WQ0000667_Regional Office Historical File Pre 2018

OY
C VED
At MIMAttlitia
State of North Carolina
'L)epartr' aturail Resources and Community Development
Divisiionjof Environmental Management
5I2 Nosh Salisbury Street • Raleigh, North Carolina 27611
Jaynes G. Martin, Governor
S. Thomas Rhodes, Secretary
Mr. D. E. Whitley.
Reichhold Chemicals, Inc.
PO Box 11051
Charlotte, NC 28220
Dear Mr.. Wh is
October 26, 1988
Ci. Permit No, WQ0000667
Reichhold Chemicals, Inc,
Land Application of Sludge
Mecklenburg County
R, Paul Wilms
Director
In accordance with your appl.icatiran received June 14, 1988, we are fo.rwardirs
herewith Permit No. WQ0000667, dated October 26, 1988, to Reichhold Chemicals,.
Inc. for the application of sludge at Reichhold Chemicals' Pineville Land Treatment
Facility.
This permit shall be effective from the date. of issuance until October 31,
1989', and shall be subject to the conditions and limitations as specified therein.
If any parts, r.eguhrents, or limitations contained in this permit are
unacceptable to you, you have the right to request an adjudicatory hearing upon
written. request within 30 days following receipt of this permit. This request must
be in the form of a. written petition, conforming to Chapter 1508 of North Carolina
General Statutes, and filed with the Office of Administrative Hearings, Post Office
Drawer 11666, Raleigh, North Carolina 27604. Unless such demands are made this
permit shall be final and binding.
If you need additional information concerning this matter, please co,
Babette Mckemie, telephone No. 919/733-5083, ext. 546.
cc: Mecklenburg County Health Department
Mooresville Regional Supervisor
Mecklenburg EPA
A. R. Rubin
Bill Reid - Groundwater
Pollution Prevention Pays
P.©, Box 27687, Raleigh, North Carolina 276H-7687 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

NOR'T'U CAROLINA
ENVIRONMENTAL MANAGEMENT COMM.ISSION
DEPA,R"FMENT OF NATURAL RESOURCES AND COMMUNITY DEVELOPMENT
RA LE I. G]I
PERMIT
For the discharge of Sewage-, industrial Wastes, or Other Wastes
Inaccordance
orrth Carolina
land application..
to Reichhoid Chein
2 acres, pt
the project plan,
approved by the
considered. a part
with the p
as amended,
ions of Article 21 of Chapter 143, General Statutes
and other applicable Laws, Rules, and Regulations
PERMISSION 1 ]HEREBY GRANTED TO
Reic'hhold Chemicals, Inc,
Mecklenburg Coun'ty
FOR TIE
sludge from Ri.echhold Chern icals, Inc. s pre-treatment facilities
icals' Pineville Land Treatment Facility consisting of approximately
the application received June 14, 1988, and in c_onformtty with
specifications, and other supporting data subsequently filed and
Department of Natural Resources and. Community Development and,
of this permit.
This permit shall be effective
and shall he subject to the following specified conditions and 'limitations:
1. This permit shall become voidable unless the facilities are constructed in
accordance with the approved plans, specifications and other supporting data.
This permit is effective only with respect to the nature and volume of wastes
described in the application and other supporting data.
The facilities shall be properly maintained and operated at all times,
4. This permit i.s not transferable.
This permit shall be
adequately absorb the
installed, maintained,
water quality standards
the date of issuance untie) October 31, 1989,
ome voidable in the event of failure trf the soil to
wastes and may be rescinded unLe;ss the facilities are
and operated in a manner which rill protect the assigned
of the surface waters and g
6. In the event that the facilities fail to perform satisfactorily,
creation of nuisance conditions, the Permittee shall take str
corrective action as may be required by this Division, including the
of additional or replacement wastewater treatment or disposal facilities.
aclrtditg the
Ir immediate
construction

7. A suitable year round vegetative cover sh
intained.
The Perrlttee, at least six (6) months prior to the expiration of this mit,
shall request its extension, Upon receipt of the, request, the t`ca:amisslan will
review the adequacy of the facilities described therein, and if warranted, w:11
extend the Permit for such period of time and under such conditions arbd
limitations as it: may deem appropriate.
The issuance of this permit shall not relieve the Fermittee of the responsibility
for damages to surface or groundwaters resulting from the operation o:i` this
facility,
10. The facilities shall be effectively maintai.t aed and operated as a non -di
system to prevent the discharge of any wastewater resulting from the opera
this facility.
barge
on of
11. No type of sludge other than that from Reichhold Chemicals, inc. shall be placed
on the land application disposal site.
A 100-foot buffer shall be maintained between the appropriate land owner
property line and any applied sludge.
13. The site shall he adequately limed to a soil. 111 of 6.5 prior to sludge
application,
14. Maximum slope for sludge appl.°}c
for subsurface applications.
be 10% for surface application and 18%
A 50-foot buffer shall be maintained between drainageways, a 100-foot buffer
shall be maintained between each landowner's property lines, and a 400-foot
buffer shall be maintained between any residence and any applied sludge.
16. A recorded log shall be maintained by the Fermittee including, but not limited. to
the followg:.
a) amounts applied, dates, method of app
c
ion
b) a semi-annual sludge analysis for nutrients and heavy metals
) an annual sot boring analysis for the following constituents: CEC, Flit, P,
Cd, Cu, Zn, Mg, Fe, Pb, and }lg
d) total cum lat`.i.ve heavy metal loadings ftr the site
semi-annual basis.
This log shall be
basis.
villa Fle a. nal Office on
d. on
Mudge shall he applied evenly over the entire application. area at
application.

18. A suitable cover crop shall be established and a crop management plan, detailing
cover crop maintenance and including application of fertilizer, shall be
submitted to the Mooresville, Regional Office within sixty (60) days of permit
issuence,
19. Cumulative heavy metal loadings shall not exceed the following:
Metal lb/ac
Ph 500
Zn 250
Cu 125
Ni 50
Cd 5
20. Annual Cd application shall not. exceed .45 lh/ac
21. The application rates shall not exceed 71,5 dry tons/acre/year.
22. The "abandoned" two (2)-inch drilled well located near monitoring well number
shall be abandoned in, accordance with 15 NCAC 2C .0113.
23, The three (3) existing monitor wells shall 'be sampled every March, July and
November for the following parameters:
NO
5 F0C
TD
Chloride
PI' SO
Cadmium 4
Phenol
TOX (in Nov. only) Water Level
Ba. Zn
Pb Cu
Ni
The measurement of water level must be made prior to sampling for the remaining
parameters.
The analytical methods used for TOX must be capable of detecting the total of all
halogenated organic compounds present at a concentration of 5.0 parts per billion
(ppb) or greater. In the event that a TOX concentration of 5.0 ppb or greater is
detected, any individual halogenated organic compound(s) present at a
concentration at or above the method detection. limit (MOL) must be identified and
quantified. utilizing EPA methods 601, 602, 604 and 611.
The results of the sampling and analysis shall be sent to. the N.C. Division of
Environmental Management on Form GW-59 (Compliance Monitoring Report Form) every
April, August and December.
24, Any additional groundwater quality monitoring, as deemed necessary by the
Department, shall be provided.
25. Sludge shall not he applied in. inclement weather or until 24 hours following a
rainfall event of I/2-inch or greater in 24 hours. Emergency sludge disposal
measures shall be approved by the Division of Environmental Management

the 26th day o Oct he 1988.
NORTH (1AROLI N IRI) P EaNrrAL LANAGh �`I CN I ,ON
a `.t' ul i 1n J)It� tar`
Div is L v nt
y i t <, l.ts of the fi v^ c anagernent Commis s lot
No. Q0000667

you as
A renewal
rn u,r s t be
0 05(c)
perm:i.trt:ecl
facilities,
Etrvir.otrnrer t<a
payment of an annuta1
1J1] Led separately for
Sludge
Dept,
State of `forth. Carolina
er t o Natural Resources and CornmuniDevelopment
Division of Environmental Management
19 C re rth Salisbury Street • Raleigh, North Carolina
ir_r, (itwernc�r
;y, Ir., Secretary
WHITLEY
OLD C1l1 MICALoS-PINEVLLE
P. O. BOX 110 1.
C£irllil,C)TTE , NC; 28220
Our files i.radi c rt::r tha. tw tit e
9.
exp:l:ration
date.
June 22,
R. Paul °kr'ilrrts
Director
1� Ji�1.lT NO. WO0000667
RE., TC,11llOI,1} CHEMICALS P I NEV
MECKI,FNBURG COUNTY
issued en ]()O a P,r" ,as
a requ es t. f'e r r e.rtewa i mus t be
not rece v'etl a rrgnest: for reuuewe1
request slralI cons wi.st of e letter regue.sti.nf renew+1,
ed. with. the r.egraest. l'l. tsrr find attached a copy
t .ous. The 1 rroeess inn, fee for your facility
rver i_s appropr:iat: , listed. in the
renewals are based case total acres of land
trg rrr€ ert. Commis lean. adopt ro l es on August 1,
fee for: most
that: fee (4 f
This. matter slaon.ld be gi_veur
Lb e permit 9 s r xla irr l i.can without.
rie.Swa1. , cons tit:ir.Les
€?. regun.s t. fo r enewFa.''...
C C .
For
Cent:.ra1 E`i.1es
after yoi
permitted. facilities (Sen Attach
ab 1
prompt WA
the f.i.4i.ng
a perm_i L
abm, t.t.ed to
Eng
North 4Earo 1 1.3
1s
that eontin
complete ar:rc.
a viol 7t 4on C)f ES
r equu
You
o r o V 0,(1
919/7'373-5081'3
Pollution !Woo tc�arz Tray,
P.O. Box 27687, Raleigh„ North Carolina 27Oi-7687 Telephone 99V9-7337015
An Equal OpportunityAffira vativc Action Employer

mical:F, Inc.
s []vision
th CBotevard
JAN
8
har otte, North Carona 28220
January 5, 1989
Mr. Arthur Mouberry
State of North Carolina
Department of Human Resources and
Community Development
Division of Environmental Management
P. O. Box 27687
Raleigh, N. C. 27611-7687
SUBJECT: Permit No. WQ0000667
Reichhold Chemicals, Inc.
Land Application of Sludge''
Mecklenburg County
Dear Mr.. Mouberry:
REICHHOLD
During our telephone conversation on December 21, 1988 you requested I write
you concerning our proposed action to be taken at subject, Our proposal is as
follows:
. Purchase and install a dewatering system at our 5000 South Boulevard facility
by March 31, 1989. Test equipment has already been piloted and we feel
the sludge at the approximate 40% solids would be suitable for the County
Landfill.
. File DHS Form 3151 with the Waste Determination Section Division of Health
Services, Raleigh, N. C.
. File Browning -Ferris Industries (BFI) Waste Characterization Data Form
with BFI. We would propose to use BFI as a transporter.
. Keep Mecklenburg County Environmental Protection informed of our progress.
We would retain title to our Land Application Area and would monitor the
three wells as outlined in the permit. The "abandoned" two (2) inch drilled
well located near monitoring well number 1 has been abandoned in accordance
with 15NCAC2C .0113 as requested.
The records will show we have operated the land application area for approximately
15 years. During this period we have always operated within the confines of
the law which can be documented by Mecklenburg County Environmental Protection
and North Carolina Department of Natural Resources and Community Development.
Implementing the conditions outlined in the permit would have a detrimental financial
impact on our facility i.e. equipment would have to be purchased or leased to
evenly apply the sludge over the entire application area at each application
and storage would have to be constructed and approved by the Division of Environmental
Management for us to comply with the inclement weather section of the permit,
etc.
(J04)52 ;t2't
1;8OO" '138-1017

ua ry
1989
If you find the above acceptable we would withdraw our request for a adjudicatory
hearing.
Thank you for your con
additional information
Sincerely,
D. E. Whitley
Plant Manager
deration in this ratter and call meat 704-525-6420 i
s desired.
©EW:bs
cc: R. G. Arnott-Dover/Silver Lake
89:5
D I SSDOC7

Mr, D. E. Whitley
Riechhold Chemical, Inc.
P.O. Box 110561
Charlotte, NC 28220
State of North Carolina
Department of Natural Resources and Community Development
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina '27o11
. Martin Governor Flay 19,989
W Cobcy, jr., Secretary R. Paul mai ms
Director
SUBJECT: WQ0000667
Reichhold Chemical, Inc.
Land Application of Sludge
Mecklenburg County
ey:
a-rt r `terence to your requests for permit amendment dat .d November 28,
ua.ry 5, 1989,
The requieremer t that the sludge be applied evenly over the nppl i.cation
area et: each nppl cation (Condition. No. 17) is in keeping wth the Departments
policies and regulatl_cazt. pertaining to the land application of sludge. Due to the.
industrial nature of the. sludge and the potential for environmental impact it is not
a'rppropriate to make an exception to this requirement and any additional sludge
transported, to this site must be applied in accordance with the conditions of the
current permit.
The groundwater monitoring data submitted to date .indicates that C:N,ass "IGA"
groundwater quality standards have been exceeded at the land application site. For
this reason, groundwater monitoring activities must continue as required by Conditions
No. 23 and. 24 of the subject permit for the foreseeable future. if exceedances of
groundwater quality standards are confirmed, modifications /additions to the
groundwater monitoring program may be requi.red
If nny parts, req
unacceptable to you, you have the rig
written request within 30 days following r
contained in the permit are
an adjudicatory hearing up
of this permit. This request must be
General Statutes and filed we Office., of Administrative ve lca aNa #1 f aror Ina
the form of a written petition, conforming to Chapter
' with thr;r ng� � "&'cry t� flice
Drawer 11666, Rale gh, North Carolina. 27604. Unless such dem it s are=made permit.
shall be final and binding.,il„ pe
i 1tutrPrc7.'enla`r"r
n.
PO Box 27687, Raleigh North Carol' taa 2C76H-7 v&7. Telephone 9t 7

McKemie, ni f Your telephone number 9.19/733-5083.
have rrny questions concerning this permit:, please.ontnct Mrs.
CC:
Reid -OW
sville Reg,i.orr,1 Office.
Copy

State of North Carolina
Department of Natural Resources and C mmunity f evelopnent
Mooresville Reg i:a al Office
G. "iartin, Governor
iarn W Cobey, Jr., Secretary
CERTIFIED MAIL
RETURN RECEIPT REQUEST
Mr. D. E. Whitley
Reichold Chemicals, Inc.
5000 South. Boulevard
P. Q. Box 11051
Charlotte, N. C. 28220
Dear Mr. Whitle
Albert F. Hilton, Regional i'` aI a
DIVISION OF ENVIRONMENTAL MANAGEMENT
April 11, 1989
RE: Notice of Violation
15 NCAC 2L Classifications and
Water Quality Standards Applicable
to the Groundwaters
Reichold. Chemicals, Inc.
Permit No: WQ0000667
Mecklenburg County, N. C.
Chapter 143, North Carolina General Statutes, authorizes and directs the
Environmental. Management Commission of the Department of Natural Resources and
Community Development to protect and preserve the water and air resources of
the State. The Division of Environmental Management has the delegated authori
to enforce adopted pollution control rules.
Based upon a review of your groundwater compliance monitoring data
submitted on March 23, 1989 as a requirement of Permit No. WQ0000667, the
Division has reason to believe that the permitted activities have resulted in
noncompliance with 15 NCAC 2L Classifications and. Water Quality Standards
Applicable to the Groundwater. Condition No. 9 of your permit states:
"The issuance of this permit shall not relieve the Permittee of the
responsibility for damages to surface or groundwaters resulting from the
operation of this facility."
9I9 North Malin Street„ PO. [lox 950, Moor Mlle, N.C. 28115-0950 • `rekkphone 704-663•3699
An Equal Opportunity Affirmative Action Enip9oycr

Mr. D. E. Whitley
April 11, 1989
Page Two
Specific violations of 15 NCAC 2L were as follows:
1.
Monitoring Well No.
Barium - 4.6 mg/1
Lead - 0.137 mg/1
Sulfate - <1250 mg/1
Phenol - 0.2 mg/1
2. Monitoring Well No. 2
Barium - 1.8 mg/1
Lead - 0.125 mg 1
Sulfate - <1250 mg/1
Phenol - 0.1 mg/1
3. Monitoring Well No. 3
Barium - 4.1 mg/1
Lead - 0.101 mg/1
Sulfate - <1000 mg/1
Phenol - 0.2 mg/1
2L Standard
Barium - 1.0 mg/1
Lead - 0.05 mg/1
Sulfate - Background
Phenol - .001 mg/1
It is requested a written response be submitted to this Office by no later
than fifteen (15) days after receipt of this Notice explaining reasons for the
noncompliance.
In the interim, Reinhold Chemicals, Inc. must perform the following:
1. Resample the three monitoring wells for the parameters noted in
noncompliance.
This information must be submitted within thirty (30) days after receipt
of this letter.
If continued groundwater quality standard violations are verified then
Reinhold Chemicals, Inc- must undertake to define the horizontal and vertical
extent of the contaminationand propose corrective action.
Failure to respond. within the time specified and tovoluntarily achieve
compliance may result in the recommendation of enforcement action, including
the issuance of a special. order against you under the authority of General
Statute 143-215.2; and/or revocation of your permit.

Mr. D. E. Whitley
April 11, 1989
Page Three
Your response and/or questions should be first directed to Jesse W. Wells,
Hydrogeological Technician, if unavailable then t© Eric J. Klingel, Regional
Hydrogeological Supervisor of the Mooresville Regional Office at (704)
663-1699.
Sincerely,
Brenda J. Smith, P.G.
Regional Supervisor
cc: Office of Legal Affairs
Bob Cheek
.:� `�son

Reichhold Chemicals, inc.
Emulsion Polymers D'ivision
>00.0 South firmlevaal
IV !lx 11051
Cl Arlot Ito, North Carolina 28220
November 29, 1988
North Carolina General Statutes
Office of Administrative Hearings
P. O. Drawer 11666
Raleigh, North Carolina 27604
NOV
N, 1,111NT, N
17,AA01',J:A;
SUBJECT: Permit No, W00000667
Reichhold Chemicals, Inc.
Land Application of Sludge
Mecklenburg County
Dear Sirs:
NOV
wiNAG[tENT
Rile4,,f1, NC
REICHUO
This letter is being sent to provide a written request for an adjudicatory hearing
regarding our land application of sludge Permit No. WQ0000667.
Since the date of our application Reichhold Chemicals has been, exploring alternative
technologies and as recent as last week completed an extended trial ofnew equipment /2
that looks favorable for making our sludge suitable for:Municipal landfill; Final
negotiations and funding are not expected to be complete unTrarounmniiary 15,
1989. Final preparation and startup should be completed within thirty days following
approval.
However, in the event that we find it necessary to continue usage of our Pineville
land application site there are certain provisions in the permit that we would
like the opportunity to discuss further. Some of these conditions we believe will
cause an undue hardship for the economics of our plant site.
.As indicated previously, we do not expect funding approval prior to January 15,
1989. We would, therefore, like to propose to you at this time a hearing on this
matter on or after that date and to request permission for continued operation
under interim status until a final decision is reached.
Please advise us at your earliest convenience whether or not the above proposal
is satisfactory and of the exact date, time, and place of the hearing.
Sincerely,
David E. Whitley
Plant Manager
DEW:bs
cc: 14r. J. Paul Wilms
State of North Carolina
NOV „Idd
Department of Natural Resources and Community Development
Department of Environmental Management
512 North Salisbury Street
Raleigh, N. C. 27611
]el [phone]
tRi1111.11P1C117 n

fiEC
*64* ow
VE0
TAt MA&%UMW
re,
OR 23 ;90
STATE OF NORTH CAROLINA
O1PICE OFIADMINISTRATIVE HEARINGS
December 12, 1988
David E. Whitley, Plant Manager
R6ithhold.:: CheMica1,6,Inc
5000 South Boulevard
P.O. Box 11051
Charlotte, NC 28220
Dear Mr. Whitley:
WQoopo
Your letter requesting a hearing was received on
November 29, 1988. In accordance with G.S.1508-23(a), this
letter does not constitute a petition, therefore we cannot
open a contested case file in this matter.
I am enclosing a Petition form and. a Certificate of
Service. When filled out and, returned to our office it will
be filed. and processed.
If we can be of any further assistance, pleaselet us
know.
Sincerely,
Dean C. Farrar
Chief Hearings ierk
DCF/kga
Enclosures
cc: NC Department of Natural Resources
and Community Development
POST OFFICE DRAWER 11666 / RALEIGH, NORTH CAROLINA 27604
RULES: 919/733-2678 ADMINISTRATION: 919/733-2691 HEARINGS: 919/733-2698

Date: October 12, 1988
STAFF REPORT AND RECOMMENDATIONS
County: Mecklenburg
APN No. 011737
PART I - GENERAL INFORMATION
Facility and Address:
2. Date o Investigation:
Report Prepared By: Mi
Engineer I
Reichhold Chemicals, Inc.
Sludge Land Application Site
Post Office Box 11051
Charlotte, North Carolina 28220
August 10, 1988
hael L. Parker, Environmenta
4. Person Contacted: Mr. D. E. Whitley, Plant Manager;
telephone number [phone]
5. Directions to Site: From the junction of Highway 521 and
S. R. 3637 (Dorman Road) travel 0.7 mile southwest on S. R.
3637 and turn left onto a dirt access road (note yellow
gate). The existing land application site is at the end of
this road.
6. Discharge Point: N/A
Attach a USGS Map Extract and indicate treatment plant site
and discharge point on map.
USGS Quad No.: G 15 SW
7. Size (land available for expansion and upgrading):
Approximately two (2) acres are available for sludge
disposal.
8. Topography (relationship to flood plain included): Gently
sloping in area of disposal (1-3%). Site is not located in
a flood plain.
9. Location of Nearest Dwelling: No dwellings exist within
500 feet of the application site.
10. Receiving Stream or Affected Surface Waters: N/A
PART II - DESCRIPTION OF SLUDGE
1. Type of Sludge: 100% Industrial
a. Volume of sludge: 5500 lbs. per day

Page Two
b. Types of industrial sludge: Waste sludge is generated
from the wastewater pretreatment facilities located at
Reichhold Chemicals. The primary raw materials are:
vinyl acetate, methyl methacrylate and butyl acrylate.
c Prevalent toxic constituents in sludge: All analysis
and test performed (including EP Toxicity) have shown
the sludge to be non -hazardous.
d. Pretreatment Program (POTWs only): N/A
2. Production Rates (industrial discharges only in Pounds:
N/A
Description of Industrial Process (for industries only) and
Applicable CFR Part and Subpart: N/A
4. Type of Treatment (specify whether proposed or existing):
N/A
5. Sludge Handling and Disposal Scheme: Sludge is loaded from
pretreatment facilities onto a dump truck and transported
to the disposal site where it is deposited and later spread
out using a bulldozer.
6. Treatment Plant Classification: N/A
PART III - OTHER PERTINENT INFORMATION
1. Is this facility being constructed with Construction Grants
Funds (municipals only)? No
2. Special monitoring requests: N/A
3. Additional effluent limits requests: N/A
4. Other: N/A
PART IV - EVALUATION AND RECOMMENDATIONS
Reichhold Chemicals manufactures emulsion polymers for the
adhesive, paper and latex paint industries and subsequently
generates approximately 15,000 gpd of wastewater which is
pretreated by on -site facilities using chemical coagulation and
filtration. Chemicals utilized for pretreatment include Ferric
Chloride, Sodium hydroxide and Anionic and Cationic Polymers.
Sludge, containing approximately 204 solids, is generated from
the pretreatment facilities and is presently being disposed of
on an existing unpermitted site.
The existing site does not appear to have any topographic
limiting constraints which would preclude, its use. Although
McAlpine Creek borders the southeastern edge of the site,
adequate buffering exists to prohibit surface movement of waste
constituents into the creek. No other surface drainage channels

Page Three
exist on the site and the gradual slope should allowor gradual
movement of the waste constituents into the soil.
Soils found on the site are primarily Cecil and Pacolet
(as noted in a report filed by A. R. Rubin). These soils are
generally considered as good receivers for sludge application.
Soil borings from the site have shown that selected constituents
(primarily heavy metals) have not been applied which would
exceed acceptable levels. The results of these borings has
indicated that movement of waste constituents into the soil
profile has been minimal.
Vegetation at the site has also been sampled to determine
if constituents were present in unusually high levels and for
determining the effect of the present land disposal program on
the existing cover crop. As a result, no abnormal levels of
constituents were found and actually many were deficient as
compared to normal values. It does not appear that the sludge
has had an adverse effect on existing site vegetation.
Three (3) groundwater monitoring wells exist at the site
plus one (1) former residential well. All of the three
groundwater wells have been sampled for various analysis (as
prescribed by the Mooresville Regional Office Groundwater
Section) and all results were below applicable groundwater
standards. It does not appear that any form of groundwater
contamination presently exists at this site. The Mooresville
Regional Office Groundwater Section has recommended, pending
permit issuance, a list for groundwater monitoring to be
performed.
One facet of this operation which should be examined prior
to permit issuance (or could be a condition of the permit) is
that when the sludge is deposited on -site, it is not being
spread evenly across the site, but rather allowed to accumulate
in depths ranging from 1-3 feet. Because of this, very little
of the actual site is being utilized and may eventually
concentrate constituents in such a manner as to eventually
contravene groundwater standards in certain area. The applicant
should submit a proposal on more effective site management which
includes:
1. An improved method of sludge application which will
better utilize the entire disposal site and allow for
improved management.
2. A specific application rate proposal detailing
disposal rates (daily, weekly or monthly basis) based
on present sludge analysis and an estimate of site
life (determined by limiting constituents).

Page Four
3. An agronomist report or crop management plan detailing
cover crop maintenance including application of
fertilizer (as requested by Dr. Rubin to improve the
availability of macro and micro nutrients) and lime to
raise soil pH.
Also, records of all sludge disposal should be maintained
by the Company and submitted for review to the Mooresville
Regional Office on a semi-annual basis. This submittal should
also contain the results of a yearly soil boring done at or
about the center of the disposal area in which analysis of the
following constituents must be included: CEC, pH, acidity, P,
K, Cd, Cu, Zn, Mg, Fe, Pb and Hg.
Additional groundwater monitoring has been recommended by
the Mooresville Regional Office Groundwater staff.
Pending receipt and approval by the ERG and Mooresville
Regional Office of the above requested data it is recommended
that a non -discharge permit be issued containing all standard
sludge disposal conditions.
Si fursReport P eparer
/
Water Quality R ional Supervisor

3S In bS
(N©1ONICO

application and supporting materials
has been assigned the number shown above.
inquiries on this project.
Your project has been
detailed engineeringreview.
this acknowledgement is not
engineer listed above.
Be aware that the Division ° s
recommendations from the Regional Supery
project., prior to final action by the Division.
Date:
Dear
The Division's Permit and Engineering Unit acknowledges receipt of your persist
, 19 y,.:. his application
to this number when making
Please
acknowledgettent
thin thirty (30)
for a
If
ays, please contact the
be foa thcamin
1 office, copied below, must provide.
a Procedure Four Evaluation for this.
If you have any questions, please call the review engineer listed above at
[phone].
Arthur Mouberry, P.E.
Supervisor, Permits and Engineering
cc: Regional Supervisor

Fine n ttt of iettr al
Environmental Mien
EON -DISCHARGE P
elteral Statutes Chalet
fpriri;trct (n'l.o) eitY� 61f(9er tawrrtw sitlry
FOR::
Ttet t
A
crge Treat
t Facilities
iott System
Sd Sewer Systems
NATURE OF WASTEWATER
Sludte'Ittdteserial Wa
s Caputo
B O. D. (5-day
pended 5
TOTAL
t oliform Ba
Applicant assures that ,proposed works
specitcatiorts or approved cliarages thereto
blic)
p
INSTRUCTIONS:
1. FiII- n ALL s
2. Securr.eppropr
Of legally con': u
design engineer or of
3. Submit to MCC, 0ep;artr
original and first copy of appl
NOTE, Application rev
for other projects
d ot.
For Assistance, call t
*Asheville [phone]
159 Woodfin Street
Asheville, NC 28801
"Fayetteville [phone]
Suite 714 Wochovia Building
Foyerreville, NC 28301
lslela(ttrrth N
Es► meta►d Cos
Pumping
Seat en
Treatment
Plant
Ot
Compl
ordan a with approv
ry distrtat boar
uthottzataan
a; p p1 it
I Rcsasu
f finatilt+td p(
riot of COMPLET
ource and
t Commission
T APPLICATION*
4 Artie 21
A.
ity Development
App)ie tissmt
Brief. ProjectDescription.
treatment nudge.
linzation of No
A
TOTAL T
MATE
d, supervised, operates and
din.
Telspe NO 1fl
io pality, c i+
*posed warf4
Community Dove
peciflcatlons and other sup
t, Gonorally, 30
e Central Office 919/733-5083
04l n3-1699 Washington (919
1502 North Marko
t 2f1115 Washington,NC 27
4
Zips
per off
27687, Raleigh, N.0
sWinst©n-5a
8003 Silas
Winston -Sale
761 2351
y Extension
'Wilmingteroi° 171 2.56.4181
7225 Wrightsville Avenue
Wilmington, NC 2840.3

Reichhald Chemicals, inc.
Emulsion Poiyrners Division
5000 South Boulevard
P.0 . Box 11051
C'�1 rlctte, North Carol�rrd .0
6
May 31, 1988
8
Mr. Arthur Mouberry
State of North Carolina
Department of Natural Resources
and Community Development
Division of Environmental Management
P. O. Box 27687
Raleigh, N. C. 27611-7687
SUBJECT: Project Return APN 007523
Reichhold Chemicals, Inc.
Land Application of Sludge
Mecklenburg County
Dear Mr. Mouberry:
R CHHOLD
In response to your letter dated June 26, 1987, I advised your Mr.
Michael L. Parker in Mooresville, N. C. by letter on July 6, 1987
that we had contracted with North Carolina Extension Service to do
a study of our land application area. Dr. A. R. Rubin, Department
of Biological and Agricultural Engineering, N. C. State University
was assigned as consultant for this study.
This study has been completed and a copy is enclosed. Also enclosed.
is a new Non -Discharge Application and other pertinent data relating
to our Pineville Land Treatment Facility.
If you have any further questions regarding this matter, please call
me at 704-525-6420.
Very truly yours,
D. E. Whitley
Plant Manager
DEW:bs
Enclosures
cc: Mr. Michael L. Parker w/enclosures
State of North Carolina
Department of Natural Resources and Community Development
919 North Main Street
Mooresville, N. C. 28115
Mr. R. G. Arnott, Reichhold Chemicals, Inc. w/enclosures
P.Q. Drawer K
Dover, Delaware 19936
)17
88:139

REICHHOLD CHEMICALS, INC.
CHARLOTTE, N.C.
PINEVILLE, N.C. LAND TREATMENT FACILITY INFORMATION
Land application si
in Mecklenburg Coun
e is located off Dorman Road, Pineville, N. C.
2. a) Map Delineating Property Boundaries (attached)
b) Residences Located Within 500 Feet of Application Field - none
c) Wells Within 100 Feet of Application_ Field
- three (3) Monitoring Wells
- one (1) on property which belongs to Reichhold and is no
longer used.
d) Size of Application Field - 2 acres - (attached)
Narrative of Overall Land Application Procedure
Sludge is transported from Reichhold plant site at 5000 South
Boulevard, Charlotte, N. C., transported via Reichhold dump truck
to land application site, dumped on the ground and approximately
5 times per year a dozer is rented to spread out the dried sludge.
4. Sludge Characteristics - test performed by Dr. A. R. Rubin, N. C.
State University - (attached). Test performed by Dr. Rubin gives
total metals. EP Toxicity performed by EMS gives extractable
metals (attached) .
Description of Pretreatment Facility - (attached)
6. Site Investigation Report From Dr. A. R. Rubin, N. C. State
University -(attached)

D E
E ONLY
North Carolina Department of Natural Resources and Community Development
Environmental Management Commission
NON -DISCHARGE PERMIT APPLICATION*
* in accordance with N.C. General Statutes Chapter 143, Article 21
Applicant (name of board, individual, or others):
Reichhold Chemicals,Inc.
PrOect name of city, village, town„ sanitary district, estahtishment):
Pineville Land Treatment Facili
y
Permit Nu :
lCounty:
MecXlen
Applicat(on Date;
May 27, 1988
FOR
(33 Non -Discharge Treatment/Disposal Facilities
0 Pretreatment Facilities
Sewer Collection System (private)
0 Extend Sewer and Sewer Systems (public)
NATURE OF WASTEWATER:
Sewage
Sludge/Industrial Waste
Other Waste
Brief Project Description:
Land application of Non -Hazardous Waste
Water pre-treatment Sludge.
From (s•wers, pretreatment foci ities, treatrnen
Pre-treatment Facility
name of treatment plant
N/A
At (location of treatment plant)
N/A
tants
*king (city, institution, 65Y South l3oulevar
IReichhold Chemicals,Inc.Charlotte,N
Tributary To (name of water course):
1N/A
Name on p ate Address of Engineering Fni Zp Codo. Tel phooe No
Dr. A.R. Rubin, NC State University, Box 7625,Raleigh, NC 27695-7625 919-737-2675
Treatment Works Capacity to Serve (name of prokct):
Reichhold Chemicals Inc.
Far (no, yrs, Aver*. oil Gallons Sewage or Waste Flow:
Indef1rLite
Affect Overall R.thctiGrl in Pal ution
B O. D. (5-day 211
Suspended Solids
TOTAL SOLIDS
Coliform Bacteria
plicable fr sewer projects
s ireated
NIA
Toxic Materials (sPeci fy ench, add pages if no•clic)
None
N A %
Sewers
Pumping
% Station
N/A
TOTAL TOXIC MATERIALS
Treatment
% Plant 1
Other (s
Estimated Completion Date:
Applicant assures that proposed works wifl be constructed, supervised, operated and main)ained in acordance with appro'ed plans and
specifications or approved changes thereto,
Print Name;
D. E. Whitley
Signature,:
Title:.
Plant Manager
Mailing Address: Zip Code
P.O.Box 11051, Charlotte, NV 28220
Telephone
No 7041-525 6420
INSTRUCTIONS:
1. Fill-in ALL spaces.. If not applicable, enter N/A.
2. Secure appropriate signature (rnayar/city manager far mun)cipality; chairman for sanitary district board; owner/proper official of corporation;
or legally constituted board or commission in charge of proposed works), A letter of authorization is required from proper official if
design engineer or other agent signs application.
3. Submit to N„C„ Department of Natural Resources and Community Development, Environmental Management, Raleigh, NC, the
original and fast copy of application, 2 sets of finalized plans, specifications and other supporting, data as. required by Corarnisslon Rules,
NOTE. Application reviews are scheduled on receipt of COMPLETE information. Generally, 30 days are required for pollution abatement prolects; 90 days
for other praiscts
For Assistance, call the State Central Office 919/733-5083, P.O. Box 27687, Raleigh, N.C. or:
"Ashevii.e. [phone] 'Mooresollle [phone] •Washogton [phone] *Winston -Solon, [phone]
159 Woodiin Street. 919 North Main Street 1 502 North Market Street 8003 Silos Creek Parkway Estension
Asheville, NC 28801 Maoresville„ NC 28115 Washington, NC 27889 Winston-Salem, NC 27106
'Fayetteville [phone]
Suite 714 Wochavio Building
Fayetteville, NC 28301
'Raleigh (9191 733-2314
Box 27687
Role;pgh, NC 27611
•Wilmington (919) 2.56-4161
7225 Wrightsvi1le Avenue
Wilmington,. NC 28403

REICHHOLD
Pinevilie,NC
Land
Application
Site

,,. r.��

89.5 11."
SLUDGE"C CTERISTICS
TEST P 0 DY DR. RUBIN
NO3N
38.E 400
2210 1,083 11 9 1 4 6
TOC
12350
8.5

IS Laboratories, Inc,
2 POMPANO DRIVE
ARLOTTE, NORTH CAROLINA 28216
1) 392-6276
rIPLE SOURCES
PVA Sludge
L TO:
Reichhold Chemicals
500 S. Blvd.
Charlotte, N.C. 28220
Att:. Mr. David itley
PARAMETER
Lindane, EP' Tox Extract
% Spike recovery
Endrin, EP Tox Extract.
% Spike recovery
Toxaphene, EPTox Extract
% Spike recovery
2,4-D, EPTox Extract
% Spike recovery
Silvex, EP Tox Extract
7. Spike recovery
REPORT DATE 2/10/86 DATE RECEIVED 12/17/86
EMS SAMPLE #
P.O. M SAMPLE TYPE X GRAB _ COMPOSITE
504
WASTEWATER
SLUDGE
OIL
LEACHATE
OTHER
RESULTS Fie t . Li t DATE ANALYZED
ND 0.004 1/9/86
80
ND
119
ND
113
ND
87
ND
67
0.002
0.005
0.01
0.001
Herbicide Derrivatization Complete NA
Pesticide Extraction, Water Complete NA
1/9/86
1/9/86
1/20/86
1/20/86
1/20/86
1/6/86
ND - analyte not detected at detection limit indicated
NA Not applicable
All results in mg/L
DATE SAMPLED
COLLECTED BY
REMARKS PVA
11/18/85
dge Leachate
EP Toxicity Extraction
REPORT'
NUMBER
No.0©549
Do not pay from
this copy
ANALYST
DJO
DJO
DJO
ACB
ACB
ACB
DJO
METHOD OF ANALYSIS
SW846 8080
SW846 8080
SW846 8080
SW846 8080
SW846 8080
SW8468080
SW846 8080
SW846 8080
SW846 8080
SW846 8080
NA
NA
Total
CHARGE
$300.00
TA REVIEWED BY;
RFPC1RT rr1AV

51-5—UTborai©rleS, Inc.
32 POMPANO DRIVE
IARLOTTE, NORTH CAROLINA 28216
14) 392-6276
MPLE SOURCES
,eichold Chemical, Inc.
.L TO:
eichold Chemical, Inc.
000 South Blvd. - P.O. Box 11051
harlotte, NC. 28220
REPORT DATE
/27/85
DATE RECEIVED 11/21/85
EMS SAMPLE 0 405
P.O. 0 19976 - SAMPLE TYPE ? GRAB COMP
WASTEWATER DATE SAMPLED
SLUDGE COLLECTED BY
OIL REMARKS PVA Slud
LEACHATE E P Toxicity Extrac
OTHER
PARAMETER
,rsenic, As
arium, Ba
;admium, Cd
hromium, Cr
,ead, Pb
ercury, Ng
eienium, Se
Mier, Ag
Note:
lTA REVS WFD LOY.
SPIKE
RESULTS RECOVERY
<0.01 90%
1.5 95%
<0.01 95%
<0.05 98%
<0.05 937.
<0.001 100%
<0.005 90%
<0.01 100%
Metal Analysis perfo
DATE ANALYZED
11/27/85
11/22/85
11/25/85
11/25/85
11/25/85
11/26/85
11/27/85
11/25/85
ANALYST
DF
DF
DF
DF
DF
DF
DF
DF
ed on leachate of EP Toxicity Procedur
'Total
SSW 846 1310)
METHOD OF ANALY
206.2
208.2
213.1
218.1
239.1
245.1
270.2
272.1
CHARGE
$459.20

DESCRIPTION OF PRETREATMENT FACILITY
Reichhold's Charlotte Plant manufactures emulsion polymers for the
adhesive, paper, and latex paint industries. Primary raw materials
are vinyl acetate, methyl methacrylate, and butyl acrylate.
The plant produces about 15,000 gal/day of waste water which is
pretreated by chemical coagulation and filtration. (See attached
drawing)
The chemicals used in pretreating are:
a) Ferric Chloride
b) Sodium Hydroxide and/or lime
c) Anionic and Cationic Polymers
Approximately 5500 lbs. of 20% solids sludge are produced each day
in the pretreatment system. The sludge is loaded into dump trucks
and transported to the land application site off Dorman Road in
Pineville, North Carolina. The sludge has been tested by independent
laboratories and found to be non -hazardous.

AGRICULTURAL
EXTENSION
SERVICE
Department of Biological and
.Agricultural Engineering
Box 7625, Raleigh, NC 27695-7625
Telephone [phone]
North Carolina State University
School of Agriculture and Life Sciences
MEMORANDUM
TO: Dave Whitley
FROM: A. R. Rubin, Extension Specialist
Biological and Agricultural Engineering
SUBJECT: Report of Investigation
Attached is a copy of the report for the land application of
waste at:
Reichhold, Inc- Report
ARR.: sb
MAY 6 1988
Reichho!Li Ghornicals, Inc.
Charlotte, N. C.
Cooperative Extension Work in Agriculture and Rorne Economics A&7and N.C. State Universities,100 Counties and U. S. Department of Agriculture

SITE INVESTLC7aTItiN
Reichhold, Inc..
Mecklenburg County
The Reichhold, Incorporated operates a manufacturing plant to produce
latex emulsion in Charlotte, North Carolina. They have an industrial
wastewater pre-treatment facility located on the site which renders the
wastewater suitable for discharge to the Charlotte municipal utility district.
During this pre-treatment process, wastewater residuals are removed from the
waste stream and. render as sludge. These residuals or sludges have been
transported from the Reichhold facil
in Mecklenburg County.
This dedicated s
to a dedicated land application located
s not permitted under the State Division of
Environmental Management rules and regulations. Ultimately Reichhold requested
a permit for this site from the State Division of Environmental Management.
The State requested that Reichhold provides supporting documentation to ensure
that the on -going operation did not contravene the environmental quality in the
area. Reichhold contacted North Carolina State University, Biological and
Agricultural Engineering. Department to evaluate the existing sludge receiver
site and to determine the possible effects of the on -going sludge management
program on soil, vegetation, and groundwater.
There are two purposes for the brief report which follows. The first i
to describe conditions encountered on the site and to describe the procedures
use to evaluate the ,site. The second
to make recommendations regarding
continued use of the Reichhold sludge receiver site.
Location
The single site evaluated in this project is 1
:ed on State Road 3637
in. the south central portion of Mecklenburg County, North, Carolina. The site

2
is located on the attached map. McAlpine Creek serves as a physical border as
well as a hydrologic border for this site. Adequate buffers do appear to be
place to prevent service contamination of the creek. The site is located in an
isolated rural section of the county and location should not limit the
suitability of this site to continue to serve as a receiver for this non -toxic
and non -hazardous waste.
Topo raphy
The single site used by Reichhold as a receiver for waste is typical of
the Piedmont physiogeographic province of the state. Slopes range from gently
rolling to steeply sloping. The actual area which is currently used as a
receiver for the waste sludge is gently rolling, while the buffer is more
steeply sloping and is severely gullying in some areas.
The topography on the waste receiver site was evaluated with an
inclinometer. Topographic maps are available of the area. The maximum slope
from the uppermost to the lowermost elevation on the site is considered
excessive, but the slope on the actual waste receiver site is generally 2 or 3
percent. There is considerable fall from the area serving as the waste
receiver sate to McAlpine Creek. The entire site is not use as a receiver for
waste and for this reason, topography should not be limiting. The topography
an the area currently serving as a receiver for waste is ideal and the
constituents which are applied to the soil and which will move through the soil
will follow the gentle gradients off the site.
In general, waste can safely be applied to the site with as much as 15%
slope. Slope as high as 20% can be used with subsurface injection. The relief
or slope evaluated on the portion of the Reichhold site currently used as a
receiver
e for waste is not excessive and topography or relief should pose
no hazard to the use of this area as a receiver for waste.

The July 1980 Soil Survey of Mecklenburg County, North Carolina, listed
soils in the area on. which Reichhold waste has been applied as Cecil and.
Pacolet soils. Hand auger borings were advanced in the area to determine the
presence of these soils on the site. Thee results of the. hand auger borings do
indicate that the soil resources on portion of the site have been affected, but
that the original, soil could have been the Cecil or Pacolet series.
Additionally, the areas along the periphery of the site contain soils which are
more typical of a Wilkes -like soil. These. soils were confirmed with. hand auger
borings.
Additionally, soil core samples were collected as the project began and
samples have been collected subsequently. The soil core samples were evaluated
to determinepresent or absence of selected heavy metals and the nutrient
status of the soil. Standard methods were utilized by the North Carolina
Department of Agriculture to evaluate soil fertility and the present or absence
of selected heavy metals. The soil core samples were analyzed on a quarterly
basis and the results of that analysis are presented in the following section.
on recommendations. The soil analysis was accomplished to determined whether
selected constituents had been applied to the fields in sufficiently high
concentrations to be detrimental to the soil/plant system. These analyses
indicate that there are no co
nt.s which were evaluated which exceed
acceptable levels. The result of the soil analysis are s mmarized. in Table 1
attached. The analysis indicates that no constituent contained in the soil are
at rates greater than expected for either the waste receiver site or the back-
ground s:i.te. The data indicates that there is very little significant
difference between the cons
uents contained in the waste receiver site and on
the background site. Some minor variations are noted in the phosphorous
content of the receiver site verses the forested non -receiver site. These

4
differences can be explained in variation in crop growth and in the application
of the waste. Phosphorous concentration less than 100 are within normal and
acceptable, ranges for soils throughout the Piedmont. Phosphorous is not
considered. a. terribly detrimental nutrient and in fact€act is essential for plant
growth. In general, the soils on the site do not appear to have been seriously.
degraded through this land treatment program.
Vegetations
Samples of vegetation actively growing on the Reichhold waste receiver
site were collected for chemical analysis. The purpose of the chemical
analysis of the. vegetation was to determine whether the land treatment program
had any affect on the characteristic of the vegetation growing on the site.
Samples of vegetation from both the waste receiver site and from an area not
affected by land treatment were collected. The results of that analysis is
summarized. in the table attached. The vegetation was collected during the most
active growing season of the year. For this reason only one sample of
vegetation is reported. The results of the analysis do indicate that there are
only minor variations noted in the constituents contained in the samples of
vegetation growing on the site. The content of macro -nutrient on the site
which did not receive waste in intermediate between the two readings for the:
site which did receive waste. This analysis is indicative of the successful
operation of this land treatment program. There do not appear to be serious
excess of constituents contained in the vegetation on the site. In fact,
constituents vegetation on the site is present at only very low levels and the
crop on the site would be a poor feed for agricultural livestock. In general,
the vegetation on the. site does not appear to have an adversely affect by the
land treatment of the Reichhold waste. This is verified by the normal values
representing constituent concentrations in the vegetations for the control and
from waste receiver sites.

5
Groundwater
The groundwater levels and groundwater quality were monitored in ground-
water monitoring wells advanced on the Reichhold site. Water levels fluctuated
on the site during the year. Groundwater sample were collected from the site
the day following the measurement of the water table. Groundwater was removed.
from the. monitoring well and the groundwater samples were collected 24 hours
after the baling event. A sample of groundwater was collected in May of 1987
and the sample. was analyzed for selected organics. Each of the organics were
reported at levels below the detection limit. That analysis is attached. Other
constituent were reported in the groundwater monitoring program at levels which
could be. detected. Each of the constituents reported in the groundwater
monitoring program were. present at levels which were below the standard for
drinking water. No analysis was performed to evaluate. the present or absence
of bacteria in the groundwater. Bacteria analysis was deemed unnecessary
because the waste applied to the site contained no fecal coliform organism.
The results of the groundwater monitoring are presented in the table attached.
All technique used in the analysis arestandard technique. The technique are
reported in the water quality laboratory methods handbook, North Carolina State
University, Department of Biological and Agricultural Engineering for the
inorganic constituents. The water quality analyzed for the organics was
accomplished with a gas chromatography mass spectrophotometer. This was
accomplished at a private certified lab in North Carolina.
Conclusion
Soil vegetation and groundwater samples from the Reichhold waste receiver
site do not appear tobe contaminated with selected or organic or inorganic
constituents. Soil sampling indicates that there are minor deficiencies
located on the site which could be satisfied through the application of macro

phespheexs
matter
present
decomposition Sri
corrected through,
the groundwater ea
ers. The gheaphereus
vane can be
er.
index value for the sail on
pr aved through the
The acidity, the at and PH
at high levels nd is deco
p
addition of
d a.cate that; organic
g. This organic
increase soil acidity and decrease se
he additen e agricultural liege. Bet
affected try the Indust
on the site.
PH. This can ,be
h the vegetation and
sste-de net appear to be'cent e�inated e
a waite management act avitie
1 -- 7/AR ,dl
adverse
ch had been on —going

Site
SOIL AN `SIS, 1IHT t L17
Date CEC pH Ac dity,
9/6 5.3 5,5
4.3 5.1
12I86 3.9 7.0
4.2 5.
7
Receiver site
Back rotind sail
1.6 66 44 6
1 46 67
47 2 64
1
60 60
6.2; *' 70 6 57 24 58
5.2 12 40 61 23 68 4
5w 6.2 1.2 5d 44 69 24 47 56
5.2 5.7 .8 10 28 72 26 43 5
11x ac
(Fo
e dpplad.
tio aste
applied..

Cott
01
4»28
3 7
VEGETATION ANALYSIS
52
.57
Cu

ichhold Chemicals, inc.
Etrt„Fttm porrners DF,Fst,n
FA,u0 ,FFouth Boulevrco
FOBoxflObl.
,Lt
C 0
July 6, 1987
u
Mr. Michael L. Parker
State of North. Carolina
Department of Natural Resources and. Community. Development
919 North Main Street
Mooresville, N. C. 28115
SUBJECT: Project Return APN 007523
Reichhold Chemicals, Inc.
Land Application of Sludge
Mecklenburg County
Dear Mr. Parker:
At, ttt AttA. „N IFYRAL
AND
, i„Dif ()PM iINT
tF Ewgru muwn
WEESVILLE iiikONAL
This is in response to Mr. R. Paul Wilms letter dated June 26, 1987
and our telephone conversation of July 2, 1987 regarding subject -
In early 1986 we were requested to obtain a permit to operate our
Land Application Area in Mecklenburg County. Listed below is a
brief history of what has transpired sincethat time:
Ft i tth t t
t 10 1,
• April 12, 1986 - Non -Discharge Application Permit,
dated April 11, 1986 was sent to. your
Mr. Horne.
. May 12, 1986 - Check in the amount of $100.00 was mailed
to Raleigh to cover the application fee.
• June 9,
986 - Memorandum of Agreement between North
Carolina Extension Service and Reichhold.
Chemicals, Inc. was signed for the University
todo a study of our land application area.
Dr. A. R. Rubin was assigned as consultant
for this study.
. October1986, - Law Engineering, Charlotte, N. C. completed
three (3) monitoring wells on the site at
locations specified by Dr. Rubin, and in
accordance with your standards.
. NovemberNovernber4, 1986-Waste Determination Form was completed and
mailed to Waste Determination, Raleigh, N.C.
with a copy to your attention.
. January 15,1987- Letter to Mr. Michael L. Babuin, Hydrogeologist
regarding the disposal of coagulated pre-
treatment sludge and general up -dated information

Mr. Michael L. Parker
July 6, 1987
Page 2
Copies of any or all the above correspondence are available to you
upon request.
June 12, 1987 - Letter and sampling data from Dr. Rubin.
Both documents are attached. As stated
in Dr. Rubins letter, sampling shows
very low levels of inorganic constituents
and the May samples were sent to a private
consulting lab for GC/MS analysis.
When the completed report and recommendation are received from
Dr. Rubin, we should be in the position to file another Non -
Discharge Permit Application. In the meantime, if you have any
further questions, please call me at 704-525-6420.
Very truly yours,
D. E. Whitley
Plant Manager
DEW:hs
Enclosures (2)
cc: Dr. A. R. Rubin - N.C. State, Raleigh, N.C.
R. G. Arnott Reif Dover, Delaware
8'1:232

AGRICULTURAL
EXTENSION
SERVICE
North Carolina State University
School of Agriculture and Life Sciences
Department of Biological and
Agricultural Engineering
Box 7625, Raleigh, NC 27695-7625
Telephone [phone]
Dave Whitley
Reichhold Chemical Co..
P. 0. Box 11051
Charlotte, NC 28220
Dear Dave:
Water samples have been collected from the Reichhold landfill facility for
analysis on 3 separate occasions. Water table depths were also recorded. The
water table depth and the sampling are summarized in the table attached.
In general, the sampling shows very low levels of inorganic constituents
in the groundwater. Samples were saved and the May samples were sent to a
private consulting lab for a GC/MS analysis. The May samples were sent for
analysis because they showed the highest concentration of organic carbon of all
samples collected.
As the results of the GC/MS analysis become available, I will complete my
Trite -up and forward to you. I have enjoyed working with you and I look
forward to continuing.
Sincerely,
A. R. Rubin, Extens
Biological and Agri
ARR:d1
Attachment
n Specialist
ltural Engineering
Cooperatiue Extension Work in Agriculture and Home Economics A&T and N.C. State UnuuersitiesR 1Qi? Counties and U. S. Department of Agriculture

Sample Depth TKn NH3 NO T.P. 0.P. Cl COD pH Na pb 2n. Cu Ni Cd TOC
IA 62 2.53 .196 .1 .21 .15 4.1 24.5 7.93 9.1 0 0 0 0 0 2.89
18 57 2.89 .220 .09 .21 .18 4.3 32.5 7.99 9.2 0 0 0 0 0 2.84
1C 59 3.04 .061 .70 .48 .40 15.0 21.2 - 11.2 0 .15 0 0 0 7.64
2A 47 2.39 .096 .08 .27 .24 11.0 48.0 7.68 16.1 0 .01 0 0 0 1.66
2B 41 4.83 .100 .07 .27 .23 11.2 50.5 6.43 16.1 0 .01 0 0 0 1.78
2C 42 4.07 .060 .21 .51 .48 13.7 40.7 - 14.8 0 .11 0 0 0 3.19
3A 42 2.17 .097 .11 .30 .30 23.3 33.5 7.29 7.7 0 .02 0 0 0 1.80
38 29 2.57 .076 .11 .33 .31 22.9 25 6.85 7.4 0 .01 0 0 0 1.46
3C 33 2.10 .040 .21 .41 .41 17.0 18.9 - 7.9 0 .06 0 0 0 1.79
0 = Not Detected

LMIDATE
TELEPHONE
PERMIT
OF MI
DATE AFT C +Jt D
DATE ACKNe
REVIEWED
REG COMM Rag
INFO REQS
END
WPTION
t ,,ES FACILITY AND
FOR PERMIT
CHEMIOALE
TRUED
INZTANI
his€ •.. : 0. ,;} 6
ANUOTAPA
ANcs
NC
PERMIT DATA
ENGINEER: E$ 6.
ZIP 28220 CITY, RALL
TELEICMIWA
ylarf CONTACT
PERMIT
LAT
.^i nar.,...
RERRIRNED
IESULD
EXPIRATION
WIDE
TRI
A:END:IN/CHANCE PERMIT
00
DATE
REGION
03
ZIP 27695

old Chemicals, inc.
' Oroston
051
North Caro una 282'20
REI D
Nove
er
1986
State of North Carolina
Department of Human Resources
Division of Health Services
Solid & Hazardous Waste Management Branch
P. O . Box 2091
Raleigh, N. C. 27602
Attention: Waste Determination
Subject: Reichhold Chemicals, Inc.
Land Application -Pretreatment Sludge
APN 007523
Mecklenburg County
Ladies or Gentlemen:
Your Mr. D. Rex Gleason requested we complete a Waste Determination
Form and send the original to your attention with a copy to Mr.
Michael L. Parker at the Mooresville office. This form is attached
with a copy going to Mr. Parker.
If you have any further questions, please advise.
Very truly yours,
D. E. Whitley
Plant Manager
DEW:bs
Enclosure
cc: Mr. Michael L. Parker w/a
State of North Carolina.
Department of Natural Resources & Co unity Development
P. O . Box 950
Mooresville, N. C. 28115-0950
Mr. D. Rex Gleason - Mooresville, N. C.

STATE OF NORTH CAROLINA
DEPARTMENT OF HUMAN RESOURCES
Division of Health Services
ENVIRONMENTAL HEALTH SECTION '
Solid & Hazardous Waste Management Branch
PROCEDURE AND CRITERIA FOR WASTE DETERMINATION
This procedure will be used by the. Division of Health Services to
determine whether a waste is (1) hazardous as defined by 10 NCAC ]OF, and
(2) suitable for disposal at a solid 'Waste management facility.
The types of wastes that will be evaluated by this procedure ar
primarily, but not exclusively, industrial and commercial wastes and
sludges, and Publicly Owned Treatment Works sludges.
The Division of Health Services reserves the right to request
additional information or waive some of the requirements based on the type
of waste if it deems necessary. The Division may also require some wastes
to be, treated or altered to render the waste environmentally immobile
prior to disposal at a sanitary landfill. Wastes disposed at sanitary
landfills must be non —liquid and in a form that can be confined,
compacted, and covered in accordance with the "Solid Waste Management
Rules". APPROVAL TO DISPOSE OF THE WASTE SHALL ALSO BE OBTAINED FROM THE
OWNER OR OPERATOR OF THE LANDFILL PRIOR TO DISPOSAL.
(
The following information is required for an evaluation. An asterisk
denotes information required for Publicly Owned Treatment Works.
GENERAL INFORMATION
1. Name and address of facility or person generating -waste
Reichhold Chemicals, Inc., 5000 S. Blvd., Charlotte, N.C.
2. What is the waste? Coagulated Solids From Polyvinyl Acetate
Emulsion Manufacturing Process.
What volume of disposal will there be? Approximately 5,500 pounds
of 2.0% Solids Sludge Daily— 5 days per week.
4. What frequency of disposal will there be? Daily — 5 Days/Week
5. Explain either the manufacturing process or how the waste was
generated. The Plant On South Boulevard Manufactures Polyvinyl
Acetate Emulsions For The PainttPaper and Adhesive Industries.
Waste_Water Generated From The Manufacturin• Process Is Treated
to Chloride. Lime And/Or Caustic Soda, Anionic And
s A Slud e Is Generated And Trans orted To
Our Land application Site Off Dorman Road,t Pineville, N. C.

-2-
I f0RMATION FOR HAZARDOUS (RCRA) DETERMINATION (10 NCAC 10F .0029)
Is the waste listed under .0029(e) (i.e., 40 CFR 26I.31 - 261.33)?
If yes, list number. No
2. Does the waste exhibit any of the four characteristics as defined by
..0029(d) (i.e., 40 CFR 261.21 - 261.24)? (Attach lab results)
(EP 'Toxicity for metals and pH). No
INFORMATION FOR LANDFI'LLING 'DETERMINATION
1. Does the waste contain any hazardous waste constituents listed in
.0029(e), Appendix VIII (i.e., 40 CFR 26], Appendix VIII)? If yes,
what constituents and what concentration? (Attach Jab results.)
No Appendix VIII Constituents Are Believed To Be Present.
In Significant Levels.
2. What other constituents are present and in what concentration? (Attach
lab results.) To The Best Of Our Knowledge No Other Chemicals
Listed By EPA Are Present In This Waste.
What is the moisture content? Approximately 80%
4. Which solid waste management facility is the request for?
Reichhold Chemicals, Inc., Off Dorman Road, Pineville, N.C.
5. Specify how the waste will be delivered - in hulk or containers (i.e.,
barrels, bags, etc.)? Dump Truck
"I hereby certify that the information submitted in regard to
a
C Mfg. Facility (Chemical Separation)(name of waste) is true and correct
The best of my knowledge and belief."
(signature
All questions concerning this "Procedure should be directed to
Gordon Layton or Jerry Rhodes at [phone]. Answer specific
questions in space provided. Attach additional sheets if necessary.
Complete all information, sign and submit to:
Division of Health Services
Solid & Hazardous Waste Management Branch.
P. 0. Box 2091
Raleigh, NC 27602
Attn: Waste Deternination
DHS Form 3151
Solid & 13
Rev. 4/84
rdous Waste Management Branch

S Laboratories, Inc.
F,}MPANO DRIVE
UT E, WORTH CAROLINA 28216
.1''4 6276
It E SOURCES
VA Sludge
60:
eichbald Chemicale
00 5. Blvd.
harlotte, N.C. 28220
tt Mr. David Wbitlev
d °ARAMETER
,indane, EP Tax. Extract
7. Spike recovery
:ndrin, EP Tox Extract
I Spike recovery
apbene, EPTox Extract
Spike recovery
,4-D, EPTox Extract
X Spike recovery
ivex, EP Tox Extract
Spike recovery
REPORT DATE 2/1Q/ii6 DATE RECEIVED 12/l7/86
EMS SAMPLE 1.
PO, 0
WASTEWATER
SLUDGE
OIL
LEACHATE
OTHER
SAMPLE TYPE
DATE SAMPLED
COLLECTED BY
AB
COMPOSITE
8/15
REMARKS PVASIude^ Leachate
No.00549
Do not pay Imo
IN: copy
EP Texicity Extcti
RESULTS pet. Limit DATE ANALYZED
ND 0.004 1/9/86
80
ND
119
0.002
1/9/86
ND 0.005 1/9/86
113
ND
87
ND
67
0.01
0.001
fx rbicide Derrivatization Complete NA
`t.:utieide Extraction, Water Complete NA
1/20/86
1/20/86
1/20/86
1/6/86
ND analyte not detected at detection limit indicated
NA - Not applicable
All results in mg/L
ANALYST
DJO
DJO
DJO
ACB
ACB
ACB
DJO
METHOD OF ANALYSIS
SW846 8080
SW846 8080
SW846 8080
SW846 8080
SW846 8080
SW8468080
SW846 8080
SW846 8080
SW846 8080
SW846 8080
NA
NA
Total
CHARGE
00

LisiltJra ofj+ ,, C.
>re1PANO DRIVE
NORTl! CAROLINA 2821r!
16
[ OURCES
zetchold Chemical, Inc.
J TO:
',choldChemical i , Inc.
r''I south Blvd. - P.O. Sox 11051
lotte, tJC. 28220
A nAMETER
I.c, As
m, Ba
Cd
Cr
Note;
REPORT DATE
EMS SAMPLE Ir, 40
P.O.1
WASTEWATER
SLUDGE X
OIL
LEACHATE
OTHER
SPIKE
RESULTS RECOVERY
<0.01 90%
1.5 95%
<0.01 95%
<0.05 98%
<0.05 93%
<0.001 100%
<0.005 90%
<0.01 1007.
DATE ANALYZED
11/27/85
11/22/85
11/25/85
11/25/85
11/25/85
11/26/85
11/27/85
11/25/85
DATE RECEIVED 11 2
SAMPLE TYPE RAS, COMP
DATE SAMPLED 11/13
COLLECTED BY
REMARKS PV'
E P Toxicity Extra t —m
ANALYST
DF
DF
DF
DF
DF
DF
DF
DF
1 Analysis performed on leachate of EP Toxicity Procedure
Tota1
(SW 846 - 1310)
METHOD OF ANALY
206.2
208.2
213.1
218.1
239.1 •
245.1
270.2
272.1 1.
TE
00ay�
Do not Psi
copy
CHARGE
$459.

89.5
C
PCI
12/85
CT
8..:
59
oPO4
.6.6
STICS
U I
8.0
C

State of North Carlin
Department of Natural Resources and Community Development
Division of Envirortmertta1 Management
512 North Salisbuty Street • Raleigh, North Carolina 27611
"horna .h
We acknowledge receipt of the following documents
permit application - APN
engineering plans
specifications
other tf
Your project has been assigned to
All project documents will be reviewed wi'tlt respect to the proposed
this Division to approving any expansion of these treatment faciliti
MAY a
a d
This revi
in the future,
Prior to the issuance of the permit, you will be advised of the reconnmend Lions any nomtrtents of this Division,
You will also be informed of any matter which needs to be resolved
Our reviews are scheduled based on receipt date of complete informa
before your project can be reviewed,
permit application (copies enclosed)
engineering plans (signed and sealed by N,C.P,E.)
specifications (signed and sealed by N.C.P.E.)
other additional information detailed on attachment.
bove checked information is needed by ., .,, If not received, your application
e Regional Office.
must provide RECOMMENDATIONS from. the Regional Supervisor or a Procedure Four Evaluation for this project,
prior to final action by the Division,
The
package will be returned as incomplete. Please be aware that the Division's
cc:
hecked below are needed
If you have any questions, please call the review engineer at this telephone number '919/73-5083.
t?c ficx 27687,;
"7 at#-7687 Telephone 9t9-733-4984

ARCS f'ERIcIIT AP
Cltattter 14* Aeti
e Treatment ;+ a tportal Facilityi
Pretreatment Facilities
it wer Collection System (private)
end Sewer and Sewer Systems (public)
NATURE OF WASTEWATER-
0 Sewage
Q Sludge/Industrial Waste
palter 9ffate ......... .... .....
At (lac
Treatment
Af#'ecf Over
Capaci
U
ducfon to P
0. D. (5-day 2fr C?
lle.naled Solids
TOTAL SOLIDS
Coliform Bacteria
a
Applicant assures that proposed works
specifications or approved changes alter
(p Code.
Toxic 1
21.
y Development
VON*
For (nay yrs.) Average
TOTAL TOXIC MAT ERIA LS
constructed, supervis
ud mairitai
County
SE
Te)epiagrar N
F
E
Trestm erto.t
d Cos
unplug
ion
Plant
nct with approved plans and
Title:
INSTRUCTIONS;
1, Fill-in ALL spoces, If not applieabfa +enter N/A.
2. Secure appropriate signature {mayor/city manager for munic{ptality; c]tasrarea
or legally constituted board or commission in charge of proposers works) A
design engineer or other open, signs application,
3 Submit to N.C. Deportment of Natural Resources and Codinnunity Development, Environmental Manogerrtent, Raleigh, NC, the
origina#.. rand first copy of application, 2 sets of finalised plans, specil'icat"sons and other supporting data asrepair ed by Commuss6arr Rules..
ft21Ei Applicati on reviews,ore scheduled en receipt of COMPLETE infonnation, Generally, 30 mays are required for pollution abatement projects; 90 days
for other projects
For Assistance, call the State Central Office 919/733-5083, P.O. Box 27687, Raleigh, N.C. or:
*Asheville 004) 253•3341 "Mooresville [phone] "Washington (#f19) 946-6 k81 •Winston-Salen' (919) 761-2'35.1
159 Woodfin Street 919 North Moin Street 1502 North Mork*? Street 8003 Silas Creek Parkway Extension
Asheville, NC 28801 Mooresville, NC 28115 Washington, NC 27889 Winston-Salem, NC 27106
*Fayetteville [phone]
Suite 714 Waehovio Building
Fayetteville, NC 28301
*Raleigh [phone]
Box 27687
Raleigh, NC 27611
ary district board; owner/proper official
authorization is required from proper
*Wilmington [phone]
7225 Wrightsvi Ile Avenue
Wilmington, NC 28403
corporat
affitial of

State of North Carolina
Department of Natural Resources and Community Development
Division of Environmental Management
12 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor
S. Thomas Rhodes, Secretary
MEMORANDUM
May 16, 1986
TO: William L. Meyer, Head
Solid and Hazardous Waste Management Branch
FROM: Cecil G. Madden, Review Engineer
State Engineering Review Group
SUBJECT: Reichhold Chemicals, Inc.
Land Application Pre -Treatment Sludge
APN007523
Mecklenburg County
R. Paul Wilms
Director
The Reichhold Chemical Company has requested a non -discharge permit
for the land application of sludge at agronomic rates. The sludge was generated
at the Reichhold Chemical lndustridl Wastewater Pre -Treatment Facility. As
per the agreement between our departments, I am hereby requesting your review
and comments on the attached documents.
Please review this information to determine if it is non -hazardous and
non -toxic and provide our office with your comments. If questions arise,
please call me at 919/733-5083, ext. 122.
cc: Dennis Ramsey
Mooresville Regional Office
Central Files
CM /jp
Pollution Prevention .Pays
l?U. Box 27687, Ra
North Carolina 27611-7687 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

11PP-
DESCRIPTION OF PRETREATMENT FACILITY
Reichhold's Charlotte Plant manufactures emulsion polymers for the
adhesive, paper, and. latex paint. industries. Primary raw materials
are vinyl acetate, methyl methacrylate, and butyl acrylate.
The plant produces about 15,000 gal/day of waste water which is
pretreated by chemical coagulation and filtration. (See attached
drawing)
The chemicals used i.n. oretreating are:
a) Ferric Chloride
b) Sodium Hydroxide and/or Lime
c) Anionic and Cationic Polymers
About 5500 lbs. of 20% solids sludge are produced each day in the
pretreatment system. The sludge is loaded into dump trucks and.
transported to the. land application site off Dorman Road in Pineville,
North Carolina. The sludge has been tested by independent laboratories
and found to be non -hazardous.

EMS Laboratari 5, Inc.
4132 POMPANO 011IV
CI ARLOT "1'L, NO11111 CAR fu (.INA 21)216
[phone]
SAMPLE SOURCES
PVA Sludge
BILL TO,
Reicllhold Chemicals
500 S. Blvd.
Charlotte, N.C. 2.8220
Att: Mr. David Whitley
PARAMETER
Lindane, EP Tox Extract
% Spike recovery
Endrin, EP Tox Extract
®% Spike recovery
Toxaphene, EPTox Extract
% Spike recovery 1.1.3
ND 0.01 1/20/86
ND
80
REPORT I.)AIl
EMS SAMPLE N _ 504.
P.O.
WASTEWATER
SLUDGE. ......,.,,.w_
OIL
LEACLIATE
©TIER
0.004
6
DATE ANALYZED
1/9/86
ND 0.002 1/9/86
119
2,4-D, EPTox Extract
Spike recovery 87
ND 0.005 1/9/86
Silvex, EP Tox Extract
7.Spike recovery
Herbicide DerrivaLi at:ion
Pesticide. Extraction, Water
ND' 0.001 1/20/86
67
Complete NA
Complete NA
1/2
86
1/6/86
ND - analyte not detected at detection limit indicated
NA Not applicable.
All results in mg/L
DA I L LiLCLIVLD
SAMPLE 1 Y1'L X _GRAB __,_,ACOMPOSI1 L
LATE SAMPLED 1111, $5
COL 1 LI) LIY
REMALIKS PVA Sludge Leachate
EP Toxicity
ANALYST
DJO
DJO
DJO
ACB
ACB
ACB
DJO
action
MET OD OF ANALYSIS
SW846 808()
SW846 8080
SW846 8080
SW846 8080
SW846 8080
SW84 68080
SW846 8080
SW846 8080
SW846 8080
SW846 8080
NA
NA
No. 00549
_ Do not pay Irmo
this copy
CHARGE
Total $300. 00
DATA REVIEW .l
REPORT
COPY

MS Laboratories, Inc.
POMPANO DRIVE
IARLUI IL, NOM I I CAROLINA 2U2ll
:A) 392 62/6
,MPLE &OUIICES
Reichold Chemical , Inc.
LL TO,
Reichold Cle teal, Inc.
5000 South Blvd. - P.O. Box 11051
Charlotte, NC. 28220
HLPORI LIAIL
EMS SAMPLE
p 19976
WASTEWATER
SLUDGE X_
OIL
LEACHATE
OTHER
A LIVLD 111211,85_
1.
SAMPLE TYPEX ‘rma CO TE
DATE SAMPLED 1111
COLLEGTEDBY
nEmAms PVA
E 1' Toxicity E )1'ocedui.e
4 aj
r" • — e
PARAMETER
Arsenic, Aa
Barium, Ba
Cadmium, Cd
Chromium, Cr
Lead, Pb
Mercury, llg
Selenium, Se
Silver, As
Note,
•
SPIKE
RESULTS RECOVERY
<0.01 90%
1.5 95%
<0.01 95%
<0.05 98%
<0.05 93%
<0.001 100%
<0.005 907.
<0.01 100%
DATE ANALYZED
11/27/85
11/22/85
11/25/85
11/25/85
11/25/85
11/26/85
11/27/85
11/25/85
;!
ANALYST METHOD OF ANALY!TAIS
DF 206.2 1
•!
DF 208.2 1*.:
DF 213.1
DF 218.1 :*
DF 239.1 "‘
DF 245.1
DF 270.2
DF 272.1
Metal Analysts performed on leachate of EP Toxlcity Procedure.focal
,t
(SW 846 - 1310)
4
NU
t 0.00376
fle rtot pay tram
this copy
CHARGE
.1:459.20
")ATA PEVIEVAA)

MEMORANDUM TO:
THROUGH:
FROM:
SUBJECT:
DIVISION OF ENVIRONMENTAL MANAGEMENT
August 6, 1986
Len Bramhle
Ron McMiilai
Bill Crawford pc
Non --Discharge Permit Application Review
Reichhold Chemicals, Inc.
Mecklenburg County, North Carolina
I have reviewed the subject permit application at the above referenced site and
submit the following recommendations:
1. A monitoring well system consisting of one up gradient well and a minimum
of three down gradient wells is recommended to determine if the past, non -
permitted :and application of sludge has contaminated the groundwater at
this site. I have plotted the recommended locations for the monitoring
wells on the attached site map.
2. The monitoring wells should be sampled for the following parameters:
COD
TOC
Chloride
pH
Sp. Conductance
Organics
Sulfates
Nitrates
Total Kjeldahl Nitrogen (TKN)
Total Solids
Water Level
Metals (Ar, Ba, Cd, Cr, Pb, Hg, Se, Al)
Water samples should be obtained from the existing 2" drilled well on the
property to be analyzed for the same parameters as the monitoring wells to
determine if contamination exists in the confined zone.
4. A soil boring should be made adjacent to each field used thus far to define the
major types of lithologic strata underlying the site and the estimated
vertical hydraulic conductivity of the consolidated thickness of the strata
encountered.
Should you have questions regarding the above recommendations, please call me.
Mr. Mike Parker

GROUNDWATER SECTION
DIVISION OF ENVIRONMENTAL MANAGEMENT
RECORD OF WASTE DISPOSAL PERMIT APPLICATION REVIEW
REVIEW BY: William H. Crawford
FIELD INVESTIGATION BY: Jesse W. Wells DATE:
FACILITY NAME: Reichhold Chemicals, Inc.
TOWN: Pienville
LOCATION: Off Dorman Road -SR 3637 (see attached ysite
TYPE OF DISPOSAL SYSTEM (LANDFILL, LAGOON, ETC):
DESIGNED CAPACITY (GPD): 5500 lbs/day
WASTE PHYSICAL CHARACTERISTIC: Vinyl Acetate, Methyl methaerylate, butyl acrylate,
DESCRIPTION OF FACILITY:'Approx. 5500 lbs. of 20 solids sludge produced each day in
es ment s stem.,, Suud a haul d b, dun truck to a.t 1_ a e,Dozer Dor used approx,
CHEMICAL ANALYSE ANDSOTHER DATA AVAI'ABLE: (CHECK THOSE APPLICABLE AND ATTACH COPIES):
AMBIENT GROUNDWATER QUALITY (WATER TABLE) RAW WASTE © OTHER
r 1 AMBIENT GROUNDWATER QUALITY (ARTESIAN) MD TREATED WASTE SPECIFY
NAME OF NEAREST STREAM: McAlpine Creek _ DISTANCE:approx. 200'
DISTANCE TO NEAREST WELL: approx. 300' DEPTH: 65.5PUMPING RATE: Unknown
PROPOSED METHOD FOR PREVENTING GROUNDWATER CONTAMINATION: Recommend monitoring well
system.
DATE: S/5/B6
COUNTY: Mecklenburg
STRUCTURE, LITHOLOGY AND PERMEABILITY OF SURFICIAL MATERIALS:Overburden consists of
red clay (±50) on hills and ridges; silty clay in flood plain areas.
HYDRAULIC RELATIONSHIP BETWEEN WATER TABLE AND ARTESIAN AQUIFERS: The water table
aquifer is connected to the artesian aquifer by the fracture system in the bedrock
DEPTH TO BEDROCK ±50 feet DEPTH TO SEASONAL HIGH WATER TABLE: ±40 feet
MONITORING FACILITIES NEEDED (ATTACH SKETCH): Monitoring well system consisting of one
upgradient well and a minimum of _three down gradient wells.
RECOMMENDED SAMPLING SCHEDULE AND PARAMETER REQUIRED:
Slufates, Nitrates, Total Nitrogen (TKN)„ Sp,, Cond. pW. Otg_an .cs. Water, Levey
REMARKS AND RECOMMENDATIONS Groundwater contamination may exiRt at thia,sitp from non -
permitted land aiarlication in,"pis
ct Mart
samples for contamination tarior to issuance of non -discharge pPrmir_
ua
t yeax5, _ oift.pring wE11s"Ahptild be jnsrallP
GW 48
Revised 7/84

2
2'30"

D E M USE ONLY
North Carolina Department of Natural Resources and Community Development
Environmental Management Commission
NON -DISCHARGE PERMIT APPLICATION' '
' in accordance with N.C. General Statutes Chapter 14
Permit Number:
Cau
yMECELENBURG
Appfieant
RE
came 0f board endtvlduol, ar other
CHHOLD CHEMICALS
NC.
Froiect ( ame of city village town sanitary d'6
nti:
PINEVILLE LAND TREATMENT FACILITY
A
A
1986
R:
Discharge Treatment%Disposal Peelliti
Pretreatment Facilities
© Sewer Collection System (private)
Extend Sewer and Sewer Systems (public)
NATURE OF WASTEWATER:
Sewage
Sludge/lndustr"sal Baste
Other Waste
From (sewers, ptetrse meat far tie
Pretreatment Faci
Into (nome of treatment pleat),
N/A
At (location of treattrtent plant);
N/A
Brief Project Description:
xn
Land Application of Nan Haaa=r
Waste Water, Pre .tr Itz
tiiPS1ON t7i t'.;',:M=`:\ \ 1. tilANAuE"AENI
n (ci
ReichhoLyd Che
unary To (norm*
t omglete Address o,f' Engineering Firm. Zip Code.
A.R. Rubin, N.C.State University,Box 7625,R
A
Telephone No.
eigh,NC 276+95-7625,737-2.67
Treatment Works Ca
REICHHOLD
ci tt+ to S.rrve (name of propeet):
CHEMICALS, INC.
For
e
yrs.) Average Daily
0
00
e Flowa
A
Qve
Pollsption (not app)rc
B. O. D. (5-day 2f:t C)
Suspended Solids
TOTAL SOLIDS
Coliform, E3
N/A
Toxic Materials (specity °rr e,n odd pages 'if needed)
None
N/A
N/A
N/A
Pumping
nation
N/A
Treatment
Plant
TOTAL TOXIC MATERIALS
Other (specify)
Estimated Complet
EXISTING
Dare;
ppl-cant assures that proposed works well be constructed, supervised, operated and maintained in accordance with approved plans and
pecifications or approved changes thereto.
P
D. E.
Signature;
T
Plant Manager
Moiling Address: Zip Code
P.O.Box 11051,Charlotte,NC 28220
Telephone No, / /
'704-525-6420
PNST RUCTIONS:
1. Fil$-in ALL spaces. If not applicable, enter N/A.
2. Secure appropriate signature (mayor/city rnonager for municipality; chairman for sanitary district board; owner/proper official of.c.orporatior
or legally constituted board or commission in charge of proposed works). A letter of authorisation is required from proper official if
design engineer or other agent signs application.
3, Submit to N,C. Departmant of Naturo( Resources and Community Development, Environmental Management, Raleigh, NC, the
original and first copy of application, 2 sets of finalised plans, specifications and other supporting data eo required by Commission Rules,
NOTE: Application reviews ore scheduled on receipt of COMPLETE information. Generally, 30 days are required far pollution abatement protects; 90 days
for ether protects
For Assistance,
*Asheville [phone]
159 woodf'rn Street
Asheville, NC 28801
call the State Central Office 919/733-5083, P.Q. Box 27687, Raleigh, N.C. or
'Fayetteville [phone]
Suite 714 Wochovia Building
Fayetteville, NC 28301
'Mooresrille (7041 663-1699 "Washington [phone]
919 North Main Street 1502 North Market Street
Mooresville, NC 28115 Washington, NC 27889
•Raleigh (9191 733-2314
Box 27687
Raleigh, NC 27611
'Winston-Solem (9191 761.2351
8003 Silas Creek parkway Extension
Winston-Salem, NC 27106
'Wilmington (9191 256-4161
7225 Wrightsvil'te Avenue
Wtlm.ingtort, NC 28403

Reichhold Chemicals, Inc.
Emulsion Polymers Dyson
5000 South Boulevard
PO, Box 11051
Charlotte, North. Carolina 28220
April 12, 1986,
ArWslatV of
Mr. J. Thurman Horne, P.E.
Environmental Engineer II
Div. of Environmental Management
Mooresville Regional Office
N.C. Department of Natural Resources
and Community Development
919 North Main Street
Mooresville, N. C. 28115
Dear Mr. Horne:
MOORE:Maur,
P2,10x4L off4
RC OD
APR :7
"
As requested, we are pleased to submit for your consideration the enclosed
Non -Discharge Permit Application for our Land Application Site located
off Dorman Road near Pineville, N. C. Also enclosed is Reichhold's
response to your Preliminary Information Request of November 13, 1985
and a letter and proposal from Dr. A. R. Rubin of the Agricultural
Extension Service, North Carolina State University for an evaluation
of conditions of the site.
We plan to sign a letter of understanding with N.C. State University
to initiate the studies described in the proposal. We have contacted
local well drilling contractors regarding installation of the necessary
groundwater monitoring wells, and would like to meet with you, Dr.Rubin
and Mr. Jesse Wells at an early date to discuss plans for the site
and finalize details of the evaluation program. We will contact you
at an early date to set-up a time for the meeting.
We appreciate your continued interest in this matter and trust you
will contact us if you have any further questions.
Very truly yours,
D. E. Whitley
Plant Manager
DEW:bs
Enclosures
cc: D. E. Frey - RCI Silver Lake
M. Kowalski - RCI White Plains
TeL [phone]
[phone]
Twx, 8106210559

AGRICULTURAL
EXTENSION
SERVICE
North Carolina State University
School of Agriculture and Life Sciences
Department of Biological and
Agricultural Engineering
Box 7625, Raleigh, NC 27695-7625
Telephone (919) 7'7-2.675
Mr. David Whitley
Reichhold Chemical Company, Inc.
P. 0. Box 11051
Charlotte, NC 28220
Dear Mr. Whit
It is a pleasure to submit the attached research proposal to you. The
research results gained from this project will be beneficial to Reichhold
Chemical Company, Inc., the Agricultural Engineering Department at North
Carolina State University and the State Division of Environmental
Management/Water Quality Section.
If you have concerns or comments concerning the attached proposal, please
do not hesitate to contact me at the letterhead address. I look forward to
working with you toward completion of this project and toward initiation of
subsequent projects.
Sincerely,
A. R. Rubin, Extension Specialist and
Assistant Professor
Biological and Agricultural Engineering
ARR:wm
Enclosure
Cooperative Extension. Work in Agriculture and Horne Economics A&T and V. C. State Universities.100 Counties and U. S. Department of Agriculturc

PROPOSAL
to
REICHHOLD CHEMICAL, INC.
Charlotte, North Carolina
Purpose:
The purpose of this project is to determine whether the land treatment
facility operated by Reichhold Chemical Company, Inc. near Charlotte, North
Carolina, has influenced soil or groundwater quality at the 22-acre site in
south Mecklenburg County.
Objectives:
A. To determine the areal extent of the landfill operation and
examine the records prepared by Reichhold Chemical Company to
determine the volume of material applied to the site.
B. To install groundwater quality monitoring wells and to examine
the shallow groundwater quality up gradient from the land treatment/
landfill facility and down gradient.
C. To determine the physical and chemical properties of untreated soil
from the site.
D. To examine soils on the landfill/land treatment site for the
identical physical and chemical properties investigated above.
Background:
Reichhold Chemical Company, Inc. operates a wastewater pretreatment
facility at Charlotte, North Carolina. The purpose of the pretreatment
facility is to provide the necessary industrial wastewater pretreatment for
discharge to the Charlotte municipal utility district. In accomplishing the
necessary industrial pretreatment, the solids (sludges) generated must be
removed from the facility to ensure its proper operation. This process is
called sludge wasting. The wasted sludges must be handled in a manner approved
by the State Division of Environmental Management. A method deemed by the
Division of Environmental Management is land treatment. Since the land
treatment facility has been in operation for someunknown period of time and no
accurate records are available, there must be some determination of the effects
of the current operation on the soil, site, and underlying groundwater.
The purpose of this project is twofold. The first is to determine the
effects of the operation upon the site and the second to make recommendations
regarding continued use of the receiver site to serve Reichhold Chemical
Company, Inc. as a receiver for the industrial sludges generated at their
Charlotte facility.

Procedure:
This project must be accomplished in several phases. The first phase will
consist of examination of Reichhold Chemical Company, Inc. records from their
Charlotte facility. This examination will be used to determine a best estimate
of the volume of material applied to the site. A thorough chemical analysis of
the waste generated at Reichhold Chemical Company must be performed to
determine the standard extraction procedure toxicity, micro and macro nutrient
values, and the levels of chloride, sulfate, sodium, potassium, and other
constituents that may be critical in the design and operation of a land
treatment facility. This characterization of the sludge and estimate of the
sludge volume applied is essential if the site is to be used further. Many of
the constituents in the waste stream have cumulative loading limits, and it is
imperative to determine both estimates of volume applied and chemical
characteristics to determine the useful life remaining in the site.
Groundwater monitoring is also essential. In order to assess the quality
of the underlying, shallow water table, monitoring wells should be advanced to
the first or unconfined aquifer. Generally, this unconfined aquifer is
encountered within 25 to 30 feet of the soil surface. The shallow groundwater
monitoring wells must be placed on the site to assess the quality of the
underlying water. Type II groundwater monitoring wells are recommended for
most land treatment facilities by the State of North Carolina. For this reason
the groundwater monitoring wells proposed for this site should be constructed
to state standards as Type II groundwater monitoring wells. These wells will
be required if the facility remains in operation as a land treatment system.
Once installed, samples of the shallow groundwater must be collected for
analysis. A minimum of three groundwater monitoring wells should be placed on
the site. One groundwater monitoring well should be placed up gradient from
the land treatment/landfill operation and two should be placed down gradient.
Groundwater monitoring welts must be installed by a reputable well drilling
contractor. Boring logs must be maintained an each of the groundwater
monitoring wells.
Groundwater samples must be collected from each well. These well samples
should be collected once the well is stabilized. The groundwater samples
should be collected by a representative from the Biological and Engineering
Department at North Carolina State University and transported immediately to
the waste management laboratory at the University. Samples must be preserved
properly and cooled prior to transportation. Analysis shall be as determined
by the State Division of Environmental Management but should include at minimum
the following constituents:
- Chemical Oxygen Demand
- Total Organic Carbon
- Chlorides
- Sulfates
- Nitrates
- Total Kjeldahl Nitrogen (TKN)
- Total Solids
- Electrical Conductivity
- pH
- Selected organics as determined from the
sludge analysis
2

Subsequent sampling may include analysis for additional organics which are
found present in the sludge. Monitoring shall be accomplished initially at the
time of installation of the groundwater monitoring wells and subsequently for
one year following their installation on a quarterly basis.
Soil and site sampling will include collection of shallow soil core
samples from both treated and untreated sites. Sail cores will be analyzed for
selected organic constituents as determined from the sludge analysis. In
addition, fertility status, pH, nutrient status and sodium index values will be
determined for both the background or benchmark soils as well as from treated
cells in the waste treatment area. The initial analysis will be used to
determine or assess the effects of previous practices as well as to make
recommendations regarding continued use of the site. Soil samples will be
collected by representatives of the Department of Biological and Agricultural
Engineering and analysis shall be performed in the Biological and Agricultural
Engineering Department laboratory at. North Carolina State. University as well as
the North Carolina Department of Agriculture Soil/Agronomy Lab. Soil sampling
and analysis should be accomplished as an initial effort, and subsequent
sampling will be accomplished from the experimental or treatment cells on a
quarterly basis once the project begins.
Data Analysis:
The data collected in this project will be analyzed using appropriate
statistical techniques. The analysis will be presented to Reichhold Chemical
Company, Inc. for their review prior to release to the State Division of
Environmental Management.
Investigator:
The principal investigation for this project is Dr. A. R. Rubin, Extension
Specialist and Assistant Professor, Biological and Agricultural Engineering
Department at North Carolina State University. Other personnel will be a
research technician currently employed in the Department of Biological and
Agricultural Engineering, laboratory personnel employed in the Department of
Biological and Agricultural Engineering; and secretarial assistance will be
provided by personnel also employed in the Department of Biological and
Agricultural Engineering.
Location:
This research activity will take place at the Reichhold Chemical Company
landfill/land treatment site located in Mecklenburg County, North Carolina.
Every effort will be made to minimize the requirements for travel to the site.
Results:
The results of this project will be provided to Reichhold Chemical
Company, Inc. as they are generated. In addition, the results will be
published in technical journals and other publications with the approval of
Reichhold Chemical. Company, Inc.

Budget:
Personnel
A. Principal Investigator(IOX).•....................k,..,.. $2000
Technician(10).........................♦.,....k.♦...... 1000
. Secretarial (5)......,...................................
II. Monitoring and Laboratory Analysis
A. COD - $10 x 4 samples/year x 3 wells..
500
00
.$ 120
B. Total organic Carbon - $10/sample x 4 samples/yr x 3 wells. 120
C. Chlorides - $7/sample x 4 samples/yr x 3 wells............. 84
D. Sulfates..
B. Nitrates..
Total Kjeldahl Nitrogen♦.
Total. Solids...........,•.........♦ ..................♦.....
Electrical Conductivity..
pH. .
135
. + . . . . . ♦ ♦ . . # • ♦ . . ♦ . • . . . . . • . . . . . . . . k ♦ . ♦ 120
120
. . ♦ . . . ♦ • . ♦ . . k ♦ k . . . . . . . ♦ . . . . . .. 60
60
Selected organics
a. Groundwater($400 per sample x 3 wells x 2 samplesll) 2400
b. Soil ($400 per sample x 3 wells x 2 samples)........... 2400
5,703
III. Travel
1000 mi. x 25C/mile...........4.444444444444040444444.♦.
IV'.. Subsistence
$4 per meal x 20 meals ..................♦...,....,...♦...
V.
Supplies and Equipment.............k.......................♦.
Total Budget.
************
250
80
500
830
0
It is a pleasure to submit this proposal to Reichhold Chemical Company for
their review. The Department of Biological and. Agricultural Engineering at
North Carolina State University looks forward to working with you toward
completion of this project.
4

PRELIMINARY INFORMATION REQUEST
REICHHOLD CHEMICALS, INC.
CHARLOTTE, N. C.
1. Land application site is located off Dorman Road, Pineville, N.C.
(Mecklenburg County).
2. a) Map delineating property boundries - (attached).
b) Residences located within 500 feet of application field -
none.
c) Wells within 100 feet of application - one well on property
which belongs to Reichhold.
d) Size of application field - 2 acres - (attached).
3. Narrative of overall land application procedure - sludge is transported
from plant site at 500O South Boulevard, transported via. Reichhold
dump truck to land application site, dumped on the ground and
approximately 5 times per year a dozer is rented to spread out
the dried sludge.
4. Sludge characteristics - tests performed by Dr. Rubin, N. C. State
University - (attached). Test methods used by Dr. Rubin gives total
metals. EP Toxicity performed by EMS gives extractable metals,
5. EP Toxicity analyses - test performed by EMS Laboratories, Charlotte,
N. C. - (attached).
6. Depth to groundwater - 2 inch well on Reichhold property is 65'6"
deep. Water level is 46'0" from ground level.
7. Descriotion o
eatment facility - (attached)

REICHfOL©
neville,NC
Land
plication
Site

SLUDGE CHARACTERISTICS
TEST. PERFORMED BY DR. RUBIN
RCI
12/85
TKN NH N NO N tP oPO4P Cl TOC
89.5 11.7
.8 38.8
.52 3400 12350
Na Ca Mg Cu Zn Ni
2210 1083 211 59 16.6 8.0 1.3 18.5
Cd
Pb

EMS Laboratories, Inc.
4132 POMPANO DRIVE
CHARLOTTE., NORTH CAROLINA 29216
[phone]
SAMPLE SOURCES
PVA. Sludge
L TO;
Reichhold Chemicals
500 S. Blvd.
Charlotte, N.C. 28220
Att: Mr. David Whitley
REPORT DATE 2/10/M86 DATE RECEIVED
EMS SAMPLE N 504
RO. # SAMPLE TYPE XGRAB COMPOSITE
WASTEWATER DATE SAMPLED 11/18/85
SLUDGE COLLECTED BY T.
OIL
LEACHATE
OTHER
REMARKS PVA Sludge
Leachate
REPORT
NUMBER
No.00549
no not pay from
this copy
EP Tox
city Extraction
PARAMETER
Lindane, EP Tox Extract
% Spike recovery
Endrin, EP Tox Extract
• Spike recovery
Toxaphene, EPTox Extract
% Spike recovery
2,4-D, EPTox Extract
• Spike recovery
Silvex, EP Tox Extract
• Spike recovery
RESULTS Det. Limit DATE ANALYZED
ND
80
0.004
ND 0.002
119
ND 0.005
113
ND 0.01
87
ND
67
0.001
Herbicide Derrivatization Complete NA
Pesticide Extraction, Water Complete NA
1/9/86
1/9/86
1/9/86
1/20/86
1/20/86
1/20/86
1/6/86
ND - analyte not detected at detection limit indicated
NA - Not applicable
All results in
ANALYST
DJO
DJO
DJO
ACB
ACB
ACB
DJO
METHOD OF ANALYSIS
SW846 8080
SW846 8080
SW846 8080
SW846 8080
SW846 8080
SW8468080
SW846 8080
SW846 8080
SW846 8080
SW846 8080
NA
NA
CHARGE
Total $300.00
DATA REVIEWED
REPORT COPY

MS Laboriilories, Inc.
132 POMPANO OHNE
MARIA)] IE.', NORTH CAROLINA 28216
704) 392-6276
AMPLE SOURCES
Reichold Chemical, Inc.
ILL TO:
Reichold Chemical, Inc.
5000 South Blvd. - P.O. Box 11051
Charlotte, NC. 28220
REPORT DAIS 1I/27
EMS SAMPLE 405
P.O. 19976 SAMPLE TYPE X GRAB COMP
#
WASTEWATER DATE SAMPLED 11/18/8
SLUDGE X COLLECTED BY
OIL REMARKS PVA Slud
LEACHATE E P Toxicity
OTHER
. •.
!JAI E (IL.CLIVED .
PARAMETER
Arsenic, As
Barium, Ba
Cadmium, Cd
Chromium, Cr
Lead, Pb
Mercury, Mg
Selenium, Se
Silver, Ag
Note:
DATA PEvIEWFD DY.
ng/L
11
11
SPIKE
RESULTS RECOVERY
<0.01 90%
1.5 95%
<0.01 95%
<0.05 98%
<0.05 93%
<0.001 1007.
<0.005 90%
<0.01 100%
DATE ANALYZED
11/27/85
11/22/85
11/25/85
11/25/85
11/25/85
11/26/85
11/27/85
11/25/85
5
REPORT
NUMBER
V '
• :
e 0 e 1 ,r, No. 0 0 3 7 6
edui-e
, Do nol pay from
- ,',
io Ilits copy
ANALYST
DF
DF
DF
DF
DF
DF
DF
DF
Metal Analysis performed on leachate of EP Toxicity Procedure -
Total
(SW 846 - 1310)
METHOD OF ANALYqS
t ;
206.2
208.2
213.1
218.1
239.1
245.1
270.2
272.1
CHARGE
$459.20
RU'ORT rrp‘r

DESCRIPTION OF PRETREATMENT FACILITY
Reichhold's Charlotte Plant manufactures emulsion polymers for the
adhesive, paper, and latex paint industries. Primary raw materials
are vinyl acetate, methyl methacrylate, and butyl acrylate.
The plant produces about 15,000 gal/day of waste water which is
pretreated by chemical coagulation and filtration. (See attached
drawing)
The chemicals used in pretreating are:
a) Ferric Chloride
b) Sodium Hydroxide and/or lime
c) Anionic and Cationic Polymers
About 5500 lbs. of 20% solids sludge are produced each day in the
pretreatment system. The sludge is loaded into dump trucks and
transported to the land application site off Dorman Road in Pineville,
North Carolina. The sludge has been tested by independent laboratories
and found to be non -hazardous.

.IP,-4Pi/6
N©74:i CHI Nor SCALA 11F14 DAtMrlr7
Uf[ IIINCt ic» s
A 11 r rA M1 i 1 rrinr

Department of Biological and
Agricultural Engineering
Box 7625, Raleigh, NC 27695-7625
Telephone [phone]
ttt,cia 1. rs iltt
2 22O
T. nor visit to dic,hd tnitl
The pur ne ti it lo OW* irs t is
f Mt i Lit t i a is d trlel
� r aii Idiy ser iM g ti
indu4tri l h t at Itele0gg
T .,:r ar oxi t ty 6 sere* tit cl *red ldn d
m to rtd idi h01iai,rates
los inn i'a vy tl s t high level t ;
can be tr t d nth landprovid 4 stiflk.ient n
ae1<xilate th esti u aid :provided su
did to inti 1 a' iu n r i id in
gnttiorr da to urr .itii
The only t its
ascertsirt d ,fl h+t the h d t i i ti
and a more
submit
uc ha,
Cooperative Ex tettsion
North Carolina State Uniuersi
School of Agriculture and Life Sciences
to of end tr u iir i l l n tb;
tinin t ssitliility the
rdt, 1, fit $ ur nt In add it i r
link pet` i i rat i mil ,r In
too
urr
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t coil ctit:ut
yOur t o 1prp.Ma't;.'init
t tit
r� star ure c tt i a e srs rrxis A& State Universit sR 1`t unties A

ReiChhold Chemicals, Inc.
ErnoionParyrr,o-Dro',Aw
5000 South
P'0 E3o 1, 05
Charlotte, Norin Carolina 28220
April 12, 1986
Ahvisa„ -
Mr. J. Thurman Horne, P.E.
Environmental Engineer II
Div. of Environmental Management
Mooresville Regional Office
N.C. Department of Natural Resources
and Community Development
919 North Main Street
Mooresville, N. C. 28115
Dear Mr. Horne:
hi000 ESWILt(
Aidiv
RE CHI -FOLD
As requested, we are pleased to submit for your consideration the enclosed
Non -Discharge Permit Application for our Land Application Site located
off Dorman Road near Pineville, N. C. Also enclosed is Reichhold's
response to your Preliminary Information Request of November 13, 1985
and a letter and proposal from Dr. A. R. Rubin of the Agricultural
Extension Service, North Carolina State University for an evaluation
of conditions of the site.
We plan to sign a letter of understanding with N.C. State University
to initiate the studies described in the proposal. We have contacted
local well drilling contractors regarding installation of the necessary
groundwater monitoring wells, and would like to meet with you, Dr.Rubin
and Mr. Jesse Wells at an early date to discuss plans for the site
and finalize details of the evaluation program. We will contact you
at an early date to set-up a time for the meeting.
We appreciate your continued interest in this matter and trust you
will contact us if you have any further questions.
Very truly yours,
D. E. Whitley
Plant Manager
DEW:bs
Enclosures
cc: D. E. Frey - RCI Silver Lake
M. Kowalski - RCI White Plains
Tel [phone]
[phone]
Twx 8106210559

;
North Carolina Department of Natural Resources and Community lopment
Environmental Management Commission
NON -DISCHARGE PERMIT APPLICATION'
in accordance with N.C. General SatChapter 143 Article 2
/icon? (name of board, individual, or others ;
REICHHOLD CHEMICALS,INC.
t am• of city, tIo iwn, I8fli1ry district, tistablishmentl:
PINEVILLE LAND TREATMENT FACILITY
DE
Parrnit
Cauntvi4ECKLENBURG
Application Dote:
April
986
OR:
fa Non -Discharge Treatment/Disposal Facilities
13 Pretreatment Facilities
Sewer Collection System (private)
Extend Sewer and Sewer Systems (public)
NATURE OF WASTEWATER:
IDSewage
Sludge/Industrial Waste
Other W*set
From (sewers, pretreatment facilities, treatment
Pretreatment Facility
I nto
Brief Project Description:
Land Application of Non -Hazardous.
Waste WattVEnsiorment Sludge.
COVISK*4 Eli .o.!' 4^ ;P,
APR lit 19E6
Serving (city,
IReichho
duatry),
d Chemicals Inc.,Charlot e,NC
5000 .I31vd.
N/A
cation of treatment plant
N/A
0 A Engineering FIrrnu Zip Code:
Dr. A.R. Rubin, N.C.State University,
Tributary To
1
(w.. of water course):
N/A
Telephone No, 4
x 7625 Ra igh NC27695-7625,737-2675
Treatment Works Capacity to cf):
REICHHOLD CHEMICALS,INC.
0
n P
B, O. D. (5-1:lay 2ff C)
Suspended Solids
TOTAL SOLIDS
Coliform Bacteria
its
For (no. yrs. veto ally al
Izefinit
100
O 0 O W41S flOWt
'we, ptojec
E
Cits
N/A
N/A
NA
N/A
Toxic Mster
None
specify
odd *
Sewers
Pumping
Station
Treatment
Plant
N/A
TOTAL TOXIC MATERIALS
Applicant assures t at proposed wor ted, supervised, operated and maintained in actor
specifications or approved changes thereto.
her
EstLmet.d Completion Da
EXISTING
e with approved plans and
Print Narn•i Tit t
D. E. Whitle
atm,*
ST RUT1DNSi
Filt-.n ALL sp.:mgrs. If not applicablsi, •ntsir N/A.
Secure appropriate signature (mayor/city manager for municipality; chairman for sanitary district board
or I•gally constituted board er commission in charg• of proposed works). A Isitt4r of authorization is
design •ngiritttor or other agent signs application.
3. Submit to N.C. Deportment of Natural RIWILCOUNCOS and Community D•vitlopm•nt, Erivironmentel
original and first copy of application, 2 sets of finalised plan*. specifications and other sup -porting data as require
Plant Manager
Hailing Address t Zip Code
P.O.Box 11051,Charlotte,NC 28220
Telephone Nch
704-525-6420
NOTE Application reVie.,11 are scheduled on receipt of COMPLETE information. Generally, 30 days are required for
for other prefects
For Assistance, call the State. Central Office 919/733-5083, P.O. Box
'Asheville (700 253.3341
159 Witacifin Street
Asheville, NC 210101
•Foyeettevilie [phone]
Suite 711 Wochovia Building
Fayetteville, NC 28301
•Moorststrille [phone] "Washington (9)9) 916441
919 North Main Street 1502 North Market Street
Mooresville, NC 28115 Washington, NC 27889
*Roleigh (919 733-2314
Box 27647
lightish, NC 27611
own•r/prop•r official of corporation,
required from proper official if
Nanaartment, Raleigh, NC, th•
d by Commission Rulers.
pollution abatement wouocts; % days
27687, Raleigh, N.C. or:
*Winston.Salem (9)9) 761-2351
$003 Silas Creek Parkway E *tor -osier%
Winston-Salem, NC 27106
*Wilmington (919) 2564161
7225 wrialosvi lie Avenue
Wilmington, NC 2$1103

PRELIMINARY INFORMATION REQUEST
REICHHOLD CHEMICALS, INC.
CHARLOTTE, N. C.
1. Land application site is located off Dorman Road, Pineville,
(Mecklenburg County).
2. a) Map delineating property boundries - (attached).
b) Residences located within 500 feet of application field -
none.
c) Wells within 100 feet of application - one well on property
which belongs to Reichhold.
d) Size of application field - 2 acres - (attached).
Narrative of overall land application procedure - sludge is transported
from plant site at 5000 South Boulevard, transported via Reichhold
dump truck to land application site, dumped on the ground and
approximately 5 times per year a dozer is rented to spread out
the dried sludge.
4. Sludge characteristics - tests performed by Dr. Rubin, N. C. State
University - (attached). Test methods used by Dr. Rubin gives total
metals. EPToxicity performed by EMS gives extractable metals.
5. EP Toxicity analyses - test performed by EMS Laboratories, Charlotte,
N. C. - (attached).
6. P,pji.9roundwater - 2 inch well on Reichhold property is 65'6"
deep, Water level is 46'0" from ground level.
7. Description of pretreatmentfacility - (attached)

REICHHOLT
Pineville,,
Land
Appiicatior
Site

SLUDGE CHARACTERISTICS
TEST PERFORMED BY DR.. RUBIN
RCI
11/12/85
TKN NH3N NO3N P °PO4P Cl TOC
89.5 11.7 .8 38.8 .52 3400 12350
N
2210
Ca
CuLta Zn Ni
211 59 16.€ 8.0 1.3 18.5
Cd
Pb

EM$ Laboratories, Inc.
132 POMPANO DRIVE
HARLOTTE. NORTH CAROLINA 28216
704) 392-6276
AMPLE SOURCES
Reichold Chemical, Inc.
ML TO:
Reichold Chemical Inc.
5000 South Blvd. - P.O. Box 11051
Charlotte, NC. 28220
PARAMETER
Arsenic, As
Barium, Ba
Cadmium, Cd
Chromium, Cr
Lead, Pb
Mercury, Hg
Selenium, Se
Silver, Ag
Note:
mg/L
PI
11
11
REPORT DATE 11/27
EMS SAMPLE II_
RO. N
WAS
SLUDGE
OIL
LEACHATE
OTHER
SPIKE
RESULTS RECOVERY
<0.01 90%
1.5 95%
<0.01 95%
<0.05 98%
<0.05 937
<0.001 100%
<0.005 90%
<0.01 100%
19976
05
DATE RECEIVED
DATE ANALYZED
11/27/85
11/22/85
11/25/85
11/25/85
11/25/85
11/26/85
11/27/85
11/25/85
SAMPLE TYPE X GRAB
DATE SAMPLED
COLLECTED BY
REMARKS PVA Slud
E P Toxicity Extra
ANA LYST
DF
DF
DF
DF
DF
DF
DF
DF
Metal Analysis performed on leachate of EP Toxicity Procedur eT"otal
(SW 846 - 1310)
COMP�SIT
REPOR
NUMBER
No. 0 0 3 7
rocedute
.1 no not pay fror
this copy
METHOD OF ANALYSIS
/
206.2
208.2
213.1
218.1
239.1
245.1
270.2
272.1
CHARGE
$4,59.20
ITA REVIEWED BY
WO.

EMUS Laboratories, Inc.
4132 POMPANO DRIVE
CHARLOTTE, NORTH CAROLINA 28216
('704) 392-6276
SAMPLE SOURCES
PVA Sludge
BILL TO:
Reichhold Chemicals
500 S. Blvd.
Charlotte, N.C. 28220
Att: Mr. David Whitley
PARAMETER
indane, EP Tox Extract
X Spike recovery
Endrin, EP Tox Extract
% Spike recovery
Toxaphene, EPTox Ex
% Spike recovery
2,4-D, EPTox Extract
% Spike recovery
act
Silvex, EP Tox Extract
% Spike recovery
REPORT DATE 2/10/86
EMS SAMPLE #
Pta #
WASTEWATER
SLUDGE
OIL
LEACHATE
OTHER
504
RESULTS Det. Limit DATE ANALYZED
ND 0.004 1/9/86
80
ND
119
ND
113
ND
87
ND
67
0.002
0.005
0.01.
0.001
Herbicide Derrivatization Complete NA
Pesticide Extraction, Water Complete NA
1/9/86
1/9/86
1/20/86
1/20/86
1/20/86
1/6/86
ND - analyte not detected at detection limit indicated
NA - Not applicable
All results in mg/L
DATE RECEIVED.
2/17/86
SAMPLE TYPE X GRAB COMPOSITE
DATE SAMPLED 11/18/85
COLLECTED BY
REMARKS PVA Sludge Leachate
EP Toxicity Extraction
ANALYST
DJO
DJO
DJ©
ACB
ACB
ACB
DJO
REPORT
NUMBER
No. 0054
0o not pay from
this copy
METHOD OF ANALYSIS
SW846 8080
SW846 8080
SW846 8080
SW846 8080
SW846 8080
SW8468080
SW846 8080
SW846 8080
SW846 8080
SW846 8080
NA
NA
Total
CHARGE
$3©0.00
DATA REVIEWED BY
REPORT COPY

DESCRIPTION OF PRETREATMENT FACXLITY
Reichhold's Charlotte Plant manufactures emulsion polymers for the
adhesive, paper, and latex paint industries. Primary raw materials
are vinyl acetate, methyl methacrylate, and butyl acrylate.
The plant produces about 15,000 gal/day of waste water which is
pretreated by chemical coagulation and filtration. (See attached
drawing)
The chemicals used in pretreating are:
a) Ferric Chloride
b) Sodium Hydroxide and/or lime
c) Anionic. and. Cationic Polymers
About 5500 lbs. of 20% solids sludge are produced each day in the
pretreatment system. The sludge is loaded into dump trucks and
transported to the land application site off Dorman Road in Pineville,
North Carolina. The sludge has been tested by independent laboratories
and found to be non -hazardous.

♦ nr©Rir rrrr

AGRICULTURAL
EXTENSION
SERVICE
Department of Biological and
Agricultural Engineering
Box 7625, Raleigh, NC 27695-7625
Telephone [phone]
Mr. David Whitley
Reichhold Chemical Company, Inc.
P. 0. Box 11051
Charlotte, NC 28220
Dear Mr. Whitley:
North Carolina State University
School of Agriculture and Life Sciences
It is a pleasure to submit the attached research proposal to you. The
research results gained from this project will be beneficial to Reichhold
Chemical Company, Inc., the Agricultural Engineering Department at North
Carolina State University and the State Division of Environmental
Management/Water Quality Section.
If you have concerns or comments concerning the attached proposal, please
do not hesitate to contact me at the letterhead address. I look forward to
working with you toward completion of this project and toward initiation of
subsequent projects.
ARR:wm
Enclosure
Sincerely,
(de
A. R. Rubin, Extension Specialist and
Assistant Professor
Biological and Agricultural Engineering
Cooperative Extension Work in Agriculture and Horne Economics A&T and NC. State Universities,100 Counties and U.0 S. Department of Agriculture

PROPOSAL
to
REICHHOLD CHEMICAL, INC.
Charlotte, North Carolina
Purpose:
The purpose of this project is to determine whether the land treatment
facility operated by Reichhold Chemical Company, Inc. near Charlotte, North
Carolina, has influenced soil or groundwater quality at the 22-acre site in
south Mecklenburg County.
Objectives:
A. To determine the areal extent of the landfill operation and
examine the records prepared by Reichhold Chemical Company to
determine the volume of material applied to the site.
B, To install groundwater quality monitoring wells and to examine
the shallow groundwater quality up gradient from the land treatment/
landfill facility and down gradient.
C. To determine the physical and chemical properties of untreated soil
from the site.
D. To examine soils on the iandfill/land treatment site for the
identical physical and chemical properties investigated above.
Background:
Reichhold Chemical Company, Inc.. operates a wastewater pretreatment
facility at Charlotte, North Carolina. The purpose of the pretreatment
facility is to provide the necessary industrial wastewater pretreatment for
discharge to the Charlotte municipal utility district. In accomplishing the
necessary industrial pretreatment, the solids (sludges) generated must be
removed fro u the facility to ensure its proper operation. This process is
called sludge wasting. The wasted sludges must be handled in a manner approved
by the State Division of Environmental Management. A method deemed by the
Division of Environmental Management is land treatment. Since the land
treatment facility has been in operation for some unknown period of time and no
accurate records are available, there must be some determination of the effects
of the current operation on the soil, site, and underlying groundwater...
The purpose of this project is twofold. The first is to determine the
effects of the operation upon the site and the second to make recommendations
regarding continued use of the receiver site to serve Reichhold Chemical
Company, Inc. as a receiver for the industrial sludges generated at their
Charlotte facility.

Procedure:
This project must be accomplished in several phases. The first phase will
consist of examination of Reichhold Chemical Company, Inc. records from their
Charlotte facility. This examination will be used to determine a best estimate
of the volume of material applied to the site. A thorough chemical analysis of
the waste generated at Reichhold Chemical Company must be performed to
determine the standard extraction procedure toxicity, micro and macro nutrient
values, and the levels of chloride, sulfate, sodium, potassium, and other
constituents that may be critical in the design and operation of a land
treatment facility. This characterization of the sludge and estimate of the
sludge volume applied is essential if the site is to be used further. Many of
the constituents in the waste stream have cumulative loading limits, and it is
imperative to determine both estimates of volume applied and chemical
characteristics to determine the useful life remaining in the site.
Groundwater monitoring is also essential. In order to assess the quality
of the underlying, shallow water table, monitoring wells should be advanced to
the first or unconfined aquifer. Generally, this unconfined aquifer is
encountered within 25 to 33 feet of the soil surface. The shallow groundwater
monitoring wells must be placed on the site to assess the quality of the
underlying water.. Type II groundwater monitoring wells are recommended for
most land treatment facilities by the State of North. Carolina. For this reason
the groundwater monitoring wells proposed for this site should be constructed
to state standards as Type II groundwater monitoring wells. These wells will
be required if the facility remains in operation as a land treatment system.
Once installed, samples of the shallow groundwater must be collected for
analysis. A minimum of three groundwater monitoring wells should be placed on
the site. One groundwater monitoring well should be placed up gradient from
the land treatment,/landfill operation and two should be placed down gradient.
Groundwater monitoring wells must be installed by a reputable well drilling
contractor. Boring logs must be maintained on each of the groundwater
monitoring wells.
Groundwater samples must be collected from each well. These well samples
should be collected once the well is stabilized. The groundwater samples
should be collected by a representative from the Biological and Engineering
Department at North Carolina State University and transported immediately to
the waste management laboratory at the University. Samples must be preserved
properly and cooled prior to transportation. Analysis shall be as determined
by the State Division of Environmental Management but should include at minimum
the following constituents:
- Chemical Oxygen Demand
- Total Organic Carbon
- Chlorides
- Sulfates
- Nitrates
- Total Kjeidahl Nitrogen (TN)
- Total Solids
- Electrical Conductivity
- pH
- Selected organics as determined from the
sludge analysis

Subsequent sampling may include analysis for additional organics which are
found present in the sludge— Monitoring shall be accomplished initially at the
time of installation of the groundwater monitoring wells and subsequently for
one year following their installation on a quarterly basis.
Soil and site sampling will include collection of shallow soil core
samples from both treated and untreated sites. Soil cores will be analyzed for
selected organic constituents as determined from the sludge analysis. In
addition, fertility status, pH, nutrient status and sodium index values will be
determined for both the background or benchmark soils as well as from treated
cells in the waste treatment area. The initial analysis will be used to
determine or assess the effects of previous practices as well as to make
recommendations regarding continued use of the site. Soil samples will be
collected by representatives of the Department of Biological and Agricultural
Engineering and analysis shall be performed in the Biological and Agricultural
Engineering Department laboratory at North Carolina State University as well as
the North Carolina Department of Agriculture Soil/Agronomy Lab. Soil sampling
and analysis should be accomplished as an initial effort, and subsequent
sampling will be accomplished from the experimental or treatment cells on a
quarterly basis once the project begins.
Data Analysis:
The data collected in this project will be analyzed using appropriate
statistical techniques. The analysis will be presented to Reichhold Chemical
Company, Inc. for their review prior to release to the State Division of
Environmental Management.
Investigator:
The principal investigation for this project is Dr. A. R. Rubin, Extension
Specialist and Assistant Professor, Biological and Agricultural Engineering
Department at North Carolina State University. Other personnel will be a
research technician currently employed in the Department of Biological and
Agricultural Engineering, laboratory personnel employed in the Department of
Biological and Agricultural Engineering; and secretarial assistance will be
provided by personnel also employed in the Department of Biological and
Agricultural Engineering.
Location:
This research activity will take place at the Reichhold Chemical Company
landfill/land treatment site located in Mecklenburg County, North Carolina.
Every effort will be made to minimize the requirements for travel to the site.
Results:
The results of this project will be provided to Reichhold Chemical
Company, Inc. as they are generated. In addition, the results will be
published in technical journals and other publications with the approval of
Reichhold Chemical Company, Inc.

Budget:
I. Personnel
A. Principal Investigator
B. Technician
C. Secretarial (52)• • .• • • • • • • • • • • • • • • • • • • •• ••• • • • • • ••• • •• • • •
II. Monitoring and Laboratory Analysis
A.
$2000
1000
500
3500
COD - $10 x 4 samples/year x 3 120
B. Total Organic Carbon - $10/sample x 4 samples/yr x 3 veils. 120
C. Chlorides - $7/sample x 4 samples/yr x 3 84
De S135
E.
Nitrates •* • • •••••• • • ••• •• • 4 • • • • • •••••••••••••••• rt.* •••••••* 120
F. Total Kjeldahl 120
G. Total 84
11.
1.
Electrical Conductivity....................................
01****".*********"...4.404.***.****W4**.****00*********
60
60
J. Selected Organics
a. Groundwater($400 per sample x 3 wells x 2 samples/well) 2400
b. Soil ($400 per sample x 3 wells x 2 2400
5,703
III. Travel
1000 mi. x 25c/mile.•4 •••••0* • • • • • 80.•••••••••••••••
IV. Subsistence
$4 per
ea1 x 20 meals.• • . • • • • • • • • • • • • • • • • • • • • • • • • • • • •
250
80
V. Supplies and Equipment.-- **41.011******.**C0.4*.**** *******..** 500
830
Total Budget* • • • 0. • • • • • • • • • • • • • • • • • • • • • • • • • W)%033
************
It is a pleasure to submit this proposal to Reichhold Chemical Company for
their review. The Department of Biological and Agricultural Engineering at
North Carolina State University looks forward to working with you toward
completion of this project.
4

State of North Carolina
Department of Natural Resources and Community Development
Mooresville Regional Office
James G..Martin, Governor Albert F. Hilton, Re Tonal Manager
S, Thomas Rhodes, Secretary
DIVISION OF ENVIRONMENTAL MANAGEMENT
September 26, 1986
Mr. D. E. Whitley, Plant Manager
Reichhold Chemicals, Inc,
P. O. Box 11051
Charlotte, N. C. 28220
Subject: Reichhold Chemicals, Inc.
Land Application -pretreatment sludge
APN 007523
Mecklenburg County
Dear Mr. Whitley:.
This Office is in receipt of your Permit Application for land application
of pretreatment sludge on a site in southern Mecklenburg County.
Prior to our review, it is requested that the enclosed Waste Determination.
form be completed and forwarded to the address listed at the bottom of the
second page. A copy of thisform should also be forwarded to this Office
to the attention of Mr. Michael L. Parker. Once this form has been received,
you will be contacted regarding a site visit by Mr. Parker. This
information is needed before review of this application can begin.
If you have any questions regarding this matter, please contact Mr.
Michael L. Parker or me at [phone] in Mooresville.,
cc; Gil Vinzani
MLP:pb
Sincerely,
e
D. Rex Gleason, P. E.
Water Quality Regional Engineer
919 North Main Street, PO, Box 950, Mcxresville, NC. 28115-0950 • Telephone [phone]
An Equal Opportunity Af irmative Action Employer

State of North Carolina
Depart, ent of Natural Resources and Community Development
Mooresville Regional Office
James G. Martin, Governor
S. Thomas Rhodes, Secretary
Mr. D. E.
Reichhold
P. O. Box
Charlotte
Whitley, Plant Manager
Chemicals, Inc.
11051
, N. C. 28220
Dear Mr. Whitley:
Albert F. Hilton, Regional Manager
DIVISION OF ENVIRONMENTAL MANAGEMENT
November 4, 1986
Subject: Proposed Sludge Land Application Site
APN No. 007523
Reichhold Chemicals, Inc.
Mecklenburg County, N. C.
This Office is currently reviewing the application and supporting material
submitted by Reichhold Chemicals inorder to process your non -discharge permit
request. Further review of this project is being conducted by our Raleigh
Central Office and the North Carolina Department of Human Resources, Solid
and Hazardous Waste Branch.
It is our understanding that the site has already been utilized on several
occasions for sludge disposal. From recent site visits by Mooresville Regional
Office personnel, it has been determined that four (4) groundwater monitoring
wells (one upgradient, three downgradient) have been drilled at the site. These
wells were recommended by Mooresville Regional Office groundwater personnel.
Because of past sludge disposal at this site and the uncertainty of possible
groundwater contamination, which may already exist, the implementation of a
groundwater monitoring program is necessary. Such a program will enable this
Office to determine if possible contamination exist, which would reflect on
our decision to recommend approval or denial of the site. Groundwater clean-up
and/or removal may_also be required depending on sampling results. Until this
monitoring data is received, we must withhold further processing of your application.
The recommended sampling parameters along with a sampling schedule as recommended by
the Mooresville Regional. Office Groundwater Staff is attached to this letter.
Any questions concerning the proper procedures concerning groundwater monitoring or
well sampling should be directed to Mr. Jesse Wells at this Office.
It is recommended that two (2) separate samplingsbe made at least
sixty (60) days apart. Once the results from these two samplings have been
919 North Main Street, PO. Box 950, Mooresville, N.C. 28115-0950 • Telephone [phone]
An Equal Opportunity Affirmative Action Employer

Mr. D. E. Whitley
November 4, 1986
Page Two
received they should be forwarded to this Office, to the attention of Mr.
Michael L. Parker.
If you have any questions concerning this matter, please co
Mr.. Rex Gleason or Mr. Michael L. Parker at 704) 663-1699 in Mo
Sincerely,
Ronald L. McMillan
Regional Supervisor
cc:
Gil Vinzani
Jesse Wells
Bob Cheek
MLP:pb
tact
resville.

RECOMMENDED GROUNDWATER SAMPLING
PROGRAM FOR REICHHOLD CHEMICALS
PARAMETERS
1. COD
2. TOC
Chloride
4. pH
5. Specific Conductance
6. Organics
7. Sulfates
8. Nitrates
9. Total Kjeldahl Nitrogen (TKN)
10. Total Solids
11. Water Level
12. Metals (specifically Ar, Ba, Cd, Cr, Pb, Hg, Se and Al)
A sample should also be obtained from the existing 2" well on -site and
analyzed for the parameters listed above to determine if contamination exist
in the confined zone.

State of North Carolina
Department of Natural Resources and Community Development
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Govor
S. Thomas Rhodes, Secretary
Mr.. D. E. Whitley, Plan
Rei.chhoid Chemical
P.O. Box 11051
C;h+rlottc, N.C. 28220
Dear Mr, Whi.t.l_ey:
Inc.
1.987
SUBJECT: Project. Return APN00752.3
Retchhoid Chemicals, Inc.
Land Appi:[cation of Sludge
Mecklenburg County
Reference is made t:o your application received April 14, 1986, for a
Non -Discharge Permit to land .apply wastewater sludge..
R. Paul Wilms
Director
l:ar a letter dated November 4, .986 you were asked to provide specific
technical. late by the Mooresville Regional. Office. In accordance with North Car -cal.
General Statute 143.215.1, the Division may return your application. package as
incomplete if requested. information is not received. within 60 days, in accordance
with this regulation we must hereby return your application.
Vinzax
When Re.ichhold Chem a. has obtained the required information, the
appl:icraton. and plan documents can be resubmitted for review action,
ff there are ny questions concerning this matter, please contact Mr. Gil
rat 919/733-5083, or Mr. Mike Parker at 704/663-1699.
Sincerely your:
Original Signed By
Arthur Mouberry
1 Wilms
cc: Mooresville Regional Supervisor
Mr, Dennis R. Ramsey
Groundwater Section
Pollution Pretreation Pays
P.O., lox 27687, Raleigh, North Carolina 7611-7687 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

Reichhold Chemscalis, Inc.
5000 South Boureva.rr
P.O. Box 11051
Charlotte, North Car
RE
November 4
State of North Carolina
Department of Human Resources
Division of Health Services
Solid & Hazardous Waste Management Branch
P. C. Box 2091
Raleigh, N. C. 27602
Attention: Waste Determination
Subject: Reichhold Chemicals, Inc.
Land Application -Pretreatment. Sludge.
APN 007523
Mecklenburg County
Ladies or Gentlemen:
Your Mr. D. Rex Gleason requested we complete a Waste Determination
Form and send the original to your attention with a copy to Mr.
Michael L. Parker at the Mooresville office. This form is attached
with a copy going to Mr. Parker.
If you have any further questions, please advise.
Very truly yours,
D. E. Whitley
Plant Manager
DEW:bs
Enclosure
cc: Mr. Michael L. Parker w/a
State of North Carolina
Department of Natural Resources & Community Development
P. O. Box 950
Mooresville, N. C. 28115-0950
Mr. D. Rex Gleason - Mooresville, N. C.
36:.364

December 1985
r. Thurman Thorne, ..
Environmental Engineer II
Division Environmental Management
North Carolina Department of Natural
Resources & Community Development
919 North Main Street
Mooresville, N. C. 28115
Tear Mr Horne:
Enclosed is s dopy oft o EP Toxicityreport from EMS Laboratories,
Charlottecover in a sample of PVAc Sludge.Sample was taken
on November 18, 1985 and was delivered to EMS on November 1 1985.
maybe we can discuss this in more detail when you visit with u
on December ea ber 17 In the meantime it yau have questions, please
advise.
Very tr
Ye
D Whitley
plant Manager
N:b
Enclosure
1

EMS Laboratories, Inc.
4132 POMPANO DROVE,
CHARLOTTE, NORTH CAR(M INA 28216
[phone]
SAMPLE SOURCES
Reichold Chemical, Inc.
BILL TO;
Reichold Chemical, Inc.
5000 South Blvd. - P.O. Box 11051
Charlotte, NC 28220
PARAMETER
Arsenic, As
Barium, Ba
Cadmium, Cd
Chromium, Cr
Lead, Pb
Mercury, Hg
Selenium, Se
Silver, Ag
Note:
DATA REVIEWED w'EY
mg/L
REPORT DATE.,.,
1
EMS SAMPLE 4 4
P.O. n...... 19.9.76
WASTEWATER _____
SLUDGE e
i71L.
LEACHATE
OTHER
SPIKE
RESULTS RECOVERY
<0.01 90%0
1.5 95"r
<0.01 95%
<0.05 98©/
<0.05 937
<0.001 100%
<0.005 90%
<0.01 100%
2
DATE ANALYZED
11/27/85
11/22/85
11/25/85
11/25/85
11/25/85
11/26/85
11/27/85
11/25/85
DATE RECEIVED_,._.
2
SAMPLE TYPE m X.._.GRAB ...,_,_COM'P©SITE
DATE SAMPLED 11/18
COLLECTED BY
REMARKS PVA Stud
E PToxt icity Extrvac
ANALYST
DF
DF
DF
DF
DF
DF
DF
DF
Metal Analysis performed on leachate of EP Toxicity Procedure —
Total.
SW 846 - 1310)
Procec
METHOD OF ANALYSIS
206.2
208.2
213.1
218.1
239.1
24.5.1
270.2
272.1
REPOR
NUMBER
No.00376
8o not pay from
this copy
CHARGE

November 1985
r. J. Iran Horner P-E-
North Carolina Department of natural
Resources, and Community Develo ment
919 North Main Street
Mooresville, N. C. 28115
Dear Mr.Horne:
This wi confirm the discussion we had during our meeting which
was held in Charlotte on September 24, 1 5-
t
our intent to continue operating our landfill eite,,locate
Dorman load, Pineville, sort arolina.` —W ll apply for a
permit upon receipt ef furtherinstructions from you.
Thank you for your interest and assistance in this matter.
Very
i . Whitley
Plant Manager
DEW:bs
HES,

PRELIMINARY INFORMATION REQUEST
REICHOLD CHEMICAL CO.
November 12, 1985
1. Map delineating property boundaries, any residences located within 500 feet
of application area, any wells within 100 feet of application field, land
application field (indicate size, in acres, of application field).
2. Volume of sludge disposed each day and a general narrative of hauling
procedures.
3. Narrative of overall land application procedures.
4. Sludge characteristics:
Parameter
a. Solids, %
b. Lead, ppm
c. Cadmium, ppm
d. Nickel, ppm
e. Copper, ppm
f. Zinc, ppm
g. PO4 as P, ppm
h. TKN, ppm
i. NH3 as N, ppm
j. NO2 + NO3, ppm
k. Chromium,, Total,
1. Ph, S.U.
5. EP Toxicity analysis
5. Depth to groundwater
ppm

CI