WQ0002702_Regional Office Historical File Pre 2018 (9)

09/09/2003 15:17 7042798418 ALCHEM INC PAGE 01
w
Ao.LCHEM, INC.
8135 RED ROAD
ROCKWELL, NC 28138
704-279-7908 FAX: [phone]
adryedalltel.net
FAX
TO
FROM:
Wes Bell
Wayne Drye
FAX NUMBER:
DATE.
704-663-6040
COMPANY
TOTAL NO OF PAGES MCLUDIIG COVER.
NCDENR
3
PHONE NUMBER
704-663-1699
Please call me when you receive this so we can discuss.

09/09/2003 15:17 7042798418 ALCHEM INC PAGE 02
ALCHEM, INC
8135 RED ROAD
ROCKWELL, NC 28138
704-279-7908 fax [phone]
. pdryc(aalltel.net
September 9, 2003
Mr. Wes Bell
NCDENR
Division of Water Quality
919 North Main Street
Mooresville, NC 28115
Dear Mr. Bell,
r axn sending to you the letter from Andrews & Associates for the remediation proposal
offered.
,Alchem, Inc has completed the trench 24" X 24" to divert the storm water from Red
Road around the impounded area.
Tara Group has completed the berm 5' X 8' wide around all the impoundment area and
all low grade areas.
Tara Group is close to completion on the enlarged settlement basin -
Our goal now is to remove all sand from the stream and adjoining property owners as
soon as possible.
Best regards,
ALCHEM, rNC
Wayne Drye,
pd

09/09/2003 15:17 7042798418 ALCHEM INC PAGE 03
"LlVVM01VWff)VTAL J Z FJ t I WL4TION CONSULTANTS"
2522 Parrish Street
Burlington, NC 27215
Phone: [phone] --- Fax: [phone]
September 9, 2003
Mr. Wayne Drye
Vice President
ALCHEM, INC.
8135 Red Road
Rockwell, NC 28138
Subject: Remediation of Affected Areas
Dear Mr. Drye
Concerning the Client Report:
l . Removal of sand from seasonal tributary.
2. Removal of sand from areas outside of impoundment boundaries.
3. Increased containment at property line.
4. Remediation of neighboring property.
Remediation Proposals:
The best solution for the removal of the sand would be the use of a "Sand Hog Type" pump. Fluidizing the sand using
water from the seasonal tributary or well water only would do this. No impounded water would be used for this purpose.
The resulting slurry would be pumped to the impoundment area for proper treatment. I can arrange for the equipment and
people to do this or I can supervise Alchem, Inc. employees during the removal. .
I would also recommend that a trench 12" to 18" with a berm l to 2It. high be dug at the nearest point to the property line
that is feasible. This would catch the rainwater, which would then be pumped, back to the impoundment arcs. This will
result in zero discharge from your facility. We are contacting the owners of the adjoining properties to work out a
remediation plan that is agreeable to thern. I expect to have a plan for this in the next two weeks.
Conclusion:
The remediation can be accomplished with minimum disturbance to the environment using the proposals that I have out
lined above. Please let me (mow your decision as soon as possible so that the proper equipment may be obtained. We can
start within 2 to 3 days of its arrival.
Sincerely,
ANDREWS & ASSOCIATES
�JV
Kcith Andrews,
President

M
Division of Water Quality
Biological Assessment Unit
8 May 2007
Memorandum
To: Jimmie Overton
Through: Trish MacPherson
From: Michael Walters
Re: Results of benthic sampling of site downstream of Alchem Inc. facility, Rockwell NC
Introduction
On 21 March 2007 the Biological Assessment Unit (BAU) received a request from Kim Colson with the Aquifer
Protection Section to investigate possible impacts to an unnamed tributary to Second Creek below the Alchem
Inc. facility in Rockwell NC. Subsequently, contact was made with Ellen Huffman of Mooresville Regional Office to
further discuss the issue. Alchem Inc. is a producer of alum (aluminum sulfate) for use in wastewater treatment.
Potential impacts to the stream below the facility are low pH, high aluminum concentration, and habitat alteration
due to the movement of sand from the facility to the adjacent streambed.
Benthic macroinvertebrates were sampled from a site approximately 950 meters downstream of the Alchem
facility on an unnamed tributary to Second Creek (figure 1). A second site was sampled on the same day on
another unnamed tributary to Second Creek to assess background conditions.
Methods
The study site below the Alchem facility was selected with the aid of a topographic map and the judgment of BAU
staff. The two considerations for study site selection were: 1) a drainage area of sufficient size such that adequate
flow for benthic sampling could be reasonably assured; 2) above relatively large tributaries so that dilution would
not mask the potential effects of the facility on water quality.

Potential reference sites were selected that had the following characteristics as determined from topographic
maps and aerial images: 1) near a road crossing for ease of access; 2) a drainage area of similar size to the site
downstream of Alchem; 3) a similar density of residences within the drainage area with respect to the Alchem site;
4) very few or no small impoundments in the drainage area. Two such potential reference sites were identified.
On 25 April 2007, benthic macroi nverteb rates were collected from the study site downstream of the Alchem
facility near Rockwell in Rowan County. The sample was collected using Qual-4 methods (2006. Standard
Operating Procedures for Benthic Macroinvertebrates. NCDENR DWQ Biological Assessment Unit). The Qual-4
sample is a composite of four collections: a kick, a sweep, a leaf -pack, and "visual' collections. All organisms
were picked in the field.
The two potential reference sites were reconnoitered. One of the two sites was rejected due to the presence of
livestock adjacent to the stream at the site. The second reference site was selected as the reference site, though
macroinvertebrate habitat suffered by the dominance of sand. As for the Alchem site, a benthic collection using
Qual-4 methods was made at the site selected as the reference.
The purpose of benthic sampling is to inventory the aquatic fauna and produce an indication of the relative
abundance of organisms for each taxon. Organisms are classified as Rare (1-2 specimens, denoted by "R" on
taxa tables), Common (3-9 specimens, "C"), or Abundant (>_10 specimens, "A"). Data from the inventory are
entered to a relational database.
Several data summaries (metrics) are calculated from those benthic data to facilitate the detection of water quality
problems. The metrics are based on a long history of observations and studies that show unstressed streams and
rivers have higher invertebrate diversity and a relatively high proportion of intolerant species. Conversely, polluted
streams have lower invertebrate diversity and are dominated by tolerant species. The diversity of the invertebrate
fauna is evaluated using taxa richness (i.e. the total number of distinct taxa present); the tolerance of the stream
community is evaluated using a biotic index (derived -from the response of each taxon to the presence of
generalized stressors).
Two especially robust metrics are used extensively by the BAU for evaluating water quality in North Carolina: EPT
richness and the North Carolina Biotic Index (NCBI). Taxa within the three EPT insect orders (Ephemeroptera,
Plecoptera, and Trichoptera) are generally intolerant of many kinds of pollution. Therefore, higher EPT taxa
richness values indicate better water quality. Sampling was performed outside of the summer sampling window
(June through September) on which EPT criteria are based; therefore, before determining a bioclassification, EPT
taxa richness was corrected to remove winter -spring stoneflies that would not be present in summer (Appendix 1).
When comparing EPT richness between stream sites within the same season the uncorrected values are used.
The relative tolerance of the macroinvertebrate community to stressors, as summarized by the NCBI, is also used
to help evaluate water quality. Both tolerance values for individual taxa and the final biotic index values have a
range of 0-10, with higher numbers indicating more tolerant taxa and more polluted conditions respectively. As
with EPT richness, it is necessary to adjust the BI, which is based upon summer sampling, for seasonality. For
piedmont samples collected during the spring sampling window (March through May) a value of 0.20 is added to
the biotic index before determining a bioclassification. When comparing biotic index values between stream sites
within the same season the unadjusted NCBI values are used.
Criteria for stream sites with a drainage area of less than 3 mi2 have not yet been developed by the BAU; such
sites are sampled using Qual-4 sampling methods and assigned a rating of either "Not Impaired" or "Not Rated"
based upon EPT richness criteria for EPT samples on larger streams. Sites that would rate Good -Fair or better
are considered "Not Impaired"; otherwise the stream is classified as "Not Rated." Piedmont criteria were used in
this study.
Fish/macroinvertebrate habitat was evaluated at both sites using a qualitative scoring system designed for
mountain and piedmont streams. A score was given to each of the following habitat components: degree of
channel modification; amount and variety of in -stream habitat; substrate composition; pool frequency and variety;
riffle length and frequency; stream -bank stability; light penetration; and riparian vegetative zone width. The scores
for each habitat component were summed to give an overall habitat score for each of the sites. Values for the
overall score range from 1 to 100.
2

Several physicochemical properties of the streams at both sites were measured. Data for temperature, dissolved
oxygen, and specific conductance were collected using a YSI-85 multi -meter. Measurements for pH were
collected using an Accumet AP61 meter.
Study Sites
unnamed tributary to Second Creek off Deer Chase Lane, Rockwell / Rowan County—"Alchem site"
Drainage area: 0.5 mi2
Stream width: 1.5 m
Stream depth: 0.2 m average
0.3 m maximum
Channel
characteristics:
Riffles and pools:
Substrate
Habitat:
Bank
characteristics
Riparian zone:
Canopy:
Habitat score:
Specific
conductance:
pH:
little sinuousity
pools frequent, though of similar
size; riffles infrequent, though
well-defined
mostly cobble, sand, and gravel;
cobbles moderately embedded
rocky substrate, sticks,
leafpacks, snags, undercut
banks, and root mats were all
common or abundant
erosional areas present; sparse mixed bank vegetation
with breaks; wide on left, narrow on right with adjacent fallow field
provides full shade to stream surface
72 (out of 100)
286 Nmhos/cm
6.8
unnamed tributary to Second Creek off SR 1006 / Rowan County —"reference site"
Drainage area: 0.5 mi2
Stream width: 1.5 m
Stream depth: 0.3 m average
1.0 m maximum
Channel
characteristics:
Riffles and pools:
Substrate:
Habitat:
Bank
characteristics:
Riparian zone:
Canopy:
Habitat score:
Specific
conductance
pH:
natural, sinuous
pools frequent, though of similar
size; riffles infrequent, though
well-defined
mostly sand, with small areas of
bedrock, boulder, cobble, and
silt
sticks, leafpacks, undercut
banks, and root mats were
either abundant or common;
rocky substrate, snags, and logs
were rare
bank vegetation healthy and of diverse types; one bank with a small amount of erosion
present
wide, though with a few breaks on both banks
provides a good mix of light and shade
71
78 Nmhos/cm
6.6
3

Results
Habitat conditions, physical and chemical water data, and geographical coordinates for the study and reference
sites are given in Table 1. Summary biological metrics and resultant bioclassifications are given in Table 2. Taxa
identified and the corresponding abundance classifications for the study and reference sites are given in Appendix
Table 1. Habitat conditions, physical and chemical water data, -and geographical coordinates for study (Deer
Chase Lane) and reference (SR 1006) sites
sampled for benthic
macroinvertebrates on 25 April 2007.
Stream
UT Second Cr
UT Second Cr
Site Location
off Deer Chase Ln
off SR 1006
County
Rowan
Rowan
Drainage area (mil)
0.5
0.5
Collection date
25-Apr-07
25-Apr-07
BAU sample number
10158
10159
Habitat Scores
Channel modification
4
5
In -stream habitat
18
12
Bottom substrate
11
3
Pool variety
8
8
Riffle habitats
12
12
Bank stability and vegetation
6
13
Light penetration
8
10
Riparian vegetative zone width
5
8
Total Habitat
72
71
Other Habitat
Average stream width (m)
1.5
1.5
Average stream depth (m)
0.2
0.3
Canopy (%)
100
70
Substrate (%)
Bedrock
0
10
Boulder
5
5
Cobble
35
5
Gravel
20
0
Sand
30
75
Silt
10
5
Physicochemical
Temperature (°C)
15.8
19.4
Dissolved oxygen (mg/L)
6.6
6.1
Specific conductance (pmhos)
286
78
pH
6.8
6.6
Coordinates
Latitude (1)
35.567
35.551
Longitude (0)
-80.413
-80.459
Latitude (DD MM SS)
35 34 02
353302.
Longitude (DD MM SS)
-80 24 46
-80 27 33
4

Table 2. Summary biological metrics for study (Deer Chase Lane) and reference (SR 1006) sites sampled for
benthic macroinvertebrates on 25 April 2007.
Stream
UT Second Cr
UT Second Cr
Site Location off Deer Chase Ln
off SR 1006
County
Rowan
Rowan
Drainage area (mil)
0.5
0.5
Collection date
25-Apr-07
25-Apr-07
BAU sample number
10158
10159
Sample method
Qual 4
Qual 4
Richness (number of taxa)
Ephemeroptera
4
8
Plecoptera
1
3
Trichoptera
7
9
Total EPT
12
20
Seasonal Plecoptera
0
1
Corrected EPT
12
19
Odonata
5
4
Megaloptera
0
1
Coleoptera
5
9
Diptera: Chironomidae
19
23
Diptera less Chironomidae
6
8
Oligochaeta
6
4
Mollusca
3
1
Other
3
6
Total taxa richness
59
76
Other biological measures
EPT abundance
46
88
EPT Biotic Index
3.76
3.80
NCBI
5.62
5.20
Seasonal correction
0.20
0.20
Corrected NCBI
5.82
5.40
Bioclassification
Not Rated
Not Impaired
The preliminary bioclassifications for the Alchem site and the reference site are "Not Rated" and "Not Impaired"
respectively. Criteria have not been developed for small streams. The classifications used here are based on
criteria for the number of EPT taxa found in larger piedmont streams.
More important to this study are comparisons of the benthic community between the reference site and the study
site downstream of the Alchem facility. There was a slight increase in the NCBI value between the reference site
and the Alchem site, from 5.20 to 5.62, suggesting poorer water quality at the Alchem site. The greater indication
of a difference in water quality between the two sites is seen by comparing EPT richness. EPT richness indicates
diversity within the three orders of insects most sensitive to the presence of stressors; higher EPT richness
indicates better stream conditions. Twenty EPT taxa were collected from the reference site while 12 were
collected from the Alchem site, a decrease of 40%. The fact that the area for macroi nverteb rate colonization was
less at the reference site (due to the dominance of sand as the substrate) than at the Alchem site makes the
difference in EPT richness even more significant; the dominance of sand at the reference site likely depresses
EPT richness from what it would be otherwise with a substrate composition more similar to the Alchem site.
Degraded water quality at the site sampled downstream of the Alchem facility is indicated by the results of this
study.

cc: Ellen Huffman, Peggy Finley, Wes Bell, Andrew Pittner —Mooresville Regional Office
Darlene Kucken=Planning Section

Appendix 1. Taxa identified from and corresponding abundance classifications for study (Deer Chase Lane)
and reference (SR 1006) sites sampled for benthic macroinvertebrates on 25 April 2007. Superscript
"s" (s) indicates taxa removed for seasonal correction.
Stream
UT Second Cr
UT Second Cr
Site Location
off Deer Chase Ln
off SR 1006
County
Rowan
Rowan
Collection date
25-Apr-07
25-Apr-07
BAU sample number
10159
Ephemeropter-a
_10158
_
Baetis flavistriga
R
Baetis pluto
A
Plauditus spp.
C
A
Ephemerella invaria sp. group
C
Eurylophella verisimilis
C
C
Maccaffertium modestum
A
A
Stenacron interpunctatum
C
Para leptophlebia spp.
A
A
LPlecoptera---_------�
_ _ _ ------
_
__�]
Perlesta spp.
C
R
Diploperla duplicata6
A
Isoperla holochlora
C
—�-
T
Cheumatopsyche spp.
C
C-�
Diplectrona modesta
C
R
Hydropsyche betteni
C
Triaenodes ignitus
R
Triaenodes melaca
C
Ironoquia punctatissima
C
C
Pycnopsyche spp.
R
R
Chimarra spp.
R
R
Lype diversa
R
Neophylax oligius
A
Neophylax ornatus
C
O_do_nata -
—
Calopteryx spp.
A
A
Argia spp.
R
Enallagma spp.
R
Boyeria vinosa
R
R
Gomphus spp.
R
R
Ophiogomphus spp.
_R
Corixidae
R
Nigronia serricomis
R
LcP-Iqg -_-
Helichus fastigiatus
A
A
Agabus spp.
R
Neoporus spp.
C
A
Dubiraphia spp.
R
Macronychus glabratus
R
Microcylloepus pusillus
R
Stenelmis spp.
C
A
Cymbiodyta spp.
R
Ectopria nervosa
R
Anchytarsus bicolor
A
C
P ra
--
Palpomyia group spp.
C
Culex spp.
R
Dixa spp. ,
R
Simulium spp.
A
A
Tabanus spp.
R
Antocha spp.
R
Dicranota spp.
R
Hexatoma spp.
R
C
Pseudolimnophila spp.
R
R
Tipula spp.
C
R

Appendix 1. —continued.
Stream
UT Second Cr
UT Second Cr
Site Location
off Deer Chase Ln
off SR 1006
County
Rowan
Rowan
Collection date
25-Apr-07
25-Apr-07
BAU sample number
10158
10159
Diptera. Chironomidae
Cryptochironomus spp.
R
Micropsectra polita
R
Microtendipes pedellus sp. group
A
A
Paracladopelma undine
R
Paratanytarsus quadratus
R
C
Paratendipes spp.
C
C
Phaenopsectra spp.
C
C
Polypedilum aviceps
C
Polypedilum fallax sp. group
R
Polypedilum flavum
A
Polypedilum spp.
R
Rheotanytarsus spp.
C
Stictochironomus spp.
A
Tanytarsus sp. M
C
Tanytarsus spp.
R
R
Tribelos jucundum
R
R
Potthastia longimanus
R
Corynoneura spp.
C
C
Orthocladius dubitatus
R
Orthocladius robacki
C
Parakiefferiella spp.
R
Parametriocnemus spp.
A
A
Rheocricotopus glabricollis
C
Rheocricotopus robacki
R
Thienemaniella spp.
R
R
Tvetenia bavarica sp. group
C
C
Ablabesmyia mallochi
R
Larsia spp.
R
Natarsia spp.
C
Tanypus spp.
R
Thienemannimyia group spp.
A
C
EOHdR—cFa—eta
Branchiobdellida�
C
Enchytraeidae
R
Lumbriculidae
R
A
Megadrile
R
Nais spp.
R
R
Pristinella spp.
R
Slavina appendiculata
R
Tubificidae
R
Lqrustacea __
Crangonyx spp.
R
C
Cambaridae
R
C
Caecidotea spp.
C
C
_ —
Micromenetus dilatatus
C
Elimia spp.
R
A
Bivalvia
Pisidium spp_.
A
Other � _—.------------
--.
_
Turbellaria
R
Dugesia tigrina
R
H.

.............................................................................................................................................................................................
FROM FAX NO. Feb. 20 2002 06:50AM P1
ALCHEM, INC.
Spies and 1VYanu acturin
C—or nvr—at e O ce 8135 Red Road
2042 Buie Philadelphus Road Rockwell, NC 28138
Red Strings, NC 28377 Tel, 704-279-7908 — 800-462-2586
-Tel. [phone] — 900-522-2944 Fax [phone]
Fax [phone] pdryeCs'alltel-net
rfa(g�semr.net
February 8, 2007
Mr. Wes Bell
Environmental Technician
NCDENR
Mooresville, NC
Dear Mr. Bell:
In my previous letter I forgot to touch base on the small area beside the railroad track that
we discussed. Both Trent Tidwell and I are looking at this. I will have you a plan within
30 days. We are already planxiing to make certain that no more Sulfuric Acid is dropped
in this area. We have spread some agricultural Lime in the area also.
Best regards,
ALCHEM, INC.
a
Randall F. Andrews,
Plant Manager
ams

...............................................................................................................................................................................................
FROM FAX NO. Feb. 19 2002 12:19PM P1
ALCHEMYINC..
Cornoraite Qi ee nufac�krinQ
2042 Buie Philadelphus Road Sales and Manu Red Road
Red SUrings, NC 28377 8135
Tel. 910•843-2121 — 800-522-2944 Rockwell, NC 28138
Fax [phone] - Tel. [phone] n- 800-462.2586
rfa(Lbsemnnet Fax [phone]
Pdrye(&WItel.net
February 7, 2007
Mr. Wes Bell
Environmental Technician
NCDENR
Mooresville, NC
Dear Mr. Bell.:
Thank you for meeting with me 'Wednesday, Unfortunately, I cannot call 'Wayne Drye to
discuss the problems you brought up. However, I did discuss with Trent Tidwell at the
plant. Once I did remember that Larry Samples and Wayne had discussed waiting until
the ground was frozen to move equipment in to the dig in the ditch. The idea is that by
doing so it would have a smaller impact on Larry Sample's yard. ' Trent is going to call
Larry and discuss.
I called and spoke with Mr. Wayne Alexander about coming to look at the trees. He is an
arborist who formerly worked with the N.C. Forestry Service. He lives about 3 or .
miles from the 'plant. Trent will speak with Larry Samples and get the OK for Mr.
Alexander to come. Mr, .Alexander did say that he would be able to determine more
about he trees when they have leaves on them. 1 will be back with you on both items.
Best regards,
ALCHEM, INC.
Randall F. Andrews,
Plant Manager
arms

06/26/2006 02:34 9108435789 IAC INC PAGE 01
ALGHEM, INC,
Cornarate Office Sales and Manufacturing
2042 Buie Philadelphus Road 8135 Red Road
Red Springs, NC 28377 Rockwell, NC 28138
4M578
Tel. [phone]?Z-Z9g4 Tel. [phone] -- 800-462.25M
[e-mail]
Fax t Fax [phone]
emr.
pdrye0alltel.net
June 19, 200G ,r✓'
Mr. Rex Gleason
N.C.D.E.N.R.
401 Oberlin Rd.
Suite 1.50
Raleigh, NC 27605
Dear Mr. Gleason:
After numerous meetings with Lawyers, I believe that we have come to a conclusion
about the problem on the property owned by Laney Samples and Barbara Daniels.
Our action plan is:
I. Dig a small trench to allow the water to drain consistent with what Allen
Johnson of the NCDENR showed us and was agreed upon by Larry Samples.
2. Take a soil test.
3. Use the results to place an amount of Limestone consistent with soil testing
recommendations. I suspect that it will only take a small amount as the amount of
land to be covered is probably 300 square feet or 0.0007 acres.
4. Fill in the hole near Mr. Sample's property so that he is satisfied.
5. Get an arborist to look at the property and make certain that by adding Lime to
the area that we do not damage any trees.
Would you let me know if you have any objections or concerns.
Best regards,
ALCHEM, INC
Randall F. Andrews
ams

ALCHEM, INC.
Gs=nvr'ate Office Sales and Manufacturin4
2042 Buie Philadelphus Road 8135 Red Road
Red Springs, NC 28377 Rockwell, NC 28138
Tel. [phone] -- 800-522-2944 Tel. [phone] — 800-462-2586
Fax [phone] Fax [phone]
[e-mail] [e-mail]
February 7, 2007 `
APR
Mr. Rex Gleason, P.E.
NC Division of Water Quality
Mooresville Regional Office
919 N. Main St.
Mooresville, NC 28115
Dear Mr. Gleason:
This week I had three employees work for two days in the stream near ALCHEM. They
worked under the direction of Larry Samples, who is a neighbor. As far as I know Larry
Samples and Barbara Daniels are completely satisfied and have no more complaints. Mr.
Wayne Alexander who formerly worked for the N.C. Forestry Service came, looked and
gave us a report. A copy is enclosed.
Please call me if yoij-have any questions.
Best regards,
ALCHEM, INC.
Randall F. Andrews,
Plant Manager
ams

01/28/2007 19:55 9108435789 IAC INC
ALCHEM, INC.
Corporate Office
2042 Buie Phlladelphus Road
Red Springs, NC 28377
Tol. 910-80,9121 — 800-522-2944
Fax 91,0.843-5789
rfa(q,semr.net
January 26, 2007
Mr. Andrew Pitner
.Fuvironmental Regional Supervisor
NCDENR
61.0 .East Center St-, Suite 301
Mooresvil-le, NC 28115
Re; .NOV No. NOV-2006-PC-0061
Dear Mr. Ptiner:
PAGE 01
Sales and Manufacturing
8135 Red Road
Rockwell, NC 28138
Tel. [phone] — 800.462-2586
Fax [phone]
pdrye a.alltal.not.
Tii.ank you for your letter of January 19, 2007. Alchem has not used the permitted fill .
area since we received a letter about this in mid December. T have been talking with
Engineers about this project since then and trying to find a solution to tl:l .s problem. At
one time we sold some of, our sand to a fertilizer manufacturer. I have contacted them
and taken new samples to try and. get this as ati. outlet again. T.l.1e only proposal that I
I).ave, I recently received and just the cost for the engineering was .fa.r more than the value
of our company. At one time T called the Salisbury Landfill, but having to pay the
disposal fee is something that would wreck us economically. We are fast pulling the
water down to very minimal Ievels again. There were two very large rain storms back in
middle and late November. We have changed tb.e ditch coming under the railroad and so
now the water from the large area across the railroad is diverted frorn. our contained area.
I would like to ask that you consider allowing us to put about 500 tons from the storage
area nearest: our reactor bato the area near the raill-oa.d. I plan to use that f%1.1, and that area.
on w11.i.ch to put our Magnesium, Hydroxide and CaIciur.n. Hydroxide mixing tanks.
Th.ard,c you for, your consideration.
Best regards,
ALCHEM, INC
Randall F. Andrews,
Plant Manager.

610
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
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 Reportfor 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 on -site remedial activities. This office is concerned with the consistently low pHs
measured within the stormwater diversion ditch 4acent.tothe 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
J MCamU,
llvatur 4
N. C Division of Water Quality, Mooresville Regional Office, 610 East Center Avenue, Suite 301, Mooresville NC.28115 [phone] Customer Service
1 _1t77_,7 2_/7d St

Mr. Wayne Drye
Page Two
June 21, 2005
1699.
Should you have questions, please do not hesitate to contact Mr. Bell or me at (704) 663-
Sincerely,
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[,)8TIME 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 Departrnent
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

f
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, andponded 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. Tn
addition, no actions had been taken to address the accumulations of the residual bauxite ore (at
the unloadingstation) 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 s.u. to 7.37 sm. 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
xepairingthe silt 'fence and initiatexemedial activities surrounding the stonmwater 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.

;t
GDA&CSA onomrc Divisron :Phonee.,..1"Site `::wvvwrica y M 55
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Grower:
Alchem Inc.
Copies To:
8135 Red Rd.
Rockwell, NC 28138
ozl est flqport
-.
Parm:
�
3/11/2005 SERVING N.C. RESIDENTS FOR OVER 60 YEARS
Rowan County
Agronomist Comments
C - 12, $
Freld?.Informatron
A 1redLrme
F, Recomineidationsb°-
1 f '�
�
.�,��;
.
Sample No. Last Crop
Mo Yr T/A
Crop or Year Lime
N P205 K20
Mg Cu
Zn B Mn
Se ote­
A
Ist Crop: Clover/Grass, E 6.6T
10-30 150-170 . 100-120
$ 0
$
12
2nd Crop: Clover/Grass, E 0
10-30 150-170 100-120
$ 0
- $ 0
12
Test Results
Soil Class HM% W/V CEC BS% Ac pH P-I KI Ca% Mg%
Mn-I Mn-AI(1)Mn-AI(2) Zn-I
Zn-AI
Cu-I S-I
SS -I NO3-N NH4-N Na
MIN 0.76 0.69 8.6 20.6 6.9 4.0 31 52 12.0 5.0
161 106 106 23
23
58 197
0.1
.. ♦.. ... ., 5:.. .N-.Y :�i w,> ....:.., ... a.,.
.,.. sr,f
.�
>. • ..e::... .. a.r:..,:
A lred Lane.
M .c .:y.3 ..... <.^.S ,.. .: s . -.rvt .. ,xe ... b 1, .zx.�
Recommenclatrons �
�;Freld':Informatron �
Sample No. Last Crop
Mo Yr T/A
Crop or Year Lime
N" P205 K20
Mg �Cu
Zn B Mn
See Note
B
1st Crop: Clover/Grass, E 4.9T
10-30 220-240 150-170
0 0
0 0
12
2nd Crop: Clover/Grass, E 0
10-30 220-240 150-170
0 0
0 0
12
Test Results
-
Soil Class HM% W/V CEC BS% Ac pH P-I K-I Ca% Mg%
Mn-I Mn-AI(1)Mn-AI(2) Zn-I
Zn-AI
Cu-I S-I
SS-1 NO3-N NII4-N Na
MIN 0.51 0.84 8.3 39.0 5.1 4.2 5 32 26.0 11.0
365 228 228 30
30
33 485
0.1
_r .. ,. ,. ii: F ;, :..'^
Ereld'IriforinatI 11
:",:.. .'c• e>.z-* ..,:':.
t1 lred Lrme
.S +:t-:.Fr. d a.�m+ .i -il:e >T y, 4: i:.
F:Recomm'endatrons" '.` g
�.. �._ v_
Sample No. Last Crop
Mo Yr T/A
Crop or Year Lime
N . P205 K20
Mg Cu
Zn B Mn
See Note
C
1st Crop: Clover/Grass, E 2T
10-30 240-260 200-220
0 0
0 0
12
2nd Crop: Clover/Grass, E 0
10-30 240-260 200-220
0 0
0 0
12
Test Results
Soil Class HM% W/V CEC BS% Ac pH P-I K-I Ca% Mg%
Mn-I Mn-AI(1)Mn-AI(2) Zn-I
Zn-AI
Cu-I S-I
SS -I NO3-N NH4-N Na
MIN 0.66 1.18 5.4 61.0 2.1 4.6 0 12 38.0 23.0
82 59 59 44
44
32 248
0.1
Fiel&lnformation ;.:.`
AppliedLrme
;Recommendations
Sample No. Last Crop
Mo Yr T/A
Crop or Year Lime
N P205 K20
Mg Cu
Zn B Mn
See Note
D
1st Crop: Clover/Grass, E 5.6T
10-30 240-260 150-170
0 0
0 0
12
2nd Crop: Clover/Grass, E 0
10-30 240-260 150-170
0 0
0 0
12
Test Results
Soil Class HM% W/V CEC BS% Ac pH P-I K I Ca% Mg%
Mn-I Mn-AI(1)Mn-AI(2) Zn-I
Zn-AI
Cu-I S-I
SS-1 NO3-N AW4-N Na
MIN 0.86 0.83 8.7 32.0 5.9 4.3 0 32 22.0 8.0
472 293 293 45
45
51 233
0.1

CDA&CS`Agronomic.Division' ;4300 ReedyCreelt Road 1040 Mail Service Center, Raleigh NC 276994040 (919) 73372655: :
' Guru,- Ro
a m Undeivstandh7, the oil Test)?eport -
. FUNDED %
www.ncagr.com/agronomi/ustr.
htm
Britt Cobb, Commissioner of Agriculture
F.ORAGE/PASTURE., CROSS. (Crop Codes 040-060)
Soil pH and the amount of lime required for optimum yields are crucial parts of the soil test
report. Low soil pH and low phosphorus cause more yield losses than any other factors in
forage production. Excessive soil acidity (low pH) reduces the -capacity of forage crops to
utilize applied fertilizer nutrients. Lime recommendations are based on pH, amount of acidity,
and desired pH for the designated crop. Establishment and maintenance of legumes depend
very heavily on maintaining the proper pH.
For best results, recommended lime and fertilizer should be mixed into the top 6 to 8 inches of
the soil before establishment. Although most forage crops show no response to phosphorus
and potassium above an index of 50, some fertilization will be recommended for certain crops.
Recommendations for nitrogen, phosphorus and potassium are for annual application.
Depending on the crop, climate and soils, split applications of nitrogen and potassium may
required. Past experience, management level and economics will influence rates and time of
application. For additional information, see Note 12: Forage and Pasture Crops, which
accompanies your soil test report. The table below shows the relationship between soil test
index value and crop response to applied nutrients.
Soil Test Index
Crop Response to Nutrient Application
Range
Rating
Phosphorus
Potassium
Manganese
Zinc
Copper
0-10
Very Low
Very High
Very High
Very High
Very High
Very High
11-25
Low
High
High
High
High
High
26-50
Medium
Medium *
Medium *
None
None
None
51-100
High
None
Low -None
None
None
None
100+
Very High
None
None
None.
None
None
Soil Test Report Abbreviations
,MiN
. mineral soih.class
NI 0 mineral organic soil class`=
T
bRG { "
organic: soil class `
HM%
=percent huimc matter
W/V
; weight per volume, of soil-
CEC
,capon exchange capacity - `' !
BS%
percent of CEC occupied by bases"
Ac
:acidity (decreases. a_ s pH increases),
current soilpH
P-I
p - osphorus'mdex _.
K I-
potassium index
percent of CEC occupied by ,
calcium -
Mg%;_
,"percent:ofCECoccupiedby,
ma esium •.. . - "
M11-1
manganese index
Mn-AI
manganese availability. index
Zn-I "
zinc index -
Zn-AI
zinc availability index
Cu-I
coppei index
S-I
sulfur index
.SS-1
soluble salt index
NO3-N
' nitrate nitrogen (ppm)
NH4 N
ammonium nitrogen (ppm)
Na
sodium .
P205
phosphate
K2O
potash
B
boron
* Response decreases as soil test index increases.
April 2004 5,000 copies of this public document were printed at a cost of $105.93 or $0.02 per copy.

N.GDA&GS A onomie Davision-Phone g1g 733 2655 tWeb Site www.nca comXa Re o t 5523
,onom :GAlche
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.�IRiel'�l .Information �K
.:�Reco_m_mendatron �:� '. � �.� � ;� � �<� � .
Sample No. LastCrop
Mo... Yr T/A
Crop or. Year _
Lime N �P205K20 -Mg Cu: Zn�
B Mn See Note
rCvG,
-0p ,ST. -30 . 210230 170=190
0. 12E
:.
. .
2nd Crop -Clover/Grass, E. - .
.0
0 10-30 _. 210-230 ': 170-190 . 0
0 12
`Test Results
Soil Class dIM% W/V :.CEC BS% AC`, pH - PI' : .-KI
Ca°o Mgl Mn-I Mn-AI(1)Mn-AI(2);.Zn I:.- Zn-AI: ,- Cu-I
S-I SS -I .. NO3-N NHS-N Na
.419.0 MIN 0:3
409 69
0.16.8

Michael I ;aslcN, kioverno;
William G. ktxsa Jr„ SC,=11r\•
North Carolina Department of Environment and Naturul Fesoun-cs
Alan W. Klunck. 1'. E.. Dtrx-,nor
Division of \Vater Qualit\
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 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 December 30, 2004 and January 5, 2065 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 s.u. ( 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.
I,�
N. C Division of Water Quality, Mooresville Regional Office, 610 East Center Avenue, Suite 301, Mooresville NC 28115 (704) 663-16x1 Customo- Service
i-o7r-623-6748

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 ofNCGS 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/riparian areas on the facility's property.
Should you have questions, please do not hesitate to contact Mr. Bell or me at [phone].
Sincerely,
al?.-e,
D. Rex Gleason, P.E.
Surface Water Protection Regional Supervisor
r L'Laui LGuu
cc: Rowan County Health Department
Stormie Forte, Associate Attorney General
Wayne Drye, Plant Manager, ALCHEM, Inc.

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: December 30, 2004 and January 5, 2005
WV
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
REPORT:
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 wooded/riparian 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 T`wo
pH measurements were taken by Mr. Bell on January 5, 2005. The upstream pH ranged from
6.22 sm. 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.

STATE OF NORTH CAROLINA
COUNTY OF ROWAN,
ALCHEM, INC., WAYNE D
FILED IN THE OFFICE OF
ADMINISTRATIVE HEARINGS
Z004 MAR - 2 P 3: S Q _ 03 EHR 1587
DOFFICE OF
RYE, qp
iJOISTRATIVE
HEARINGS
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 et seq and Non -Discharge Permit WQ0016338.
DENR and the Petitioner have reached the following settlement agreement in this matter:
1. Petitioner will adhere to the following conditions:
a. Petitioner will submit a plan or schedule to remove sand and
other materials from a tributary to Second Creek and the
-1-

riparian areas of the two affected private properties adjacent
to Alchem, 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 of the Division of Water Quality
within thirty (30) days of execution of this 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
owned by Alchem, Inc. and the two 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 $5,600.00 - 20% of penalty = $4,480.00 (80% of penalty) + investigative costs of
$398.28 = $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-

March 1, 2004 in the amount of two hundred three dollars and thirty cents ($203.30). Each
payment thereafter shall be due and payable on the I" day of each month consecutively in
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:
Stormie 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
1-1
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-

5. DENR agrees to accept payments totaling four thousand eight hundred seventy-
eight dollars and twenty-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.C. § 523.
Nothing in this Agreement releases any nondischargeability claims that may be asserted by
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.
8. This Agreement shall be binding upon the parties and is entered into knowingly,
intelligently, and voluntarily.
CS

WITHDRAWAL OF PETITION
9. Entry of this Agreement serve as Petitioner's Withdrawal of its Petition for
Contested 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 136 day of February 2004.
FOR THE DIVISION OF WATER
QUALITY
Alan Klimek, Director of
Water Quality
Date: 3 z O `f
D. Rex Gleason; Mooresville
Regional Supervisor
Date:
ROY COOPER
Attorney General
By:
tormie D. Forie-
Associate Attorney General
N. C. Department of Justice
Environmental Division
9001 Mail Service Center
Raleigh, NC 27699-9001
[phone]
[phone]/Fax
-5-
PETITIONER:
Alchem,.Inc., Wayne D. Drye
Date: � -- 02 0 — a dn`i
Randall F. Andrews, Consultant
Alchem, Inc.
Date: )�— �_ L/�' Z 00 /

�410E
MAR 0 5 2004

State of North Carolina
ROY COOPER Department of Justice Reply to:
ATTORNEY GENERAL P. O. BOX 629 Stormie D. Forte
RALEIGH Environmental Division
27602-0629 Tel: [phone]
Fax: [phone]
[e-mail]
MEMORANDUM
TO: es : ell
Allen Johnson
J. Kent Wiggins
FROM: Stormie D. Forte, Associate Attorney General
I&lr
DATE: October 15, 2003
a I_s ., 2 2 2003
-DEPT. OF ENVENT
AND -NATURAL FEBWRcES
MOORESVILLE REDIONAL OFFICE
RE: Assessment of Civil Penalties appeal by Alchem, Inc., Wayne Drye of Rowan County;
OAH # 03 EHR 1587; Agency File No.: 03-313
Please note that I have been assigned to handle the Permit appeal by Alchem, Inc., Wayne Drye.
I will need to begin preparing our case as soon as possible. Please review the important dates listed
below and provide me with the requested information by hand delivery or by mail.
October 19, 2003 Prehearing Statements and Document Constituting Agency Action due to be
filed with OAH. The file was copied on today, October 15, 2003. If any
additional documentation is added to the file subsequent to today, please forward
it to us as soon as possible.
December 1, 2003 Discovery must be sent to Petitioner to give us enough time to receive answers
prior to hearing. If we are to conduct discovery, we must have the file in order to
compile discovery questions.
January 12, 2004 If Petitioner sends discovery questions to us, we must respond within 15 days of
receipt. All Discovery must be completed by the January 5, 2004 date.
January 26, 2004 Hearing set in High Point, NC with .Julian Mann, III, Chief Administrative Law
Judge presiding. You have been listed as witnesses. If this list of names should
change for any reason, please inform this office immediately.
If you have any questions or comments regarding this case, please do not hesitate to call this
office.

T
ALCHEM, INC
8135 RED:ROAD
ROCKWELL, NC 28138
704-279-7908 fax [phone]
[e-mail]
February 23, 2004
DENR/DWQ/Water Quality Section
Mr. Daryl Merritt
Non -Discharge Compliance/Enforcement Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Dear Mr. Merritt:
Enclosed are the monitoring and reporting requirements for our permit number
WQ0016338.
For the year of 2003, we did not accumulate enough Silica residual to land apply.
Please let me know if you need anything further.
Best regards,
ALCHEM, INC
Wayne D. Drye,
Plant Manager
..
cc: Mooresville Regional Office

t, L I ANNUAL LAND APPLICATION CERTIFICATION FORM
Permit#: WQ0016338 County: ROWAN Year:
2003
Facility Name (as shown on permit):
Land Application Operator:
ALCHEM, INC
WAYNE DRYE, PLANT MANAGER Phone: [phone]
Land application of residual solids as allowed by the permit occurred during the past calender year?
❑ Yes 0 No If No, skip Part A, and Part B and proceed to the certification. Also, if residuals were
generated but not land applied, please attach an explanation on how the residuals were handled.
Part A:
Total number of application fields in permit:
Total number of fields land application occurred during the year:
Part B:
Facility was compliant during calendar year with all conditions of the land application permit
(including but not limited to items 1-12 below) issued by the Division of Water Quality. ❑ Yes p No
If no please, provide a written description why the facility was not compliant, the dates, and explain
corrective action taken.
1. Only residuals approved for this permit were applied to the permitted sites.
2. Soil pH was adjusted as specified in the permit and lime was applied (if needed) to achieve a soil pH of at
least 6.0 or the limit specified in the permit.
3. Annual soils analysis were performed on each site receiving residuals during the past calendar year and three
(3) copies of laboratory results are attached.
4. Annual TCLP analysis was performed and three (3) copies of certified laboratory results are attached.
5. All other monitoring was performed in accordance with the permit and reported during the year as required
and three (3) copies of certified laboratory results are attached.
6. The facility did not exceed any of the Pollutant Concentration Limits in Table 1 of 40 CFR Part 503.13 or the
Pollutant Loading Rates in Table 2 of 40 CFR part 503.13 (applicable to 40 CFR Part 503 regulated facilities).
7. All general requirements in 40 CFR Part 503.12 and management practices in 40 CFR Part 503.14 were
complied with (applicable to 40 CFR Part 503 regulated facilities).
8. All operations and maintenance requirements in the permit were complied with or, in the case of a deviation,
prior authorization was received from the Division of Water Quality.
9. No contravention of Ground Water Quality Standards occurred at a monitoring well or explanations of
violations are attached to include appropriate actions and remediations.
10. Vegetative cover as specified in the permit was maintained on this site and the crops grown were removed
in accordance with the crop management plan.
11. No runoff of residuals from the application sites onto adjacent property or nearby surface waters has occurred.
12. All buffer requirements as specified on the permit were maintained during each application of residuals.
"I certify, under penalty of law, that the above information is, to the best of my knowledge and belief, true,
accurate, and complete. I am aware that there are significant penalties for submitting false information,
including the possibility of fines and imprisonment for knowing violations."
Wayne D Drye, Plant Manager
Permittee Name and Title (type or print)
Signat e of Prepar Date
(if different from Permittee)
' Preparer is defined in 40 CFR Part 503.9 (r)
-,�b3k
Signature -'of PermitteeDate
Signiture of Land Applier Date
(if different from Permittee and Preparer)
DENR FORM ACF (5/2003)

ALCHEM, INC
8135 RED ROAD
ROCKWELL, NC 28138
704-279-7908 fax [phone]
[e-mail]
FORM ACF:
Residuals were pumped into holding lagoon.
Alchem, Ines storage area for its fill material discharged into a drainage/wooded area
and stream. This was due somewhat to the large amounts of rain we had the first part of
2003.
Alchem has been collecting the fill material from the wooded area and the stream. A 24"
X 24" trench to divert the storm water from Red Road around the impounded area has
been completed. A 5' X 8' wide berm has been placed around the impoundment area and
all low grade areas. An enlarged settlement basin has been completed.

ANNUAL RESIDUAL SAMPLING SUMMARY FORM
Attach this form to the corresponding Annual Report
Please note that your permit may contain additional parameters to be analyzed than those required to be summarized on this form.
Permit Number: WQ0016338
Facility Name:
NPDES # or
WQ#:
WWTP Name:
Residual Analvsis Data
ALCHEM, INC
Laboratory: 1)
2)
3)
4)
5)
TBL LABORATORY
Sample or
Composite Date
Percent Solids
"I certify, under penalty of law, that this document was prepared under my direction or supervision in accordance with a system
designed to assure that qualified personnel properly gathered and evaluated the information submitted. I am aware that there are
significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations."
Signa(& of Prep er
3a
Date
DENR FORM RSSF (5/2003)

ANNUAL RESIDUAL SAMPLING SUMMARY FORM
Attach this form to the corresponding Annual Report
Please note that your permit may contain additional parameters to be analyzed than those required to be summarized on this form.
Permit Number: WQ0016338
Facility Name:
NPDES # or
WQ#:
WWTP Name:
Residual Analysis Data
ALCHEM, INC
Laboratory: 1) TBL LABORATORY
2)
3)
4)
5)
Sample or
Composite Date
MMMMMMMMMMMM
"I certify, under penalty of law, that this document was prepared under my direction or supervision in accordance with a system
designed to assure that qualified personnel properly gathered and evaluated the information submitted. I am aware that there are
significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations."
pij&�
Signat e of Prepare
Date
np:mp F:npu RSSF-R (5/7nni1

Element One Inc.
5022-C Wrightsville Ave.
j Wilmington, NC 28403
Phone: [phone];.
Fax: '910 792 *6853
el lab@hotmail com -
elernentOne
FINAL
REPORT OF ANALYSES
Pam Hester
December 29;
2003
TBL Laboratory
Client, Project Name;
Alchem, Inc.
P.O..Box 589
Client Project Number TBL-13616
Lumberton, NC 28359
I
PO Number
J ;
:.
E1 Project -Number'e2615
Sample #
Sample, ID
t
Lago6n#3
•
Sample Matrix ;
Sample Type
Date Received
12/16/03
Date Sampled 12/11/03 .:.
- Time
Sampled, ...0800
...............
; ..
....,Time Received
1515
Delivered by Picked Up
Sampler
Wayne-Drye
Received by
PDS
Page 1 of 1
E1 Sample'#
2615-1
Parameter
Result
Unit;
Dilution
DL
Method
Date
Sodium
218
mg/Kg
" 1
0.02
EPA 200.8
12/17/03
Magnesium
139
mg/I<g
1
0.02
EPA 200.8
12/17/03
Aluminum
21402
mg/Kg
1000
0.005
EPA 200.8
12/17/03
Phosphorus
85.4
mg/Kg -
1
0.02_.
EPA 200.8
-12/17/03
Calcium
885
mg/Kg
5 - _
0.05�- `-
': EPA 200.8 -
12/1.7/03
Chromium
14.3
mg/Kg '
1._ .
0.005
EPA 200.8
12/17/03
Manganese
4.15
mg/Kg
1
0.005
EPA 200.8
12/17/03 -
Nickel
1.32.
mg/Kg .<
1 ..,
0.005
EPA 200.8
12/1.7/03 .
Copper
3.13
mg/Kg
1
0.003
EPA 200.8
12/17/03
Zinc
1.57
mg/Kg ;
1
0.005 •
EPA 200.8
12/17/03
Arsenic
0.889
m /K
1
, 0.005
EPA 200.8
.12/17/03. • . _
Selenium
0.889'
m�/Kg
9 g
1 • �
0.005
EPA'200.8
12/17/03
Silver
0.356 ..
mg/Kg.
1
0.002_
EPA 200.8..._
12/17103
Cadmium
0.356
mg/Kg
1
0.002
EPA 200.8
12/17/03
Barium
82.4
m9 g/K
.
2'
0.005
EPA 200.8
12/17/03
Lead
29.7
,...
mg/Kg
2
0.003
EPA 200.8
12/17/03
Mercu ry`
0.0849
m /K
g g':
1 .
0.0002
EPA 245:1 �" ""
" " `12/23/03" . .
pH
3.57
SU :
1
EPA 9045C
12/17/03',
en Smit , Laboratory Director
'
NC Certifications, DW 37788 and DWQ DENR
604

~ Element One Inc..
' 5022-C Wrightsville Ave.
e' Wilmington, NC 28403
Phone:" 910 793-0128:
j i Fax: 910' 792-6853,',
t el lab@hotmaiI com
,�elementOne.:
;
-'�' --FINAL, REPORT
-OF:ANALI!SES.',.-..':....
Pam Hester
August 13, 2003
TBL Laboratory
Client Project Name ALCHEM, 1INC
;.;..
P.O. Box 589
Client Project Number
TBL-13205
Lumberton, NC
28359 " -
PO Number
'E1 Project Number e2075 .
Sample #
Sample ID
� `.Lagoon,#3
Sample Matrix
Sample Type
t ;
' Date Received
7/31 / 03'Y
Date Sampled
7/29/03 Time;Sampled; .
0800 ; .
Time Received
1630
Delivered by
".
Picked Up Sampfer' ` ""Wayne Dryer ' ; -
Received Eby
:-: PDS,:,>:,.
Page 1 of 1
Ef Saiiiple:##
2075=1
V�
Parameter
Result Unite "
Dilution DL
Method
Date
Sodium
153 mg%L_;;
5 0.01
EPA 200.81
811/03
Magnesium
105 ...mg/L, !
5 0.01
EPA 200.8
8/1%03,:
Aluminum
,_ 16800. mg/L,
50001 - 0.005;-.
EPA200.8.:
8/1/03„
Phosphorus
76:1' mg/L
5 0.01
EPA .200.8:..
8/1/03,
Calcium
827 .' mg/L` '
5 0.02 ::
EPA 200.8 v
8/1J03`
Chromium
`• 12;6 mg/L'. ;
5 ° 0.005
EPA 200.8 .
Manganese
4.14 'trig/L '
S 0.005 "
: "EPA'200.8'
8/1/03:'
Nickel
:"' 1.23 mg/L
;1 ' 0.005
EPA 200.8'
Copper
2.93 mg/L
`_ .5 ' 0.003
EPA'200.8
8/1/03 -
Zinc
1.65 mg/L
- .1 -:- - -. 0.005
EPA200.8 `
; 8/1/03
Arsenic
< 0.5, mg/L,
.1 0.005 ;
EPA 200.8;; ,
8/1103
Selenium
< 6.5 mg/L
i1 0.005 i
EPA'200.8,
8/1/03
Silver
0,210 mg/L
1 0.002
EPA 200.8E
`8/1/03 ?:
Cadmium
< 0.2 mg/L
1.. 0,002 ;
EPA 200.8'
; 8/1/03',
Barium
66.3 mg/L
5 ; 0.005
EPA200.8
8/1/03 "'
Lead
25,9 ". mg
5 0.003
EPA200.8
8/1/03
Mercury
=;0:0865; mg/L
,1 0.0002
EPA245.1..,
"8/6/03
pH
3.60 SU .
1 i
EPA 9045C
8/6/03.'
en Smith, Laboratory Director
NC Certifications:': DW 377,88 and DWQ DENR 604
:

ALCHEM., INC.
Corporate QMce
2042 Buie Philadelphus Road
Red Springs, NC 28377
Tel. [phone] — Fax [phone]
[e-mail]
April 5, 2004
Mr. D. Rex Gleason
Water Quality Regional Supervisor
NCDENR
919 North Main Street
Mooresville, NC 28115
Dear Mr. Gleason:
Sales and Manufacturing
8135 Red Road
Rockwell, NC 28138
Tel. [phone]aa8 — Fax [phone]
Nk; DEPi'. 0Ftjy i 6i� J � t}ntemet.net
AND NATURAL RESOURCES
RESVILLF 7—MMMAL OFFICE
' 'APR 1 2 2004
v
According to the agreement I signed with you Alchem, Inc. is supposed to advise you about continued cleaning of the
sand from out property and the property of two neighbors. We have told you that Alchem, Inc. has received a letter
demanding that we not trespass on the neighbor's property.
We were supposed to have a meeting with the attorney for the neighbors and their attorney on March 29, 2004. On the
morning of March 29, 2004 a woman from our attorney's office called and said that the wife of our attorney had a
stroke over the weekend and the meeting was rescheduled for April 30, 3004. We feel that we cannot enter the
neighbor's property without permission.
Also, the attorney Roman Pible is apparently contesting the agreement anyway. Are we supposed to ahead and start
making the payments? We are confused. Where do we make the payments? Do you invoice us? Please advise us on
what to do?
Best regards,
ALCHEM, INC.
Randall F. Andrews,
Consultant
vll

ALCHEM, INC,
8135 Red Road
Rockwell, NC 28138
J NV ✓ I E : / 0 l -- / / � ga.Ilir � r
^� 279� 7 4 279- 8418
[e-mail]
FAX TRANSMITTAL
Date and Time: December 31, 2003
To: Mr. D. Rex Gleason
Company: NCDENR
Fax No.: 704-663-6040
From: Randall Andrews
Company: ALCHEM, INC,
Phone No.: 704-279-7908
Fax No.: 704-279-8418
-No. of Pages: 3 , including cover
Message:
id W060:0i LOW iZ .Oaa ON Xdd /

ALCHEM, INC.
Corporate Office
2042 Buie Philadelphus Road
Red Cprjna,. INC 28377
Tel. [phone] — Fax [phone]
r1& semr.ncl
December 31, 2003
Mr. D. Rex Gleason
Water Quality Regional Supervisor
NCDENR
919 North Main Street
Mooresville, NC 281.1.5
Dear Mr. Gleason:
Sales and Manufacturin
8135 Rod Road
Rockwell, NC 28138
Tel. [phone] — Fbx 704-279.8418
pdrye [e-mail]
Alchem, Inc. is certain you are aware of the problems at our plant in Rockwell. Alchem, Inc. is interested in the
possibility of settling with you on this. Alchcm, Inc. is sure you know the real problem was that Alchem, Inc. has had
very large amounts of rainfall. Rainfall amount information from Salisbury is being included.
Alchem, Inc feels that they have been in compliance with all of the regulations until this very large amount of rainfall
came. When Alchem, Inc. did find that Alchem, Inc. had a problem Alchem, Ilse, had trouble repairing the problem
because of the large amount of rainfall. Alchem, Inc. also has found that the dry run creek is normally at a ph or about
4.2 to 4.5 after a rain fall event. Alchem, Inc. recognizes that the spring that is located on the property has a ph of
about 6.
However,, the rainfall in the area is at ph 4.2. Therefore Alchem, Inc. does not feel that we are causing a low ph. The
low ph is natural. Alchem, Inc. also found that there is an abundance of aquatic life in the stream. Alchem, Inc. would
like to ask you to do the following:
a
Abate the S 2,000.00 penalty for low stream ph as the rainfall has a 4.2 ph.
Settle the rest of the penalty at fifty percent.
Alchem, Inc. will pay the investigative costs.
Alchem, Inc. would like to inform you that they have spent over S .10,000.00 cleaning up the sand down stream from
our property. Alchem, Inc. has put up a much larger holding bank ofdirt. Alchem, Inc. feels this can never happen
again. Although financial considerations are not your problem the last three years have been difficult .for them
financially. Please give Alchem, Inc. any consideration that you can.
Best regards,
ALCHEM, INC.
Randall F. Andrews,
Consultant
vll
Zd WHOT :OZ 200E ZZ '3aQ 'ON Xdd WOcld

v State Climate Office of NC: piedmont Research Station (SALI) data retrieval Page l of 1
Station: SALT - Piedmont Research Station Date of first observation: 07/24/1996
Station type: ECONET - Tower U
City, State_ Salisbury, NC County: Rowan County
Latitude: 35.7° Longitude:-80.620
' Elevation: 823 feet above sea level
Climate division: NC04 - Central Piedmont
River basin: Yadkin —
Supported by: NC Agricultural Research Service
Retrieving monthly data from Piedmont Research Station for 11/2002 thru 11/2003
13 records found for this time period
uClick here to plot 08111y Precipitation
`
DatelTimte of ob
monthly SUM of
Daily Precipitatioia
at 2m (in)
11/2002
4.31
12/2002
5.17
01/2003
1.11
02/2003
3.72
03/2003
6.88
04/2003
9.06
05/2003
6.31
06/2003
5.46
07/2003
5.78
08/2003
5.35
09/2003
�5,32
10/2003
1.7
11 /2003
0.5
NC CRONOS Database version 1,Sq
Page expelled in 0.044 secs.
file://C:1Docutncnts%20and%20Settings\adztiinistratol-Tocal%20ScttinL,s\Tni-nnnmr0r%?n t I /I
Ed WdOT:OT 200E 12 '3aQ : 'ON Xdd : WObd

U
J ALCHEM INC
/!+ 8135 RED ROAD
ROCKWELL, NC 28138
704-279-7908 fax [phone]
[e-mail]
September 9, 2003
Mr. Wes Bell
NCDENR
Division of Water Quality
919 North Main Street
Mooresville, NC 28115
Dear Mr. Bell,
I am sending to you the letter from Andrews & Associates for the remediation proposal
offered.
Alchem, Inc has completed the trench 24" X 24" to divert the storm water from Red
Road around the impounded area.
Tara Group has completed the berm 5' X 8' wide around all the impoundment area and
all low grade areas.
Tara Group is close to completion on the enlarged settlement basin.
Our goal now is to remove all sand from the stream and adjoining property owners as
soon as possible.
Best regards,
ALCHEM, INC
Wayne Drye,
U

A'
`gyp fr.a-4, ... �,�.y, e,�_.
u ..v _ i.. :�i� - • 99
2.
66_ N D? ®1� NTAL _E DL. T ON CONSULTANTS
2522 Parrish Street
Burlington, NC 27215
Phone: [phone] — Fax: [phone]
September 9, 2003
Mr. Wayne Drye
Vice President
ALCHEM, INC.
8135 Red Road
Rockwell, NC 28138
Subject: Remediation of Affected Arcas
Dear Mr. Drye:
Concerning the Client Report:
1. Removal of sand from seasonal tributary.
2. Removal of sand from areas outside of impoundment boundaries.
3. Increased containment at property line.
4. Remediation of neighboring property.
Remediation Proposals:
The best solution for the removal of the sand would be the use of a "Sand Hog Type" pump. Fluidizing the sand using
water from the seasonal tributary or well water- only would do this. No impounded water would be used for this purpose.
The resulting slurry would be pumped to the impoundment area for proper treatment. I can arrange for the equipment and
people to do this or I can supervise Alchern, Inc. employees during the removal.
I would also recommend that a trench 12" to 18" with a berm 1 to 2ft. high be dug at the nearest point to the property line
that is feasible. This would catch the rainwater, which would then be pumped, back to the impoundment area. This will
result in zero discharge from your facility. We are contacting the owners of the adjoining properties to work out a
remediation plan that is agreeable to them. I expect to have a plan for this in the next two weeks.
Conclusion:
The remediation can be accomplished with minimum disturbance to the environment using the proposals that I have out
lined above. Please let me know your decision as soon as possible so that the proper equipment may be obtained. We can
start within 2 to 3 days of its arrival.
Sincerely,
ANDREWS & ASSOCIATES
-Kko�', Clk
Keith Andrews,
President

ALCHEM, INC
8135 RED ROAD
ROCKWELL, NC 28138
704-279-7908 fax [phone]
[e-mail]
July 7, 2003
Mr. D. Rex Gleason
Water Quality Regional Supervisor
NCDENR
919 North Main Street
Mooresville, NC 28115
Dear Mr. Gleason:
I have enclosed the plan for the site work at Alchem, Inc. I have also given the plan to
Mr. Greg Greene, CPESC, Environmental Specialist 1, of the Rowan County
Environmental Services in Salisbury, NC.
If you should have any questions please give me a call.
Best regards.
ALCHEM, INC
Wayne Drye, �J
Vice President
M

ALCHEM,, INC
8135 RED ROAD
ROCKWELL, NC 28138
704-279-7908 fax [phone]
pdrye. aIchem@cb i internet.com
February 5, 2003
Mr. J.R. Joshi
NC Division of Water Quality
Non -Discharge Compliance/Enforcement Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Dear Mr. Joshi:
Enclosed is the Monitoring and Reporting requirements for our permit number
WQ0016338.
For the year of 2002, we used 2,538 tons of Silica residual from our on -site bauxite
digestion process as a fill material. I have included the Annual Residual Sampling
Summary form and a map.
Please let me know if you have any questions.
Best regards,
ALCHEM, INC
&'�m V - ;"I "
Randall F. Andrews,
President

ANNUAL RESIDUAL SAMPLING SUMMARY FORM
Attach this form to the corresponding laboratory analysis
Please note that your permit may contain additional parameters to be analyed than those required to be summarized on this form_
Permit Number WQ0016338
Facility Name ALCHEM, INC. LABORATORY 1) TBL LABORATORY
NPDES # 2)
or WO # (residual only Facilities) 3)
WWTP Name
Zesidual Analysis Data
Date Sampled (grab) or 08/09/02 01 /15/03
Date Composited
Percent Solids
i
Pnrmmc,tnrc Imnitrn rint wpinhtl
Aluminum
10,700
7,900
Arsenic
3.05
<.04
Barium
21.9
36.9
Cadmium
2.2
<0.2
Calcium
95.0
583
Chromium
81.10
6.64
Copper
18.8
2.13
Lead
126.0
.
14.3
Magnesium
25.4
126.0
Manganese
0.7
3.3
Mercury
0.033
0.067
Nickel
7.36
0.554
Selenium
<0.4
<0.4
Silver
0.77
<0.2
Sodium
99.0
101.0
Total Phosphorus
12.8
43.0
Zinc
20.2
1.75
X %O�(l J- , (i,,c�(, 1, L- - 24' 02/05/03
(SIGNATURE OF PREPARER) DATE
" I certify, under penalty 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 evaluated the information submitted. I am aware that there are
significant penalties for submitting false information, including the possiblity of fines and imprisonment for knowing violations."
DEM FORM SSF (10/94)

y
l / 49.00'
S 0I'-03•-00-E 810.97' S 01'-02'-20"E 1294.OZ
/ o
Well
Lagoon
CD 11
p Zvi °I
Won
/ M �c r 1 / • \ Ff
Acres / /
Well / 6tr C N 2k• �d /j / 1 - , '
Ca\rNA RDAO
8 NORTHWESTERN o p -
(• Nm
p
p N to
1 r-,
uk
bet
�h h O Pin N. N� � Co
O iv to q r p A00
-
= O O O
_ --- - -- - - - Well M. >f I • - _• --- •: �- f•} - - -
�•
- Top of well elevation . 80923' 12 � 200 f
i Ground elevation . 808.14'
(Latitude . 3S•_33•-S• 2.rJ(4 Longitude ..80•-
J2s'-zar •� �--'�
v I Stalk wf.r I -of below gap of casing . 32.
1 Woler level from Wayne Dry. of ALCEK Inc.)
Top of well elevation - 805.18'
i Ground elevation . 802.89- -
i Latitude a 33•_33-.
Longitude . 80•-2a'-2G G--
Slatic water level below, top of casing'. 22
1 water level
�- from wed! Conshitillon records) -
Top of weg elevation . '
Ground elevation . - ,
Latitude . 791-20-
L20
aa•-aa•_a�.a- _ -
Langttude - eo•-29'-2La'
stalk water level below
top of cuhq . I3'
Water level from weA conshrcllon records I ` -

eft
elementOne
FINAL REPORT OF ANALYSES
Element One Inc.
5022-C Wrightsville Ave.
Wilmington, NC 28403
Phone: [phone]
Fax: [phone]
el [e-mail]
Pam Hester
January 15, 2003
TBL Laboratory
Client Project Name
ALCHEM, Inc.
P.O. Box 589
Client Project Number
TBL-12614
Lumberton, NC 28359
PO Number
E1 Project
Number e1274
Sample #
Sample ID
Lagoon #3
Sample Matrix
Sample Type
Date Received
1/9/03
Date Sampled 1/7/03
Time Sampled
0800
Time Received
1345
Delivered by Picked Up
Sampler
.
Wayne Drye
Received by
CMO
Page 1 of 1
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
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
1/18/03
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
Aenmith, Laboratory Director
NC Certifications: DW
37788 and DWQ DENR 604

....... . .
Element One Inc.
5022-C Wrightsville'Ave.
Wilmington, NC'28463.
Phone: [phone]
Fax: [phone]
al Inh n7t hnf nil d-r%M
elementOne
FINAL REPORT OF ANALYSES
Pam'Hester
August 9, 2002
7Laboratory BL Laborato
Client Project Name ALCHEM Inc
..,:P.O. Box 589
Client Project Number TBL-1 2141
Lumberton, NC 28359
P.O Number
E1 Project Number e0625
.,Sample #
Lagoon #3
-hple
Sar Matrix
Sample Type
Date Received:':
02,
7 26/-
aeS
Date Sampled 7/24/02
Time Sampled
0800
'i
Time Rece ved
1640'.
Delivered by Picked Up
Sampler
Wayne Drye
Received by
BGH',,
Page 1 of 1
El Sample#
0625-1
Parameter
Result Unit
Dilution DL-
Method
Date
Aluminum
10700 mg/Kg:
1000 0.8
EPA 200.8
8/5/02''.
Arsenic
.3.05. mg/Kg
1 0.4.
EPA 200.8-
8/5/02,
Barium
21.9'- mg/Kg
0.4-
EPA 200.8
8/502
2.20 'mg/Ko
A 0.2
EPA A 200.8
":.,,8/5/02
Calcium
95.0 mg/Kg
1 1.6
EPA 200.8
8/5/02
Chromium.
81.1 mg/Kg
1 0.4
EPA 200.8
1" 8/5/02'
Copper
18.8 mg/Kg
1 0.2
EPA 200.8
8/5/02
Lead
126 mg/Kg
1 0.2
EPA 200.8
Magnesium
25.4 mg/Kg
1 0.8
EPA 200.8
.8/5/02
8/5/02
Manganese
0.70 mg/Kg
1 0.4
EPA 200.8
8/5/02
Mercury
0.033 mg/Kg
1 0.01
EPA 200.8
8/1/02
Nickel
7.36. mg/Kg
1 0.4
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
0.4
EPA-200.8.
..`'8/5/02
Silver
0.77 mg/Kg
1 0.2 -
EPA 200.'8
8/5/02..'
Sodkirh'
.99.0 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',
pH
3.4 SU
1
EPA 9045G:,
.8/9/02
7.
en Smith, Laboratory Director
NC Certifications: DW 37788,and DWQ DENR 604

ALCHEM, INC.
Corporate Office
2042 Buie Philadelphus Road
Red Springs, NC 28377
Tel. [phone] -- Fax [phone]
[e-mail]
January 17, 2002
Mr. D. Rex Gleason, P.E.
NC Division of Water Quality
Mooresville Regional Office
919 North Main Street
Mooresville, NC 28115
RE: Permit # WQ0016338
Dear Mr. Gleason:
Sales and Manufacturin
8135 Red Road
Rockwell, NC 28138
Tel. [phone] --- Fax [phone]
[e-mail]
After reviewing your letter of January 15, 2002 and our files we have found these reports
were sent to the Raleigh office to the attention of Mr. Kevin Barnett.
I am sending to you the copies of the reports which were sent to that office. I am also
sending the letter that was attached to the reports in question.
For future reports, would you let us know the correct person to send these reports to.
Please let us know if you have any questions.
Best Regards,
ALCHEM, INC
Randall Andrews,
President

ALUHEIV1,q IN lam.
Voroorate Office Sales and Manufacturing
2042 Buie Philadelphus Road 8135 Red Road
Red S `rm NC 28
p 8s+ 377 RodnyeU, NC 28138
Tel. [phone] -- Fax [phone] Tel. 7o4-279-79o8 — Fax 7o4-279-8418
[e-mail] pdrjealchem@cbunternetnet
December 22, 2000
Mr. Kevin Barnett
NC DIVISION OF WATER QUALITY
WATER QUALITY SECTION
Non -Discharge Compliance/Enforcement Unit
512 North Salisbury Street
9th Floor
Raleigh, NC 27604
Dear Mr. Barnett:
Enclosed is the Monitoring and Reprting Requirements for our permit number
WQoo16338. For the year of 2000, we used 2, 885 tons of Silica residual from
our on -site Bauxite digestion process as fill material for our building. Enclosed
you will find the Annual Residual Sampling Summary form and a map. Please
call me if you have any questions.
Best regards,
ALCHEM, INC.
lwhh'�Ell mlt�j / ��
Randall Andrews,
President
vll

ANNUAL RESIDUAL SAMPLING SUMMARY FORM
Attach this form to the corresponding laboratory analysis
Please note that your permit may contain additional parameters to be analyed than those required to be summarized on this form.
Permit Number WQ0016338
Facility Name ALCHEM, INC. LABORATORY 1 TBL LABORATORY
NPDES # 2
or WQ # (residual only Facilities) 3)
WWTP Name
Residual Analysis Data
Date Sampled (grab) or 7/25100 11/17/00
Date Composited
Percent Solids
Parameters (ma/ka dry weiaht)
Aluminum
18,740
10000
Arsenic
<5.000
BDL
Barium
38.78
36.0
Cadmium
<0.5000
BDL
Chromium
13.79
5.5
Copper
<5.000
1.2
Lead
12.22
8.9
Mercury
<0.01000
0.049
Nickel
2.411
BDL
Selenium
<5.000
0.64
Silver
<0.5000
BDL
Sodium
157.0
170
Total Phosphorus
0.210
0.71
Zinc
1
1 9.8151
1 2.4
X
(SIGNATURE OF PREPARER) DATE
" I certify, under penalty 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 evaluated the information submitted. I am aware that there are
significant penalties for submitting false information, including the possiblity of fines and imprisonment for knowing violations."
DEM FORM SSF (10/94)

. .. .. .......: \. ... .... ..._ .5�. .. .\'11�...'.1.. .. .. ... ..n ...,.._.. _._.•.\�:�... �::t.`l �~I:�. ..... ._. .. �t.tl .. .. .t `...___�. til_.'.wt17�n.i:C. �•1���'i�, J:i��.�i-�: 1'.1 v?a:'ii.:.��. t': wa.
t Z
ALCHEM, INC.
2042 BUIE PHILADELPHUS ROAD RED SPRINGS, NC 28377
910-843-2121- FAX [phone] - EMAIL [e-mail]
December 22, 2000
Mr. Kevin Barnett
NC DIVISION OF WATER QUALITY
WATER QUALITY SECTION
Non -Discharge Compliance/Enforcement Unit
512 North Salisbury Street
9ch Floor
Raleigh, North Carolina 27626-0535
Dear Mr. Barnett:
Our permit number is WQ0016338. We would like to request that you allow our
company to start testing only once a year for the residual analysis in the year 2001. This
is in accordance with our permit. A copy of the affected page is enclosed. Please let us
hear from you.
Best regards,
ALCHEM, INC.
Randall Andrews,
President
vll

NHEMC I.ctu�La MamaAan
sales
Corporate Office
2042 Buie Philadelphus Road
Red Springs, NC 28377 5789
Tel. [phone] -- Fax 910-843-
[e-mail]
March 14, 2000
Mr. Kevin Barnett Quality
NC Division of Water Q ty
Water Quality Section
Non -Discharge Compliance/ Enforcement Unit
512 North Salisbury Street
9tn Floor
Raleigh NC 27604
8135 Red Road
Rockwell, NC 28138
Tel. 704-27 d 7 e0alchem@cb0 n?eme�n 8
P �
fl . j dl'� "
t4A
61, jkA-44'
Dear Mr. Barnett: permit number
Enclosed is the Monitoring and Reporting Requirements for our
wQ0016338.
99, we used 21755 tons of Silica residuaherCemainingm our n
-site BauAlte
For the year of 19requirements
digestion process as a fill material. Following you will find t
for our permit. our this
r company additional days for sending
We would like to thank you for allowing questions, please let me know.
information to your office. If you have any q
Best Regards,
ALCHEM, INC.
Randall Andrews,
President
ko

02/11/2005 10:19 7042798418 ALCHEM INC PAGE 01
ALCHEM., INC.
CPrparat6 Qfice Saves and Manufacturing
2042 Buie Philadelphus Road 8135 Red Road
Red Springs, NC 28377 Rockwell, NC 28138
Tel. ,M-843-2121 -- Pax 910-843-5789 Tel. [phone] -- Pax 704-279-8418
rfa�semr.net 1% [e-mail]
C
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.
I will continue giving you reports of our progress.
Best regards,
ALCHEM, INC.
Oja'Y Gj-� r"
Wayne Drye,
Plant Manager
A

ALCHEM, INC
8135 RED ROAD
ROCKWELL, NC 28138
704-279-7908 fax [phone]
[e-mail]
January 27, 2005
1.4
JUL 1 1 2005
Mr. Wes Bell
Environmental Tech IV
NCDENR
Division of Water Quality
Mooresville Regional Office
610 East Center Ave. Suite 301
Mooresville, NC 28115
Dear Mr. Bell:
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
C)c4 '-Q- 1Dfkj-)e'
Wayne Drye,
Plant Manager
ped

WATER & LAND SECTION Fax:[phone] Nov 8 '04 15:25 P.01
ROY (: c)c.)P R
ATTORNEY GENET tAL
State of North Carolina
Department of Justice
goo I Mail Service Center
RALEIGH, NORTH CAROLINA
27F399-C-)W I
FAx TRANSMISSION
ENVIRONMENTAL. DIVISION
[phone]
Fax: [phone]
To: Wes Bell
Fax #: [phone]
From- Stormie D. roue
Subject: Alcham
COMMENTS:
Date: November 8, 2004
Pages: 9 pages, includmi g this cover
sheet.

DATER & LAND SECTION Fax:[phone] Nov 8 '04 15:25 P.02
From:WOODSON SAYERS AND ATTYS 704 000 41F-3 08/18/2004 28:24 #OSJ P.002/002
WOODSON, SAYERS, L LATHER, SHORT
i PARRQT'r & WALKER, L.L.P
ATTORNEY$ AND COUNSELLORS AT LAW
245 NoPtTW MAIN ST19CI"T, SUITE: P-00
00NAL0 V� SAYZRS
POST CiRFICr Dax eag WALYCR H.WOouSUN IB7R-IS1b4
F. F71VEii3 L/'4lYHL'R,JR.
SALIA;BURY, NoPTM CAROUNA 2S145-0029
CAhI I�I,8MOh1, J�•
�-
B.EoWAnn PP11r,01Y
TLLLPMON6 (70-4) 043-h000
$FAN C.WALkER
TCLeFAx(7041 837-2398
6-MAIL: W00d1aW*0dr0FT)A,rtC0M
August 19, 2004
I
Stonnie D. Forte
Associate Attorney General
1lnvirontnental Division
§001 Mail Service Center
Raleigh, North Carolina 27699-9001
NTTA FAC,SiM1LE; 919i,716.6766
Dear Stomlie:
I
1 received a call ,f#'om your assistant this monvng as to whether I continue to
opresent Alchom, Inc. U.1yropreaernation ofAlctaein was completed in this matter when
the proposed Motion to Intervene was denied. I understand that Mr, Randall Andrews
has requested that you deal directly with him regarding further issues POTI, ini ng to this
case and X would agree. Iailight of Mr.. Andrt;ws request altd the fact that the litigation is
Qncluded, I no longer colnsidex myself attorney of record in this matter for Alchem.
Accordingly, feel free to deal directly and correspond directly with Alchem, I11c.
Iai) d Mr. Andrews.
I
Kiudest rtgards,
I
-'Sean C. Walker

WATER & LAND SECTION Fax:[phone] Nov 8 '04 15:25
y STATF
State of forth Carolina
ROY COOPER
ATTORNEY OENERAL
Department of Justice
9001 Mai) Service Center
RALEIGH, NORTH CARO.(v NA
27699-C" l
August 24, 2004
Randell Andrews
Alchem, Incorporated
2042 Buie Philadelphus Road
Red Springs, North Carolina 28377
Re. AlchernInc. v NCDE Division of Water Quality
Office of Administrative Hearings
File No. 03 EHR..1587
Dear Mr. Andrews:
Reply to:
Stormic D. Fortc
Environmental Division
Tel [phone]()
Fax [phone]
[e-mail]
P. 03
I am writing in response:to your letter dated August 13, 2004. Pursuant to the terms of the
settIement agreement for this mkter, Atchem will make twenty-four (24) monthly payments. The
first payment in the arnount of $ ?03.30 is due on September 15, 2004, The twenty-three
subsequent payments will be due on the first day of each month consecutively and will be in the
amount of $203,26, The last payment shall be, due and payable on or before; August 1, 2006,
The checks should be made payable to the North Carolina Department of Environment
and Natural Resources (or to "D.I:NR") at the following address:
Stormie D. Forte, Esq.
Attorney General's Office
Environmental Protection Division
9001 Mail Service Center
Raleigh, NC 27699-9001
MY office will send you a confirmation letter for each payment received. We will not
send you a monthly bill, however, we will. send you a reminder netice if your payment is not
received by the first day of each month_

DATER & LAND SECTION Fax:[phone] Nov 8 '04 15:26 P.04
Alchem-Fage 2
If you have any additional questions or concerns, please feel fine to contact me-, With best
wishes, I am
Very truly ou ,
• Stormie D. Fo e
Associate Attorney General

UJRTER & LRND SECTION Fa.x:919-716-6766 Nov 8 '04 15:26 P.05
SPATE OF NORTH CAROL;INA FILED IN THE OFFICE OF
ADMINISTRATIVE HEARINGS
COUNTY OF ROWAN, t 2604 MAR ,2 p 3= SO 03 EHR 1587
OFFICE OF
ALCHE,M, INC., WAYNE D. DRYE, ADMIOISIRATWE
HE)ARIUGS
Petitioner, )
V. )
SETTLEMENT AGREEMENT AND
NORTI4 CAROLINA DEPARTMENT OF WITHDRAWAL OF PETITION
ENVIRONMENT AND NATURAL )
RESOURCES, DIVISION OF WATEF, )
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 ixi 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-eiglit cents ($39828)
in enforcement costs), imposed upon Petitioner on August 18, 2003 for alleged violations of
North Carolina General Statuter, § 143-215.1 et seq and Non -Discharge Pen -nit W00016338.
J)ENR and the Petitioner have reached the following settlement agreement in this matter:
1. Petitioner will adhere, to the followring conditions:
a. Petitioner will submit a plan or schedule to remove sand and
other materials from a tributary to Second Creek and the
-1-

WATER & LAND SECTION Fax:[phone] Nov 8 '04 15:26 P.06
riparian areas of the two affected private properties adjacent
to Alchem, Inc.;
b. Petitioner will submit a plan or schedule for removal of sand
and other materials deposited by Petitioner's facility to the
Moordsville Regional Office of the Division of Water Quality
within thirty (30) days of execution of this agreement.;
o. Pletitioner shall remove sand and other materials from the
creek, creek bank, and the areas where the deposits exist in
tb.e forested area adjacent to the creek located on property
owned byAlchem, Inc. andthe two affected private properties
adjacent to Alchem, Inc, in accordance with the plan or
schedule 5ubm.itted.;
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 $5,600.00 - 20% of penalty = 4$ ,480.00 (80% of penalty) + investigative costs of
398. = $4,878,28) to DENIM for settlement in the manner hereinafter described. The
Settlement Amount shall be mdde 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-

WATER & LAND SECTION Fax:[phone] Nov 8 '04 15:27 P.07
March 1, 2004 in the amount of two hundred three dollars and ilaiily cents ( OIS' 0). Each
payment thereafter shall be due and payable on the 1" day of each month consecutively in
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 du.e and payable on or before
February 1, 2006.
3. The payments shall he by check made payable to the North Carolina Department
of Environment and Natural Resources (or to "DENR") at the following address;
Stormie, D_ Forte, Esq.
Attorney General's Office
Environmental Protection Division,
Post Office Box; 629
Raleigh, NC 271602-0629
4. The breach of ao.y condition. of Paragraphs one (1), or two (2) by Petitioner will
render due and payable the entil e 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 ]7ENR 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 Ietitioner, the sole issue in any action by DENR is to collect the
Entire amount or 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
teens of paragraph four (4) above and will be limited to the Petitioner's compliance with the
terms of this Agreernent.
-3.

WATER & LAND SECTION Fax:[phone] Nov 8 '04 15:27 P.08
S. DENR agrees to accept payments totaling four thousand eight hundred seventy-
eight dollars and twenty-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 fixture Aolations; 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.C. § 523.
Nothing in this Agreement releases any nondischar-geability claims that may be asserted by
DENR. in any bankruptcy proceeding, and nothing in -this Al reernent 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 nondisdliargeable.
S. This Agreement'ishall be binding upon the parties and is entered into knowingly,
intelligently, and voluntarily.
-4-

WATER & LAND SECTION Fax:[phone] Nov 8 '04 15:27 P.09
WITHDRAWAL OF PETITTON
9. Entry of this Asymement serve as Petitioner's Withdrawal of its Petition for
Contested Case Hearing Without Prejudice in these matters. The parties agree this natter is
concluded and that no further proceedings are neededor required to resolve the contested. case.
This the _[�.f day of February 2004.
FOR THE DIVISION OF WATER.
QUALITY
Alan Klimek, Director of
Water Quality
Date:
D. Rex Gleason, Mooresville .
Regional Supervisor
Date: S ` 6
ROY COOPER
Attorney General
By: � &4
Storm.ie D. Forte
Associate Attom.ey General
N'. C. Department of Justice
Environmental Division
9001 Mail Service Center
Raleigh, NC 27699-9001
[phone]
[phone]/Fax
-s-
PETITIONER:
Alchem, Inc., Wayne D. Drye
Date:r,��
Randall F. Andrews, Consultant
Alchein, Inc.
Date: -1z -, Zovt

ROY COOPER
ATTORNEY GENERAL
Sean C. Walker, Esq.
State of North Carolina
Department of .Justice
9001 Mail Service Center
RALEIGH, NORTH CAROLINA
27699,9001
July 29, 2004
Woodson, Sayers, Lawther, Short, Parrott & Walker,-L.L.P.
Attorneys and Counselors at Law
Post Office Box 829
Reply to:
Stormie D. Forte
Environmental Division
Tel [phone]
Fax [phone]
Sforte@ncdoc�otupe
Mj)MAf uPPL f+,ES0URCE8
OFFICE,
AUG 0 2 200A
Salisbury, North Carolina 28145-0829 ,`'`'
WATER
Re: Alchem, Inc., Wayne D. Drye. v. NCDENR Division of Water Quality
Office of Administrative Hearings
File No. 03 EHR 1587
Dear Mr. Walker:
I am writing'regardirig'the Settlement Agreement that was previously executed and filed
in this matter. As you are aware, we agreed to suspend the terms of the agreement regarding
payment of the Civil Penalty until the issue 'of the Motion to Intervene was resolved. Judge Mann
denied the motion. Therefore, the Settlement Agreement is considered properly filed and its
terms maybe implemented.
We are requesting the first monthly payment, in the amount of $203.30 be made by
August 15, 2004. Each subsequent payment is due by the first day of -leach month for twenty three
(23) consecutive months. The final payment will be due on or before July 1, 2006.
If you have any additional questions or concerns, please feel free to contact me. With best
wishes, I am
Very truly ours,
M �V �r-
./k
Stormie D. Forte
Associate Attorney General
ater Quality Regional Supervisor, Mooresville Regional Office

ALCHEM, INC
8135 RED ROAD
ROCKWELL, NC 28138
704-279-7908 fax [phone]
[e-mail]
December 9, 2004 ,lv
Mr. D. Rex Gleason, , C
Mooresville Regional Supervisor
NCDENR
Division of Water Quality
Iredell County Government Center South
610 East Center Avenue, Suite 301
Mooresville, NC 28115
Subject: Remediation of affected areas
Dear Mr. Gleason:
Alchem, Inc has already removed 80% of sand on Alchem, Inc property, creek bank and
creek. Alchem, Inc has removed 80% of sand on a tributary to Second Creek and the
riparian areas of the two affected private properties adjacent to Alchem, Inc. The
affected areas are in a very low area that stays wet most of the time.
Alchem, Inc will remove all sand from the creek and creek bank.
Alchem was served with a civil action for trespassing on the two affected private
properties adjacent to Alchem, Inc. Therefore, this stopped the cleanup on these
properties. Alchem, Inc will continue the clean up on the two affected adjacent
properties with a vacuum pump and any equipment needed to complete the clean up.
Alchem, Inc will need to have written permission from the two adjacent private property
owners attorney before we can complete this clean up.
Best Regards,
ALCHEM, INC.
Wayne D Drye,
Plant Manager
Z
p01 1

01/27/2005 16:38 7042798418 ALCHEM INC PAGE 01
4W/ ALCHEM, INC.
8135 RED ROAD
ROCKWELL, NC 28138
704-279-7908 FAX: [phone]
pdrye0balltel,net
FAX
TO; FROM;
Mr, D. Rex Gleason, P.E. Wayne Drye
FAX NUMBER: DATE:
1 /27/2005
COMPANY: TOTAL NO. OF PAGES INCLUDING COVER;
NCDENR 2
PHONE NUMB U• R:
RC:
Tracking #: NO V"-2005-SS-001

01/27/2005 1G:38 7042799418 ALCHEM INC PAGE 02
ALCHEM, INC
8135 RED ROAD
ROCKWELL, NC 28138
704-279-7908 fax [phone]
pdrye a alltel_net
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 employees have applied some 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. Alchem is in the process now of
putting rip zap rock at the base of the silt fence and the silt fence will be observed more often.
'Para 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 ply testing every week since the last N.Q.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 permitting.
If possible we would like to meet with you before you take any action on this.
Best regards,
ALCHEM INC
Wayne Drye,
Platt Manager
pcd

OF W AT�R Michael F. Easley, Governor (Ad
William G. Ross Jr., Secretary
`O� QG North Carolina Department of Environment and Natural Resources
: r Alan W. Klimek, P. E. Director
—{ Division of Water Quality
ti� Y Coleen H. Sullins, Deputy Director
Division of Water Quality
n
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
VA
14CDENR
N. C. Division of Water Quality Mooresville Regional Office 919 North Main Street Mooresville NC 28115 [phone] Customer Service
1-877-623-6748

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,
15A NCAC 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;

STATE OF NORTH CAROLINA
COUNTY OF ROWAN
IN THE MATTER OF ALCHEM, INC.
FOR VIOLATIONS OF:
N.C.G.S. 143-215.1,
15ANCAC 2B .0211(3(g), AND
PERMIT CONDITIONS OF
NON -DISCHARGE PERMIT NO
WQ0016338
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
File No. PC/SS
FINDINGS AND DECISIONS AND
ASSESSMENT OF CIVIL PENALTIES
Acting pursuant to delegation provided by the Secretary of the Department of
Environment and Natural Resources and the Director of Water Quality, I, Jeffrey O. Poupart,
Supervisor of the Non -Discharge Compliance and Enforcement Unit of the Division of Water
Quality (DWQ), make the following:
FINDING OF FACT:
A. ALCHEM, Inc. is a corporation organized and existing under the laws of the
State of North Carolina.
B. ALCHEM, Inc. operates a bauxite residuals reuse program (as structural fill) on
ALCHEM, Inc.'s property, which is located at 8135 Red Road in Rockwell, North
Carolina.
C. On January 21, 1999, ALCHEM, Inc. was issued Permit No. WQ0016338,
effective January 21, 1999, with an expiration date on December, 31, 2004.
D. Permit No. WQ0016338 issued to ALCHEM, Inc. contained the following
conditions:
Part I., Section 1, Performance Standards
The residuals program shall be effectively maintained and operated as a non -
discharge. system to prevent the discharge of any wastes resulting from the
operation of this program.
Part II, Section 3, Operation and Maintenance Requirements
Adequate provisions shall be taken to prevent wind erosion and surface runoff
from conveying pollutants from the residuals treatment area onto the adjacent /
property or into any surface waters.

ALCHEM, Inc.
Findings and Decisions
Page Two
Part III (Monitoring/Reporting Req.$), Section 6, Noncompliance Notification
The permittee shall report by telephone to the Mooresville Regional Office,
telephone number [phone], as soon as possible, but in no case more than 24
hours or on the next working day following the occurrence or first knowledge of
the occurrence of any of the following:
Any'failure of the reuse program resulting in a release of material to receiving
waters.
Persons reporting such occurrences by telephone shall also file a written report in
letter form within five (5) days following first knowledge of the occurrence.
E. The surface water quality standard for pH is between 6 — 9 s.u., as set forth in 15A
NCAC 2B .0211 (3)(g).
F. On April 30 and May 8, 2003, DWQ/MRO investigations had determined that the
runoff from ALCHEM, Inc.'s residual storage area had impacted up to 500 linear
feet of a tributary to Second Creek and the riparian areas of two adjacent private
properties. Inadequate erosion control measures were observed at ALCHEM,
Inc.'s residual storage area. DWQ/MRO staff measured up to 24 inches of
residual deposition in the tributary and up to 12 inches throughout the riparian
areas. A sediment basin (at the residual storage area) was observed discharging
into the tributary during both site investigations. Several pH measurements of the
impacted tributary were measured in the range of 4.15 s.u. to 4.22 s.u. and the pH
of the sediment basin discharge was measured at 3.86 s.u. Both discharges had
caused the instream pH to fall below the 6 — 9 s.u. pH stream standard range for
Class C Waters. The release of the residuals into the tributary was never reported
to DWQ/MRO.
G. On May 12, 2003, DWQ/MRO orginally issued a.Notice of Violation and Notice
of Recommendation for Enforcement -to. ALCHEM, Inc., for violations of
.conditions of Permit No. WQ0002702 and surface water quality standards. Upon
DWQ/MRO's further investigation it was found that the referenced permit number
was incorrect. On May 14, 2003, DWQ/MRO, issued a clarification letter that had
corrected the referenced permit number to WQ0016338.
H. ALCHEM, Inc. was issued a NOV on January, 15, 2002 for the failure to submit
the required monitoring reports stipulated in Section III, Parts 3 and 4 of Permit
No. WQ0016338.

ALCHEM, Inc.
Findings and Decisions
Page Three
I. The cost to the State of the enforcement procedures in this matter totaled $398.28.
Based upon the above Findings of Fact, I make the following:
II. CONCLUSIONS OF LAW:
A. ALCHEM, Inc. is a "person" within the meaning of G.S. 143-215.6A
pursuant to G.S. 143-212(4).
B. Permit No. WQ0016338 is required by G.S. 143-215.1.
C. ALCHEM, Inc. violated G.S. 143-215.1 and Permit No. WQ0016338 by
not properly operating and maintaining the facility as a non -discharge
facility.
E. ALCHEM, Inc. violated G.S. 143-215.1 and Permit No. WQ0016338 by
failing to provide adequate provisions to prevent surface runoff from
conveying pollutants from the residuals treatment area onto adjacent
property or into surface waters.
F. ALCHEM, Inc. violated G.S. 143-215.1 and Permit No. WQ0016338 by
failing to notify this office of the residuals release into the receiving stream.
D. ALCHEM, Inc. violated the pH water quality stream standard pursuant to
15A NCAC 213 .0211(3)(g).
E. 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) per violation per day may be
assessed against a person who is required but fails to apply for or to secure
a permit required by G.S. 143-215.1, or who violates or fails to act in
accordance with the terms, conditions, or requirements of such permit or
any other permit or certification issued pursuant to authority conferred by
this part.
F. ALCHEM, Inc., may be assessed civil penalties in this matter pursuant to
G.S. 143-215.6A(a)(1), which provides that'a civil penalty of not more
than twenty-five thousand dollars ($25,000) pei violation per day may be
assessed against a person who violates any classification, standard,
limitation, or management practice established pursuant to G.S. 143-215,
143-215.1, or 143-215.3.

ALCHEM, Inc.
Findings and Decisions
Page Four
G. The State's enforcement cost in this matter may be assessed against
ALCHEM, Inc., pursuant to G.S. 143-215.3(a)(9) and G.S. 14313-
282(b)(8).
H. The Supervisor of the Non -Discharge Compliance and Enforcement Unit,
Division of Water Quality, pursuant to delegation provided by the
Secretary of the Department of Environment and Natural Resources and
the Director of the Division of Water Quality, has the authority to assess
civil penalties in this matter.
Based upon the above Findings of Fact and Conclusions of Law, I make the
following:
III. DECISION:
Accordingly, ALCHEM, Inc. is hereby assessed a civil penalty of:
$ for of one violation for failure to properly operate and
maintain the facility as a non -discharge facility to prevent the
discharge of any wastes resulting from the operation of this
program as required by Part I , Section 1 of Permit No.
WQ0016338.
$ for of one violation for failure to provide adequate
provisions as to prevent surface runoff from conveying pollutants
from the residuals treatment area onto adjacent property or into
surface waters as required by Part II, Section 3 of Permit No.
WQ0016338.
$ for of one violation for failure to provide notification to
the MRO of the failure of the reuse program resulting in a release
of material to receiving waters as required by Part III, Section 6 of
Permit No. WQ0016338.
$ for of three violations of the pH stream standard pursuant
to 15A NCAC 2B .0211(3)(g).
$ TOTAL CIVIL PENALTY, which is percent of the maximum
penalty authorized by G.S:AY43-215,88A.
Pursuant to G.S. 143-215.6A(c), in determining the amount of the penalty I have i
taken into account the Findings of Fact and Conclusions of Law and the factors set forth
at G.S. 14313-282.1(b), which are:
r

ALCHEM, Inc.
Findings and Decisions
Page Five
(1) The degree and extent of harm to the natural resources of the State, to the
public health, or to private property resulting from the violation(s);
(2) The duration and gravity of the violation(s);
(3) The effect on ground or surface water quantity or quality or on air quality;
(4) The cost of rectifying the damage;
(5) The amount of money saved by noncompliance;
(6) Whether the violation(s) was committed willfully or intentionally;
(7) The prior record of the violator in complying or failing to comply with
programs over which the Environmental Management Commission has
regulatory authority; and
(8) The cost to the State of the enforcement procedures.
Date
Jeffrey O. Poupart, Supervisor
Non -Discharge Compliance and Enforcement Unit
Division of Water Quality
r�l

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

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
0
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
14 hours by investigators for investigating and
drafting report @ $17.38/hour
1.0 hour by Water Quality Regional Supervisor
for review @ $39.96/hour. .
1.0 hour for clerical support @ $15.00/hour
= $100.00
$243.32
_ $ 39.96
$ 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.

11. Mitigating Circumstances:
Permit No. WQ0016338 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 (C1ass'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)

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):
Wesley .._Be11;.Environmental Tech. IV
Date:

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�oF W A rF9 L
�` pv Michael F. Easley, Governor
> r William G. Ross, Jr.,Secretary
� T
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
May 14, 2003
Mr. Wayne Drye, Plant Manager
ALCHEM, Inc.
8135 Red Road
Rockwell, North Carolina 28138
Subject: Permit Number Correction
NOV/NRE
ALCHEM, Inc.
Rowan County, N.C.
Dear Mr. Drye:
Our records indicate that your facility has been issued two Non -Discharge Permits (WQ0016338
and WQ0002702) with the same effective (January 21, 1999) and expiration (December 31, 2004) dates.
However, the referenced permit number in the NOV/NRE report was mistakenly printed as WQ0002702.
Please note that the permit number should have been WQ0016338 (which was incorrectly listed and
submitted to the permittee, Randall Andrews, and our office as WQ0016388). The permit conditions
referenced in the NOV/NRE report were cited from Permit No. WQ0016338. We apologize for any
inconvenience this may have caused.
1699.
Should you have questions, please do not hesitate to contact Mr. Wes Bell or me at (704) 663-
Sincerely,
D. Rex Gleason, P.E.
Water Quality Regional Supervisor
Attachments
cc: Rowan County Health Department
I
N.
WIM
'HONE "704) 663-1699 Mooresville Regional Office. 919 North Main Street, Mooresville. NC 28115 NZDENR
=AX [phone] Customer Service

O�O� ,SAT �9QGUL U
May 12, 2003
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Wayne Drye, Plant Manager
ALCHEM, Inc.
8135 Red Road
Rockwell, North Carolina 28138
U5
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
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. Drve:
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) 2B .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
NON= 04) 663-1699
'(7
=AX 104) 663-6040
*Ar
N'CDERR
Customer Service
i R n n R7277dR

Mr. Wayne Drye
NOV/NR.E
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 2B .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

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 m: [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
REPORT:
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.

WaTF9�
Michael F. Easley, Governor
j1 r William G. Ross. Jr.,Secretary
Ma
North Carolina Department of Environment and Natural Resources
✓ Alan W. Klimek. °.E., Director
Division of Water Quality
May 12.2003
Mr. Larry Samples
8470 Medium Road
Rockwell, North Carolina 28138
Subject: Complaint Investigation
ALCHEM, Inc./Ille2al Discharae
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
Mooresville Regional Office, 919 North Main Street, Mooresville, NC 28115 NCD`NR
'HONE i704) 663-1699 Customer Service
=AX 704) 663-6040 1 800 823-7748

ALCHEM, INC.
Corporate Office Sales and Manufacturing
2042 Buie Philadelphus Road 8135 Red Road
Red Springs, NC 28377 Rockwell, NC 28138
Tel. gio-843-2121 — Fax gio-843-5789
Tel. [phone] —Fax [phone]
[e-mail]
l � [e-mail]
�N
May 28, 2003
Mr. D. Rex Gleason
Water Quality Regional Supervisor
NCDENR
919 North Main Street
Mooresville, NC 28115
Dear Mr. Gleason:
R E C""'Erv'F
MAY z 0 2003
NC DEFT cn- zwVlk(}MMEN
AND PMATURAL RESOURCES
MOORESVILLE REGIONALOFFICE
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.
Corporate Office
2042 Buie Philadelphus Road
Red Springs, NC 28377
Tel. 9io-843-2121 — Fax [phone]
[e-mail]
Sales and Manufacturing
8135 Red Road
Rockwell, NC 28138
Tel. [phone] — 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.
Wayne Drye,
Vice President
vll

4do bcnsaq� c
P S
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GR A M \A0r,'
May 23, 2003
The TARA GROUP OF LUMBERTON, INC.
2042 Buie Philadelphus Rd Red Springs, NC 28377
NC# 41562 — SC# 98350
Equipment vards — Hwy 72 West, Lumberton, NC
Red Road, Rockwell, NC
Telephone [phone] N 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. w a co 1 33(,
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

May 28, 2003
061"k4c
RO
AMaR%°
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. TARA GROUP OF LUMBERTON, INC.
Wayne Drye, Denise B. Andrews,
Vice President President
WOMAN BUSINESS ENTERPRISE!
Heavy Highway Utilities Sewer Plants Mining

Thanks you for your corporation in this matter.
Sincerely
Charlie Andrews
CC: Johnny Nobles, RLS; Johnny Nobles & Associates
Mr. Wayne Drye, Plant Manager, Alchem, Inc.
WOMAN BUSINESS ENTERPRISE!
Heavy Highway Utilities Sewer Plants Mining

State of North Carolina
Qepartment of Environment
and Natural Resources
Division of Water Quality 10
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E.,
Mr. Randall F. Andrews
Alchem, Incorporated
8135 Red Road
Rockwell, NC 28138
Dear Mr. Andrews:
Director.___
January 21, 1999
1 •
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Subject: Permit No. WQ00 1 �_ Z e
Alchem, Incorporated
Bauxite Residuals Reuse Program
Rowan County
In accordance with your application received on October 23, 1998, we are forwarding herewith Permit
No. WQ0016388, dated January 21, 1999, to Alchem, Incorporated for the on -site reuse of a silica residual
from bauxite digestion as a fill material.
This permit shall be effective from the date of issuance until December 31, 2004 and shall be subject
to the conditions and limitations as specified therein. Please pay particular attention to the monitoring and
reporting requirements contained in this permit. Failure to establish an adequate system for collecting and
maintaining the required operational information will result in future compliance problems.
If any parts, requirements, or limitations contained in this permit are unacceptable, you have the right
to request an adjudicatory hearing upon written request within thirty (30) days following receipt of this permit.
This request must be in the form of a written petition, conforming to Chapter 150B of North Carolina General
Statutes, and filed with the Office of Administrative Hearings, P.O. Drawer 27447, Raleigh, NC 27611-7447.
Unless such demands are made this permit shall be final and binding.
If you need additional information concerning this matter, please ntact Joe Pearce at [phone]
extension 544. �—
Sincere
/A. Preston Howard, Jr., P.E.
cc: Rowan County Health Department
Mooresville Regional Office, Water Quality Section
Technical Assistance and Certification Unit
Non -Discharge Compliance/Enforcement Unit
PO Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] Fax [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/10% post -consumer paper

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
RALEIGH
PERMIT FOR THE USE OF RESIDUALS
In accordance with the provisions of Article 21 of Chapter 143, General Statutes of North Carolina as
amended, and other -applicable Laws, Rules, and Regulations
PERMISSION IS HEREBY GRANTED TO
Alchem, Inc.
Rowan County
FOR THE
operation of a bauxite residuals reuse program (as structural fill) on Alchem, Inc.'s property at 8135 Red Road,
Rockwell, North Carolina using approximately 3000 dry tons per year of residuals from the sources listed in
Condition II 2, with no discharge of wastes to the surface waters, pursuant to the application received on
October 23, 1998, and in conformity with the project plan, specifications, and other supporting data
subsequently filed and approved by the Department of Environment and Natural Resources and considered a
part of this permit.
This permit shall be effective from the date of issuance until December 31, 2004 and shall be subject
to the following specified conditions and limitations:
I. PERFORMANCE STANDARDS
1. The residuals program shall be effectively maintained and operated as a non -discharge system to
prevent the discharge of any wastes resulting from the operation of this program.
2. This permit shall become voidable in the event of failure of the residuals program to adequately
protect the assigned water quality standards of the surface waters and groundwaters.
3. The issuance of this permit shall not relieve the Permittee of the responsibility for damages to .
surface or groundwaters resulting from the operation of this program..
4. In the event that the bauxite residuals reuse program is not operated satisfactorily, including the
creation of nuisance conditions, the Permittee shall cease the reuse operation take any immediate
corrective actions as may be required by the Division of Water Quality (Division).
Written notification must be submitted to the Mooresville Regional Office, [phone], at least
two weeks prior to any use of residuals within 50 feet of any surface waters.
No residual shall be used with 100 feet of a potable water supply well unless a clay or synthetic
liner is placed over and under the residual during installation. It will be the responsibility of

Alchem, Inc. to verify the position and integrity of the liner prior to backfill. Under no
circumstances shall residuals be located within 25 feet of a potable water supply well.
II. OPERATION AND MAINTENANCE REQUIREMENTS
1. No residuals other than the following are hereby approved for use in accordance with this permit:
Permit Volume
Source County Number (Dry Tons/Year)
Alchem, Inc. Leached Bauxite Rowan WQ0002712 3000
2. The following use of the residual is hereby approved:
- Structural fill on Alchem, Inc.'s property at at 8135 Red Road, Rockwell, North Carolina
Adequate provisions shall be taken to prevent wind erosion and surface runoff from conveying
pollutants from the residuals treatment area onto the adjacent property or into any surface waters.
4. No residuals shall be utilized for land reclamation within one foot of a seasonal high water table
and within three feet of a permanent water table.
5. No residuals shall be used as pipe bedding for sanitary sewer, storm sewer, or potable water lines.
6. The permittee shall insure that the transportation of the residuals does not cause any adverse
impact, i.e. transport in a leak proof truck for wet material, ensure that trucks are covered for dry
material, or otherwise protected to prevent any adverse impact resulting from operation.
III. MONITORING AND REPORTING REQUIREMENTS
1. Any monitoring (including groundwater, surface water, residuals,. soil, or plant tissue analyses)
deemed necessary by the Division to insure protection of the environment will be established and
an acceptable sampling and reporting schedule shall be followed.
2. Proper records shall be maintained by the Permittee tracking all utilization activities. These
records shall include, but are not necessarily limited to the following information:
a. location of residuals utilization
b. volume of residuals utilized in tons
A residual analysis shall be conducted twice per year from the date of permit issuance by the
Permittee. The results of all analysis shall be maintained on file by the Permittee for a minimum
of five years. The residuals analysis shall include the following parameters:
Arsenic
Nickel
Magnesium
Cadmium
Selenium
Sodium
Chromium
Zinc
Manganese
Copper
Barium
pH
Lead
Silver
Phosphorus
Mercury
Calcium
Aluminum
After the residuals have been monitored for two years at the above frequency, the Permittee may
submit a request to the Division for a permit modification for the reduction of the frequency of
monitoring for pollutant concentrations, but in no case shall the frequency of monitoring be less
than once per year.

4.. A Toxicity Characteristics Leaching Procedure (TCLP) analysis shall be conducted by the
Permittee annually. The TCLP analysis shall include the following parameters (please note the
regulatory level in mg/L in parentheses):
Arsenic (5.0)
Cadmium (1.0)
Chlorobenzene (100.0)
o-Cresol (200.0)
Cresol (200.0)
1,2-Dichloroethane (0.5)
Endrin (0.02)
Hexachlorobenzene (0.13)
Lead (5.0)
Methoxychlor (10.0)
Pentachlorophenol (100.0)
Silver (5.0)
Trichloroethylene (0.5)
2,4,5-TP (Silvex) (1.0)
Barium (100.0)
Benzene (0.5)
Carbon tetrachloride (0.5)
Chlordane (0.03)
Chloroform (6.0)
Chromium (5.0)
m-Cresol (200.0)
p-Cresol (200.0)
2,4-D (10.0)-
1,4-Dichlorobenzene (7.5)
1,1-Dichloroethylene (0.7)
2,4-Dinitrotoluene (0.13)
Heptachlor (and its hydroxide) (0.008)
Hexachloro-1,3-butadiene (0.5)
Hexachloroethane (3.0)
Lindane (0.4)
Mercury (0.2)
Methyl ethyl ketone (200.0)
Nitrobenzene (2.0)
Pyridine (5.0)
Selenium (1.0)
Tetrachloroethylene (0.7)
Toxaphene (0.5)
2,4,5-Trichlorophenol (400.0)
2,4,6-Trichlorophenol (2.0)
Vinyl chloride (0.2)
5. Three copies of all required monitoring and reporting requirements as specified in conditions 1111,
III 2, III 3, and III 4 shall be submitted annually on or before March 1 of the following year to the
following address:
NC Division of Water Quality
Water Quality Section
Non -Discharge Compliance/Enforcement Unit
Post Office Box 29535
Raleigh, North Carolina 27626-0535
6. Noncompliance Notification:
The Permittee shall report by telephone to the Mooresville Regional Office, telephone number
[phone], as soon as possible, but in no case more than 24 hours or on the next working day
following the occurrence or first knowledge of the occurrence of any of the following:
a. Any occurrence with the residuals reuse program which results in the utilization of significant
amounts of residuals which are abnormal in quantity or characteristic.
b. Any failure of the reuse program resulting in a release of material to receiving waters.
c. Any time that self -monitoring information indicates that the facility has gone out of
compliance with the conditions and limitations of this permit.
e. Any spillage or discharge from a vehicle or piping system during transportation of residuals.
Persons reporting such occurrences by telephone shall also file a written report in letter form
within five (5) days following first knowledge of the occurrence. This report must outline the
actions taken or proposed to be taken to ensure that the problem does not recur.

IV. GROUNDWATER REQUIREMENTS
The COMPLIANCE BOUNDARY for the reuse site is specified by regulations in 15A NCAC 2L,
Groundwater Classifications and Standards. The Compliance Boundary is for the disposal system
constructed after December 31, 1983 is established at either (1) 250 feet from the waste disposal
area, or (2) 50 feet within the property boundary, whichever is closest to the waste disposal area.
An exceedance of Groundwater Quality Standards at or beyond the Compliance Boundary is
subject to immediate remediation action in addition to the penalty provisions applicable under
General Statute 143-215.6A(a)(1).
In accordance with 15A NCAC 2L, a REVIEW BOUNDARY is established around the disposal
systems midway between the Compliance Boundary and the perimeter of the waste disposal area.
Any exceedance of standards at the Review Boundary shall require remediation action on the part
of the permittee.
2. Any groundwater quality monitoring, as deemed necessary by the Division, shall be provided.
V. INSPECTIONS
1. The Permittee or his designee shall inspect the residuals storage, transport and fill sites to prevent
malfunctions and deterioration, operator errors and discharges which may cause or lead to the
release of wastes to the environment, a threat to human health, or a nuisance. The Permittee shall
maintain an inspection log or summary including at least the date and time of inspection,
observations made, and any maintenance, repairs, or corrective actions taken by the Permittee.
This log of inspections shall be maintained by the Permittee for a period of five years from the
date of the inspection and shall be made available to the Division or other permitting authority,
upon request.
2. Any duly authorized officer, employee, or representative of the Division may, upon presentation
of credentials, enter and inspect any property, premises or place on or related to the treatment site
or facility at any reasonable time for the purpose of determining compliance with this permit; may
inspect or copy any records that must be kept under the terms and conditions of this permit; and
may obtain samples of groundwater, surface water, or leachate.
VI. GENERAL CONDITIONS
This permit shall become voidable unless the residuals reuse program is carried out in accordance
with the conditions of this permit, the supporting materials, and in the manner approved by this
Division.
2. This permit is effective only with respect to the nature and volume of residuals described in the
application and other supporting data.
3. This permit is not automatically transferable. In the event that there is a desire for the facilities to
change ownership or a name change of the Permittee, a formal permit request must be submitted
to the Division accompanied by an application fee, documentation from the parties involved, and
other supporting materials as may be appropriate. The approval of this request will be considered
on its merits and may or may not be approved. .

4. Failure to abide by the conditions and limitations contained in this permit may subject the
Permittee to an enforcement action by the Division in accordance with North Carolina General
Statute 143-215.6A to 143-215.6C.
5. The annual administering and compliance fee must be paid by the Permittee within thirty (30)
days after being billed by the Division. Failure to pay the fee accordingly may cause the Division
to initiate action to revoke this permit as specified by 15 NCAC 2H .0205 (c)(4).
6. The issuance of this permit does not preclude the Permittee from complying with any and all
statutes, rules, regulations, or ordinances which may be imposed by other government agencies
(local, state, and federal) which have jurisdiction.
7. The Permittee, at least six (6) months prior to the expiration of this.permit, shall request its
extension. Upon receipt of the request, the Commission will review the adequacy of the facilities
described therein, and if warranted, will extend the permit for such period of time and under such
conditions and limitations as it may deem appropriate.
8. This permit may be modified, or revoked and reissued to incorporate any conditions, limitations
and monitoring requirements the Division deems necessary in order to adequately protect the
environment and public health.
Permit issued this the wenty-first day of January, 1999
NORTH C LINA ENTVIRC03W AL MANAGEMENT COMMISSION
t�. Preston Howard, Jr., P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission
Permit Number GJ GZ 000 7,70 Z

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, 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.
Enclosure
KHC/bb
Sincerely,
Brenda Smith, P.G.
Regional Supervisor
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 �W,Xf
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.

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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DIVISION OF ENVIRONMENTAL MANAGEMENT
May 9, 1985
MEMORANDUM TO: Bill Jeter
THROUGH: Ron McMillan
FROM: Monty Payne/Jesse Wells
On November 15, 1984'this Office received.a complaint from Mrs. Carol McCombs
about Alchem and runoff from their property onto other people's land. Mr. Payne
of the Water Quality Section investigated on November 30, 1984. Mr. Payne found
that the runoff from Alchem had ponded up on other people's land. He took samples
of the water and the pH was below 2 standard `units, colormetic paper. The results
showed a high concentration of Al, Fe, Na, and Zn, see results.
In early December this Office got a complaint about a white creek near Alchem.
Mr. Payne took samples where the creek crosses under Highway 52 and these samples
showed a high concentration of Al, Fe, and Mn.
Two follow-up investigations was conducted in January, 1985 and all stream
samples showed a heavy concentration of Al, Fe, and Zn. During this time a small
tributary was found going into the creek and sampled, the results showed a high
concentration of Al and Fe. Groundwater contamination was found at this time and
Jesse Wells of the Groundwater Section was called in. Mr. Wells sampled two wells
for contamination and the results showed no contamination.
On March 26, 1985, Ms. Patricia Poole called this Office and was concerned about
her well being contaminated. Tana Fryer and Monty Payne investigated and found where
runoff from Alchem had gotten onto her land and ran within 40 feet of her well.
Samples of the well showed a high concentration of Al and Mn. They also checked the
stream below Alchem and it had a yellowish -brown billowy substrate. This was
believed to be alum that has settled out from the contamination. Secondly, they
found a path that the runoff had followed to within 100 feet of the stream. Soil
samples were obtained of the runoff to the stream and Ms. Poole's land, and the
results showed a high concentration of Al and Fe. Stream samples were also obtained
above and below the tributary, which showed a heavy concentration downstream of
the tributary and very little contamination upstream of the tributary.
On May 2, 1985,.Jesse Wells visited the Poole residence. Mrs. Poole's well is
a 24" bored well, 49 feet total depth. Mrs. Poole had a water analysis report from
the Rowan County Health Department. (Attachment #1). .Mr. Wells took a pH and
Specific Conductance sample. The pH was analyzed as 5..3 and specific conductance
was 410.
Mr. Payne is to have a joint meeting with Keith Andze.zs, owner, Jesse Wells,
Groundwater Section, Rex Gleason, Water Quality Regional Engineer, and Ron McMillan,
Regional Supervisor.
If more information is needed, please advise.

NORTH CAROLINA DEPARTMENT OF NATURAL RESOURCES AND COMMUNITY DEVELOPMENT
DIVISION OF ENVIRONMENTAL .MANAGEMENT
WATER QUALITY SECTION
POST OFFICE BOX 950
MOORESVILLE, NORTH CAROLINA 28115
REPORT OF Complaint Investigation: Alchem Inc.
PLACE VISITED Alchem Inc. Rockwell
DATE Report Date: 12/30/85
ADDRESS P. O, Box 171, Rockwell
RIVER BASIN Yadkin
CEP G BY WHOM
Mr. Monty Payne Ms. Tana Fryer, Mr. Rex �� TIME SPENT
Gleason, Mr. Jesse Wells
PERSONS CONTACTED Mr. Randall Andrews, Mr. Keith Andrews, Co -Owners
REASON FOR VISIT Coll, m laint Investigation
COPIES TO: Rowan County Health Department
Jesse Wells
REPORT: On November 15, 1984, this Office received a complaint concerning runoff
from Alchem, Inc. The complaint was about material stockpiled at the site running
off onto adjoining property and washing into a nearby stream as a result of rainfall
runoff.
On November 30, 1984, Mr. Monty Payne of this Office investigated. The
investigator observed where rainwater and spillage entered a makeshift catch basin,
from which it had overflowed onto adjacent property. Mr. Keith Andrews, Co-owner,
was contacted at this time and he explained how an excessive amount of rain fall had
caused the basin to overflow,.aad they (Alchem) were planning to recycle the water
in the basin back to the plant, remove the contaminated soil in the field and build
a larger basin to prevent future runoff.
Mr. Andrews also explained that the material stored behind the plant was
their raw product, aluminum hydrate. Which they combined with concentrated sulfric
acid to made a high grade alum. The aluminum hydrate in the contaminated soil and
rainwater could be used in their process after some of the impurities were removed.
Checking the pH with litmus paper before collecting samples, the investigator
found that the pH was not greater than 2.0 standard units at the catch basin and in

Page Two
the adjacent field where the runoff had accumulated. The metals sample obtained
at the same locations showed a high concentration of aluminum, iron, sodium and zinc.
The stream below Alchem was checked by Mr. Payne at the bridge on SR 2340, but
nothing abnormal was observed, although the metals sample taken did show a slightly
elevated con tentration of aluminum and iron.
On December 6, 1984, this Office received a complaint from the City of
Rockwell's maintenance department concerning.a white coloration to an unnamed
tributary to Second Creek. On December 7, 1984, Mr. Payne investigated. He found
no discoloration to the creek, but the sample obtained did show a high
concentration of aluminum.
On January 2, 1985, Mr. Jesse Wells, of this Office, and Mr. Payne returned
to the Alchem area to sample wells at adjacent residences for possible contamination.
Neither of the wells sampled showed contamination but a stream sample obtained
showed very high concentrations of aluminum, iron, zinc and manganese. On
January 7, 1985, stream samples were again obtained and again they showed extremely
high concentrations of aluminum, iron and zinc.
During the time of mid December through early January, the stream bottom
became covered with a dirty -white floc. This floc appeared to start where a small
underground spring, or tributary, entered the creek. It is believed that this spring
or tributary was contaminated from material leaching through the soil at Alchem.
On February 28, 1985, stream samples were again obtained and they also showed
high levels of aluminum, iron and manganese in the creek.
On March 26, 1985, this Office received another complaint from a resident in
the Alchem area about possible well water contamination. The complainant was
concerned about his/her well.water being contaminated because it had a brownish
color, bad taste, and left a residue on anything that was exposed to continuous
water contact.
The following day, March 27, Ms. Tana Fryer, of this Office, and Mr. Payne
investigated. Because of the excessive amount of disturbance in this area the
(the area was being cleared and the brush burned) the investigators did not find
the runoff complained about, for they were under the impression that the runoff
had just occurred. But on a return investigation on April 1, 1985, they found the
runoff complained about, which appeared to have occurred sometime before the complaint.
Soil and well water samples were taken at the complainants residence during
these visits. The soil samples showed a high concentration of aluminum, iron
and magnesium; the well water sample showed high concentrations of aluminum and
manganese. Stream samples were also taken. The samples upstream of the small
underground tributary did not show the high concentrations of aluminum, iron,
manganese, iron and zinc as the downstream sample did.
The final discovery from these visits, was a path that the runoff had followed
toward the stream. Although the path stopped 100-150 ft. from the stream, it
was still very pronounced.
Stream samples obtained on June 11, 1985, showed a high concentration of
aluminum, iron and manganese downstream of the small tributary. Upstream of the
tributary these concentrations were higher than expected, but nowhere near the
level of the downstream sample. Bioassay samples were also taken at this time.

Page Three
The downstream sample had a LC50 of 27%; the upstream sample had a LC50 of
zero, no toxicity. The Aquatic Toxicology Group who performs bioassay testing for
the State, reported that what appeared to kill the test organisms was a low pH.
In July more stream samples were obtained. The tributary was again used
as the dividing point to separate upstream and downstream. Next the stream
was vertically divided into an upper and lower zone, providing four areas to
consider. The top zones, both upstream and downstream, showed no problems with metal
concentrations or pH, but the bottom zones showed a vast difference. The upstream
bottom zone showed a high concentration of aluminum, iron and zinc, but no pH
problem. The downstream bottom zone showed high concentrations of aluminum, iron
chromium, copper, manganese and zinc; it also had a low pH.
On August 8, 1985, a meeting was held at Alchem, Inc. with Mr. Randall
Andrews, Co-owner of Alchem Inc., Mr. Richard Doby and Mr. Mack Henderson of
Solid & Hazardous Waste, Mr. Jesse Wells, Mr. Rex Gleason and Mr. Monty Payne
of the Division of Environmental Management. The meeting dealt with what
impact Alchem was having on the environment and a walk through the plant.
During the tour, the pH was taken at several points and a pH below 2.0 units was
found at several points, which classified the material as hazardous. Therefore,
the clean-up of this facility comes under the jurisdiction of Solid & Hazardous Waste.
On September 9, 1985, another meeting was held, in Raleigh, with Representatives
from Alchem, Solid & Hazardous Waste and this Department to determine what actions
need to be taken for the clean-up. It was determined that the ponds need to be
emptied and the contaminated soil be removed and if the lagoon was continued to be
used it had to be lined. Secondly the contaminated soil has to be neutralized or
removed. Thirdly, the contaminated well would have to be cleaned or a new well
put in. Last, there was an excessive amount of spillage throughout the plant
which had to be controlled.
Summary: The samples obtained over the year show that an excessive amount of aluminum
and possibly sulfric acid has escaped from the facility, which has apparently caused
surface and ground water contamination. Alchem has begun clean-up procedures in
conjunction with Solid & Hazardous Waste and Division of Environmental Management.
They have removed some of the soil around the contaminated well and replaced this
well. They have also submitted an application for a non -discharge permit to
construct an additional storage lagoon, which is being evaluated by this Office.
This Office will keep abreast of the clean-up at Alchem until it is completed.

State of North Carolina
Department of Natural Resources and Community Development
Mooresville Regional Office
James G. Martin, Governor
S. Thomas Rhodes, Secretary
Mr. Steven Daniels
Medium Drive
Rockwell, N. C. 28138
Dear Mr. Daniels:
Albert F. Hilton, Regional Manager
DIVISION OF ENVIRONMENTAL MANAGEMENT
June 2, 1986
Subject: Complaint Investigation
Alchem
Rowan County, North Carolina
Enclosed please find a copy of the Complaint Investigation Report for
the investigation conducted on May 30, 1986 by Mr. Monty Payne and Ms. Tana
Fryer of this Office. The Report should be self-explanatory.
If you should have any questions concerning this matter or require
additional information, please do not hestiate `to contact Mr. Pavne or me.
aerely,
Ronald L. McMillan
Regional Supervisor
Enclosure
cc: Rowan County Health Department
919 North Main Street, P.O. Box 950, Mooresville, N.C. 28115-0950 • Telephone 70¢663.1699
An Equal Opportunity Affirmative Action Employer

NORTH CAROLINA DEPARTMENT OF NATURAL RESOURCES AND COMMUNITY DEVELOPMENT
DIVISION OF ENVIRONMENTAL MANAGEMENT
WATER QUALITY SECTION
POST OFFICE BOX 950
MOORESVILLE, NORTH CAROLINA 28115
REPORT OF Complaint Investigation: Alchem
PLACE VISITED Alchem
ADDRESS
BY WHOM Monty Payne, Tana Fryer y�
PERSONS CONTACTED
REASON FOR VISIT Complaint Investigation
COPIES TO: Rowan County Health Department
DATE 5/30/86.
RIVER BASIN Yadkin
TIME SPENT 2 hours
REPORT: On May 29, 1986, this Office received a complaint concerning a black
plastic pipe from the Alchem plant in Rockwell _._going into a nearby creek.
On May 30, 1986, Mr. Monty Payne and Ms. Tana Fryer of this Office investigated.
The investigators found the pipe leading from the plant to the creek and a white
liquid substance in the pipe. Next the investigators went to the plant and
talked wih the plant manager who explained that the pipe was being used to clean
out the creek. They were using_a_portable.pump Jand the plastic pipe) to -pump
the alum sludge that has accumulated on the bottom of the creek back up to the
plant.
This appears to be what is happening, for there was no alum sludge on the
creek bottom where the plant manager stated they had been working; sludge was
still present downstream of this area.
Alchem is in the process of cleaning out the creek as requested by this
Office; therefore this Office will monitor the situation until the clean-up
is complete.
/pb

LOB
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 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 iri 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]
AM ,&
MCDENR
Customer Service
1-877-623-6748

z
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-
1699.
Sincerely,
D. Rex Gleason, P.E.
Water Quality Regional Supervisor
Attachments
cc: Rowan County Health Department
Wayne Drye, Plant Manager, ALCHEM, Inc.
ME

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
VA
(�1
INVESTIGATED BY: Wes Bell and Ellen Huffmaht�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 woodedhiparian
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 213 .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.

12/06/2006 09:29 919-715-0588
NCDE&NR/WATER QUAL
PAGE 01
State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
�0. W T Q
o C,
CID
p
Q �
Michael F. Easley, Governor
William G. Boss Jr., Secretary
Alan W_ Klimek P.E., Director
Division of Water Quality
Aquifer Protection Section
Location: 2728 Capital Blvd.
Raleigh, NC 27604
Mailing Address: 1636 Mail Service Center
Raleigh, N.G. 27699-1636
FAX: [phone]
[phone]
Date:
FROM'.V�r
PHONE: LIE 1 a
NO. OF PAGES INCLUDING THIS SHEET:
if you receive this fax by mistake call: Aquifer Protection Section 9 9.19-733-3221

0
12/06/2006 09:29 919-715-0588
NCDE&NR/WATER QUAL
PAGE 02
Temperature and pH Readings taken at the ,A LCX-MM Facility in Rockwell
by APS Personnel on December 5, 2006
Site
Water
#
Site Description
Temp
pH
1
Stormwater Drainane Ditch, downstream of railcar off-loading spot.
6.1°C
3.68
2
Approximately 50 feet downstream of Site # I.
6.2°C
3.52
3
Shallow wetland or seep from stormwater detention pond, outside bezxn.
6.1°C
3.16
4
Same area as Site # 3, near the, base of the berm.
6.4°C
3.08
5
The "comer" of the bermed stormwater detention pond.
9.7°C
3.80
6
Close to Site # 5.
9.7°C
3.82
7
Upstream location along the "boundary" stream.
7.0°C
5.36
8
Approximately 90 feet downstream of Site # 7.
6.0°C
5.44
9
Approximately 90 ,feet downstream of Site # S.
6.7°C
5.56
10
Possible surface seep in. wet area between "boundary' stream and berm_
9.8°C
5.66
11
"Elbow" of the "boundary"'stream where it changes direction.
9.3°C
5.28
12
Apparent seep area below berm. Seeps noted on the berm itself.
8.4°C
3.04
13
Upper stormwater detention pond on northern side of isthmus.
9.2°C
3.94
14
Dower stornwater detention pond on southern side of isthmus.
9.1°C
3.98
15
Northwest corner of Lagoon, # 2_
6XV
3.41
16
Northeast corner of Lagoon # 3.
8.6°C
2.62
1.7
Southern edge of Lagoon # 1.
6.1°C
3.31
Note: All three Lagoons were essentially full of "sand" at the time of the field visit
on December 5, 2006.

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10-6
�O G Michael F. Easley, Governor
C
> [ William G. Ross, Jr.,Secretary
-i North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
May 14, 2003
Mr. Wayne Drye, Plant Manager
ALCHEM, Inc.
8135 Red Road
Rockwell, North Carolina 28138
Subject: Permit Number Correction
NOV/NRE
ALCHEM, Inc.
Rowan County, N.C.
Dear Mr. Drye:
Our records indicate that your facility has been issued two Non -Discharge Permits (WQ0016338
and WQ0002702) with the same effective (January 21, 1999) and expiration (December 31, 2004) dates.
However, the referenced permit number in the NOV/NRE report was mistakenly printed as WQ0002702.
Please note that the permit number should have been WQ0016338 (which was incorrectly listed and
submitted to the permittee, Randall Andrews, and our office as WQ0016388). The permit conditions
referenced in the NOV/NRE report were cited from Permit No. WQ0016338. We apologize for any
inconvenience this may have caused.
Should you have questions, please do not hesitate to contact Mr. Wes Bell or me at (704) 663-
Sincerely,
D. Rex Gleason, P.E.
Water Quality Regional Supervisor
Attachments
cc: Rowan County Health Department
V*a
Mooresville Regional Office, 919 North Main Street, Mooresville, NC 28115
NCDENR
-HONE [phone] Customer Service
=AX [phone] 1 800 623-7748

�0
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
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 t4fDEN_R_
'HONE [phone] Customer Service
=AX [phone] 1 800 623-7748

Mr. Wayne Drye
NOWNRE
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 2B .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
MR

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
REPORT:
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.

Q�Alr Ro
Michael F. Easley, Governor
=� r William G. Ross, Jr.,Secretary
—i North Carolina Department of Environment and Natural Resources
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 tJCDEN"►t
'HONE [phone] Customer Service
=AX [phone] 1 800 623-7748