WQ0002702_Regional Office Historical File Pre 2018 (30)

SUSTAINABLE STRATEGIES FOR GLOBAL LEADERS
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January 26, 2010
Charlotte V. Jesnick, Head
North Carolina Department of Environment
and Natural Resources
Division of Waste Management
Inactive Hazardous Sites Branch
Superfund Section
1646 Mail Service Center
Raleigh, North Carolina 27699-1646
JAN 2 8 2010
Reference: Inclusion of Alchem, Inc. on the December 31, 2009
Inactive Hazardous Waste Site Priority List
Rockwell, Rowan County, North Carolina
Groundwater Incident No.: 200502451
Delta Project No.: 5EO805096P
® E L T AA Dear Ms. Jesnick:
am<,b« I,
Xinoge�—,ce
On behalf of Alchem, Inc. (Alchem), Delta Consultants has prepared
this letter regarding Alchem's inclusion on the December 31, 2009
State Inactive Hazardous Waste Site Priority List. Alchem requests
that the subject site be removed from the list based on the following
facts presented below.
Alchem manufactures aluminum sulfate, iron sulfate, calcium
hydroxide, and manganese hydroxide products for sale to private
industry and municipalities for use predominantly in wastewater
treatment operations. The subject site currently operates under two
permits issued by the North Carolina Department of Environment
and Natural Resources (NCDENR), Division of Water Quality
(DWQ) including a Recycle System Permit (WQ0002702) and a
Surface Disposal of Residual Solids Permit (WQ0016338).
Current groundwater assessment at the site has been directed by Ms.
Peggy Finley of the DWQ, Aquifer Protection Section (APS),
Mooresville Regional Office as detailed in correspondence to
Alchem dated February 5, 2008. Since contamination identified at
the site is represented by non -hazardous pollutants (pH and sulfate),
the DWQ, APS continues to regulate this site and has retained
jurisdiction as evidenced by correspondence issued to Alchem by the
DWQ, APS dated December 29, 2009 (two years and ten months
after the February 2007 reorganization of the NCDENR). The
Alchem site has been issued an incident number by the DWQ, APS
(No. 200502451) and groundwater impact at the site is currently
being defined under oversight by this division. The DWQ and its
predecessors have been regulating this site and incident for over 25
years.
8008 CORPORATE CENTER DRIVE SUITE 100 CHARLOTTE, NORTH CAROLINA 28226 USA
PHONE [phone] FAx [phone] WWW.DELTAENV.COM

Inclusion of Alchem, Inc. on the December 31, 2009
Inactive Hazardous Waste Sites Priority List
Rockwell, Rowan County, North Carolina
Groundwater Incident No. 200502451
Page 2 of 2
In addition to the fact that the DWQ has regulatory responsibility, the Alchem, site should also be
removed from the list since the site meets the first exception defined in the overview section of the
Inactive Hazardous Sites Branch (IHSB) website. The Alchem site (No. NONCD0001242) should
be excluded from the list of an inactive hazardous substance or waste disposal site under the statute
because the incident is related to "contamination resulting from permitted activities or those that
should have been permitted...".
Since the Alchem site meets the exception of an inactive hazardous substance or waste disposal site
and Since the DWQ, APS has retained jurisdiction for this incident, we request that the Alchem site
be removed from the State Inactive Hazardous Waste Site Priority List.
If you have any questions or comments or wish to discuss this matter further, please contact me at
[phone] or at [e-mail]. We look forward to your response.
Sincerely-,
DELTA CONSULTANTS
b
ohn D. Reuscher, P.G., RSM
Project Manager
PC: Mr. Randall F. Andrews — Alchem, Inc.
Mr. Bruce Parris — NCDENR, DWM, IHSB
`Ms: Beggy Finley NCDENR; DWQ,—APS

Finley, Peggy
From: John Reuscher [[e-mail]]
Sent: Friday, May 14, 2010 2:00 PM
To: Finley, Peggy
Subject: RE: Alchem Site
Thanks. Will do.
John Reuscher, P.G., RSM I Senior Project Manager I North American Operations
Delta Consultants, an Oranjewoud N.V. Company
Direct [phone] Mobile [phone] USA Toll Free 800 477 7411
jreuscherCldeltaenv.com I www.deltaenv.com
SUSTAINABLE STRATEGIES FOR GLOBAL LEADERS
Member of Inogen@ I www.inogenet.com
Confidentiality Notice: If you are not the intended recipient of this email, please delete it. Thank you.
From: Finley, Peggy[mailto:[e-mail]]
Sent: Friday, May 14, 2010 1:48 PM
Toi John Reuscher
Subject: RE: Alchem Site
John:
I've reviewed the lab results from the water samples. Since the concentration of sulfate in the Anderson well is so close
to the 2L standard, please sample this well again during the next round of quarterly sampling.
A formal report is not necessary at this time. Please just include the data for these wells in the next quarterly
monitoring report.
Peggy
From: John Reuscher [mailto:[e-mail]]
Sent: Monday, May 03, 2010 10:12 AM
To: Finley, Peggy
Cc: RANDALL ANDREWS
Subject: Alchem Site
Peggy:
Attached are the laboratory analytical results of the water samples collected from the Daniels (Barbara) and Anderson
water -supply wells on April 21, 2010. Both pH and sulfate are within the established range of 6.5 to 8.5 Standard Units
and below the established standard of 250 milligrams per liter, respectively.
Please review the results and contact me with any questions or comments. Also, if you prefer a formal letter report along
with updated tables and figures summarizing this data, please contact me.
Thanks and I look forward to your response.
John Reuscher, P.G., RSM I Senior Project Manager I North American Operations
Delta Consultants, an Oranjewoud N.V. Company

Finley, Peggy
From: John Reuscher [[e-mail]]
Sent: Monday, May 03, 2010 10:12 AM
To: Finley, Peggy
Cc: RANDALL ANDREWS
Subject: Alchem Site
Attachments: Daniels and Anderson Lab Results.pdf
Peggy
Attached are the laboratory analytical results of the water samples collected from the Daniels (Barbara) and Anderson
water -supply wells on April 21, 2010. Both pH and sulfate are within the established range of 6.5 to 8.5 Standard Units
and below the established standard of 250 milligrams per liter, respectively.
Please review the results and contact me with any questions or comments. Also, if you prefer a formal letter report along
with updated tables and figures summarizing this data, please contact me.
Thanks and I look forward to your response.
John Reuscher, P.G., RSM I Senior Project Manager I North American Operations
Delta Consultants, an Oranjewoud N.V. Company
Direct [phone] Mobile [phone] USA Toll Free 800 477 7411
[e-mail] I www.deltaenv.com
Member of Inogen@ I www.inogenet.com
Confidentiality Notice: If you are not the intended recipient of this email, please delete it. Thank you.

aceAnalytilcaf
www.pacekbs.com
April 30, 2010
John Reuscher
Delta Environmental Consultant
8008 Corp. Center Drive
Suite 100
Charlotte, NC 28226
RE: Project: Sampling 4/21
Pace Project No.: 9268005
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
Dear John Reuscher:
Enclosed are the analytical results for sample(s) received by the laboratory on April 23, 2010. The
results relate only to the samples included in this report. Results reported herein conform to the
most current NELAC standards, where applicable, unless otherwise narrated in the body of the
report.
Inorganic Wet Chemistry and Metals analyses were performed at our Pace Asheville laboratory and
Organic testing was performed at our Pace Huntersville laboratory unless otherwise footnoted. All
Microbiological analyses were performed at the laboratory where the samples were received.
If you have any questions concerning this report, please feel free to contact me.
Sincerely,
Kevin Godwin
[e-mail]
Project Manager
Enclosures
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
I�VIYL�z
�a
Page 1 of 9

('15'oeAnalytical
www.pscelabs.ccm
Project: Sampling 4%21
Pace Project No.: 9268005
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
CERTIFICATIONS
Asheville Certification IDs
2225 Riverside Dr. Asheville, NC 28804
North Carolina Drinking Water Certification #: 37712
Connecticut Certification #: PH-0106
North Carolina Bioassay Certification #: 9
Virginia Certification #: 00072
New Jersey Certification #: NC011
Tennessee Certification #: 2980
Massachusetts Certification #: M-NC030
South Carolina Certification #: 9903001
Louisiana/LELAP Certification #: 03095
South Carolina Bioassay Certification #: 9903002
Florida/NELAP Certification #: E87648
Pennsylvania Certification #: 68-03578
West Virginia Certification #: 356
North Carolina Wastewater Certification #: 40
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
Page 2 of 9

;5neAnalXical
www.pacelabs cw
Project: Sampling 4/21
Pace Project No.: 9268005
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
SAMPLE SUMMARY
Lab ID
Sample ID
Matrix
Date Collected
Date Received
9268005001
9268005002
DANIELS
ANDERSON
Water
Water
04/21/10 16:30
04/21/10 16:00
04/23/10 09:30
04/23/10 09:30
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
rapnC4-F.
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
Page 3 of 9

aceAnalytical
www.pacelabaccm
Project: Sampling 4/21
Pace Project No.: 9268005
Lab ID Sample ID
9268005001 DANIELS
9268006002 ANDERSON
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
SAMPLE ANALYTE COUNT
Method
EPA 9040
ASTM D516-90
EPA 9040
ASTM D516-90
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
Analytes
Analysts
Reported
SAJ
1
SAJ
1
SAJ
1
SAJ
1
r
Page 4 of 9

aceAnali cal it
www.pacelabsx=
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
ANALYTICAL RESULTS
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
Project: Sampling 4/21
Pace Project No.: 9268005
Sample: DANIELS Lab ID: 9268006001 Collected: 04/21/10 16:30 Received: 04/23/10 09:30 Matrix: Water
Parameters Results Units Report Limit DF Prepared Analyzed CAS No. Qual
9040 pH Analytical Method: EPA 9040
pH 6.9 Std. Units 0.10 1 04/27/10 09:55 H6
ASTM D516-90 Sulfate Water Analytical Method: ASTM D516-90
Sulfate 27.8 mg/L 5.0 1 04/30/1010:35 14808-79-8
Date: 04/30/2010 06:06 PM
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
■y�� N ACCpq
`L11 i
Page 5 of 9

aceAnalylical
..pscelabs.com
Project: Sampling 4/21
Pace Project No.: 9268005
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
ANALYTICAL RESULTS
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
Sample: ANDERSON Lab ID: 9268005002 Collected: 04/21/10 16:00 Received: 04/23/10 09:30 Matrix: Water
Parameters Results Units Report Limit DF Prepared Analyzed CAS No. Qual
9040 pH Analytical Method: EPA 9040 '
pH 6.7 Std. Units 0.10 1 04/27/10 09:55 H6
ASTMI D516-90 Sulfate Water Analytical Method: ASTM D516-90
Sulfate 2" mg/L 55.0 11 04/30/10 11:29 14808-79-8
Date: 04/30/2010 06:06 PM REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
Page 6 of 9

aceAnalyiical
wmpacelabs com
Project: Sampling 4/21
Pace Project No.: 9268005
QC Batch: WET/12183
QC Batch Method: EPA 9040
Associated Lab Samples: 9268005001, 9268005002
SAMPLE DUPLICATE: 434002
Parameter Units
pH
Date: 04/30/2010 06:06 PM
Std. Units
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
QUALITY CONTROL DATA
Analysis Method: EPA 9040
Analysis Description: 9040 pH
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 2B078
[phone]
9267688002 Dup Max
Result Result RPD RPD Qualifiers
7.1 7.1 0 20 H6
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
Page 7 of 9

acmnalytical
www.pacelabs.com
Project: Sampling 4/21
Pace Project No.: 9268005
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
QUALITY CONTROL DATA
• v 1.
Pace Analytical Services, Inc. .
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
QC Batch: WETA/7263 Analysis Method: ASTM D516-90
QC Batch Method: ASTM D516-90 Analysis Description: ASTM D516-90 Sulfate Water
Associated Lab Samples: 9268005001, 9268005002
METHOD BLANK: 435345 Matrix: Water
Associated Lab Samples: 9268005001, 9268005002
Blank Reporting
Parameter Units Result Limit Analyzed Qualifiers
Sulfate mg/L ND 5.0 04/30/1010:30
LABORATORY CONTROL SAMPLE: 435346
Spike LCS LCS % Rec
Parameter Units Conc. Result % Rec Limits Qualifiers
Sulfate mg/L 20 20.5 102 90-110
MATRIX SPIKE SAMPLE:
435347
9268001006
Spike
MS
MS
% Rec
Parameter
Units
Result
Conc.
Result
% Rec
Limits Qualifiers
Sulfate
mg/L
17.1
20
35.8
93
75-125
MATRIX SPIKE SAMPLE:
435350
9267844005
Spike
MS
MS
% Rec
Parameter
Units
Result
Conc.
Result
% Rec
Limits Qualifiers
Sulfate
mg/L
ND
20
24.5
100
75-125
SAMPLE DUPLICATE: 435348
9268001005
Dup
Max
Parameter
Units
Result
Result
RPD
RPD
Qualifiers
Sulfate
mg/L
7.2
7.1
1
20
SAMPLE DUPLICATE: 435349
9267844004
Dup
Max
Parameter
Units
Result
Result
RPD
RPD
Qualifiers
Sulfate
mg/L
37.5
38.0
1
20
Date: 04/30/2010 06:06 PM
REPORT OF LABORATORY ANALYSIS
Page 8 of 9
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc

• aceAnalj&al
www.pacelabs mm
QUALIFIERS
Project: Sampling 4/21
Pace Project No.: 9268005
T�91v!I�IiPI:F-'?
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
DF - Dilution Factor, if reported, represents the factor applied to the reported data due to changes in sample preparation, dilution of
the sample aliquot, or moisture content.
ND - Not Detected at or above adjusted reporting limit.
J - Estimated concentration above the adjusted method detection limit and below the adjusted reporting limit.
MDL -Adjusted Method Detection Limit.
S - Surrogate
1,2-Diphenylhydrazine (8270 listed analyte) decomposes to Azobenzene.
Consistent with EPA guidelines, unrounded data are displayed and have been used to calculate % recovery and RPD values.
LCS(D) - Laboratory Control Sample (Duplicate)
MS(D) - Matrix Spike (Duplicate)
DUP - Sample Duplicate
RPD - Relative Percent Difference
NC - Not Calculable.
Pace Analytical is NELAP accredited. Contact your Pace PM for the current list of accredited analytes.
U - Indicates the compound was analyzed for, but not detected.
ANALYTE QUALIFIERS
H6 Analysis initiated more than 15 minutes after sample collection.
Date: 04/30/2010 06:06 PM REPORT OF LABORATORY ANALYSIS Page 9 of 9
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
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ZeAnalytical
www.pacelabs.com
CHAIN -OF -CUSTODY / Analytical Request Document
The Chain -of -Custody is a LEGAL DOCUMENT. All relevant fields must be completed accurately.
Section A Section B Section C
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Required Client Information: Required Project Information: Invoice Information:
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Finley, Peggy
From: Finley, Peggy
Sent: Thursday, January 14, 2010 1:14 PM
To: 'John Reuscher'; Peggy Finley
Cc: RANDALL ANDREWS
Subject: RE: Samples Meeting
John:
This is a follow-up to our telephone conversation this morning.
Since Mr. Samples has denied access, a transitional bedrock monitoring well needs to be installed near Alchem's
property boundary in proximity to MW-7.
Please continue to monitor Mr. Samples water supply well as part of the quarterly sampling program.
Peggy
From: John Reuscher [mailto:][e-mail]]
Sent: Wednesday, January 13, 2010 3:41 PM
To: Peggy Finley
Cc: RANDALL ANDREWS
Subject: Possibly spam: Samples Meeting
Peggy:
We met with Mr. Larry Samples yesterday to discuss the installation of monitoring wells on his property to better define
groundwater quality to the east/northeast of Alchem. He is not going to allow Delta to install the wells on his property.
The other property owners located in the area where we need to install the wells have not responded to any of our
certified letter requests to sample their wells so it is doubtful they will respond to the request to install wells.
As a result, it is unlikely that we will get permission from nearby property owners to define groundwater quality in that
direction. We can install the wells which we have permits for and continue to monitor Mr. Samples well.
Please call me to discuss and to advise. Thanks.
John Reuscher, P.G., RSM I Project Manager I North American Operations
Delta Consultants, an Oranjewoud N.V. Company
Direct [phone] Mobile [phone] USA Toll Free 800 477 7411
ireuscher(o)deltaenv.com I www.deltaenv.com
SUSTAINABLE STRATEGIES FOR GLOBAL LEADERS
Member of Inogen@ I www.inogenet.com
Confidentiality Notice: If you are not the intended recipient of this email, please delete it. Thank you.

NCDENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Division of Water Quality Secretary
December 29, 2009
Alchem, Inc.
2042 Buie Philadelphus Road
Red Springs, North Carolina 28337
Attention: Randall Andrews
RE: Request for Extension
Second Comprehensive Site Assessment Addendum
Red Road Facility
Rowan County, N.C.
Dear Mr. Andrews:
On December 28, 2009, this office received your consultant's request for an extension of the deadline for submission of your
second CSA addendum. The report was due in this office by January 15, 2010. It was stated in the correspondence that
negotiations are underway to secure access to install a monitoring well(s) on the Larry Samples property but that this cannot be
finalized before January 12, 2010. The purpose of these wells would be to establish vertical and horizontal extent of groundwater
contamination to the northeast of the Alchem property
Your request for an extension is hereby granted until March 30, 2010. Your report should also include data and evaluation of.the
quarterly sampling event in February. Should unforeseen obstacles arise that may prevent you from meeting this deadline, you
must notify this office immediately.
Please be advised that prior to the installation of these monitoring wells, it will be necessary for you to obtain a monitoring well
permit from this office. Should you have any questions, please call me at 704/235-2183 or contact me via email at:
peggy.finley0ncdenr.gov.
Sincerely,
Peggy Finley
Environmental Specialist
Cc: Robert Wolcott — Alchem, Inc., 8135 Red Road, Rockwell 28138
John Reuscher, P.G. — Delta Consultants, 8008 Corporate Center Dr., Ste.100, Charlotte 28226
MAF/achem/CSA/ext req 12-29-09
610 East Center Avenue, Suite 301, Mooresville, North Carolina 28115 One
Phone: [phone] FAX: [phone] Internet: www.ncwaterquality.org NNat
o�%�-a olina
An Equal Opportunity 1 Affirmative Action Employer— 50% Recycled 110% Post Consumer Paper "���

Finley, Peggy
From: John Reuscher [[e-mail]]
Sent: Monday, December 28, 2009 2:42 PM
To: Peggy Finley
Cc: RANDALL ANDREWS
Subject: Alchem Incident No. 200502451
Peggy:
We have received our permit from the NCDENR to install monitoring wells on the Industrial and Agricultural Chemicals,
Inc. (IAC) property and within the North Carolina Department of Transportation (NCDOT) right of way along Red Road.
As such, we have permission from IAC and NCDOT as well.
We are in the process of obtaining permission from Larry Samples to install wells on his property to better define
groundwater quality to the northeast of Alchem. Mr. Samples cannot meet with us to discuss our proposed locations on
his property until January 12, 2010 due to health issues with his wife and father-in-law. As a result, it is unlikely that we
can meet the deadline of January 15, 2010 for completion of the second CSA Addendum as requested in your letter to
Alchem dated October 14, 2009. Mr. Samples property is the only real alternative we have northeast of the site since we
have received no response from other nearby property owners regarding our water -supply well survey/sampling request.
We submitted the Quarterly Groundwater Monitoring Results report to you on December 12, 2009 which clarified items
No. 2, 3, and 4 in your letter. The next quarterly sampling event will be conducted in February 2010. The installation of
the off -site wells we proposed and agreed upon by you will provide the information requested in item No. 1 of the letter.
We can schedule the installation of the IAC and NCDOT wells at this time but wanted to make you aware of the Samples
situation. As such, to provide the data you requested, Alchem would likely require an extension to submittal of the second
Addendum.
Please advise and thank you.
John Reuscher, P.G., RSM I Project Manager I North American Operations
Delta Consultants, an Oranjewoud N.V. Company
Direct [phone] Mobile [phone] USA Toll Free 800 477 7411
[e-mail] I www.deltaenv.com
SUSTAINABLE STRATEGIES FOR GLOBAL LEADERS
Member of Inogenp I www.inogenet.com
Confidentiality Notice: If you are not the intended recipient of this email, please delete it. Thank you.

Finley, Peggy
From:
John Reuscher [[e-mail]]
Sent:
Thursday, November 12, 2009 4:38 PM
To:
Peggy Finley
Cc:
RANDALL ANDREWS
Subject:
Alchem Additional Assessment
Attachments:
ALCHEM - Proposed Well Location Map.pdf
Peggy:
Please find the attached Proposed Groundwater Monitoring Well Location Map for the Alchem site (Incident No.
200502451). The proposed wells include two shallow Type II wells and three deep Type III wells at the locations shown in
green. One well pair will be installed in the NCDOT right of way along Red Road, one pair on Industrial and Agricultural
Chemicals, Inc. property east of the Alchem property, and one deep well to pair with shallow well MW-7. The owner of the
property south of MW-4 has not accepted previous certified mail submitted to him in order to gain access to the property
and it is unlikely that will change in the future (considering past relationships).
Since installing deep monitoring wells is very expensive we wanted to get your input into our proposed plan prior to
implementation. Please review the attached and let us know your thoughts as well as any revisions that you might
suggest as we move forward. A quarterly sampling event is being scheduled for next week, which will include the on -site
monitoring wells and water -supply wells as well as three off -site water -supply wells (Beaver, Samples, and Daniels) for
analysis of pH and sulfate. We have not received an authorized access agreement to sample the well on
the Bautista/McIntyre property; however, these parcels are connected to municipal water supplied by Alchem.
Thank you and we look forward to your response.
John Reuscher, P.G., RSM I Project Manager I North American Operations
Delta Consultants, an Oranjewoud N.V. Company
Direct [phone] Mobile [phone] USA Toll Free 800 477 7411
ireuscher0deltaenv.com I www.deltaenv.com
SUSTAINABLE STRATEGIES FOR GLOBAL LEADERS
Member of Inogen@ I www.inogenet.com
Confidentiality Notice: If you are not the intended recipient of this email, please delete it. Thank you.

Corrective Action Groundwater Monitoring Network
• Include the compliance wells in Permit No. WQ0001730 in the corrective action
monitoring.
- These wells are MW-13, MW-20, MW-22, MW-41, MW-42, MW-44, MW-45, MW-
46, MW-47, MW-48, MW-49, MW-50, MW-51, MW-52, MW-53, and MW-54.
- The permit compliance sampling schedule is the same as the recommended
monitoring schedule (March, July, and November of each year).
• Continue sampling and monitoring the existing groundwater monitoring wells shown
in Figure 1 the Groundwater Corrective Action Variance Application (June 26, 2009).
- All "active monitoring wells" listed on Figure 1: TW-1, TW-2, TW-9, TW-11, TW-
14, TW-16, TW-18, TW-24, TW-25, TW-30, TW-30.1, TW-31, TW-31 A, TW-32,
TW-32A, TW-33, TW-34, TW-35, TW-36, TW-37, TW-45A, TW-642, MW-100,
MW-101, MW-101 D, MW-102, MW-103, MW-104, MW-105, MW-105D, MW-106,
MWA 07, MWA 08, MWA 09, MWA 10, MWA 11, MWA 11 D, MWA 12, MWA 13D,
MW114, MW-115, MW-116, MW-117, MW-121, MW-122, MW-122D, MW-123D,
MW-124D, MW-125D, MW-126D, MW-127, MW-201, MW-202, MW-203, GP-1,
GP-3, GP-5, GP-8, GP-9, GP-10, GP-12, GP-17, GP-21, and GP-22.
- Replace monitoring wells in this network that are chronically dry with deeper wells.
Use existing water level information to plan replacement well depths such that well
would not be expected to be dry under typical seasonal conditions.
- After reviewing the "Remediation and Non-compliance Well Data" received on
August 31, 2009, DWQ identified several "active monitoring wells" as chronically
dry such that water quality parameters could not be collected. For this review,
"chronically dry" was defined as the well being listed as "dry" three or more times
during the time period from January 2007 through July 2009 on a sampling
schedule three times each year (March, July, and November). These wells are
TW-1, TW-2, TW-14, TW-16, TW-31A, TW-45A, MW-104, MW-121, MW-124A,
GP-1, GP-3, GP-5, GP-8, GP-10, GP-12, and GP-22.
- Specifically, it is recommended that monitoring wells MW-121, MW-104, and GP-3
be replaced with wells screened in partially weathered rock or bedrock.
• The existing wells at the site are predominantly shallow and screened in saprolite.
To address concerns about the nitrate impacts to deeper groundwater in the partially
weathered rock and bedrock aquifers, the installation of additional deep wells is
recommended in several locations.
- Install a deep well screened in partially weathered rock south of Field 60, near or
adjacent to existing well MW-48.
- Install a deep well screened in bedrock near or adjacent to existing well MW-112.
24

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LOCATION MAP
FlGURE NO.:
ALCHEM, INC.
DATE:
REV.:
D E LTA
ROCKWELL,
NORTH
CAROLINA
10/27/08
10/05/09

(��' �-n �,j 4-,,� v-,,— j, 6,_e
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74
r
NCDENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor . Division of Water Quality Secretary
September 20, 2010
Alchem, Inc.
2042 Buie Philadelphus Road
Red Springs, North Carolina 28337
Attention: Randall Andrews
RE: Request for Extension
Submission of Corrective Action Plan
Red Road Facility, Rockwell
Groundwater Incident No. 2997
Rowan County, N.C.
Dear Mr. Andrews:
Your request for an extension was received in this office on September 15, 2010. Based on the
information provided, the request is hereby granted. The plan will be due in this office no later than
December 20, 2010.
Should you have any questions, please call me or Peggy Finley at 704/663-1699.
Sincerely,
Andrew H. Pitner, P.G.
Environmental Program Supervisor III
Aquifer Protection Section
Cc: Groundwater Investigation Unit, APS
John Reuscher, P.G., Delta Environmental, 8008 Corporate Center Dr., Ste. 100, Charlotte 28226
MAF/alchem CAP ext req 9-20-10
610 East Center Avenue, Suite 301, Mooresville, Noah Carolina 28115
Phone: [phone] FAX: [phone] Internet: www.ncwaterquality.org
An Equal Opportunity 1 Affirmative Action Employer— 50% Recycled 110% Post Consumer Paper
Nne
orthCarolina
�Vaturjallry

SUSTAINABLE STRATEGIES FOR GLOBAL LEADERS
LTA
September' 13, 20`10
North Carolina Department ofEnviroiunent
`and Natural Resources
Division of Water Quality -
Aquifer Protection Section
610 East Center Avenue, Suite 301
Mooresville, North Carolina 28115
Attn: Peggy Finley
Subject: Request for Extension
Corrective Action Plan
Alchem, Inc. Site
Rockwell, Rowan County, North Carolina
Incident No.: 2997
Delta Project No.: 5E0805096P
Dear Peggy:
On behalf of Alchem, Inc. (Alchem), Delta Consultants (Delta) is
requesting an extension for completion and submittal of the Corrective
Action Plan as requested by your office in the Acknowledgement of Receipt,
CSA — Addendum C dated July 23, 2010.
Delta requests anextension of 90 days from the date of this letter to review
available technologies applicable for remediating groundwater impacted by
low pH and elevated concentrations of sulfate. Based on our review of the
site hydrogeological characteristics and initial discussions with remediation
contractors; typical remedial technologies such as in situ chemical
reduction and groundwater extraction would not likely be feasible
alternatives for groundwater cleanup at the site. As a result, further
investigations into alternative technologies are necessary.
Groundwater monitoring of the incident related monitoring and water -
supply wells is planned for October 2010. This event will be coordinated
with the monitoring required to comply with Alchem's non -discharge
permit WQ0002702 (condition 33). A groundwater monitoring report will
be provided to you within 60 days of completing the sampling event.
We appreciate your consideration for the extension requested. If you have
any questions or comments, please do not hesitate to contact me at (704)
543-3928 or at jreuschergdeltaenv.com.
Sincerely,
DELTA CONSULTANTS
QoD. Reuscher,
Senior Project Manager
. -b,, f.
8008 CORPORATE CENTER DRIVE SUITE 100 CHARLOTTE, NORTH CAROLINA 28226 USA
Ino en°
me gE���.�,,,,,,�Ce PHONE [phone] FAX [phone] WwW.DELTAENV.COM

METHOD 6020A
INDUCTIVELY COUPLED PLASMA -MASS SPECTROMETRY
SW-846 is not intended to be an analytical training manual. Therefore, method
procedures are..written based on the assumption that they will be performed. by analysts who are
formally trained in at least the basic principles of chemical analysis and in the use of the subject
technology.
In addition, SW-846 methods, with the exception of required method use for the analysis
of method -defined parameters, are intended to be guidance methods which contain general
information on how to perform an analytical procedure or technique which a laboratory can use
as a basic starting point for generating its own detailed Standard Operating Procedure (SOP),
either for its own general use or for a specific project application. The performance data
included in this method are for guidance purposes only, and are not intended to be and must
not be used as absolute QC acceptance criteria for purposes of laboratory accreditation.
1.0 SCOPE AND APPLICATION
1:1 Inductively coupled plasma -mass spectrometry (ICP-MS) is applicable to the
determination of sub-Ng/L concentrations of a large number of elements in water samples and in
waste extracts or. digests (Refs. 1 and 2). When dissolved constituents are required, samples
must be filtered. and acid -preserved prior to analysis. No digestion is required prior to analysis
for dissolved elements in water samples. Acid digestion prior to filtration and analysis is
required for groundwater, aqueous samples, industrial wastes, soils, sludges, sediments, and
other solid wastes for which total (acid -soluble) elements are required.
1.2 ICP-MS has been applied to the determination of over 60 elements in various
matrices. Analytes for which EPA has demonstrated the acceptability of this method in a multi -
laboratory study on solid and aqueous wastes are listed below.
Element
CASRN8
UJ Aluminum
(AI) —
7429-90-5
Antimony .
(Sb)
7440-36-0
Arsenic
(As)—
7440-38-2
Barium
(Ba)
7440-39-3
Beryllium
(Be)
7440-41-7
Cadmium
(Cd)
7440-43-9
Calcium
(Ca)
7440-70-2
Chromium
(Cr) —
7440-47-3
Cobalt
(Co)
7440-48-4
Copper
(Cu)
7440-50-8
W 5 (�Jl ron
(Fe)
7439=89-6
w50 Lead
(Pb) —
7439-92-1
Magnesium
(Mg)
7439-95-4
yy,JManganese
(Mn)---
7439-96-5
Mercury
(Hg)
7439-97-6
Nickel
(Ni) —
7440-02-0
Vs�
uJ ,le,
6020A - 1 Revision 1
February 2007

METHOD 6010C
INDUCTIVELY COUPLED PLASMA -ATOMIC EMISSION SPECTROMETRY
SW 846 is not intended to be an analytical training manual. Therefore, method
procedures are written based on the assumption that they will be performed by analysts who are
formally trained in at least the basic principles of chemical analysis and in the use of the subject
technology.
In addition,•SW-846 methods, with the exception of required method use for the analysis
of method -defined parameters, are intended to be guidance methods which contain general
information on how to perform an analytical procedure or technique which a laboratory can use
as a basic starting. point for generating its own detailed Standard Operating Procedure (SOP),
either for its own general use or for a specific project application. The performance data
included in this method are for guidance purposes only, and are not intended to be and must
not be used as absolute QC acceptance criteria for purposes of laboratory accreditation.
1.0 SCOPE AND APPLICATION
1.1 Inductively coupled plasma -atomic emission spectrometry (ICP=AES) may be used
to determine trace elements in solution. With the exception of groundwater samples, all
aqueous and solid matrices need acid digestion prior to analysis. Groundwater samples that
were prefiltered and acidified will not need acid digestion. Samples which are not digested
need either an internal standard or should be matrix -matched with the standards. If either
option is used, instrument software should be programmed to correct for intensity differences of
the internal standard between samples and standards. Refer to Chapter Three, "Inorganic
Analytes," for a listing of digestion procedures that may be appropriate. The following analytes
have been determined by this method:
Element Symbol CAS Number Element Symbol CAS Number
Aluminum
Al
7429-90-5
Mercury
Hg
Antimony
Sb
7440-36-0
Molybdenum
Mo
Arsenic
As
7440-38-2
Nickel
Ni
Barium
Ba
7440-39-3
Phosphorus
P
Beryllium
Be
7440-41-7
Potassium
K
Boron -
B
7440-42-8
Selenium
Se
Cadmium
Cd
7440-43-9
Silica
SiOZ
Calcium
Ca
7440-70-2
Silver
Ag
Chromium
Cr
7440-47-3
Sodium
Na
Cobalt
Co
7440-48-4
Strotium
Sr
Copper.
Cu
7440-50-8
Thallium
TI
Iron .
Fe
7439-89-6
Tin
Sn
Lead
Pb
7439-92-1
Titanium
Ti
Lithium
Li
7439-93-2
Vanadium
V
6010C - 1
7439-97-6
7439-98-7
7440-02-0
7723-14-0
7440-09-7
7782-49-2
7631-86-9
7440-22-4
7440-23-5
7440-24-6
7440-28-0
7440-31-5
7440-32-6
7440-62-2
Revision 3
February 2007

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleen 11. Sullins Director
Division of Water Quality
August 15, 2007
MEMORANDUM
TO: All Laboratories, Consultants, Permittees, and Interested Parties
FROM: Ted L. Bush, Jr., Chief
Aquifer. Protection Secti
SUBJECT: Aquifer Protection See ion Policy for Metals Determinations Required by
15A NCAC 2L
The policy that addresses the preparation of groundwater samples for metals analyses,
implemented March 1, 1993 under the former Division of Environmental Management,
Groundwater Section, currently the Division of Water Quality, Aquifer Protection Section, is still
in effect. All groundwater samples for metals analyses required by the North Carolina Division
of Water Quality, Aquifer Protection Section, will be collected and analyzed according to
Standard Method 3030C "Preliminary Treatment for Acid -Extractable Metals", "Preliminary
Treatment for Acid -Extractable Metals, Standard Methods for the Examination of Water and
Wastewater 17th edition, 1989, 18th edition, 1992, and 19t1i edition, 1995. Specific conditions that
are outlined in. this memorandum will apply.
The policy was implemented to establish statewide consistency in the handling of
groundwater sample analyses and continues to be applicable.
. 15A NCAC 2L .0202(g) that addresses Class GA Standards for groundwater, states that
"the standard refers to the total concentration in milligrams per liter of any constituent in a.
dissolved, colloidal or particulate form that is mobile in groundwater." The purpose of collecting
and analyzing groundwater samples is to obtain a representation of constituents that are mobile
in groundwater. This can usually be achieved with few problems when. clear samples are
collected from wells that have been properly developed so that sediment in the water is minimal.
There has been considerable controversy about whether or not highly sedimented samples
(primarily a result of poor well construction and/or poor well development) should be filtered
prior.to laboratory analysis. In the past some samples have been filtered in the held or laboratory
prior to analysis. There was no consistency on when, and under what conditions, filtration tools
place. In other instances, no filtration was conducted, all acid -reactive particulate matter was
digested (i.e. dissolved and digested in boiling nitric acid), and the result reported as a "total"
concentration. These inconsistencies have caused conflict and confusion among permittees,
consultants, laboratories, regional office personnel, and other regulatory officials. There is no
olle
No thCarolina
. �GZifllPll��1,1
Aquifer Protection Section 1636 Mail Service Cutter
lnternt t: www.ncwaterquality.ora Location: 2728 Capital Boulevard
An Equal Opportunity/Affirmative Action Employer— 50% Recyded/10% Post Consumer Paper
Raleigh, NC 27699-1636 Telephone: [phone]
Raleigh, NC27604 Fax 1: [phone]
Fax 2: [phone]
Customer Service: [phone]

established guidance for clarification of highly sedimented samples analyzed for mobile
constituents in groundwater. Inquiries and -requests for guidance from the U.S. Environmental
Protection Agency, U.S. Geological Survey, environmental industry, and the scientific
community, failed to provide a consistent resolution of the concerns. There seems to be no way
to differentiate between sediment that represents formational material in a sample, and mobile
particulates or precipitates.
Laboratory analysis of groundwater is our primary tool for evaluating compliance with
groundwater quality standards. We, therefore, must ensure that those analyses reflect as little
bias as possible as a result of the presence of sediment in samples being analyzed for metals that
are.mobile (i.e., dissolved and colloidal phases). Well redevelopment has been recommended for
highly sedimented wells. Other recommendations have included using specific groundwater
sample collection techniques, such as low flow purging andsampling, as well as purging and
then allowing wells to settle for up to 24 hours prior to collecting samples when sediment in
wells is a problem. Analysis for "Total Metals" and "Total Recoverable Metals" have been the
established methods for determining total concentrations, however both employ digestion
.procedures that may bias results high by including metals in the sediment as well -as colloidal and
dissolved phases. On the other hand, analysis for "Dissolved Metals" may bias results low as a
result of sample filtration through a 0.45 micron filter prior to acidification. Filtration prior to
acidification may remove some normally mobile metals that are colloids, metals that have been
absorbed onto formational material, or metals that have moved from the liquid to solid phase as
chemical precipitates upon exposure to air.
Standard Method 3030C, "Preliminary Treatment for Acid -Extractable Metals,"
(Standard Methods for the Examination of Water and Wastewater 17`h edition, 1989, 181h edition,
1992, and 19`h edition, 1995) was designed to determine both the dissolved and extractable
metals lightly adsorbed on particulate matter. Of the established methods available, this method
provides the least impact from sediment on groundwater analyses for total concentrations of
mobile metals.
The following policy, established March 1, 1993 to address treatment of all groundwater
quality samples for metal analyses required by 15A NCAC 2L is still applicable:
Note: This policy affects those metals analyses that are required to determine
compliance with North Carolina's groundwater quality standards. Additional
metals analyses, that may be required under local ordinances or federal
regulations (such as RCRA and CERCLA), are not affected by this policy.
Sample filtration in the field will not be permitted for metals analyses.
Standard Method 3030C, "Preliminary Treatment for Acid -Extractable Metals,"
(Standard Methods for the Examination of Water and Wastewater 17`h edition, 1989, 181h
edition., 1992, and 19`h edition, 1995) will be the only accepted preparation method for all
metals analyses, except mercury, for determination of compliance with groundwater
quality standards in 15A NCAC 2L .0202. This method requires field acidification, and
laboratory filtration following an acid extraction procedure. Acid contact time (holding

time) and filter size are unspecified by the method and must be specified as procedural
conditions. Since the objective of the method is to extract metals which are lightly
adsorbed on particulate material while limiting absorption by the sample container, it is,
necessary to limit the acid contact time in order to minimize the dissolution of some
formational material that may be present. The following specific conditions will apply to
all groundwater samples for metals analysis:
Samples must be acidified at the time of collection with 5 mL of concentrated
nitric acid per liter of sample, maintained at 4° C, and delivered to the laboratory
so that preparation for analysis (acid extraction and filtration) can be completed
within 72 hours of collection. Acid may be added to the samples in the field at
the time of collection, or may be added to the clean containers prior to transport to
the field. A 0.45-micron filter must be used .for filtration in the laboratory
following acid extraction.
A 72 hour holding time is specified for sample preparation (acid extraction and
filtration) to allow reasonable transport time to the laboratories and to allow some
flexibility in scheduling sample collection while minimizing acid contact tithe.
Since field acidification will prevent precipitation and adsorption of metals onto
the container, and filtration is required after acid extraction in the laboratory, a
sinall pore size (6.45 micron) filter is specified.
Please ensure that this policy, effective March 1, 1993 and still applicable, continues to
be adhered to by all staff and applicable members of the public.
cc: Environmental Regional Supervisors
Coleen Sullins
Debra Watts
Betty Wilcox
Files

6
A
NCDNgR
North Carolina Department of Environment and
Beverly Eaves Perdue
Governor
Alchem, Inc.
2042 Buie Philadelphus Road
Red Springs, North Carolina 28337
Attention: Randall Andrews
Dear Mr. Andrews:
Coleen H. Sullins
Division of Water Quality
t
Natural Resources
Dee Freeman
Secretary
May 28, 2009
RE: Third Request for Extension
Comprehensive Site Assessment
Red Road Facility
Rowan County, N.C.
In a January 29, 2009 letter, this office requested that you to submit a CSA addendum -by April 30, 2009. Your most recent CSA
extension request was received in this office on May 12, 2009. Robert Wolcott, your operations manager, provided some additional
information during a telephone conversation with me on May 26.
Your request for an extension is hereby granted on the condition that you provide monthly updates via emails to this office on your
progress. The addendum report is due in this office no later than August 31, 2009. Should unforeseen obstacles arise that may
prevent you from meeting this deadline, you must notify this office immediately. It should be noted that the new deadline is more
than one year beyond when the completed CSA was originally due! You should be aware that failure to meet the deadline may
subject you to a civil penalty assessment under the authority of G.S.143-215.6A of up to $10,000 a day from the original due date.
Please be advised that prior to the installation of off -site monitoring wells, it will be necessary for you to obtain a monitoring well
permit from this office. Should you have any questions, please call me at 704/235-2183 or contact me via email at:
peq_ yq finley @ncdenr.gov.
Sincerely,
Pe yUny.
Environmental Specialist
Cc: Robert Wolcott— Alchem, Inc., 8135 Red Road, Rockwell 28138
John Reuscher, P.G. — Delta Consultants, 8008 Corporate Center Dr., Ste.100, Charlotte 28226
610 East Center Avenue, Suite 301, Mooresville, North Carolina 28115
Phone: [phone] FAX: [phone] Internet: www,ncwaterquality.org
An Equal opportunity l Affirmative Action Employer— 50% Recycled %.10% Post Consumer Paper
NorthCarolina
�Vaturallff

SUSTAINABLE STRATEGIES FOR GLOBAL LEADERS
May 11, .2009
North 'Carolina Department bf Environment
and Natural Resources
Division of Water Quality
Aquifer Protection Section D
610 East Center Avenue, Suite 3 V9 12
Mooresville, North Carolina 2811
Attn- Peggy Finley ' pWQ -Aquifer Protection 1
Subject- Request for Extension
Comprehensive Site Assessment Addendum
Alchem, Inc. Facility
D EL T A Rockwell, Rowan County, North Carolina
Delta Project No.: 5EO805096P
Dear Peggy:-
On'behalf of Alchem, Inc. (Alchem), Delta Consultants (Delta)
is requesting'an extension for--completionand submittal of the
Comprehensive Site Assessment (CSA) Addendum as
requested by your office in the Acknowledgement of
Receipt/Additional Info Request dated January 29, 2009.
Delta requests an extension of 120 days from receipt of this
letter to conduct the necessary additional CSA components
and provide an addendum report summarizing these activities.
To date, Delta has completed the following activities related to
the CSA Addendum:
■ A review of available files at the DWQ Mooresville
Regional Office was completed in March 2009.
■ Property owners with water -supply wells located within
1,500 feet of the Alchem site were contacted via
certified mail in March 2009 regarding available
construction and usage information of their well(s) as
well as access approval to collect a groundwater quality
sample from the well(s). To date out of the 59 property
owners contacted, we have received 20 responses and
13 returned certified letters (34% response). It is
unlikely that the response percentage will increase
dramatically in the future.
a member of:
8008 CORPORATE CENTER DRIVE SUITE 100 CHARLOTTE, NORTH CAROLINA 28226 USA
Ino en
gEnwonmentnlAlliance PHONE [phone] FAX [phone] WWW.DELTAENV.COM

Request for Extension
' Alchem, Inc. Facility
Rockwell, North Carolina
Additional tasks are currently being evaluated and budgeted including:
May 11, 2009
Page 2
• Off -site monitoring well installations (two) along Red Road within the North Carolina
Department of Transportation right of way;
■ Completion of the unused, on -site water -supply well (WW-3) as a deep monitoring
well (including packer testing and down -hole video logging);
• Completion of the deep, on -site monitoring well (MW-6D) installed in September
2009 (including packer testing and down -hole video logging); and
■ Initiation of quarterly sampling of on -site monitoring and water -supply wells and
selected off -site water -supply wells.
We appreciate your consideration for the extension requested. If you have any questions
or comments, please do not hesitate to contact me at [phone] or at
ireuscher@deltaenv. com.
Sincerely,
DELTA CONSULTANTS
ohn D. Reuscher, P.G., RSM
Project Manager
PC: Randall F. Andrews — Alchem, Inc.; Red Springs, NC
Robert A. Wolcott — Alchem, Inc.; Rockwell, NC

Alchem Well Sampling
Subject: Alchem Well Sampling
From: Peggy Finley <[e-mail]>
Date: Tue, 03 Mar 2009 09:22:09 -0500
To: [e-mail]
John:
We'd like the first round of metals sampling to include the 3030C parameters. We can
modify that for subsequent sampling events, based on the first results. Peggy
Peggy Finley - [e-mail]
North Carolina Dept. of Environment & Natural Resources
Div. of Water Quality - Aquifer Protection Section
Iredell County Government Center
610 E Center St., Suite 301
Mooresville, NC 28115
Ph: [phone] Fax: [phone]
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.
1 of 1 3/3/2009 9:44 AM

C ; ,
V
Finley, Peggy
From: John Reuscher [[e-mail]]
Sent: Tuesday, September 02, 2008 8:41 AM
To: Peggy Finley
Subject: RE: Alchem CSA - Additional Information Request
OK. We are proceeding as quickly as our schedules allow.
-----Original Message -----
From: Peggy Finley [mailto:[e-mail]]
Sent: Friday, August 29, 2008 4:55 PM
To: John Reuscher
Subject: Re: Alchem CSA - Additional Information Request
John:
After reviewing your request, please be advised that we cannot grant
your request for an extension.
Peggy
John Reuscher wrote:
> Peggy:
> We have completed the historical review and site history - the basic
> background info required in the CSA. The earliest the drilling
> company can get on -site is September 18th since we had to postpone
> drilling that was scheduled for tomorrow. The drilling activities
> will take approximately two days. We will be collecting soil samples
> during well installation and groundwater samples the week after to
> allow the wells to equilibrate. Let me know if you will require slug
> testing as that may add to the schedule as well. Ultimately, once we
> review the lab results and can confirm that, for the most part the CSA
> is complete, we can prepare and submit the report. Considering the
> time requirements, that is why I suggested a due date at the end of
> October.
> Please advise and thank you.
> --- yiginal Messaged ----
> From: Peggy Finley [mailto:[e-mail]]
> Sent: 'W�dnesday,- August�27;2008�1:31PM
> To: John Reuscher
> Cc: Andrew Pitner
> Subject: Alchem CSA - Additional Information Request
> John:
> In reviewing your request with Andrew, we noted that the current CSA
> submission deadline of August 31, 2008 was granted in response to your
> May 2 request for an extension. The original deadline for receipt of
> this report, as stated in the February 5 NOV, was May 6. In other
> words, over six months have passed since we made our original request.
1

to
Another extension would push it out to eight months. Please submit a
time line that shows which aspects of the CSA have been accomplished
date.
Peggy
John Reuscher wrote:
Peggy:
As we discussed this morning, Delta Consultants.is requesting an
extension for submittal of the Comprehensive Site Assessment (CSA) at
>> the Alchem, Inc. site in Rockwell, Rowan County. As I mentioned, we
>> have approval from Alchem to implement our proposed activities which
>> includes the installation of five shallow Type II and one deep Type
>> III groundwater monitoring wells at the site. We have to date
» collected information required for the CSA but have been held up with
>> the drilling schedule due to the driller's availability, heath issues
>> with the site manager, and of course the current weather situation.
>> As you are aware, Alchem has made substantial progress in correcting
>> past issues and intends to comply fully with the requirements of the
>> CSA. Please allow an extension for completion and submittal of the
>> CSA activities and final report until October 31, 2008. Once the
>> site
>
>> is allowed to dry sufficiently to access the well locations, the
>> drilling company will be scheduled to begin work. It is our
>> understanding that they will not be able to begin work on the project
>> until mid -September based on their current work load.
>> In addition, please advise me whether the Regional Office will
>> require slug tests to be performed at the site as part of the CSA.
>> Based on the Guidelines, this activity is optional and at the
>> discretion of the
>> Office.
>> Thank for your consideration of this proposed extension. If you have
>> any questions, comments, or concerns, please contact me.
>> Sincerely;
>> John D. Reuscher, P.G.
>> Project Manager
>> DELTA CONSULTANTS
>> 8008 Corporate Center Drive
r

>> Suite 100
>> Charlotte, NC 28226
>> ireuscher(@deltaenv.com <mailto:-jreuscher(@deltaenv.com>
>> Direct: 704.543.3928
» Fax: [phone]
>> Mobile: [phone]
>> www.deltaenv.com <http://www.deltaenv.com/>
>> Member of:
>> Inogen Environmental Alliance
>> www.inogenet.com <http://www.inogenet.com/>
Peggy Finley - Peggy.Finley(@ncmail.net
North Carolina Dept. of Environment & Natural Resources
Div. of Water Quality - Aquifer Protection Section
Iredell County Government Center
610 E Center St., Suite 301
Mooresville, NC 28115
Ph: [phone] Fax: [phone]
y� a
3

Ze: Alchem CSA - Additional Information Request
9
Subject: Re: Alchem CSA - Additional Information Request
From: Peggy Finley <[e-mail]>
Date: Fri, 29 Aug 2008 16:54:58 -0400
To: John Reuscher <[e-mail]>
John:
After reviewing your
an extension.
Peggy
John Reuscher wrote:
Peggy:
request,. please be advised that we cannot grant your request for
We have completed the historical review and site history - the basic
background info required in the CSA. The earliest the drilling company
can get on -site is September 18th since we had to postpone drilling that
was scheduled for tomorrow. The drilling activities will take
approximately two days. We will be collecting soil samples during well
installation and groundwater samples the week after to allow the wells
to equilibrate. Let me know if you will require slug testing as that
may add to the schedule as well. Ultimately, once we review the lab
results and can confirm that, for the most part the CSA is complete, we
can prepare and submit the report. Considering the time requirements,
that is why I suggested a due date at the end of October.
Please advise and thank you.
--Original Message----- 27,
[e-mail]] Sent: Wednesday, August
From: Peggy Finley[mailto:pe
2008 1:31 PM
To: John Reuscher
Cc: Andrew Pitner
Subject: Alchem CSA - Additional Information Request
John:
In reviewing your request with Andrew, we noted that the current CSA submission
deadline of August 31, 2008 was granted in response to your May 2 request for an
extension. The original deadline for receipt of this report, as stated in the
February 5 NOV, was May 6. In other words, over six months have passed since we
made our original request. Another extension would push it out to eight months.
Please submit a time line that shows which aspects of the CSA have been
accomplished to date.
Peggy
John Reuscher wrote:
Peggy*
As we discussed this morning, Delta Consultants is requesting an
extension for submittal of the Comprehensive Site Assessment (CSA) at the
Alchem, Inc. site in Rockwell, Rowan County. As I mentioned, we have approval
from Alchem to implement our proposed activities which includes the
installation of five shallow Type II and one deep Type III groundwater
monitoring wells at the site. We have to date collected information required
for the CSA but have been held up with the drilling schedule due to the
driller's availability, heath issues with the site manager, and of course the
current weather situation.
As you are aware, Alchem has made substantial progress in correcting
past issues and intends to comply fully with the requirements of the CSA.
Please allow an extension for completion and submittal of the CSA activities
and final report until October 31, 2008. Once the site
10/15/2008 9:54 A
1 Af

Re: Alchem CSA - Additional Information Request
is allowed to dry sufficiently to access the well locations, the drilling
company will be scheduled to begin work. It is our understanding that they
will not be able to begin work on the project until mid -September based on
their current work load.
In addition, please advise me whether the Regional Office will require
slug tests to be performed at the site as part of the CSA. Based on the
Guidelines, this activity is optional and at the discretion of the
Office.
Thank for your consideration of this proposed extension. If you have
any questions, comments, or concerns, please contact me.
Sincerely;
John D. Reuscher, P.G.
Project Manager
DELTA CONSULTANTS
8008 Corporate Center
Suite 100
Charlotte, NC 28226
[e-mail]
Direct: 704.543.3928
Fax: [phone]
Mobile: [phone]
www.deltaenv.com <http
Drive
<mailto:[e-mail]>
://www.deltaenv.com/>
Member of:
Inogen Environmental Alliance
www.inogenet.com <http://www.inogenet.com/>
Peggy Finley - [e-mail]
North Carolina Dept. of Environment & Natural Resources
Div. of Water Quality - Aquifer Protection Section
Iredell County Government Center
610 E Center St., Suite 301
Mooresville, NC 28115
Ph: [phone] Fax: [phone]
2 of 2 10/15/2008 9:54 AM

Alchem CSA - Additional Information Request
m
Subject: Alchem CSA - Additional Information Request
From: Peggy Finley <[e-mail]>
Date: Wed, 27 Aug 2008 13:30:44 -0400
To: John Reuscher <[e-mail]>
CC: Andrew Pitner <[e-mail]>
John:
In reviewing your request with Andrew, we noted that the current CSA submission
deadline of August 31, 2008 was granted in response to your May 2 request for an
extension. The original deadline for receipt of this report, as stated in the
February 5 NOV, was May 6. In other words, over six months have passed since we
made our original request. Another extension would push it out to eight months.
Please submit a time line that shows which aspects of the CSA have been accomplished
to date.
Peggy
John Reuscher wrote:
Peggy:
As we discussed this morning, Delta Consultants is requesting an extension for
submittal of the Comprehensive Site Assessment (CSA) at the Alchem, Inc. site in
Rockwell, Rowan County. As I mentioned, we have approval from Alchem to implement
our proposed activities which includes the installation of five shallow Type II
and one deep Type III groundwater monitoring wells at the site. We have to date
collected information required for the CSA but have been held up with the drilling
schedule due to the driller's availability, heath issues with the site manager,
and of course the current weather situation.
As you are aware, Alchem has made substantial progress in correcting past issues
and intends to comply fully with the requirements of the CSA. Please allow an
extension for completion and submittal of the CSA activities and final report
until October 31, 2008. Once the site is allowed to dry sufficiently to access
the well locations, the drilling company will be scheduled to begin work. It is
our understanding that they will not be able to begin work on the project until
mid -September based on their current work load.
In addition, please advise me whether the Regional Office will require slug tests
to be performed at the site as part of the CSA. Based on the Guidelines, this
activity is optional and at the discretion of the Office.
Thank for your consideration of this proposed extension. If you have any
questions, comments, or concerns, please contact me.
Sincerely;
John D. Reuscher, P.G.
Project Manager
DELTA CONSULTANTS
8008 Corporate Center Drive
Suite 100
Charlotte, NC 28226
[e-mail] <mailto:[e-mail]>
Direct: 704.543.3928
Fax: [phone]
Mobile: [phone]
www.deltaenv.com <http://www.deltaenv.com/>
Member of:
Inogen Environmental Alliance
www.inogenet.com <http://www.inogenet.com/>
1 of 2 8/27/2008 1:55 PM

SUSTAINABLE STRATEGIES FOR GLOBAL LEADERS
May 29, 2008
North Carolina Department: of: Environmel
and Natural Resources
Division of Water Quality D
Aquifer Protection Section
610 East Center Avenue, Suite 301
Mooresville, North Carolina 28115
Attn: Peggy Finley
JUN - 2 2008
Subject: Clarification and Request for Data
Alchem, Inc. Facility
Rockwell, Rowan County, North Carolina
D E LTA Delta Project No.: 5070210112
Dear Peggy:
On behalf of Alchem, Inc. (Alchem), Delta Consultants (Delta)
is providing the following clarification to our correspondence to
the. North Carolina Department of Environment and Natural
Resources (NCDENR) :dated May 20, 2008.
Based on further discussions with Mr. Robert Wolcott of
Alchem, subsurface soil excavation was not completed at
potential source areas. Rather, the former acid containment
structure including associated holding tanks were removed
and replaced with new process equipment. In addition, limited
grading was completed at the site for purposes of erosion
control and contouring for placement of the upgraded
containment operation. No subsurface soils were excavated at
potential source areas at the site and disposed off -site. We
apologize for any confusion our previous correspondence may
have caused.
In order to move forward with completion of the initial elements
of the Comprehensive Site Assessment, Delta requests that
we be provided with copies of the laboratory analytical reports,
sample location maps, and property owners information
associated with the water -supply wells sampled by the
NCDENR in the vicinity of the Alchem site. As such, please
contact me regarding the most convenient and expeditious
manner to satisfy this request.
a member of.•
xlnogen®
Environmental Alliance
8008 CORPORATE CENTER DRIVE SUITE 100 CHARLOTTE, NORTH CAROLINA 28226 USA
PHONE [phone] FAx [phone] WWW.DELTAENV.COM

Clarification and Request for Data
Alchem, Inc. Facility
Rockwell, North Carolina
May 29, 2008
Page 2
We appreciate your response. If you have any questions or comments, please do not
hesitate to contact me at [phone] or at ire uscher a�deltaenv.com.
Sincerely,
DELTA CONSULTANTS
C
C)n D. Reuscher, P.G.
Project Manager
PC: Randall F. Andrews — Alchem, Inc.; Red Springs, NC
Robert A. Wolcott — Alchem, Inc.; Rockwell, NC

ivy`
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W ATFR
QG
Alchem, Inc.
8135 Red Road
Rockwell, North Carolina 28138
Attention: Robert Wolcott
Dear Mr. Wolcott:
Michael F. Easley, Governor
[FlyWilliam G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleen H. Sullins, Director
Division of Water Quality
AQUIFER PROTECTION SECTION
May 28, 2008
RE: Receipt of Additional Information
CSA Extension Request
On May 21, 2008, this office received the additional information submitted on your behalf by John
Reuscher, P.G. The work schedule proposed a submission date of October or November for the CSA
report. The report was originally due on May 6, 2008. Based on a review of all the information
associated with this extension request, this office will extend the deadline to no later than Auqust 31,
2008. The CSA report must include the horizontal and vertical extent of soil and groundwater
contamination. Please refer to the enclosed guideline.
The letter makes reference to soil excavation that has recently taken place. The purpose of the CSA is
to identify the source of the problem so that an appropriate corrective action plan (CAP) can be
developed and executed. The Division has not been informed of nor approved the excavation of any soil
in any potential source areas at the site. Within 30 days, please submit a description, map and copies of
disposal manifests for such activities.
In response to other issues raised in the letter, please be aware that sampling by MRO staff identified
two other off -site water supply wells that appear to have been impacted by the activities at Alchem. The
McIntyre well was cited in the February 5, 2008 Notice of Violation because it was the most affected
water supply known at the time. Also, the contaminants of concern do not have to be considered
hazardous by statute to represent a violation of Title 15A NCAC 2L .0202.
Should you have any questions, feel free to contact me by phone at 704/235-2183 or via email at
[e-mail].
Sincerely,
re �L ,
Peg it ey
Environmental Specialist
Enclosure: excerpt from Groundwater Section Guidelines for the Investigation and Remediation of Soil
and Groundwater, July 2000
Cc: Kim Colson, P.E. — APS Land Application Unit
Randall Andrews, 2042 Buie Philadelphus Rd., Red Springs, NC 28377
John Reuscher, P.G., Delta Environmental, 8008 Corporate Center Dr., Suite 100, Charlotte 28226
Maf/alchem ext Itr 5-28-08
Division of Water Quality / Aquifer Protection Section / Mooresville Regional Office Phone: [phone] Fax: [phone] Nor hCarolina
610 East Center Avenue, Suite 301, Mooresville, NC 28115 Customer Service 1-877-623-6748 Internet: www.ncwaterguality.org Xqw, 11b,

SUSTAINABLE STRATEGIES FOR GLOBAL LEADERS
May 20, 2008
North Carolina Department of Environment
and Natural Resources
Division of Water Quality
Aquifer Protection Section
610 East Center Avenue, Suite 301
Mooresville, North Carolina 28115
Attn: Peggy Finley
Subject: Request for Extension
Comprehensive Site Assessment
Alchem, Inc. Facility
Rockwell, Rowan County, North Carolina
D E LTA Delta Project No.: 5E0702101 P
.mabe.,.
Xinogen mental Alliance
Dear Peggy:
On behalf of Alchem, Inc. (Alchem), Delta Consultants (Delta)
is requesting an extension for completion and submittal of the
Comprehensive Site Assessment (CSA) as requested by your
office in the Notice of Violation (NOV-2008-LV-0064) dated
February 5, 2008. The NOV was issued to the referenced
facility as a result of apparent on -site and off -site groundwater
impacted by sulfate concentrations above the established
North Carolina Groundwater Quality Standard (NCGQS) and
pH levels below the established NCGQS range.
Delta requests an extension of 120 days from receipt of this
letter to conduct the necessary initial CSA components and
provide a report summarizing these activities. Delta proposes
to complete the CSA in increments based on the following:
■ Substantial environmental restoration has occurred at
the subject site over the previous four months. The
activities completed at the site to date have included
excavation of subsurface soils at areas thought to
represent potential source areas of the impact
identified.
■ Only one off -site potable water -supply well has been
impacted, the source of which has not been determined.
Alchem has voluntarily connected the well users to the
municipal supply thereby eliminating the potential
exposure pathway.
8008 CORPORATE CENTER DRIVE SUITE 100 CHARLOTTE, NORTH CAROLINA 28226 USA
PHONE [phone] FAx [phone] WWW.DELTAENV.COM

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Request for Extension May 20, 2008
Alchem, Inc. Facility
Rockwell, North Carolina
Page 2
The contaminants of concern at the subject site are not hazardous substances, do
not exhibit the characteristics of a hazardous waste, or are not listed hazardous
wastes as defined in 40 CFR Part 261.
Our proposed schedule for implementation of the CSA-related activities include:
Completion of the site usage history, updated receptor survey, and
assess me nt/ch aracte rizati on of potential source areas— May to July 2008;
Completion of the site hydrogeologic assessment beginning with the installation of a
network of shallow groundwater monitoring wells sufficient to define the horizontal
extent of apparent impact. Vertical assessment of the apparent impact as well as
groundwater modeling will be conducted to the extent required based on the
shallow investigation results — July to October 2008; and
Completion and submittal of a CSA report or interim report detailing the CSA
components addressed during this time frame — October to November 2008.
We appreciate you consideration for the extension requested. If you have any questions
or comments, please do not hesitate to contact me at [phone] or at
0reuscher@deltaenv. com.
Sincerely,
DELTA CONSULTANTS
ohn D. Reuscher, P.G.
Project Manager
PC: Randall F. Andrews — Alchem, Inc.; Red Springs, NC
Robert A. Wolcott — Alchem, Inc.; Rockwell, NC

ALCHEM, INC
8135 RED ROAD
ROCKWELL NC 28138''
704-279-7908 fax [phone] [e-mail]
May 2, 2008
RE: REQUEST FOR EXTENSION ON COMPREHENSIVE SITE ASSESSMENT FOR
ALCHEM, INC
Dear Ms. Peggy Finley,
Alchem has hired John Rouscher, NC Licensed Geologist with Delta Environmental. Mr.
Roucher has informed me that due to the extensiveness of this study and the work entailed in
completing this study, the May 6, 2008 deadline for this to be completed is not feasible. Based
on this, it is at this time that I would like to respectfully request an extension for this study to be
preformed. The delay in hiring Delta Environmental is due to ALL the other compliance issues
that ALCHEM, INC has received from the Mooresville Office over the past 3months.
However it is at this time that I am pleased to inform you that approximately 90% of the first 10
compliance issues are complete. With these issues being almost complete, we are now able to
proceed with the Lagoon Inspections & CSA of the site. During the past month Alchem, Inc has
gone through a monumental undertaking of Environmental & General Clean — Up.
I would ask that you also take financial reasons into consideration for this delay. Over the past
3 '/2 - 4 months, ALCHEM has spent close to $500,000.00 in its effort to rectify compliance
issues and clean up, i.e. payroll + overtime, equipment rentals, fuel, etc. From what Mr. Roucher
has explained to me the CSA that you are requiring be performed can run into the 6 figure range.
Once again let me say that I truly understand the track record Alchem, Inc has had in the past
with NCDENR. I regretfully can not change the past but have asked that NCDENR recognize the
fact that Alchem, Inc is a completely NEW company with new employees, management, image
and that we have worked EXTREMELY hard to get into compliance with all of your requests
over the past 4 months.
In closing I would like to thank you in advance for your understanding and cooperation during the
reconstructuring of ALCHEM.
Thank you,
Robert Wolcott
CHIEF OPERATIONS OFFICER
ALCHEM, INC
8135 RED RD
ROCKWELL, NC 28138

cc: Kim Colson, P.E., Supervisor, APS Land Application Unit
John Roucher, Licensed Geologist, Delta Environmental
8008 Corporate Center Dr, Suite 100
Charlotte, NC 28226
Randall Andrews
H. Addison Winters, Attorney at Law, The Yarborough Law firm
P.O. Drawer 705
Fayetteville, NC
NC STATE SENATOR Andrew Brock, 1119 Legislative Building
Raleigh, NC 27601-2808
Sean Walker, Attorney at Law, Law Firm of Woodson, Sayers, Lawther, Short, Parrot &
Walker, LLP
225 North Main St, Suite 200
P.O. Box 829
Salisbury, NC 28145-0829

micnaei r-. tasiey, governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleen H. Sullins, Director
Division of Water Quality
'IV
LF) 11 AQUIFER PROTECTION SECTION
May 9, 2008
Alchem, Inc.
8135 Red Road
Rockwell, North Carolina 28138
Attention: Robert Wolcott
RE: Acknowledgement of Receipt
Request for Extension
Dear Mr. Wolcott:
Your letter requesting an extension for submission of the comprehensive site assessment (CSA) was
received in this office on March 6, 2008. The request arrived on the day of the deadline as per NOV-
2008-LV-0064. In order to consider your request, additional information is needed. Within 10 days of
receipt of this letter, please submit a proposed work schedule. The schedule should include a timeline
for completion of the activities required by the CSA as well as submission of the report that details the
findings and recommendations.
Should you have any questions, please call me at 704/235-2183.
Sincerely,
Peggy Finley
Environmental Specialist
Cc: Kim Colson, P.E., APS Land Application Unit
Randall Andrews 2042 Buie Philadelphus Rd., Red Springs NC 28377
John Reuscher, L.G. — Delta Environmental, 8008 Corporate Center Dr., Suite 100, Charlotte 28226
maf/achem req for ext 5-8-08
Division of Water Quality / Aquifer Protection Section / Mooresville Regional Office Phone: [phone] Fax: [phone] NorthCarolina
610 East Center Avenue, Suite 301, Mooresville, NC 28115 Customer Service 1-877-623-6748 Internet: w,,vw.nclvaterauality.ora Naturallb,

Michael F. Easley, Governor
O William G. Ross Jr., Secretary
\L�J/ North Carolina Department of Environment and Natural Resources
i Coleen H. Sullins, Director
Division of Water Quality
AQUIFER PROTECTION SECTION
April 25, 2008
Alchem, Inc.
8135 Red Road
Rockwell, North Carolina 28138
Attention: Robert Wolcott
RE: Acknowledgement. of Receipt
Report on Providing Alternate Water to
McIntyre Well Users
Non -discharge Permit No. WQ0002702
Industrial Recycle — Bauxite Process
Alchem Facility, Rockwell, Rowan County
Dear Mr. Wolcott:
This office received the referenced status report on March 12, 2008. The report detailed the
installation of a municipal water line for the residents heretofore served by the water supply well known
as the McIntyre Well, described in the Notice of Violation (NOV-2008-PC-0064) dated February 5, 2008.
We appreciate your efforts to comply in a timely fashion with this requirement of the notice.
Your environmental concerns regarding land use activities on adjacent properties are being
forwarded to the appropriate regulatory agencies, specifically the Rowan County Environmental Health
for the failing septic tank and drainfield issues and the North Carolina Division of Waste Management
and Rowan County Solid Waste for the hazardous and solid waste issues.
As I stated in our telephone conversation earlier this week, Alchem is responsible for submission
of the Comprehensive Site Assessment, which is due in this office on or before May 6, 2008.
Should you have any questions, do not hesitate to contact me at 704/663-1699, ext. 2180.
Sincerely,
a
Andrew H. Pitner, P.G.
Environmental Regional Supervisor
Cc: Kim Colson — APS Land Application Unit
Randall Andrews, Alchem Inc., 2042 Buie Philadelphus Rd., Red Springs, NC 28377
MAF/achem/enforcements ack 4-25-08
Division of Water Quality / Aquifer Protection Section / Mooresville Regional Office Phone: [phone] Fax: [phone] NorthCarolina
610 East Center Avenue, Suite 301, Mooresville, NC 28115 Customer Service 1-877-623-6748 Internet: www.ncwateraualitv.ora Naturally

�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 19, 2008
Rowan County Environmental Health
402 N. Main Street
Salisbury, North Carolina 28147
Attention: Lyn Aldrege, Supervisor
RE: Citizen Complaint Concerning
230 Large Ave., Rockwell
Dear Mr. Aldrege:
Enclosed you will find a copy of a letter that was included in a report that I recently reviewed. The
author, Robert Wolcott, operates the Alchem, Inc. facility that is adjacent to the property at 230 Large
Ave. Since the issue of a failing septic system this is a matter that would be under the jurisdiction of
Rowan County Environmental Health, I have advised Mr. Wolcott that I would be forwarding this
information 'to you for follow-up.
Should you have any questions, please contact me or Andrew Pitner at 704/663-1699.
Sincerely, ,
Peggy Finley
Environmental Specialist
Enclosures
Maf/Alchem-Lyn Aldrege Itr 3-19-08
One
Division of Water Quality / Aquifer Protection Section / Mooresville Regional Office Phone: [phone] Fax: [phone] NthCarolhia
610 East Center Avenue, Suite 301, Mooresville, NC 28115 Customer Service 1-877-623-6748 Internet: vvww.ncwaterguality.org d►utllra��1�

micnaei r. casiey, %zeovernur
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 19, 2008
Rowan County Environmental Services
402 N. Main Street
Salisbury, North Carolina 28147
Attention: Lori Swaim
RE: Citizen Complaint Concerning
230 Large Ave., Rockwell
Dear Ms Swaim:
Enclosed you will find a copy of a letter that was included in a report that I recently reviewed. The
author, Robert Wolcott, operates the Alchem, Inc. facility that is adjacent to the property at 230 Large
Ave. Since some of the issues mentioned are matters that would be under the jurisdiction of Rowan
County Environmental Services, I have advised Mr. Wolcott that I would be forwarding this information to
you for follow-up.
Should you have any questions, please contact me or Andrew Pitner at 704/663-1699.
Sinc
erely,
�r�'ley v
Environmental Specialist
Enclosures
Maf/Alchem-Lori Swaim CO SW Itr 3-19-08
One
Division of Water Quality / Aquifer Protection Section / Mooresville Regional Office Phone: [phone] Fax: [phone] N0 Carolina
610 East Center Avenue, Suite 301, Mooresville, NC 28115 Customer Service 1-877-623-6748 Internet: 1rrww.ncARaterauality.ora d+u�ura��l✓