file History
Page 2
residuals in the county landfill. The applicant has failed to submit acceptable detailed engineering
plans and specs as requested.
Recommendations: Considering the past history of this facility, it is imperative that a thorough
evaluation is made prior to permit issuance...
Jan. 7, 1986 — A meeting in Rockwell between DEM & ALCHEM, concerning a need for a permit for
the ALCHEM facility.
Jan. 8, 1986 — DEM WQ MRO memorandum — WQ reviews an application and recommends that
ALCHEM do a thorough investigation of the present subsurface conditions prior to issuance of the
permit.
Jan. 8, 1986 — MRO GW memo from Jesse Wells to Len Bramble. GW recommends that ALCHEM do
a thorough investigation of the present subsurface conditions including directional flow and gradient of
the groundwater, lithologic description and determination of the hydraulic conductivity of the soil, and
sampling of the saturated zone as a requirement before issuance of the permit.
Jan. 30, 1986 - A letter from DENR & Community Development, regarding insufficient data to process
the permit application.
April 10, 1986 — A letter from DENR to ALCHEM regarding Operation of an un-permitted non -
discharge Waste Treatment System.
May 5, 1986 ALCHEM submits a permit application for a tank spill containment area & a sand filter.
May 14, 1986 — DEM Groundwater section memo from Len Bramble to Bill Crawford. Subject
application of new permit APN 0076633 and GW 8680. "We have received copy of the above
referenced application which was sent to your regional office for comment on or about May 12, 1986"...
June 17, 1986 — A letter from ALCHEM to DENR Addendum to application APN007633.
Sept. 12, 1986 — DEM GW — memo. Sub. Permit app. Review, ALCHEM, GW86080. Recommends
issuance of permit with 2 conditions. 1- the sand filter bed must be lined with a geotech fiber and two
layers of 6 mil. (12 mil. total) synthetic liner. 2- any groundwater monitoring deemed necessary by the
department.
September 22, 1986 — A note to file regarding a letter from ALCHEM to Thurmond Horne evaluating a
vacuum filter. Note from staff suggests that the dept. hold the permit application for four weeks before
returning the application to ALCHEM as incomplete.
(what happened to 1987?)

"I
_y
ALCHEM file History
Page 3
Jan. 19, 1988 — A letter from DENR to ALCHEM —Subject: Project ReturnAPN007633. In reference to
application received May 7, 1986.
Feb. 1988 — A etter from ALCHEM to DENR. " I did not realize that our non -discharge Permit was
being held. We decided to put in a sand filter enclosed in a tank..."
July 30, 1989 — A letter from DENR & Comm. Dev. regarding information needed for a review of
ALCHEM Ind. Recycle (WQ0001987) permit to be completed.
October 2, 1989 —A letter from DENR to ALCHEM. Subject: Project Return (WQ0001987).
October 11, 1989 — A staff report from MRO recommends that the ERG and groundwater provide
comments before permit issuance and possible cake sludge storage issues. (Allen Hardee, MRO staff).
January 10, 1990 - DENR issues permit WQ0002702 after review of Nov. 17,1989 (permit) application.
(cannot find copy of application in file for this date)
May 4, 1990 — A letter from ALCHEM to DENR (Carolyn McCaskill) referencing permit WQ0002702
and regarding removal of a partition between two lagoons.
May 21, 1990 A letter from ALCHEM to MR. Rex Gleason (MRO) referencing permit WQ0002702 and
regarding installed facilities ready for inspection.
October 25, 1990 — A Notice of Violation regarding a discharge of alum (?) into the creek.
Oct. 8, 1992 — ALCHEM submits a permit application for a recycle system.
Oct. 19, 1992 — An application from ALCHEM received by DEHNR (no application found in MRO
files).
March 11, 1993 — GW memo regarding modification of permit WQ0002702 (concerning) proposed
sludge storage lagoons. GW recommends (two) monitoring wells.
March 23, 1993 — A renewal application from ALCHEM received by DEHNR (no application found in
MRO files).
April 8, 1993 - The amended permit is issued to ALCHEM.
April 20, 1993 — A letter from ALCHEM to DEHNR regarding amendment of permit WQ0002702
including monitoring well requirements and construction of only two lagoons rather than the original
five. Sees no need for groundwater monitoring.
April 20, 1993 — A letter from DEHNR to ALCHEM was conveying groundwater -monitoring guidance.

ALCHEM file History
Page 4
June 9, 1993 —A memo from Don Saffrit, P.E., Asst. Chief for Teck. Support to Ted Bush Asst. Chief,
groundwater section regarding a petition (ALCHEM monitoring wells) with the Office of
Administrative hearings.
June 22, 1993 — A memo from MRO GW (David Eudy) to Jack Floyd regarding adjudication request -
regarding concerns with sulfuric acid in large quantities and past history of non-compliance, there is
ample justification for groundwater monitoring requirements.
June 25, 1993 — A memo from Central GW to MRO GW, regarding adjudication request. "The
groundwater section stands firm with its decision to recommend groundwater monitoring to remain a
part of the permit".
June 30, 1993 — A letter from DEHNR to ALCHEM, regarding groundwater monitoring to stay in the
amended permit.
Sept. 21, 1993 — A letter from ALCHEM to NC EMC asking permission to drop VOC testing
requirements from the permit.
April 6, 1994 — A memo from MRO GW to DEM GQ, acknowledging receipt of a permit renewal
application for ALCHEM WQ0002702.
April 27, 1994 — A memo to DEM GW Compliance Group from Barbara Christian, MRO GW
Supervisor regarding a site inspection (for a permit renewal) on April 26, 1994 that raised several
concerns.
• Raw aluminum ore storage issues
• Monitoring reports indicate that monitoring wells were not purged prior to sampling
• Lack of chemical analyses of the lagoon wastewater
• Inaccurate topographic site map
May 23, 1994 — A memo from Cindy Boyles to Carolyn McCaskill, regarding ALCHEM permit renewal
(permit WQ0002702) reads "run-offinto a drainage way still poses a problem to the residents directly
below grade ".
June 27, 1994 — (renewed) permit WQ0002702 issued.
July 11, 1994 — A letter from DEHNR to ALCHEM, regarding (groundwater) monitoring guidance.
October 30, 1995 — A certified letter to ALCHEM from MRO GW regarding proper purging of
monitoring wells prior to sampling (permit WQ0002702).
October 20, 1998 — ALCHEM submits for a permit renewal and modification (permit WQ0002702).
4

ALCHEM file History
Page 5
Nov. 10, 1998 — A staff report by G.T. Chen includes very little comment. "pending final review and
approval by the SERG and the Groundwater Section, it is recommended that the subject permit
(WQ0002702) be renewed and modified to allow sand by-product to be mixed with clay.
December 8, 1998 — Memo from Peggy Findley, MRO, to Dr. Ken Rudo. Request for Health Rick
Evaluation for the public water supply well on the ALCHEM premises.
December 30, 1998 — a memo from Brian Wootton (MRO) to Kim Colson WQS, regarding groundwater
monitoring changes to the ALCHEM permit WQ0002702. Existing monitoring wells MW-1 & MW-2
shall be sampled Feb. & July for water level, aluminum, and pH.
Jan. 21, 1999 — renewal permit WQ0002702 (industrial recycle bauxite process) is issued to ALCHEM.
*****March 1, 1999 - Permit WQ00016338 is issued to ALCHEM for a bauxite (residuals) reuse
Program "... for the operation of a bauxite residuals reuse program (as structural fill) on ALCHEM Inc.'s
property at 8135 Red Road, Rockwell, NC..."
April 25, 2000 — A letter from DEHNR, MRO, to ALCHEM, regarding (permit WQ0002702) field
analysis data (section 4 of the groundwater G-59 form).
Oct. 11, 2001 — A letter from Groundwater MRO, to ALCHEM, regarding an upward trend of aluminum
in MW-1 and MW-2 (permit WQ0002702). Letter asks from ALCHEM to re -sample within 60 days,
including the drinking water supply well that serves the office.
October 17, 2001 — A letter from IAC (Ind. & Agri. Chem. Inc. -parent company of ALCHEM)
regarding the Oct. 11, 2001 letter to ALCHEM...."Alchem manufactures aluminum sulfate. Both cation
and anion are very water-soluable. We have noticed the increase in aluminum values but with no
corresponding sulfate increase. Naturally, we are concerned. However, is it possible that the aluminum
is coming from other sources since there is no increase in the sulfate anion? We are going to follow
your instructions and will be in touch with you".
Jan. 7, 2002 - A Notice of Violation letter, groundwater quality violations.
March 15, 2002 — Notice of Violation for WQ0016338 concerning monitoring reports for sect. III, part
3&4.
April 12, 2002 - A rescission of NOV letter from Peggy Finley, MRO, to ALCHEM.
April 29, 2003 — A complaint received by MRO, from a downstream neighbor of large amounts of
white substance being washed down the creek from ALCHEM property. Wes Bell, MRO investigated.
Spent Bauxite is found to be over 2 feet think in parts of the stream.

April 30 and May 8, 2003 — Investigations had determined that the run-off from ALCHEM had
impacted up to 500 linear feet of a tributary to Second Creek.
ALCHEM file History
Page 6
May 12, 2003 — NOWNRE for permit WQ0016338 regarding the above complaint investigation.
May 14, 2003 — A letter from DENR MRO to ALCHEM, regarding the NOV stating that the NOV
should have been issued against permit WQ0416338.
May 23, 2003 — The TARA Group is hired to repair erosion control issues at ALCHEM.
May 28, 2003 — A letter from ALCHEM to Rex Gleason, supervisor WQS, MRO in response to the May
12, 2003 NOV/NRE. ALCHEM sends an outline of a cleanup plan.
August 8, 2003 — MRO photos reflect no clean up activity.
August 18, 2003 — (WQ0016338) a penalty was assessed in the amount of $5,998.28 for the May 12,
2003 NOV.
August 19, 2003 — A NOV (WQ0016338) was issued for failure to incorporate remedial actions/illegal
discharge to surface water.
Feb. 24, 2004 — ALCHEM submits the annual report for WQ0016338. ALCHEM reports "for the year
2003, we did not accumulate enough silica residual to land apply".
July 29, 2004 — ALCHEM is on a payment plan with AGO for the May 12, 2003 NOV, per Janet Leach.
Aug. 13, 2004 — A letter from DEHNR to ALCHEM, regarding withdrawal of permit application
package for WQ0016338.
Sept. 29, 2004 - MRO receives a request to renew WQ0002702.
Sept. 20, 2004 — MRO receives a request to renew WQ0016338.
October, 2004 — MRO photos show new berm built around fill area.
Oct. 25, 2004 — A staff report by Ellen Huffinan, MRO, for both permit renewals, requests that due to
past confusion between the two permits that they be combined for better monitoring of a site with many
compliance issues in the past. There were also many other changes requested.
December 28, 2004 — A renewal permit for WQ0002702 (recycle) is issued with the many changes (as
requested by MRO, but the other permit (WQ0016338, residuals) is not issued. It is currently being held
in Central Offices until the confusion is cleared up.
Permit WQ0016338 was not renewed until Dec. 28, 2006.

ALCHEM file History
Page 7
Dec. 30, 2004 & Jan.5, 2005 — A follow-up investigation by Wes Bell, MRO, revealed stormwater run-
off issues with low pH continuing to impact the stream.
Jan. 12, 2005 — NOV/NRE issued due to continued problems found during the investigation on Dec. 30,
2004 and Jan. 5, 2005.
Jan. 27, 2005 — A letter from ALCHEM to Rex Gleason, MRO, regarding further cleanup of stream.
Letter states that their pH readings are not as low as the readings that Wes Bell had gotten.
Feb. 9, 2005 - A letter from ALCHEM to Rex Gleason, MRO, regarding soils sampling, liming affected
areas, hiring a tree expert, and repairing silt fences.
Feb. 10, 2005 — A letter from ALCHEM to Div. Of WQ, Central Office, regarding the receipt of the new
permit WQ0002702. The permit was dated Dec. 28, 2004 but ALCHEM says that they did not receive it
until Jan. 28, 2005. This letter asks for an extension of 90 days to review the permit. To the writer's
knowledge, Central Office did not reply to this letter.
March 8, 2005 — A letter from ALCHEM to Div. Of WQ, Central Office, regarding many objections to
the permit conditions of WQ0002702. To the writer's knowledge, no response received by Central
Office.
March 10, 2005 — A letter from ALCHEM to Non-Dis. Compliance conveys the annual report for
WQ0016338. This letter states that they did not accumulate enough silica residual to land apply, just like
the 2003 annual report. The writer recalls that ALCHEM stated that they plan to clean out a lagoon (or
two) in the spring which is why the staff report asked for extra pH testing on excavated materials and an
inspection of the lagoon liner.
April 22, 2005 — A Notice of Regulatory Requirements for WQ0002702 was sent regarding the recently
renewed permit. The MRO stated that they considered this permit enforceable as the adjudication period
had passed without comment.
June 8, 2005 — Central Office asks for additional information via registered letter, to be received by July
8, 2005. Additional information requested, included engineering documentation of the fill area and the
berm.
June 21, 2005 — A letter from DWQ MRO Supervisor regarding concern with the consistently low pH
readings measured in the stormwater ditch adjacent to the railroad tracks by unloading station.
July 8, 2005. — No additional information is received.

August 2, 2005 - Email from David Goodrich regarding phone call from Mr. Nathan Cook of BOYLE
Engineering, who has been retained by Randall Andrews (ALCHEM) to perform site evaluation of Red
Rd. facility.
ALCHEM file History
Page 8
August 2, 2005 — Copy of Decision of Dismissal (dated July 29, 2005) is received by MRO via fax.
August 4, 2005 — Inspection reflects poor conditions persist including; no freeboard in lagoons, burying
construction debris in the fill area, low pH in recycle system water, and new water line places in fill
area.
August 15, 2005 — Mr. Andrews sends a letter to Shannon Thornburg, (Author of permit), asking for
DWQ to relax the provision regarding pH in the spent bauxite lagoon water.
August 24, 2005 — An email from Larry Ausley, DWQ Laboratory Section, emails results from an ad
hoc experiment of 3 spent bauxite samples collected by Ellen Huffman from sand at the fill area August
23, 2005. See file for preservation and test method. Results were 3.7, 3.5, and 3.0, SUs respectively.
September 20, 2005 — NOWNRE WQ0002702 was issued for the August inspection for permit WQ
0002702 renewed in December 2004, for permit conditions. A requested site life estimate for the fill
area, and a long-range disposal plan were requested in the renewed permit. This NOWNRE was never
assessed because the permit is still in the adjudication process.
October 10, 2005 — A letter from ALCHEM stating that they are "sorry for the violations" and "we are
committing the time and the money to correct any problems here" AND "our new permit remains under
appeal".
October 11, 2005 — A letter from Alchem contains a copy of the business card for Nathan Cooke, with
BOYLE Consulting Engineering. The letter also states that James T. Hill, RLS, a surveying company in
Salisbury is re -surveying the property at Red Rd.
October 24, 2005 — ALCHEM receives the Geotechnical Exploration and Analyses report regarding the
earthen berm built around the fill area.
January 6, 2006 — NRE — for the renewed permit WQ0002702, was issued for the requested site life
estimate for the fill area and a long-range disposal plan. This NOWNRE was never assessed because the
permit was in the adjudication process.
January 26, 2006 — Deficiencies are noted in initial Laboratory Certification Inspection for pH
calibration.

January 30, 2006 — A call to BOYLE Engineering confirms that ALCHEM has received the
geotechnical report regarding the earthen berm and the fill area. The MRO requests a copy of this report
from ALCHEM.
March 1, 2006 — MRO receives the Boyle Engineering report.
ALCHEM file History
Page 9
November 16, 2006 — File note indicates that ALCHEM has hired DELTA Environmental for assistance
with site issues.
December 5, 2006 — An inspection reflects the same site conditions found in previous inspections,
including low pH in all three lagoons, low pH in stormwater 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 — A 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 NOV/NRE).
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. Andrews schedule.
January 19, 2007 — A certified letter from MRO responding to the January 8 letter from ALCHEM,
reiterating conditions in the NOV/NRE and the need for a 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 — A 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 held at MRO with Randall Andrews, ALCHEM. Mr. Andrews did not have
an alternative disposal plan. Mr. Andrews said that he would have a plan by February 2, 2007.

February 9, 2007 — A faxed letter from ALCHEM mentions disposal possibilities but no real plan. Asks
again for permission to remove sand to fill area.
February 14, 2007 — MRO letter to ALCHEM reminding ALCHEm that they are not to use the fill area.
February 14, 2007 — A letter from ALCHEM stating that they have retained Delta Consultants to
evaluate existing berm structure. Letter also states "current thoughts are to install a synthetic barrier..."
February 19, 2007 — A letter from ALCHEM regarding NOV for permit WQ0002702. Note: the NOV
was for groundwater violations. The letter did not offer any real solutions but again, requested
permission to remove sand to the fill area that is permitted under WQ0016338.
10

COUNTY ROWAN
RIVER BASIN :
REPORT TO MRO Regional Office
Other :
COLLECTOR(S) : W BELL
DIVISION OF WATER QUALITY
Chemistry Laboratory Report/ Water Quality
PRIORITY
❑ AMBIENT Ej QA
XD COMPLIANCE CHAIN OF CUSTODY
EMERGENCY VISIT ID
W❑ SAMPLETYPE
0 STREAM
❑ EFFLUENT
❑ LAKE
INFLUENT
ESTUARY
1
Lab Number
3W5063
Date Received:
8/12/2003
Time Received:
9:15 AM
Received By
Data Released :
AR
Date Reported:
8/20/2003
Estimated BOD Range: Station Location: UT TO SECOND CRK
Seed: Chlorinated: Remarks:
Station 9 Date Begin (yy/mm/dd) Date End (yy/mm/dd) Time Begin Time End I Depth - DM, DB, DBM Value Type - A, II, L Composite-T, S, II Sample Type
BOD310 m /L
COD High 340 m /L
COD Low 335 m /L
Coliform: MF Fecal 31616 /100ml
Coliform: MF Total 31504 /100ml
Coliform: tube Fecal 31615/100ml
Coliform: Fecal Strep 31673/100ml
Residue: Total 500 m /L
Volatile 505 m /L
Fixed 510 m /L
Residue: Suspended 530 m /L
Volatile535 m /L
Fixed 540 m /L
H 403 units
Acidity to pH4.5436 m /L
Acidity to pH8.3435 m /L
Alkalinity to pH8.3415 m /L
Alkalinity to pH4.5410 m /L
TOC680 m /L
Turbidity 76 NTU
Coliform Total Tube "/100 mis
Chloride 940 m L
Chill a: Tri 32217 ti /L
Chl a: Corr 32209 u /L
Pheo h tin a 32213 u /L
Color: True 80 C.U.
Color: H 83 pH= C.U.
Color: PH 7.6 82 C.U.
Cyanide 720 m /L
Fluoride 951 m /L
Formaldehyde 71880 m /L
Grease and Oils 556 m /L
Hardness Total900 m /L
Specific Cond. 95 umhos cm2
MBAS38260 m L
Phenols 32730 u /L
Sulfate 945 m /L
Sulfide 745 m /L
Boron
Tannin & Li in u /L
Hexavalent Chromium u /L
Bicarbonate m /L
Carbonate .m /L
NH3asN610
m /L
TKN an N 625
m /L
NO2 plus NO3 as N 630
m /L
P: Total as P 665
m /L
PO4 as P 70507
m /L
P: Dissolved as P 666
m /L
K-Potassium
m /L
XX
Cadmium 1027
2.OU u /L
X
Cr-Chromium:Total1034
25U u /L
X
Cu- Copper 1042
4.9 u / L
ICd-
X
15 u /L
-Ni-Nickel1067
Pb- Lead 1051
IOU u /L
X
Zn- Zinc 1092
43 u /L
IV -Vanadium
u /L
X
I A-Silver1077
5.OU u /L
12000 u /L
-Be llium1012
IOU u /L
a-Calcium916
25 m /L
RXA,I-'Alumirmm1105
o- Cobalt1037
50U u L
e- Iron 1045
13000 u /L
X
Li-Lithium1132
25U u /L
X
Mg- Magnesium 92
11 m /L
X
Mn-Manganese 105.
2400 u L
X
Na- Sodium 929
6.4 m /L
X
Arsenic:Total1002
IOU u /L
X
Se -Selenium 1147
5.OU u L
HA- Mercu71900
u /L
Ba_Barium
u /L
Or anocWorme Pesticides
Or ano hos horns Pesticides
Acid Herbicides
Base Neutral&Acid Extractable Organics
TPH Diesel Range
Pur eable Organics(VOA bottler 'd
TPH Gasoline Range
TPH BTEX Gasoline Range
Ph to lankton
COMMENTS:
gY.vsa. rer-r-.r r rhea ne�+nntnnr r,rq+
� a
"a
AUG 2 2 2003
'J a'.],5

D ISION OF WATER QUALITY WATER QUALIT IELD I)
COUNTY �Uf ►1 PRIORITY 1 SAMPLETY
RIVER BASIN (1 ' — (� e ❑
REPORT TO: ARO FR �R6RO WaRO WiRO WSRO TS
COMPLIANCE
AT BM
Other
Shipped by: Bus, CDStaff, Other
COLLECTOR(S): W Al P
Estimated BOD Range: 0-5/5-25/25-65/40-130 or 100 plus
�—�/
Seed: Yes ❑ No © Chlorinated: Yes ❑ No E
AMBIENT ' VSTREAM ❑ EFFLUENT
❑ LAKE ❑ INFLUENT
❑ EMERGENCY ' ❑ ESTUARY
@I,
For Lab Use ONLY
Lab Number:
'500—J
Date Received:
V Time:
Rec'd b :
DATA ENTRY BY:
From: Bu Courie Hand Del.
CK:
DATE REPORTED:
STATION LOCATION: Lt- f + O 5 e c e n d C vf,•P e /
REMARKS: l i D S `Ff P C1 iYi U In Cl of 03 Ly y) 5 7 000 YA � Stt�l iD' 1y► Q � O CA f jA SIf
Station 0
Date Begin (yy/mm/dd)
Time Begin
Date End
Time End
Depth DM DB DBM
Value Type
Composite
Sample Type
3(9
I :15 Pn1
A H L
T S B
C G GNXX
1
BOD5 310 mg/L
2
COD High 340 mg/L
3
COD Low 335 mg/L
4
Coliform: MF Fecal 31616 /100ml
5
Coliform: MFTotal 31504 /100ml
6
Coliform: Tube Fecal 31615 /100ml
7
Coliform: Fecal Strep 31673 /100ml
8
Residue: Total 500 mg(L
9
Volatile 505 mg/L
10
Fixed 510 mg/L
I 1
Residue: Suspended 530 mg/L
12
Volatile 535 mg/L
13
Fixed 540 mg/L
14
pH 403 units
15
Acidity to pH 4.5 436 mg/L
16
Acidity to pH 8.3 435 mg/L
17
Alkalinity to pH 8.3 415 mg/L
18
Alkalinity to pH 4.5 410 mg/L
19
TOC 680 mg/L
20
Turbidity 76 NTU
Chloride 940 mg/L
Chi a 70953 µg/L
Color: True 80 Pt -Co
Color:(pH ) 83 ADMI
Color:pH 7.6 82 ADMI
Cyanide 720 mg/L
Fluoride 951 mg/L
Formaldehyde 71880 mg/L
Grease and Oils 556 mg/L
Hardness Total 900 mg/L
Specific Cond. 95
MBAS 38260 mg/L
Phenols 32730 µg/L
Sulfate 945 mg/L
Sulfide 745 mg/L
NH3 as N 610 mg/L
TKN as N 625 mg/L
NO2 plus NO3 as N 630 mg/L
P: Total as P 665 mg/L
PO4 as P 665 mg/L
P: Dissolved as P 666 mg/L
IT
Cd-Cadmium 1027 µg/L
Cr-Chromium;Total 1034 µg/L
Cu-Copper 1042 µg/L
Ni-Nickel 1067 µg/L
Pb-Lead 1051 µg/L
Zn-Zinc 1092 µg(L.
Ag-Silver 1077 µg/L
Al -Aluminum 1105 µg/L
Be -Beryllium 1012 µg/L
Ca -Calcium 916 mg/L
Co -Cobalt 1037 µg/L
\/
Fc-Iron 1045 µg/L
Li -Lithium 1132 µg/L
Mg -Magnesium 927 mg/L
✓
Mn-Manganese 1055 µg/L
Na-Sodium 929 mg/L
Arsenic:Total 1002 µg/L
Sc-Selenium 1147 µg/L
Hg-Mcrcury 71900 µg/L
Organochlorine Pesticides
Organophosphorus Pesticides
Acid Herbicides
Basc/Neutral Extractable Organics
Acid Extractable Organics
Purgeable Organics (VOA bottle req'd)
Phytoplankton
Lab Use Onlv
Temperature on arrival:
Sampling Point %
Conductance at 25°C
Water Temperature °C
D.O. mg/L
pH
Alkalinity
Acidity
Air Temperature °C
�2-3eC/1O 5tC
rja/LI q
pH 8.3pH 4.5
pH4.5 pH 8.3
2
4
0
300
400
43 82242
0
Salinity 96°
Precipitation (in/day)
Cloud Cover%
Wind Direction (Deg)
Stream Flow Severity=1350
everity
Wind Velocity
Mean Stream Depth ft.
Stream Width ft.
80
5
2
6
1351
35
64
4

DIVISION OF WATER QUALITY
Chemistry Laboratory Report / Water Quality
W❑ SAMPLE TYPE
COUNTY ROWAN
PRIORITY
RIVER BASIN:
❑ AMBIENT E::] QA
STREAM
EFFLUENT
REPORT TO MRO Regional Office
X❑ COMPLIANCE 0 CHAIN OF CUSTODY
LAKE
INFLUENT
Other
EMERGENCY VISIT ID
ESTUARY
COLLECTOR(S) : W BELL
Lab Number : 3W5064
Date Received: 8/12/2003
Time Received: 9:15 AM
Received By DS
al o
Datatteleased : AR
Date Reported : 8/20/2003
Estimated BOD Range: Station Location: ALCHEM INC SEDIMENT BASIN EFFLUENT
Seed: Chlorinated: Remarks:
Station q Dale Begin (yy/mm/dd) Date End (yy/mm/dd) Time Begin Time End I Depth - DM, DB, DBM Value Type - A,11, L Composite-T, S, B I Sample Type
B0D310 m /L
COD High 340 m /L
COD Low 335 m L
Coliform: MF Fecal 31616 /100m1
Coliform: MF Total 31504 /loom]
Coliform: tube Fecal 31615 /100ml
Coliform: Fecal Step, 31673 /100ml
Residue: Total 500 m L
Volatile 505 m L
Fixed 510 m L
Residue: Suspended 530 m /L
Volatile535 m /L
Fixed 540 m /L
H 403 units
Acidity to pH 4.5 436 m /L
Acidity to pH 8.3 435 m /L
Alkalinity to PH8.3415 m /L
Alkalinity to pH 4.5 410 m /L
TOC 680 m /L
Turbidity 76 NTU
Colifonn Total Tube "/100 mis
COMMENTS:
Chloride940 m /L
Chi a: Tri 32217 u / L
Chi a: Corr 32209 u /L
Pheo h tin a 32213 u /L
Color: True 80 C.U.
Color: H 83 pH= C.U.
Color: pH 7.6 82 C.U.
Cyanide 720 m /L
Fluoride951 m /L
Formaldehyde 71880 `n /L
Grease and Oils 556 m /L
Hardness Total900 m /L
Specific Cond. 95 umhos cm2
MBAS38260 m /L
Phenols32730 u /L
Sulfate945 m /L
Sulfide745 m /L
Boron
Tannin & Li in u L
Hexavalent Chromium u /L
Bicarbonate m /L
Carbonate m /L
NH3 as N 610
m /L
TKN an N 625
m /L
NO2 plus NO3 as N 630
m /L
P: Total as P 665
m L
PO4 as P 70507
m L
P: Dissolved as P 666
m L
K-Potassium
m /L
X
Cd- Cadmium 1027
2.OU u L
X
Cr-Chromium:Tota11034
25U u /L
X
Cu- Copper 1042
19 u L
X
Ni-Nickel1067
92 u /L
X
Pb- Lead 1051
IOU u L
X
Zn- Zinc 1092
150 u L
V-Vanadium
u /L
X
A-Silver1077
5.OU u L
X
AI- Aluminum 1105
110000 u /L
X
Be- Beryllium 1012
IOU u /L
X
Ca- Calcium 916
88 m L
X
Co- Cobalt 1037
65 u /L'
X
Fe- Iron 1045
4300 u L
X
Li -Lithium 1132 190 u /L
X
Mg- Magnesium 92: 44 m /L
X
Mn-Manganese 105. 5200 v L
X
Na- Sodium 929 4.9 m /L
X
Arsenic:Tota11002 IOU u L
X
Se- Selenium 1147 5.OU u L
H - Mercury 71900 u L
Ba_Barium u L
Or anochlorine Pesticides
Or ano hos horus Pesticides
Acid Herbicides
Base Neutral&Acid Extractable Organics
TPH Diesel Range
Pur eable Organics(VOA bottle re 'd
TPH Gasoline Range
TPH BTEX Gasoline Range
Ph to lankton
iJl- lavW,vlvsnt�tap
Inre®�;�� �t,-,,tnl razrra
AUG 2 2 200S

I�'I ION OF WATER QUALITY WATER QUA Y FI
COUNTY PRIORITY SAMPLE TYPE
RIVER BASIN RIVER BASIN d La — 0"�" AMBIENT ❑ STREAM [R/EFFLUENT
REPORT TO: ARO FR RO O WBRO WiRO WSRO TS
AT BM COMPLIANCE ❑ LAKE ❑ INFLUENT
Shipped by: Bus, Dune) Staff, Other ❑ EMERGENCY I ❑ ESTUARY
COLLECTOR(S): (A)A/ 6 / j� J�/� r
Estimated BOD Range::.0-55/5-25/25-65/40-130 or 100 plus STATION LOCATION: A ✓ C 4% /t � Ti) C • 1 S Pd 1 %%�i j' j� hq Cy f�, e T �& e /j
Sced: Ycs❑ NoL�J Chlorinated: Yes El No
dMilmMoErNel.I Wd
Lab Number:
O V
Date Received:
� Time: ,
Rec'd b
DATA ENTRY BY:
-Dune From: Bu Hand Del.
CK:
DATE REPORTED:
Station # Date Begin (yy/mm/dd) Time Begin Date End Time End Depth DM DB DBM Value Type Composite Sample Type
(7 3 1 0$ I 0$ la`a5 PM A H L T S B C GNXX
I
BOD5 310 mg/L
2
COD High 340 mg/L
3
COD Low 335 mg/L
4
Coliform: MF Fecal 31616 /100ml
5
Coliform: MFTotal 31504 /100ml
6
Coliform: Tube Fecal 31615 /100ml
7
Coliform: Fecal Strep 31673 /100ml
8
Residue: Total 500 mg/L
9
Volatile 505 mg/L
10
Fixed 510 mg/L
I I
Residue: Suspended 530 mg/L
12
Volatile 535 mg/L
13
Fixed 540 mg/L
14
pH 403 units
15
Acidity to pH 4.5 436 mg/L
16
Acidity to pH 8.3 435 mg/L
17
Alkalinity to pH 8.3 415 mg/L
18
Alkalinity to pH 4.5 410 mg/L
19
TOC 680 mg/L
20
1
Turbidity 76 NTU
Chloride 940 mg/L
Chl a 70953 µg/L
Color: True 80 Pt -Co
Color:(pH ) 83 ADMI
Color:pH 7.6 82 ADMI
Cyanide 720 mg/L
Fluoride 951 mg/L
Formaldehyde 71880 mg/L
Grease and Oils 556 mg/L
Hardness Total 900 mg/L
Specific Cond. 95
MBAS 38260 mg/L
Phenols 32730 µg/L
Sulfate 945 mg/L
Sulfide 745 mg/L
NH3 as N 610 mg/L
TKN as N 625 mg/L
NO2 plus NO3 as N 630 mg/L
P: Total as P 665 mg/L
PO4 as P 665 mg/L
P: Dissolved as P 666 mg/L
Cd-Cadmium 1027 µg/L
Cr-Chromium;Total 1034 µg/L
Cu-Copper 1042 µg/L
Ni-Nickcl 1067 µg/L
-Lead 1051 µg/L
Zn-Zinc 1092 µg/L
Ag-Silvcr 1077 µg/L
AI -Aluminum 1105 µg/L
Be -Beryllium 1012 µg/L
Ca -Calcium 916 mg/L
Co -Cobalt 1037 µg/L
Fe -Iron 1045 µg/L
f
Li -Lithium 1132 µg/L
Mg -Magnesium 927 mg/L
Mn-Manganese 1055 µg/L
Na-Sodium 929 mg/L
Arsenic:Total 1002 µg/L
Se -Selenium 1147 µg/L
Hg-Mercury 71900 µg/L
Organochlorinc Pesticides
Organophosphorus Pesticides'
Acid Herbicides
Basc/Ncutral Extractable Organics
Acid Extractable Organics
Purgeablc Organics (VOA bottle req'd)
Phytoplankton
Lab Use Only
Tem erature on arriv
Sam lin Point %
Conductance at 25"C
Water Temperature *C
D.O. mg/L
pH
AlkalinityAcidityAir
Temperature "C
o
/ Q
3'
pH 5
pH 4.5 p
2
4
0/ `
300
400 `� V
244 4314
243 2242
20
Salinity 96o
Precipitation (in/day)
Cloud Cover %
Wind Direction (Deg)
Stream Flow SeverityT135�O
rbidity Severity
Wind Velocity
Mean Stream Depth ft.
Stream Width ft.
80
5
2
6
1351
35
64
4
5io J(e) 3 °C of\ %/$ - r6/ f f C rP r,`r,ai6ark
N_'dn phl 0;.2.5AAt

Report to 0-0 o W
WATER QUALITY SECTION
CHAIN OF CUSTODY (COC) RECORD
NC DENRIDWQ LABORATORY (check one): CENTRAL 1 [ ARO [ [ WaRO
Page J_ of
For Investigation of: i I It T h - A LC I'LTAITnr- • -�nC
Sample collector (print name) i
and DM-1 forms completed by: W P_ S lee e ��
Sample collector's signature: �.
-Ly
Field storage conditions and location (when applicable):
mmo,,m e Hw f�5erda+,on 4nCl 5fhf0
,, //
5-f-o f ej Ems. 3 oC .•r4 f o fr 13 e
e A C06bt W/,cP t fcVh rb/g
Lab Use Only
LAB NO.
STATION NO.
STATION LOCATION
DATE
SAMPLED
TIME
SAMPLED
NUMBER
OF
CONTAINERS
0
o e Cf
k —> u 5ffeam ciounsir
$ /$/0,3
[ JL c
M cn
GJ
ALC
ta'
AI
Relinq ish by (signatu e):
Date
Time
ic;mq
Rec 4 e signature
to
( 03
iEne
• P�
Relinquished by (signature):
Date
Time
Received by (signature):
ate
Time
Relinquished by (signature):
Date
Time
Received by (signature):
Date
Time
Method of Shipment circle one):
State Couri Hand -delivered Federal Ex ress UPS Other:
Security Type and Conditions:r4A
Sealed y: (3
$/►[ 1103
� Id : �7 A
Broke �
INTRALABORATORY CHAIN OF CUSTODY - Lab Use Only
LAB NUMBERS
FROM THROUGH
NUMBER
BOTTLES
ANALYSES
REQUESTED
RELINQUISHED
BY:
RECEIVED
BY:
DATE
TIME
lJ�rr (,�4- �i�l�lri��th19�
1\A1i
t:'
rttit�
Y19V ems. P`4'•ri,. I.j'�:m.4:���
c"'6
QA\Forms\Sample Receiving\COC form WQ 11 t r n ! 17�0

05/02/2003 09:02 7042798418 ALCHEM INC PAGE 01
ALCIH[EM, INC.
8135 RED ROAD
ROCKWELL, NC 28138
704-279-7908 FAX: [phone]
[e-mail]
FAX
1110M
Mr. Wes Bell
Wayne Drye
FAX NUMBER.
DATE
704-663-6040
5/2/2003 ....__.........
........ ........... .--....... ....... ... ............................. .... .
COMPANY
TOTAL NO OF PAGES fNCLUDING COVER.
NCDENR
PHONE NUMBER:
704-663-1699
RE:
I am sending to you the Annual Residual Sampling Summary Form that was
sent to Raleigh in February 2003 along with the sand analyses. I am also
sending the visual inspection sheets of the lagoons.
Please let us know if we can be of further help to you.
Thanks,
Wayne

ANNUAL RESIDUAL SAMPLING SUMMARY FORM
Attach this form to the corresponding laboratory analysis
Please nole that your permit may contain additional parameters to be analyed than those required to be summarized on this form_
Permit Number W00016338
Facility Name ALCHEM, INC. LABORATORY 1 TBL LA80RATORY
NPDES # 2)
a Mt) ) (r®ouel Wr Faclifies) 3 )
WWTP Name
tesidual Analysis Data
Dale SarrVied (grab) or 08/09102 01/15/03
Date Corrq=ited
Percent Solids
II,. Jam. �L•l
�C�iiii_iii• �iriYiFi
W
Total Phosphorus
X n��PP tl �r(t/���® 02105/03
(SIGNATURE OF PREPARER) DATE
I certify, under penally of law. that this document was prepared under my direction or supervision in accordance with a system
designed to assure that qualified personnel property gathered an evafualed the information submAled I am aware that there are
significant penalties for submitting false informalion including the possib)ily of fines and imprisonmenl for knowing violations "
DEM FORM SSF (10194)

05/02/2003 09:02
el,
7042798418
elementOne
Pam Hester
TBL Laboratory
P,O, Box 589
Lumberton, NC 28359
Sample #
Sample Matrix
Date Sampled 1/7/03
Delivered by Picked Up
Page 1 of 1
ALCHEM INC
Element One Inc.
5022-C Wrightsville Ave.
Wilmington, NC 28403
Phone: [phone]
Fax: [phone]
[e-mail]
FINAL REPORT OF ANALYSES
PAGE 03
January 15, 2003
Client Project Name ALCHEM, Inc.
Client Project Number TBL-12614
PO Number
E1 Project Number e1274
Sample ID
Lagoon #3
Sample Type
Date Received 1 /9/03
Time Sampled
0800 Time Received 1345
Sampler
Wayne Drye Received by CMO
E1 Sample #
1274-1
Parameter
Result
Unit
Dilution
DL
Method
Date
Aluminum
7900
mg/Kg
500
0.4
EPA 200.8
1/13/03
Arsenic
< 0.4
mg/Kg
1
0.4
EPA 200.8
1/13/03
Barium
36.9
mg/Kg
1
0.4
EPA 200.8
1/13/03
Cadmium
< 0.2
mg/Kg
1
0.2
EPA 200.8
1/13/03
Calcium
583
mg/Kg
20
1.6
EPA 200.8
1/13/03
Chromium
6.64
mg/Kg
1
0.4
EPA 200.8
1/13/03
Copper
2.13
mg/Kg
1
0.2
EPA 200.8
1/13/03
Lead
14.3
mg/Kg
1
0.2
EPA 200.8
1/13/03
Magnesium
126
mg/Kg
1
0:8
EPA 200.8
1/13/03
Manganese
3.30
mg/Kg
1
0.4
EPA 200.8
1/13/03
Mercury
0.067
mg/Kg
1
0.01
EPA 245.1
1/13/03
Nickel
0.554
mg/Kg
1
0.4
EPA 200.8
1/13/03
Phosphorus
43.0
mg/Kg
1
0.8
EPA 200.8
1/13/03
Selenium
< 0.4
mg/Kg
1
0.4
EPA 200.8
1/13/03
Silver
< 0.2
mg/Kg
1
0.2
EPA 200.8
1/13/03
Sodium
101
mg/Kg
1
0.8
EPA 200.8
1/13/03
Zinc
1.75
mg/Kg
1
0.4
EPA 200.8
1/13/03
pH
3,73
SU
1
EPA 9045C
1/13/03
en Smith, Laboratory Director
NC Certifications' DW 37788 and DWQ DENR 604

05/02/2003 09:02
7042798418
ALCHEM INC
PAGE 04
elementOne
Pam Hes(Pr
TBL Lziboratory
P 0 Box 589
Lumberton. NC 28359
Sraniple #
Sample Matrix
Dale Sampled 7124102
Delivered by Picked Up
Page_ 1 of 1
Element One Inc.
!3022-C W, iOhtsvillp Ave,
Wilmington, NC 28403
Phone: [phone]
Fax, 910 792-6853
ellab@hutmail coin
FINAL REPORT OF ANALYSES
August 9, 2002
Client Project Name ALCHEM, Inc
Client Project Number TBL-12141
PO Number
E1 Project Number e0625
Sample ID
Lagoon #3
Sample Type
Date Received 7/26/02
Time Sampled
0800 Time Received 1640
Sampler
Wayne Drye Received by BGH
E 1 Sample #
0625-1
Palametel
Result
Unit
Dilution
DL
Method
Date
AILP'llinUrn
10700
mg/Kg
1000
08
EPA 200.8
8/5102
Arsenic
3.05
mg/Kg
1
0A
EPA 200.8
8/5/02
Barium
21.9
mg/Kg
1
04
EPA 200 8
8/5!02
C;rniuIli
2.2.0
mg/Kg
1
0.2
EPA 200,8
8/5102
(. a1(":I(irr1
95 0
mg/Kg
1
1,6
EPA 200.8
8/5/02
Chr(,)rT)iurri
81,1
mg/Kg
1
04
EPA 200 8
8/5/02
Copper
18 8
mq/Kg
1
02
EPA 200 8
8/5/02
L.uad
126
mg/Kg
1
0.2
EPA 200.8
8/5!02
Madnesiurn
25.4
rrlg/Kg
1
0 8
EPA 200.8
8i5102
Manganese
0,70
mg/Kg
1
0,4
EPA 200.8
8i`5102
rvler,,ury
0 033
mg/Kg
1
0 01
EPA 200.8
8111!0"
N i c ke,1
7 36
mg/Kg
1
04
EPA 200.8
8/5/02
Phosphorus
12 8
mg/Kg
1
0 8
EPA 200 8
8/5/02
Selenium
< 0.4
mg/Kg
1
0,4
EPA 200.8
8/5/02
`>ilvc:�r
0,77
mg/Kg
1
0 2
EPA 200 8
8/5102
Sodium99
0
mg/Kg
1
0 8
EPA 200.8
8/5''02
Zinc.
20.2
mg/Kg
1
0 4
EPA 200 8
8/5/02
I)H
3.4
SU
1
EPA 9045C
8/9i02
r�
/�er)Srnith, Lat)oratory Director
NC Certifications: DW 37788 and DWQ DENR 604

S0 39dd DNI W3HD-lV 8ib86LZvOt Z0:60 E00Z/Z0/90

05/02/2003 09:02 , 7042798418
ALCHEM INC
PAGE 06

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Item 3. Preclusion of Best Usage
On May 81h, DWQ visited the site and confirmed that in excess of 400 linear feet
of stream impacts (see attached photos) occurred due to the deposition of sediment from
the holding area. Large amounts of sediment was carried from this site by stormwater
and deposited in to surface waters. Specifically, staff observed sediment accumulations
up to 24 inches in the impacted stream. In addition, sediment deposition in the riparian
areas adjacent to the stream was up to 12 inches deep. The sediment observed in the
stream represents a removal of best usage and is a stream standard violation.
Specifically, 15A NCAC 213 .0211 (2) states that the preclusion of best usage, which
includes aquatic life propagation, biological integrity, wildlife, and secondary recreation,
and agriculture, represents a water quality standard violation.
This Office requires that violations, as detailed above, be abated immediately. Also
please note, these violations and any future violations are subject to civil penalty
assessment of up to $25,000.00 per day for each violation. This Office requests that you
respond to this letter, in writing, within 20 days of receipt of this Notice. Your response
should address the following items:
- Please provide a map that details the number of linear feet of stream channel
impacted by sedimentation. You should also provide maps indicating the
accumulations of sediment in the stream, the impacts streamside (riparian) areas, and
any wetland impacts.
You should plan to restore the stream and riparian areas. This will require you
develop a restoration plan for the streams and riparian zone (streamside areas). This
issue should be addressed immediately. Also, must contact the Division of Land
Resources and discuss whether these efforts will require a modification to the erosion
and sediment control plan. It is also required that that you contact the MRO for
guidance with respect to stream restoration efforts. Please keep in mind that many
portions of the stream will require laborers to remove the sediment by hand.
- A Restoration Plan for the stream and buffer impacts should be submitted to
Mooresville Regional Office for our review. This plan should include the following:
1) Stream - This plan should detail sedimentation removal methods and a Physical
Monitoring Plan. In this plan you should 1) specifically address the location of
the riparian area to be restored, 2) the sedimentation depths in both the stream and
riparian areas, 3) methods of sediment removal, 4) locations of spoil placement
and stabilization, 5) a time line with dates that explains when the restoration will
be started and completed, 6) report on how you can ensure that future impacts to
stream and the riparian zone will not occur.
- Please clearly indicate what efforts you have taken to temporarily stabilize the stream
banks and streamside areas. This issue should be addressed immediately in order to

help avoid additional stream standard violations. Also please clearly indicate if you
are currently compliance with your permit NCGO10000. Also, please provide
monitoring records as requested in Item I above.
It is required that you contact the Mooresville Regional Office of the Division of
Land Resources at [phone], and the U.S. Army Corps of Engineers at (828)
271 -7980 ext. 5. These contacts are necessary to ensure that _your restoration efforts
are in compliance with Land Resources and Section 404 of the Clean Water Act
requirements.
Thank you for your attention to this matter. This Office is planning to send a
recommendation for enforcement to the Director of the Division of Water Quality
regarding these issues and any future/continued violations that may be encountered. Your
response to this correspondence will be considered in this process. Should you have any
questions regarding these matters, please contact Mike Parker or myself at (704) 663-
1699.
Sediment filled stream channel on right side of photo. Deposition in "flood plain".
Approximately 1+ acres was observed to be impacted in addition to the stream channel.

Deposition at the edge of the complainants yard approximately 300 feet downstream from
Alchem.
Deposition of sediment 400+ ft. downstream of Alc�pm.