WQ0002702_Regional Office Historical File Pre 2018 (4)

North Carolina -Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
—{ u Division of Water Quality
AQUIFER PROTECTION SECTION
January 6, 2006
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Randall Andrews, Owner
ALCHEM, Inc.
2042 Buie Philadelphus Road
Red Springs, NC-28377
and
ALCHEM, Inc.
8135 Red Road -
Rockwell, NC 28138
Subject: 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.
This letter will serve as a notice of deadline for ALCHEM to supply information requested in the above
referenced permit dated December 28, 2004, and the September 20, 2005, Notice of .Violation/Notice of
Recommendation for Enforcement. Your response to the Notice of violation dated October 11, 2005, stated
that you had retained the services of Boyle Engineering and that you would have the information "very soon."
As a permit holder, it is your responsibility to provide the information to the State. You also stated that your
new permit was under appeal. The appeal was dismissed on July 29, 2005 (see attached). This office must
receive the requested information by January 19, 2006. If not received by this date, this office will proceed to
enforcement.
This information includes:
• Permit condition 14, which 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.
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

Page 2 of 2
January 6, 2006
• Permit condition 15, which 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.
Guidance regarding how to comply with these permit conditions were discussed with you and your
consultant, John D. Reuscher, Mid -Atlantic Assoc., in detail at the meeting at the Mooresville Regional Office
on May 11, 2005.
If you have justification that these violations are caused by circumstances beyond your control, or you
have an explanation that you wish to present following receipt of this notice, please respond by January 19,
2006. 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 day per violation as well as criminal
penalties for violations of state environmental laws 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 Notice of Enforcement, as well as the permit number. Please
remember, this office must receive the requested information, by January 19, 2006. If you have any
questions concerning this matter, please do not hesitate to contact Ms. Huffman at [phone].
Sinc, rely,
Andrew H. Pitner, P.G.
Mooresville Region
Qi inmrwicnr
■ Complete items 1, 2, and 3. Also complete
Attachment — Order c item 4 if Restricted Delivery is desired.
Is Print your name and address on the reverse
so that we can return the card to you.
cc: Land Aplicationl ■ Attach this card to the back of the mailpiece,
Central Files - or on the front'if space permits.
1: Article Addressed to:
ALCHEM, INC.
8135 RED ROAD
ROCKWELL ` NC 28138
ap/eh 1/6/06
A. Signature
X ❑ Agent
❑ Addressee
B. Received by (Printed Name) C. Date of Delivery
D. Is delivery address different from item 1? ❑ Yes
If YES, enter delivery address below: ❑ No
3. ervice Type
Certified Mail ❑ Express Mail
❑ Registered ❑ Return Receipt for Merchandise
❑ Insured Mail ❑ C.O.D.
4. Restricted Delivery? (Extra Fee) ❑ Yes
z ._.,... Zo521', H6p 00013492: 7631
F PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540

Michael F. Easln., Governor
William G. Ross Jr.. Secretary1� ' "
North Carolina Department of Environment and Natural Resources t/
Alan W. Klimek, P. E. Director
Division of Water Quality
Coleen H. Sullins, Deputy Director
Division of Water Quality
August 19, 2003
CERTIFIED MAIL
RETURN RECEIPT REQUESTED 7001 2510 0004 8287 6432
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]
V"A
Nr-DENR
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.
Should you have questions, please do not hesitate to contact Mr. Bell or me at (704) 663-
110001]
Attachments
Sincerely,
UNITED STATES POSTAL SERVICE
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Permit No. G-10- w
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Wayne Drys
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WATER QUALITY SECTION, E� � ; �
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919 NORTH MAIN STREET "'' r�� t4
MOORESVILLE NC 28115
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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: August 7 and 8, 2003
INVESTIGATED BY: Wes Bell and Ellen Huffmahll�"TIME 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 the unnamed tributary
from the residual storage area. On 8/8/03, Mr. Bell and Mrs. Huffman observed the same
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.

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Certified Mail
Return Receipt Requested
Mr. Randall Andrews
Alchem, Inc.
8135 Red Road
Rockwell, North Carolina 28138
Dear Mr. Andrews:
Michael F. Easley, Gover r,
William G. Ross, Jr.,Secretary
North Carolina Department of Environment and Natural Resources
Gregory J. Thorpe, Ph.D.
Acting director
Division of Water Quality
January 15, 2002
Subject: Notice of Violation
Permit # WQ0016388
Bauxite Residuals Reuse Program
Rowan County
A review of our records shows permit No. WQ0016398 was issued on March 1, 1999 for the
land application of sludge generated by your wastewater treatment facility. A review of our files
conducted by Mrs. Ellen Huffman with this Office indicate that the Division of Water Quality has
not received monitoring reports as required by Section III, parts 3 and 4 of your permit.
It is requested that Alchem, Inc. respond to this Notice within ten (10) working days of receipt of
this letter. Your response should include mitigating circumstances for the violation and a discussion of
any new procedures that will be implemented to prevent recurrence. Please reference the subject permit
number when providing your response.
Please be aware that Alchem, Inc. may be assessed civil penalties in this matter pursuant to G.S.
143-215.6A(a)(2), which provides that a civil penalty of not more than twenty five thousand dollars
($25,000.00) per violation per day may be assessed against a person who violates any permit
condition, classification, standard, limitation, or management practice established pursuant to G.S.
143-214.1, 143-214.2 or 143-215.
NEDE�; .
Customer Service Mooresville Regional Office PHONE [phone]
1 800 623-7748 919 North Main Street, Mooresville, NC 28115 FAX [phone]

Mr. Randall Andrews
Alchem, Inc.
8135 Red Road
Rockwell, North Carolina 28138
page 2
If you have any questions regarding this Notice, please do not hesitate to call Mrs. Huffman
or me at 704-663-1699.
Sincerely,
x .✓� -L
D. Rex Gleason, P.E.
Mooresville Region Water Quality Supervisor
cc: Non -Discharge Compliance / Enforcement Unit
Non -Discharge Permitting Unit
Central Files
■ Complete items 1, 2, and 3. Also complete
item 4'if ;Restricted Delivery is desired.
■ ,Print your name and address on the reverse
Iso that we can return the card to you.
■ Attach this card to the back of the mailpiece,
or on the front if space permits.
1. Article Addressed to:
MRRANDALLANDREWS
ALCI EKWX
8135 RED-RD 'O'
---t
A. Received by (Please Print Clearly) I B. Date of Delivery
C. Sig ture
__ _.::..... Agent
X� Addre
D. Is delivery address different from item 1? ❑ Yes
E enter delivery address below: ❑ No
3—Faprvice
ROCKWELL NC 28138
W�
CedE ail
❑ Express Mail
sd
❑ Return Receipt for Merchandise
Mail
❑ C.O.D.
1� O
4, ricted Delivery? (Extra Fee) ❑ Yes
2. ArtichNumber ( py rom;service1label).
PS Form 3811,. July,1999 .. ,
Domestic Return Receipt
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102595-99-M-1789

1
4
F WAT
�Q 9 Michael F. Easley
Governor
William G. Ross Jr., Secretary
Department of Environment and Natural Resources
4 Kerr T. Stevens
Division of Water Quality
GROUNDWATER SECTION
April 12, 2002
Industrial and Agricultural Chemicals, Inc.
2042 Buie Philadelphus Road
Red Springs, North Carolina 28377
Attention: Randall Andrews
Dear Mr. Andrews:
On March 14, 2002, this office received your response to the Notice of Violation (NOV) issued
January 7, 2002 regarding violation of the NC groundwater quality standards for aluminum at the
referenced facility. Based upon staff review of the report, I am hereby rescinding the NOV.
The installation and sampling of the two new downgradient monitoring wells (MW-lR and
MW-2R) suggests that the original monitoring wells may not have been providing accurate data about
the concentration of aluminum in the surficial aquifer. We also agree with your consultant that the
upgradient bedrock supply well may not represent the background concentration of aluminum in the
surficial aquifer.
No further investigative action is necessary at this time. However, an increase in the
concentration of aluminum in the new wells may require further assessment, including but not limited
to, installation of an upgradient monitoring well.
Should you have any questions, please contact Peggy Finley by phone at 704/663-1699, ext.
238 or via email at [e-mail].
cc: John D. Reuscher, P.G. - Mid -Atlantic Assoiates., P.A.
MAF/alchem.nop
NCDENR
Customer Service
1 800 623-7748
RE: Rescission of Notice of Violation
Non -Discharge Permit No. WQ0002702
Alchem, Inc. - Rockwell Facility
Rowan County
Sincerely,
Matthew J. Heller, P.G.
Regional Groundwater Supervisor
Division of Water Quality / Groundwater Sectior9
1636 Mail Service Center Raleigh, NC 27699-1636
Phone: [phone] Fax: [phone] Internet: httD://www.aw.ehnr.state.nc.us

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Michael F. Easiey
Governor
William G. Ross, Jr., Secretary
Department of Environment and Natural Resources
Gregory J. Thorpe, Ph.D.
Actina Director
Division of Water Quality
GROUNDWATER SECTION.
January 7, 200/4—
CERTIFIED MAIL
R T URN F, .IPT REQUESTED '1 3 -V v e)
Industrial and Agricultural Chemicals, Inc.
2042 Buie Philadelphus Road
Red Springs, North Carolina 28377
Attention: Randall Andrews
Subject: NOTICE OF VIOLATION
Title 15A NCAC Subchapter 2L
Groundwater Qualiry Violations
Non -Discharge Permit No. VTQ0002702
Alchem, Inc. 8135 Red Rd., Rockwell
Industrial Recycle - Bauxite Process
Rowan County
Dear Mr. Andrews:
Thank you for submitting the requested groundwater data for the subject site. This letter is to formally notify
you of violations of 15A NCAC 2L (Groundwater Quality Standards) and to advise you of what you are required to
do to correct these violations. The violations include, but are not limited to the following -
Well No. Date Constituent Concentration Standard
MW-1 I 11/7/01 I Aluminum I 684 ma/L.
MLU-? /7/(11 4111miTillm 17 a
* if not naturally occurring or if no standard is specified, the constituent shall not be permitted to exist above
background concentrations. Background concentration is .014 mg/L, based on sampling of the upgradient
water supply well.
Due to these violations at or beyond the compliance boundary, you are required to take the following actions
in accordance with applicable provisions in 15A NCAC 2L .0106 (d)(2):
''�4D;NF.
Customer Service
1 &00 62�— 7745
Division of Water Quality / Groundwater Section
919 North Main Street Mooresville, NC 2311S
Phone: [phone] Fax: (7D4) 66'3-6040 Internet: htto://gw.ehnr.state.nc.us

Randall Andrews
January 7, 2001
Page Two
Take immediate action to eliminate the source or sources of contamination;
2. Submit a report to the Mooresville Regional Office assessing the cause, significance and extent of
the violation; and
Implement an approved corrective action plan for restoration of groundwater quality in accordance
with a schedule established by the Director of the Division of Water Quality, or his designee. In
establishing a schedule the Director, or his designee shall consider any reasonable schedule proposed
by the person submitting the plan. A report shall be made to the Health Director of the county or
counties in which the contamination occurs in accordance with the requirements of Rule .0114(a) in
this section.
Please note that the site assessment should include the following:
1. The source and cause of contamination;
2. Any imminent hazards to public health and safety and actions taken to mitigate them in accordance
with Paragraph (f) of this Rule;
All receptors and significant exposure pathways;
4. The horizontal and vertical extent of soil and groundwater contamination and all significant factors
affecting contaminant transport; and
Geological and hydrogeological features influencing the movement, chemical, and physical character
of the contaminants.
To assist you in conducting the investigation and preparing the Comprehensive Site Assessment (CSA),
please consult Volume I of the Groundwater Section Guidelines for the Investigation and Remediation of Soils and
Groundwater (DENR, July, 2000- available via the internet at http://gw.ehnr.state.ne.us). In the event that the CSA
shows impact to soils or groundwater, you may be required to submit additional information and/or develop and
implement a Corrective Action Plan (CAP) in accordance with Title 15A NCAC 2L .0106.
All site assessment activities must be conducted under the direct supervision of a North Carolina Licensed
Geologist or Professional Engineer. Your assessment report must be submitted to the Mooresville Regional Office
for review within 90 days of receiving this letter. Failure to submit the required reports or failure to expeditiously
eliminate the contaminant source and restore groundwater quality in the affected area may result in the
recommendation of enforcement action.
We request that you respond to this notice within fifteen working days after its receipt. In your response,
please confirm your intent to comply with the above requirements by specifying the actions you plan to undertake to
correct the violations and by submitting a proposed schedule for accomplishing these actions.

A T -
Michael F. Easley
Govi�rmor
Li
CERTIFIED MAIL
RETURN RECEIPT REQUESTED G rY, 'A -7 a `' `1 3 Sr L'
Industrial and Agricultural Chemicals, Inc.
2042 Buie Philadelphus Road
Red Springs, North Carolina 28377
Attention: Randall Andrews
Dear Mr. Andrews:
William G. Ross, Jr., Secretary
Department of Environment and Natural Resources
Subject: NOTICE OF VIOLATION
Title 15A NCAC Subchapter 2L
Groundwater Quality Violations
Non -Discharge Permit No. WQ0002702
Alchem, Inc. 8135 Red Rd., Rockwell
Industrial Recycle - Bauxite Process
Rowan County
Gregory J. Thorpe, Ph.D.
Acting Director
Division of Water Quality
GROUNDWATER SECTION
January 7, 2001
3 ?- r) 3
Thank you for submitting the requested groundwater data for the subject site. This letter is to formally notify
you of violations of 15A NCAC 2L (Groundwater Quality Standards) and to advise you of what you are required to
do to correct these violations. The violations include, but are not limited to the following:
Well No.
Date
'Constituent
Concentration
T Standard
MW-1
11/7/01
Aluminum
.584 mg/L
_7
/
v
* if not naturally occurring or if no standard is specified, the constituent shall not be permitted to exist above
background concentrations. Background concentration is .014 mg/L based on sampling of the upgradient
water supply well.
Due to these violations at or beyond the compliance boundary, you are required to take the following actions
in accordance with applicable provisions in 15A NCAC 2L .0106 (d)(2):
N-'-C?ENR.
Customer Service Division of Water Quality / Groundwater Section
1 800 623-7748 919 North Main Street Mooresville, NC 28115
Phone: [phone] Fax: [phone] Internet: http://gw.ehnr.state.nc.us

Randall Andrews
January 7, 2001
Page Three
We appreciate your attention and prompt response in this matter. If you have questions, please do not
hesitate to call Peggy Finley at 704/663-1699, ext. 238 or via email at: peggy.fnley cL.ncmail.net
Sincerely
Matthew J. Heller, P.G.
Regional Groundwater Supervisor
cc: Brian Wootton-GWS, Permits & Compliance Unit
Rowan County Environmental Health
Z ii - n 14 -4zj� r-, a n - M a� to q S
Enclosures: Comprehensive Site Assessment Guidelines
Approved Methods for Groundwater Analyses
Approved Methods for Soil Analyses
MAF/alchem.nov

MID -ATLANTIC
ASSOCIATES, P.A.
Environmental Solutions
PO Box 669004 /Charlotte /North Carolina 128266-9004
800-750-0298 1704-398-9112 1704-398-9114 Facsimile
www maaonline.com
March 13, 2002
Ms. Peggy Finley
North Carolina Department of Environment
And Natural Resources
Division of Water Quality
Groundwater Section
919 North Main Street
Mooresville, North Carolina 28115
RECEIVED
MAR 14 2002
NC DEPT. OF ENVAON14EN1
AND NATURAL RESOURCES
MOORESVi5lr REGIONAL OFFICE
Subject: GROUNDWATER ASSESSMENT AND SAMPLING RESULTS
ALCHEM, INC. SITE
ROCKWELL, ROWAN COUNTY, NORTH CAROLINA
MID -ATLANTIC PROJECT NO.: C291
Dear Ms. Finley:
On behalf of Alchem, Inc. (Alchem), Mid -Atlantic Associates, P.A. (Mid -Atlantic) is
pleased to submit this letter summarizing additional groundwater assessment and
sampling activities conducted by at the referenced site. The subject facility operates
two lagoons to recycle wastewater generated from the on -site bauxite processing
operation (non -discharge permit #W00002702).
BACKGROUND
Two shallow, Type II groundwater monitoring wells (MW-1 and MW-2) were located
downgradient of the existing lagoons. The wells were installed to depths of
approximately 20 feet below land surface (BLS). In addition, an upgradient water -
supply well installed to a depth exceeding 300 feet BLS was utilized as a background
compliance point. Based on the information provided for our review, total aluminum
was detected in groundwater samples collected from monitoring wells MW-1 and
MW-2 on November 17, 2001 at concentrations of 0.584 milligrams per liter
(mg/L) and 1.12 mg/L, respectively. The sample collected from the water -supply
well exhibited a total aluminum concentration of 0.014 mg/L. According to Mr.
Wayne Drye, Plant Manager of Alchem, the water samples collected from the
monitoring wells were historically high in colloidal material.

Groundwater Assessment and Sampling Results March 13, 2002
Alchem, Inc. Site Page 2
Rockwell, North Carolina
On January 7, 2002, Alchem was issued a Notice of Violation (NOV) from the
North Carolina Department of Environment and Natural Resources (NCDENR),
Division of Water Quality (DWQ). The NOV indicated that the aluminum
concentration detected in MW-1 and MW-2 exceeded the background
concentration. For purposes of the NOV, the upgradient water -supply well was
established as the background compliance point.
A groundwater quality standard for aluminum has not been established by the
NCDENR. In addition, the Environmental Protection Agency (EPA) has not
established a primary Maximum Contaminant Level (MCL) or MCL Goal for
aluminum. A Secondary MCL for aluminum of 0.05 mg/L to 0.20 mg/L has been
established by the EPA. However, Secondary MCLs are unenforceable federal
guidelines regarding taste, color, odor, and other non -aesthetic effects of drinking
water. The EPA Region III has established a Risk -based Concentration (RBC) for
aluminum in drinking water of 37 mg/L.
According to the Risk Assessment Information System (RAIS) developed by the
United States Department of Energy, Office of Environmental Management,
aluminum is the most abundant metallic element in the lithosphere, comprising
approximately eight percent of the earth's crust. Aluminum occurs combined with
other elements most commonly aluminsilicates, oxides, and hydroxides in rock,
minerals, clays, and soil. Based on sampling conducted in 1998, the average
concentration of aluminum in the soils of Rowan County, North Carolina was
reportedly 25,500 milligrams per kilogram (Connell, K., Groundwater in North
Carolina, September 1999, pages 5-6). Dissolved aluminum levels in groundwater
vary with the pH and humic acid content of the aquifer. In addition, aluminum has
been measured in atmospheric precipitation in the United States at concentrations
up to 1.2 mg/L. Based on previous studies, aluminum concentrations in drinking
water in the United States range from less than 0.001 mg/L (California, Oregon,
and Washington) to 1.029 mg/L (South Carolina).
GROUNDWATER ASSESSMENT AND SAMPLING
On January 18, 2002, two new groundwater monitoring wells were installed by
Geologic Exploration, Inc. (GEX) of Statesville, North Carolina to replace existing
monitoring wells MW-1 and MW-2, which became dry and have historically
contained little water column. The well construction records are contained in
Attachment A. The new monitoring wells were installed downgradient of the on -
site wastewater lagoons to depths of 45 feet BLS (MW-1 R) and 35 feet
MID -ATLANTIC
ASSOCIATES, P.A.
Environmental Solutions

Groundwater Assessment and Sampling Results March 13, 2002
Alchem, Inc. Site Page 3
Rockwell, North Carolina
BLS (MW-2R). The new monitoring wells were developed by GEX following
installation to remove fine sediment particles and improve the hydraulic connection
between _the borehole and shallow aquifer. On January 28, 2002, Mid -Atlantic
purged MW-1 R and MW-2R of approximately 42 gallons and 37.5 gallons of water,
respectively, until dryness. On February 12, 2002, Alchem personnel purged the
monitoring wells of three volumes using a submersible pump and collected
groundwater'quality samples for submittal to Oxford Laboratories of Wilmington,
North Carolina. At the laboratory, the water samples were analyzed for aluminum
according to EPA Method 200.8.
LABORATORY ANALYTICAL RESULTS
The laboratory analytical report for the groundwater samples collected from
monitoring wells MW-1 R and MW-2R are contained in Attachment B. As reported
by the laboratory, aluminum was detected in the water samples collected from
MW-1 R and MW-2R at concentrations of 0.089 mg/L and 0.077 mg/L,
respectively.
CONCLUSIONS AND RECOMMENDATIONS
Based on the recent laboratory analytical results of the groundwater samples
collected from the new monitoring wells (MW-1 R and MW-2R), the concentrations
of aluminum detected in the water table downgradient of the on -site lagoons are
within the Secondary MCL range of 0.05 mg/L to 0.20 mg/L and below the EPA
Region III RBC of 37 mg/L. In addition, the background compliance well (deep
facility water -supply well) should not be used as a background well for comparison
to concentrations detected in the shallow monitoring wells, since this well is a deep
water -supply well and not constructed similar to the monitoring wells.
Mid -Atlantic recommends the continued collection of water quality samples from
MW-1 R and MW-2R as required in Alchem's non -discharge permit. In addition, we
recommend that the NCDENR rescind the NOV issued to Alchem on January 7,
2002.
MID -ATLANTIC
ASSOCIATES, P.A.
Environmental Solutions

Groundwater Assessment and Sampling Results March 13, 2002
Alchem, Inc. Site Page 4
Rockwell, North Carolina
CLOSING
We look forward to your response to our recommendations. If you have any
questions, comments, or require additional information, please contact us at (704)
398-91 12.
Sincerely,
MID -ATLANTIC ASSOCIATES, P.A.
ohn D. Reuscher, P.G.
Senior Environmental Geologist
J"&'_ �e� �-'
Darin M. McClure, P.E.
Principal Engineer
Pc: Mr. Wayne Drye — Alchem, Inc., Rockwell, NC
ATTACHMENTS:
Attachment A Well Construction Records
Attachment B Laboratory Analytical Results
MID -ATLANTIC
ASSOCIATES, P.A.
Environmental Solutions

ATTACHMENT A
WELL CONSTRUCTION RECORDS

WELL CONSTRUCTION RECORD
North Carolina - Department of Environmental and Natural Resources - Division of Water Quality - Groundwater Section
WELL CONTRACTOR (INDIVIDUAL) NAME (print) MARK GETTYS CERTIFICATION # 2345
WELL CONTRACTOR COMPANY NAME GEOLOGIC EXPLORATION, INC. PHONEY [phone]
STATE WELL CONSTRUCTION PERMIT# ASSOCIATED WQ PERMIT#
(if applicable) (if applicable)
1. WELL USE (Check Applicable Box): Residential ❑ Municipal/Public ❑ Industrial ❑ Agricultural ❑
Monitoring ® Recovery ❑ Heat Pump Water Injection ❑ Other[] If Other, list Use
2. WELL LOCATION:
Nearest Town: ROCKWELL County ROWAN
8135 RED ROAD
(Street Name, Numbers, Corrummiry, Subdivision, Lot No., Zip Code)
3.OWNER: ALCHEM,INC
Address 8135 RED ROAD
(Street or Route No.)
ROCKWELL NC 28128
City or Town State Zin Code
[phone]
Area Code - Phone Number
4. DATE DRILLED 01-18-02
5. TOTAL DEPTH: 35.0 FEET
6. DOES WELL REPLACE EXISTING WELL? YES ❑ NO
7. STATIC WATER LEVEL Below Top of Casing: FT.
(Use " if Above Top of Casing)
8. TOP OF CASING IS 2.5 FT. Above Land Surfaces
'Top of casing terminated at/orbelo%v land surface requires a
sanance in accordance with 15A NCAC 2C .01 18.
9. YIELD (gpm): N/A METHOD OF TEST N/A
10. WATER ZONES (depth): N/A
11. DISINFECTION: Type
12. CASING:
Depth
From 0.0
To 15.0
From
To
From
To
13. Grout:
Depth
From 0.0
To 11.0
From
To
14. SCREEN:
Depth
From 15.0
To 35.(
From
To
15. SAND/GRAVEL PACK:
Depth
N/A
Amount
Wall Thickness
Diameter or WeighVFL
Material
Ft
21NCH SCH40
PVC
Ft.
Ft.
Material
Method
Ft.
Portland Bentonite
Slurry
Ft.
Diameter Slot Size
Material
Ft.
2.0 in. .010 in
PVC
Ft.
in. in
Size Material
Topographic/Land setting
❑ Ridge ❑ Slope ❑ Valley ® Flat
(check appropriate box)
Latitude longitude of well location
(degrees/minutes/seconds)
Latitude/longitude source: ❑ GPS ❑ Topographic map
(check box)
DEPTH DRILLING LOG
From To Formation Description
0.0 10.0 RED CLAY
10.0
23.0
23.0
35.0
ORANGE CLAY
TAN SILTY CLAY
LOCATION SKETCH
Show direction and distance in miles from at least
two State Roads or Countv Roads, inculed the road
numbers and common road names.
From 13.0 To 35.0 Ft. 2040 FINE SILICA SAND
From To Ft.
m tJ a per De.6ra;\ ;1�-I 2-0L
16. REMARKS:-#� BENTOMTE SEAL FROM 11.0 TO 13.0 FEET
D _Al2,,a
I DO NEARBY CERTIFY THAT THIS WELL WAS CONSTRUCTED IN ACCORDANCE WITH 15A NCAC 2C, WELL
CONSTRUCTION STANDARDS, AND THAT A COPY OF THIS RECORD HAS BEEN PROVIDED TO THE WELL OWNER
ov(-�O� vs - _" 1) 3 ) I va,
SIGNATURE OF PERSON CONSTRUCTING THE WELL DATE
Submit the original to the Division of Water Quality, Groundwater Section, 1636 Mail Service Center- Raleigh, NC
27699-1636 Phone No. [phone], within 30 days. OW-1 REV. 0712001

WELL CONSTRUCTION RECORD
North Carolina - Department of Environmental and Natural Resources - Division of Water Quality - Groundwater Section
WELL CONTRACTOR (INDIVIDUAL) NAME (print) MARK GETTYS CERTIFICATION # 2345
WELL CONTRACTOR COMPANY NAME GEOLOGIC EXPLORATION, INC. PHONE # [phone]
STATE WELL CONSTRUCTION PERMIT# ASSOCIATED WQ PERMIT#
(if applicable) (if applicable)
1. WELL USE (Check Applicable Box): Residential ❑ Municipal/Public ❑ Industrial ❑ Agricultural ❑
Monitoring ® Recovery ❑ Heat Pump Water Injection ❑ Other[] If Other, list Use
2. WELL LOCATION:
Nearest Town: ROCKWELL
County ROWAN
8135 RED ROAD
(Street Name, Numbers, Community, Subdivision, Lot No., Zip Code)
3. OWNER: ALCHEM, INC
Address 8135 RED ROAD
(Street or Route No.)
ROCKWELL NC 28128
City or Town State Zin Code
[phone]
Area Code - Phone Number
4. DATE DRILLED 01-18-02
5. TOTAL DEPTH: 45.0 FEET
6. DOES WELL REPLACE EXISTING WELL? YES ❑ NO
7. STATIC WATER LEVEL Below Top ofCasing: FT.
(Use" if Above TopofCsing)
8. TOP OF CASING IS 2.5 FT. Above Land Surface'
'Top of rasing terminated at/or below land surface requires a
vanance in accordance with 15A NCAC 2C .0118.
9. YIELD (gpm): N/A METHOD OF TEST N/A
10. WATER ZONES (depth): N/A
11. DISINFECTION: Type
12. CASING:
Depth
From 0.0
To 25.0
From
To
From
To
13. Grout:
Depth
From 0.0
To 21.0
From
To
14. SCREEN:
Depth
From 25.0
To 45.(
From
To
15. SAND/GRAVEL PACK:
Depth
N/A
Amount
Wall Thickness
Diameter or Weight/Ft.
Material
Ft
21NCH SCH 40
PVC
Ft.
Ft.
Material
Method
Ft.
Portland Bentonite
Slum
Ft.
Diameter Slot Size
Material
Ft.
2.0 in. .010 in
PVC
Ft.
in. in
Size Material
Topographic/Land setting
❑ Ridge ❑ Slope ❑ Valley E Flat
(check appropriate box)
Latitude/longitude of well location
(degrees/minutes/seconds)
Latitude/]ongitude source: ❑ GPS ❑ Topographic map
(check box)
DEPTH DRILLING LOG
From To Formation Description
0.0 5.0 RED CLAY
5.0 25.0 ORANGE CLAY
25.0 45.0 TAN SILTY CLAY
LOCATION SKETCH
Show direction and distance in miles from at least
two State Roads or County Roads, inculed the road
numbers and common road names.
From 23.0 To 45.0 Ft. 2040 FINE SILICA SAND
From To Ft.
MW Pe'r D-e_boric_k 'qI 02_
16. REMARKS: BENTONITE SEAL FROM 21.0 TO 23.0 FEET
t ,?.---
I DO NEARBY CERTIFY THAT THIS WELL WAS CONSTRUCTED IN ACCORDANCE WITH 15A NCAC 2C, WELL
CONSTRUCTION STANDARDS, AND THAT A COPY OF THIS RECORD HAS BEEN PROVIDED TO THE WELL OWNER
SIGNATURE OF PERSON CONSTRUCTING THE WELL DATE
Submit the original to the Division of Water Quality, Groundwater Section, 1636 Mail Service Center- Raleigh, NC
27699-1636 Phone No. [phone], within 30 days. GW-1 REV. 07/2001

ATTACHMENT B
LABORATORY ANALYTICAL RESULTS

LABORATORIES
OXFORD
Division of Tritest
ALCHEM INC
8135 RED ROAD
ROCKWELL, NC 28138
ATTENTION: WAYNE DRYE
Analytical and Consulting Chemists
DATE RECEIVED 02-13-02
DATE REPORTED 02-15-02
02T4137
PAGE 1 OF 1
SAMPLE DESCRIPTION: 2 MW SAMPLES 2-13-02
1. MW #1 2-12-02
2. MW #2 2-12-02
Aluminum, as Al, PPM
pH (Lab)
RESULTS
1 2
.089 .077
6.40 5.60
1316 South Fifth Street
Wilmington, N.C. 28401
[phone]
Fax [phone]
�AXE�
6v,)X,.
TERESA ADAMS, LAB MANAGER
LAB pH RESULTS ARE NON —REPORTABLE FOR NPDES COMPLIANCE MONITORING

State of North Carolina
Department of Environment, Health, and Natural Resources
Mooresville Regional Office
James G. Martin, Governor Albert F. Hilton, Regional Manager
William W. Cobey, Jr., Secretary
DIVISION OF ENVIRONMENTAL MANAGEMENT
October 25,.y�1990
Mr. Randall F. Andrews, President
Alchem, Inc.
Route 2, Box 521-C
Red Springs, North Carolina 28377
Subject: Notice of Violation
Alchem, 8135 Red Road
Rowan County; NC
Dear Mr..Andrews:
Please find enclosed a Report.of Investigation by Mr. Kim
Colson of this Office concerning a discharge at the subject
facility. The report should.be self-explanatory.
This discharge is a violation of G.S. 143-215.1 for which
enforcement action may -be recommended which may result in a civil
penalty of up to $10,000 per violation. Corrective measures should
be taken to prevent any future discharges. It is requested that you
submit a written response by November 7, 1990 detailing corrective
measures taken to rectify this problem.
If you have any questions concerning this.matter, please feel
free to contact Mr. Kim H. Colson, Mr. D. Rex Gleason, Water Quality
Regional Supervisor, or me at this Office.
Sincerely,
Brenda Smith, P.G.
Regional Supervisor
Enclosure
KHC/bb
919 North Main Street, Mooresville, N.C. 28115 • Telephone [phone] • FAX [phone]
An Equal Opportunity Affirmative Action Employer

NORTH CAROLINA DEPARTMENT OF ENVIRONMENT,. HEALTH
AND NATURAL RESOURCES
DIVISION OF ENVIRONMENTAL MANAGEMENT
WATER QUALITY SECTION
POST OFFICE BOX 950
MOORESVILLE, NORTH CAROLINA 28115
REPORT OF: Unpermitted Discharge
PLACE VISITED: Alchem, Inc., Rockwell
DATE: October 15, 1990
ADDRESS: 8135 Red Road, Rockwell
RIVER BASIN: Yadkin -Pee Dee 03-07-04
BY WHOM: Kim H. Colson, Environmental Engineer I -lm�f W l
TIME SPENT: 3 hours
PERSONS CONTACTED: Wayne Drye, Alchem
REASON FOR.VISIT: Complaint Investigation
COPIES TO: Rowan County Health Department
REPORT:
On October 15, 1990 this Office received a report concerning a
possible discharge of alum into an unnamed tributary to Second
Creek.
Several pH readings were taken along this stream. All pH
readings taken were below the stream standard of 6 s.u. In an
adjacent tributary, a pH reading of 6.8 s.u. was obtained. (See
attached U.S.G.S. map for exact location of pH readings.)
Alchem, Inc. is located at the upper end of the subject
stream's watershed. The investigation at Alchem did reveal that a
lagoon, storing aluminum hydrate, had overtopped due to recent
rains. The lagoon is located just south of the Alchem office. The
lagoon showed evidence of overtopping along the southernmost
embankment where adequate freeboard had not been maintained.
This discharge, however, may not have caused the depressed pH
readings in the stream although it could have been a contributing
factor. There was no evidence of an alum discharge at the time of
the investigation.

1 • �
Page Two
Conclusion: A Notice of Violation will be sent to Alchem, Inc. for
the unpermitted discharge from the aluminum hydrate lagoon. A
follow-up investigation will be conducted to determine the cause of
the substandard pH readings.
KHC/bb

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