WQ0002702_Regional Office Historical File Pre 2018 (26)

SUSTAINABLE STRATEGIES FOR GLOBAL LEADERS
August 4, 2009 E
Mr. Randall Andrews
President
Alchem, Inc.
2042 Buie Philadelphus Rd.
Red Springs, NC 28377
Subject: Aluminum Bauxite Disposal Area Life Expectancy Calculation
Alchem, Inc.
Rockwell, North Carolina
Permit No. WQ0016388
Delta Project No. 5EO70-2101-P
Dear Mr. Andrews:
Delta Consultants (Delta) is submitting this letter report to summarize the revised life
expectancy calculations developed for the aluminum bauxite disposal area located at
the Alchem, Inc. (Alchem) facility in Rockwell, North Carolina. The following
paragraphs provide some project background as well as a description of the
methodology used to estimate the approximate life expectancy of the disposal area.
BACKGROUND INFORMATION
The Alchem facility is located at 8135 Red Road in Rockwell, Rowan County, North
Carolina on an elongated parcel of approximately 33.7 acres. The bauxite residuals
from the production process are disposed on the land surface via a monofill surface
disposal program administered by the North Carolina Department of Environment and
D E. LTA Natural Resources (NCDENR). The facility holds a permit (WQ0016388) for the
operation of the bauxite residuals monofill surface disposal program. The facility
generates approximately 2,500 tons of bauxite residuals each year that require disposal.
The facility also operates a wastewater recycle system under non -discharge permit
number WQ0002702.
The estimated life expectancy of the of the bauxite residuals disposal area was estimated
to b'i approximately- 9.5 years -in November 2007. NCDENR requested a revised life
expectancy calculation for the area to account for current topography.
PURPOSE AND METHODOLOGY
The purpose of this phase of the project was to determine an approximate life expectancy
for the bauxite residuals monofill. For the purpose of this calculation, Delta assumed that
the final grade of the disposal area will range from approximately 805 feet above mean
sea level (ft msl) to 811 ft msl along the western portion of the site, gradually sloping
toward the berm and retention pond. While the areas on the eastern side of the property
along the western side of the drainage swale and retention pond will slope at a 3 to 1 grade
from the 805 msl contour toward the retention pond. The volume between the existing
surveyed topographic contours and the new proposed contours was estimated by dividing
the disposal area into four main groups (see attached map).
XInogei
8008 Corporate Center Drive Suite 100 Charlotte, NC 28226 USA
Phone: [phone] Fax: [phone]
www.deltaenv.com

W
Mr. Randall Andrews
Alchem, Inc.
Bauxite Residuals Disposal Area Life Expectancy
Rockwell, NC
August 4, 2009
Delta Project No. 5EO70-2101-P
2of4
Area I -western side of disposal area
Currently, this area consists of mounded soil used for road maintenance and the elevation ranges from 804 ft msl to 825 ft msl.
Once the mounded soil is removed from the site, Alchem plans to use this area for disposal of bauxite residuals. For the
purpose of this estimate, it is assumed that approximately 3 feet of bauxite residuals would be placed in this area. This would
increase the elevation to 807 ft msl. The volume of this area was approximated by sketching the area on the drainage plan
generated from a recent survey into AutoCAD 2006® and then using the software to estimate the lateral area on the map. This
lateral area was then multiplied by the increase in elevation (3 ft). Using this methodology, the volume of Area I was
calculated to be approximately 1,197.66 cubic yards.
Area II — western side of disposal area, east of Area I
Area II ranges from 802 ft msl to 804 ft msl. There is a mound of soil located at the southern edge of Area II that will
leveled on site; therefore, this area will be used for disposal of bauxite residuals and has been included in the calculations.
The facility plans to add bauxite residuals until the area increases elevation by 3 ft. The new elevation in this area would
approximately range from 805 ft msl to 807 ft msl after the increase. The volume of this area was approximated by
sketching the area on the drainage plan generated from a recent survey into AutoCAD 2006® and then using the software
to estimate the lateral area on the map. This lateral area was then multiplied bye the increase in elevation (3ft). Using
this methodology, the volume of Area II was calculated to be approximately 5,730.81 cubic yards.
Area III -western side of disposal area, east of Area 77
Area III on the proposed drainage plan currently slopes from 802 ft msl to 790 ft msl in the southern portion and from 802
ft msl to 799 ft msl in the northern portion. The facility plans to level this area to an elevation of approximately 805 ft
msl for potential future use. The volume of this area was approximated by dividing this area into five sub -areas (see
attached map). For sub -areas III -A and III-E the lateral area was multiplied by the change in elevation to obtain the
volume from three foot elevation change from 802 ft msl to 799 ft msl. The lateral area was also multiplied by one half of
the of the elevation change to estimate the volume of the sloped portion up to the 802 ft msl contour. For Area III-E the
elevation change of the sloped portion is 12 ft and for Area III -A the elevation change of the sloped area is 3 ft. to obtain
volume. The sketch below represents the cross -sectional area used to approximate the volume of areas II -A and II-E.
New Proposed Grade
805 ft msl 805 ft msl
802 ft msl
790 ft msl (Area III-E)
799 ft msl (Area III -A)
Existing Grade
In the northeastern corner of Area III (sub -areas II-B, II-C, and II-D), the volume was estimated by assuming lateral
dimensions of known geometric shape (e.g. square, triangle, rectangle, etc.) and multiplying by the average increase in
elevation for the given sub -area.
Using the methodology described above, the total volume of Area III was calculated to be approximately 6,322.40 yd3.
Area IV -eastern side of disposal area, west of Area V
Area IV on the proposed drainage plan currently slopes from 790 ft msl toward the retention pond and drainage swale
with a variable slope. The facility plans to slope this area at a 3 to 1 ratio from the new 805 ft msl elevation to 791 ft msl
to provide adequate slope toward the retention pond for runoff. The volume of this area was approximated by dividing
this area into ' seven sub -areas. For sub -areas IV -A and IV-G the cross -sectional area was multiplied by the lateral
distance to obtain volume. The sketch below represents the cross -sectional area used to approximate the volume of areas
IV -A, IV-B, IV-C and IV-D.

Mr. Randall Andrews
Alchem, Inc.
Bauxite Residuals Disposal Area Life Expectancy
Rockwell, NC
August 4, 2009
Delta Project No. 5EO70-2101-P
New Proposed Grade
805 ft msl
"X" ft msl
791 ft msl
Existing Grade
3of4
For Area IV -A, the value of "X" is 799 ft msl. The value of "X" for areas IV-B, IV-C and IV-D are 798 ft msl, 795 ft
msl and 793 ft msl, respectively.
The sketch below represents the cross -sectional area used to approximate the volume of area IV-E.
New Proposed Grade
805 ft msl
793 ft msl 802 ft msl
790 ft msl
Existing Grade
The sketch below represents the cross -sectional area used to approximate the volume of area IV-F.
New Proposed Grade
802 ft msl
790 ft msl
789 ft msl
Existing Grade
Using the methodology described above, the total volume of Area IV was calculated to be approximately 1,495.31 yd3.
Area V-eastern side of disposal area, west of drainage swale and retention pond
Area V on the attached drainage plan currently slopes at a 3:1 ratio from the edge of the pond at 781 ft msl up to 790 ft
msl. There is very little available area remaining for bauxite residuals; therefore, this area was not included in the
calculations.
CONCLUSIONS
The facility reportedly generates 2,500 yd3 (assume 1 ton per cubic yard) of bauxite residuals each year. Using the
volumes calculated above, the approximate minimum life expectancy of the disposal area "is°6 years. This calculation is
meant to provide and estimate of the life expectancy of the disposal area and does_ not adcccdiurint for compaction or
variations in the amount of bauxite residuals generated. This life expectancy calculation is conservative and assumes the
density of the residuals its 1 ton per cubic yard. Also, the calculation assumes Areas 1, 11 and III will be increased to an

Mr. Randall Andrews
Alchem, Inc.
Bauxite Residuals Disposal Area Life Expectancy
Rockwell, NC
August 4, 2009
Delta Project No. 5EO70-2101-P
4of4
elevation of 805 ft msl. The calculation assumes an average existing elevation of 802 ft msl, indicating only a 3 ft
elevation increase. Variations in the existing topography and a higher final elevation would increase the life expectancy
of the disposal area. Should the generation rate increase the life expectancy of the disposal area will decrease.
Should you have any questions about this work plan or the anticipated costs please contact Gary Ribblett at (704) 543-
3910 or Stephen Walls at [phone].
Sincerely, -
DELTA ENVIRONMENTAL CONSULTANTS, INC.
�� �)'t&'
Stephen Walls, P.E.
Project Engineer
Gary C. Ribblett, P.E.
Project Manager

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SUSTAINABLE STRATEGIES FOR GLOBAL LEADERS
2 2 M November 7, 2007
D L5 15 V
2001 North Carolina Department of Environment and Natural Resources
NOV 1 3 Division of Water Quality, Aquifer Protection Section
610 East Center Avenue
NC DENR MRO Suite 301
MlAln Any iifcr PrntPrtion Mooresville, NC 28115
Attention: Mr. Andrew H. Pitner, P.G.
Regional Environmental Supervisor
Subject: Bauxite Residuals Disposal Area Life Expectancy Calculation
Alchem, Inc.
Rockwell, North Carolina
Permit No. WQ0016388
Delta Project No. 5EO70-2101-P
Dear Mr. Pitman:
Per request from your office, Delta Consultants (Delta) is submitting this letter report
on behalf of our client, Alchem, Inc., to summarize the life expectancy calculations
developed for the bauxite residuals disposal area located at the Alchem, Inc. (Alchem)
facility in Rockwell, North Carolina. The following paragraphs provide some project
+ background as well as a description of the methodology used to estimate the
approximate life expectancy of the disposal area.
BACKGROUND INFORMATION
The Alchem facility is located at 8135 Red Road in Rockwell, Rowan County, North
Carolina on an elongated parcel of approximately 33.7 acres. The facility produces
aluminum chloride and aluminum sulfate from aluminum bauxite hydrochloric acid, and
sulfuric acid. The bauxite residuals from the process are disposed on the land surface via
a monofill surface disposal program administered by the North Carolina Department of
Environment and Natural Resources (NCDENR). The facility holds a permit
(WQ0016388) for the operation of the bauxite residuals monofill surface disposal
program. The facility generates approximately 2,500 tons of bauxite residuals each year
that require disposal. The facility also operates a wastewater recycle system under non -
discharge permit number WQ0002702.
PURPOSE AND METHODOLOGY
The purpose of this phase of the project was to determine an approximate life expectancy
for the bauxite residuals monofill. For the purpose of this calculation, Delta assumed that
the final grade of the disposal area will range from approximately 805 feet above mean
sea level (ft msl) to 811 ft msl along the western portion of the site, gradually sloping
toward the berm and retention pond. While the areas on the eastern side of the property
along the western side of the drainage swale and retention pond will slope at a 3 to 1 grade
from the 805 msl contour toward the retention pond. The volume between the existing
surveyed topographic contours and the new proposed contours was estimated by dividing
the disposal area into four main groups (see attached map).
XInogen
8008 Corporate Center Drive Suite 100 Charlotte, NC 28226 USA
Phone: [phone] Fax: [phone]

Mr. Randall Andrews
Alchem, Inc.
Bauxite Residuals Disposal Area Life Expectancy
Rockwell, NC
November 7, 2007=11=07
Delta Project NO: 5E070=2101=P
Rage 2 QP 3
Area I -western side of disposal area
Currently, this area ranges from 802 ft msl to 808 ft msl. The facility plans to add bauxite residuals until this area increases
elevation by 3 feet. The new elevation in this area would be approximately range from 805 ft msl to 811 ft msl after the
increase. The volume of this area was approximated by sketching the area on the proposed drainage plan in AutoCAD 20060
and then using the software to estimate the lateral area on the map. This lateral area was then multiplied by the increase in
elevation (3 ft). Using this methodology, the volume of Area I was calculated to be approximately 7,057 cubic yards.
Area II -western side of disposal area, east of Area I
Area II on the proposed drainage plan currently slopes from 802 ft msl to 790 ft msl. The facility plans to level this area
to an elevation of approximately 805 ft msl for potential future use. The volume of this area was approximated by
dividing this area into five sub -areas (see attached map). For sub -areas H-A and H-E the cross -sectional area was
multiplied by the lateral distance to obtain volume. The sketch below represents the cross -sectional area used to
approximate the volume of areas II -A and II-E.
New Proposed Grade
805 ft msl 805 ft msl
802 ft msl
x ft msl
Existing Grade
For sub -area II -A the existing elevation `X' is 800 ft msl, while the elevation `X' for sub -area H-E is 790 ft msl.
In.the northeastern corner of Area II (sub -areas II-13, II-C, and II-D), the volume was estimated by assuming lateral
dimensions of known geometric shape (e.g. square, triangle, rectangle, etc.) and multiplying by the average increase in
elevation for the given sub -area.
Using the methodology described above, the total volume of Area H was calculated to be approximately 11,196 yd.
Area III -eastern side of disposal area, west of Area IV
Area III on the proposed drainage plan currently slopes from 790 ft msl toward the retention pond and drainage swale
with a variable slope. The facility plans to slope this area at a 3 to 1 ratio from the new 805 ft msl elevation to 791 ft msl
to provide adequate slope toward the retention pond for runoff. The volume of this area was approximated by dividing
this area into six sub -areas. For sub -areas III -A and II1-F the cross -sectional area was multiplied by the lateral distance to
obtain volume. The sketch below represents the cross -sectional area used to approximate the volume of areas I11-A
New Proposed Grade
805 ft msl /
800 ft msl Imo/
791 ft msl
Existing Grade

Mr. Randall Andrews
Alchem, Inc.
Bauxite Residuals Disposal Area Life Expectancy
Rockwell, NC
November 7, 2007-11-07
Delta Project No. 5E070-2101-P
The sketch below represents the cross -sectional area used to approxnnate the volume of area III-F.
New Proposed Grade
805 ft msl
800 ft msl 791 ft msl
786 ft msl
Existing Grade
Page 3 of 3
In the northeastern corner of Area III (sub -areas III-13, III-C, Ili-D, and III-E), the volume was estimated by assuming
lateral dimensions of known geometric shape (e.g. square, triangle, rectangle, etc.) and multiplying by the average
increase in elevation for the given sub -area.
Using the methodology described above, the total volume of Area III was calculated to be approximately 4,284 yd3.
Area IV -eastern side of disposal area, west of drainage swale and retention pond
Area IV on the proposed drainage plan currently slopes from approximately 786 ft msl toward the retention pond and
drainage swale with a variable slope. The facility plans to slope this area at a 3 to 1 ratio from the new 791 ft msl
elevation to the retention pond and drainage swale (781 ft msl). The volume of this area was approximated by dividing
this area into thirteen sub -areas of known geometric shape (not shown on map). Each lateral dimensions of each sub -area
were multiplied by half of the elevation change to obtain the volume of a triangular prism. Using this methodology, the
total volume of Area IV was calculated to be approximately 1,172 yd3.
The lateral area calculated from measuring the thirteen sub -areas was confirmed by sketching Area IV in AutoCAD
20060..and using the software to estimate the volume. The measure area was 12,674 ft2 while AutoCAD 20068
estimated an area of 13,141 ft2, which is an acceptable margin of error (4%) for this calculation.
CONCLUSIONS
The facility currently generates approximately 2,500 yd3 of bauxite residuals each year. Using the volumes calculated
above, the approximate minimum life expectancy of the disposal area i95years. This calculation is meant to provide an
estimate of the life expectancy of the disposal area and does not account for compaction or variations in the amount of
bauxite residuals generated, which could be expected to increase the life capacity of the fill area. Further, utilization of
areas currently used for stormwater retention, which may not be necessary following final capping and vegetation of the
fill area would also add significantly to the volume available for fill, and would be expected to add some years to the
available volume. If .existing residual material from cleaning of the on site lagoons is disposed in the monofil area, it
would be expected to decrease the life of the fill area by less than one year.
Should you have any questions about this work plan or the anticipated costs please contact Gary Ribblett at (704) 543-
3910 or Stephen Walls at [phone].
Sincerely,
DELTA CONSULTANTS
Stephen Walls, P.E.
Project Engineer
_JO,k�o'
i
Gary C. Ribblett, P.E.
Project Manager
'M
21
cc: Randall Andrews - Alchem

A m R w . ,O 00
PROPOSED
DETENTION
POND
PR.OPBSED
TOPOGRAPHY
AREA
I, 63,513 ft2'��
1mJs
AREA
III 35,364
ft2 Y ��
AREA
IIA;
_2,575 ft�
AREA
LIB;
691 ft2
AREA
IICl
335 ft2
AREA
IID:
495 ft2
AREA
IIEl
31,252 ft
35,348 f t 2
AREA
III 22,107
ft z
AREA
IIIAi
4,899 f t z
AREA
IIIBI
667 ft2
AREA
IIIC;
732 f-t2
AREA
IIID:
285 f t'
AREA
IIIEI
636 f t z
AREA
IIIF:
14,798 f t 2
22,017 ft 2
AREA
IV, 13,141
f t2
1. REFERENCE 41R\FY CSNIDLICTEI BY RIBEJN LAID
SLIRVEYINC, INC, Cti 5/27/D7
1. 'EF NEW 5TEE 11 WATER RETEMICN BERM CONSTRUM11N
SPECIFICATIONS FOR FURTHER DETAILS.
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D. STONNIL&R
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ROWWRI, NORTH CARCiINA
FESIML DISPOSAL Aff:A
DIBPDSAL. AkEA CAPACRY
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1TA ROI ELT NP NG OMn
OE07D2-101-P

Michael F. Easley, Governor
/ r � William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleen H. Sullins, Director
Division of Water Quality
AQUIFER PROTECTION SECTION
June 23, 2008
Alchem, Inc.
2042 Buie Philadelphus Road
Red Springs, North Carolina 28377
Attention: Randall Andrews
RE: Acknowledgement of Receipt
Inspection Report on Lagoons #1 and #2
Non -discharge Permit No. W00002702
Industrial Recycle — Bauxite Process
Alchem Facility, Rockwell, Rowan County
Dear Mr. Andrews:
This office received the referenced report on June 20, 2008. The report detailed the inspection of two of
the on -site storage lagoons by a professional engineer. This was a requirement in the Settlement
Agreement executed on November 26, 2007.
A review of the report indicated that the integrity of both lagoon liners was judged to be good by your
engineer. Therefore, you can begin using one or both of these lagoons to store bauxite sand that has a
pH of 6.0 or greater. After cleanout of lagoon #3 is completed, please have that liner evaluated in the
same manner and submit an addendum to this report.
We appreciate your attention to this matter. Should you have any questions, do not hesitate to call me at
704/663-1699, ext. 2180.
Sinc ely,
7�
Andrew H. Pitner, P.G.
Environmental Regional Supervisor
Cc: Kim Colson — APS Land Application Unit
Bob Wolcott, Alchem Inc., 8135 Red Rd., Rockwell, NC 28138
Anita Leveaux, J.D. — NCDOJ, Environmental Division
MAF/achem/lagoon inspect rpt ack 6-24-08
Division of Water Quality / Aquifer Protection Section / Mooresville Regional Office Phone: [phone] Fax: [phone] NoOe
hCarolina
610 East Center Avenue, Suite 301, Mooresville, NC 28115 Customer Service 1-877-623-6748 Internet: www.ncwaterauality.ora Naturallrff

- SUSTAINABLE STRATEGIES FOWLFOWCLA10OUS
JUN 2 0 2008 UU
r June 18, 2008
North Carolina Department of Environment esources
Division of Water Quality, Aquifer Protection Section
610 East Center Avenue
Suite 301
Mooresville, NC 28115
Attention: Mr. Andrew H. Pitner, P.G.
Regional Environmental Supervisor
Subject: Inspection. Report for Lagoons #1 and #2
Alchem, Inc.
8135 Red Road
Rockwell, NC
Delta Project No. 5EO702101 P
Dear Mr. Pitner.
r
Enclosed, on behalf of our client, Alchem, Inc., please find the report
documenting the inspection of Lagoon #1 and Lagoon #2, per request from your
office. The lagoons were inspected following their cleanout of residual material
(—' and after drying to facilitate the inspections.
00
I was quite impressed with the work that has been accomplished at the facility
and the condition of these two storage lagoons. I believe it is likely that these
E LTA lagoons have not been cleaned to their original depth for some years or perhaps
ever, before this. In fact, existing. equipment at the facility was not capable of
reaching to the constructed depth; and equipment with a longer reach was
leased for this purpose. While this constraint may have limited the available
storage depth in the past, it would also have helped assure that the bottom liners
J of the impoundments were 'not compromised by the past cleaning operations.
Minor amounts of residual material were also -left in the lagoons during the most
recent cleanout efforts to protect the liners. Spot checks of the liners beneath
the residual waste showed them,to be in good condition.
If you have any questions, please do not hesitate to contact me at (704) 543-
3910, or Mr. Andrews of Alchem at [phone].
Sincerely,
DELTA CONSULTANTS
Gary C. Ribblett, P.E.
Senior Project Manager
cc: Randall Andrews - Alchem
enclosures
XInogen
5910 Rice Creek Parkway Suite 100 St. Paul, MN 55126 USA
Phone: [phone] Fax: [phone]

REPIrN 2 o iooa
ALCHEM, INC.
ROCKWELL, NORTH CAROLINA V_ NC
NON -DISCHARGE PERMIT NO. WQ0002702 D�Q -
DELTA PROJECT NO. 5E07-02-101P
This report was prepared for:
ALCHEM, Inc.
8135 Red Road
Rockwell, North Carolina 28138
This report was prepared by:
D E LTA
Delta Consultants
8008 Corporate Center Drive Suite 100
Charlotte, North Carolina 28226
June 2008
Protection

TABLE OF CONTENTS
1.0 INTRODUCTION.................................................................................................................... I
2.0 HISTORY................................................................................................................................. I
3.0 INSPECTION OF LAGOON #1, LAGOON #2 AND LINERS.............................................2
4.0 FUTURE INSPECTION OF LAGOON #3.............................................................................8
5.0 REMARKS...............................................................................................................................9
Figure 1 Site Map
FIGURES
APPENDIX
Appendix A Surface Impoundment Inspection Checklists

LAGOON #1 AND LAGOON #2 INSPECTION REPORT
ALCHEM, INC.
ROCKWELL, NORTH CAROLINA
(—' NON -DISCHARGE PERMIT NO. WQ0002702
DELTA PROJECT NO.5E07-02-101P
t_ 1.0 INTRODUCTION
Persuant to a request by the North Carolina Department of Environment and Natural Resources
(NCDENR), ALCHEM, Inc. (ALCHEM) contracted Delta Consultants (Delta) to inspect Lagoons
#1 and #2 after the removal of accumulated residual waste ("sand"). On June 10, Delta's Gary C.
Ribblett, P.E. visited the facility to inspect the condition of Lagoons #1 and #2 for suitability to
hold the subject waste material.
2.0 HISTORY
The Site is located at 8135 Red Road in Rockwell, Rowan County, North Carolina on an elongated
parcel of approximately 33.7 acres. The site is consists of gently rolling terrain bisected by a
drainage feature which trends toward the southeast.
The facility operates a wastewater recycle system under non -discharge permit number
WQ0002702. In addition, the facility holds a permit (WQ0016388) for the operation of a bauxite
residuals monofill surface disposal program on the property. A site plan showing layout of the
process and fill areas is included with this report as Figure 1.
Permit No. WQ0002702 provides for the operation of a lagoon recycle system, groundwater
monitoring, and surface water sampling. Currently three (3) recycle lagoons are operated. A
condition of the permit, issued by the North Carolina Department of Environment and Natural
Resources (NC DENR) requires that these surface impoundments be inspected following their
clean -out. Solid residuals generated by the process, referred to as "sand", are disposed to the fill
area under Permit No. WQ0016338.

Lagoon #1 And Lagoon #2 Inspection Report
ALCHEM, Inc.
Rockwell, North Carolina
Delta Project No. 5E07-02-101 P
Page 2
A review of permeability testing data, by Godwin -Jordan Associates, P.A., for the clay material
from which the lagoons were originally constructed indicates a coefficient of permeability of better
than 10-6 cm/sec and nearly 10-7 cm/sec.
3.0 INSPECTION OF LAGOON #1, LAGOON #2 AND LINERS
On June 10, 2008, Gary Ribblett, P.E. of Delta visited the Rockwell facility to inspect Lagoons #1
and #2. Lagoons #1 and #2 had been cleaned of nearly all the residual sand build-up in them at the
time of inspection. Water from each lagoon was removed, to the extent possible by pumping, prior
to the cleaning of the lagoon.
The inspection was conducted after a period of several days of dry weather to have the
impoundments as dry as possible. Both inspected impoundments were found to be approximately
15 feet in depth. According to facility personnel interviewed, the lagoons had not been cleaned to
this depth for some years, as the equipment owned by Alchem at the facility did not have sufficient
reach to clean to this depth. Longer reach excavator equipment was leased to accomplish this
cleaning process.
In order to protect the lagoons' liners a small layer of residual material was left in the bottom of the
lagoon to avoid scraping or erosion of the liners.

Lagoon #1 And Lagoon #2 Inspection Report
ALCHEM, Inc.
Rockwell, North Carolina
Delta Project No. 5EO7-02-IO1P
a j
y, n
�'��.y/��T��P � X- 9•aRP' - ... _1ft
Lagoon #1 Facing South
Lagoon #2 Facing North
Page

Lagoon #1 And Lagoon #2 Inspection Report
ALCHEM, Inc.
Rockwell, North Carolina
Delta Project No: 5E07-02-101 P
Page 4
Lagoon Embankments
Embankments around the two lagoons were well graded and newly seeded with grass, which was
in early growth. A geotextile material was in place on the embankments to support grass seed and
' early growth. No trees or woody shrubs, which could compromise the lagoons' integrity, were
growing in the embankments.
I �
Tops of the embankments around the two lagoons appeared to be newly graded and were of a
consistent elevation, with no observed low points. No erosion of the embankments around the
lagoons was observed. No signs of burrowing or other rodent damage were observed.
No damp areas or signs of seepage or leaks were observed at the base of the embankments, but no
positive or negative significance should be implied, as neither impoundment was holding liquid at
the time of the inspection, having recently been cleaned for inspection. No signs of past seepage
through the embankments were observed.
Lagoon #1 Northern Embankment (Bottom) and
Lagoon #2 Eastern Embankment (Top)

Lagoon #1 And Lagoon #2 Inspection Report
ALCHEM, Inc.
Rockwell, North Carolina
Delta Project No. 5E07-02-101 P
Page 5
Lagoons #2 & #3 Northern Embankment
Lagoon Liners
During the inspection of the two surface impoundments (Lagoon #1 and Lagoon #2), the
appearance and condition of the compacted clay liners were also inspected in various spot
locations within the impoundments. Care was taken during the inspection process to use non-
destructive inspection methods to avoid creating damage to the liner integrity: Destructive
testing of the compacted clay liner is not recommended for such an inspection because of its
limited value verses the potential for damage to the liner's integrity. Such testing, such as
cutting, boring, or drilling, at best may provide information for a specific point in the liner and
not the entire liner's condition. However, such testing increases the potential for long-term
damage to the liner's integrity and may provide pathways for eventual leakage, regardless of
repair technique employed.
Clay liners could be viewed by manual removal of the small depth of residual material. The
liners were inspected in several locations in each quadrant of the lagoons. The appearance of the
clay material appeared consistent in the various locations inspected. No significant cracking,

Lagoon #1 And Lagoon #2 Inspection Report
ALCHEM, Inc.
Rockwell, North Carolina
Delta Proiect No. 5E07-02-101 P
Page 6
gouging or other wear or damage to the liners was observed. In several areas, exposed to direct
sunlight, minor cracking from drying was noted, but the fine cracking was surficial only, and did
not penetrate through the liner material.
Compacted clay liners in both Lagoon #1 and Lagoon #2 appeared to be in good condition and
undamaged by use and cleaning operations.
Lagoon #1 North Side

Lagoon #1 And Lagoon #2 Inspection Report
ALCHEM, Inc.
Rockwell, North Carolina
Delta Project No. 5E07-02-101 P
Page 7
Lagoon #2 West Side
Freeboard Monitoring Svstems
Clearly visible freeboard monitoring stations have been installed at each of the four corners of
each lagoon. The freeboard markers consist of clearly marked plastic pipe and placed with laser -
grid leveling for consistency. The markers are installed in the sloped sides of the impoundments,
not on the bottom in areas with higher liquid head. They are placed such that they do not
penetrate the entire depth of the liner material, and are held in place and sealed with concrete at
the base. They are also located such that they should not be impacted by future buildup of
residuals or water in the lagoons.

Lagoon #1 And Lagoon #2 Inspection Report
ALCHEM, Inc.
Rockwell, North Carolina
Delta Protect No. 5E07-02-101 P
Page 8
Lagoon #1 North Freeboard Indicators
4.0 FUTURE INSPECTION OF LAGOON #3
Because it is necessary to keep Lagoon #3 in operation, during cleaning and inspection of the
other two Lagoons, it was not possible to fully inspect Lagoon #3. It was observed, however,
that the top surfaces of the surrounding embankments had been graded level, and the outer
surfaces of the embankments had been seeded for growth of grass.
Following cleanout of Lagoon #3, this impoundment should also be scheduled for inspection as
required by NC DENR.

Lagoon #1 And Lagoon #2 Inspection Report
ALCHEM, Inc.
Rockwell, North Carolina
Delta Project No. 5E07-02-101P
Page 9
5.0 REMARKS
The recommendations contained in this report represent Delta's professional opinions based upon
the currently available information and are arrived at in accordance with currently acceptable
professional standards. This report is based upon a specific scope of work requested by the client.
The Contract between Delta and its client outlines the scope of work, and only those tasks
specifically authorized by that contract or outlined in this report were performed. This report is
intended only for the use of Delta's Client and anyone else specifically listed on this report. Delta
will not and cannot be liable for unauthorized reliance by any other third party. Other than as
contained in this paragraph, Delta makes no express or implied warranty as to the contents of this
report.
This report was prepared by:
CAR
DELTA CONSULTANTS
Gary C. Ribblett, P.E.
Senior Project Manager °flo0(3.,'r

FIGURES

Stream '
Stormwater Pond Lagoon #1
Lagoon
SITE MAP PROJECT NO: 5E0702101P
ALCHEM, Inc. DATE: 6/11/2008
8135 Red Road SCALE: NTS E3 E L T A
Rockwell, NC DRAWN BY: GR 8008 Corporate Center Drive, Suite 100
Charlotte, North Carolina 28226

APPENDIX A

D ErLTA
Delta Consultants
Surface impoundment inspection Checklist Ino en
'� g�,�,� u ..
Pro ect/Cllent:
LC 14r—t 1
Purpose:
Location:
Z,L , /C
O W /�L
Pre -Design
Pro ect (dumber:
SC) ? O �. t'r% I P
Construction Phase
GR12Y C. j�gj'� r y
Installation Completion
Ins ectedB :
b G O
Periodic Inspection os't Cle0.h o V-y
Date:
Closure
Description:
G-O.
Item
Comments/CoMeasures
��rrective
`�pp
5t- 401 w► i� rowlk
1
Are embankments well -sodded?
/Vewi 'Y&M
2
Are embankments free of trees or woody shrubs?
(r)Ls — Swtao� � wt�� r4�1✓o�
3
Does the berm or embankment have a consistent
elevation (no low or settled areas other than planned
Y� - i1/eu)/+ .74n,01?.j, f+'""C-1 q J"Jtx
4
spillway)?
Are all berms and embankments free of erosion?
l '
rt r - vi.o ar o S/ O-A VI-5 i )v
8
Is the base of the embankment free of soggy, damp
Stl O� S C G Ova as
areas and other evidence of seepage or leaks?
d
6
Are the embankments free of burrowing or other
! e
rodent damage?
?
Is the liner free of damage due to rainfall, wind, or
C 1 Q C I+\ W Cvl�
Lly1 � a tY 14/b'
wave action?
S
Is the liner free of erosion damage around Inletloutlet
)
�eS i+tCr v ll �0.wt
pipes and agitation points?
I
9
Is the liner free of visible cracking or holes?
Nnai sVrf; l'o-r' crkckin fro,., dr htr,j
10
Other (Specify)
Sw1a < % �) ieS! �Iv &Y re.3
11
in %reo r. J of! �vrS QLIIuY�s
12
Nc ro�.ul� ,v6wed rko JjAer
13
GvY!
14
Sketch/Notes:
Gary C. RibWbft, P.E.

Delta Consultants
Surface Impoundment inspection Checklist .01 en „
g•,. ,...
D E LTA
Pro ectlCilent:
Purpose:
Location:
Al C
Pre -Design
s �5 O 7OZ IO 100
Construction Phase
Project Number:
f34pa C, �� Q L E
Installation Completion
Inspected B
i 0 O 8
Periodic Inspection i9O S t
Date:
0
Closure
Description:
Item
Comments/Corrective Measures
d 6GL-1y
1
Are embankments well -sodded?
Alew)y ,SeZ c e . jrDwt
2
Are embankments free of trees or woody shrubs?
I !' S , Swion /tld fr-Les ro� -r y1 0 bJ
3
Does the berm or embankment have a consistent
elevation (no low or settled areas other than planned
r 1
!VIS 4/e W 8 ra 4Q r r2t bo 6 rd e� QU J
O
spillway)?
4
Are all berms and embankments free of erosion?
/ v10 P-1- x IVpy�
6
Is the base of the embankment free of soggy, damp
areas and other evidence of seepage or leaks?
aO CI ry
6
Are the embankments free of burrowing or other
Ye
rodent damage?
f
7
Is the liner free of damage due to rainfall, wind, or
1 ( `
�>;r -C/Q, /me r• 1, " CL C�d1 J jV"
wave action?
B
Is the liner free of erosion damage around Inletioutlet
1
L VAJXM
pipes and agitation points?
v tr d
9
Is the liner free of visible cracking or holes?
ol
}' 'l Sr- $ur'rrcio.if n , l� s
10
Other (Specify)
lGi�pc�
!"Ilgdf aino�ri�" u�rts]aU�f �C�� a
11
170 0.Yoi d I r �2rrh
12
J 0 1 CG tS ,dv
13
'1iwer a a
14
Sketch Notes:
�nld� J'ASFCCte14
Crux J 13ke Y-
C
e.
�i � F�rezboarol Gav�..e
Gary C. Rib ta. P.E.
�a

J
00
/ DEL
a,,.
xInogev AM —
SUSTAINABLE STRATEGIES FOR GLOBAL LEADERS
September 23, 2009
North Carolina Department of Environment and Natural Resources
Division of Water Quality, Aquifer Protection Section
610 East Center Avenue
Suite 301
Mooresville, NC 28115
Attention: Mr. Andrew H. Pitner, P.G.
Regional Environmental Supervisor
Subject: Inspection Report for Lagoons #3
Alchem, Inc.
8135 Red Road
Rockwell, NC
Delta Project No. 5EO702101 P
Dear Mr. Pitner:
Enclosed, on behalf of our client, Alchem, Inc., please find the report
documenting the inspection of Lagoon #3, per request from your office. The
lagoon wase inspected following its cleanout of residual material and after drying
to facilitate the inspections.
Minor amounts of residual material were also left in the lagoon during the most
recent cleanout efforts to protect the liner. Spot checks of the liner beneath the
residual waste showed them to be in good condition.
If you have any questions, please do not hesitate to contact me at (704) 543-
3910, or Mr. Andrews of Alchem at [phone].
Sincerely,
DELTA CONSULTANTS
CJ
Gary C. Ribblett, P.E.
Senior Project Manager
cc: Randall Andrews - Alchem
enclosures
5910 Rice Creek Parkway Suite 100 St. Paul, MN 55126 USA
Phone: [phone] Fax: [phone]

LAGOON #3 INSPECTION REPORT
ALCHEM, INC.
ROCKWELL, NORTH CAROLINA
NON -DISCHARGE PERMIT NO. WQ0002702
DELTA PROJECT NO.5E07-02-101P
This report was prepared for:
ALCHEM, Inc.
8135 Red Road
Rockwell, North Carolina 28138
This report was prepared by:
D E LTA
Delta Consultants
8008 Corporate Center Drive Suite 100
Charlotte, North Carolina 28226
September 2009
N
SEP
NU vuifer Protection

TABLE OF CONTENTS
1.0 INTRODUCTION .................................................
2.0 HISTORY..............................................................
3.0 INSPECTION OF LAGOON #3 AND LINER.....
4.0 REMARKS............................................................
FIGURES
Figure I Site Map
..................................................... 1
..................................................... 1
..................................................... 2
..................................................... 7
APPENDIX
Appendix A Surface Impoundment Inspection Checklist

1, -
LAGOON #3 INSPECTION REPORT
ALCHEM, INC.
ROCKWELL, NORTH CAROLINA
NON -DISCHARGE PERMIT NO. WQ0002702
DELTA PROJECT NO.5E07-02-101P
1.0 INTRODUCTION
D L C E 0 W E
SEP 2 5 2009
NC DENR MRO
DWQ - Aquifer Protection
Persuant to a request by the North Carolina Department of Environment and Natural Resources
(NCDENR), ALCHEM, Inc. (ALCHEM) contracted Delta Consultants (Delta) to inspect Lagoon
#3 after the removal of accumulated residual waste ("sand"). On September 15, 2009, Delta's
Gary C. Ribblett, P.E. visited the facility to inspect the condition of Lagoon #3 for suitability to
hold the subject waste material.
2.0 HISTORY
The Site is located at 8135 Red Road in Rockwell, Rowan County, North Carolina on an elongated
parcel of approximately 33.7 acres. The site is consists of gently rolling terrain bisected by a
drainage feature which trends toward the southeast.
The facility operates a wastewater recycle system under non -discharge permit number
WQ0002702. In addition, the facility holds a permit (WQ0016388) for the operation of a bauxite
residuals monofill surface disposal program on the property. A site plan showing layout of the
process and fill areas is included with this report as Figure 1.
Permit No. WQ0002702 provides for the operation of a lagoon recycle system, groundwater
monitoring, and surface water sampling. Currently three (3) recycle lagoons are operated. A
condition of the permit, issued by the North Carolina Department of Environment and Natural
Resources (NC DENR) requires that these surface impoundments be inspected following their
clean -out. Solid residuals generated by the process, referred to as "sand", are disposed to the fill
area under Permit No. WQ0016338 although no residuals have been disposed to the fill area for
some time, pending approval to resume by NC DENR.

Lagoon #3 Inspection Report
ALCHEM, Inc.
Rockwell, North Carolina
Delta Project No. 5E07-02-101P
Page 2
A review of permeability testing data, by Godwin -Jordan Associates, P.A., for the clay material
from which the lagoons were originally constructed indicates a coefficient of permeability of better
than 10-6 cm/sec and nearly 10-7 cm/sec.
3.0 INSPECTION OF LAGOON #3 AND LINER
On September 15, 2009, Gary Ribblett, P.E. of Delta visited the Rockwell facility to inspect
Lagoon #3. Lagoons #3 had been cleaned of nearly all the residual sand build-up in them at the
time of inspection. Water from the lagoon was removed, to the extent possible by pumping, prior
to the cleaning of the lagoon.
The inspection was conducted after a period of several days of dry weather and the lagoon was dry
at the time of inspection. The inspected impoundment was found to be approximately 15 feet to 20
feet in depth. According to facility personnel interviewed, the lagoons had not been cleaned to this
depth for some years, as the equipment owned by Alchem at the facility did not have sufficient
reach to clean to this depth. Longer reach excavator equipment was acquired to accomplish this
cleaning process.
In order to protect the lagoon's liner, excavation was conducted only until reaching the clay liner
material, which is of a distinctly different color than the residual sand.

Lagoon #3 Inspection Report
ALCHEM, Inc.
Rockwell, North Carolina
Delta Project No 5E07-02-101P
Page 3
Lagoon #3 Facing Northeast
Lagoon #3 Western Embankment Facing North

I
Lagoon #3 Inspection Report
AL.CHEM, Inc.
Rockwell, North Carolina
Delta Project No. 5E07-02-101P
Page 4
Lagoon Embankments
Due to the location and topography around Lagoon #3, areas surrounding the lagoon are at
approximately the elevation of the tops of the embankments. As such, there are no sloped areas on
the outside of the lagoon requiring vegetative growth to prevent erosion, as is the case for Lagoons
#1 and #2. For this reason, there are no true embankments associated with this impoundment,
other than the graded surface around the lagoon, which will be described as embankments in this
report.
Surfaces around the lagoon appear to have been improved with a consistent elevation and no low
spots. No trees or woody shrubs, which could compromise the lagoons' integrity, were growing in
the embankments.
Tops of the embankments around the lagoon appeared to be newly graded and were of a consistent
elevation, with no observed low points. Tops of the embankments are also graded such that
motored maintenance vehicles can access all sides of the lagoon. No erosion of the embankments
around the lagoon was observed. No signs of burrowing or other rodent damage were observed.
Lagoon #3 Eastern Embankment Facing North

Lagoon #3 Inspection Report
ALCHEM, Inc.
Rockwell, North Carolina
Delta Proiect No. 5E07-02-101P
Lagoon #3 Southern Embankment Facing West
with Freeboard Indicators
Page 5
Lagoon Liners
During the inspection of the surface impoundment, the appearance and condition of the
compacted clay liners were also inspected in various spot locations within the impoundments.
Care was taken during the inspection process to use non-destructive inspection methods to avoid
creating damage to the liner integrity. Destructive testing of the compacted clay liner is not
- recommended for such an inspection because of its limited value verses the potential for damage
to the liner's integrity. Destructive testing, such as cutting, boring, or drilling, at best may
provide information for a specific point in the liner and not the entire liner's condition.
However, such testing increases the potential for long-term damage to the liner's integrity and
may provide pathways for eventual leakage, regardless of repair technique employed.
The clay liner could be viewed by manual removal of the small depth of residual material. The
liners were inspected in several locations in each quadrant of the lagoons. The appearance of the
clay material appeared consistent in the various locations inspected. No significant cracking,
gouging or other wear or damage to the liners was observed. In several areas, exposed to direct
sunlight, minor cracking from drying was noted, but the fine cracking was surficial only, and did
not penetrate through the liner material.

Lagoon #3 Inspection Report
ALCHEM, Inc.
Rockwell, North Carolina
Delta Proiect No. 5E07-02-101P
Page 6
The compacted clay liner in Lagoon #3 appeared to be in good condition and undamaged by use
and cleaning operations.
Lagoon #3 Western Embankment Facing South
Freeboard Monitoring Systems
Clearly visible freeboard monitoring stations have been installed at each of the four corners of
each lagoon. The freeboard markers consist of clearly marked plastic pipe and placed with laser -
grid leveling for consistency. The markers are installed in the sloped sides of the impoundments,
not on the bottom in areas with higher liquid head. They are placed such that they do not
- penetrate the entire depth of the liner material, and are held in place and sealed with concrete at
P P
the base. They are also located such that they should not be impacted by future buildup of
residuals or water in the lagoons.

Lagoon #3 Inspection Report
ALCHEM, Inc.
Rockwell, North Carolina
Delta Proiect No. 5E07-02-101P
Lagoon #3 Northern Embankment Facing West
4.0 REMARKS
Page 7
i The recommendations contained in this report represent Delta's professional opinions based upon
the currently available information and are arrived at in accordance with currently acceptable
professional standards. This report is based upon a specific scope of work requested by the client.
- The Contract between Delta and its client outlines the scope of work, and only those tasks
specifically authorized by that contract or outlined in this report were performed. This report is
intended only for the use of Delta's Client and anyone else specifically listed on this report. Delta
will not and cannot be liable for unauthorized reliance by any other third party. Other than as
` contained in this paragraph, Delta makes no express or implied warranty as to the contents of this
report.
This report was prepared by:
0 �A CAR�/
DELTA CONSULTANTS
Qi
Gary C. Ribblett, P.E.
Senior Project Manager

FIGURES

-- Stream '
Road
Stormwater Pond
Lagoon #1
Lagoon rn
1*1
SITE MAP PROJECT NO: 5E0702101 P
ALCHEM, Inc. DATE: 9/16/2009
8135 Red Road SCALE: NTS E3 IE L'117A
Rockwell, NC DRAWN BY: GR 8008 Corporate Center Drive, Suite 100
Charlotte, North Carolina 28226

APPENDIX A

Delta Consultants v
Surface Impoundment Inspection Checklistr9r
Project/Client;
_ L C hl t tv,
Purpose: 1-4- C, o
O
Location:
/
, `O C K w E 4C, A/ C
Pre -Design
Project Number:
5-6 0 7 0 2 IO I P
Construction Phase
Inspected B •
Giv C. e 1 6 E,C %T
Installation Completion
Date:
' i s- )
Periodic Inspection
Description:
L.C� .. o O-K) #
Closure
Item
Commontsl!/Corroctivo Measures
1
Are embankments well -sodded?
NA ' A/o S l'0 �'. ri• �' r (?,h f n y, ' I �t YL Fr
2
Are embankments free of trees or woody shrubs?
/
Does the berm or embankment have a consistent
3
elevation (no low or settled areas other than planned
/ PS /Vp S - d`%' oSSe ^r2 c!
spillway)?
4
Are all berms and embankments free of erosion?
1 t S ., /4,aV rctrf 14
6
Is the base of the embankment free of soggy, damp
��O �� `�tM� ���e �0
areas and other evidence of seepage or leaks?
�'• 1 E �� t x
6
Are the embankments free of burrowing or other
J
rodent damage?
7
Is the liner free of damage due to rainfall, wind, or
wave action?
1 {
%DES' C(Q. 11nPC a tcw Y1 soar! Coytdrlldn
8
Is the liner free of erosion damage around inleUoutlot
/l'0 !',�izf lIkQ1. ^
pipes and agitation points?
; n (Yo �rasro CrRi7(• Z
9
Is the liner free of visible cracking or holes?
JV r{l U eQ !� f• nrn. C f tCICs pr,1 1JOi �r n�`r�C
10
Other (Specify)
(rr1LJ rno;��r� [• 1 c��0.r << Vr� r11
11
d
J/1�?^Mrr1C•r}},r,Rv�r� 'n. er .� <)J
12
lviS 0-1-J ]'s S'YIOW� nU
13
14
Skotch/Notes:
i 7
a
VN IV/
' i
n
��///
Gary C. Ribbl it P.E.

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
0 12Y Alan W. Klimek, P.E. Director
Division of Water Quality
AQUIFER PROTECTION SECTION
March 30, 2007
Mr. Randall Andrews
Alchem, Inc.
2042 Buie Philadelphus Road
Red Springs, North Carolina 28377
and
Alchen, Inc.
8135 Red Road
Rockwell, North Carolina 28138
RE: Acknowledgement of Receipt
Performance Improvement Plan
Non -discharge Permit No. WQ0002702
Industrial Recycle — Bauxite Process
Rowan County
Dear Mr. Andrews:
This office received the referenced report on March 21, 2007. Submission of the report was prescribed in the
Notice of Violation (NOV-2006-PC-0568) dated December 20, 2006, and we appreciate your'efforts to comply with
the notice.
Upon review of the report, it was noted that execution of the proposed performance improvement plan is contingent
upon Alchem receiving approval to dispose of lagoon residuals mixed with lime in the permitted fill area. This office
cannot approve disposal of any additional residuals in the bauxite fill area until it has been stabilized. This
stabilization must include, among other things, repair or replacement of the berm as proposed in the Boyle
Engineering report or as developed through consultation with another engineer. Until the stabilization is
accomplished, you must find an alternative disposal option for the contents of at least one lagoon. Once the first
lagoon is emptied, the liner integrity is evaluated, and any necessary repairs made, you will have the storage
capacity to shift treated residuals from the other lagoons and thereby continue with the project. Your consultants
should be able to find an alternative disposal option such as nearby landfills in, Rowan or Cabarrus counties.
The proposed time line in the plan (Figure 3) is generally acceptable, however, it was also noted that the time line
does not include provisions for potential liner repairs to any of the lagoons as mentioned above. Please address
this matter when you submit a copy of the recommendations and evaluation provided by S&ME. This information
should be submitted within thirty days of receipt of this letter.
Should you have any questions, do not hesitate to contact Peggy Finley or me at 704/663-1699.
Sincerely,
Andrew H. Pitner, P.G.
Regional Environmental Supervisor
Cc: Gary C. Ribblett, P.E.- Delta Environmental Consultants, Inc., 8008 Corporate Center Dr., Suite 100,
Charlotte 28226
MAF/alchem ack 3-23-07
Division of Water Quality / Aquifer Protection Section / Mooresville Regional Office Phone: [phone] Fax: [phone] NoithCarolina
610 East Center Avenue, Suite 301, Mooresville, NC 28115 Customer Service 1-877-623-6748 Internet: www.ncwaterquality.orq Naturally

F WATF
\O ;9 Michael F. Easley. Governor
✓' N\ Q i [PED)y
William G. Ross Jr., Secretary
�0` 7 �—� North Carolina Department of Environment and Natural Resources
> [ Alan W. Klimek, P.E. Director
�=_---�--� Division of Water Quality
AQUIFER PROTECTION SECTION
May 18, 2007
Mr. Randall Andrews
Alchem, Inc.
2042 Buie Philadelphus Road
Red Springs, North Carolina 28377
Alchen, Inc.
8135 Red Road
Rockwell, Borth Carolina 28138
RE: Overdue Notice
Alchem — Red Road Site
Rion -discharge Permit No. WQ0002702
Industrial Recycle — Bauxite Process
Rowan County
Dear Mr. Andrews:
On March 30, 2007, this office sent you an acknowledgement of receipt for your
Performance Improvement Plan. In that correspondence you were requested to submit a copy
of the evaluation and recommendations that was being prepared by S&ME. You were also
requested to submit a modified timeline for bringing the lagoons into compliance. This
information was due within 30 days of receipt of the acknowledgement. To date, we have not
received the documents. Please submit them within 15 days or provide a reason why you
cannot comply.
Should you have any questions, do not hesitate to contact Peggy Finley or me at
704/663-1699.
Sincerely,
r
Andrew H. Pitner, P.G.
Regional Environmental Supervisor
Cc: Gary C. Ribblett, P.E.- Delta Environmental Consultants, Inc., 8008 Corporate Center Dr.,
Suite 100, Charlotte 28226
MAF/alchem overdue 5-18-07
Ono
Division of Water Quality / Aquifer Protection Section / Mooresville Regional Office Phone: [phone] Fax: [phone] No thCarolina
610 East Center Avenue, Suite 301, Mooresville, NC 28115 Customer Service 1-877-623-6748 Internet: www.ncwaterguality.oro No

i
RESIDUALS RECYCLE SYSTEM
PERFORMANCE IMPROVEMENT PLAN
ALCHEM, INC.
ROCKWELL, NORTH CAROLINA
NON -DISCHARGE PERMIT NO. WQ0002702
DELTA PROJECT NO.5E07-02-101P
This report was prepared for:
ALCHEM, Inc.
8135 Red Road
Rockwell, North Carolina 28138
p fEC E 9 W
:MAR2 2 2007
NC DENR MRO
DWQ -Aquifer Protection
This report was prepared by:
M � E LTA
W CD�a o
N Environmental Consultants Inc.
04
:orporate Center Drive Suite 100
irlotte, North Carolina 28226
March 2007
Z E
A o
�'+ N
El
co 0�
L N ^
Q N /\

TABLE OF CONTENTS
1.0 INTRODUCTION................................................................................................................... 1
2.0 HISTORY................................................................................................................................ 1
3.0 RESIDUALS RECYCLE SYSTEM........................................................................................ 2
4.0 PROPOSED SCHEDULE OF ACTIVITIES.......................................................................... 6
5.0 REMARKS.............................................................................................................................. 7
LIST OF FIGURES
Figure 1 Topographic Location Map
Figure 2 Site Map
Figure 3 Proposed Schedule of Activities

RESIDUALS RECYCLE SYSTEM PERFORMANCE IMPROVEMENT PLAN
ALCHEM, INC.
ROCKWELL, NORTH CAROLINA
NON -DISCHARGE PERMIT NO. WQ0002702
DELTA PROJECT NO.5E07-02-101P
1.0 INTRODUCTION
Delta Consultants (Delta), on behalf of ALCHEM, Inc. (ALCHEM), has prepared this
Performance Improvement Plan for the Residuals Recycle System at the Rockwell, North Carolina
facility. The purpose of this report is to provide North Carolina Department of Environment and
Natural Resources (NCDENR) regarding Plans and schedules for activities to improve the
residuals recycle system as required in the December 20, 2006 Notice of Violation/Notice of
Recommendation for Enforcement (NOV/NRE) under permit number WQ0002702.
2.0 HISTORY
The Site is located at 8135 Red Road in Rockwell, Rowan County, North Carolina on an elongated
parcel of approximately 33.7 acres. The site is consists of gently rolling terrain bisected by a
drainage feature which trends toward the southeast. A topographic location map of the area is
attached as Figure 1.
The facility operates a wastewater recycle system under non -discharge permit number
WQ0002702. In addition, the facility holds a permit (WQ0016388) for the operation of a bauxite
residuals monofill surface disposal program on the property. A site plan showing layout of the
process and fill areas is included with this report as Figure 2.
By raising the grade through residual fill, it is ALCHEM's desire to improve the original
topography of the fill area to allow eventual further development and building on the area.
Although the two permits are separate and this report is to address requests made by NCDENR
under Permit No. WQ0002702, the operation of each permitted system is dependent upon the
other.

Residuals Recycle System Performance Improvement Plan
ALCHEM, Inc.
Rockwell, North Carolina
Delta Proiect No. 5E07-02-101P
Page 2
Permit No. WQ0002702 provides for the operation of a lagoon recycle system, groundwater
monitoring, and surface water sampling. Currently three (3) recycle lagoons are operated. Solid
residuals generated by the process, referred to as "sand", are disposed to the fill area under Permit
No. WQ0016338. Per a December 20, 2006 NOV/NRE issued by NCDENR for Permit No.
WQ0016338, the facility has not been permitted to use the fill area for residuals disposal and to
date the facility has been unable to locate another suitable disposal option.
The NOV/NRE for WQ0002702 noted the following conditions:
0 Low pH of the wastewater in the three lagoons;
Increasing concentration of aluminum in MW-2; and
i Freeboard of 1.5 feet in lagoon #3, which is less than the 2.0 feet required by the
permit.
Based on these issues, the NOV/NRE required ALCHEM to. submit a report that specifies what
steps need to be taken so that the recycle system will perform satisfactorily. In addition, a plan
with a timeline for removal and disposal of the residuals in the lagoons was to be submitted.
Another requirement of the NOV/NRE was for the lagoon liners to be inspected by a Professional
Engineer to verify the liner integrity of the lagoons and recommend repair as necessary.
3.0 RESIDUALS RECYCLE SYSTEM
Seven steps have been identified to assure satisfactory operation of the recycle system. These steps
are:
1. Improved residuals washing and verification procedures;
2. Stormwater diversion to prevent offsite stormwater from running into the residuals
management areas;
3. Geotechnical and constructability evaluation of disposal area and recommendations;
1s

Residuals Recycle System Performance Improvement Plan
ALCHEM, Inc.
Rockwell, North Carolina
Delta Project No. 5E07-02-101P
4. Lagoon sand removal and disposal;
5. Sand pH treatment and placement;
6. Lagoon liner inspection and repair as necessary; and
7. Installation of improved freeboard monitoring system.
These steps are described in greater detail below.
r.
Residuals Washin>? and Verification Procedures
A new residuals washing mixer, with a capacity of approximately 5,000 gallons, has been obtained by
ALCHEM. Installation of the mixer is scheduled to be completed during the week of March 19, 2007.
Once installed, all residuals from the manufacturing operation will be processed through the mixer. The
procedure for residuals washing will be as follows:
• First wash of the residuals occurs in the reactor itself.
® Second -wash water and sand will then be pumped into the washing mixer.
A A 25% solution of caustic soda will be added to the mixer from a caustic soda storage
tank. The residual material will then be washed in the mixer, with =pH moriitoring-and
reaustic_so-da--addit o7l-.unti:l.-the-pH- : s=-e`onfirined-to'=be_greater.-:than 6:.0-before=transferring;
tlxe_.wash-Waterand -sand to:t1-re_lag6Un-,
•=Docuiieiitation will=be�kept onsite_vof the -recorded -pH of each batch.transferred from the-_ -
mixer to the lagoonss...
Stormwater Diversion
Stormwater from offsite had been entering the property from near and across Red Road at the area near
the rail car unloading stations. This stormwater then ran past the unloading areas and residuals fill area
and into the stormwater retention basin. During periods of heavy rain, this resulted in large quantities of
water in the retention basin which further stressed the retention berm.

Residuals Recycle System Performance Improvement Plan
ALCHEM, Inc.
Rockwell, North Carolina
Delta Project No. 5E07-02-101P
Page 4
Stormwater flow has been diverted to channel offsite stormwater around the fill area and the retention
basin. This has resulted in noticeably less accumulation of stormwater runoff in the retention basin.
Fill Area Geotechnical and Constructability Evaluation/Recommendations
A previous study provided by Boyle Engineering for ALCHEM confirmed that residuals in the fill area
had been placed randomly resulting in zones of uncompacted fill. This study offered two alternatives to
prepare the area for construction.
The first option identified would be the undercut and replacement of the existing fill with engineered fill.
This option is described in the report as "an overly conservative approach on this site given the type of
planned structures".
The second option identified in the Boyle Engineering report is the partial undercut of the existing fill and
deleterious soils to provide new, well placed compacted fill. The report also suggests that placement of
one or more feet of bridging fill or use of geotextile fabric or geogrid might be required on the undercut
fill soils to provide a working platform.
ALCHEM has engaged the services of S&ME, Inc. to evaluate the geotechnical conditions and
constructability issues at the fill area. S&ME will make recommendations regarding the details for
undercutting, compaction, and placement of geotextile as appropriate. Recommendations provided by the
S&ME evaluation will be provided to NCDENR by ALCHEM.
Lagoon sand removal/disposal
Following NCDENR approval of the residuals disposal recommendations contained herein, the
lagoons should be sequentially cleaned of the residual build-up in them. Water from each lagoon
should be removed, to the extent possible by pumping, prior to the cleaning of that lagoon. Care
should be taken during sand removal to assure that the existing liner is not damaged by the sand
removal process. Removal of the sand should be halted before scraping or erosion of the liner.
After cleaning the lagoon liner should be inspected by a North Carolina professional engineer, with
repairs conducted if necessary prior to placing a lagoon back into service.

Residuals Recycle System Performance Improvement Plan
ALCHEM, Inc.
Rockwell, North Carolina
Delta Project No. 5E07-02-1011'
Page 5
Sand pH treatment and placement
Although the purpose of this plan is to address improved performance of the residuals management
system under Permit WQ0002702, a necessary step in this improvement is the removal and
disposal of accumulated residuals from the lagoons, which is impacted by the inability to dispose
the residuals in the fill area under Permit WQ0016338.
Under separate action, ALCHEM is planning an improvement and reconstruction of the
stormwater retention berm at the base of the fill area. The purpose of the action is to assure that
runoff from the fill area is captured and returned to the process area for reuse. Problems have been
documented with the berm and the placement of the residual fill.
The report by Boyle Engineering, referenced above, states the opinion that the existing
embankment (berm) fill conditions are too variable and unsuitable to retain any additional lateral
loads without risk of failure. Such lateral loads would be exerted by increased depth of water
retained behind the berm, not by additional placement of residuals in the fill area.
While the residual fill itself is not in contact with the berm and does not exert lateral load to the
berm, leakage of lower pH water has been noted through the berm. In the interim period, while
berm improvements are designed and implemented, proper placement of additional residuals with
their pH elevated via mixing with lime, would not structurally affect the berm, but would have a
positive impact on pH of the runoff from the area.
After permission is granted by NCDENR, it is recommended that residuals removed from the
lagoons be treated to elevate the pH via mixing with lime. Additional placement of the pH
adjusted residuals, using placement and compaction recommendations from the S&ME study, onto
the existing fill area would positively affect the pH of runoff from the previously placed fill,
provide additional structural stability, and facilitate the cleaning of the lagoons.

Residuals Recycle System Performance Improvement Plan
ALCHEM, Inc.
Rockwell, North Carolina
Delta Proiect No. 5E07-02-1011'
Page 6
During removal of the sand from the lagoons, it should be well mixed with lime to assure proper
pH adjustment before placement. As required in permit WQ0002702, the pH measurements for
each load of residuals will be documented prior to disposal, and kept onsite.
Lagoon liner inspection
After each lagoon is cleaned of residuals its compacted clay liner will be inspected by a North Carolina
professional engineer prior to placing it back into service. Care should be taken during the inspection
process to use non-destructive inspection methods to avoid creating damage to the liner integrity.
Repairs to the lagoon liners, if necessary, should be conducted and the repair re -inspected prior to
placement of the lagoon back into service.
After all three lagoons have been inspected, documentation of the inspection will be submitted to
NCDENR.
Installation of improved freeboard monitoring system
Following completion of the lagoon cleanout, liner inspection, and any necessary repairs, a North
Carolina Licensed Land Surveyor will be retained to assist in placement of freeboard monitoring systems
on each lagoon. It is recommended that the system should be installed on the sloped sides of the lagoon,
at the location of the topographic low elevation of the side walls. They should be clearly visible and
located such that they are not impacted by future buildup of residuals or water in the lagoons.
4.0 PROPOSED SCHEDULE OF ACTIVITIES
The attached Figure 3 provides a proposed Gantt Chart schedule of activities described above. For the
purpose of a complete schedule, an assumption is made regarding date of NCDENR approval of the
proposed treatment and disposal methods. The schedule dates for subsequent tasks are dependent upon
this assumption, and would change as necessary to occur following approval.

Residuals Recycle System Performance Improvement Plan
ALCHEM, Inc.
Rockwell, North Carolina
Delta Project No. 5E07-02-101P
Page 7
The recommendations contained in this report represent Delta's professional opinions based upon
the currently available information and are arrived at in accordance with currently acceptable
professional standards. This report is based upon a specific scope of work requested by the client.
The Contract between Delta and its client outlines the scope of work, and only those tasks
specifically authorized by that contract or outlined in this report were performed. This report is
intended only for the use of Delta's Client and anyone else specifically listed on this report. Delta
will not and cannot be liable for unauthorized reliance by any other third party. Other than as
contained in this paragraph, Delta makes no express or implied warranty as to the contents of this
report.
This report was prepared by:
DELTA ENVIRONMENTAL CONSULTANTS, INC.
Gary C. Ribblett, P.E.
Senior Project Manager
cc: Randall Andrews - ALCHEM

FIGURES

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Oc 2004 ?4ZEctosoft Corporation. Tereus of Use Privacy Statement
FIGURE 1 - TOPOGRAPHIC LOCATION MAP PROJECT NO: 5E0702101 P
ALCHEM, Inc. DATE: 3/20/2007
8135 Red Road SCALE: AS SHOWN D E L T A
I Rockwell, North Carolina DRAWN BY: SP 8008 Corporate Center Drive, Suite 100
Charlotte. North Carolina 28226

FIGURE. 3 .
ALCHEM, Inc..
Residual Managem .nt
..System
Performance_ Improvement Plan - ... .
Proposed Schedule of Activities.'
Feb 25, `07
Mar 1.1,'07
Mar 25; '07
Apr 8; '07- .
Apr 22,'07.. .May
6, '07 . ""
May 20, '07. ' .
Jun 3,''07 . • ..
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Mon 3/12/07 1
Fri 3/23/07.
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Mon.3%12I07 I
Fri 4/6/07.
4
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(—
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Fri.4/6/07
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DENR Approval of Disposal (Date Assumed)
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Fri 4/13/07
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First Lagoon Sand Removal
Mon 4/16/071
Fri.5/25/07,
7
First Lagoon, Sand.Treatment and Placement
Mon 4/23/07
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First Lagoon Liner Inspection
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9
Second Lagoon Sand Removal
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Fri 7/6/07
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Fri 7/13/07
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Mon 7 9 07
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Fri 8/24/07
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Fri 8/_31/07
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Mon.9/3/07?
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Fri 9/7/07

W ATF Michael F. Easley, Governor
Q:� 9 William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Uj 7, Coleen H. Sullins, Director
rI
Division of Water Quality
AQUIFER PROTECTION SECTION
March 27, 2008
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Alchem, Inc.
2042 Buie Phildelphus Road
Red Springs, North Carolina 28377
Attention: Julia M. Andrews, Registered Agent
RE: Notice of Violation/Notice of Recommendation for
Enforcement — NOV-2008-PC-0134
Alchem, Inc. — Red Road Facility
Non -discharge Permit No. W00002702 and
Non -discharge Permit No. WQ0016338
Industrial Recycle Bauxite Process, Bauxite Monofill
Rockwell, Rowan County
Dear Ms. Andrews:
Chapter 143, North Carolina General Statutes, authorizes and directs the Environmental Management
Commission of the Department of Environment and Natural Resources to protect and preserve the water and
air resources of the State. The Division of Water Quality (Division) has the delegated authority to enforce
adopted pollution control rules. This letter is a standard notification and is intended to advise you of the legal
requirements under North Carolina law.
In response to a citizen complaint, staff from the Aquifer Protection Section of the Mooresville Regional
Office conducted a site visit at a property located at Maggie Lane off Tom's Creek Church Road, in Denton,
Davidson County. Approximately 27 loads of residuals from Alchem were found to have been dumped at this
location (see attachment for photos). As a result of the investigation, the Division has reason to believe that
you are in violation of the following permit conditions:
Permit WQ0016338 condition 1.3 - the facilities should be effectively maintained and operated as a
non -discharge system to prevent the discharge of any wastes resulting from the operation of this
program.
Permit WQ0002702 Condition 6 — The residuals generated from these treatment facilities must be
disposed of in accordance with General Statute 143-215.1 and in a manner approved by the Division.
• The aforementioned location is not an appropriately permitted facility for disposal and the Division did
not approve the manner of disposal or the location.
In order to correct this violation, you shall immediately cease disposal of the residuals at locations
that are not permitted for disposal or approved for application by the Division. You must also remove these
residuals from their present location in Davidson County and transport them back to the Alchem facility for
treatment or to a Subtitle D landfill for disposal. The Division has also been made aware that residuals that
were sent to Agric Chemicals, Inc., and have not been properly handled. As such, previous approval granted
to Alchem to send the residuals to Agric Chemicals, Inc. is now revoked and any future plans for using the
residuals in such processes must be submitted and approved in writing by the Division prior to off site
NorthCarollina
Division of Water Quality / Aquifer Protection Section / Mooresville Regional Office Phone: [phone] Fax: [phone] Jatllt,R[��
610 East Center Avenue, Suite 301, Mooresville, NC 28115 Internet: www.ncwaterauality.org � V

Alchem, Inc. NOV
Page 2 of 2
March 26, 2008
r
t
transport. Pending further investigation, the Division reserves the right to issue additional notices of violation
and recommendations for enforcement. As the permit holder and generator of these residuals, it is
Alchem's responsibility to ensure that they are handled properly and disposed -of within the conditions
of your permit and applicable laws. The material shall not be given away to be used as fill.
You are required to respond to this notice by submitting a plan for removal and proper disposal of the
residuals dumped in Davidson County to the Aquifer Protection Section of the Mooresville Regional Office
within 10 days following receipt of this notice. The plan shall identify the amount of material that will be sent to
a Subtitle D landfill (and the name and location of that facility) or returned to the Alchem facility for treatment.
Upon proper disposal of the residuals, you shall submit a summary report and include manifests or other
suitable documentation.
In addition, by June 26, 2008, you are required to submit a report assessing any damage to the soil
and/or groundwater at the unapproved disposal site in Davidson County. The report shall be prepared by a
North Carolina Licensed Geologist or Professional Engineer.
The above violation of G.S. 143-215.1 is subject to a civil penalty assessment under the authority of
G.S. 143-215.6A of up to $25,000 per day per violation. A recommendation for enforcement is currently being
prepared by the Mooresville Regional Office. Please note that each day the unapproved disposal
continues, you may be subject to a continuing penalty assessment.
Please address your response to me. It is also requested that your response letter reference the date
and subject of this NOWNRE as well as the permit number. Should you have any questions concerning this
matter, please do not hesitate to call me at 704/669-1699, ext. 2180.
Sin erely,
Andrew H. Pitner, P.G.
Environmental Regional Supervisor
Attachment . ,
■ RED MAIL. RECEIPT
Cc Kim Colson 4-C� -- _
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Bob Wolc `'y `' Jw.; •*'
Andrew 1-
Art Barnl ` " :" " . ..
Sherri Kr • Sender: Please print your name, address, and IP+4 in th
Henry PE
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DENR DWQ Aquifer Protection - m Zo
610 E. Center Ave., Ste. ;01 r-u
Mooresville NC 28115 -a
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To File:
Site Visit - April 17, 2008
Maggie Lane — Site of illegal Alchem dumping
Denton, Davidson County
The piles of bauxite residuals have been removed. The area has apparently been
overseeded (pine straw has been laid down as a cover).
'��45v- �� ar/09�
mS

WAT��
OF
Q
Michael F. Easley, Governor
William G. Ross Jr., Secretary
IC co
y
r
North Carolina Department of Environment and Natural Resources
j
Coleen H. Sullins, Director
Division of Water Quality
AQUIFER PROTECTION SECTION
April 1, 2008
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Randall Andrews, President and Registered Agent
ALCHEM, Incorporated
8135 Buie Philadelphus Rd.
Red Springs, NC 28377
RE: Previously Issued NOV
Dated March 27, 2008
C o t3 q
Dear Mr. Andrews:
The division has been made aware of a recent change in the registered agent for Alchem
Incorporated filed 3/3/2008 (see attached). As you are now the registered agent, we are sending you a
copy of the NOV/NRE issued to ALCHEM Incorporated for your records. The content of the NOV is
unchanged.
If you have any questions, please contact me at [phone].
Sincerely,
%,
664 J11I--
Ellen Huffman 1
Environmental Specialist
ne
Division of Water Quality / Aquifer Protection Section / Mooresville Regional Office Phone: [phone] Fax: [phone] Nor liCarolina
610 East Center Avenue, Suite 301, Mooresville, NC 28115 Internet: www.ncwaterouality.ora Naturally

■ Complete items 1, 2, and 3. Also complete
item 4 if Restricted Delivery is desired.
■ Print your name and address on the reverse
so that we can return the card to you.
■ Attach this card to the back of the mailpiece,
or on the front if space permits.
1. Article Addressed to:
MR RANDALL ANDREWS,
PRESIDENT & REG. AGENT
ALCHEM INC.
8-135 BUIE PHILADELPHUS RD
-. - RED SPRINGS NC 2X377
ap/eh _ 4/ t 108
a
A. Sig. ature
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D. Is deliv4y address different from item 1?
If YES, enter delivery address below:
rgistered
e
rtified Mail ❑ Express Mail
❑ ReturnRecelpt for Merchandise
El insured Mail ❑ C.O.D.
Agent
Delivery
❑ No
4. Restricted Delivery? (Extra Fee) ❑ Yes
2•1 ?007 1490 0�04 4505 8336. 's s L
1 J February 21JO41 ' DomesticlReturn Receipt
_ -
rvmayn w
Certified Fee
O
- Postmark '
Return Receipt Fee
O
Here
(Endorsement Required) j„
M
Restricted Delivery Fee
1:3(Endorsement
Required) fj 1
Q
�
Total MR RANDALL ANDREWS,
a
PRESIDENT & REG. AGENT \
Sent TcTc ALCHEM INC.
Q
street;' 8135 BUIE PHILADELPHUS RD
'""""""'
or POI RED SPRINGS NC 28377
Y -
city, st ap/eh 4/1/08
PS Form :00 Augus.t 2006 See Reverse for InstrUCtiOMS
102595-02-M-154u ;

O,0 , AT �9QG
r
—I
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Alchem, Inc.
2042 Buie Phildelphus Road
Red Springs, North Carolina 28377
Attention: Julia M. Andrews, Registered Agent
Dear Ms. Andrews:
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleen H. Sullins, Director
Division of Water Quality
AQUIFER PROTECTION SECTION
March 27, 2008
RE: Notice of Violation/Notice of Recommendation for
Enforcement — NOV-2008-PC-0134
Alchem, Inc. — Red Road Facility
Non -discharge Permit No. WQ0002702 and
Non -discharge Permit No. WQ0016338
Industrial Recycle Bauxite Process, Bauxite Monofill
Rockwell, Rowan County
Chapter 143, North Carolina General Statutes, authorizes and directs the Environmental Management
Commission of the Department of Environment and Natural Resources to protect and preserve the water and
air resources of the State. The Division of Water Quality (Division) has the delegated authority to enforce
adopted pollution control rules. This letter is a standard notification and is intended to advise you of the legal
requirements under North Carolina law.
In response to a citizen complaint, staff from the Aquifer Protection Section of the Mooresville Regional
Office conducted a site visit at a property located at Maggie Lane off Tom's Creek Church Road, in Denton,
Davidson County. Approximately 27 loads of residuals from Alchem were found to have been dumped at this
location (see attachment for photos). As a result of the investigation, the Division has reason to believe that
you are in violation of the following permit conditions:
Permit WQ0016338 condition 1.3 - the facilities should be effectively maintained and operated as a
non -discharge system to prevent the discharge of any wastes resulting from the operation of this
program.
Permit WQ0002702 Condition 6 — The residuals generated from these treatment facilities must be
disposed of in accordance with General Statute 143-215.1 and in a manner approved by the Division.
• The aforementioned location is not an appropriately permitted facility for disposal and the Division did
not approve the manner of disposal or the location.
In order to correct this violation, you shall immediately cease disposal of the residuals at locations
that are not permitted for disposal or approved for application by the Division. You must also remove these
residuals from their present location in Davidson County and transport them back to the Alchem facility for
treatment or to a Subtitle D landfill for disposal. The Division has also been made aware that residuals that
were sent to Agric Chemicals, Inc., and have not been properly handled. As such, previous approval granted
to Alchem to send the residuals to Agric Chemicals, Inc. is now revoked and any future plans for using the
residuals in such processes must be submitted and approved in writing by the Division prior to off site
Noi thCarolina
Division of Water Quality / Aquifer Protection Section / Mooresville Regional Office Phone: [phone] Fax: [phone] ��tllrall�
610 East Center Avenue, Suite 301, Mooresville, NC 28115 Internet: www.ncwaterguality.orq

Alchem, Inc. NOV
Page 2 of 2 "
March 26, 2008 , s
transport. Pending further investigation, the Division reserves the right to issue additional notices of violation
and recommendations for enforcement. As the permit holder and generator of these residuals, it is
Alchem's responsibility to ensure that they are handled properly and disposed of within the conditions
of your permit and applicable laws. The material shall not be given away to be used as fill.
You are required to respond to this notice by submitting a plan for removal and proper disposal of the
residuals dumped in Davidson County to the Aquifer Protection Section of the Mooresville Regional Office
within 10 days following receipt of this notice. The plan shall identify the amount of material that will be sent to
a Subtitle D landfill (and the name and location of that facility) or returned to the Alchem facility for treatment.
Upon proper disposal of the residuals, you shall submit a summary report and include manifests or other
suitable documentation.
In addition, by June 26, 2008, you are required to submit a report assessing any damage to the soil
and/or groundwater at the unapproved disposal site in Davidson County. The report shall be prepared by a
North Carolina Licensed Geologist or Professional Engineer.
The above violation of G.S. 143-215.1 is subject to a civil penalty assessment under the authority of
G.S. 143-215.6A of up to $25,000 per day per violation. A recommendation for enforcement is currently being
prepared by the Mooresville Regional Office. Please note that each day the unapproved disposal
continues, you may be subject to a continuing penalty assessment.
Please address your response to me. It is also requested that your response letter reference the date
and subject of this NOWNRE as well as the permit number. Should you have any questions concerning this
matter, please do not hesitate to call me at 704/669-1699, ext. 2180.
Sin erely,
Andrew H. Pitner, P.G.
Environmental Regional Supervisor
Attachment
Cc: Kim Colson & Ed Hardee, APS Land Application Unit
aF i le- QtG,208��01343
APS Central Files
Bob Wolcott, Operations Mgr., Alchem, Inc. 8135 Red Rd., 28138
Andrew Hammonds, DWM-Solid Waste Section, Fayetteville Regional Office
Art Barnhardt, DWQ-Aquifer Protection Section, Fayetteville Regional Office
Sherri Knight, DWQ-Aquifer Protection Section, Winston-Salem Regional Office
Henry Peele and Waymon L. Skeen, P.O. Box 377 Southmont, NC 27351-0000

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SOSID• 0002-743
Wa7c FtIlctl° 3 ®-1.550'00 PM
lame F Marshall
North Carolina Secretary of State
C200806000320
STATE OF NORTH CAROUNA
DEPARTMENT OF THE SECRETARY OF STATE
STATEMENT OF CHANGE OF REGISTERED
OFFICE AND/OR REGISTERED AGENT
Pursuant to §5513-31 of the General Statutes of North Carolina, the undersigned entity submits the following for the purpose of
changing its registered office and/or registered agent in the State of North Carolina.
INFORMATION CURRENTLY ON FILE
The name of the entity is Atchem,iln" 'i�r�A
Entity Type: Corporation, []Foreign Corporation, Nonprofit Corporation, []Foreign Nonprofit Corporation,
[]Limited Liability Company, []Foreign Limited Liability Company ❑Limited Partnership, []Foreign Limited Partnership,
❑Limited Liability Partnership, ❑Foreign Limited Liability Partnership
The street address and county of the entity's_; registered office currently on file is:
Number and Street:
ti' 0uie Pi11D elp ;I
City, State, Zip Cod' ;Bea Springs, NCT2837,,W
County: Robeson
The mailing address if different from the street address of the registered office currently on file is:
The name of the current registered agent is: Julia M. Andrews
NEW INFORMATION
1. The street address and county of the new registered office of the entity is:
(complete this item only if the address of the registered office Is being changed)
Number and Street:
City, State, Zip Code:
County:
2. The mailing address if different from the street address of the new registered office is:
(complete this item only if the address of the registered office is being changed)
3. The name of the new registered agent and the new agent's consent to appointment appears below:
(complete this item only if the name of the registered agent is being changed)
Randall F. Andrews
Type or Print Name of New Agent
Signature & Title
4. The address of the entity's registered office and the address of the business office of its registered agent, as changed,
will be identical.
5. This statement will be effective upon filing, unless a date and/or time is
This lFthe 24 day o ruar�i r-,-20Q8_ Alcli'e` Im nca ryl� a.it�
Signature
Randall F. Andrews, President
Type or Print Nameqnd'-Tine'
Notes: Filing fee is $5.00. This document must be filed with the Secretary of State.
Instead of signing here, the new registered agent may sign a separate written consent to the appoint'menG which must be attached to this statement.
CORPORATIONS DIVISION P. O. BOX 29622 RALEIGH, NC 27626-0622
Revised January 2002 Form BE-06

Alchem — Telephone Notes, Illegal Disposal
Feb. 8, 2008 Received by Peggy Finley at 3:15pm
Caller - Jason Williams cell 980/621-1651 home 704/857-1136
Mr. Williams was approached by an employee of Alchem (truck driver) about using Alchem
residuals as fill in a ravine on Mr. Williams' property. He was told that it was free and was
provided with a laboratory sheet that actually appeared to be for QA/QC. Mr. Williams called
us to inquire as to the wisdom of accepting this material. Peggy pointed out that the lab
sheet did not appear to provide information that would be useful in making that decision. In
addition, there was no guarantee that a laboratory report represented the materials that
would actually be brought to his property.