WQ0002702_Regional Office Historical File Pre 2018 (23)

AS r= -
This Document is the Confidential Property of NSF International 7,?-'/'- / y— -!S_yt/ IO
Investigation of Complaints
NSF investigates complaints related to Certified products, misuse of a Mark by a Certified company; or use/misuse of a Mark by a
Non -Certified company. Complaints are classified as "formal" or "informal."
When filing a formal complaint, a "Request for Investigation" (RFI) provided by NSF must be completed and signed by the
complainant (see reverse side.) NSF will acknowledge receipt of an RFI, promptly investigate the complaint and take appropriate
action. NSF may advise the subject of the complaint of the allegation. NSF will confirm to the complainant that the complaint
has, or has not, been verified as correct. For formal complaints from another Certified or Non -Certified company, signing of the
RFI constitutes agreement by the complainant to bear the costs of the investigation if the complaint is not .verified. � If -the„
complaint is verified, the subject of the complaint is responsible for all costs of the investigation. Regulatoryaauthorltie`s are ;*:-
exempt from bearing any costs reldtive to aninvestigation. -NSF will not identify the complainant except as required b law.
If the complainant filing an RFI does not agree to bear the costs of the investigation, the complaint shall be considered "informal."
NSF will investigate "informal' complaints on or before the next regular plant audit, but has no obligation to acknowledge the
complaint, identify the complaining party, or to notify the complainant of the results of any investigation that may be conducted.
Any complaint received via e-mail or Internet will be classified as informal.
Sample Selection and Handling
NSF will not test for enforcement purposes, any samples submitted by a complainant, or select samples for testing that are under
the control or influence of the complainant, or test samples, if NSF has reason to believe that the samples may have been altered
in a way that could affect the outcome: Samples for testing for enforcement purposes shall be selected by NSF and handled in
accordance with established procedures.
File Maintenance
Copies of all formal complaints will be kept in the Corporate file and also in the Field Services complaint file. Copies of all
informal complaints will be kept in the Field Services complaint file.
Document Control 9: AC-700-0004 Issued: September 13, 2002 Issue #: 5 Page 2 of 3

.)
NSF Certified Products - Public Water Supply Treatment Chemicals Page 1 of 2
NSF Product and Service Listings
These NSF Official Listings are current as of Thursday, May 13, 2010 at 12:15 a.m. Eastern Time. Please
contact NSF International to confirm the status of any Listing, report errors, or make suggestions.
Alert: NSF is concerned about fraudulent downloading and manipulation of website text. Always confirm this
information by clicking on the below link for the most accurate information:
http://www.nsf.org/Certified/PwsChemicals/Listinas asp?
CompanyName=Alchem&PlantState=North+Carolina+NC&
NSF/ANSI STANDARD 60
Drinking Water Treatment Chemicals - Health Effects
Alchem, Inc.
8135 Red Road
Rockwell, NC 28138
United States
704-279-7908
Facility: Rockwell, NC
Aluminum Sulfate[AL]
Trade Designation Product Function Max Use
Alum Coagulation & Flocculation 150 mg/L
Aluminum Sulfate Coagulation & Flocculation 150 mg/L
[AL] Based on an evaluation of health effects data, the level of aluminum in the finished
drinking water shall not exceed 2 mg/L.
Calcium Hydroxide
Trade Designation
Liquid Calcium Hydroxide
Ferrous Sulfate
Trade Designation
Ferrous Sulfate Solution
Number of matching Manufacturers is 1
Number of matching Products is 4
Processing time was 1 seconds
Product Function Max Use
pH Adjustment 150mg/L
Product Function Max Use
Coagulation & Flocculation 71 mg/L
http://www.nsf.org/Certified/PwsChemicals/Listings. asp?CompanyName=Alchem&Trade... 5/13/2010

Product Manufacturer Information
This Document is the Confidential Property of NSF International
NSF International
Request For Investigation
9- Formal ✓ -,- Informal (check one)
Installation Information
Co. Name �/i L� �� �' p Location
Address 2 s— ?-- <'i Address
City/State Z d d-t�ev itk—y/,3 d' City/State
Product Description (as applicable) n Date Installed
Type A rh `,� S r, y rdAk-stributor
Model No. Name
Serial No.
NSF Mark attached: Yes
NSF Mark No.
Address
No_ C City/State
Imprint on Product:
Are samples of the product available: Yes No
Complaint Descrintion: Describe in detail the specific complaint or action desired (attach a separate sheet if necessary).
Photographs or sketches can be most helpful in the initial investigation. Py (4 eyver
—fj r .)"4 /,/ S /'tea Al91V- C4�-r/G/��_ /V/ 74-
oa rid c ki A-,,
S eg 7-1�l av H12
r Imo'/" m L tn/ ^ .Pi1� , c eli 5 �.. Gr/Lf '-� � C�r,.�,.�.✓� ��.,_.� . �,l"
p2� / 4-1 -e o 7-Z ar -p r , hk , .✓, r .J �/ d J y�-
o - oAlul C Jy,- c1a-r, ,-ayt 5 d /= s .',7�v ✓o r 21rJ 4ve
Name: gIlPN f%N Address: (, / 0 - C� Gr/ �`✓w�
Title: fN I/, 30q:jL- C i a, /,-s I- City/State/Zip: 7-n a tSS ✓ /✓ C—.
t
Organization: A/C • A EDV R-- 15 W Q,141°S Phone/Fax: 7 0 i-
Signs a of omp inapt Date
If the formal box is checked and the complaint is signed, the complainant, other than regulatory or municipal authorities, agrees to
bear all costs of the investigation. See explanation on backside of this form.
Completed RFI forms should be mailed/faxed to the attention of Field Services Manager, at:
NSF International, P.O. Box 130140, Ann Arbor, MI 48113-0140
phone:[phone] fax:[phone]
© Copyright 2002 NSF International All Rights Reserved
Document Control #: AC-700-0004 Issued: September 13, 2002 Issue #: 5 Page 3 of 3

NSF International
N (`11EM, INC.
i lam :fit_ h0C'K%VFi L, NC
C"I: S,th#IF'tI 1YS E: :'�f.-
• -�StT It+tItlF-„t, In Hi',i +•'I Vt "F4h ,nz. o:h
Label of Polymer bag located
at the mixer that serves the
alum reactor (digestor)
Production steet for ALUM. Note step #13
ALUM BATCH SH9
• LOAD' DA'Y TANK WITH AIR UP
� A
2, * AiiE_UP FLOCK MIX iSoo ML
1lhtll
I117TI f'
3, - START MIXER
`'�
4. PUMP 2000 GALLONS�WATER (T MIN) IN
TfIVIL �;
If�iIKLg .� �
T'IiE REACTOR
5. STAART ACYD 250 GALLONS ACID (7;MIN)
Timt�
V
INTIIII.3 z" . _
'S, START BAUXITE ADD S'EUcKr=TS-.iS,274.0`'7�LLRS
MIME ��'
IiAYIALS-
RAUXITE 4 1,000 GALLONS OF WATER (7 MIN) $
#� CUCKIATS AIAUXITLI utED
250 GALLONS ACID (7MIN)
7. WATER ADD COMPLETE CONTINUE
TIME � �
INTIALS � U.
DAU)CITE ,i
jLpad"xALLoNS ACID ADDS
TIME
a- STEAMING F;IF,ACTIOd3 BEGINS START ADDING
INTIALS
U00 GALLONS OF WATER (i i MIN) TO KEEP
REACTION UNDER CONTROL
TIME 2' L
INTIALS
S. BAUXITE ADD COMPLETE CONTINUE ACID ADDS
-TAIL
10. WATER ADDS COMPLETE KEEP WATCH FOR ANY
SPLASHING REACTION !MAKE WATER SHOTS OF
2O SECONDS TO KEEP REACTOR CINDER CONTROL
1 C ACID ADD COMPLETE_ TOTALGALLONS
ACID USED _tj_0 (�L_
Twe i"S�.
INTIALS
12, AFT1ER i HOUR PUMP WATER THRU BOTTOM OF
REACTOR TO ADJUST BAUfME TOTAL GALLONS
OF WATER USED = -C, 00 .
TIME
IHTI/ALS
13. START ADDING MAGNAFLQC 333
TIME -' 10
INTIALSr Z (1.
14. SHUT OFF MIXER ANDIET FLOCK FOR 4 HOUR
TIME a-
TIME 14'.�
INTEAL3•-
ih4TiAL'�
15. Pf! RFSULTS Ajj.,SL a1AUIl1E Itl!5ULT5
LN
.6�
16. elLLItN CAN 1)!° PUMPED INTO STORAGE TAMS# r2
TIME -jGaQ
IHTIAL3' E}•
17. HOOK UP HOSE AND PUMP OUT
TIMI ",tact ;..
TII}iI: L: j
IHTIAkV:Zk—
i*ITIALS ,.L._
I&TOT'AL GALI.ON9.OF Al -UM PUKP "T ■
iS.A,i.la AILUL4 PUMPEO 00T ADDINd'iSO4 GALi.GN3 OF
IRTIA0 zlk-
WATrR't'O MIX SANRLAYER AND PUMP OUT
TIME wig
INTIA4�.�u—
2o,p0jo!PING 0OJT SANDLAYEFt TO L.AGOON11
.�
TIME > 0
�
INTO Li
;',1. EACTi7R EMPTY
.,
A41T`H4rl�12OD APPRCiSi!#1,%-, r �;,�dw..:� ���..t�'-.,__...,.�..�...,..._..
'ictures taken by Ellen Huffman at the ALCHEM Facility Rockwell, NC May 10, 2010

This Document is the Confidential Property of NSF International
NSF International
Request For Investigation
Formal " Informal (check one)
Product Manufacturer Information Installation Information
Co. Name
Address
City/State
Product Description (as applicable)
Type
Model No.
Serial No.
NSF Mark attached: Yes No
NSF Mark No.
Imprint on Product:
Are samples of the product available: Yes No_
Location
Address
City/State
Date Installed
Distributor
Name
Address
City/State
Complaint Description: Describe in detail the specific complaint or action desired (attach a separate sheet if necessary).
Photographs or sketches can be most helpful in the initial investigation.
Name:
Title:
Organization:
Address:
City/State/Zip:
Phone/Fax:
Signature of Complainant Date
If the formal box is checked and the complaint is signed, the complainant, other than regulatory or municipal authorities, agrees to
bear all costs of the investigation. See explanation on backside of this form.
Completed RFI forms should be mailed/faxed to the attention of Field Services Manager, at:
NSF International, P.O. Box 130140, Ann Arbor, MI 48113-0140
phone:[phone] fax:[phone]
© Copyright 2002 NSF International All Rights Reserved
Document Control #: AC-700-0004 Issued: September 13, 2002 Issue #: 5 Page 3 of 3

This Document is the Confidential Property of NSF International
NSF International
Request For Investigation
s� Formal " Informal (check one)
Product Manufacturer Information Installation Information
Co. Name
Address
City/State
Product Description (as applicable)
Type
Model No.
Serial No.
NSF Mark attached: Yes No
NSF Mark No.
Imprint on Product:
Are samples of the product available: Yes_
No
Location
Address
City/State
Date Installed
Distributor
Name
Address
City/State
Complaint Description: Describe in detail the specific complaint or action desired (attach a separate sheet if necessary).
Photographs or sketches can be most helpful in the initial investigation.
Name:
Title:
Organization:
Address:
City/State/Zip:
Phone/Fax:
Signature of Complainant Date
If the formal box is checked and the complaint is signed, the complainant, other than regulatory or municipal authorities, agrees to
bear all costs of the investigation. See explanation on backside of this form.
Completed RFI forms should be mailed/faxed to the attention of Field Services Manager, at:
NSF International, P.O. Box 130140, Ann Arbor, MI 48113-0140
phone:[phone] fax:[phone]
© Copyright 2002 NSF International All Rights Reserved
Document Control #: AC-700-0004 Issued: September 13, 2002 Issue #: 5 Page 3 of 3

This Document is the Confidential Property of NSF International
NSF International
Request For Investigation
Formal 9. Informal (check one)
Product Manufacturer Information
Co. Name
Address
City/State
Product Description (as applicable)
Type
Model No.
Serial No.
NSF Mark attached: Yes „ No
NSF Mark No.
Imprint on Product:
Are samples of the product available: Yes No_
Installation Information
Location
Address
City/State
Date Installed
Distributor
Name
Address
City/State
Complaint Description: Describe in detail the specific complaint or action desired (attach a separate sheet if necessary).
Photographs or sketches can be most helpful in the initial investigation.
Name:
Title:
Organization:
Address:
City/State/Zip:
Phone/Fax:
Signature of Complainant Date
If the formal box is checked and the complaint is signed, the complainant, other than regulatory or municipal authorities, agrees to
bear all costs of the investigation. See explanation on backside of this form.
Completed RFI forms should be mailed/faxed to the attention of Field Services Manager, at:
NSF International, P.O. Box 130140, Ann Arbor, MI 48113-0140
phone:[phone] fax:[phone]
© Copyright 2002 NSF International All Rights Reserved
Document Control #: AC-700-0004 Issued: September 13, 2002 Issue #: 5 Page 3 of 3

© 2009 NSF
NSF/ANSI 60 — 2009
Polymers shall be analyzed according to the methods described in annex B, sections B.4.3.1 through
B.4.3.3, as applicable.
B.3.12 Method K
This method shall be used for metal salt coagulants such as alum, ferric chloride, ferrous chloride, ferric
sulfate, ferrous sulfate, and polyaluminum chloride.
B.3.12.1 Preparation
For the preparation of coagulant solutions, the amount of product on a dry weight basis shall be
determined. To calculate the weight of the material (dry basis) in a coagulant solution, the following
procedure shall be followed.
a) Weigh a clean, dry 100 mL volumetric flask to the nearest 0.01 g (Wt A).
b) Pipette a known volume (20-50 mL) of well -mixed coagulant solution into the flask. (Take
care not to touch the ground glass.)
c) Weigh the flask and contents to the nearest 0.01 g (Wt C).
d) Dilute the solution to volume with DI water. (Take care not to wet the ground glass.) Do
not mix.
e) Weigh the fla k and contents to the nearest 0 01 g (Wt D)
f) After weighing mix -the contents horoughly, and transfer into a 125 mL bottle.
g) i Thorc8ughly rinse the flask with DI water lallowi they neck; of the"flak ibjdry, then fill the
flask to volume With Dlrwater. (Take care not---to�wet'the ground glass )
h) Weigh the flask and'water to the nearest am (Wt B)71
i The weight ofthe-ma" terial (i
) g (dry basis) shall be caloulatedias follows:
— Wt B - Wt A = weight of water = W;
— Wt C - Wt A = weight of sample solution = X;
— Wt D - Wt C = weight of water added = Y;
— Wt D - Wt B = weight of material (dry basis) in sample solution = M;
— W - Y = weight of water equivalent to sample solution = Z ;
— X/Z = SPG of sample solution; and
— X - Z = weight of material (dry basis) in sample solution = M.
NOTE — If the material is alum, to account for waters of hydration:
M = Wt of AI2(SO4)3; and
M x 1.7372 = Wt of (Al2(SO4)3 • 14 H2O.
For other metal salt coagulants with waters of hydration, similar calculations shall be made.
B8

© 2009 NSF
If the test material is provided as a dry product:
NSF/ANSI 60 — 2009
a) Weigh 10 times the maximum use dose of the chemical in an acid -washed 1 L volumetric
flask.
b) Dilute to volume with deionized distilled water, or follow manufacturer's instructions for
dissolving the material and then dilute to volume.
NOTE — Contaminants of interest can be determined on the base (unflocked) material. If the level
of contaminants in the base material meets the requirements of this Standard (i.e., <_ SPAC), then
no analyses need be performed for the flocked material. If the SPAC is exceeded, then the flocked
supernatant may be analyzed and the contaminant levels compared to the appropriate SPACs.
B.3.12.2 Analysis of chemical before flocking
For analysis of the base material, the base material shall be prepared as described below.
a) Pipette an aliquot of the solution into a 250 mL griffin beaker and add DI water to 100 mL.
b) Carefully add 2 mL of 30% HZOZ and 1 mL of concentrated nitric acid to the solution in
the beaker.
c) Heat for 1 h at 95 °C (203 OF), or until the volume is slightly less than 50 mL.
d) Cool to ambient temperature and quantitatively `transfer the solution into a 100 mL
volumetric flask. Dilute twith DI water and mix thoroughly'.
he volume ,
B.3.12.3 Analysis of solution after flocking
. i
For analysis of the flocked material,, the following preparation steps shall tie followed
a) The volume of solution to give the equivalent of 10 times the evaluation dose shall be
calculated by the following equation: rRq
10-, x 1 L.] �. gm �100.mL-_x.. 1000mQ = mL
(evaluation (multiple factor) (dry wt. sample in solution)
dose)
b) Pipette the calculated aliquot into a 1 L volumetric flask and dilute to volume with DI
water.
c) Transfer a 100 mL aliquot into a 200 mL beaker.
d) Add 0.1 M NaOH with constant stirring until the desired pH is reached and the pH holds
for 1 min.
e) Allow the mixture to stand undisturbed for at least 1 h.
f) Filter through GF/C (or equivalent) filter with the aid of vacuum.
g) Preserve the sample according to the requirements of annex B, table 131.
B.3.13 Method Z
This method shall be used for tracer dyes.
a) Preheat a sufficient volume of organic -free deionized water to 82 °C (180 °F).
ie

Formula:
required volume of _
mg/L x 10 x sample solution (L) mg
(maximum use (multiple factor) (amount sample
dose) to be weighed)
b) Preserve the sample according to the requirements of table B1.16
B.3.3 Method B
This method shall be used for ammonium hexafluorosilicate, ammonium hydroxide, blended phosphates,
calcium fluoride, dipotassium orthophosphate, disodium orthophosphate, fluosilicic acid, magnesium
silicofluoride, monopotassium orthophosphate, monosodium orthophosphate, potassium fluoride,
potassium hydroxide, potassium permanganate, sodium bicarbonate, sodium bisulfate, sodium
carbonate, sodium fluoride, sodium hydroxide, sodium hypochlorite, sodium sesquicarbonate, sodium
silicofluoride, tricalcium phosphate, zinc chloride, and zinc sulfate.,
NOTE — For bromate analysis of sodium hypochlorite, no preparation of the sample is required. Bromate
analysis can be performed on the sample as received.
The following procedure shall be followed for sample preparation to.this method:
a) Dilute the sample to'a strength equivalent to-10AImes the maximum use dose of the
chemical using organic -free deionized water. 14, 15, 17
Formula i
required volume of _
mg/L x. 10 x sample solution-(L) mg
(maximum i(amount sample to be
(multiple factor)_ -
use dose) -- -- _ _ - weighed)
b) Acidify with concentrated hydrochloric acid (HCI) to pH < 2.16
c) Quantitatively transfer to a volumetric flask of a size corresponding with the required
volume of sample solution determined above and dilute to volume with organic -free deionized
water.
d) Preserve the sample according to the requirements of annex B, table B1.

© 2009 NSF
NSF/ANSI 60 - 2009
The following table is a generic listing of the types of products covered in this section. This table is not intended to be a complete list of all products
used for coagulation and flocculation applications. Inclusion of a product does not indicate either a use endorsement of the product or an
automatic acceptance under the provisions of this Standard. Annex F, table F1, includes a cross-reference index of the various chemicals (and the
more common synonyms) contained in this table.
Table 4.1 - Coagulation and flocculation products - product identification and evaluation
Chemical type
Synonyms
Formula
Approximate
molecular
Preparation
Typical use
Chemistry -specific
(Description)
(CAS number)
method
level (mg/L)'
analyses2
weight
acrylamide/acrylic acid
acrylamide, acrylic acid,
copolymers
—
(31212-13-2)
4 - 30 million
—
1.0 4
acrylonitrile,
3-hydroxypropane
(polyelectrolytes)
nitrile, isobutane nitrile
activated silica
silicic acid
: SiO2 • nH20
`(9,343-98-2
-
78 @-n = 1
method A,
anrex B,base/neutral
5.0
metals5, radionuclides,
(coagulant)
.) !
section B.3.2
scan
aluminum chloride
aluminum
AICI3
(41630=01 7)
^=13334 =
method K
annex B,
70:0/26.8
metalss ,base/neutral
(metal salt coagulant)
tnchlonde j
7446-70
i
.:.F
��,
scans
0 -'
- . H
is ectionlB.3.12
aluminum
f
aluminum chlorohydrate
chloride
hydroxide,-
Al2CI(OH)5
{12042-91 0);
vanable ;
method K,
l; annex B,
—
s
metals , base/neutral
s
scan
(metal salt coagulant)
basic aluminum
j
=
section B.3.12
hydroxide, alum
� 1, ld ! l z .
aluminum sulfate
aluminum alum,
cake alum,
Al2(SO4)3. nH20
594.4
method K,
7
metals5, base/neutral
(metal salt coagulant)
aluminum
(10043-01-3)
(n =14)
annex B,
section B.3.12
156/26.8
scans
trisulfate
anionic polyacrylamide
acrylamide, acrylic acid,
(dry)s
—
(31212-13-2)
4 - 30 million
—
1.04
acrylonitrile,
3-hydroxypropane
(polyelectrolytes)
nitrile, isobutane nitrile
anionic pol acrylamide
acrylamide, acrylic acid,
(emulsion)
—
(31212-13-2)
4 - 30 million
—
4.04
acrylonitrile,
3-hydroxypropane
(polyelectrolytes)
nitrile, isobutane nitrile

e *Tetra Micronutrients Inc - Fairbury, Nebraska (NE) I Company Profile
Page 1 of 1
Tetra Micronutrients Inc
(Tetra Micronutrients, Inc*, Tetra Micronutrients*)
Oj,'ID
71025 ,569th
NE Ave )� Sic &,
Fairbury, NE 68352-5519
Phone: ' [phone]
Website: Tetramicro.com g _ /, �7�tG^ "�✓`
Business Categories �� 1/✓ v" %
Fertilizers -Manufacturers in Fairbury, NE ! ��
Mfg Prepared Feeds Mfg Phosphatic Fertilizers Mfg Fertilizers -Mix Only*, Nitrogenous Fertilizer Mfg p/
Tetra Micronutrients Inc Business Information , b %f%��-
Tetra Micronutrients Inc is a private company categorized under Prepared Feeds, Nee and located in
Fairbury, NE. Current estimates show this company has an annual revenue of $20 to 50 million and
employs a staff of approximately 20 to 49.
Also Does Business As
Tetra Micronutrients*, Tetra Micronutrients, Inc*
HQ, Branch or Single Location
Single Location
Annual Sales (Estimated)
$20 to 50 million
Employees (Estimated)
20 to 49
SIC Code and Description
Products, Services and Brands
287301, Fertilizers -Manufacturers
Information not found (?)
NAICS Code and Description
State of Incorporation
325311, Nitrogenous Fertilizer Mfg
Information not found
Years in Business
Information not found
Company Contacts
Contact Name
Title Gender
Mike Dieker
President F
Warren Pales
Finance Executive M
Related Companies
Company Name
Category
Geraldine Katz
Wheat in Fairbury, NE
Glen Rogers
Wheat in Fairbury, NE
Ivan Zimmerman
Wheat in Fairbury, NE
Jack Snyder
Wheat in Fairbury, NE
Merlin Nolte
Wheat in Fairbury, NE
Data provided by D&B. © Dun
and Bradstreet, Inc. All rights Reserved.
http://www.manta.com/c/mmez45f/tetra-micronutrients-inc 5/12/2010

-+^ DESIGNATE WITH AN (X)
SiF�I�s�®t�� ®F L�®II�G—SFC®ICY' F®RRA—®R9�1���,®ICI®i NEGOTIABLE DESIGNATE
/ RECEIVED, subject to IN classifications and tarills in effect on the date of issue of lttis Original Bill of Lading. BY TRUCK ® FREIGHT
the property described below, In apparent good order, except as noted (contents and condition of contents of packages unknown), marked, consigned, and desW as bu tated below, which said carrier (the word carrier being understood throughout
this contract as meaning any person or corporation in possession of the property under. the contract) agrees to carry to its usual place of delivery at said destination, 4 on its route, otherwise to deliver to anotrer carrier on the route to Said
destination. R Is mutually agreed, as to each carrier of all or any of said property over all or any portion of said route to destination, and as to each party at any Esto interested 1n all of arry of said property, that every service to he performed
hereunder shall be subject to all the terms and conditions of the Uniform Domestic Straight Bill of Lading set forth (1) in Official, Southern, ylkstem and flifilais Freight Classifications in effect on the date hereof, it this is a rail or a rail -water
shipment, or (2) in the applicable motor classification or tariff it this Is a motor carrier shipment.
Shipper hereby certifies that he is familiar with all the terms and conditions of the said bill of lading, including those on the back thereof, set faith in the classification or tafill which governs the transportation of this shipment, and to
said terms and conlditbns are (hereby agreed to by the shipper and accepted for himself and his assigns.
From GALVAN INDUSTRIES, INC. Harrisburg,
SRiPY�tR'S NO.
3� 2� �'� 146680
P.O.AT Box 36Harrisburg, N.C. 28075 -'��I�I�Ifi:� �- CARAIEWS1aD.T A. .
(Mail or street address of consignee - For purposes of notification only.)
i� By
CONSIGNEE ,J;> V% �¢ rv.,; z �'
AND ,. ��E'� ���e�� a ROWfWERf#G CARRIER
DESTINATION
L Aa { i3o ®� j �. CAR OR VEHICLE
WrInAl e a gin
NO.
DESCRIPTION OF ARTICLES, SPECIAL
"WEIGHT
CLASS
CHECK
Subject to Section 7 of conditions
PACKAGES
MARKS AND EXCEPTIONS
(SUBJECT TO CORR.)
OR RATE
COLUMN
of applicable hill of lading, if this ship -
merit is to be delivered 1. the con -
'A
�
S {� 1111 /�P�1
signs without recourse on the tha
fognw. the co+rent. r stvJl eitpt tt9
® ' l+ \i
following statement.
The carrier shelf nor make cialivzxy
- -
of this shfprrent without paymard of
freight and on other lawful chargus-
Per
(Signature of Consignor.)
If charges sm to be prepaid,
write or are= here. -to be Pro -
paid "
paid."
p�
to apply in pepayrtmnt of the
to apply
charges on the property described
hereon.
i
Agent or Cashier
9 S 1 r
A'
Per
(Thai signature here acknowledges
TOTAL
PIECES
?
-
ony thaamounla prepaid.)
Charges Advanced:
t The fibre boxes used for this shipment conform to the specdications at forth m the box maker's cerlIficale thereon, and all other requirements of Rule 41. o1 ft Cosesofideted Freight Classification.
$
t This Is to certify that the above -named articles are properly classified, described,packaged, marked, and labeled, and ere in proper Cenditron for transportation according to the applicable regurattom of the
C.O.D. SHIPMENT
Department of Transportation.
' It the shipment moves between two ports by a carrier by water, the law requires that the bill o1 lading shall slate whether it is "carrier's or shipper'a weight"
t Sh Ippefe Imprints in too of stamp; cal a pert of Bill of Lading approved by the Interstate Commeme Commission.
NOTE—Whsre the rate Is dependant on.velua, shippers are required to state specifically In writing the agreed or declared value of the popefty.
C.O.D. Amt.
The or"
dedamd value d lire is fire 'flcal stated the sNippar to be not exceeding
Collection Fee
THIS SHIPMENT IS CORRECTLY DESCRIBED.
Total Charges
Shipper
Per
CORRECT WEIGHT IS LBS.
- - - - GALVAN INDUSTRIES, INC. Shipper, Per
P.O. Sox 359, Harrisburg, N.C. 28075 z
Permanent post offices address of shipper
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This Document is the Confidential Property of NSF International
NSF International
Request For Investigation
s� Formal " Informal (check one)
Product Manufacturer Information Installation Information
Co. Name
Address
City/State
Product Description (as applicable)
Type
Model No.
Serial No.
NSF Mark attached: Yes No
NSF Mark No.
Imprint on Product:
Are samples of the product available: Yes No_
Location
Address
City/State
Date Installed
Distributor
Name
Address
City/State
Complaint Description: Describe in detail the specific complaint or action desired (attach a separate sheet if necessary).
Photographs or sketches can be most helpful in the initial investigation.
Name:
Title:
Organization:
Address:
City/State/Zip:
Phone/Fax:
Signature of Complainant Date
If the formal box is checked and the complaint is signed, the complainant, other than regulatory or municipal authorities, agrees to
bear all costs of the investigation. See explanation on backside of this form.
Completed RFI forms should be mailed/faxed to the attention of Field Services Manager, at:
NSF International, P.O. Box 130140, Ann Arbor, MI 48113-0140
phone:[phone] fax:[phone]
© Copyright 2002 NSF International All Rights Reserved
Document Control #: AC-700-0004 Issued: September 13, 2002 Issue #: 5 Page 3 of 3

This Document is the Confidential Property of NSF International
Investigation of Complaints
NSF investigates complaints related to Certified products, misuse of a Mark by a Certified company, or use/misuse of a Mark by a
Non -Certified company. Complaints are classified as "formal' or "informal."
When filing a formal complaint, a "Request for Investigation' (RFI) provided by NSF must be completed and signed by the
complainant (see reverse side.) NSF will acknowledge receipt of an RFI, promptly investigate the complaint and take appropriate
action. NSF may advise the subject of the complaint of the allegation. NSF will confirm to the complainant that the complaint
has, or has not, been verified as correct. For formal complaints from another Certified or Non -Certified company, signing of the
RFI constitutes agreement by the complainant to bear the costs of the investigation if the complaint is not verified. If the
complaint is verified, the subject of the complaint is responsible for all costs of the investigation. Regulatory authorities are
exempt from bearing any costs relative to an investigation. NSF will not identify the complainant except as required by law.
If the complainant filing an RFI does not agree to bear the costs of the investigation, the complaint shall be considered "informal."
NSF will investigate "informal' complaints on or before the next regular plant audit, but has no obligation to acknowledge the
complaint, identify the complaining party, or to notify the complainant of the,results of any investigation that may be conducted.
Any complaint received via e-mail or Internet will be classified as informal.
Samole Selection and Handlin
NSF will not test for enforcement purposes, any samples submitted by a complainant, or select samples for testing that are under
the control or influence of the complainant, or test samples, if NSF has reason to believe that the samples may have been altered
in a way that could affect the outcome. Samples for testing for enforcement purposes shall be selected by NSF and handled in
accordance with established procedures.
File Maintenance
Copies of all formal complaints will be kept in the Corporate file and also in the Field Services complaint file. Copies of all
informal complaints will be kept in the Field Services complaint file.
Document Control #: AC-700-0004 Issued: September 13, 2002 Issue #: 5 Page 2 of 3

This Document is the Confidential Proaerty of NSF International
Investil?ation of Complaints
NSF investigates complaints related to Certified products, misuse of a Mark by a Certified company, or use/misuse of a Mark by a
Non -Certified company. Complaints are classified as "formal' or "informal."
When filing a formal complaint, a "Request for Investigation" (RFI) provided by NSF must be completed and signed by the
complainant (see reverse side.) NSF will acknowledge receipt of an RFI, promptly investigate the complaint and take appropriate
action. NSF may advise the subject of the complaint of the allegation. NSF will confirm to the complainant that the complaint
has, or has not, been verified as correct. For formal complaints from another Certified or Non -Certified company, signing of the
RFI constitutes agreement by the complainant to bear the costs of the investigation if the complaint is not verified. If the
complaint is verified, the subject of the complaint is responsible for all costs of the investigation. Regulatory authorities are
exempt from bearing any costs relative to an investigation. NSF will not identify the complainant except as required by law.
If the complainant filing an RFI does not agree to bear the costs of the investigation, the complaint shall be considered "informal."
NSF will investigate "informal' complaints on or before the next regular plant audit, but has no obligation to acknowledge the
complaint, identify the complaining party, or to notify the complainant of the,results of any investigation that may be conducted.
Any complaint received via e-mail or Internet will be classified as informal.
Sample Selection and Handling
NSF will not test for enforcement purposes, any samples submitted by a complainant, or select samples for testing that are under
the control or influence of the complainant, or test samples, if NSF has reason to believe that the samples may have been altered
in a way that could affect the outcome. Samples for testing for enforcement purposes shall be selected by NSF and handled in
accordance with established procedures.
File Maintenance
Copies of all formal complaints will be kept in the Corporate file and also in the Field Services complaint file. Copies of all
informal complaints will be kept in the Field Services complaint file.
Document Control #: AC-700-0004 Issued: September 13, 2002 Issue #: 5
Page 2 of 3

This Document is the Confidential Property of NSF International
NSF International
Request For Investigation
Formal ,- Informal (check one)
Product Manufacturer Information
Co. Name
Address
City/State
Product Description (as applicable)
Type
Model No.
Serial No.
NSF Mark attached: Yes No
NSF Mark No.
Imprint on Product:
Are samples of the product available: Yes No_
Installation Information
Location
Address
City/State
Date Installed
Distributor
Name
Address
City/State
Complaint Description: Describe in detail the specific complaint or action desired (attach a separate sheet if necessary).
Photographs or sketches can be most helpful in the initial investigation.
Name:
Title:
Organization:
Address:
City/State/Zip:
Phone/Fax:
Signature of Complainant Date
If the formal box is checked and the complaint is signed, the complainant, other than regulatory or municipal authorities, agrees to
bear all costs of the investigation. See explanation on backside of this form.
Completed RFI forms should be mailed/faxed to the attention of Field Services Manager, at:
NSF International, P.O. Box 130140, Ann Arbor, MI 48113-0140
phone:[phone] fax:[phone]
© Copyright 2002 NSF International All Rights Reserved
Document Control M: AC-700-0004 Issued: September 13, 2002 Issue 4: 5 Page 3 of 3

North Carolina Secretary of State
Page 1 of 1
North Carolina
Flame F. Marshal! E PARTM E NT OF THE
p
Secretary ECF�E'TARY of 'TAT E
e1 „ rm
PO Box 29622 Raleigh, NC 27626-0622 [phone]
CORPORATIONS
Corporations Home
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Date: 1 /29/2009
Click here to:
View Document Filings I Sign Up for E-Notifications
mr'Print apre-populated Annual Report Form I Annual Report Count I File
an Annual Report I
Corporation Names
Name Name Type
NC THE TARA GROUP OF Legal
LUMBERTON, INC.
Business Corporation Information
SOSID:
0439784
Status:
Current -Active
Date Formed:
10/9/1997
Citizenship:
Domestic
State of Inc.:
NC
Duration:
Perpetual
Registered Agent
Agent Name:
Charles D. Andrews
Registered Office Address:
8135 Red Road
Rockwell NC 28138
Registered Mailing
8135 Red Road
Address:
Rockwell NC 28138
Principal Office Address:
8135 Red Road
Rockwell NC 28138
Principal Mailing Address:
8135 Red Road
Rockwell NC 28138
Stock
Class Shares No Par Value
COMMON 1000 Yes
Par Value
N/A
http://www.secretary.state.ne.us/corporations/Corp.aspx?Pitemld=5035236 1/29/2009

FILED
OFFICE OF
ADMINISTRATIVE HEARINGS
Nov 19 9 00 AM 2009
STATE OF NORTH CAROLINA
COUNTY OF ROWAN
Alchem Inc
Petitioner
VS.
N. C. Department of Environment and
Natural Resources
Respondent
IN THE OFFICE OF
ADMINISTRATIVE HEARINGS
08 EHR 1796
}
NOTICE OF HEARING
NOTICE IS HEREBY GIVEN that the above -captioned case will be brought on for
hearing before the undersigned administrative law judge as follows:
DATE: January 30, 2008
TIME: 9:00 AM
RECEIVED
PLACE: Rowan County Courthouse104
04r20 s2_
Courtroom 5, 3rd Floor
N.C. ATTORNEY GENERAL
210 N. Main Street
Environmental Division
Salisbury, North Carolina
1. This hearing will be conducted in accordance with G.S. Chapter 150B and the Rules of
Contested Case Hearings in the Office of Administrative Hearings, copies of which
may be obtained at cost from Molly Masich, Director of APA Services or by accessing
the OAH Web page at http://www.oah.state.ne.us/hearings/#Chapter3.
2. Unless otherwise determined by the administrative law judge, the hearing will proceed
in the following sequence:
a. Call of the case
b. Motions and other preliminary matters
c. Stipulations, agreements, or consent orders entered into the record
d. Opening statements
e. Presentation of evidence; cross-examination
f. Final arguments
3. All parties are hereby notified to bring to the hearing all documents, records, and
witnesses needed to present the parry's case.
NOTE: IF SPECIAL EQUIPMENT IS REQUIRED FOR THE PRESENTATION

PLEASE PRINT CLEARLY OR TYPE
STATE OF NORTH CAROLINA .e
COUNTY OF (1) Rowan ' W o 'CO
(2) Alchem, Inc.
Case No. PC-2008-0026
(your name) I PETITIONER,-
V
(3) N.C. Department of Envirnnmental
and Natural Resources (NCDENR)
RESPONDENT.
(The State agency or board about which you are complaining)
IN THE OFFICE OF
ADMINISTRATIVE HEARINGS
JUL 29 20
PETITION
FOR A
CONTESTED CASE HEARING
1
I hereby ask for a contested case hearing as provided for by North Carolina General Statute § I50B-23 because the Respondent has:
(Briefly state facts showing how you believe you have been harmed by the State agency or board.)
12ENE filed an enforcement action against us fnr disposing of wastai. We did not dispose of
any waste. We have a material that is a beneficial p n�1„fit that �»a rranc . a r
arm
in Davidson Count�_After ;;n it r},a,-p ,a
g wprp fnrc to brig ;t hark—tn_-aur..plant.:
(if more space is needed, attach additional pages.)
(4) Because of these facts, the State agency or board has; (check at least one from each column)
deprived me of property; x exceeded its authority oi' jurisdiction;
x ordered mee t to pay a fine or civil penalty; or
otherwise substantially prejudiced my rights; AND —x acted erroneously;
_x failed to use proper prodboure;
_x_acted arbitrarily or capriciously; or
(5) Date: 7-24-08
x failed to act as required 4 law or rule.
(6) Your phone number: ( 910) 843-21�I ext 23
(7) Print your full address: 8135 Red Road Rockwell NC 281381
(8) Print your name: Randall F. Andre>,e a s to zip
(9) Your signature:
You must mail ne the name deliver a of the perCOPY person to be serve
or of this Petition
board to determine to the State agency or board named on line (3) ofd. this fapCrrr. You should contact the agency or
CERTIFICATE OF SERVICE
I certify that this Petition has been served on the State agency or board named below by depositing a copy of id with the United States Postal Service
with sufficient postage affixed OR by delivering it to the named agency or board:
(10) Ms. Mary Penn Thompson
operson served)
(12) 1601 Mail Service Center
(street address/p.o. box)
(13) This the 24 day of
(14) f ]KOL ,n {�1.
20 08 .
(your signature)
(11) NCDENR
- (State agency or board.listed on line 3)
(state) (zip code)
When you have completed this form, you MUST mail or deliver the ORIGINAL AND ONE COPY to the
Mail Service Center, Raleigh, NC 27699-6714.
H-06 (11199)
of Administrative Hearings, 6714

—AWomsponuence rrome cover Sheet
Page 1 of 1
WDENR
Correspondence Tracking System
00307200802662
summary
Petition for a Contested Case Hearing: Alchem, Inc. v. DWQ, Aquifer Protection Section (Case No. PC-2008-0026)
Received 07/29/2008 via Letter
Legal issue for Mary Penny Thompson
Issued 07/24/2008 by Randall F. Andrews of Alchem, Inc.
For Recipient Use Only
To:
Date: / /
Respond By:
Please' Prepare a reply for my signature and return to me.
Reply, noting the letter was referred to you by me.
Prepare a reply for the Governoes signature and return to me.
Reply, noting the letter was referred to you by the Govemor.
For your information.
Take appropriate action
Note and file.
Note and return to me.
Note and see me about this.
Your comments and/or recommendations.
Copy to Secretary's Office
Remarks
http:/fbeam.enr.state.nc.uslos/dtstprintdo?dispatch--crsdProfIe&id=2662 8/1/2408

'fir, <, 0 v

6A �,
PW

Memorandum
To: Jimmie Overton
Through
From:
Re:
Division of Water Quality
Biological Assessment Unit
3 April 2007
Trish MacPherson " --
Michael Walters
Study plan: Biological assessment of unnamed stream below Alchem Inc. facility,
Rockwell NC
,r Protection
On 21' March 2007 the Biological Assessment Unit received• a request from Kim Colson with the Aquifer Protection
Section to investigate possible impacts to an unnamed stream 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. in Rockwell is a producer of alum for 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 m the facility
to the adjacent streambed.
Figure 1 shows the area around the Alchem facility. The area in green labeled"Alchem" is the approximate ground
area for the Alchem facility. The point marked "sample" indicates the site downstream of the facility that will be
sampled to detect potential impacts to the stream. The points labeled "ref1" and "ref2" are two potential reference
sites that have the following characteristics as determined from a topographical map and aerial images: 1) near a road
crossing for quick access; 2) similar drainage areas to the site downstream of Alchem; 3) 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.
The drainage area for each of the sites is indicated roughly by the area bound with a red line.

Sampling at the site below the Alchem facility is scheduled for the morning of 19 April 2007 to assess the potential
influences from water chemistry and physical habitat alteration. If it appears that the sand has not moved downstream
from near the Alchem facility to that site, a second site upstream of "sample" will be sought to assess potential habitat
impairment. Ellen Huffman will be available to assist us with locating the second site if necessary.
s
The sites "ref1" and "'ref2" Will be reconnoitered to determine the feasibility of each as a reference site. The better one
of the two sites will be sampled.
Thus, two sites will be sampled during this trip assuming adequate flow. A third site may also be sampled on the
potentially impaired stream if necessary. We may be able to complete this work in a single day, though we will be
prepared for an overnight stay if needed.
✓cc:. Ellen Huffman, Peggy Finley, Wes Bell, Andrew Pitner—Mooresville Regional Office
2

02/08/2008 02:53 7049382714
i5 1 Mot ��r
VICTOR MELTON CONST PAGE 01
ihf�
ENVIRONMENTAL
SCIENCE CORP,
Althem, Inc.
Ma. Phyllis Drye
8135 Red Road
Rockwell, NC 28138
cell a
Quality Aa$urance Report
Level II
L312565
nits _ MS RLQ Ref Res
ReC Limit.
1 os5 LeiSdnon Rd•
M Juliet, TN 3712Z
1('15) 758-5958
1 $00-767-59$y
P x (615) ry58-5859
TKx I.D. 62-0814289
8 t, 1770
i er 04, 2007
'Ref Samp Batch
Arsenic
. • . .. •• •..^•..• �/. g.:.<....6.3:0`.,`::'.::;::•,:i�3:�4:'`'�•.:'�;
51.8
; �5,0.,, ;:.;..
560•.,.•.;•;,.7.5-.125';
S; L312.508-01' WG322462
Barium
mg/kg
4•::::.::':.:.hE::::;::>.^:163
4.20
2.3.0. ,
SO
so
95.2
0.0
75-725
75-125
L312508-01 WG322462
L3125,08-01 WG322462
Calcium
:.•;.:., .......<..,..,..;..:.r.• .:..:....::.::.r.a::>.::•::: /:1 g;:,.>:k1it8:r::..::..s.;.:.:0.320
mg/kg 155000
0.00
•.:.•SQ:s :?::.t•':.:..�
;.0.>;7a�
�;Y25'
!:.Fa3X'2 08-'q1; .WG322462
Chromium
52.1
8. 20
500
50
6200
75-125
L312508-01 WG322462
er
Co$$:.
Lead ...
.. ; ,;:g
g';•:.�;$;;6
f'":: •1'0:2','
87,8
' .• ..
75-125
:•"75�125„WG322462
L312508-01 WG322462
I+
Magnesium
mg/kg 59.5
mg/kg,.40400
15.0
43600
50
500
89,0
0.0
15-125'
75-125
L312568-01 WG322462
L312508-01 WG322462
Motyybderium
41? ...�3............ ......... 6..:.:..;..;
mg/kg 43.5 0,252
5.ti .:::.°. ;':>'.l fi::.,:.75;-1
5p 86.5
5:;:L3'1250:8101'
75-125
WG322462
L312508-01
Nickel
rMIA9
$.04
50
106.
75-125
WG322462
:58.:e
;.:.;:>::•;•?'•`;�:�.; C7Ka:.:,.,,•,>.:.:`1..`:�1iO::.•�'2'}::1�:��::�>•'s;r:;:•.�y.'{Y.;•;.::...��:•.1.'��;:7u�3;dace?:.Q:B.;;i�4i•].;•:5iiG3.,�2.462
$elextittm
L312508-01 WG322462
Silver
mg/kg 25,8
mgfk 47.2.
0.00
D.00
$
50
51.6
94.4
75-129
'L312508-01 WG322462
`:•;';::'
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:, • ..,..:.;::.;•:,:::`.t1tiI1.3>t�:::•...;•4'86'.''•''::::
°sb'0.:: '''Q3":`f.
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7�;725:>L31250$-.0�.
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mg/kg 76.0
30.5
so
91.0
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L312506-01 WG322462
o.ao
'•25
105.
70-130
L312535-01 W0322650
Mtrduiy • • ..
Nitrate
Nitrite
Ammonia Nitrogen
Phogphoruri:To'ta1 •
fig/kj 51.7
3.00
50
97.4
80-120
4:p..'gq'::':'
;..m9/kg 258.
0.00
250
103.
80-120
_. mg g 0.:00.
.
0.00
Sn
L312768-01 WG322700
L3I276.8'-01 WG32270o
L312768-01 WG323163
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Unite M$p Res Ref Res Rp1P
Limit %ReC
Ref Sam Batch
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mg%kg51.8
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20
97.4
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Ba
Bari
Barium
Cadmium..
mg/kg 224:
""''k9:
163,
31.5
20
0.00
G
L3125o8-01 W322462
Calcium
mg/kg 1690,60
..:5:•36
155000
8.64
:` .20
20
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Chromium
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mg/kg 51,8
; ......, 1!)Cg's°s6.4..'.
52..1
59:.6.:•. .,:>T'.43'_
0.577
20
6760
87,2
1.0;8:;'
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%:
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61.6
3.47
•..•2,.0•
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Magnesium
M9/kg
mg/kg39700
•59..5
!40400
1.75
20
20
93:2
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Molybdenum
::.•::: mgI%.>::'::?••E<i>9:<:.:;.:::..;•r:57•::;;:a0;..'..:"ri1.0.;::;:;#t:L372508�01'WG322462
0.00
L312508-01 WG322462
Nickel
mg/kg 44.5
mg/kg 54.4
43.5
58.8
2-27
7.77
20
20
88.5
96.7
L312508-01 WG322462
potassium..
Seleriiuitl
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1;54f:'.'
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Silver
mg/k9 31.6
mg/kg 50.4
25.8
47.2
20.$
6.56
20
63.2
L312508-01 WG322462
Sodium.°.' :: :•.::• •• '•,•::::<
Zinc
::: :.::.:s::••> 3 )Kg: 0.00::;..:..>;:9.;;;.::;:.:0:7,0
mg/kg 84.8
76.0
;:;t2:4•;:.':::1
20
101.
X. •;::'Ii3i2508
L3125o8-01 W0322462
01 W43224fi'2
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20
109.
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,2'6'7....:"�.'.0..:963..
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Nitrate
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:,.., .. . •.mg/kg 51.6
51.7
0.194
20
97.2
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•••0:..00,
20
99,1
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Arcgtwnia Nitr4jCri ;;
:..., , ,;::;mg/kg 259.
258.
0.387
20
104,
L312768-01 WG323163
Ph6dphoru9 , i'Otal
m g/kg • •0.00 •••��
• 0.�00
�20
' ''::'"''
••0.00
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Batch number /Run number /
Sample number Cross reference
WG322462: R335674: L312565-01
Wraly'2o3n. olleaYo. r.�I nCCC .n,

GS 143-215.1 Page 1 of 10
§ 143-215.1. Control of sources of water pollution; permits required.
(a) Activities for Which Permits Required. - No person shall do any of the following
things or carry out any of the following activities unless that person has received a permit from
the Commission and has complied with all conditions set forth in the permit:
(1) Make any outlets into the waters of the State.
(2) Construct or operate any sewer system, treatment works, or disposal system
within the State.
(3) Alter, extend, or change the construction or method of operation of any sewer
system, treatment works, or disposal system within the State.
(4) Increase the quantity of waste discharged through any outlet or processed in
any treatment works or disposal system to any extent that would result in any
violation of the effluent standards or limitations established for any point
source or that would adversely affect the condition of the receiving waters to
the extent of violating any applicable standard.
(5) Change the nature of the waste discharged through any disposal system in any
way that would exceed the effluent standards or limitations established for any
point source or that would adversely affect the condition of the receiving
waters in relation to any applicable standards.
&�(6 );j Cause or permit any waste; directly or indirectly, to be discharged to or in any
' manner intermixed with the waters of the State in violation of the water quality
standards applicable to the assigned classifications or in violation of any
effluent standards or limitations established for any point source, unless
allowed as a condition of any permit, special order or other appropriate
instrument issued or entered into by the Commission under the provisions of
this Article.
(7) Cause or permit any wastes for which pretreatment is required by pretreatment
standards to be discharged, directly or indirectly, from a pretreatment facility
to any disposal system or to alter, extend or change the construction or method
of operation or increase the quantity or change the nature of the waste
discharged from or processed in that facility.
(8) Enter into a contract for the construction and installation of any outlet, sewer
system, treatment works, pretreatment facility or disposal system or for the
alteration or extension of any such facility.
(9) Dispose of sludge resulting from the operation of a treatment works, including
the removal of in -place sewage sludge from one location and its deposit at
another location, consistent with the requirement of the Resource Conservation
and Recovery Act and regulations promulgated pursuant thereto.
(10) Cause or permit any pollutant to enter into a defined managed area of the
State's waters for the maintenance or production of harvestable freshwater,
estuarine, or marine plants or animals.
(11) Cause or permit discharges regulated under G.S. 143-214.7 that result in water
pollution.
(12) Construct or operate an animal waste management system, as defined in G.S.
143-215.10B, without obtaining a permit under either this Part or Part IA of
this Article.
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GS 143-215.1
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(al) In the event that both effluent standards or limitations and classifications and water
quality standards are applicable to any point source or sources and to the waters to which they
discharge, the more stringent among the standards established by the Commission shall be
applicable and controlling.
(a2) No permit shall be granted for the disposal of waste in waters classified as sources of
public water supply where the head of the agency that administers the public water supply
program pursuant to Article 10 of Chapter 130A of the General Statutes, after review of the
plans and specifications for the proposed disposal facility, .determines and advises the
Commission that any outlet for the disposal of waste is, or would be, sufficiently close to the
intake works or proposed intake works of a public water supply as to have an adverse effect on
the public health.
(0) If the Commission denies an application for a permit, the Commission shall state in
writing the reason for the denial and shall also state the Commission's estimate of the changes in
the applicant's proposed activities or plans that would be required in order that the applicant may
obtain a permit.
(a4) The Department shall regulate wastewater systems under rules adopted by the
Commission for Health Services pursuant to Article 11 of Chapter 130A of the General Statutes
except as otherwise provided in this subsection. No permit shall be required under this section
for a wastewater system regulated under Article 11 of Chapter 130A of the General Statutes.
The following wastewater systems shall be regulated by the Department under rules adopted by
the Commission:
(1) Wastewater systems designed to discharge effluent to the land surface or
surface waters.
(2) Wastewater systems designed for groundwater remediation, groundwater
injection, or landfill leachate collection and disposal.
U(3)�asewater systeinsde`signed for' e moc plate reecleQr�reus_e_of industrial
process -wastewater
(b) Commission's Power as to Permits. —
(1) The Commission shall act on all permits so as to prevent, so far as reasonably
possible, considering relevant standards under State and federal laws, any
significant increase in pollution of the waters of the State from any new or
enlarged sources. No permit shall be denied and no condition shall be attached
to the permit, except when the Commission finds such denial or such
conditions necessary to effectuate the purposes of this Article.
(2) The Commission shall also act on all permits so as to prevent violation of
water quality standards due to the cumulative effects of permit decisions.
Cumulative effects are impacts attributable to the collective effects of a
number of projects and include the effects of additional projects similar to the
requested permit in areas available for development in the vicinity. All permit
decisions shall require that the practicable waste treatment and disposal
alternative with the least adverse impact on the environment be utilized.
(3) General permits may be issued under rules adopted pursuant to Chapter 150B
of the General Statutes. Such rules may provide that minor activities may occur
under a general permit issued in accordance with conditions set out in such
rules. All persons covered under general permits shall be subject to all
enforcement procedures and remedies applicable under this Article.
(4) The Commission shall have the power:
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GS 143-215.1
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a. To grant a permit with such conditions attached as the Commission
believes necessary to achieve the purposes of this Article.
b. To require that an applicant satisfy the Department that the applicant, or
any parent, subsidiary, or other affiliate of the applicant or parent:
1. Is financially qualified to carry out the activity for which the
permit is required under subsection (a) of this section; and
2. Has substantially complied with the effluent standards and
limitations and waste management treatment practices applicable
to any activity in which the applicant has previously engaged,
and has been in substantial compliance with other federal and
state laws, regulations, and rules for the protection of the
environment.
3. As used in this subdivision, the words "affiliate," "parent," and
"subsidiary" have the same meaning as in 17 Code of Federal
Regulations § 240.12b-2 (April 1, 1990, Edition).
4. For a privately owned treatment works that serves 15 or more
service connections or that regularly serves 25 or more
individuals, financial qualification may be demonstrated through
the use of a letter of credit, insurance, surety, trust agreement,
financial test, bond, or a guarantee by corporate parents or third
parties who can pass the financial test. No permit shall be issued
under this section for a privately owned treatment works that
serves 15 or more service connections or that regularly serves 25
or more individuals, until financial qualification is established
and the issuance of the permit shall be contingent on the
continuance of the financial qualification for the duration of the
activity for which the permit was issued.
C. To modify or revoke any permit upon not less than 60 days' written
notice to any person affected.
d. To designate certain classes of minor activities for which a general
permit may be issued, after considering:
1. The environmental impact of the activities;
2. How often the activities are carried out;
3. The need for individual permit oversight; and
4. The need for public review and comment on individual permits.
e. To designate certain classes of minor activities for which:
1. Performance conditions may be established by rule; and
2. Individual or general permits are not required.
(5) The Commission shall not issue a permit for a new municipal or domestic
wastewater treatment works that would discharge to the surface waters of the
State or for the expansion of an existing municipal or domestic wastewater
treatment works that would discharge to the surface waters of the State unless
the applicant for the permit demonstrates to the satisfaction of the Commission
that:
a. The applicant has prepared and considered an engineering,
environmental, and fiscal analysis of alternatives to the proposed
facility.
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b. The applicant is in compliance with the applicable requirements of the
systemwide municipal and domestic wastewater collection systems
permit program adopted by the Commission.
(b 1) Repealed by Session Laws 1991, c. 156, s. 1.
(c) Applications for Permits and Renewals for Facilities Discharging to the Surface
Waters. —
(1) All applications for permits and for renewal of existing permits for outlets and
point sources and for treatment works and disposal systems discharging to the
surface waters of the State shall be in writing, and the Commission may
prescribe the form of such applications. All applications shall be filed with the
Commission at least 180 days in advance of the date on which it is desired to
commence the discharge of wastes or the date on which an existing permit
expires, as the case may be. The Commission shall act on a permit application
as quickly as possible. The Commission may conduct any inquiry or
investigation it considers necessary before acting on an application and may
require an applicant to submit plans, specifications, and other information the
Commission considers necessary to evaluate the application.
(2) a. The Department shall refer each application for permit, or renewal of
an existing permit, for outlets and point sources and treatment works
and disposal systems discharging to the surface waters of the State to its
staff for written evaluation and proposed determination with regard to
issuance or denial of the permit. If the Commission concurs in the
proposed determination, it shall give notice of intent to issue or deny the
permit, along with any other data that the Commission may determine
appropriate, to be given to the appropriate State, interstate and federal
agencies, to interested persons, and to the public.
al. The Commission shall prescribe the form and content of the notice.
Public notice shall be given at least 45 days prior to any proposed final
action granting or denying the permit. Public notice shall be given by
publication of the notice one time in a newspaper having general
circulation within the county.
b. Repealed by Session Laws 1987, c. 734.
(3) If any person desires a public hearing on any application for permit or renewal
of an existing permit provided for in this subsection, he shall so request in
writing to the Commission within 30 days following date of the notice of
intent. The Commission shall consider all such requests for hearing, and if the
Commission determines that there is a significant public interest in holding
such hearing, at least 30 days' notice of such hearing shall be given to all
persons to whom notice of intent was sent and to any other person requesting
notice. At least 30 days prior to the date of hearing, the Commission shall also
cause a copy of the notice thereof to be published at least one time in a
newspaper having general circulation in such county. In any county in which
there is more than one newspaper having general circulation in that county, the
Commission shall cause a copy of such notice to be published in as many
newspapers having general circulation in the county as the Commission in its
discretion determines may be necessary to assure that such notice is generally
available throughout the county. The Commission shall prescribe the form and
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GS 143-215.1
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content of the notices.
The Commission shall prescribe the procedures to be followed in hearings.
If the hearing is not conducted by the Commission, detailed minutes of the
hearing shall be kept and shall be submitted, along with any other written
comments, exhibits or documents presented at the hearing, to the Commission
for its consideration prior to final action granting or denying the permit.
(4) Not later than 60 days following notice of intent or, if a public hearing is held,
within 90 days following consideration of the matters and things presented at
such hearing, the Commission shall grant or deny any application for issuance
of a new permit or for renewal of an existing permit. All permits or renewals
issued by the Commission and all decisions denying application for permit or
renewal shall be in writing.
(5) No permit issued pursuant to this subsection (c) shall be issued or renewed for
a term exceeding five years.
(6) The Commission shall not act upon an application for a new noninunicipal
domestic wastewater discharge facility until it has received a written statement
from each city and county government having jurisdiction over any part of the
lands on which the proposed facility and its appurtenances are to be located
which states whether the city or county has in effect a zoning or subdivision
ordinance and, if such an ordinance is in effect, whether the proposed facility is
consistent with the ordinance. The Commission shall not approve a permit
application for any facility which a city or county has determined to be
inconsistent with its zoning or subdivision ordinance unless it determines that
the approval of such application has statewide significance and is in the best
interest of the State. An applicant for a permit shall request that each city and
county government having jurisdiction issue the statement required by this
subdivision by mailing by certified mail, return receipt requested, a written
request for such statement and a copy of the draft permit application to the
clerk of the city or county. If a local government fails to mail the statement
required by this subdivision, as evidenced by a postmark, within 15 days after
receiving and signing for the certified mail, the Commission may proceed to
consider the permit application notwithstanding this subdivision.
(c1) Any person who is required to obtain an individual wastewater permit under this
section for a facility discharging to the surface waters of the State that have been classified as
nutrient sensitive waters (NSW) under rules adopted by the Commission shall not discharge
more than an average annual mass load of total nitrogen than would result from a discharge of
the permitted flow, determined at the time the Commission makes a finding that those waters are
experiencing or are subject to excessive growth of microscopic or macroscopic vegetation,
having a total nitrogen concentration of five and one—half milligrams of nitrogen per liter (5.5
mg/1). The total nitrogen concentration of 5.5 mg/1 for nutrient sensitive waters required by this
subsection applies only to:
(1) Facilities that were placed into operation prior to 1 July 1997 or for which an
authorization to construct was issued prior to 1 July 1997 and that have a
design capacity to discharge 500,000 gallons per day or more.
(2) Facilities for which an authorization to construct is issued on or after 1 July
1997.
(c2) Any person who is required to obtain an individual wastewater permit under this
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GS 143-215.1 Page 6 of 10
section for a facility discharging to the surface waters of the State that have been classified as
nutrient sensitive waters (NSW) under rules adopted by the Commission where phosphorus is
designated by the Commission as a nutrient of concern shall not discharge more than an average
annual mass load of total phosphorus than would result from a discharge of the permitted flow,
determined at the time the Commission makes a finding that those waters are experiencing or
are subject to excessive growth of microscopic or macroscopic vegetation, having a total
phosphorus concentration of two milligrams of phosphorus per liter (2.0 mg/1). The total
phosphorus concentration of 2.0 mg/l for nutrient sensitive waters required by this subsection
applies only to:
(1) Facilities that were placed into operation prior to 1 July 1997 or for -which an
authorization to construct was issued prior to 1 July 1997 and that have a
design capacity to discharge 500,000 gallons per day or more.
(2) Facilities for which an authorization to construct is issued on or after 1 July
1997.
(6) A person to whom subsection (cl) or (c2) of this section applies may meet the limits
established under those subsections either individually or on the basis of a cooperative
agreement with other persons who hold individual wastewater permits if the cooperative
agreement is approved by the Commission. A person to whom subsection (cl) or (c2) of this
section applies whose agreement to accept wastewater from another wastewater treatment
facility that discharges into the same water body and that results in the elimination of the
discharge from that wastewater treatment facility shall be allowed to increase the average annual
mass load of total nitrogen and total phosphorus that person discharges by the average annual
mass load of total nitrogen and total phosphorus of the wastewater treatment facility that is
eliminated. If the wastewater treatment facility that is eliminated has a permitted flow of less
than 500,000 gallons per day, the average annual mass load of total nitrogen or phosphorus shall
be calculated from the most recent available data. A person to whom this subsection applies
shall comply with nitrogen and phosphorus discharge monitoring requirements established by
the Commission. This average annual load of nitrogen or phosphorus shall be assigned to the
wastewater discharge allocation of the wastewater treatment facility that accepts the wastewater.
(c4) A person to whom subsection (cl) of this section applies may request the
Commission to approve a total nitrogen concentration greater than that set out in subsection (cl)
of this section at a decreased permitted flow so long as the average annual mass load of total
nitrogen is equal to or is less than that required under subsection (cl) of this section. A person to
whom subsection (c2) of this section applies may request the Commission to approve a total
phosphorus concentration greater than that set out in subsection (c2) of this section at a
decreased permitted flow so long as the average annual mass load of total phosphorus is equal to
or is less than that required under subsection (c2) of this section. If, after any 12-month period
following approval of a greater concentration at a decreased permitted flow, the Commission
finds that the greater concentration at a decreased permitted flow does not result in an average
annual mass load of total nitrogen or total phosphorus equal to or less than those that would be
achieved under subsections (cl) and (c2) of this section, the -Commission shall rescind its
approval of the greater concentration at a decreased permitted flow and the requirements of
subsections (cl) and (c2) of this section shall apply.
(c5) For surface waters to which the limits set out in subsection (cl) or (c2) of this section
apply and for which a calibrated nutrient response model that meets the requirements of this
subsection has been approved by the Commission, mass load limits for total nitrogen or total
phosphorus shall be based on the results of the nutrient response model. A calibrated nutrient
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GS 143-215.1 Page 7 of 10
response model shall be developed and maintained with current data, be capable of
predicting the impact of nitrogen or phosphorus in the surface waters, and incorporated into
nutrient management plans by the Commission. The maximum mass load for total nitrogen .or
total phosphorus established by the Commission shall be substantiated by the model and may
require individual discharges to be limited at concentrations that are different than those set out
in subsection (cl) or (c2) of this section. A calibrated nutrient response model shall be
developed by the Department in conjunction with the affected parties and is subject to approval
by the Commission.
(c6) For surface waters that the Commission classifies as nutrient sensitive waters (NSW)
on or after 1 July 1997, the Commission shall establish a date by which facilities that were
placed into operation prior to the date on which the surface waters are classified NSW or for
which an authorization to construct was issued prior to the date on which the surface waters are
classified NSW must comply with subsections (cl) and (c2) of this section. The Commission
shall establish the compliance date at the time of the classification. The Commission shall not
establish a compliance date that is more than five years after the date of the classification. The
Commission may extend the compliance date as provided in G.S. 143-215.113. A request to
extend a compliance date shall . be submitted within 120 days of the date on which the
Commission reclassifies a surface water body as NSW.
(d) Applications and Permits for Sewer Systems, Sewer System Extensions and
Pretreatment Facilities, Land Application of Waste, and for Wastewater Treatment Facilities Not
Discharging to the Surface Waters of the State. —
(1) All applications for new permits and for renewals of existing permits for sewer
systems, sewer system extensions and for disposal systems, and for land
application of waste, or treatment works which do not discharge to the surface
waters of the State, and all permits or renewals and decisions denying any
application for permit or renewal shall be in writing. The Commission shall act
on a permit application as quickly as possible. The Commission may conduct
any inquiry or investigation it considers necessary before acting on an
application and may require an applicant to submit plans, specifications, and
other information the Commission considers necessary to evaluate . the
application. If the Commission fails to act on an application for a permit,
including a renewal of a permit, within 90 days after the applicant submits all
information required by the Commission, the application is considered to be
approved. Permits and renewals issued in approving such facilities pursuant to
this subsection shall be effective until the date specified therein or until
rescinded unless modified or revoked by the Commission. Local governmental
units to whom pretreatment program authority has been delegated shall
establish, maintain, and provide to the public, upon written request, a list of
pretreatment applications received.
(2) An applicant for a permit to dispose of petroleum contaminated soil by land
application shall give written notice that he intends to apply for such a permit
to each city and county government having jurisdiction over any part of the
land on which disposal is proposed to occur. The Commission shall not accept
such a permit application unless it is accompanied by a copy of the notice and
evidence that the notice was sent to each such government by certified mail,
return receipt requested. The Commission may consider, in determining
whether to issue the permit, the comments submitted by local governments.
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(dl) Each applicant under subsections (c) or (d) for a permit (or the renewal thereof) for
the operation of a treatment works for a private multi -family or single family residential
development, in which the owners of individual residential units are required to organize as a
lawfully constituted and incorporated homeowners' association of a subdivision, condominium,
planned unit development, or townhouse complex, shall be required to enter into an operational
agreement with the Commission as a condition of any such permit granted. The agreement shall
address, as necessary, construction, operation, maintenance, assurance of financial solvency,
transfers of ownership and abandonment of the plant, systems, or works, and shall be modified
as necessary to reflect any changed condition at the treatment plant or in the development.
Where the Commission finds appropriate, it may require any other private residential
subdivision, condominium, planned unit development or townhouse complex which is served by
a private treatment works and does not have a lawfully constituted and incorporated
homeowners' association, and for which an applicant applies for a permit or the renewal thereof
under subsections (c) or (d), to incorporate as a lawfully constituted homeowners' association,
and after such incorporation, to enter into an operational agreement with the Commission and
the applicant as a condition of any permit granted under subsections (c) or (d). The local
government unit or units having jurisdiction over the development shall receive notice of the
application within an established comment period and prior to final decision.
(e) Administrative Review. - A permit applicant or permittee who is dissatisfied with a
decision of the Commission may commence a contested case by filing a petition under G.S.
150B-23 within 30 days after the Commission notifies the applicant or permittee of its decision.
If the permit applicant or permittee does not file a petition within the required time, the
Commission's decision is final and is not subject to review.
(f) Local Permit Programs for Sewer Extension and Reclaimed Water Utilization. -
Municipalities, counties, local boards or commissions, water and sewer authorities, or groups of
municipalities and counties may establish and administer within their utility service areas their
own general permit programs in lieu of State permit required in G.S. 143-215.1(a)(2), (3), and
(8) above, for construction, operation, alteration, extension, change of proposed or existing
sewer system, subject to the prior certification of the Commission. For purposes of this
subsection, the service area of a municipality shall include only that area within the corporate
limits of the municipality and that area outside a municipality in its extraterritorial jurisdiction
where sewer service or a reclaimed water utilization system is already being provided by the
municipality to the permit applicant or connection to the municipal sewer system or a reclaimed
water utilization system is immediately available to the applicant; the service areas of counties
and the other entities or groups shall include only those areas where sewer service or a reclaimed
water utilization system is already being provided to the applicant by the permitting authority or
connection to the permitting authority's system is immediately available. No later than the 180th
day after the receipt of a program and statement submitted by any local government,
commission, authority, or board the Commission shall certify any local program that does all of
the following:
(1) Provides by ordinance or local law for requirements compatible with those
imposed by this Part and the rules implementing this Part.
(2) Provides that the Department receives notice and a copy of each application
for a permit and that it receives copies of approved permits and plans upon
request by the Commission.
(3) Provides that plans and specifications for all construction, extensions,
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GS 143-215.1
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alterations, and changes be prepared by or under the direct supervision of an engineer
licensed to practice in this State.
(4) Provides for the adequate enforcement of the program requirements by
appropriate administrative and judicial process.
(5) Provides for the adequate administrative organization, engineering staff,
financial and other resources necessary to effectively carry out its plan review
program.
(6) Provides that the system is capable of interconnection at an appropriate time
with an expanding municipal, county, or regional system.
(7) Provides for the adequate arrangement for the continued operation, service,
and maintenance of the sewer or a reclaimed water utilization system.
(8) Is approved by the Commission as adequate to meet the requirements of this
Part and the rules implementing this Part.
(fl) The Commission may deny, suspend, or revoke certification of a local program upon
a finding that a violation of the provisions in subsection (f) of this section has occurred. A
denial, suspension, or revocation of a certification of a local program shall be made only after
notice and a public hearing. If the failure of a local program to carry out this subsection creates
an imminent hazard, the Commission may summarily revoke the certification of the local
program. Chapter 150B of the General Statutes does not apply to proceedings under this
subsection.
(f2) Notwithstanding any other provision of subsections (f) and (fl) of this section, if the
Commission determines that a sewer system, treatment works, or disposal system is operating in
violation of the provisions of this Article and that the appropriate local authorities have not acted
to enforce those provisions, the Commission may, after written notice to the appropriate local
government, take enforcement action in accordance with the provisions of this Article.
(g) Any person who is required to hold a permit under this section shall submit to the
Department a written description of his current and projected plans to reduce the discharge of
waste and pollutants under such permit by source reduction or recycling. The written description
shall accompany the payment of the annual permit fee. The written description shall also
accompany any application for a new permit, or for modification of an existing permit, under
this section. The written description required by this subsection shall not be considered part of a
permit application and shall not serve as the basis for the denial of a permit or permit
modification.
(h) Each applicant for a new permit or the modification of an existing permit issued
under subsection (c) of this section shall include with the application: (i) the extent to which the
new or modified facility is constructed in whole or in part with funds provided or administered
by the State or a unit of local government, (ii) the impact of the facility on water quality, and
(iii) whether there are cost-effective alternative technologies that will achieve greater protection
of water quality. The Commission shall prepare a quarterly summary and analysis of the
information provided by applicants pursuant to this subsection. The Commission shall submit
the summary and analysis required by this subsection to the Environmental Review Commission
(ERC) as a part of each quarterly report that the Commission is required to make to the ERC
under G.S. 143B-282(b). (1951, c. 606; 1955, c. 1131, s. 1; 1959, c. 779, s. 8; 1967, c. 892, s. 1;
1971, c. 1167, s. 6; 1973, c. 476, s. 128; c. 821, s. 5; c. 1262, s. 23; 1975, c. 19, s. 51; c. 583, ss.
2-4; c. 655, ss. 1, 2; 1977, c. 771, s. 4; 1979, c. 633, s. 5; 1985, c. 44.6, s. 1; c. 697, s. 2; 1985
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(Reg. Sess., 1986), c. 1023, ss. 1-5; 1987, c. 461, s. 1; c. 734, s. 1; c. 827, ss. 154, 159; 1989,
c. 51, s. 2; c. 168, s. 29; c. 453, ss. 1, 2; c. 494, s. 1; c. 727, ss. 160, 161; 1989 (Reg. Sess.,
1990), c. 1004, s. 17; c..1024, s. 33; c. 1037, s. 1; 1991, e. 156, s. 1; c. 498, s. 1; 1991 (Reg.
Sess., 1992), c. 944, s. 12; 1995 (Reg. Sess., 1996), c. 626, s. 2; 1997-458, ss. 6.1, 9.1, 11.2;
1997-496, s. 3; 1998-212, s. 14.9H(b), (d); 1999-329, s. 10.1; 2004-195, s. 1.5; 2006-250, s.
5.)
This document (also available in PDF and RTF formats) is not an official document.
Please read the caveats on the main NC Statutes page for more information.
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Re: Alchem
Subject: Re: Alchem
From: David Goodrich <[e-mail]>
Date: Thu, 14 Feb 2008 14:28:23 -0500
To: Peggy Finley <[e-mail]>
Peggy Finley wrote:
We're meeting with the SBI and EPA folks tomorrow morning on the illegal
disposal. I got to looking at the permit condition in WQ0002702 that deals with
the disposal of the residuals. It, of course, references G.S.143-215.1. The G.S.
doesn't quite seem to fit these circumstances. Some of paragraph (a) (6) might
apply. What are your thoughts?
ma f
Peggy,
I see what you mean about that paragraph. I am thinking that the "spent bauxite" they
have been hauling probably fails the TCLP test for a "tame" pH, and therefore may
meet the definition of a hazardous waste under RCRA. In any event, their permit
requires them to dispose of the waste residuals in a manner "approved by the
Division", and dumping off -site isn't exactly "approved by the Division".
David
1 of 1 2/14/2008 2:33 PM

N.L(iA General atatutes - Ga 14-syy. 1.,1tCermg
-.IF ,
rage i of 3
Home About ®WP1i Contact Us Site Map Search
NCGA General Statutes - GS § 14-399. Littering
§ 14-399. Littering.
(a)No person, including but not limited to, any firm,
organization, private corporation, or governing body, agents or
employees of any municipal corporation shall intentionally or
recklessly throw, scatter, spill or place or intentionally or
recklessly cause to be blown, scattered, spilled, thrown or
placed or otherwise dispose of any litter upon any public
property or private property not owned by him within this State
or in the waters of this State including, but not limited to,
any public highway, public park, lake, river, ocean, beach,
campground, forest land, recreational area, trailer park,
highway, road, street or alley except:
(1) When such property is designated by the State or
political subdivision thereof for the disposal of
garbage and refuse, and such person is authorized
to use such property for such purpose; or
(2) Into a litter receptacle in such a manner that the
litter will be prevented from being carried away or
deposited by the elements upon any part of such
private or public property or waters.
(b) When litter is blown, scattered, spilled, thrown or
placed from a vehicle or watercraft, the operator thereof shall
be presumed to have committed such offense. This presumption,
however, does not apply to a vehicle transporting agricultural
products or supplies when the litter from that vehicle is a
nontoxic, biodegradable agricultural product or supply.
(c) Any person who violates this section in an amount not
exceeding 15 pounds and not for commercial purposes is guilty of
a Class 3 misdemeanor punishable by a fine of not less than two
hundred fifty dollars ($250.00) nor more than one thousand
dollars ($1,000) for the first offense. In addition, the court
may require the violator to perform community service of not
less than eight hours nor more than 24 hours. The community
service required shall be to pick up litter if feasible, and if
not feasible, to perform other labor commensurate with the
offense committed. Any second or subsequent offense within three
years after the date of a prior offense is punishable by a fine
of not less than five hundred dollars ($500.00) nor more than
two thousand dollars ($2,000). In addition, the court may
require the violator to perform community service of not less
than 16 hours nor more than 50 hours. The community service
required shall be to pick up litter if feasible, and if not
feasible, to perform other labor commensurate with the offense
committed.
(d) Any person who violates this section in an amount
exceeding 15 pounds but not exceeding 500 pounds and not for
commercial purposes is guilty of a Class 3 misdemeanor
punishable by a fine of not less than five hundred dollars
($500.00) nor more than two thousand dollars ($2,000). In
addition, the court shall require the violator to perform
community service of not less than 24 hours nor more than 100
hours. The community service required shall be to pick up litter
if feasible, and if not feasible, to perform other community
service commensurate with the offense committed.
e),,lny person who violates this section in an amount
http://www.wastenotnc.org/swhome/LitterLawl4399.htm 6/9/2008

NUUA General Statutes - GJ 14-3y9. Littering Fage L of j
1 r t
esceeding_500, po nqsZR4in -any quantity -.for- commercial purposes;
or who discards Titter that is a hazardous wast'e'as defined-in^�
r Q_S., 130A 290 is guilty of a 'Class=l_felony,. - In._addi-ti ori; 'thei
court shall order 'tFie--violatoi-Sato:
(1) Remove, or render harmless, the litter that he
discarded in violation of this section;
(2) Repair or restore property damaged by, or pay
damages for any damage arising out of, his
discarding litter in violation of this section; or
(3) Perform community public service relating to the
removal of litter discarded in violation of this
section or to the restoration of an area polluted
by litter discarded in violation of this section.
(f) A court may enjoin a violation of this section.
(fl)If a violation of this section involves the operation of
a motor vehicle, upon a finding of guilt, the court shall
forward a record of the finding to the Department of
Transportation, Division of Motor Vehicles, which shall record a
penalty of one point on the violator's drivers license pursuant
to the point system established by G.S. 20-16. There shall be no
insurance premium surcharge or assessment of points under the
classification plan adopted under G.S. 58-36-65 for a finding of
guilt under this section.
(g) A motor vehicle, vessel, aircraft, container, crane,
winch, or machine involved in the disposal of more than 500
pounds of litter in violation of this section is declared
contraband and is subject to seizure and summary forfeiture to
the State.
(h) If a person sustains damages arising out of a violation
of this section that is punishable as a felony, a court, in a
civil action for such damages, shall order the person to pay the
injured party threefold the actual damages or two hundred
dollars ($200.00), whichever amount is greater. In addition, the
court shall order the person to pay the injured party's court
costs and attorney's fees.
(i) For the purpose of the section, unless the context
requires otherwise:
(1) "Aircraft" means a motor vehicle or other vehicle
that is used or designed to fly, but does not
include a parachute or any other device used
primarily as safety equipment.
(2) Repealed by Session Laws 1999-454, s. 1.
(2a) "Commercial purposes" means litter discarded by a
business, corporation, association, partnership,
sole proprietorship, or any other entity conducting
business for economic gain, or by an employee or
agent of such entity.
(3) "Law enforcement officer" means any officer of the
North Carolina Highway Patrol, the State Bureau of
Investigation, the Division of Motor Vehicles of
the Department of Transportation, a county
sheriff's department, a municipal law enforcement
department, a law enforcement department of any
other political subdivision, the Department, or the
North Carolina Wildlife Resources Commission. In
addition, and solely for the purposes of this
section, "law enforcement officer" means any
employee of a county or municipality designated by
the county or municipality as a litter enforcement
officer; or wildlife protectors as defined in G.S.
113-128(9);
(4) "Litter" means any garbage, rubbish, trash, refuse,
can, bottle, box, container, wrapper, paper, paper
product, tire, appliance, mechanical equipment or
part, building or construction material, tool,
machinery, wood, motor vehicle or motor vehicle
http://www.wastenottle.org/swhome/LitterLawl4399.htm 6/9/2008

N�'UA Ueneral Statutes - US § 14-399. Littermg
Page 3 of 3
part, vessel, aircraft, farm machinery or
equipment, sludge from a waste treatment facility,
water supply treatment plant, or air pollution
control facility, dead animal, or discarded
material in any form resulting from domestic,
industrial, commercial, mining, agricultural, or
governmental operations. "Litter" does not include
political pamphlets, handbills, religious tracts,
newspapers, and other such printed materials the
unsolicited distribution of which is protected by
the Constitution of the United States or the
Constitution of North Carolina.
(5) "Vehicle" has the same meaning as in G.S. 20-
4.01(49); and
(6) "Watercraft" means any boat or vessel used for
transportation across the water.
(j) It shall be the duty of all law enforcement officers to
enforce the provisions of this section.
(k) This section does not limit the authority of any State or
local agency to enforce other laws, rules or ordinances relating
to litter or solid waste management. (1935, c. 457; 1937, c.
446; 1943, c. 543; 1951, c. 975, s. 1; 1953, cc. 387, 1011;
1955, c. 437; 1957, cc. 73, 175; 1959, c. 1173; 1971, c. 165;
1973, c. 877; 1977, c. 887, s. 1; 1979, c. 1065, s. 1; 1983, c.
890; 1987, cc. 208, 757; 1989, c. 784, ss. 7.1, 8; 1991, c. 609,
s. 1; c. 720, s. 49; c. 725, s. 1; 1993, c. 539, ss. 266, 267,
1241; 1994, Ex. Sess., c. 24, s. 14(c); 1997-518, s. 1; 1998-
217, s. 2; 1999-294, s. 4; 1999-454, s. 1.)
NCDENR - Division of Waste Management 401 Oberlin Road - Suite 150, Raleigh, NC 27605 [phone] E-mail Us
http://www.wastenotnc.org/swhome/LitterLawl4399.htm 6/9/2008

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UA
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Waste Management
Beverly Eaves Perdue
Governor
CERTIFIED MAIL
Return Receipt Requested
Mr. Randall Andrews
Dexter R. Matthews
Director
April 20, 2011
Industrial & Agricultural Chemicals, Inc.
2042 Buie-Philadelphus Road
Red Springs, North Carolina
RE: Comments on Site Assessment Plan/Remedial Investigation
Industrial and Agricultural Chemicals, Inc. (IAC)
Red Springs, Robeson County, North Carolina
NONCD0001232
Dear Mr. Andrews:
Dee Freeman
Secretary
I have reviewed the Site Assessment Report (SAR) received on March 11, 2011 submitted for the subject
Site by The Clark Group ("your consultant"). While I agree with the general approach recommended by
your consultant for additional work, the following other items should also be addressed:
1. The information provided in the SAR concerning the presence and operational status of water
supply wells within a 500-foot radius of the Site is incomplete and should be more thoroughly
addressed. A work plan should be developed and implemented to sample supply wells that may have
been impacted as a result of activities that have occurred at the IAC facility. If the supply well is located
within a 500 foot radius of the Site and is deemed to be operational, samples should be collected to
determine if any of these wells including the adjacent well that was referenced in the report
recommendations have been contaminated by any of constituents that were identified in the
groundwater. Please be advised that the Branch may still require an inventory and map of all wells,
springs, and surface -water intakes used as sources of potable water within a one-half mile radius of the
center of the Site as required in the Site Assessment Request letter after reviewing the results of the
planned grog ridwater sampling event.
1646 Mail Service Center, Raleigh, North Carolina 27699-1646
Phone: [phone] FAX: [phone] Internet: www.wastenotnc.org
NortliCarolina
An Equal Opportunity 1 Affirmative Action Employer

2. As indicated on page 20 of the SAR, the target constituent concentrations for the pH and the
various detected metals in the groundwater including: Bo, Cu, Ni, Zn, As, Cd and Cr appear to be
widespread across the Site and have not been fully delineated to below the NCAC 2L Standard which is
a requirement. Therefore, additional monitoring wells need to be constructed and sampled to adequately
determine the full vertical and horizontal extent of the groundwater contaminant plumes. Additionally,
the telescoping well (T-1) that was constructed contains contaminant concentrations in the groundwater
above the 2L Standard which indicates that fiirther vertical delineation is required including an
evaluation of the vertical transport rate.
IAC must proceed immediately with developing the workplan and conducting- sampling of water
supply wells in the area. IAC should submit the sampling results for the water supply wells to this
office and the homeowner/well owner within 34 days receipt of this letter. The other recommendations
as outlined above and in the SAR, should be conducted as part of developing the required Remedial
Action Plan for the Site which should be completed within 120 days of receipt of this letter. All fiiture
correspondence and reporting should be sent to the following address unless I instruct you to do
otherwise.
P. Sean Boyles, L.G.
Inactive Sites Branch
Fayetteville Regional Office
225 Green Street, Suite 714
Fayetteville, North Carolina 28301
Failure to conduct any of this work in a timely fashion may result in this Site being recommended for
potential enforcement action.. Please respond in writing within ten (10) days receipt of this letter if you
intend to comply with the requirements. If you have any questions, please call me at [phone].
Sincerely,
P. Sean Boyles, L.G.
Hydrogeologist
cc: Stephen L. Clark, P.G., The Clark Group, Post Office Box 10136, Wilmington, NC 28404
Steven Vozzo, FRO Division of Air Quality
Mike Lawyer, FRO Water Quality Section
Peggy Finely, MRO Aquifer Protection Section

_u e
Huffman, Ellen
From:
Boyles, Sean
Sent:
Tuesday, April 20, 2010 9:46 AM
To:
Williford, Mike
Cc:
Walch, John; Nelms, Robert; Lilley, David; Barber, Jim; Huffman, Ellen
Subject:
FW: Questions about Industrial Agric and Chemicals in Robeson County
Mike,
Bobby and I are supposed to meet at the Site next Thursday to see what's going on at the IAC Site. It may be advisable
to also consider doing some sampling while we are down there. It's been reported that a pond located on an adjacent
property to the north of the property has a drain pipe that has been acting as a conveyance for sulfuric acid and metals
that are being stripped out of bauxite. The aerial photography seems to indicate that there is a pathway leading away
from IAC to this pond. If possible, I would like to request some assistance in collecting some samples at the site for pH
and RCRA metals. Please let me know.
Thanks,
Sean
From: Boyles, Sean
Sent: Monday, April 19, 2010 9:58 AM
To: Nelms, Robert
Subject: FW: Questions about Industrial Agric and Chemicals in Robeson County
From: Boyles, Sean
Sent: Monday, April 19, 2010 9:57 AM
To: '[e-mail]'
Cc: Walch, John; Shackelford, Dennis; Cook, Steve; Vozzo, Steven; Huffman, Ellen; Barnhardt, Art; Pitner, Andrew;
Lawyer, Mike
Subject: FW: Questions about Industrial Agric and Chemicals in Robeson County
I'm not sure if this is any sort of a violation of any permit they have with you guys in Hazardous Waste but we have not
given approval to Randall Andrews or anyone else to conduct this activity. The Clark Group who is working on the Site
Assessment plan for Mr. Andrews claims to know nothing about what is going on as far as any excavation or removal of
material from the IAC Site. Don't know where the material is being taken to or if it is hazardous. Is this something that
your group can take any action to resolve?
Thanks,
Sean
From: Boyles, Sean
Sent: Friday, April 16, 2010 5:21 PM
To: Vozzo, Steven
Cc: Huffman, Ellen; Barnhardt, Art; Shackelford, Dennis; Cook, Steve; Walch, John; Pitner, Andrew
Subject: RE: Questions about Industrial Agric and Chemicals in Robeson County

Under the Inactive Hazardous Sites Branch (IHSB) requirements, if this is a cleanup action they are doing then the RP
would be required to have a signed administrative agreement with IHSB and our approval prior to undertaking any
remedial action. We have requested completion of a draft Site Assessment plan which is just the first phase of
investigation and does not include any remedial work. The question perhaps is if this material is considered to be a
waste or if the RP will claim that there is some beneficial use to the material they are hauling off. There was a report
that some material had been dumped into a pond just north of the property and I was, waiting to hear if Ellen Huffman in
the AP Section in MRO had received an affidavit from this witness concerning any such illicit activity. Since it's so late in
the day, I guess it will have to wait until Monday to discuss what is going on at this facility. I'm sending a copy of this e-
mail to my supervisor in Raleigh (John Walch) to discuss what action may be warranted.
Thanks,
Sean
From: Vozzo, Steven
Sent: Friday, April 16, 2010 4:53 PM
To: Boyles, Sean; Cook, Steve; Shackelford, Dennis
Cc: Hayden, Robert
Subject: Questions about Industrial Agric and Chemicals in Robeson County
DAQ was on site at I.A.C. on Friday. A couple of questions to discuss with you. One big question is the clean up on the
property. Since our last visit over the summer, IAC is actively cleaning up their property. All the land around the
buildings look like it has been freshly bulldozed. Look like bare clay. We saw them loading tractor trailer hauling trucks
owned by Tara Group. Several questions —
Can this material be dumped in Mine Site (Buie Land, Tara Group, etc)?
If not, then it needed to be taken to a landfill. If that is the case, which one of our Environmental groups investigates
where they took the materials? Do they have receipts for the dumping on the morning of 4/16? Clearly this is not an
Air Quality issue, but it seems like a DENR issue. We have had too many DENR inspects get shuffled around by this
company. Hopefully they are cleaning up for the better good, but based on their history, is the material being properly
handled?
Another question might also be who monitors the water around this site?
I hope we can talk this over on Monday morning. Please give me a call when you get this message.
Steven Vozzo, Regional Air Quality Supervisor
Fayetteville Regional Office - NC DENR Division of Air Quality
225 Green Street, Suite 714, Fayetteville NC 28301-5095
910-433-3361 phone [phone] fax
www. ncair. org
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law
and may be disclosed to third parties.
Before printing this email, please consider your budget and the environment.
If you must print, please print only what you need and use color inks only when needed.
Thank you for helping NC DENR be environmentally responsible.

ConnectGIS Page 1 of 1
IM-1
http://www. gis.co.robeson.nc.usIConnectGIS Webl(S(oyzeOh550yfg 1 xydxr4fhted))IMap/... 11 /25/2009

prism labs, charlotte, nc - Google Maps
Page 1 of 1
CSC Sle maps prism labs, near Charlotte, NC
A. Prism Laboratories Inc
449 Springbrook Rd, Charlotte, NC -
704)529-6364
Get Google Maps on your phone
0
Text the word "GMAPS" to 466453
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http://maps.google.comlmaps?f=q&source=s_q&hl=en&geocode=&q=prism+labs,+charl... 11 /23/2009

Industrial and Agri Chem., Inc
Red Springs, NC �. 2 7

tY i
+gam,}3.'"'•4T �+^Y M
Full Somice Analytical& Environmental Solutions
NCDENR DWQ APS Mooresville Reg.
Ellen Huffman
610 E. Center Avenue
Mooresville, 'NC 28115-2578
Customer Number:
Invoice for Laboratory Services
Invoice Number: 49842
Invoice Date: 11/30/09.
Project ID: WQ0016338
Project Name: Robeson County
Project No.:
Project Mgr: Ellen Huffman
P.O. No.`
Sales Code: HOUSE
The following charges are due for the indicated sample(s) received by this laboratory on Nov 24, 2009
Lab Sample ID.: 264468 264469 264470
COC group Number G1109676
Unit
Matrix Description Method Priority Price Qty. Total
Solid pH Value, Electrometric Method 9045C 1 Day $22.00 3 $6600
Sample Processing and'Disposal Fee 1 Day $2.00 1 $2.00
Invoice Total: $68.00
We Appreciate Your Business.
Payment Terms: Net 10 Days
Remit payment to.: Prism Laboratories, Inc. WE ACCEPT MASTERCARD AND VISA
P.O. Box 240543 ACCT.#—-----,.�---
Charlotte, N.C. 28224-0543 EXP. DATE:
NAME ON CARD: ^_
SIGNATURE:
449 Springbrook Road - P.O. Box240543- Charlotte, NC 28224-0543
Phone: [phone] Toll Free Number: 1-800/529-6364 Fax: [phone]
Page 1 of 1

.1 ?
PRISM
LABORATORIES,INO.
Date: 11/25/09
Company: NCDENR DWQ APS Mooresville Reg.
Contact: Ellen Huffman
Address: 610 E. Center Avenue
Mooresville, NC 28115-2578
Case Narrative
ol of /w V o
Client Project ID: _" WQ001_6338
Prism COC Group No: G1109676
Collection Date(s): 11/24/09
Lab Submittal Date(s): 11/24/09 -`
Client Project Name Or No: Robeson County
This data package contains the analytical results for the project identified above and includes a Case Narrative, Laboratory Report and Quality
Control Data totaling 5 pages. A chain -of -custody is also attached for the samples submitted to Prism for this project.
Data qualifiers are flagged individually on each sample. A key reference for the data qualifiers appears at the end of this case narrative. Quality
control statements and/or sample specific remarks are included in the sample comments section of the laboratory report for each sample
affected.
Semi Volatile Analysis
N/A
Volatile Analysis
N/A
Metals Analysis
N/A
Wet Lab and Micro Analysis
No Anomalies Reported
Please call if you have any questions relating to this analytical report.
Data Reviewed by: Robbi A. Jones Project Manager:
Signature: Signature:
Review Date: 11/25/09 Approval Date:
Data Qualifiers Key Reference:
B: Compound also detected in the method blank.
#: Result outside of the QC limits.
DO: Compound diluted out.
E: Estimated concentration, calibration range exceeded,
J: The analyte was positively identified but the value is estimated below the reporting limit.
H: Estimated concentration with a high bias,
L: Estimated concentration with a low bias.
M: A matrix effect is present.
Robbi A. Jones
11 /25/09
Notes: This report should not be reproduced, except in its entirety, without the writtten consent of Prism Laboratories, Inc. The results in this
report relate only to the samples submitted for analysis.
449 Springbrook Road, P.O. Box 240543, Charlotte NC 28224-0403
Phone: [phone] Toll Free: 8001529.6364 Fax: [phone]

NC Certification No. 402
SC Certification No. 99012
NC Drinking Water Cert. No. 37735
Full Service Malytlml S Environmental Solutions
NCDENR DWQ APS Mooresville Reg. Project Name: Robeson County
Attn: Ellen Huffman Project ID: WQ0016338
610 E. Center Avenue Sample Matrix: Solid
Mooresville, NC 28115-2578
Laboratory Report
11 /25109
Client Sample ID:
ROB-1
Prism Sample ID:
264468
COC Group:
G1109676
Time Collected:
11/24/09 10:35
Time Submitted:
11/24/09 15:10
Parameter Result Units Report MDL Dilution Method
Limit Factor
PH Value, Electrometric Method
pH 3.22 pH units 1 9045C
Analysis Analyst Batch
Date/Time ID
11/24/09 17:07 mtye Q46182
Sample Comment(s):
BRL = Below Reporting Limit
Values are reported down to the reporting limits only. No J-flags applied.
The results in this report relate only to the samples submitted for analysis and meet state certification requirements other than
NELAC certification except for those instances indicated in the case narrative and/or test comments.
All results are reported on a wet -weight basis
Angela D. Overcash, V.P. Laboratory Services
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number: 1-800/529-6364 - Fax: [phone] Page 1 Of 3

NC Certification No. 402
SC Certification No. 99012
f
NC Drinking Water Cart. No. 37735
Full Service Analytical & Environmental Solutions
NCDENR DWQ APS Mooresville Reg. Project Name: Robeson County
Attn: Ellen Huffman
Project ID: WQ0016338
610 E. Center Avenue
Sample Matrix: Solid
Mooresville, NC 28115-2578
Laboratory Report
11 /25109
Client Sample ID:
ROB-2
Prism Sample ID:
264469
COC Group:
G1109676
Time Collected:
11/24/09 10:36
Time Submitted:
11/24/09 15:10
Parameter Result Units Report MDL Dilution Method Analysis Analyst Batch
Limit Factor Date/Time ID
pH Value, Electrometric Method
pH 2.82 pH units
1 9045C 11/24/09 17:08 mtye Q46182
Sample Comment(s):
BRL = Below Reporting Limit
Values are reported down to the reporting limits only. No J-flags applied.
The results in this report relate only to the samples submitted for analysis and meet state certification requirements other than
NELAC certification except for those instances indicated in the case narrative andlor test comments.
All results are reported on a wet -weight basis
Angela D. Overcash, V.P. Laboratory Services
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number: 1-800/529-6364 - Fax: [phone]
Page 2 of 3

j 3 NC Certification No. 402
a SC Certification No. 99012
NC Drinking Water Cert. No. 37735
Full Service Analytical & Environmental Solutions
NCDENR DWQ APS Mooresville Reg. Project Name: Robeson County
Attn: Ellen Huffman Project ID: W00016338
610 E. Center Avenue Sample Matrix: Solid
Mooresville, NC 28115-2578
Laboratory Report
11/25/09
Client Sample ID:
ROB-3
Prism Sample ID:
264470
COC Group:
G1109676
Time Collected:
11/24/09 11:05
Time Submitted:
11/24/09 15:10
Parameter Result Units Report MDL Dilution Method Analysis Analyst Batch
Limit Factor Date/Time ID
pH Value, Electrometric Method
pH 10.92 pH units
1 9045C 11/24/09 17:09 mtye Q46182
Sample Comment(s):
BRL = Below Reporting Limit
Values are reported down to the reporting limits only. No J-flags applied.
The results in this report relate only to the samples submitted for analysis and meet state certification requirements other than
NELAC certification except for those instances indicated in the case narrative and/or test comments.
All results are reported on a wet -weight basis
Angela D. Overcash, V.P. Laboratory Services
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number: 1-800/529-6364 - Fax: [phone] Page 3 of 3

NC Certification No. 402
SC Certification No. 99012
° NC Drinking Water Cert. No. 37735
Full Service Anaiytical 3 Environmental Solutions
NCDENR DWQ APS Mooresville Reg. Project Robeson County
Attn: Ellen Huffman Name:
610 E. Center Avenue Project ID: WQ0016338
Mooresville, NC 28115-2578
PH Value, Electrometric Method, method 9045C
Level 11 QC Report
11 /25/09
COC Group Number: G1109676
Date/Time Submitted: 11/24/09 15:10
Laboratory Control Sample
Recovery
Recovery
Qc Batch
Result
Spike Amount
Units
Ranges
ID
pH
6.86
6.86
pH units 100
99,21-100.7
046182
Duplicate
Sample
Duplicate
RPD
RPD
Range
QC Batch
Sample ID:
Result
Result
Units
%
%
—ID
264470 pH
10.92
10.88
pH units
0
0 - 20
Q46182
#-See Case Narrative
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number: 1-8001529-6364 - Fax: [phone]
Page 1 of 1

li
Full Service Analytical & Environmental Solutions
449 Springbrook Road • P.O. Box 240543 • Charlotte, NO 28224.0543
Phone:[phone] Fax:[phone]
Client Company Name: NC DENR DWQ APS Mooresville rag.
Report To/Contact Name: E.Huffman
Reporting Address: 610 E. Center Avenue. Mooresville, NC
CHAIN OF CUSTODY RECORD
PAGE _ OF_ QUOTE X TO ENSURE PROPER BILLING:
Project Name: WQ0016338
Short Hold Analysis:.. (Yes) (No) UST Project (Yes) (No)
"Please ATTACH any project specific reporting (QC LEVEL 1.11111 IV)
provisions and/or QC Requirements
Invoice To:
Address:
Phone: [phone] . Fax (Yes) (No): [phone]
[e-mail] Purchase Order NoJBilling Reference
Email (YXS) (No) Email Address Requested Due Date 1 Day 2 Days . 3 Days 4 Days 5 Days. .
q Y Y Y
-
TO BE FILLED IN BY CLIENT/SAMPLING PERSONNEL
Certification: NELAC USACE FL NC
EDD Type:_PDF_ Excel— Other "Working Days" : 6-9 Days standard 10 days
Robeson County
Site Location Name: Samples received after 15:00 will be processed next business day.
Site Location Physical Address: Turnaround time is based on business days, excluding weekends and holidays.
.. (SEE REVERSE FOR TERMS & CONDITIONS REGARDING SERVICES
RENDERED BY PRISM LABORATORIES, INC. TO CLIENT)'
SC OTHER N/A
Water Chlorinated: YES_ NO_
Sample Iced Upon Collection: YES NO
TIME
MATRIX
SAMPLECONTAINER
ANALYSES REQUESTED
PRISM
CLIENT
SAMPLE DESCRIPTION
DATE
COLLECTED
COLLECTED
MILITARY
HOURS
(SOIL,.
WATER OR
SLUDGE)
PRESERVA-
JIVES
REMARKS
a
LAB
ID NO.
'TYPE
SEE BELOW
.. NO.
SIZE
R013-1
11/24/2009
v `3S
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G
1
none
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ROB-2
11/24/2009
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11/24/2009
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Sampler's Signature Sampled By (Print Name) Ellen Huffman Affiliation NC DENR DWQ APS
Upon relinquishing, this Chain of bust s your authorization for Prism to proceed with the analyses as requested above. Any changes must be eWM
submitted in writing to the Prism Project Manager. There will be charges for any changes after analyses have been initialized.
Relinquished By: i at Rece ved By: Signature) Date M IltaryMours Additional Comments:.��F,4StQ4+t'aaY
Relinquished By S u Received By: (Signature) Date -. r1q fy disi$L.
Relinquished By: (Signature) Received For Prism La boratodes By: Date
Z1.k�1+."".�tW�£:
Method of Shipment: NOTE: ALL SAMP E COOLERS SHOULD BE TAPED HUT WITH CUSTODY SEALS Fuji TRANSPORTATION TO THE LABORATOR . Log -In Group No.
SAMPLES ARE NOT ACCEPTED AND VERIFIED AGAINST COO UNTIL RECEIVED AT THE LABORATORY. t
Fed Ex UPS X Hand -delivered Prism Field Service Other
NPDES: UST: GROUNDWATER: DRINKING WATER: SOLID WASTE: RCRA: CERCLA LANDFILL OTHER:
_NC _SCI NO _SCI _NC —SO I =NC _SC _NC _SC I _NC _SC _NC _SC NO _SCI Nm�3BSO
ORIGINAL
*CONTAINER TYPE COD St A = Amber C = Clear G = Glass P = Plastic; TL = Teflon -Lined Cap VOA = Volatile Organics Analysis (Zero Head Space)

` t^��-f�1A80liATORIES INC �
Full Service Analytical & Environmental Solutions
449 Springbrook Road • P.O. Box 240543 a Charlotte, NC 28224-0543
Phone:[phone] • Fax.[phone]
Client Company Name: NC DENR DWQ APS Mooresville reg.
Report To/Contact Name: E.Huffman
Reporting Address' 110 E. Cenler Avenue, Mooresville, NC
CHAIN OF CUSTODY RECORD
PAGE _ OF— QUOTE $ TO ENSURE PROPER BILLING:
Project Name: WQ0016338
Short Hold Analysis: (Yes) (No) UST Project: (Yes) (No)
*Please ATTACH any project specific reporting (QC LEVEL 111 III IV)
provisions and/or QC Requirements
Invoice To:
Address:
Phone: kf j......y Fax (Yes) (No): I—'0 _0u4u
Purchase Order No./Billing Reference
TO BE FILLED IN BY CLIENT/SAMPLING PERSONNEL
Email (Yxs) (No) Email Address [e-mail]
Requested Due Date 1 Day 2 Days 3 Days 4 Days 5 Days
Certification: NELAC USACE FL NC
EDD Type:_PDF ExcelOther "Working Days" ... 6-9 Days Standard 10 days
Site Location Name: Robeson county
Samples received after 15:00 will be processed next business day.
SC OTHER N/A
Site Location Physical Address- Turnaround time is based on business days, excluding weekends and holidays.
Water Chlorinated: YES— NO —
(SEE REVERSE FOR TERMS & CONDITIONS REGARDING SERVICES
Sample Iced Upon Collection: YES NO
p
RENDERED BY PRISM LABORATORIES, INC. TO CLIENT)-
—
TIME
MATRIX
SAMPLE CONTAINER
ANALYSES REQUESTED
PRISM
CLIENT
DATE
COLLECTED
(SOIL,
PRESERVA-
LAB
`TYPE
SAMPLE DESCRIPTION
COLLECTED
MILITARY
WATER OR
JIVES
REMARKS
HOURS
SLUDGE)
SEE BELOW
NO.
SIZE
t1
ID NO.
R013-1
11/24/2009
��
Soil
G
1
none
R013-2
11/24/2009
�' ' Jd (
Soil
G
2
none
✓
ab4yb
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11/24/2009
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G
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Ellen Huffman NC DENR DWQ APS
Sampler's Signature Sampled By (Print Name) Affiliation
Upon relinquishing, this Chain of Gust Is your authorization for Prism to proceed with the analyses as requested above. Any changes must be
submitted in writing to the Prism Project Manager. There will be charges for any changes after analyses have been initialized.
Relinquished By: Si at ) \ Received By: (Signature) Date Military/Hours Additional Comments: Slfe Arriva171me'�"` '
tj
Jl
Relinquished By(ftpiruW J Received By: (Signature) Data ,SIIe�1;ep�rtuCe Tlme u g
Field Tech Fep r k {
Relinquished By: (Signature) Received For Prism Laboratories By: Date ,
S,
Method of Shipment: NOTE: ALL SAMPLE COOLERS SHOULD BE TAPED SHUT WITH CUSTODY SEALS FOR TRANSPORTATION TO THE LABORATORY. Log -In Group No.
SAMPLES ARE NOT ACCEPTED AND VERIFIED AGAINST COC UNTIL RECEIVED AT THE LABORATORY.
Fed Ex UPS Hand-dellverd ePrismField Service Other JI091af)
NPDES: UST: GROUNDWATER: DRINKING WATER: SOLID WASTE: RCRA: CERCLA LANDFILL OTHER: '
r
NC _SC NC _SC _NC _SC _NC _SC _NC _SC _NC _SC _NC _SCI _NC _SC ANC _SC
_ _—001038 (IOIr�1Al Al
*CONTAINER TYPE CODES: A = Amber C = Clear G = Glass P = Plastic; TL = Teflon -Lined Cap VOA = Volatile Organics Analysis (Zero Head Space)

2042 Buie philadelphus Rd, Red Springs, NC - Google Maps
Page 1 of 1
Address 2042 Buie - Philadelphus Rd Get Google Maps on your phone
t,00sle-maps Red Springs, NC 28377
Text the word "GMAPS"to466453
http://maps. google.comlmaps?hl=en&q=2042+Buie+philadelphus+Rd,+Red+Springs,+N... 11 /20/2009

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7 Or-
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PFJSM
LABORATORMS.M.
Date: 11/25/09
Company: NCDENR DWQ APS Mooresville Reg,
Contact: Ellen Huffman
Address: 610 E. Center Avenue
Mooresville, NC 28115-2578
Client Project ID:
Prism COC Group No:
Collection Date(s):
Lab Submittal Date(s):
Client Project Name Or No:
Case Narrative
WQ0016338
G1109676
11/24/09
11/24/09
Robeson County
This data package contains the analytical results for the project identified above and includes a Case Narrative, Laboratory Report and Quality
Control Data totaling 5 pages. A chain -of -custody is also attached for the samples submitted to Prism for this project.
Data qualifiers are flagged individually on each sample. A key reference for the data qualifiers appears at the end of this case narrative. Quality
control statements and/or sample specific remarks are included in the sample comments section of the laboratory report for each sample
affected.
Semi Volatile Analysis
N/A
Volatile Analysis
N/A
Metals Analysis
N/A
Wet Lab and Micro Analysis
No Anomalies Reported
Please call if you have any questions relating to this analytical report,
Data Reviewed by: Robbi A. Jones Project Manager:
Signature: Signature:
Review Date: 11/25/09 Approval Date:
Data Qualifiers Key Reference:
B: Compound also detected in the method blank.
#: Result outside of the QC limits.
DO: Compound diluted out.
E: Estimated concentration, calibration range exceeded.
J: The analyte was positively identified but the value is estimated below the reporting limit.
H: Estimated concentration with a high bias.
L: Estimated concentration with a low bias.
M: A matrix effect is present.
Robbi A. Jones
11/25/09
Notes: This report should not be reproduced, except in its entirety, without the writtten consent of Prism Laboratories, Inc. The results in this
report relate only to the samples submitted for analysis.
449 Springbrook Road, P.O. Box 240543, Charlotte NC 28224-0403
Phone: [phone] Toll Free: 800/529-6364 Fax: [phone]

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prism labs, charlotte, nc - Google Maps
ooq e maps prism labs, near Charlotte, NC
A. Prism Laboratories Inc
449 Springbrook Rd, Charlotte, NC -
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Page 1 of 1
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� 1Il\II
1
ALCHEM response review notes-E.H.
August 2009-November-24, 2009
Issues sited in NOV/NOI June 2, 2009 and summary of ALCHEM response: -
1 . Lagoon #3 has not been cleaned out and the liner has not been inspected as per the
November 27, 2007 Settlement Agreement finish date of June 1, 2008.
Response review: ALCHEM stated that lagoon #3 is 50% cleaned out. Photos from the
most recent inspection show piles of sand still in lagoon # 3. If ALCHEM has done any
spent sand removal, they have not submitted documentation to where any of the
residuals leaving the facility for disposal have gone. ALCHEM has known the
importance of documenting where the spent bauxite goes as stated in the response
dated March 24, 2008 to the NOV issued Feb.21, 2008.
2. An annual report for 2008 for permit WQ0016338 was due on March 1, 2009, and has
not been received by the division as required by Part III, condition 7.
Response review: The 2008 Annual Report was submitted for WQ0016338 as a part of
the NOV response. The report does not include the data required by the permit.
Specifically:
• No spent bauxite residual analyses for metals as required in 111.3 .
• No TCLP analyses as required in 111.4.
• No records submitted for 111.6 a - dated freeboard measurements,
• 111.6d — cumulative volume of residuals in gallons or cu. yds. excluding freeboard
(lagoon),
• 111.6e — remaining volume in the surface disposal unit in gallons or cubic yards
excluding freeboard, and 111.6f - remaining disposal life in disposal unit in years
(lagoon).
• Hauling records of spent bauxite for off -site disposal as required by Wg0016338
111.2b.
3. The log that contains pH readings of the water in the lagoons was not available for
review at the time of the inspection. This information was not received by fax as
promised. (WQ0002702 permit condition 13).
Response review: An inspection report for Lagoons 1 & 2 submitted by DELTA for
ALCHEM reported Lagoon #land #2 being totally cleaned out and the liners tested on
June 10, 2008. Production records indicate lagoon #1 being used starting June 20,
2008. There were no pH read ings'submitted for all the spent sand from production
batches sent to lagoon #1 for June, July, August, September, or October (95 batches of
spent bauxite), however, lagoon pH readings for lagoon #1 for the same period reflect
pH readings of 3.40, 3.42, 3.41, 3.44, 3.45, 3.42, 3.45.
This indicates that the pH of the spent bauxite after production was not being adjusted
to 6.0 S.U. prior to the spent bauxite being sent to lagoon #1 after cleanout. The 2008
annual report submitted indicated daily batches being processed and only weekly ph
data being taken. Several months of production, May 28, 2008 through October 21,
2008, had no pH readings at all. Report indicates 95 batches @ 20 tons each,
produced with no pH readings.
4. A permit renewal was due in May 2009.
Alchem's response stated that a renewal would be submitted to the RMO by August 6,
2009. This office as well as Central Office, has not received anything from ALCHEM
regarding the renewal of permit WQ0002702.

The above response was due June 12, 2009. Response was received August 4, 2009.
The Addendum to the NOV/NOI dated July 23, 2009 added:
4. Permit WQ 0002702, Condition 10 requires that freeboard in all lagoons shall not be
less than two feet at any time. Lagoon #3 does not have adequate freeboard in that
bauxite residuals have exceeded capacity and are piled several feet above the elevation
of the lagoon walls. This violation continues to exist because the lagoon has not been
cleaned out and the liner inspected as per the November 27, 2007 Settlement
Agreement completion date of June 1, 2008.
Response was due August 6, 2009. Response received August 4, 2009.
Response review: Freeboard response to MRO is not factual. Response indicated that clean -
out activity for lagoon #3 as 50% completed and currently, has 6 feet of freeboard vertically and
40 feet horizontally and that this has not changed since June of 2008. The 2008 annual report
indicates that Lagoon #3 has been used for production disposal of sand in March, April, May,
and June of 2008. File indicates records of 14 loads (22.5 tons each) documented sent to IAC
in January 2008. There is no documentation for disposal of sand for the Feb. -June 2008 time
period, as required by the Nov. 2007 settlement agreement.
File photo lagoon #3 April 2009
The records received' for lagoon pH and temp readings (Peggy Finley) reported readings of
samples identified as R/R acid and R/R bauxite and in some cases, sand. Staff is unsure what
these readings are for. Records submitted date back to February 2007. The intervals of pH
readings vary from month to month. There are no records for All of January 2008 and only 1
week documented for February 2008.
September 25, 2009 — a report for lagoon liner testing was received. No records of spent
bauxite hauling were submitted with this report. In the report the engineer remarks state that
only the work requested by the client is contained in the report.

Metalplate Galvanizing, L.P.
INDUSTRIAL & AGRICULTURAL
CHEMICALS, INC.
2042 HUIE PHILADELPHUS ROAD
RED SPRINGS NC 29277
Metalplate Galvanizing, L.P.
P.O. Box 43402
505 Selig Drive, S.W.
Atlanta, GA. 30336
[phone] FAX: [phone]
Remlt To:
Metalplate Galvanizing, L.P.
P.O. BOX 1463
Birmingham, AL 35201-1463
INVOICE
N0. 3-100498
/INDUSTRIAL &.AGRICULTURAL
/CHEMICALS, INC. ;
2042 HUIE PHILADELPHUS ROAD
t� RED SPRINGS NC 28377
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19 SUPER SACKS SULFATE CRYSTALS 40,502 1.25
TOTAL WEIGHT 40,502 -
TOTAL MATERIALS
TOTAL DUE
j
506.27
506 27
506.27
Terms and Conditions on reverse side apply to all sales.
ORIGINAL INVOICE
9379

This M�mo1'andum is an ackhorviedgment that a Bill of Lading has been Issued and is not Origins( Shipper No.
BIN of Lading, nor a copy or duplicate. covering the property named herein, and is / \
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CARRIER
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Metalplate Galvanizing, L.P.
INDUSTRIAL & AGRICULTURAL
• CHEMICALS, INC.
2042 BUIE PHILADELPHUS ROAD
RED SPRINGS NC 28377
Metalplate Galvanizing, L.P. INVOICE
P.O. Box 43402
505 Selig Drive, S.W.
Atlanta, .GA. 30336 No. 3-101066
[phone] FAX: [phone]
Remit To:
Metalplate Galvanizing, L.P.
P.O. BOX 1463
Birmingham, AL 35201-1463
1/1 1NDUSTRIAL & AGRICULTURAL
` CHEMICALS, INC. y
j 204E BUIE PHILADELPHUS ROAD
RED SPRINGS NC 283®7s7'
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Data of Invoice
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TOTAL WEIGHT 40,351
TOTAL MATERIALS
ENERGY/ENVIRONMENTAL SURCHARGE
TOTAL DUE
504.3E
30.26
534.64
Redd Terms and Conditions on reverse side apply to all sales.
By
rn.,,_ ORIMMAI INVOIr:F 9382:

Is an acknowledgment that a Bill of lading has been issued and Is not Original Shipper No.
This Memorandum
Bill o1 Lading, nor a copy or duplicate, covering the property named hereln, and is
intended solely for filing or record. O�f� k / camer No.
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%spent --�auxite
Subject: Re: spent bauxite
From E Lee Bray <[e-mail]>
Date: Mon, 25 Jun 2007 12:05:43 -0400
To: Ellen Huffman <[e-mail]>
Hi Ellen,
I've checked through my files on waste products from spent bauxite. There has been a lot of research on
disposal methods other than landfilling the spent bauxite, but there is always more of the material than
practical uses so lots ends up in landfills near the processing plants. Some uses I found include making
bricks and cement. Road base material is also a use that has been explored. If the material is neutralized
and does not contain excessive leachable toxic metals, these uses are practical in some instances. The
problem is that they are only substitutes for commonly available materials that are not very expensive in
most places, so transporting the spent bauxite over great distances makes it economically unfeasible
compared to other materials that are available locally. As a result, most of the spent bauxite is only used
for these purposes near the processing plants.
I'm afraid that is all I can come up for you.
.............................................
E. Lee Bray
Aluminum Commodity Specialist
US Geological Survey
Minerals Information Team
989 National Center
Reston, VA 20192
phone [phone]
Fax [phone]
e-mail ([e-mail]
Ellen Huffman <[e-mail]> To ([e-mail]
cc
06/22/2007 04:33 PM
Subject spent bauxite
Hello Lee,
Ellen (in NC) here. I am looking for information regarding beneficial
end uses for spent bauxite from the process of manufacturing ALUM (for
water treatment). I have heard of using it as filler for fertilizer
manufacturing, as well as in cement mixing process. Any information is
greatly appreciated. Thank you.
Sincerely,
Ellen in NC
Ellen Huffman
Environmental Specialist II
North Carolina Dept. of Environment & Natural Resources
1 of 2 6/25/2007 1:41 PM

f
Page 1 of 3
BAUXITE AND ALUMINAI/
(Data in thousand metric dry tons, unless noted)
Domestic Production and Use: In 1995, three companies operated surface bauxite mines
in Alabama and Georgia. Virtually all domestic ore was consumed in the production of
nonmetallurgical products, such as abrasives, chemicals, proppants, and refractories.
Approximately 95% of the total bauxite consumed in the United States during 1995 was
converted to alumina. Primary aluminum smelters received approximately 90% of the
alumina supply. Annual alumina capacity was 5.6 million tons, with four Bayer
refineries in operation at yearend.
Salient Statistics --United States:2/
1991
1992
1993
1994
1995e/
Production, bauxite, mine
W
W
W
W
W
Imports of bauxite for consumption3/
12,300
11,400
11,900
11,200
10,000
Imports of alumina4/
4,590
4,700
3,940
3,120
3,900
Exports of bauxite3/
58
68
92
137
130
Exports of alumina4/
1,350
1,140
1,240
1,040
650
Shipments of bauxite from Government
stockpile excesses
--
437
565
5
150
Consumption, apparent, bauxite and alumina
(in aluminum equivalents)5/
4,610
4,860
4,510
3,840
4,000
Price, bauxite, dollars per ton,
f.o.b. mine
15-18
15-18
15-24
15-24
15-18
Stocks, bauxite, industry, yearend
2,600
2,300
1,600
1,600
1,000
Employment, bauxite mine
35
35
35
35
20
Net import reliance,6/ bauxite and alumina
as a percent of apparent consumption
100
100
100
99
99
Recycling: None.
Import Sources (1991-94):7/ Bauxite: Guinea, 34%; Jamaica, 30%; Brazil, 14%; Guyana,
13%; and other, 9%. Alumina: Australia, 73%; Jamaica, 10%; Suriname, 6%; and other,
11%. Total: Australia, 33%; Jamaica, 21%; Guinea, 19%; Brazil, 9%; and other, 18%.
Tariff: Import duties on bauxite and alumina were abolished in 1971 by Public Law
92-151. Only imports from non -most -favored nations were dutiable. Countries that
supplied commercial quantities of bauxite or alumina to the United States during the
first 8 months of 1995 had most -favored -nation status.
Depletion Allowance: 22% (Domestic), 14% (Foreign).
Government Stockpile:
Stockpile Status--9-30-95
Uncommitted
Committed
Authorized
Disposals
Material
inventory
inventory
for disposal
Jan. -Sept. 95
Bauxite, metal grade:
Jamaica -type
11,100
739
10,900
8/ 610
Suriname -type
4,980
--
4,980
--
Bauxite, refractory -
grade, calcined
208
21
146
9/ 11
Events, Trends, and Issues: World output of bauxite and alumina for 1995 increased
to accommodate the increase in world primary aluminum metal production.
U.S. alumina plant engineered capacity remained essentially unchanged from that of
yearend 1994. However, capacity utilization decreased as a result of the temporary
closure of a 635,000-ton-per-year alumina plant in St. Croix, VI.
Prepared by Patricia A. Plunkert, [phone].
BAUXITE AND ALUMINA
http://minerals.usgs.gov/minerals/pubs/mcs/1996/bauxite.txt 6/22/2007

Page 2 of 3
Spot prices for metallurgical -grade alumina, as published by Metal Bulletin,
increased dramatically during the first three quarters of 1995. The price range
began the year at $127 to $130 per ton. By the end of September, the price range had
increased to $320 to $340 per ton. In early October, the price had decreased
slightly to a range of $290 to $310 per ton.
The fiscal year 1996 Annual Materials Plan (AMP) submitted by the Defense National
Stockpile Center proposed the sale of 915,000 dry metric tons of metallurgical -grade
bauxite (610,000 tons of Jamaican -type and 305,000 tons of Suriname -type) during the
period October 1, 1995 to September 30, 1996. In addition, the FY 1996 AMP provided
for the sale of 81,000 calcined metric tons of refractory -grade bauxite from the
National Defense Stockpile. These are the maximum amounts that could be sold under
the new AMP and not necessarily the amounts that would actually be offered for sale.
World Bauxite Mine Production, Reserves, and Reserve Base:
Mine
production
Reservesl0/
Reserve basel0/
1994
1995e/
United States
W
W
20,000
40,000
Australia
41,700
42,700
5,600,000
7,900,000
Brazil
8,120
8,500
2,800,000
2,900,000
Greece
1,600
1,600
600,000
650,000
Guinea
14,400
14,500
5,600,000
5,900,000
Guyana
2,100
2,100
700,000
900,000
Hungary
900
900
300,000
300,000
India
5,400
5,500
1,000,000
1,200,000
Jamaica
11,700
12,000
2,000,000
2,000,000
Suriname
3,440
3,400
580,000
600,000
Venezuela
4,790
5,000
320,000
350,000
Other countries
12,700
12,400
3,500,000
5,100,000
World total (rounded)
ll/ 107,000
ll/ 109,000
23,000,000
28,000,000
World Resources: Bauxite resources are estimated to be 55 to 75 billion tons, in
South America (33%), Africa (27%), Asia (17%), Oceania (13%), and elsewhere (10%).
Domestic resources of bauxite are inadequate to meet long-term demand, but the United
States and most other major aluminum -producing countries have essentially
inexhaustible subeconomic resources of aluminum in materials other than bauxite.
Substitutes: Bauxite is the only raw material used in the production of alumina on a
commercial scale in the United States. However, the vast U.S. resources of clay are
technically feasible sources of alumina. Other domestic raw materials, such as
anorthosite, alunite, coal wastes, and oil shales, offer additional potential alumina
sources. Although it would require new plants using new technology, alumina from
these nonbauxitic materials could satisfy the demand for primary metal, refractories,
aluminum chemicals, and abrasives. Synthetic mullite, produced from kyanite and
sillimanite, substitutes for bauxite -based refractories. Although more costly,
silicon carbide and alumina-zirconia substitute for bauxite -based abrasives.
e/Estimated. W Withheld to avoid disclosing company proprietary data.
1/See also Aluminum. As a general rule, 4 tons of bauxite are required to produce 2
tons of alumina, which, in turn, provide 1 ton of primary aluminum metal.
2/Includes U.S. Virgin Islands.
3/Includes all forms of bauxite, expressed as dry equivalent weights.
4/Calcined equivalent weights.
5/The sum of U.S. bauxite production and net import reliance (all in aluminum
equivalents).
6/Defined as imports - exports + adjustments for Government and industry stock changes
(all in aluminum equivalents).
7/Aluminum equivalents.
8/Sold under long-term contract commenced in 1993.
9/Dry equivalent weight--16,500 metric tons.
10/See Appendix C for definitions.
http://minerals.usgs.gov/minerals/pubs/mcs/1996/bauxite.txt 6/22/2007

Page 3 of 3
11/Excludes U.S. production.
Mineral Commodity Summaries, January 1996
http://minerals.usgs.gov/minerals/pubs/mes/1996/bauxite.txt 6/22/2007

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What Is Urea Formaldehyde? Page 1 of 2
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t Process
Page 1 of 5
nril-
Galvanizing
�s
� M1e
Cleveland, Ohio p
{Home} (Con anj mgor },I JDesiQn jLjbdcatio>�.J {Process)
Galvanizin for Corrosion Protection
,Process
,Plot dip galvanizing is the process of applying a zinc coating to fabricated iron or steel material by
immersing the material in a bath consisting primarily of molten zinc.
The process is described in more detail below, but the process is inherently simple. The simplicity of
the galvanizing process is a distinct advantage over other methods of corrosion protection.
History Of Galvan I
The recorded history of galvanizing goes brick to 1742 when a French chemist named Melouin, in a
presentation to the French Royal Academy, described a method of coating iron by dipping it in molten
zinc. In 1836, Sorel, another French chemist, obtained a patent for a means of coating iron with zinc
after.first cleaning it with 9% sulfuric acid and fluxing it with ammonium chloride. A British patent_for
a similar process was granted in 1837. By 1850, the British galvanizing industry was using 10,000 tons
of zinc a year for the protection of steel.
Galvanizing is found in almost every major application and industry where iron or mild steel is used.
The utilities, chemical process, pulp and paper, automotive, and transportation industries, to name just
a few, historically have made extensive use of galvanizing for corrosion control. They continue to do so
today.
For over 150 years, galvanizing has had a proven history of commercial successas a method of'
corrosion protection in myriad applications worldwide.
(LOP)_
http://www.artgalvanizing.com/Process.htm 4/23/2010

Process
Page 2 of 5
Click to Enlarge
Iron and Steel Protection Methods
Barrier protection is perhaps the oldest and most widely used method of corrosion protection. It acts
by isolating the metal from the electrolytes in the environment. Two important properties of barrier
protection are adhesion to the base metal and abrasion resistance. Paint is one example of a barrier
protection system.
Cathodic protection is an equally important method for preventing corrosion. Cathodic protection
requires changing an element of the corrosion circuit, introducing a new corrosion element, and
ensuring that the base metal becomes the cathodic element of the circuit.
Hot dip galvanizing provides excellent barrier protection as well as cathodic protection.
There are two major variations of the cathodic method of corrosion protection. The first is called the
impressed current method. In this method an external current source is used to impress a cathodic
charge on all the iron or steel to be protected. While such systems generally do not use a great deal of
electricity, they often are very expensive to install.
The other form of cathodic protection is called the sacrificial anode method in which a metal or alloy
that is anodic to the metal to be protected is placed in the circuit and becomes the anode. The protected
metal becomes the cathode and does not corrode. The anode corrodes, thereby providing the desired
sacrificial protection. In nearly all electrolytes encountered in everyday use, zinc is anodic to iron and
steel. Thus, the galvanized coating provides cathodic corrosion protection as well as barrier protection.
(Told
Click to Enlarge
G lvacnzziaZ Process
The galvanizing process consists of three basic elements:
http://www.artgalvanizing.com/Process.htm 4/23/2010

Process
Page 3 of 5
. Sui face Preparation
Galvanizing
. Inspection
Surface preparation is the most important step in the application of any coating. In most instances
where a coating fails before the end of its expected service life, it is due to incorrect or inadequate
surface preparation.
The surface preparation step in the galvanizing process has its own built-in means of quality control
in that zinc simply will not react with a steel surface that is not perfectly clean. Any failures or
inadequacies in surface preparation will be immediately apparent when the steel is withdrawn from the
molten zinc because the unclean areas will remain uncoated. Immediate corrective action is taken.
On -site painting or other field -applied systems of corrosion protection may involve the use of
different subcontractors and/or work groups to prepare the surface and apply the coating. This can
result in problems in coordinating activities, leading to costly and time-consuming delays, errors, and
disputes concerning. responsibility and financial liability. Once a•job has been delivered`and accepted at
the galvanizer's plant, there is one point of responsibility for ensuring that the material leaves the plant
properly galvanized. That point of responsibility is the galvanizer.
Surface preparation for galvanizing typically consists of three steps: caustic cleaning, acid pickling,
and fluxing.
Caustic Cleaning - A hot alkali solution often is used to remove organic contaminants such as dirt,
paint markings, grease, and oil from the metal surface. Epoxies, vinyls, asphalt, or welding slag must
be removed before galvanizing by grit blasting, sand blasting, or other mechanical means.
Pickling - Scale and rust normally are removed from the steel surface by pickling in a dilute solution
of hot sulfuric acid or ambient. temperature hydrochloric acid.
Surface preparation also can be accomplished using abrasive cleaning as an alternative to or in
conjunction with chemical cleaning. Abrasive cleaning is a process whereby sand, metallic shot, or grit
is propelled against the steel material by air blasts or rapidly rotating wheels.
Fluxing - Fluxing. is the final surface preparation step in the galvanizing process. Fluxing removes
oxides and prevents further oxides from forming on the surface of the metal prior to galvanizing and
promotes bonding of the zinc to the steel or iron surface. The method.for applying the flux depends
upon whether the particular galvanizing plant uses the wet or dry galvanizing process.
In the dry galvanizing process (see Figure 5), the steel or iron materials are dipped or pre fluxed in an
aqueous solution of zinc ammonium chloride. The material is then thoroughly dried prior to immersion
in molten zinc. In the wet galvanizing process, a blanket of liquid zinc ammonium- chloride is floated on
top of the molten zinc. The iron or steel being galvanized passes through the flux on its way into the
molten zinc.
(T-01)1
cGalvangLng
http://www.artgalvanizing.com/Process.htm 4/23/2010

Process
Page 4-of 5
Surface .Preparation Galvanizing Inspection
Caustic Molten Zinc Cooling and
Cleaning Rinsing Pickling i2insing Flux solution Bath Cleaning
In this step, the material is completely immersed in a bath consisting of a minimum of 98% pure
molten zinc. The bath chemistry is specified by the American Society for Testing and Materials (ASTM)
in Specification D 6. The bath temperature is maintained at about 850 F (454 Q.
Fabricated items are immersed in the bath long enough to reach bath temperature. The articles are
withdrawn slowly from the galvanizing bath and the excess zinc is removed by draining, vibrating,
andlor centrifuging. Art Galvanizing specializes in the Centrifuge Process for Small and Difficult
Items.
The chemical reactions that result in the formation and structure of the galvanized coating continue
after the articles are withdrawn from the bath as long as these articles are near the bath temperature.
The articles are cooled in either water or ambient air immediately after withdrawal from the bath.
('COP).
Click to Enlarge
The two properties of the hot dip galvanized coating that are closely scrutinized after galvanizing are
coating thickness and coating appearance. A variety of simple physical and laboratory tests may be
performed to determine thickness, uniformity, adherence, and appearance.
Products, are galvanized according to long-established, well -accepted, and approved standards of the
ASTM. the Canadian Standards Association (CSA), and the American Association of State Highway
and Transportation Officials (AASIITO). These standards cover everything from the minimum
required coating thicknesses for various categories of galvanized items to the composition of the zinc
metal used in the process.
http://www.artgalvanizing.com/Process.htm 4/23/2010

Process
Page 5 of 5
Testing methods and interpretation of results are covered in the publication, The Inspection of
Products Hot Dip Galvanized After Fabrication, published by the AGA and available from theArt
Galvanizing or AGA.
(TOlJ
Click.. Here tog o to Additional Process Considerations
.Please contact us at:
3935 Valley Road
Cleveland, Ohio 44109
Phone: [phone]
Fax: [phone]
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15156
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18916
8430
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18353
10104
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17937
4434
937.79
937.79
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17005
4434
937.79
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871.72
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1440807010
520 20TH AVE N
N MYRTLE BCH SC 29582-
2358
N1/213 15 S1/2 17
ANDREWS RANDALL F &
JULIA M
0
550
0
0
Tax Information:
Current Fair Market Value:
Residential Value:
Farm Use Valle:
Other Value:
Farm Market Value:
Last Appraisal Date:
,279,500009�
279500.00
0.00
0.00
0.00
l�
Tax Year Receipt Number Assessed Value Taxes wed,' Taxes Paid Post Date Collection Status Paid Status
2009 5020 11180 1,1112.42. 0.00 10/01/2009 NONE OPEN
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2008
4769
11056
1,188.51
1,188.51
10/01/2008 NONE
FULL
2007
4746
11056
1,169.72
1,169.72
10/01/2007 NONE
FULL
2006
4722
11056
2,053.78
2,361.85
10/02/2006 NONE
FULL
2005
4075
11056
1,991.87
1,991.87
10/01/2005 NONE
FULL
2004
4151
7776
1,342.99
1,342.99
10/01/2004 NONE
FULL
2003
4070
7776
1,342.99
1,342.99
10/01/2003 NONE
FULL
2002
3899A
7776
1,300.22
1,300.22
07/22/2003 NONE
FULL
2001
87210
2100
444.15
444.15
10/01/2001 NONE
FULL
2000
47564
2100
412.86
549.79
10/01/2000 NONE
FULL
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Alchem history from MRO files
By Ellen Huffinan March 2005
Please note that the author has found files in several sections/divisions due to the different types of permits issued for the
same process i.e., residuals and recycle.
May 9, 1985 — A memorandum concerning a spill/runoff into creek (investigated on Nov. 15, 1984)
from the ALCHEM plant and drinking water well contamination. All stream samples showed high
concentrations of Al, Fe, Na, and Zn.
May 14, 1986 — DEM Groundwater section memo from Len Bramble to Bill Crawford. Subject
application of new permit APN 0076633 and GW 8680. "We have received copy of the above
referenced application which was sent to your regional office for comment on or about May 12, 1986"...
Dec. 30, 1985 — WQ MRO complaint investigation report summing up issues from multiple spills
throughout the last 12 months since the Nov. 15, 1984 investigation.
Dec. 6, 1984 — Complaint from City of Rockwell of white color in creek.
Jan. 2 & 7, 1985 — WQ samples the stream. Samples come back with extremely high
concentrations of Al, Fe, Na, and Zn. (data in file)
Feb. 28, 1985 — stream samples still show high levels of Al, Fe, & Na.
March 26, 1985 — WQ received another complaint from a resident in the ALCHEM area.
April 1, 1985 - Soil samples showed high levels of Al, Fe, & Na. Well samples taken at the
same time were high in Al & Na. Down stream samples showed high concentrations of Al, Fe,
Na, and Zn. Upstream samples did not show high concentrations of Al, Fe, Na, and Zn. Also
discovered the path of runoff from ALCHEM property to the stream.
May 9, 1985 — A memorandum from Monty Payne & Jesse Wells to Bill Jeter concerning
multiple complaints from neighbors of ALCHEM.
June 11, 1985 — stream samples once again show high levels of Al, Fe, & Na.
Sept. 9, 1985 — During a meeting with WQ and ALCHEM, it was determined that the ponds need
to be emptied and contaminated soil be removed or neutralized. If the lagoon was to be used it
must be lined. They also must submit an application for a non -discharge permit.
Jan. 3, 1986 — WQ staff report (Thurmon Horne) for ALCHEM (APN 005232) The facility has 2
existing (un-permitted) recycle lagoons. DEM & DHR have both conducted investigations regarding
well and groundwater contamination. ALCHEM has had to replace one off site drinking water well,
cleaned areas affected be run-off, and removing all liquid from the lagoons with the intention of
removing the lagoons (excavating and removing contaminated soils). ALCHEM proposes to construct a
new recycle system. The new process will involve mixing bauxite, sulfuric acid, and water in a reactor.
The waste residuals (pH between 2.0 and 2.5) will be pumped to the proposed non -discharge recycle

f

wastewater treatment facility. The residuals from the facility will be pumped to the retention pond
where LIME will be added to raise the pH to 6 s.u. The applicant proposes to dispose of the
residuals in the county landfill. The applicant has failed to submit acceptable detailed engineering
plans and specs as requested.
Recommendations: Considering the past history of this facility, it is imperative that a thorough
evaluation be made prior to permit issuance...
Jan. 7, 1986 — a meeting in Rockwell between DEM & ALCHEM, concerning a need for a permit for
the ALCHEM facility.
Jan. 8, 1986 — DEM WQ MRO memorandum — WQ reviews an application and recommends that
ALCHEM do a thorough investigation of the present subsurface conditions prior to issuance of the
permit.
Jan. 8, 1986 — MRO GW memo from Jesse Wells to Len Bramble. GW recommends that ALCHEM do
a thorough investigation of the present subsurface conditions including directional flow and gradient of
the groundwater, lithologic description and determination of the hydraulic conductivity of the soil, and
sampling of the saturated zone as a requirement before issuance of the permit.
Jan. 30, 1986 - A letter from DENR & Community Development, regarding insufficient data to process
the permit application.
April 10, 1986 letter from DENR to ALCHEM regarding Operation of an un-permitted non -discharge
Waste Treatment System.
May 5, 1986 ALCHEM submits a permit application for a tank spill containment area & a sand filter.
June 17, 1986 — letter from ALCHEM to DENR Addendum to application APN007633.
Sept. 12, 1986 — DEM GW — memo. Sub. Permit app. Review, ALCHEM, GW86080. Recommends
issuance of permit with 2 conditions. 1- the sand filter bed must be lined with a geotech fiber and two
layers of 6 mil. (12 mil. total) synthetic liner. 2- any groundwater monitoring deemed necessary by the
department.
September 22, 1986 — A note to file regarding a letter from ALCHEM to Thurmond Horne evaluating a
vacuum filter. Note from staff suggests that the dept. hold the permit application for four weeks before
returning the application to ALCHEM as incomplete.
(what happened to 1987?)
Jan. 19, 1988 — letter from DENR to ALCHEM —Subject: Project Return APN007633. In reference to
application received May 7, 1986.
Feb. 1988 — letter from ALCHEM to DENR. " I did not realize that our non -discharge Permit was being
held. We decided to put in a sand filter enclosed in a tank..."

n

June 25, 1993 — A memo from Central GW to MRO GW, regarding adjudication request. "The
groundwater section stands firm with its decision to recommend groundwater monitoring to remain a
part of the permit".
June 30, 1993 — A letter from DEHNR to ALCHEM, regarding groundwater monitoring to stay in the
amended permit.
Sept. 21, 1993 — A letter from ALCHEM to NC EMC asking permission to drop VOC testing
requirements from the permit.
April 6, 1994 — memo from MRO GW to DEM GQ, acknowledging receipt of a permit renewal
application for ALCHEM WQ0002702.
April 27, 1994 — memo to DEM GW Compliance Group from Barbara Christian, MRO GW Supervisor
regarding a site inspection (for a permit renewal) on April 26, 1994 that raised several concerns.
• Raw aluminum ore storage issues
• Monitoring reports indicate that monitoring wells were not purged prior to sampling
• Lack of chemical analyses of the lagoon wastewater
• Inaccurate topographic site map
May 23, 1994 — A memo from Cindy Boyles to Carolyn McCaskill, regarding ALCHEM permit renewal
(permit WQ0002702) reads "run-off into a drainage way still poses a problem to the residents directly
below grade".
June 27, 1994 — (renewed) permit WQ0002702 issued.
July 11, 1994 — A letter from DEHNR to ALCHEM, regarding (groundwater) monitoring guidance.
October 30, 1995 — A certified letter to ALCHEM from MRO GW regarding proper purging of
monitoring wells prior to sampling (permit WQ0002702).
October 20, 1998 — ALCHEM submits for a permit renewal and modification (permit WQ0002702).
Nov. 10, 1998 — A staff report by G.T. Chen includes very little comment. "pending final review and
approval by the SERG and the Groundwater Section, it is recommended that the subject permit by
renewed and modified to allow sand by-product to be mixed with clay.
December 8, 1998 — Memo from Peggy Findley, MRO, to Dr. Ken Rudo. Request for Health Rick
Evaluation for the public water supply well on the ALCHEM premises.
December 30, 1998 — a memo from Brian Wootton (MRO) to Kim Colson WQS, regarding groundwater
monitoring changes to the ALCHEM permit WQ0002702. Existing monitoring wells MW-1 & MW-2
shall be sampled Feb. & July for water level, aluminum, and pH.
4

Jan. 21, 1999 — renewal permit WQ0002702 (industrial recycle bauxite process) is issued to ALCHEM.
*****March 1, 1999 - Permit WQ00016338 is issued to ALCHEM for a Bauxite residuals reuse
Program "... for the operation of a bauxite residuals reuse program (as structural fill!!!) on ALCHEM
Inc.'s property at 8135 Red Road, Rockwell, NC..."
what were we thinking?
BTW, this was three months before I was on NMO staff.
April 25, 2000 - A letter from DEHNR, MRO, to ALCHEM, regarding (permit WQ0002702) field
analysis data (section 4 of the groundwater G-59 form).
Oct. 11, 2001 — A letter from Groundwater MRO, to ALCHEM, regarding an upward trend of aluminum
in MW-1 and MW-2 (permit WQ0002702). Letter asks from ALCHEM to re -sample within 60 days,
including the drinking water supply well that serves the office.
October 17, 2001 — A letter from IAC (Ind. & Agri. Chem. Inc. -parent company of ALCHEM)
regarding the Oct. 11, 2001 letter to ALCHEM. ... "Alchem manufactures aluminum sulfate. Both cation
and anion are very water-soluable. We have noticed the increase in aluminum values but with no
corresponding sulfate increase. Naturally, we are concerned. However, is it possible that the aluminum
is coming from other sources since there is no increase in the sulfate anion? We are going to follow
your instructions and will be in touch with you".
Jan. 7, 2002 - A Notice of Violation letter, groundwater quality violations.
March 15, 2002 — Notice of Violation for WQ0016338 concerning monitoring reports for sect. III, part
3&4.
April 12, 2002 - A rescission of NOV letter from Peggy Finley, MRO, to ALCHEM.
April 29, 2003 — complaint received by MRO, from a downstream neighbor of large amounts of white
substance being washed down the creek from ALCHEM property. Wes Bell, MRO investigated. Spent
Bauxite is found to be over 2 feet think in parts of the stream.
April 30 and May 8 — investigations had determined that the run-off from ALCHEM had impacted up to
500 linear feet of a tributary to Second Creek.
May 12, 2003 — NOV/NRE for permit WQ0016338 regarding the above complaint investigation.
May 14, 2003 — a letter from DENR MRO to ALCHEM, regarding the NOV. The NOV should have
been issued against permit WQ0016338.
May 23, 2003 — The TARA Group is hired to repair erosion control issues at ALCHEM.
May 28, 2003 — A letter from ALCHEM to Rex Gleason, supervisor WQS, MRO. This letter is in
response to the above mentioned NOV/NRE. ALCHEM sends an outline of a cleanup plan.

August 18, 2003 — (WQ0016338) a penalty was assessed in the amount of $5,998.28 for the May 12,
2003 NOV.
August 19, 2003 — A NOV (WQ0016338) was issued for failure to incorporate remedial actions/illegal
discharge to surface water.
Feb. 24, 2004 — ALCHEM submits the annual report for WQ0016338. ALCHEM reports "for the year
2003, we did not accumulate enough silica residual to land apply".
July 29, 2004 — ALCHEM on payment plan with AGO for the May 12, 2003 NOV, per Janet Leach.
Aug. 13, 2004 — A letter from DEHNR to ALCHEM, regarding withdrawal of permit application
package for WQ0016338.
Sept. 29, 2004 - MRO receives a request to renew WQ0002702.
Sept. 20, 2004 — MRO receives a request to renew WQ0016338.
Oct. 25, 2004 — A staff report by Ellen Huffman, MRO, for both permit renewals, requests that due to
past confusion between the two permits that they be combined for better monitoring of a site with many
compliance issues in the past. There were also many other changes requested.
December 28, 2004 — A renewal permit for WQ0002702 (recycle) is issued with the many changes (as
requested by MRO, but the other permit (WQ0016338, residuals) is not issued. It is currently being held
in Central Offices until the confusion is cleared up.
Dec. 30, 2004 & Jan.5, 2005 — follow-up investigation by Wes Bell, MRO, revealed stormwater run-off
issues with low pH continuing to impact the stream.
Jan. 12, 2005 — NOV/NRE issued due to continued problems found during the investigation on Dec. 30,
2004 and Jan. 5, 2005.
Jan. 27, 2005 — A letter from ALCHEM to Rex Gleason, MRO, regarding further cleanup of stream.
Still states that their pH readings are not as low as the readings that Wes Bell had gotten.
Feb. 9, 2005 - A letter from ALCHEM to Rex Gleason, MRO, regarding soils sampling, liming affected
areas, hiring a tree expert, and repairing silt fences.
Feb. 10, 2005 — A letter from ALCHEM to Div. Of WQ, Central Office, regarding the receipt of the new
permit WQ0002702. The permit was dated Dec. 28, 2004 but ALCHEM says that they did not receive it
until Jan. 28, 2005. This letter asks for an extension of 90 days to review the permit. To the writer's
knowledge, this letter has not been responded to by Central Office.
6

March 8, 2005 — A letter from ALCHEM to Div. Of WQ, Central Office, regarding many objections to
the permit conditions of WQ0002702. To the writer's knowledge, this letter has not been responded to
by Central Office.
March 10, 2005 — A letter from ALCHEM to Non-Dis. Compliance conveys the annual report for
WQ0016338. This letter states that they did not accumulate enough silica residual to land apply, just like
the 2003 annual report. The writer recalls that ALCHEM stated that they plan to clean out a lagoon (or
two) in the spring which is why the staff report asked for extra pH testing on excavated materials and an
inspection of the lagoon liner.

YES Signs of runoff / ponding
Monitoring well(s) Y/N: Y
The wells at this site are associated with the water recycle system permitted under WQ0002702
Lagoon #1 conditions as of August 20, 2007
Lagoon #1 retaining wall

r.
n
f9
a
Cement pad
berm wall prep for repairs and stormwater collection pond

ALCHEM August 4, 2005

MARCH 2O02 AERIAL PHOTOGRAPHY 1 inch equals 200 feet e

COUNTY :
QUAD NO:
ROWAN
REPORT TO : MRO
COLLECTOR(S) : E HUFFMAN
DATE: 8/23/2005
TIME:
PURPOSE:
T ARnRATf)RV ANAT.VCTC
DIVISION OF WATER QUALITY
Chemistry Laboratory Report / Ground Water Quality
13AMPT.F. PRTORITY
iROUTINE EMERGENCY
Regional Office X❑ CHAIN OF CUSTODY ❑
2
S� SAMPLE TYPE
Owner: ALC M, M
Location or Site:
Description of sampling point
Sampling Method:
Remarks:
Lab Number 5G2221
Date Received : 8/24/2005
Time Received 8:30 AM
Received By DS
/-�j0
eased B�: I
Date reported : 12/30/2005
SG2221

GR�ATER FIELD/LAB FORM
SAMPLE:
County ROWAN ❑ Water
Quad No Serial No. moil
Lat. Long. ❑ other
North Carolina
Department of Environment and Natural Resources
DIVISION OF WATER QUALITY -GROUNDWATER SECTION
SAMPLE PRIORITY
Routine Lab Number "Y°
�R§Yh f Date Receive Time: �►
Rec'd By: rom:Bus ouri Hand Del.,
to
H `;,J I m N- I �� Other. -
Report To: ARO, FR , MlRO, RO, WaRO, WiRO, Data Entry to Ck:
WSRO, Kinston F ust, Central Off., Other: Date Reported:
Shipped by: Bu Cour and Del., Other: ,purpose:
Collector(s): man Date-23-05 TimeLL: cram Baseline, Complaint, Compliance,(circle USne)Pesticide Study, Federal Trust, Other:
FIELD ANALYSES Owner _ALCHEM
pH 400 Spec. Cond.9a at 250C Location or Site Residuals fill area
Temp.lo °C Odor Description of sampling point residuals collected out of residuals fill area
Appearance Sampling Method grab Sample Interval
Remarks
Field Analysis By um ater.ao.
..... ...� (Pumping time. air temp., etc.)
..JAI vc+rf[+
BOD 310
mg/L
COD High 340
mg/L
COD Low 335
mg/L
Coliform: MF Fecal 31616
/100mI
Coliform: MF Total 31504
/100ml
TOC 680
mg/L
Turbidity 76
NTU
Residue, Suspended 530
mg/L
units
Alkalinity to pH 4.5 410a
Alkalinity to pH 8.3415
Carbonate 446
Bicarbonate 440
Carbon dioxide 405Chloride
940Chromium:
Hex 1032Color:
True 80
Cyanide 720 mg/L
Lab Comments
Diss. Solids 70300 mg/L
Fluoride 951 mg/L
Hardness: Total 900 mg/L
Hardness (non-carb) 902 mg/L
Phenols 32730 ug/l
Specific Cond. 95 uMhos/cm
Sulfate 945 mg1L
Sulfide 745 mg/L
Oil and Grease mg/L
R"NH3
as N 610 mg/L
N 62 g/L
N as 5 m
NO2 + NO3 as N 630 mg/L
P: Total as P 665 mg/L
Nitrate (NO3 as N) 620 mg/L
Nitrite (NO2 as N) 615 mg1L
GW-54 REV. 7/03 For Dissolved Analysis -submit filtered sample and write "DIS" in block.
Ag-Silver 46566
u /L
X
AI -Aluminum 46557
u /L
X
As -Arsenic 46551
u /L
Ba-Barlum 46558
u /L
Ca -Calcium 46552
m /L
X
Cd-Cadmium 46559
u IL
X
Cr-Chromium 46559
u /L
X
Cu-Copper 46562
u /L
X
Fe-tron 46563
u /L
X
Hg-Mercury 71900
u /L
K-Potassium 46555
m /L
Mg -Magnesium 46554
m IL
Mn-Manganese 46565
u /L
Na-Sodium 46556
m /L
X
Ni-Nickel
u /L
X
Pb-Lead 46564
u IL
X
Se -Selenium
u /L
X
Zn-Zinc 46567
u /L

ALCHEM
Subject: ALCHEM
From: Ellen Huffman <[e-mail]>
Date: Fri, 16 Sep 2005 14:55:53 -0400
To: John Murray <[e-mail]>
CC: Ed Robinette <[e-mail]>, DAVID GOODRICH
<DAV ID. [e-mail]>
Hello John,
First, thanks for taking time to look at ALCHEM, Rowan County. It is one of those
permits that are clear as mud. I have attached a time line that I put together
regarding the history of ALCHEM and WQ section. ALCHEM has two non -discharge
permits. The permit in question is WQ0016338, which is the bauxite reuse permit
.This permit is currently in review. 'It is the intention of the Aquifer Protection
Section non -discharge permitting section to re -issue this permit as a monofil. The
question is should we be re -issuing this permit or should this be permitted by
solid waste? Hopefully, the meeting scheduled for Wed. Sept. 21st. will clear
things up. Of course, there is the possibility that it will just muddy the waters
even more. Please forward this to the person in the Winston rerional office (Hugh
J.) as Teresa does not handle Rowan county. We can include anyone who wants by
phone on Wednesday. I will try to
Thanks,
Ellen
PS -Ed, have you heard from thier consultants yet?
Ellen Huffman
Environmental Specialist II
North Carolina Dept. of Environment & Natural Resources
Aquifer Protection
610 East Center Avenue
Mooresville, NC 28115
Ph: 704.663.1699 Fax: [phone]
Alchem history84-2005.doc Content -Type: application/msword
Content -Encoding: base64
1 of 1 9/16/2005 3:00 PM

r
Alchem history from MRO files
By Ellen Huffinan March 2005
Please note that the author has found files in several sections/divisions due to the different types of permits issued for the
same process i.e., residuals, recycle, groundwater.
May 9, 1985 — A memorandum concerning a spill/funoff into creek (investigated on Nov. 15, 1984)
from the ALCHEM plant and drinking water well contamination. All stream samples showed high
concentrations of Al, Fe, Na, and Zn.
May 14, 1986 — DEM Groundwater section memo from Len Bramble to Bill Crawford. Subject
application of new permit APN 0076633 and GW 8680. "We have received copy of the above
referenced application which was sent to your regional office for comment on or about May 12, 1986". .
Dec. 30, 1985 — WQ MRO complaint investigation report summing up issues from multiple spills
throughout the last 12 months since the Nov. 15, 1984 investigation.
Dec. 6, 1984 — Complaint from City of Rockwell of white color in creek.
Jan. 2 & 7, 1985 — WQ samples the stream. Samples come back with extremely high
concentrations of Al, Fe, Na, and Zn. (data in file)
Feb. 28, 1985 — stream samples still show high levels of Al, Fe, & Na.
March 26, 1985 — WQ received another complaint from a resident in the ALCHEM area.
April 1, 1985 - Soil samples showed high levels of Al, Fe, & Na. Well samples taken at the
same time were high in Al & Na. Down stream samples showed high concentrations of Al, Fe,
Na, and Zn. Upstream samples did not show high concentrations of Al, Fe, Na, and Zn. Also
discovered the path of runoff from ALCHEM property to the stream.
May 9, 1985 — A memorandum from Monty Payne & Jesse Wells to Bill Jeter concerning
multiple complaints from neighbors of ALCHEM.
June 11, 1985 — stream samples once again show high levels of Al, Fe, & Na.
Sept. 9, 1985 — During a meeting with WQ and ALCHEM, it was determined that the ponds need
to be emptied and contaminated soil be removed or neutralized. If the lagoon was to be used it
must be lined. They also must submit an application for a non -discharge permit.
Jan. 3, 1986 — WQ staff report (Thurmon Horne) for ALCHEM (APN 005232) The facility has 2
existing (un-permitted) recycle lagoons. DEM & DHR have both conducted investigations regarding
well and groundwater contamination. ALCHEM has had to replace one off site drinking water well,
cleaned areas affected be run-off, and removing all liquid from the lagoons with the intention of
removing the lagoons (excavating and removing contaminated soils). ALCHEM proposes to construct a
new recycle system. The new process will involve mixing bauxite, sulfuric acid, and water in a reactor.
The waste residuals (pH between 2.0 and 2.5) will be pumped to the proposed non -discharge recycle

wastewater treatment facility. The residuals from the facility will be pumped to the retention pond
where LIME will be added to raise the pH to 6 s.u. The applicant proposes to dispose of the
residuals in the county landfill. The applicant has failed to submit acceptable detailed engineering
plans and specs as requested.
Recommendations: Considering the past history of this facility, it is imperative that a thorough
evaluation be made prior to permit issuance...
Jan. 7, 1986 — a meeting in Rockwell between DEM & ALCHEM, concerning, a need for a permit for
the ALCHEM facility.
Jan. 8, 1986 — DEM WQ MRO memorandum — WQ reviews an application and recommends that
ALCHEM do a thorough investigation of the present subsurface conditions prior to issuance of the
permit.
Jan. 8, 1986 — MRO GW memo from Jesse Wells to Len Bramble. GW recommends that ALCHEM do
a thorough investigation of the present subsurface conditions including directional flow and gradient of
the groundwater; lithologic description and determination of the hydraulic conductivity of the soil, and
sampling of the saturated zone as a requirement before issuance of the permit.
Jan. 30, 1986 - A letter from DENR & Community Development, regarding insufficient data to process
the permit application.
April 10, 1986 letter from DENR to ALCHEM regarding Operation of an un-permitted non -discharge
Waste Treatment System.
May 5, 1986 ALCHEM submits a permit application for a tank spill containment area & a sand filter.
June 17, 1986 — letter from ALCHEM to DENR Addendum to application APN007633.
Sept. 12, 1986 — DEM GW — memo. Sub. Permit app. Review, ALCHEM, GW86080. Recommends
issuance of permit with 2 conditions. 1- the sand filter bed must be lined with a geotech fiber and two
layers of 6 mil. (12 mil. total) synthetic liner. 2- any groundwater monitoring deemed necessary by the
department.
September 22, 1986 — A note to file regarding a letter from ALCHEM to Thurmond Horne evaluating a
vacuum filter. Note from staff suggests that the dept. hold the permit application for four weeks before
returning the application to ALCHEM as incomplete.
(what happened to 1987?)
Jan. 19, 1988 — letter from DENR to ALCHEM —Subject: Project Return APN007633. In reference to
application received May 7, 1986.
Feb. 1988 — letter from ALCHEM to DENR. " I did not realize that our non -discharge Permit was being
held. We decided to put in a sand filter enclosed in a tank..."
2

July 30, 1989 — A letter from DENR & Comm. Dev. regarding information needed for a review of
ALCHEM Ind. Recycle (WQ0001987) permit to be completed.
October 2, 1989 —from DENR to ALCHEM. Subject: Project Return (WQ0001987).
October 11, 1989 — A staff report from MRO recommends that the ERG and groundwater provide
comments before permit issuance and possible cake sludge storage issues. (Allen Hardee, MRO staff).
January 10, 1990 - DENR issues permit WQ0002702 after review of Nov. 17,1989 (permit) application.
(can not find copy of application in file for this date)
May 4, 1990 — a letter from ALCHEM to DENR (Carolyn McCaskill) referencing permit WQ0002702
and regarding removal of a partition between two lagoons.
May 2.1, 1990 A letter from ALCHEM to MR. Rex Gleason (MRO) referencing permit WQ0002702 and
regarding installed facilities ready for inspection.
October 25, 1990 — A Notice of Violation regarding a discharge of alum (?) into the creek.
14
Oct. 8, 1992 ALCHEM submits a permit application for a recycle system.
Oct. 19,1992 — application from ALCHEM received by DEHNR(no application found in MRO files).
March 11, 1993 — GW memo regarding modification of permit WQ0002702 (concerning) proposed
sludge storage lagoons. GW recommends (two) monitoring wells.
March 23, 1993 — renewal application from ALCHEM received by DEHNR (no application found in
MRO files).
April 8, 1993 - amended permit is issued to ALCHEM.
April 20, 1993 — a letter from ALCHEM to DEHNR regarding amendment of permit WQ0002702
regarding monitoring well requirements and construction of only two lagoons rather than the original
five. Sees no need for groundwater monitoring.
April 20, 1993 — a letter from DEHNR to ALCHEM was conveying groundwater -monitoring guidance.
June 9, 1993 — memo from Don Saffrit, P.E., Asst. Chief for Teck. Support to Ted Bush Asst. Chief,
groundwater section regarding a petition (ALCHEM monitoring wells) with the Office of
Administrative hearings.
June 22, 1993 — A memo from MRO GW (David Eudy) to Jack Floyd regarding adjudication request -
concerns with sulfuric acid in large quantities and past history of non-compliance, there is ample
justification for groundwater monitoring requirements.

June 25, 1993 — A memo from Central GW to MRO GW, regarding adjudication request. "The
groundwater section stands firm with its decision to recommend groundwater monitoring to remain a
part of the permit".
June 3 0, 1993 A letter from DEHNR to ALCHEM, regarding groundwater monitoring to stay in the
amended permit.
Sept. 21, 1993 —A letter from ALCHEM to NC EMC asking permission to drop VOC testing
requirements from the permit.
April 6, 1994 — memo from MRO GW to DEM GQ, acknowledging receipt of a permit renewal
application for ALCHEM WQ0002702.
April 27, 1994 — memo to DEM GW Compliance Group from Barbara Christian, MRO GW Supervisor
regarding a site inspection (for a permit renewal) on April 26, 1994 that raised several concerns.
• Raw aluminum ore storage issues
• Monitoring reports indicate that monitoring wells were not purged prior to sampling
• Lack of chemical analyses of the lagoon wastewater
• Inaccurate topographic site map
May 23, 1994 — A memo from Cindy Boyles to Carolyn McCaskill, regarding ALCHEM permit renewal
(permit WQ0002702) reads "run-off into a drainage way still poses a problem to the residents directly
below grade".
June 27, 1994 — (renewed) permit WQ0002702 issued.
July 11, 1994 — A letter from DEHNR to ALCHEM, regarding (groundwater) monitoring guidance.
October 30, 1995 — A certified letter to ALCHEM from MRO GW regarding proper purging of
monitoring wells prior to sampling (permit WQ0002702).
October 20, 1998 — ALCHEM submits for a permit renewal and modification (permit WQ0002702).
Nov. 10, 1998 — A staff report by G.T. Chen includes very little comment. "pending final review and
approval by the SERG and the Groundwater Section, it is recommended that the subject permit by
renewed and modified to allow sand by-product to be mixed with clay.
December 8, 1998 — Memo from Peggy Findley, MRO, to Dr. Ken Rudo. Request for Health Rick
Evaluation for the public water supply well on the ALCHEM premises.
December 30,1998 — a memo from Brian Wootton (MRO) to Kim Colson WQS, regarding groundwater
monitoring changes to the ALCHEM permit WQ0002702. Existing monitoring wells MW-1 & MW-2
shall be sampled Feb. & July for water level, aluminum, and pH.

Jan. 21, 1999 — renewal permit WQ0002702 (industrial recycle bauxite process) is issued to ALCHEM.
*****March 1, 1999 - Permit WQ00016338 is issued to ALCHEM for a Bauxite residuals reuse
Program "... for the operation of a bauxite residuals reuse program (as structural fill!!!) on ALCHEM
Inc.'s property at 8135 Red Road, Rockwell, NC..."
April 25, 2000 — A letter from DEHNR, MRO, to ALCHEM, regarding (permit WQ0002702) field
analysis data (section 4 of the groundwater G-59 form).
Oct. 11, 2001 — A letter from Groundwater MRO, to ALCHEM, regarding an upward trend of aluminum
in MW-1 and MW-2 (permit WQ0002702). Letter asks from ALCHEM to re -sample within 60 days,
including the drinking water supply well that serves the office.
October 17, 2001— A letter from. IAC (Ind. &" Agri. Chem. Inc. -parent company of ALCHEM)
regarding the Oct. 11, 2001 letter to ALCHEM. ... "Alchem manufactures aluminum sulfate. Both cation
and anion are very water-soluable. We have noticed the increase in aluminum values but with no
corresponding sulfate increase. Naturally, we are concerned. However, is it possible that the aluminum
is coming from other sources since there is no increase in the sulfate anion? We are going to follow
your instructions and will be in touch with you".
Jan. 7, 2002 - A Notice of Violation letter, groundwater quality violations.
March 15, 2002 — Notice of Violation for WQ0016338 concerning monitoring reports for sect. lII, part
3&4.
April 12, 2002 - A rescission of NOV letter from Peggy Finley, MRO, to ALCHEM.
April 29, 2003 — complaint received by MRO, from a downstream neighbor of large amounts of white
substance being washed down the creek from ALCHEM property. Wes Bell., MRO investigated. Spent
Bauxite is found to be over 2 feet thik in parts of the stream.
April 30 and May 8 — investigations had determined that the run-off from ALCHEM had impacted up to
5000 lines feet of a tributary to Second Creek.
May 12, 2003 — NOV/NRE for permit WQ0016338 regarding the above complaint investigation.
May 14, 2003 — a letter from DENR MRO to ALCHEM, regarding the NOV. The NOV should have
been issued against permit WQ0016338.
May 23, 2003 — The TARA Group is hired to repair erosion control issues at ALCHEM.
May 28, 2003 — A letter from ALCHEM to Rex Gleason, supervisor WQS, MRO. This letter is in
response to the above mentioned NOV/NRE. ALCHEM sends an outline of a cleanup plan.
August 18, 2003 — (WQ0016338) a penalty was assessed in the amount. of $5,998.28 for the May 12,
2003 NOV.

August 19, 2003 — A NOV (WQ0016338) was issued for failure to incorporate remedial actions/illegal
discharge to surface water.
Feb. 24, 2004 — ALCHEM submits the annual report for WQ0016338. ALCHEM reports "for the year
2003, we did not accumulate enough silica residual to land apply
July 29, 2004 — ALCHEM on payment plan with AGO for the May 12, 2003 NOV, per Janet Leach.
Aug. 13, 2004 — A letter from DEHNR to ALCHEM, regarding withdrawal of permit application
package for WQ0016338.
Sept. 29, 2004 - MRO receives a request to renew WQ0002702.
Sept. 20, 2004 — MRO receives a request to renew WQ0016338.
Oct. 25, 2004 — A staff report by Ellen Huffman, MRO, for both permit renewals, requests that due to
past confusion between the two permits that they be combined for better monitoring of a site with many
compliance issues in the past. There were also many other changes requested.
December 28, 2004 — A renewal permit for WQ0002702 (recycle) is issued with the many changes (as
requested by MRO, but the other permit (WQ0016338, residuals) is not issued. It is currently being held
in Central Offices until the confusion is cleared up.
Dec. 30, 2004 & Jan.5, 2005 — follow-up investigation by Wes Bell, MRO, revealed stormwater run-off
issues with low pH continuing to impact the stream.
Jan. 12, 2005 — NOV/NRE issued due to continued problems found during the investigation on Dec. 30,
2004 and Jan. 5, 2005.
Jan. 27, 2005 — A letter from ALCHEM to Rex Gleason, MRO, regarding further cleanup of stream.
Still states that their pH readings are not as low as the readings that Wes Bell had gotten.
Feb. 9, 2005 - A letter from ALCHEM to Rex Gleason, MRO, regarding soils sampling, liming affected
areas, hiring a tree expert, and repairing silt fences.
Feb. 10, 2005 — A letter from ALCHEM to Div. Of WQ, Central Office, regarding the receipt of the new
permit WQ0002702. The permit was dated Dec. 28, 2004 but ALCHEM says that they did not receive it
until Jan. 28, 2005. This letter asks for an extension of 90 days to review the permit. To the writer's
knowledge, this letter has not been responded to by Central Office.

March 8, 2005 — A letter from ALCHEM to Div. Of WQ, Central Office, regarding many objections to
the permit conditions of WQ0002702. To the writer's knowledge, this letter has not been responded to
by Central Office.
March 10, 2005 — A letter from ALCHEM to Non-Dis. Compliance conveys the annual report for
WQ0016338. This letter states that they did not accumulate enough silica residual to land apply, just like
the 2003 annual report. The writer recalls that ALCHEM stated that they plan to clean out a lagoon (or
two) in the spring which is why the staff report asked for extra pH testing on excavated materials and an
inspection of the lagoon liner.

t, .1..
02/23/2006 10:08 9108435789
PAGE 01
ALCHEMY INC_
JINOM nr& .VEST or ERUjff 'o .�.AX
2042 Buie Philadelphus Rd N Red Springs, NC 28377
Tel. [phone] ext. 27 l- Fax [phone]
[e-mail]
'Facsimile transmittal
To:
Chuck Boyle
From:
6rline Locklesr
Re:
Report
Cc:
f4s. Ellen Huffman
Fax: [phone]
Date: 2/23/2006
Pages: 1
X Urgent 0 For review ❑ Please 0 Please
Notes:
Mr. Boyle:
Please recycle
Randall Andrews actually asked me to do this yesterday. I apologize for not sending this yesterday.
Nevertheless, please fax a copy of the ALCHEM, INC. Report to Ms. Ellen Huffman with the NCDENR
office in Mooresville, NC. The fax number is 704-663-6040. Please let me know if you have any
questions. Also, please fax a note to our office informing Randall Andrews that this has been done.
Regards,
'P
6,t/
'4;'t A
�
Erline Locklear

\•.. Combining ALCHEM's e Cts(W=Q0002702�an�,,WQOO16338
)
Current status of the January 12, 2005 Notice of Violation and any possible
penalty assessments.
• Our response to the Permittee on:
o Permit Issues
o The Notice of Violation
o The March 2, 2004 Settlement Agreement
B
b 'BI-, C'.
�. S

41`7
� ----`+mil/ ?-ZzV �, e3l,, , , ,,, ,4v-p q

�'4iRi•;ti
State of North C'.arolina
t2nY C_OC)I 17-1a DCpartment of ,lUSticc
\I-l'UttfVt:Y CiriNl-t2:\t, P. 0. BO:C 629
RALEIGH Jj
27602.0629 DATE: ` V
FACSIMILE TRANSMITTAL. SHEET
., • , . �A .
FROM: 41 - L
PHONE NO: [phone]
FAX NO: [phone]
FAX NO: il-57 b50 6
SUBJFCT_�
NO. OF PAGES INWMING TR.ANSMI'!'TAL SHEET
COMMENTS:
CONFIDENTIALITY NOTE: The information contained in this facsimile is legally privileged and confidential and is
intended only for the osc of the individual or entity named above. If the reader of this message is not the intended recipient, you
are hereby notified that any dissemination, distribution or copy of this information is strictly prohibited. If you have received this
facsimile in error, please immediately notify us by telephone an return the original message to us at the address above by U.S.
postal service. Thank you.
TO 'd 717: TT S0, T idU 99Z9-9TZ-6T6: xE3 NOIlOMS QNUI ' d3113m

4 -
n
STATE OFNORTH CAROLTNA r- C I L E D IN THE OFFICE OF
A.DMINIS'T'RATIVE HEARINGS
COUNTY OF ROWAN, Z094 MAR -2 p 3: SO 03 EHR 1587
OFFICE OF
AL CHEM, INC., WAYNE D. DRYE, ADMIOISTRATIV�
HE)4RNGS
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 iunety-eight dollars and twenty-eight cents (S398.28)
in enforcement costs), imposed upon Petitioner on August 18, 2003 for alleged violations of
North Carolina General Statutes § 143-215.1 erseq 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 fi-om a tributary to Second Creek and the
7n'.4 Zv:TT S0, T ..add 9929-9TZ-6T6:xp3 NOI193S GNU-1 ' 2131dM

r-
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
ownedbyAlchem, Inc, andthetwo affected private properties
adjacent to Alchem, Inc, in accordance with the plan or
schedule submitted.;
d. Petitioner shall submit .written notice of completion of
removal of sand and other materials to the Mooresville
Regional Office of the Division of Water Quality within five
(5) days of said completion.
2. The Petitioner will pay a total of four thousand eight hundred seventy-eight
dollars and twenty-eight cents ($4,878.28 ("Settlement Amount"), calculated as follows: Total
Penalty $5,600.00 - 20% of penalty = 4 480.00 (80% of penalty) + investigative costs of
3$ 98.28 = $4,878.28) to DENR for settlement in the manner hereinafter described. The
Settlement Amount shall be made in the following manner: The Settlement Amount shall be
made in twenty-four (24) monthly payments. The first payment shall be due and payable on
-2-
SO'd Sb:TT S0, T .add 99Z9-9TZ-6T6:x?J NOI103S QNU� 2 d31dm

A 1.1
W I , t
March 1, 2004 in the amount of two hundred three dollars and thirty cents ($203.30). Each
1 payment thereafter shall be due and payable on the l.' 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. Th-e 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:
Stornue 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 neithcr admits nor denies the allegations contained in the Findings and
Decisions and At sessment of Civil Penalties. However, upon a breach of paragraph one (1) or
two (2) of this Agreement, by Petitioner, the sole issue in any action by DENR is to collect the
Entire amount of the civil penalty assessment including investigative costs i.e., five thousand
nine hundred ninety-eight dollars and twenty-eight cents ($5,998.28)'in accordance with the
terms of paragraph four (4) above and will be limited to the Petitioner's compliance with the
terms of this Agreement.
t70'd 2b:IZ SO, T jdH 99Z9-9ZZ-6S6:XE3 N0I133S GNH-I '8 831HM

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.G. § 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.
SO'd �V:TT SO. T jdd 99Z9-9T2_-6T6:X2J NOI103S GNU-1' 231bM

WITHDRAWAL OF PETITION
9. Entry of this Agreement serve as Petitioner's Withdrawal of its Petition for
ConLeAed Case Hearing Without Prejudice in these matters. The panics agree this matter is
concluded and that rio further proceedings are needed or required to resolve the contested case.
This the �� day of February 2004.
ROY COOPER
Attorney General
By.
ormie D. Forte
Associate Attorney General
N. C. Department of Justice
Environmental Division
9001 Mail Service Center
Raleigh, NC 27699-9001
[phone]
[phone]/Fax
FOR THE DIVISION OF WATER PETITIONER:
QUALITY
. 0" "�L- . .
Alan Klimek, Director of Alchem"Inc., Wayne e
Water Quality
Date:- O Date:
.._.�: a
D. Rex Gleason", Mooresville Randall F. Andrews, Consultant
Regional Supervisor Alchem, Inc.
r
Date: Date�` T J 7iD0
90 -d 5,b: TT S0, T .add 99Z9-9TZ-6T6: xPJ NOI 33S QNdI '8 2131dm

NCDENR MRO
Fax:[phone]
Apr 1 2005 15:24
P. 01
01{27(r20e5 15:08
7042798418
ALCHEM INC
ALCHEM, INC.:
8135 RED ROAD :; V
ROCKWELLG NC 2F `p) p r�
704-279-7908 fax 704-7 +g k -S
pdrye(a�a11te1_aet �� `��9
PAGE 02
a�1
"� rt
fazivary 27, 2005��—
Mr. D. Rex Gleason, P.E.
SurfaCe Water Protection Regional -Supervisor �' o �1 16
NCDENR
Division of Water Quality
Surface Water Protection Unit s
610 East Centex Ave, Suite 341
Mooresville, NC 28115
Dear MT, Gleason,
A1chern, Inc is very coua=e4 about the impact of tho rupo rom Alchem prvperty-
Ale6crrt, zzkc has removed sand from, the stream and wooded areas using temporary persopnel- Some of
the areas were not possible to enter with manual labor.
roup Construction to bring in heavy equipment to complete this cleanup in a
Qlchem has hued Tara G
quick and professional Planner-
Alchextt 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. Alchesn is in the process now of
�'+,,o p,ir.f,-„re, apclahe_silt fence.,wxll be observed more often.
putting rip rap racx az qua uaac �� •••� --
erm around the entire residual storage periruetcz in the last week and
Tara Group has applied 3 feet to the b
very close to moving into the heavily wooded areas for clean up.
.
Alchetn has contacted Rowan Community College to hire a student to do environmental alaecks, pH
testiztg, collect water sample$, etc for Alchew.
did pH testing every week since the last N.O•V. The pH reading was not as low as
A)Cliero
Mr. Wes Inc personnel
Bell reported.
ebruary weather perixtittin$.
1 expect to have this clean, up completed by mid F
If possible we.would like to meet with you before you take any action on this:
Best regards,
A,,LCHENI INC
W)IM, � X�w
Wayne D;rye,
P]aalt �zsnagtr
pcd

s NCDENR MRO Fax:[phone] Apr 1 2005 15:25. P.02
02/11lae08 10:19 7042798418 ALCHEM INC PACE 01
ALCHEM, INC.
Coraoratc Office Sates and MangfacturinA
2042 Buie ?h;ladelphus Road 8133 Red Road
J2ad Springs, NC 2-8377 Rockwall, NC 28138
Tel. [phone] — Fax 910-843S789 Tel. [phone] — Fax [phone]
i{a { aemr.net pdrye,a3chem@&ffi%tematnet
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.
. 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^rC�., un-,,,;11.-
2. r b e havincontacted
nac$ to visitens xe weekit, ad- anduiwill a hen give us 'some
recommendations.
3. We have completely repaired the silt fence and put much larger stones
on it to hold it in place.
1 will continue giving you reports of our progress.
Best. regards,
ALCHEM, INC.
Wayne Drye,
Plant Manager
vll

Re: ALCHEM revisited
Subject: Re: ALCHEM revisited
From: David Goodrich <[e-mail]>
Date: Tue, 02 Aug 2005 15:11:47 -0400
To: Ellen Huffman <Ellen.Huff [e-mail]>
CC: Shannon Thornburg <[e-mail]>, andrew pitner
<[e-mail]>, Peggy Finley <[e-mail]>
Everyone,
I have just been contacted by a Mr..Nathan Cook of Bowle Engineering (a
geotechnical/ environmental consulting firm) who has been retained by Mr.
Andrews of ALCHEM to perform some site (and material) investigation
activities in answer to our registered letter of June 8; 2005 requesting
additional information. He intends to perform a number of physical tests on
the "silica", and to similarly examine and test the underlying materials to
see how viable a foundation material would be that would be made from a
mixture of the two. He has a copy of our letter to Mr. Andrews requesting
additional information, and plans to send the results of his investigation
to us in the form of a report that will provide the additional information
we have requested.
David
Ellen Huffman wrote:
Hey Shannon,
Late Friday, (July 22), I got a call back from David Goodrichconcerning
ALCHEM permit WQ0016338. He has not heard from ALCHEM regarding the add
info request (to be submitted by July 8) for WQ0016338. Hey, can we
rescind it?-ok, wishful thinking Regarding WQ0002702, a call to
the OAH revealed a court date of Sept 5th., however; Stormy (w/ AG
office) says that they have the rescission still in the works. ALCHEM
responded (to Stormy) concerning the rescission with a letter that I
have not seen. The saga continues...
Ellen in MRO
Ellen Huffman
Environmental Specialist II
North Carolina Dept. of Environment & Natural Resources
Aquifer Protection
610 East Center Avenue
Mooresville, NC 28115
Ph: 704.663.1699 Fax: [phone]
1 of 1 9/22/2005 4:05 PM

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South Carolina
Secretary of State
Mark Hammond
Notice to Recipient;
This facsimile (teIecopy) message is pririileged and confidential. It is intended for the use of the individual named below_ Ifyou are not the intended recipient, or the person
responsible todeliver it to.the narned'recipie4, you are hereby advised that any dissemination, distribution, or copying of this communication is prohibited. lfyou have received this
facsimile messaup in error; please4mmediately notify the sender by telephone at 803-734 2170 and return this message to thesender by U_S. M' ail.
To: Ellen Hxffrnan _`77.FAX: [phone]
From: Jw nes Woodard' ail: [e-mail]
sos.sc.go�r Voice: [phone]
- Fax: [phone]
-fihere are 3 Pages transmitted including this cover sheet
n-,
Comments: LIME-CHEK INC
o
PO Box 11350 [phone] [phone] (803) 734-21 19 (803) 73 2164 1205 Pendleton Street
Columbia, SC 29211 Information Business Filings. Notaries FAX Bro►vn BIdt Suite 525
Columbia, SC 29201
s �
R

nioutn c:arouna secretary or State
Corporation Details
Corporation Information
Corporation Name: LIME-CHEM, INC.
Name Type: CORP Status: GDS
Corp Entail:
Agent Name: NATIONAL REGISTERED AGET S, INC.
z
Addressl: 2 OFFICE PARK CT
Address2: STE 103
,a
n,
a
n5
2E
4
Profit/ Non -Prof it: P
City: COLUMBIA-
2iis 29223 Incorporated State: SOUTH CAROLINA
Agent Eiti}ail:
Corporation Comment:
Filing Information
State: SC
File ID - Filing Date Type Description Comment
110401-0060 03/29/2011 INC ARTICLES Or- INCORPORATION INCORPORATION
Domestic/Foreign: D
Original Filing 03/29/2011
Effective Date: 03/29/2011
Expiration Date:
Dissolved Date:
Termination Date
LLP Renewal Date:
Tax Year End:
Associated Name
LIME- CHEM, INC.
Microfilm
ID
Associated Names Information
Associated Name Associated Corporation Name Name Type Status Expiration
Type Date
LIME-CHE Evil INC. INC LIME-CHEM, INC. CORP GDS
Effective Date: 05/0612011 13:32:47
4 a.

May, 6. 2011 1;36PM
No.7980 P. 3
1 u
STATE OF SOUTH CAROLINA
SECRETARY OF STATE
ARTICLES OF INCORPORATION
TYPE OR PFUMICI.FA YIN @TACK INK
1, The name of the proposed corporation is lime -Chem, Inc.
2. The initial registered office of the corporation is 2 Offioe Park ourtr,uite 103
StrM Address
Columbia, County of Richland, SC 29223
City County State EP Gode
and the initial registered agent at such address isNational Registered Agents, Inc.
Pried IvamEs
I hereby consent to pointment as t d agent of the corporation:
AgWe S I,
Victor Alfano, Vice Prey{ '
3. The corporation is authorized to Issue shares of stock as is applicable: fallow'b. Complete "a° orwhichever
a• 9Q The corporation is authorized to issue a single class of shares, the total number
of shares authorized is ��d0
b. [ ] The corporation {s authorized to Issue more that one diass of shares:
Class of shares Authorized No, of l=ach Class
The relative right, preference, and limitations of the shares of each class, and of each series
within a class, are as follows:
N/A
4. The existence of the corporation shall begin as of the filing date with the Secretary of State unless
a delayed date is indlcated (See Section 33-1-230(b) of the 1976 south Carolina Code of Laws,
as amended)
5, The optional provisions, which the corporation elects to include In the articles of incorporation, are
as follows (Seethe applicable provisions of Sections 33-2-102. 35-2A nFi AnA 4R h -)IM .a .
1976 South Carolina Code of Laws, as amerided). IlUD14M O FILED: 63=2011
LIME-CHEM, INC,
F0i Fee: S935.DD ORIG
Mark Hamntand South OwAna SecmAary of State

r ' May. 6. 2411• 1:36PM
No.7960 P. 4
Lime -Chem, Inc.
mq of CDrporation
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7. 1, an attomey licensed to practice In the state of south
Caroline, certliod w that ttre corporatlon, to whose articles of incorporation this oertlficate is attached,
has complied with the requirements of Chapter 2, Title 33 of the 1976 South Carolina Code of
Laws, as amended, relating to the articles of incorporation.
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From Corporation Wiki website:
Industrial & Agricultural Chemicals Services, Inc. is located at 2042 Buie Philadelphus Rd Red Springs, NC 28377. The
officers include Randall F Andrews. Industrial & Agricultural Chemicals Services, Inc. was incorporated on Monday,
December 11, 2000 in the State of TX and is currently active. Randall F Andrews represents Industrial & Agricultural
Chemicals Services, Inc. as their registered agent.
Source: Public Record data - Department of State - Division of Corporations.
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STATE OF NORTH CAROLINA
COUNTY OF IREDELL
POLYTEC, INC.
Plaintiff,
M
RANDALL F. ANDREWS; ALCHEM
INCORPORATED; INDUSTRIAL &
AGRICULTURAL CHEMICALS,
INCORPORATED; BRENNTAG
SOUTHEAST, INC.; PURE WATER
TECHNOLOGIES, LLC; DENISE K.
WOLCOTT and ROBERT WOLCOTT,
Defendants.
IN THE GENERAL COURT OF JUSTICE
SUPERIOR COURT DIVISION
09-CVS-3733
OPPOSITION TO NOTICE OF
DESIGNATION OF ACTION AS
MANDATORY COMPLEX BUSINESS
CASE UNDER N.C. GEN. STAT. § 7A-45.4
COMES NOW Plaintiff Polytec, Inc. ("Polytec") in opposition to the designation of this
civil action as a "mandatory complex business case" under N.C. Gen. Stat. § 7A-45.4. In support
of this opposition, Polytec respectfully shows the Court as follows:
1. Polytec commenced this civil action on October 9, 2009 in Iredell County
Superior Court against Randall F. Andrews ("Andrews"), Alchem Incorporated ("Alchem"),
Industrial & Agricultural Chemicals Incorporated ("IAC"), Brenntag Southeast,
Inc.(`Brenntag"), Pure Water Technologies, LLC ("Pure Water"), Denise K. Wolcott ("D.
Wolcott") and Robert Wolcott ("R. Wolcott").
2. This lawsuit concerns (1) Andrews', Alchem's and IAC's breaches of a 2006
settlement agreement (the "Agreement") entered into in settlement of a prior lawsuit filed in
Iredell County Superior Court in 2005 (Case No. 05-CVS-2406) and (2) the remaining
Defendants' assistance with those breaches and interference with Polytec's contract rights under
the Agreement.
3. The Agreement, which was fully executed on October 31, 2006, includes a
"Non -Competition Covenant," which provides, among other things, that for a period of three (3)
years after the Closing Date (October 31, 2006), Andrews, Alchem or IAC shall not, without the
express written consent of Polytec, own, manage, operate, control or in any other material
capacity, engage, participate, or become affiliated or connected in any material business
relationship with any Competing Business which competes with the business of Polytec. A
"Competing Business" is defined to include, among other things, providing and selling certain
chemical products to municipal and industrial wastewater treatment facilities for wastewater

treatment purposes or selling calcium hydroxide to existing customers of Polytec (for wastewater
use only).
4. The sum and substance of the allegations that form the basis for the claims against
the Defendants in this lawsuit are that (1) Andrews, Alchem and/or IAC have been directly and
indirectly selling and/or providing calcium hydroxide and perhaps other products to existing
customers of Polytec before the expiration of the 3-year Non -Competition Covenant term in
violation of the Agreement and (2) Brenntag, Pure Water, D. Wolcott and R. Wolcott were aware
of the rights of Polytec and the obligations of Andrews, Alchem and IAC under the Agreement
but nevertheless cooperated with Andrews, Alchem and IAC to interfere with Polytec's
contractual rights.
5. Based on the basic factual allegations included in the Complaint, Polytec has
asserted claims for (1) Breach of Contract against Andrews, Alchem and IAC, (2) Tortious
Interference with Contractual Relations and Prospective Economic Advantage against Brenntag,
Pure Water and the Wolcotts and (3) Unfair and Deceptive Trade Practices, Civil Conspiracy and
(4) Equitable Tolling/Permanent Injunction against all Defendants arising out of and relating to
the breach of the Agreement.
6. On November 11, 2009, Brenntag designated this lawsuit as a mandatory complex
business case, alleging that the issues in this lawsuit concern state trademark or unfair
competition law. According to Brenntag, this lawsuit concerns "several material issues of state
unfair competition law, including, inter alia, the enforceability and/or applicability of the non -
compete agreement in question to the challenged business transactions; the extent to which a
non -compete can bind parties not in privity with the plaintiff ... and the extent to which the
justification of legitimate market competition provides a defense to the claims of tortious
interference."
7. To warrant the mandatory designation of a case as complex business and secure
the adjudication of an action under the jurisdiction of the North Carolina Business Court, N.C.
Gen. Stat. § 7A-45.4(a) requires that the matter concern one or more of the following issues:
(1) The law governing corporations, partnerships, limited liability companies
and limited liability partnerships;
(2) Securities law;
(3) Antitrust law, except claims based solely on unfair competition under N.C.
Gen. Stat. § 75-1.1;
(4) State trademark or unfair competition law, except claims based solely on
unfair competition under N.C. Gen. Stat. § 75-1.1;
(5) Intellectual property law; or
(6) The Internet, electronic commerce, and biotechnology.
8. The designation of this lawsuit as complex business, requiring adjudication within
the Business Court, is without merit. Polytec asserts no claims concerning state trademark law.
To the extent that Polytec's claims against the Defendants concern "state unfair competition
law," those claims only support claims for under N.C. Gen. Stat. § 75-1.1, which § 7A-45.4(a)

expressly excludes from designation as mandatory complex business designation. Polytec's
claims against the Defendants concern only (1) breaches of the Agreement or (2) tortious
interference with the performance of the Agreement. Those claims support a claim under N.C.
Gen. Stat. § 75-1.1 but do not involve complex issues of "state unfair competition law" such as
misappropriation of trade secrets, which each of the cases cited by Brenntag in its Notice of
Designation involved. See Covenant Equip. Corp. v. Forklift Pro. Inc., 2008 NCBC 10, * 11
(N.C. Super. Ct. 2008) (citing claims for misappropriation of trade secrets); Better Bus. Forms &
Prods. v. Craver, 2007 NCBC 34, * 1 (N.C. Super. Ct. 2007) (citing claims under North Carolina
Trade Secrets Protection Act); Digital Recorders, Inc. v. McFarland, 2007 NCBC 23, *5 (N.C.
Super. Ct. 2007) (citing claims for misappropriation of trade secrets). Moreover, this dispute
does not even include requests for temporary and preliminary injunctive relief that the Business
Court might otherwise provide more available accommodations. Therefore, under the express
exception of § 7A-45.4(a), a complex business designation is unwarranted under the
circumstances.
9. Brenntag's interpretation of "state trademark or unfair competition law" is overly
broad and inconsistent with the context of the mandatory complex business criteria. Under the
reading of § 7A-45.4(a) proposed by Brenntag, virtually every case involving a basic covenant
not to compete would be subject to a mandatory designation as complex business. Considering
the level of complexity of the § 7A-45.4(a) factors and the express exception of the § 75-1.1
claims, designation of every lawsuit concerning a non -compete agreement, without more, as
complex business is inconsistent with the purpose of § 7A-45.4(a). There is no basis to conclude
that § 7A-45.4(a) mandates that the claims at issue in this lawsuit, all of which surround the
breach of a simple non -compete provision contained in a settlement agreement, warrant
mandatory proceedings before the North Carolina Business Court.
WHEREFORE, Plaintiff Polytec, Inc. respectfully requests that the Court remand this
matter to the Iredell County Superior Court for all further proceedings.
This the 1Ith day of December, 2009.
JOHNSTON, ALLISON & HORD, P.A.
/s/ Kerr L. Trayum n
Greg C. Ahlum, N.C. Bar No. 14 1
Kerry L. Traynum, N.C. Bar No. 32968
JOHNSTON, ALLISON & HORD, P.A.
P.O. Box 36469
Charlotte, NC 28236
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
Attorneys for Plaintiff

CERTIFICATE OF SERVICE
I hereby certify that the foregoing OPPOSITION TO NOTICE OF DESIGNATION
OF ACTION AS MANDATORY COMPLEX BUSINESS CASE UNDER N.C. GEN.
STAT. § 7A-45.4 was served on each party by sending a true and accurate copy of same by U.S.
first class mail, addressed as follows:
Eric Cottrell
Mayer Brown LLP
214 North Tryon Street
Suite 3800
Charlotte, NC 28202
Attorneys For Randall F. Andrews; Alchem
Incorporated; Industrial & Agricultural
Chemicals, Incorporated
Pure Water Technologies, LLC
c/o Denise K. Wolcott, Registered Agent
8135 Red Road
Rockwell, NC 28138
Robert Wolcott
8135 Red Road
Rockwell, NC 28138
K. Alan Parry
Smith, Anderson, Blount, Dorsett, Mitchell
& Jernigan, LLP
2500 Wachovia Capitol Center
Raleigh, NC 27601
Attorneys for Defendant Brenntag Southeast,
Inc.
Denise K. Wolcott
8135 Red Road
Rockwell, NC 28138
This the 1 lth day of December, 2009.
/s/ KM L. Tra num
Kerry L. Traynum, N.C. Bar 2968
[e-mail]
JOHNSTON, ALLISON & HORD, P.A.
P. O. Box 36469
Charlotte, NC 28236
Tel: [phone]
Fax: [phone]

2
NORTH CAROLINA
IREDELL COUNTY
POLYTEC, INC.
Plaintiff,
vs.
RANDALL F. ANDREWS, ALCHEM
INCORPORATED, INDUSTRIAL AND
AGRICULTURAL CHEMICALS
INCORPORATED, BRENNTAG
SOUTHEAST, INC, PURE WATER
TECHNOLOGIES, LLC, DENISE K.
WOLCOTT and ROBERT WOLCOTT,
Defendants.
IN THE GENERAL COURT OF JUSTICE
SUPERIOR COURT DIVISION
09 CVS 03733
NOTICE OF DESIGNATION OF ACTION
AS MANDATORY COMPLEX
BUSINESS CASE UNDER
N.C. GEN. STAT. § 7A-45.4
Pursuant to N.C. Gen. Stat. § 7A-45.4, Defendant Brenntag Southeast, Inc. (`Brenntag")
hereby designates the above -captioned action as a mandatory complex business case. In good
faith and based on information reasonably available, Brenntag, through counsel, hereby certifies
that this action meets the following criteria for designation as a mandatory complex business
case pursuant to N.C. Gen. Stat. § 7A-45.4(a), and should be adjudicated in the Business Court:
(1) The law governing corporations, partnerships, limited liability companies, and
limited liability partnerships.
(2) Securities law.
(3) Antitrust law, except claims based solely on unfair competition under
N.C. Gen. Stat. § 75-1.1.
x (4) State trademark or unfair competition law, except claims based solely on
unfair competition under N.C. Gen. Stat. § 75-1.1.
(5) Intellectual property law.
(6) The Internet, electronic commerce, and biotechnology.
The following is a brief explanation of why this action falls within the category of N.C.
Gen. Stat. 7A-45.4(a) checked above, as well as additional information that may be helpfal to the
#1463208_3.DOC

Court in determining whether the Business Court should retain jurisdiction of this matter:
1. This case is based on the alleged breach by Defendants Randall F. Andrews
("Andrews"), Alchem Incorporated ("Alchem") and Industrial and Agricultural Chemicals
Incorporated ("IAC") (collectively, the "Andrews Defendants") of a covenant not to compete
contained in a settlement agreement and stock redemption agreement entered into between those
parties and Plaintiff Polytec, Inc. ("Polytec"). Andrews is the former president and 50%
shareholder in Polytec, and the agreement at issue arose out of a prior shareholder derivative suit
against Andrews.
2. But Polytec has expanded the scope of its action beyond just the Andrews
Defendants, asserting claims for tortious interference with contract, tortious interference with
prospective economic advantage, civil conspiracy and unfair and deceptive trade practices
against Brenntag — a competitor of Polytec's in the chemical business — and others, none of
whom were parties to the prior litigation or the agreement at issue.
3. By this suit, Polytec seeks to recover damages from Brenntag and the other
Defendants and/or to enjoin Brenntag and the other Defendants from future competition, based
on the agreement between Polytec and its former president, Andrews. Specifically, Polytec
claims, inter alia, that Brenntag, its competitor, is liable to it in damages and/or subject to
permanent injunction to the extent that Brenntag has allegedly been supplied materials by (i) the
Andrews Defendants, who were parties to the agreement with Polytec, and/or (ii) Defendant Pure
Water Technologies, LLC, a third -party entity with which Polytec does not even claim to have
any non -compete agreement.
4. The resolution of this case involves several material issues of state unfair
competition law including, inter alia, the enforceability and/or applicability of the non -compete
#1463208_3.DOC
2

agreement in question to the challenged business transactions; the extent to which a non -compete
can bind parties not in privity with the plaintiff, including the plaintiff's competitors in the
marketplace; and the extent to which the justification of legitimate market competition provides
a defense to claims of tortious interference.
5. The North Carolina Business Court regularly hears and decides matters involving
issues similar to those likely to be the focus of this dispute. See, e.g., Covenant Equip. Corp. v.
Forklift Pro, Inc., 2008 NCBC 10 (N.C. Super. Ct. 2008) (involving claims for, among other
things, breach of a restrictive covenant, tortious interference with contract, civil conspiracy,
unfair/deceptive trade practices); Better Bus. Forms & Prods. v. Craver, 2007 NCBC 34 (N.C.
Super. Ct. 2007) (involving claims for, among other things, breach of a restrictive covenant,
tortious interference with contract, punitive damages, unfair/deceptive trade practices and
injunctive relief); Digital Recorders, Inc. v. McFarland, 2007 NCBC 23 (N.C. Super. Ct. 2007)
(denying injunctive relief to enforce covenant not to compete and involving claims for, among
other things, tortious interference with contract, breach of contract and unfair and deceptive trade
practices).
6. The Complaint in this case was filed on October 9, 2009 and served on Brenntag
on October 19, 2009, so this Notice of Designation is timely pursuant to N.C. Gen. Stat. § 7A-
45.4(d)(3).
A copy of all pleadings listed in N.C. R. Civ. P. 7(a) that have been filed to date in this
action are attached hereto as Appendix A for the convenience of the Court. For the foregoing
reasons, Brenntag designates this action as a mandatory complex business case, which should be
adjudicated in the North Carolina Business Court.
#1463208_3.DOC
3

' it
Respectfully submitted this 131h day of November, 2009.
SMITH, ANDERSON, BLOUNT, DORSETT,
MI-'CHaL , L.L.P.
K! Alan Parry
N.C. State Bar N .: 31343
Jang H. Jo
N.C. State Bar No.: 86
2500 Wachovia Capitol Center
Post Office Box 2611
Raleigh, NC 27602-2611
Phone: [phone]
Fax: [phone]
ap arry@,smithlaw. com
jio(a)smithlaw.com .
ATTORNEYS FOR DEFENDANT BRENNTAG
SOUTHEAST, INC.
#1463208_3.DOC

CERTIFICATE OF SERVICE
This is to certify that the foregoing Notice of Designation has been served on all parties
by regular mail, addressed as follows, with email copies provided to counsel of record:
Greg C. Ahlum
Kerry L. Traynum
Johnston, Allison & Hord, P.A.
Attorneys for Plaintiff Polytec, Inc.
P.O. Box 36469
Charlotte, NC 28236
ahg lumQjahlaw.com
ktrg:[e-mail]
Sean C. Walker
Woodson, Sayers, Lawther, Short,
Parrott, Walker & Abramson, L.L.P.
Attorneys for Defendants Randall F. Andrews, Alchem Inc., and
Industrial & Agricultural Chemicals, Inc.
225 North Main Street, Suite 200
Post Office Box 829
Salisbury, NC 28145-0829
[e-mail]
Defendant Pure Water Technologies, LLC
c/o Denise K. Wolcott, Registered Agent
Defendant Denise K. Wolcott
Defendant Robert Wolcott
3105 Sides Road
Rockwell, NC 28138
This is to further certify that the foregoing Notice of Designation has been served on the
Chief Justice of the North Carolina Supreme Court and the Chief Judge of the North Carolina
Business Court by email directed as follows:
Hon. Sarah Parker, Chief Justice
North Carolina Supreme Court
Attn: David Hoke, [e-mail]
Hon. Ben F. Tennille, Chief Judge
North Carolina Business Court
Attn: Julie Hol
This the 13th day of November, 2009.
##1463209 3.DOC
5

STATE OF NORTH CAROLINA
COUNTY OF IREDELL
)
POLYTEC, INC. }
Plaintiff, )
VS. }
RANDALL F. ANDREWS; ALCHEM ,
INCORPORATED; } INDUSTRIAL & )
AGRICULTURAL CHEMICALS, }
INCORPORATED; BRENNTAG
SOUTHEAST, INC.; PURE WATER
TECHNOLOGIES, LLC; DENISE K. )
WOLCOTT and ROBERT WOLCOTT,
}
Defendants. }.
IN THE GENERAL COURT OF JUSTICE
SUPERIOR COURT DIVISION
09-CVS-
COWLAINi'
(Jury Triad Demand
COMES NOW, Plaintiff PoIytec, Inc., complaining of the Defendants and alleges and
says as follows:
PARTIES AND TURISDICUON
1. Polytec, Inc. C.'Polytec") is a corporation organized and existing under the laws of
the State of North Carolina and has its place of'business and principal office at 191 Barley Park
Lane, Mooresville, Iredell County, North Carolina.
2. Upon information and belief, Defendant Randall F. Andrews ("Andrews"), is a
citizen and resident of Robeson County, North Carolina.
3. Alchem Incorporated ("Alchem") is a corporation organized and existing under
the laws of the State of North Carolina. Andrews is the registered agent for service of process
upon Alchem.
483828 v.3
25921.900I

0
4. Upon information and belief, Industrial and Agricultural Chemicals, incorporated
("IAC") is a corporation organized and existing under the laws of the State of North Carolina.
Andrews is the registered agent for service of process upon IAC.
5. Upon information and belief, Brenntag Southeast, Inc. ("Brenntag"), is a
corporation organized and existing under the laws of the State of North Carolina and having an
office and principal place of business in Durham County, North Carolina. CT Corporation
System is the registered agent for service of process upon Brenntag.
6. Upon. information and belief, Pure Water Technologies, LLC ("Pure Water"), is a
North Carolina limited liability company. Denise K. Wolcott is the registered agent for service
of process upon Pure Water.
7. Upon information and belief, Denise K. Wolcott ("D. Wolcott"), is a citizen and
resident of Rockwell, Rowan County, North Carolina. At all times relevant hereto, Wolcott was
an employee of AIchem or IAC and was the manager for Pure Water.
8.- Upon information and belief, Robert Wolcott ("R. Wolcott" or, with D. Wolcott,
the "Wolcotts"), is a citizen and resident of Rockwell, Rowan County, North Carolina. At all
times relevant hereto, Wolcott was an employee of Alchem or IAC and Pure Water.
NATURE OF THIS ACTION
9. Paragraphs 1 through 8 above are incorporated herein by reference.
10. By this Complaint, Polytec seeks (1) to enforce against Andrews, IAC and
Alchem a covenant not to compete ("Non -Competition Covenant") contained in a settlement
agreement and stock redemption agreement between Polytec and Andrews, IAC and Alchem (the
"Settlement Agreement"), and also seeks to enjoin Co -Defendants, Brenntag, Pure Water and the
Wolcotts from assisting Andrews, Alchem and IAC from violating the Non -Competition
Covenant.
483828 v.3 2

11. By this Complaint, Polytec also seeks the following additional relief:
a. Equitable tolling of the applicable term of the Non -Competition Covenant
from the date of the last breach of that Covenant by Defendants Andrews, IAC and/or
Alchem;
b. Permanent injunctive relief preventing Andrews, IAC and Alchem from
violating the Non -Competition Covenant, directly or indirectly through Brenntag, Pure
Water and/or the Wolcotts during the term of the Non -Competition Covenant as equitably
tolled;
C. Damages from Andrews, IAC and/or Alchem resulting from their breaches
of contract and unfair and deceptive trade practices including, but not limited to, recovery
from and full forfeiture by Andrews of monies paid to Andrews for redemption of his
stock, including damages up to three and half million dollars ($3,500,000.00);
d. Claims against Brenntag, Pure Water and the Wolcotts for Tortious
Interference with Contract; and
e. Claims against the Defendants for Tortious Interference with Prospective
Economic Advantage and Civil Conspiracy.
BACKGROUND INFORMATION
Creation and Initial Operation of Polytee
12. Paragraphs 1 through 11 above are incorporated herein by reference.
13. Polytec was incorporated on or about August 22, 1994.
14. Polytec is primarily engaged in the distribution of chemicals and equipment used
for clarification and purification of water.
483828 v.3

15. Immediately after the incorporation of Polytec, Jack Harmon became the owner of
five hundred (500) shares of Polytec stock, which at the time represented fifty percent (50%) of
the outstanding stock of Polytec.
16. Immediately after the incorporation of Polytec, Andrews became an owner of five
hundred (500) shares of Polytec stock, which at the time represented fifty percent (50%) of the
outstanding shares of Polytec.
17. Andrews was the President and an officer of Polytec from the date of Polytec's
incorporation until on or about October 31, 2006 when Polytec purchased and Andrews sold all
of Andrews' stock in Polytec.
18: Andrews was at no time a full-time employee of polytec.
19. While a shareholder of Polytec and serving as an officer and President of Polytec,
Andrews had an ownership interest in and operated and worked for Alchem and/or IAC.
20. IAC and Alchem are in the chemical business and are competitors of Polytec.
Prior Lawsuit (Iredell County Case No • 05-CVS-2446) and Settlement Agreement
21. On or about September 21, 2005, Jack W. Harmon, derivatively and in the right of
Polytec, Xnc., commenced a shareholders derivative action against Andrews in Iredell County
Superior Court, Case No. 05-CVS-2406 entitled Jack W. Harmon, derivatively in the right of
Polytec, Inc. and individually, v. Randall F..Andrews" (hereinafter referred to as "Shareholder
Derivative Lawsuit''.)
22. The nature of the Shareholder Derivative Lawsuit filed against Andrews included,
but was not limited to, claims against Andrews resulting from his conversion of Polytec's and
Harmon's property, damages resulting from Andrews' constructive fraud and unfair and
deceptive trade practices and preliminary and permanent injunctive relief against Andrews
483828 v.3 • 4

preventing Andrews from stripping Polytec of its assets and converting valuable corporate assets
of Polytec for his own individual use and benefit.
23. The Shareholder Derivative Lawsuit also included the following claims against
Andrews:
a. Shareholder's derivative action against Andrews for breach of fiduciary
duties of good faith, loyalty and due care;
b. Breach of fiduciary duties and constructive fraud;
C. Unfair and deceptive trade practices;
d. Conversion;
C. Inspection and copying of Polytec records in possession, custody and
control of Andrews;, and
f. Requests for preliminary and permanent injunctive relief.
24. AlIegations supporting the claims against Andrews filed in the Shareholder
Derivative Lawsuit included, but were not limited to, the following:
a. On or about April 18, 2002, Andrews wrote a check to himself from
Polytec in the amount of one hundred and seventy-one thousand thirty-one dollars and
twenty cents ($171,031.20) without obtaining Board approval for the issuance of the
Polytec check and without obtaining Harmon's approval to issue the check;
b. On or about December 31, 2002, Andrews instructed Paychecks, the
company handling Polytec's payroll, to issue a check to the Internal Revenue Service on
behalf of Andrews in the amount of one hundred eight thousand, six hundred twenty-two
dollars ($108,622.00) without obtaining Board approval for theissuace ofholnPytec
check and without obtaining Harmon,s approval to issue the check; j
i
i
483828 v.3 5

C. Harmon did not learn that Andrews unilaterally and without authorization
took two hundred seventy-nine thousand, six hundred fifty-three dollars and twenty cents
($279,653.20) from Polytec during calendar year 2002 until January 2003;
d. On or about March 3, 2003, Andrews wrote himself a check from Polytec
for thirty thousand dollars ($30,000.00) and designated this as a loan in Polytec's General
Ledger. The thirty thousand dollar ($30,000.00) loan was not approved by Harmon;
e. On March 31, 2004, Andrews unilaterally paid himself an additional two
hundred twenty-two thousand, six hundred one dollars and eighty cents ($222,601.80)
from Polytec. Andrews directed his wife to write and Andrews' wife wrote a check from
Polytec's account to Andrews in the amount of $222,601.80. Andrews did not obtain
Board approval nor did he notify or inform Harmon that he was having his wife to write
him a check in the amount of $222,601.80;
f. in addition to the check for two -hundred and twenty-two thousand,
six -hundred one dollars and eighty cents ($222,601.80), on or about April 7, 2004,
Andrews also instructed Polytec to pay the Internal Revenue Service sixty-six thousand,
seven hundred and ninety-six dollars and forty cents ($66,796.40) on behalf of Andrews.
Andrews did not obtain approval from the Polytec board or from Harmon to approve the
payment of sixty-six thousand, seven hundred ninety-six dollars and forty cents
($66,796.40) by Polytec to the Internal Revenue Service on behalf of Andrews;
g. Andrews removed from Polytec, by way of five separate checks made
payable to Andrews and/or the Internal Revenue Service for and on behalf of Andrews,
an amount equal to approximately seven hundred ninety-five thousand dollars
($795,000.00), plus unapproved loans in an amount equal to approximately eighty
483828 v.3 6

thousand dollars ($80,000.00) without Board approval and without approval or
knowledge of Harmon;
h. Despite repeated requests by Harmon to audit Polytec's books, Andrews
refused to allow Harmon to audit the books of Polytec;
i. Andrews threatened employees of Polytec that unless they purchased
chemicals from his company, Alchem, that they would be terminated;
j. Andrews also demanded that Polytec utilize other products and services
provided by Alchem and/or Andrews' other company, IA.C;
k. While attending sales meetings at Polytec and learning of Polytec's plans
concerning the sale of chemicals, Andrews, through his other company, Alchem, directly
I
and indirectly competed against Polytec and solicited customers of Polytec on behalf of
Alchem; and
1. Specific allegations were made in the Shareholder Derivative Lawsuit
concerning calcium hydroxide, which is also known as "lime slurry",
25. On September 28, 2004, an order for Preliminary Injunction was entered against
I
Randall Andrews in the Shareholder Derivative Lawsuit. A true, accurate and genuine copy of
I
the Preliminary Injunction entered against Andrews in the Shareholder Derivative Lawsuit is
marked as Exhibit "A" and attached hereto.
26. After protracted litigation, Harmon, Polytec, Andrews, Alchem and 1AC entered
into the Settlement Agreement on October 31, 2006.
27. Alchem and 1AC were joined in the Settlement Agreement solely for the purposes
of being a party to the non -competition and non -solicitation portions of the Settlement
Agreement and acknowledging that Andrews had an ownership and controlling interest in
Alchem and IAC. The agreement of Alchem and 1AC to be subject to the terms of the non-
483828 v.3
i

competition and non -solicitation provisions of the Settlement Agreement was consideration for
Polytec's agreement to the terms of the Settlement Agreement.
28. A true, accurate and genuine copy of the Settlement Agreement, dated
October 31, 2006 entered into between Harmon, Polytec, Andrews, IAC and Alchem is marked
as Exhibit `B", and attached hereto.
29. Under the terms of Settlement Agreement, Polytec purchased and Andrews sold,
all of Andrews' stock in Polytec for three million, five hundred thousand dollars
($3,500,000.00), which amount was paid to Andrews by Polytec.
30. In exchange for redemption by Polytec of Andrews' stock in Polytec for three
million, five hundred thousand dollars ($3,500,000.00), Andrews, IAC and Alchem entered into
the Settlement Agreement that included, among other things, the Non -Competition Covenant.
31. The Non -Competition Covenant is set forth in Paragraph 5(a) of the Settlement
Agreement.
32. The Non -Competition Covenant provides in part that for a period of three (3)
years after the Closing Date (October 31, 2006), Andrews shall not, without the express written
consent of Polytec, own, manage, operate, control or acquire an equity interest in (excepting
ownership in any entity which is publicly traded), or be a partner, principle, director, officer,
employee of, or in any other material capacity, engage, participate, or become affiliated or
connected in any material business relationship with any Competing Business which competes
with the business of Polytec.
33. The definition of "Competing Business" is specifically set forth in Paragraph 5(a)
of the Settlement Agreement and is defined as follows:
For purposes herein, "Competing Business" shall mean the providing and selling
of any of the following chemical products to municipal and industrial wastewater
483928 v.3 8

treatment facilities for wastewater treatment purposes (other than sales to
Polytec):
i) water soluble polymer, and water soluble polymer blends
with aluminum sulfate, aluminum chloride, ferric sulfate,
ferric chloride, and aluminum chlorohydrate,
ii) nutrients for bacteria in wastewater that include sources of
nitrogen, phosphorus, BOD or carbon, including aU
products that are carbon sources that will enhance the
denitrifi.cation of wastewater,
iii) ' . products to mask odors,
iv) products to -increase inorganic nutrients in wastewater such -
as copper, manganese, iron, magnesium, cobalt and
molybdenum, and
v) defoamers.
It is agreed that Andrews may sell calcium or magnesium products, other than
those used for the neutralizing potable water. Andrews shall be permitted to sell
calcium hydroxide for wastewater use only to customers other than the existing
customers of Polytec on the effective date hereof. In addition, Alchem agrees that .
it shall not manufacture alkalinity products for potable water or for wastewater
application through a manufacturing method that uses a Porta Batcher.
34. Paragraph 5(b) includes a non -solicitation covenant pursuant to which Andrews
agreed not to solicit any employees of Polytec for a period of three years from the Closing Date.
35. Pursuant to Paragraph 5(c) of the Settlement, Agreement, IAC and Alchem
acknowledged as signators and parties to the Settlement Agreement that they are entities that are
related, either directly or indirectly, to Andrews and the non -competition and non -solicitation
provisions of the Agreement shall be binding upon them to the same full force and effect as they
are binding upon Andrews.
36. On or about October 31, 2006, Polytec, in accordance with the terms of the
Settlement Agreement, purchased all of Andrews' stock in Polytec for three million, five
hundred thousand dollars ($3,500,000.00). A true, accurate and genuine copy of the Closing
483828 v,3 9

Statement evidencing the redemption purchased and/or payment of Andrews' stock in Polytec is
marked as Exhibit "C" and attached hereto.
37. On October 31, 2006, the effective date of the Settlement Agreement, the City of
Monroe and Nestle were existing customers of Polytec,
Violation of Settlement Agreement
38. In July 2008, Polytec suspected that Andrews, IAC and/or Alchem were violating
the Non -Competition Covenant by selling calcium hydroxidellime slurry to one of Polytec's
existing customers, Smithfield Foods, located in Tarheel, North Carolina, by partnering or
engaging in a business relationship with Co -Defendant Brenntag.
39. Upon learning of the sales to Smithfield Foods, Polytec notified Andrews, IAC,
Alchem and Brenntag that such actions were in violation of the Non -Competition Covenant
contained in the Settlement Agreement.
40. By letter dated July 21, 2008, Polytec, through its attorneys, sent a letter to
Andrews, IAC and/or Alchem demanding that they immediately cease and desist any attempts,
directly or indirectly, through Brenntag to sell calcium hydroxide to Polytec customers, including
Smithfield Foods.
41. Upon information and belief and based upon an August 15, 2008 letter, Andrews,
IAC and Alchem authorized its attorneys to address the concerns raised by Polytec in the
July 21, 2008 letter,
42. The August 15, 2008 letter from. Andrews' attorney in response to Polytec's
July 21, 2008 letter states in part as follows:
"As to the first matter concerning the allegation of the sale of calcium hydroxide
products to Smithfield Foods, your client (Polytec) can be assured that neither
Randall Andrews, individually, IAC or Al (Alchem) has attempted to or intends
to sell calcium hydroxide products to Smithfield Foods or to Brenntag in
contravention of the Settlement Agreement. At no relevant time have Randall
483M v.3 10

Andrews, individually, IAC or AI engaged or partnered, or intended to engage
or partner, in any business relationship with Brenntag with respect to Smithfield
Foods. Further, to that end, neither Randall Andrews, individually, IAC or AI
have or intend to deliver any calcium hydroxide products to Smithfield Foods."
43. Andrews, also through his attorney, denied having any involvement, ownership
interest or affiliation in any manner whatsoever with Pure Water Technologies, LLC.
44. Polytec believed the statements and representations made by and on behalf of
Andrews, IAC and Alchem set forth in the August 15, 2008 letter.
45. A true and accurate copy of the August 15, 2008 letter authorized by Andrews,
IAC and Alchem in response to Polytec's claim and concerns relating to the sale of calcium
hydroxide/lime slurry through a partnership or business relationship with Brenntag is marked as
Exhibit "D" and attached hereto.
The City of Monroe
46. On or about May 6, 2009, Polytec's existing customer, the City of Monroe, North
Carolina, requested bids to supply the City of Monroe with calcium hydroxide/lime slurry for its
waste water treatment plant.
47. At the time the City of Monroe submitted for public bid its solicitation for the
supply of calcium hydroxide for use in its waste water treatment plants, Polytec was the current
supplier of calcium hydroxide to the City of Monroe.
48. At the time the City of Monroe submitted for public bid its solicitation for the
supply of calcium hydroxide for use in its waste water treatment plants, Polytec had been
supplying calcium hydroxide to the City of Monroe at the price of $.05 per pound.
49. In response to the City of Monroe's request for bid, Alchem and IAC submitted a
bid to supply calcium hydroxide/lime slurry to the City of Monroe.
483828 0 11

50. When the City of Monroe discovered that Andrews, Alchem and IAC had entered
into a Settlement Agreement with Polytec that included a Non -Competition Covenant as part of
Andrews' sale of his stock to Polytec, Alchem and IAC immediately withdrew their bid to
supply calcium hydroxide to the City of Monroe.
51. The City of Monroe then awarded the contract to supply calcium hydroxide to the
City of Monroe's waster water treatment facility to Brenntag for $.0499 per pound.
52. Brenntag did not produce the calcium hydroxide it supplied to the City of Monroe
pursuant to its contract.
53. instead, Andrews and Alchem entered into a business relationship and/or
partnership with Brenntag to use Brenntag as a third -party conduit to supply calcium hydroxide
to the City of Monroe.
54. Alchem supplied its calcium hydroxide to Brenntag which in turn sold the
calcium hydroxide to the City of Monroe.
55. Marked as Exhibit "B" and attached hereto is a true, accurate and genuine
photograph of Alchem's truck delivering calcium hydroxide to the City of Monroe on July 11,
2009 for and on behalf of Brenntag.
56. The City of Monroe confronted Brenntag when it learned that Brenntag was
supplying the City of Monroe with calcium hydroxide from Andrews and Alchem, In response,
Brenntag informed the City of Monroe that it had inadvertently ordered the calcium hydroxide
from. Alchem by mistake but that it would no longer purchase its calcium hydroxide from
Alchem.
57. The City of Monroe asked Brenntag to accurately complete its chemical tracking
sheet for all future shipments of calcium hydroxide.
483828 v.3 12

58. The next shipment of calcium hydroxide delivered to the City of Monroe from
Brenntag came from Alchem's facility but was delivered on a different truck.
59. Brenntag, when filling out the City of Monroe's chemical tracking sheet, used a
post office box in Rockwell, North Carolina ("P.O. Box 118, Rockwell, North Carolina 28138")
as the plant address for the facility from which it obtained the calcium hydroxide.
60. The post office box used by Brenntag on the City of Monroe chemical tracking
sheet is the post office box for Pure Water.
61. Pure Water is a limited liability company formed by two employees of Alchem,
Denise K. Wolcott and her husband, Robert Wolcott, A third employee of Alchem, Trent
Tidwell, also works for Pure Water,
62. Pure Water does not manufacture calcium hydroxide.
63. The calcium hydroxide supplied to the City of Monroe by Brenntag was coming
from Alchem.
64. In an attempt to further cover up the fact that Alchem was supplying the City of
Monroe with calcium hydroxide, Andrews and Alchem sold the calcium hydroxide to Pure
Water, who then sold it to Brenntag who then delivered it to the City of Monroe.
65. Brenntag is obtaining calcium hydroxide or has received calcium hydroxide from
Alchem and has delivered it to the City of Monroe.
66. Pure Water and/or the Wolcotts have obtained calcium hydroxide from Alchem,
sold it to Brenntag, who in turn sold and delivered it to the City of Monroe.
67. Andrews, Alchem and IAC are using third party "straw men" Brenntag and Pure
Water and/or the Wolcotts to indirectly sell calcium hydroxide to the City of the' Monroe in
violation of the Non -Competition Covenant contained in the Settlement Agreement.
483828 v,3 13

68. Upon learning further information concerning the relationship between Andrews,
Alchem, IAC, Pure Water and Brenntag, the City of Monroe discontinued its relationship with
Brenntag and began purchasing lime slurry from. Polytec as it previously had done.
69. Brenntag knew that it was a violation of the Non -Competition Covenant by
Andrews, Alchem and/or IAC for Brenntag to supply to the City of Monroe calcium hydroxide
obtained from Andrews, Alchem and/or IAC.
70. Pure Water and the Wolcotts knew that it was a violation of the Non -Competition
Covenant by Andrews, Alchem and/or IAC for Pure Water or the Wolcotts to supply to the City
of Monroe calcium hydroxide obtained from Andrews, Alchem and/or IAC.
71. Polytec lost at -least $4500.00 in profit during the time in which Brenntag supplied
to the City of Monroe calcium hydroxide obtained from Andrews, Alchem and/or IAC.
Nestle
72. Nestle Frozen Food Company (,,Nestle") was an existing customer of Polytec on
October 31, 2006, the effective date of the Settlement Agreement,
73. Upon information and belief, in or around July 2008, Brenntag began marketing
sales of calcium hydroxide and other waste treatment products to Nestle, an existing customer of
Polytec, located in Gaffney, South Carolina,
74, In the course of Brenatag's marketing efforts to Nestle, Brenntag used Trent
Tidwell, an employee of Pure Water and Alchem, to act as Brenntag's agent to review and assess
Nestle's facility and product needs.
75, Upon information and belief, Andrews, Alchem and/or IAC agreed to provide
Brenntag with equipment, chemicals and expertise to be used in Brenntag's bbsiness proposals to
Nestle and otherwise assist Brenntag with such proposals.
483M v.3 14

76. Upon information and belief, Brenntag conducted equipment and chemical trials
for Nestle with the assistance of Andrews, Alchem and/or IAC, beginning in July 2008.
77. In February 2009, Nestle executed an equipment loan agreement with Polytec
wherein Nestle agreed to allow Polytec to perform certain upgrades to their calcium hydroxide
chemical feed systems- and Polytec would loan certain equipment to Nestle for use in its waste
water treatment activities (the "Equipment").
78. Upon information and belief, Brenntag, with the assistance of Andrews, Alchem
and/or IAC, performed another series of equipment and chemical trials for Nestle in late
February 2009 at or around the same time that Nestle executed the equipment loan agreement.
79. Nestle cancelled the equipment loan agreement approximately 2 weeks after its
execution and requested a new proposal from Polytec for an outright purchase of the Equipment
described in the equipment loan agreement. Nestle subsequently requested a proposal that would
include Polytec's installation of the Equipment and allow for Nestle's outright ownership of the
Equipment within one year of installation.
80. Upon information and belief, Brenntag, with the assistance of Andrews, Alchem
and/or IAC, offered Nestle outright ownership of certain calcium hydroxide chemical feed and
storage equipment at the end of one year in exchange for agreeing to provide Brenntag with
business related to purchase of calcium hydroxide, polymers and other products and allowing
Brenntag to install the equipment.
81. Upon information and belief, Andrews, Alchem and/or IAC agreed to provide
Brenntag with any equipment or chemicals that were included in Brenntag's proposal to Nestle. .
82. On or about July 6, 2009, Nestle notified Polytec that it would be purchasing all
of its calcium hydroxide and polymers from Brenntag and that it would no longer be purchasing
calcium hydroxide and polymers from Polytec.
483828 v.3 15

83. Nestle informed Polytec that Brenntag furnished calcium hydroxide chemical feed
and storage equipment to Nestle for use with the calcium hydroxide as part of the calcium
hydroxide program. Nestle also informed Polytec that it would own the calcium hydroxide
chemical feed and storage equipment supplied by Brenntag within one (1) year.
84. Upon information and belief, the calcium hydroxide chemical feed and storage
equipment supplied to Nestle by Brenntag came from Alchem.
85. Upon information and belief, Alchem and Brenntag collaborated in developing
and designing Nestle's new calcium hydroxide program for Nestle's waste water treatment plan.
86. Upon information and belief, Andrews, Alchem and/or LAC has a business
relationship with Brenntag and is supplying calcium hydroxide, polymers and other products to
Brenntag for sale to Nestle.
87. Upon information and belief, Andrews, Alchem and/or LAC has a business
relationship with Pure Water and/or the Wolcotts and is supplying calcium hydroxide to Pure
Water and/or the Wolcotts who in turn is supplying that calcium hydroxide to Brenntag for sale
to Nestle.
88. On August 10, 2009, a private investigator, Tom Rose, performed surveillance at
the Alchem facility in Rockwell, North Carolina and witnessed a truck and trailer depart the
Alchem facility at approximately 9:54 a.m. "Paul M. Bost" appeared on the doors of the truck
(the `Bost Truck").
89. Also on August 10, 2009, Paul Schroll, another private investigator working in
conjunction with Tom Rose performed surveillance at the Nestle facility in Gaffney, SC. At
approximately 11:35 a.m., Mr. Schroll witnessed the same Bost Truck previously seen departing
from the Alchem facility by Mr. Rose arrive at the Nestle facility.
483828 v.3 16

90. After apparently delivering a load of certain materials from Alchem to Nestle, the
Bost Truck exited the Nestle facility at approximately 1:18 p.m. and returned to the Alchem
facility at approximately 3:02 p.m.
91. Upon information and belief, Alchem, Brenntag, Pure Water and/or the Wolcotts
have been providing supplying calcium hydroxide to Nestle, directly or indirectly, for at least
two (2) months.
92. During the same two (2) month period in which Alchem, Brenntag, Pure Water
and/or the Wolcotts have been supplying, directly or indirectly, calcium hydroxide to Nestle,
Nestle has not purchased from Polytec any of the products it was previously purchasing.
93. As a result of the actions of Alchem, Brenntag, Pure Water and/or the Wolcotts
related to Nestle, Polytec has suffered lost sales.
94. Brenntag knew that it was a violation of the Non -Competition -Covenant by
Andrews, Alchem and/or IAC to supply to the Nestle facility in Gaffney, South Carolina calcium
hydroxide obtained from Andrews, Alchem and/or IAC or to otherwise assist Brenntag in its
competition with Polytec.
95. Pure Water and the Wolcotts knew that it was a violation of the Non -Competition
Covenant by Andrews, Alchem and/or IAC to supply to the Nestle facility in Gaffney, South
Carolina calcium hydroxide obtained from Andrews, Alchem and/or IAC or to otherwise assist
Pure Water and the Wolcotts in their competition with Polytec.
96. Polytec has satisfied all conditions precedent to the Settlement Agreement,
FIRST CAUSE OF -ACTION
(Breach of Contract/Breach of Covenant Not To Compete)
97. Paragraphs 1 through 96 above are incorporated herein by reference.
483828 0 17

98. The Settlement Agreement constitutes a valid and binding agreement between
Polytec and Andrews, IAC and Alchem.
99. Under the terms of the Settlement Agreement, Andrews, IAC and Alchem had
obligations not to own, manage, operate, control or acquire an equity interest in (excepting
ownership in any entity which is publicly traded), or be a partner, principle, director, officer,
employee of, or in any other material capacity, engage, participate, or become affiliated or
connected in any material business relationship with any Competing Business which competes
with the business of Polytec.
100. By directly supplying or indirectly supplying through a business relationship with
Brenntag and/or Pure Water calcium hydroxide to Smithfield Foods, the City of Monroe, Nestle
or any other existing client of Polytec, Andrews, IAC and/or Alchem has breached the
Settlement Agreement.
101. The Non -Competition Covenant contained in the Settlement Agreement is
_ reasonable and valid.
102. The actions of Andrews, IAC and/or Alchem described herein constitute breaches
of the Settlement Agreement.
103. The actions of Andrews, IAC and or Alchem in breaching the Settlement
Agreement, including the routing of sales to existing customers of Polytec to Brenntag, either
directly or .indirectly through Pure Water and/or the Wolcotts, constitute malicious breaches of
the Settlement Agreement.
104, As a result of the breaches of the Settlement Agreement by Andrews, IAC and
Alchem, Polytec has been damaged in the loss of sales, profits and goodwill it would have
otherwise realized from business opportunities with the City of Monroe, Nestle and other
existing customers of Polytec.
483828 v3 18

105. Polytec is entitled to damages for the lost sales and profits from existing
customers resulting from the breaches of the Settlement Agreement by Andrews, Alchem and
IAC.
106. In the alternative to the permanent injunction/equitable tolling claim for relief
requested below, Polytec is entitled to damages in the amount of three mullion five hundred
thousand dollars ($3.5 million) or some portion thereof as a result of the breaches of the
Settlement Agreement by Andrews,1AC and Alchem.
SECOND CAUSE OF ACTION
(Tortious Interference with Contractual Relations)
107. Paragraphs 1 through 106 above are incorporated herein by reference.
108. The Settlement Agreement is a valid and enforceable .contract between Polytec
and Andrews, IAC and Alchem pursuant to which Polytec had contractual rights concerning,
among other things, a prohibition against direct or indirect competition by Andrews, IAC or
Alchem
109. Brenntag, Pure Water and/or the Wolcotts had knowledge of the Settlement
Agreement and the obligations of Andrews, IAC or Alchem thereunder, including the obligations
related to the Non -Competition Covenant.
110. Brenntag, Pure Water and/or the Wolcotts intentionally induced Andrews, IAC or
Alchem not to perform the Non -Competition Covenant obligations under the Settlement
Agreement.
M. Neither Brenntag, Pure Water nor the Wolcotts had justification for inducing
Andrews, IAC or Alchem to breach the Settlement Agreement.
483828 v3 19

112. The actions of Brenntag, Pure Water and/or the Wolcotts were malicious and
designed to deprive Polytec of its bargained -for contractual rights with Andrews, Alchem and
1A.C.
113. As a result of the actions of Brenntag, Pure Water and/or the Wolcotts as alleged
herein, Polytec has suffered damages in an amount exceeding $10,000.00.
T1HRD CAUSE OF ACTION
(Torturous Interference with Prospective Economic Advantage)
114, Paragraphs 1 through 113 above are incorporated herein by reference.
115. At the time that the Defendants began supplying materials, directly or indirectly,
to the City of Monroe and Nestle, the City of Monroe and Nestle were existing customers of
Polytec.
116. The Defendants knew that the City of Monroe and Nestle were existing customers
of Polytec.
11'1. Andrews, IAC and Alchem knew of the materials prices that Polytec used in
providing materials to the City of Monroe and Nestle.
118. Pure Water, the Wolcotts and Brenntag have concealed the nature of their
relationships with Andrews, IAC and Alchem from the City of Monroe and Nestle.
119. The actions of the Defendants were without justification.
120. The actions of the Defendants were malicious and unlawful and designed to gain
an advantage at the expense of Polytec.
121. . As a result of the Defendants' actions, the City of Monroe was induced to refrain
from entering into or continuing a contract with Polytec for calcium hydroxide.
122. As a result of the Defendants' actions, Nestle was induced to refrain from entering
into or continuing a contract with Polytec for wastewater purification materials.
483828 v3 20

123. But for the actions of the Defendants, the City of Monroe would have entered into
or continued a contract with Polytec for the supply of calcium hydroxide and Polytec has been
damaged as a result.
124. But for the actions of the Defendants, Nestle would have entered into or continued
a contract with Polytec for the supply of wastewater materials, and Polytec has been damaged as
a result.
FOURTH CAUSE OF ACTION
(Unfair and Deceptive Trade Practices)
125. Paragraphs 1 through 124 above are incorporated herein by reference.
126. Defendants' actions described herein were unethical and unscrupulous.
127. Defendants' actions described herein had the tendency to deceive and did deceive
Polytec and -existing customers of Polytec who would not have done business with Defendants
had they known the true nature of the business relationships between Brenntag, Pure Water
and/or the Wolcotts and Andrews, Alchem and IAC.
128. Defendants' unfair and deceptive actions described herein occurred in the course
of or otherwise affected commerce.,
129. Defendants' unfair and deceptive actions described herein proximately caused
injury to Polytec, including damages in excess of $10,000.00.
130. Pursuant to N.C. Gen. Stat. § 75-16, the damages proximately caused by.
Defendants' unfair and deceptive actions should be trebled.
131. Because Defendants have acted willfully and maliciously to usurp business
opportunities of Polytec and have refused to resolve this matter in a reasonable fashion, Polytec's
attorneys' fees should be taxed as court costs against Defendants pursuant to N.C. Gen. Stat. §
75-16.1.
483828 v.3 21

FIFTH. CAUSE OF ACTION
(Civil Conspiracy)
132. Paragraphs 1 through 131 above are incorporated herein by reference.
133. Upon information and belief, Defendants Andrews, IAC, Alchem, Brenntag, the
Woicotts and Pure Water agreed to and executed a common scheme to usurp business
opportunities and compete illegally with Polytec.
134. Upon information and belief, some or all of the Defendants have executed this
common scheme to usurp other business opportunities, including business opportunities with
Nestle, from Polytec by using Polytec's confidential business information and in direct
contravention of the Settlement Agreement.
135. The acts of the Defendants in carrying out their common scheme were unlawful.
136. As a result of the common scheme agreed to and executed by the Defendants,
Polytec has been injured in an amount in excess of $10,000.00.
SIXTH CAUSE OF ACTION
(Equitable Tolling and Permanent Injunction)
137, Paragraphs 1 through 136 above are incorporated herein by reference.
138. Defendants Andrews, IAC and Alchem are subject to the terms of the non -
competition and non -solicitation provisions included in the Settlement Agreement and explained
herein.
139. As described above; Defendants Andrews, 1AC and Alchem have violated the
terms of the Non -Competition Covenant of the Settlement Agreement by selling, directly and
indirectly, calcium hydroxide to existing customers of Polytec during the term of the Non -
Competition Covenant.
483828 v.3 22

140. As described above, Defendants Brenntag, Pure Water and the WoIcotts have
willingly and knowingly assisted Defendants Andrews, IAC and Alchem with their breaches of
the Non -Competition Covenant.
141. Defendants' actions in violation of or in assisting with a violation of the Non -
Competition Covenant have resulted in irreparable injury, loss, and damage to Plaintiff,
including loss of profits, loss of business opportunities, and loss of goodwill, above and beyond
the known and quantifiable damages alleged herein.
142. Plaintiffs have demanded that Defendants cease and desist from their conduct, but
they have failed and/or refused to do the same.
143. By violating the Non -Competition Covenant, Defendants Andrews, IAC and
Alchem have acted inequitably.
144. PIaintiff will not obtain the benefit of the Non -Competition Covenant so long as
Defendants continue to violate the Non -Competition Covenant or assist the violation of the Non -
Competition Covenant.
145. As a result, the term of the Non -Competition Covenant should be equitably tolled
from such time as the commencement of the most recent violation of the same by Defendants
Andrews, IAC or Alchem and shall resume again for the duration of the restrictive period only
upon Defendants Andrews, IAC and Alchem's cessation of any and all violations of the Non -
Competition Covenant, including, without limitation, supplying materials to Nestle.
146. Upon resumption of the equitably tolled term of the Non -Competition Covenant,
Defendants shall be permanently enjoined from violating or assisting with the violation of the
Non -Competition Covenant for the remainder of such term of the Non -Competition Covenant
consistent with the equitable tolling of such term as permitted by the Court.
483828 v.3 23

WHEREFORE, the Plaintiff, Polytec, Inc. respectfully requests the following relief from
this Court:
1. For an award in excess of $10,000 against Defendants based on the claims for
relief asserted herein against each of them;
2. That the damages awarded to Plaintiffs for Defendants' unfair and deceptive trade
practices be trebled pursuant to N.C. Gen. Stat. § 75-16;
3. That Plaintiff's attorneys' fees_ be taxed as court costs against Defendants
pursuant to N.C. Gen. Stat. § 75-16.1 or as otherwise allowed by law;
4. For an order temporarily, preliminarily and permanently enjoining the Defendants
from violating or assisting with the violation of the Non -Competition Covenant of the Settlement
Agreement;
5. That the term of the Non -Competition Covenant of the Settlement Agreement be
equitably tolled from such time as the commencement of the last violation of the. same by
Defendants Andrews, IAC or Alchem and shall re -commence for the remainder of the term only
upon Defendants Andrews, IAC and Alchem's cessation of any and all violations of the Non -
Competition Covenant, including, without limitation, providing materials to Nestle;
6. For a trial by jury on all issues so triable;
7. That all costs of this action be charged against Defendants; and
8. For any such further relief as the Court deems just and proper.
483828 v.3 24

THIS the � day of October, 2009.
JOHNSTON,ALLISON & FORD, P.A.
"l
Greg C. N.C. Bar No. 14o21
Kerry L. Traynum, N.C. Bar No. 32968
JOHNsToN, AuisON & HORD, P:A.
P.O. Box 36469
Charlotte, NC 28236
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
Attorneys for Plaintiff
483828 v.3 25

I kCS - Caribbean Industrial and Agricultural Chemical Services Limited -
Goats & Objectives
Services
Life SupPort EgUiPrnent
Equipment Information
Training & Certification
SERVICES OFFERED
The service offered by CIACS is quite unique. Major si
customise our services to satisfy the needs and demands of
DISPOSAL OF SPENT CATALYST
Spent Catalyst poses a problem rfo the client after it US be
along with our sister compan I,qC in the USA` have develc
dispose of spent catalyst.
Ai our company's job site in Claxton Bay, we have constru
storing 10, 000 cubic ff of material, This pit is water
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types of.cata/yst. The s
directly from the pent Catalyst never touches ot
the grd
vessel into awaiting dump trucks or storage
At the pt
the filled tr t Site dry ice is
' stored, treated which will be laced on fhe truck b
At the and prepared force poi immediated beds be sfore II
and sh pit, the spent catalv�� ..... port
the ,! p to ni),� — .
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consumption g' mr
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,.C:IACS - Caribbean Industrial and Agricultural Chemical Services Limited - Services Page 2 of 2
CIACS offers three levels of vibration screening capabilities.
material and also removes the dust and fines. The Screen uE
INERT INSPECTION AND SAMPLING
A vessel that contains a hazardous atmosphere or that m
necessary equipment for such operations.
These would include life support systems, certified personr
and the ability to provide two-way communication betw(
Technicians while carrying out inspections.
CATALYST PACKING
At CIACS, we have developed efficient methods of screenin
material to be loaded. This method in turn decreases Ic
discrepancies_._ - -
'+DISPOSAL OF HARZADOUS CHEMICAL AND LAE
We remove the chemical and lab waste from the client an(
consumption. End user certificates are issued after consump
About Us I Goals & Objectives I Services I Life Support Equipment I Equipmi
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Page - �CIACS = Caribbean Industrial-and"A:.. ;11
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- Caribbean Industrial and Agricultural
al Services Limltpr1
SERVICES OFFERED ''"-= = _ - - -
The service offered by CIACS is quite unique_ Major services are detailed below and we
customise ourservices to satisfythe needs and demands of our customers_
DISPOSAL OF SPENT CATALYST
Spent Catalyst poses a problem forthe client after it has been removed from the vessel_ CIACS
along with our sister company IAC in the USA have developed an environment safe solution to
dispose of spent catalyst.
At our company's job site in Claxton Bay, we have constructed a Catalyst pit that is capable of
storing 10,000 cubic ft of material. This pit is water tight and can be partitioned to store up to
four types of catalyst. The spent Catalyst never touches the ground at your plant as it is
vacuumed directly from the vessel into awaiting dump trucks or storage containers.
At the Plant Site dry ice is placed on the truck beds before loading up the catalyst, then on top of
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iACS - Caribbean Industrial and Agricultural Chemical Services Limited - Services Page 1 of 2
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SERVICES OFFERED
The service offered by CIACS is quite unique. Major sf
customise our services to satisfy the needs and demands of
Goals & Objectives - - - -
Services DISPOSAL OF SPENT CATALYST 1
Life Support Equipment Spent Catalyst poses a problemfor_the client after it has be
along with our sister company IAC in the_USA_!gve devele
Equipment Information dispose of spent catalyst.
Training & Certification At our company's job site in Claxton Bay, we have constru
storing 10,000 cubic ft. of material. This pit is water tight and
types of catalyst. The spent Catalyst never touches the grc
directly from the vessel into awaiting dump trucks or storage
At the Plant Site dry ice is placed on the truck beds before Ic
the filled tray, which will be sealed for immediate transport
stored, treated and prepared for export.
At the pit, the spent catalyst will be oxidized by airing, skimr
and ship to our sister company IAC for consumption. End u;
the life cycle of the material.
VACUUMING
CIACS has four vacuum units, which provides clients the le
units are all capable of Nitrogen Recirculation with dust se
units, all of CIACS' units are customised for the filling of ci
these units are diesel powered and the other is a 480 Volt A(
VIBRATION SCREENING
http://ciacstt.com/services/index.php 5/14/2010